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HomeMy WebLinkAboutNC0000272_Complete File - Historical_20001228BLUE RIDGE PAPER PRODUCTS INC. December 28, 2000 Mr. Forrest Westall Regional Water Quality Supervisor North Carolina Department of Environment and Natural Resources 59 Woodfin-Place Asheville, NC 28801 RE: NPDES Permit No. NC0000272, Blue Ridge Paper Products, Inc. Canton Mill January 1, 2001 Color Limit Feasibility Report Dear Mr. Westall: Attached is the January 1, 2001 Color Limit Feasibility Report required by Part III, Section E 12 of the Canton Mill's NPDES permit. This report is also required by the Settlement Agreement, paragraph 24, and the Revised Color Variance, paragraph 5H. Blue Ridge Paper Products is submitting this report to you in your capacity as Regional Water Quality Supervisor for the Division of Water Quality and as a member of the Technology Review Workgroup. Blue Ridge Paper Products would appreciate you distributing the enclosed copies to the members of the Technology Review Workgroup. Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of 48,000 — 52,000 pounds per day is feasible. Due to the limited data set available, Blue Ridge Paper Products believes it is appropriate to use a 99 ° percentile confidence interval to extrapolate long term and continuing monthly and annual average effluent limitations. Based on this statistical review of the available data from January 1998 - October 31, 2000 the Canton Mill recommends an annual average color limit of 49,612 lbs/day and an average monthly color limit of 59,796 lbs/day. For the June 1, 2001 report, (required by Part III, Section E, paragraph 14, of the Canton Mill's NPDES Permit), Blue Ridge Paper Products recommends using a 95`h percentile confidence interval to statistically evaluate the monthly and annual average color discharge. Using a 95a' percentile statistical review of the limited data available from January 1998 — October 31, 2000 the annual average color is 48,388 Ibs/day and the monthly average color is 55,556 lbs/day. Blue Ridge Paper Products believes the 95 s percentile confidence interval will be appropriate with the additional color data that will be available for the June 1, 2001 analysis. The attached Table includes the summary of the 99 s and 95 h percentile statistical data. Please call me at (828) 646-2033 or Derric Brown at (828) 646-2318 if you have any questions regarding this report. Sincerely, l`��Oinrte�r�d_. Bob Williams Director - Environmental, Health and Safety Attachments 175 Main Street • P.O. Box 4000 Canton, North Carolina 28716 • Phone: 828-646-2000 Raising Your Expectations BLUE RIDGE PAYER PRODUCTS INC. Copy: Keith Haynes North Carolina Department of Environment Health and Natural Resources 59 Woodfin Place Asheville, NC 28801 Technology Review Workgroup (via Division of Water Quality) January 1, 2001— Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina I. Introduction The following report details the Canton Mill's ability to achieve a target annual average color limit in the 48,000 — 52,000 lb/day range in accordance with the requirements of the 1997 modified Color Variance and NPDES Permit. Part III, Paragraph E 12 of the 1997 Permit provides in part, as follows: "...The permittee shall submit to the Division of Water Quality and the Technology Review Workgroup by January 1, 2001, a report on the feasibility of achieving a target annual average color loading limit within the range of 48,000 — 52,000 Ibs/day based on full implementation of the Near -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. 500000 c>s 400000 N .a G O 300000 ;s] 100000 N Aug-85 January 1, 2001 - Color Limit Feasibility Report Monthly Average Secondary Effluent Color (Ibs/day) January 1987 - October 2000 Apr-88 Jan-91 Oct-93 --o— SE Color Ibs/day Jul-96 Apr-99 Blue Ridge Paper Products, Inc. Figure 1 Canton Mill page 2 January 1, 2001— Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina H. Color Performance The Canton Mill has achieved a color reduction of over 85% since 1988 in the annual average amount of color discharged, as illustrated in Figure 1. The improved color performance is due to the Canton Modernization Project, full implementation of the "Near -Term Package" and continuous color management by the mill. The Near -Term Package includes the installation of BFRTm on the mill's pine fiberline, implementation of best management practices (BMPs) detailed in the June 1, 1998 Color Technology Report, and partial BFR (Eo filtrate recycle) on the hardwood fiberline. These collective efforts have contributed to the mill's continuous and significant reduction in effluent color. The 1998 average annual color discharged was 50,386 lbs/day and the 1999 average annual color discharged was 41,048 lbs/day. The 2000 average annual color (through October) is 44,837 lbs/day. All of these values are within or below the target annual average color range of 48,000 — 52,000 lbs/day specified in Part III, Paragraph E 12 of the 1997 Permit. The 48,000 - 52,000 target range was selected because it was projected to result in significant mitigation in the occurrence and degree of color at the Hepco gage. Based upon North Carolina's minimum flow criterion (30Q2), historical flow records, and the January 1998 — October 2000 annual average color value of 45,458 lbs/day, it is expected that color in the Pigeon River at the Hepco gage will be less than 50 scu's (standard color units) 100% of the time at all flows above 30Q2. At all monthly average flows greater than the 30Q2 since January 1999, average monthly color at Hepco has been less than 50 scu's. Therefore, Blue Ridge Paper Product's actual color performance has resulted in significant mitigation in the occurrence and degree of color at the Hepco gage as projected by the 1997 Permit and Settlement Agreement. January 1, 2001— Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina III. Recommended Color Limits The January 1998 — October 2000 actual average annual color of 45,458 Ibs/day and the January 2000 — October 2000 actual average annual color of 44,837 lbs/day are both below the target annual average color range of 48,000 — 52,000 Ibs/day specified in Part III, Paragraph E 12 of the 1997 Permit. It was anticipated, and has now been demonstrated, that full implementation of the Near -Term package would achieve an annual average color within the 48,000 — 52,000 Ibs/day range. 3.1 Review of Color Performance Data Based on a statistical evaluation of the mill's annual color, Blue Ridge Paper Products believes an annual average effluent color limit in the 48,000 — 52,000 lb/day range is achievable. Due to the limited data set available, it is appropriate to use a 99% confidence interval to extrapolate long term and continuing monthly and annual average effluent limitations. The January 1998 — October 2000 annual color average using a 99`h percentile distribution is 49,612 Ibs/day. The January 2000 — October 2000 annual color average using a 99`h percentile distribution is 48,911 Ibs/day. These values are both within the 48,000 — 52,000 lb/day range. Based on a statistical review of the data and the limited data set available, Blue Ridge Paper Products, Inc. recommends an annual average effluent limit of 49,612 lbs/day. The January 1998 — October 2000 monthly color average using a 990, percentile distribution is 59,796 lbs/day. The January 2000 — October 2000 monthly color average using a 99`h percentile distribution is 58,953 lbs/day. Based on a statistical review of the data and the limited data set available, Blue Ridge Paper Products recommends a monthly average effluent limit of 59,796 lbs/day. 11 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. TABLE January 1, 2001 Color Limit Feasibility Report Monthly Average Data - Max Month Calc Data Set = KS Normality test Autocorrelation= no. of obs. _ xbar stddev 95th safe MONTH from normal dist 99th safe MONTH from normal dist 95th safe YEAR from normal dist 99th safe YEAR from normal dist Ranked observations 95th percentile for max MONTH 100th percentile for max MONTH 1 /1198-10/31 /2000 1 /112000-10/3112000 normal normal 0.61 34 10 45478.5 44836 6145 6059 66556 54773 59796 58953 48388 47704 49612 48911 56809 55514 58542 58009 BLUE RIDGE PAPER PRODUCTS INC. June 14, 2001 Mr. Forrest Westall Regional Water Quality Supervisor North Carolina Department of Environment and Natural Resources 59 Woodfin Place Asheville, NC 28801 Jtkl 1 5101 I J RE: NPDES Permit No. NC0000272, Blue Ridge Paper Products Inc. Request to Change Division of Water Quality Approved Study Plan for Dioxin Monitoring in Fish Tissue, February 1990 Dear Mr. Westall: Since 1990 the Canton Mill has been conducting annual fish tissue monitoring for dioxin in the Pigeon River. This compliance monitoring requirement in Part III, Section H of the NPDES Permit is performed in accordance with the DWQ approved Study Plan for Dioxin Monitoring in Fish Tissue, February 1990. In 1994 North Carolina changed the "Do not consume" advisory for all types of fish in the Pigeon River to a "Consumption advisory" for carp and catfish only. During the term of the current NPDES Permit term, all sportfish (redbreast sunfish, black crappie, smallmouth bass, largemouth bass and rock bass) have been below the level of detection for 2,3,7,8-TCDD (see attached table). Since 1996, the Toxicity Equivalent Concentrations (TEC's) for all sportfish have been based on non -detect values for all isomers and all TEC values are well below 3 ppt, the North Carolina level for fish consumption advisories. Based on the fact that 2,3,7,8-TCDD has been non -detectable for the last six years and the non - detect based TEC's are well below 3 ppt, Blue Ridge requests that the study plan be modified so that it is no longer necessary to collect sportfish in these annual fish tissue surveys. It is also requested that collection of bottom feeder whole bodies be removed from the study plan since the consumption advisory covers filets, not whole bodies. Up to 90 fewer fish per year will be collected from the Pigeon River as a result of this change to the annual study. If approved by the DWQ, the 1990 Study Plan will be revised to reflect these changes. Please contact me at (828) 646-2318 if you have any questions. The Canton Mill would appreciate consideration of this matter so that, if approved, it will be applied to the August 2001 fish tissue collection. Sincerely, Derric Brown Manager, Environmental Affairs Attachment Xc: Mark Hale Keith Haynes Lou Ann Williams 175 Main Street • P.O. Box 4000 Canton, North Carolina 28716 • Phone: 828-646-2000 Raising Your Expectations BLUE RIDGE PAPER CANTON MILL FISH FILLET TISSUE ANALYSIS RESULTS, 1996-2000(a) 1996 Results(b) 1997 Results0) Station Species Number of Fish Length Range (ram) 2,3,7,8-TCDDt Station Species Number of Fish Length Range (mm) 2,3,7,8-TCDDt� I Redbreast sunfish 5 154-185 ND (0.13) 1 Redbreast sunfish 5 144-161 ND (0.11) RM 64.5 Rock bass 5 160-208 ND (0.085) RM 64.5 Rock bass 5 162-194 ND (0.23) Black redhorse 5 401-440 ND (0.089) Black redhorse 4 291-424 ND (0.22) 2 Redbreast sunfish 5 179-187 ND (0.10) 2 Redbreast sunfish 5 183-200 ND (0.26) RM 59.0 Redbreast sunfish 5 183-191 ND (0.12) RM 59.0 Redbreast sunfish 5 160-181 ND (0.12) Common carp 5 543-580 1.5 Common carp 5 506-615 1.4 3 Redbreast sunfish 5 184-190 ND (0.13) 3 Redbreast sunfish 5 187-202 ND (0.18) RM 52.3 Redbreast sunfish 5 165-185 ND (0.13) RM 52.3 Redbreast sunfish 5 164-195 ND (0.18) Common carp 5 516-630 0.87 Common carp 5 450-505 ND (0.33) 4A Black crappie 5 216-233 ND (0.15) 4A Black crapppie 5 215-231 ND (0.27) RM 41.5 Black crappie 5 215-229 ND (0.18) RM 41.5 Black crappie 5 220-230 ND (0.10) Common carp 5 562-632 4.2 Common carp 5 570-655 2.3 Channel catfish 5 418482 2.0 4B Black crappie 5 223-258 ND (0.11) 4B Black crappie 5 226-241 ND (0.17) RM 39.0 Largemouth bass 5 278-310 ND (0.13) RM 39.0 Largemouth bass 5 270-360 ND (0.21) Common carp 5 470-623 4.0 Common carp 5 605-690 11.0 Flathead catfish 5 430-540 0.62 5 Rock bass 4 169-186 ND (0.077) 5 Rock bass 5 143-214 ND (0.15) RM 19.0 Smallmouth bass 5 315454 ND (0.12) RM 19.0 Smallmouth bass 5 278-367 ND (0.27) Smallmouth buffalo 5 451-555 ND (0.12) Smallmouth buffalo 5 406-525 ND (0.22) Total Fish Filleted 89 Total Fish Filleted 99 BLUE RIDGE PAPER CANTON MILL FISH FILLET TISSUE ANALYSIS RESULTS 1998 Results') 1999 Results0i Station Species Number of Fish Length Range (mm) 2,3,7,8-TCDDot Station Species Number of Fish Length Range (mm) 2,3,7,8-TCDD0) 1 Redbreast sunfish 5 145-176 ND (0.19) 1 Redbreast sunfish 5 141-177 ND (0.21) RM 64.5 Rock bass 5 158-179 ND (0.29) RM 64.5 Rock bass 5 164-180 ND (0.37) Black redhorse 5 340-396 ND (0.18) Black redhorse 5 352-427 ND (0.33) 2 Redbreast sunfish 5 164-177 ND (0.20) 2 Redbreast sunfish 5 167-190 ND (0.37) RM 59.0 Redbreast sunfish 5 166-193 ND (0.28) RM 59.0 Redbreast sunfish 5 158-178 ND (0.29) Common carp 5 551-661 1.3 Common carp 5 544-615 ND (0.27) 3 Redbreast sunfish 5 168-193 ND (0.34) 3 Redbreast sunfish 5 169-189 ND (0.36) RM 52.3 Redbreast sunfish 5 167-200 ND (0.22) RM 52.3 Redbreast sunfish 5 162-176 ND (0.37) Common carp 5 449-550 ND (0.38) Common carp 5 500-591 0.57 4A Black crappie 5 220-240 ND (0.49) 4A Black crappie 5 220-268 ND (0.18) RM 41.5 Largemouth bass 5 227-330 ND (0.15) RM 41.5 Black crappie 5 219-244 ND (0.08) Common carp 5 585-621 1.6 Common carp 5 574-645 0.58 Channel catfish 5 416458 ND (0.28) Channel catfish 5 425-482 0.83 4B Black crappie 5 233-252 ND (0.15) 4B Black crappie 5 233-244 ND (0.27) RM 39.0 Largemouth bass 5 259-330 ND (0.17) RM 39.0 Largemouth bass 5 276-305 ND (0.32) Common carp 5 563-686 9.1 Common carp 5 621-680 4.7 Flathead catfish 5 414-523 ND (0.20) Flathead catfish 5 372-513 ND (0.46) 5 Rock bass 4 155-190 ND (0.11) 5 Rock has 5 170-203 ND (0.29) RM 19.0 Smallmouth bass 5 295-365 ND (0.21) RM 19.0 Smallmouth bass 5 297.430 ND (0.19) Smallmouth buffalo 5 464-537 ND (0.31) Smallmouth buffalo 5 476-565 ND (0.31) Total Fish Filleted 99 Total Fish Filleted 100 BLUE RIDGE PAPER CANTON MILL FISH FILLET TISSUE ANALYSIS RESULTS 2000 Resultst"t Station Species Number of Fish Length Range (mn) 2,3,7,8-TCDDC' 1 Redbreast sunfish 5 137-148 ND (0.48) RM 64.5 Rock bass 5 162-186 ND (0.45) Black redhorse 5 357-396 ND (0.38) 2 Redbreast sunfish 5 169-176 ND (0.31) RM 59.0 Redbreast sunfish 5 164-181 ND (0.43) Common carp 5 505-582 ND (0.42) 3 Redbreast sunfish 5 169-181 ND (0.43) RM 52.3 Redbreast sunfish 5 186-199 ND (0.32) Common carp 5 514-569 ND (0.53) 4A Black crappie 5 212-241 ND (0.29) RM 41.5 Black crappie 5 220-241 ND (0.24) Common carp 4 559-604 1.1 Channel catfish 5 435487 ND (0.70) 4B Black crappie 5 213-231 ND (0.41) RM 39.0 Black crappie 5 220-230 ND (0.37) Common carp 4 593-712 4.4 Flathead catfish 5 407-450 ND (0.42) 5 Rock bass 5 171-198 ND (0.45) RM 19.0 Smallmouth bass 5 209-238 ND (0.31) Black redhorse 5 427-476 ND 0.35) Total Fish Filleted 98 Prepared for: North Carolina Division Water Quality Prepared by: Blue Ridge Paper Products Inc. Canton, North Carolina May 31, 2001 BLUE RIDGE PAPER PRODUCTS INC. May 29, 2001 Mr. Forrest Westall Regional Water Quality Supervisor North Carolina Department of Environment and Natural Resources 59 Woodfin Place Asheville, NC 28801 RE: NPDES Permit No. NC0000272, Blue Ridge Paper Products, Inc. Canton Mill June 1, 2001 Required Reports Dear Mr. Westall: Attached are the June 1, 2001 Comparative Evaluation Report and the June 1, 2001 Color Performance Statistical Evaluation. These reports are submitted to fulfill part of the requirements stated in Part III, Paragraph E 14 of the modified 1997 NPDES Permit. Please call me at (828) 646-2033 or Derric Brown at (828) 646-2318 if you have any questions or concerns regarding these reports. Sincerel -\6k Bob Williams Director - Environmental, Health and Safety Attachment 175 Main Street • P.O. Box 4000 Canton, North Carolina 28716 • Phone: 828-646-2000 Raising Your Expectations Xc: Keith Haynes Dave Goodrich Mikee Myeis June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina I. Introduction The following report describes the important color reduction activities that have been accomplished over the term of the modified 1997 NPDES Permit ("1997 Permit") and includes a discussion of technology assessments Blue Ridge has undertaken to evaluate potential color reduction options. Part III, E. Paragraph 14 of the 1997 Permit provides, in part, that: "...By June 1, 2001, the permittee will submit a report to the NPDES Committee and N.C. DENR, Division of Water Quality, on the comparative evaluation of the above collective efforts as part of the Variance review process (Triennial Review of North Carolina Water Quality Standards.)..." This report is submitted to fulfill this requirement of Part III, E. Paragraph 14. Permit No. NC0000272 Page 1 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina II. Summary of Color Reduction Activities Since the issuance of the 1997 NPDES Permit, the Canton Mill has accomplished the following color reduction activities: 1. Identified and implemented certain Best Management Practices (BMP's) to reduce color. The following BMP's were implemented before June 1, 1998, and a report on the implementation was submitted to DWQ, the TRW and the NPDES Committee on that date. a. Installation of replacement digester recirculation pumps. b. Installation of a double -chambered pine courtyard spill collection sump. c. Installation of weak black liquor tank containment, and d. Correction of evaporate set demister clogging, installation of condensate instrumentation and sampling ports for the evaporator set and assurance of continued dry conveying of knot rejects. 2. Submitted Low Flow Contingency Plan to DWQ and TRW by December 1, 1998 (approved by NPDES Committee in February 1999). 3. Prior to December 1, 1998, complied with a reduced color limit in the Permit of 60,000 lbs. per day (annual average) and 69,000 lbs. per day (monthly average). 4. Began implementation of partial Eo stage filtrate recycle on the hardwood line before January 1, 1999 and submitted a report on the color reduction benefit resulting from the partial implementation and a projection of potential color reduction benefit to be gained from full implementation of BFR on the hardwood line to DWQ, TRW and the NPDES Committee by December 1, 1999. 5. Submitted a color limit feasibility report to DWQ, TRW and the NPDES Committee before January 1, 2001, which concluded that the Canton Mill could comply with a color limit within the range of 48,000-52,000 lbs. per day (annual average). Permit No. NC0000272 Page 2 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina Implementation of these BMP's, together with improved mill operations and continued commitment to further reduce color, has reduced color by 32% over the term of the 1997 Permit. As described in the January 1st, 2001 Report, the mill has achieved a target annual average color loading of 48,000 — 52,000 pounds per day. On May 1, 2001 the North Carolina Division of Water Quality reduced the permit limit for annual average color from 60,000 Ibs/day to 48,000 Ibs/day and the monthly average color limitation was reduced from 69,000 Ibs/day to 55,000 Ibs/day. Based on data received from the National Council on Air and Stream Improvement (NCASI), the Canton Mill has the lowest color of any mill in its industry category.' 1 Based on a June 7, 2000 Benchmarking Canton Wastewater Effluent Parameters letter from the National Council for Air and Stream Improvement (NCASI). Permit No. NC0000272 Page 3 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina III. Additional Color Reduction Studies 3.1 End -of -Pipe Treatment and In -Process Technologies In an effort to identify either a breakthrough improvement in color removal efficiency or reduction in cost, the mill has evaluated end -of -pipe color reduction technologies three times in the past thirteen years, including a 2001 study by Jacobs Engineering Group, Inc. (2001 Color Removal Technology Assessment, the "Jacobs Report"). The Jacobs Report evaluated 16 end -of -pipe technologies. It is clear that no breakthrough in economic or technical feasibility has or is likely to occur in end -of -pipe color removal technologies. Such technologies have not been commercially demonstrated and are generally not economically feasible because they require a significant initial capital investment with continued operating costs and no associated savings. During this same thirteen -year period, however, the Canton Mill implemented alternative in -process pollution prevention technologies including oxygen delignification, Elemental Chlorine Free bleaching, Bleach Filtrate Recycle TM and those technologies comprising the "Near -Term" package, resulting in a significant reduction in the color discharged. Therefore, based upon this record, it is Blue Ridge's intention in the future to focus on in -process pollution prevention technologies and the potential treatment of selected, colored wastewater streams before they enter the wastewater treatment plant (WWTP) and, in particular, the Chloride Removal Process (CRP). Blue Ridge believes in -process pollution prevention and treatment of selected wastewater streams hold the greatest likelihood of success for further color reduction. In the future, Blue Ridge believes its time and resources would be Permit No. NC0000272 Page 4 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina better devoted to in -mill treatment of particular wastewater streams rather than end -of -pipe, secondary effluent color removal approaches. 3.2 Polyamine Trials Polyamine addition trials were conducted in January 2001 at the primary clarifier, secondary clarifier, and colored in -mill wastewater streams, and were not successful: - -The concept- of Polyamine addition is to reduce color through precipitation of color bodies, which attach to the polyamine, coagulate, and settle in primary clarification. Numerous trial approaches were conducted to study comprehensively the effectiveness of polyamine for color removal. While treatment of colored wastewater streams in the pulping and recovery areas appeared to remove color, the color bodies re-solubilized in the wastewater collection system and there was no significant net reduction in secondary effluent color. Treating the primary clarifier resulted in color reductions, but wastewater treatment plant sludge quality declined to an unmanageable condition and recycled belt press filtrate solids increased significantly. Treating the secondary effluent resulted in minimal color reductions; in addition, this type of treatment would require the installation of equipment and increased operating costs as described in the Jacobs Report , and might have adverse effects on the chronic toxicity of the wastewater discharge. 3.3 CRP Treatment with Lime Laboratory studies were recently performed on the Chloride Removal Process (CRP) purge stream, a relatively high color, low flow stream -associated with the BFRTM process. The purge stream was treated with various sources of calcium in an effort to precipitate color bodies. Lime precipitation was concluded to be Permit No. NC0000272 Page 5 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina infeasible due to the massive quantities necessary to partially reduce color and the large quantities of solid waste generated. 3.4 Third Party Evaluation of Canton Mill As part of Blue Ridge's commitment to continued color reduction, the Canton Mill, in collaboration with a coalition of environmental groups, engaged Dr. Norm Liebergott,—President of--Liebergott—& Associates Consulting Inc., and Lewis Shackford, Vice president of Technology for GL&V Pulp Group Inc., a major supplier to the pulp and paper industry, to undertake a thorough evaluation of the mill's pulping and bleaching operation. The evaluation is focusing on potential process and equipment modifications targeted at environmental performance improvements. Liebergott and Shackford will identify options for consideration that may lead to decreased effluent load, in particular color, with technologies that will not increase effluent toxicity. Blue Ridge plans to submit this information to the Division of Water Quality for its consideration in conjunction with the information from the Technology Review Workgroup (TRW) to evaluate options for potential reductions in effluent color over the term of the next NPDES Permit. Permit No. NC0000272 Page 6 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina IV. Commitments to Further Color Reduction The Canton Mill is committed to further discharge color reduction. In conjunction with the Technology Review Workgroup (TRW), the Canton Mill believes further color improvements may be achieved utilizing the following options. 4.1 BFR Improvements -Since October 1998, the average-BFR closure rate of the pine fiberline D1 and Eo stages has averaged approximately 74%. This rate is lower than the targeted BFR closure rate of 80%. The obstacles to achieving a sustained pine fiberline closure of 80% are related to the operational reliability of the BFR equipment, primarily the Metals Removal Process (MRP). Blue Ridge is committed to undertake improvements to the MRP in order to achieve an 80% pine fiberline closure rate. These improvements include a new media filter and softener, rebuilding piping and valves, and changing materials of construction to better withstand the harsh environment (corrosivity, erosion and deposition). Blue Ridge estimates the cost of these improvements to be up to $1,300,000 and the estimated discharge color reduction from these upgrades to be 1,000 —1,200 Ibs/day. The other component of the BFR process is the Chloride Removal Process (CRP). The CRP system purges chloride and potassium from the mill's chemical recovery system. This purge is a low flow, relatively high color stream that contributes an average of 6,000 Ibs of color per day to the wastewater treatment plant primary influent (or less than 4,000 Ibs/day in the discharge). The Canton Mill will investigate potential technologies that may reduce this source of color. Permit No. NC0000272 Page 7 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina 4.2 Additional Black Liquor Leak and Spill Control The Canton Mill has extensive equipment to reduce black liquor leaks and spills. Additional improvements to further manage black liquor losses to the wastewater collection system are currently under evaluation. The first improvement involves diversion of clean water from the digester area sump. This diversion of clean water will prevent dilution of concentrated brown color, thereby allowing the sump to -capture a greater percentage of- the -brown color from the digester area. Another upgrade is to collect the filtrate from the knotter bins to reclaim color that is leached from knots. An evaluation of alternatives to reduce screen room color will also be conducted. Blue Ridge estimates the cost of these improvements to be in excess of $100,000. The discharge color reduction could be in the range of 1,000 — 3,000 Ibs/day. 4.3 Evaluation of Potential In -Process Color Reduction Technologies As described in Section 3.4, Liebergott and Shackford are evaluating technologies that may result in reduced discharge color. While this report is not yet complete, Blue Ridge can provide an overview of Liebergott's and Shackford's scope of work. The scope of the Liebergott and Shackford study involves evaluation of potential process modifications to see if such modifications are technically, operationally and economically feasible. The report will consider impacts on process control, production capability and pulp production cost and quality. Liebergott and Shackford will consider changes to each fiberline, 2-stage oxygen delignification, strategic use of hydrogen peroxide and the alternative use of peracetic acid Permit No. NC0000272 Page 8 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina and/or ozone in the bleaching stages.. An evaluation of whole mill effluent and segregated higher color wastewater streams will also be conducted. A final report will be issued summarizing the technical, economic and operational feasibility of the technologies reviewed, including a discussion of commercially demonstrated use. This report will be provided to the Division of Water Quality. In addition to -this third -party assessment, the USEPA has a dedicated Technology Review Workgroup that is studying additional color reduction technologies. This report is also expected to be available to the Division of Water Quality in the second quarter of 2001. Permit No. NC0000272 Page 9 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina V. Conclusion The Canton Mill has successfully reduced color from 83,000 Ibs/day to less than 48,000 Ibs/day over the term of the 1997 NPDES Permit. Blue Ridge is committed to further improvements to the BFR process, the digester area spill control systems and to the knotter and screen operations, which will further reduce discharge color. Blue Ridge is also committed to evaluating other process technologies, which may reduce color, over the term of the 2001 NPDES Permit. Permit No. NC0000272 Page 10 June 1, 2001 Statistical Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina I. Introduction The following report describes the statistical evaluation of the Canton Mill's color discharge since completion of the color reduction activities required by the modified 1997 NPDES Permit and Settlement Agreement. Part III, E. Paragraph 14 of the revised 1997 Permit provides, in part, the following: "... Further, based on the continued development of color discharge information from the reconfigured mill, the permittee will statistically evaluate its monthly average color discharge, its annual average color discharge, and the performance of the mill in relation to color discharged..." This report is submitted to fulfill this requirement of Part III, E. Paragraph 14. Permit No. NC0000272 Page 1 June 1, 2001 Statistical Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina II. Discussion The Canton Mill has achieved a color reduction of over 88% since 1988 in the annual average amount of color discharged, as illustrated in Figure 1. The improved color performance is due to the Canton Modernization Project, full implementation of the "Near -Term Package' and continuous color management by the mill. The Near -Term Package included the installation of BFWm on the mill's pine fiberline, implementation of best management practices (BMPs) detailed in the June 1, 1998 Color Technology Report, and partial BFR (Eo filtrate recycle) on the hardwood fiberline. Partial hardwood Eo recycle was still being evaluated and optimized through December 1999, and therefore, the January 2000 — December 2000 time period was used as the basis for the statistical evaluation. This period is representative of mill discharge color performance after implementation of all activities (i.e. "the reconfigured mill") required in the 1997 NPDES Permit. However, it is important to note that November and December 2000 are not representative of typical mill pulp production. This is due to the No. 19 Paperboard Machine outage and start-up, when pulp production was very low compared to normal operation. Permit No. NC0000272 Page 2 Figure 1: Canton Mill Secondary Effluent Color Performance Annual Averages: 1988 - 2000 400000 T Including Permit Limitations Permit Limitations: 350000 1 - 258,945 #/d Monthly Ave. efi. 4114/94 2-172,368 #/d Annual Ave. eft. 4/14/94 3-125,434 #/d Monthly Ave. eH. 12/12/96 4 - 98,168 #/d Annual Ave e6. 12/12/96 6 - 95,000 Old Monthly Ave eft. 111198 300000 6 - 69,000 91d Monthly Ave. eR. 1211198 T 7 - 60,000 #/d Annual Ave. e8. 1211/98 to 8 - 48,000 #/d Annual Ave. eff. 5/1/01 9 N c 250000 ti 0 1 0 U d 200000 LU w D150000 0 2 u rn 100000 5 0 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 Blue Ridge Paper Products, Inc. ® Permit Limitaions i SE Color Annual Ave. Wd JF=7 Canton Mill 5/31/01 June 1, 2001 Statistical Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina III. Statistical Evaluation of Color Performance Data The attached Table summarizes the statistical evaluation. Based on January 2000 — December 2000 color data, the 95th percentile expected annual average is 46,475 Ibs/day. This 95th percentile annual average is representative of the reconfigured mill's performance. The monthly average numbers were calculated, using the same data as above, by two different statistical methods. The expected monthly color average based on a 95th percentile distribution is 54,089 Ibs/day. Using a 95th percentile distribution and interpolation from ranked observations, the expected monthly color average is 55,003 Ibs/day. These two 951h percentile monthly average numbers represent current mill performance. The maximum monthly average observed during this time period was 58,009 Ibs/day. 1 Interpolated numbers come from the empirical (i.e. the actual ranked values) data using the calculated percentile by assuming it lies linearly between the closest smaller percentile and the closest larger percentile within the cumulative percentage distribution. Due to the limited data set available, an interpolated statistical evaluation is only possible for a monthly value, not for an annual value. Permit No. NC0000272 Page 3 June 1, 2001 Statistical Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina IV. Conclusion Based upon color discharge data during the period after the Mill had implemented all improvements required by the 1997 NPDES Permit, the expected annual average is 46,475 Ibs/day. Expected monthly color averages using the same data from two different statistical evaluations are 54,089 and 55,003 Ibs/day. Using North Carolina's governing flow criteria (30Q2), historical flow records, and the 2000 annual average color discharge of 43,386 Ibs/day, it is expected that color in the Pigeon River at the Hepco gage will be less than 50 true color units 100% of the time at all flows above 30Q2. Permit No. NC0000272 Page 4 Table 1: June 1, 2001 Statistical Evaluation Monthly Average Data - Max Month/Annual Calculation Data Set n= X-bar std dev 95th percentile for Month 99th percentile for Month Max month 95th percentile for Year from normal distribution 99th percentile for Year from normal distribution Ranked observations - by interpolation 95th percentile for max month 99th percentile for max month January 2000 - December 2000 12 43,386 6527 54,089 58,593 58,009 46,475 47,775 BRPP Inc. Canton Mill June 1, 2001 Statistical Evaluation Attachment 55,003 57,408 BLUE RIDGE PAPER PRODUCTS INC. June 14, 2001 Mr. Forrest Westall Regional Water Quality Supervisor North Carolina Department of Environment and Natural Resources 59 Woodfin Place Asheville, NC 28801 RE: NPDES Permit No. NC0000272, Blue Ridge Paper Products Inc. Canton Mill Addendum to June 1, 2001 Statistical Evaluation Dear Mr. Westalh As we discussed on May 31, 2001, a statistical evaluation was performed on the mill color data from January 2000 through October 2000. The 95 s percentile expected monthly color from this data was 54,773 Ibs/day and the 95 ° percentile expected annual color was 47,704 lbs/day. In November of 2000, substantial process improvements were implemented on No. 19 Paperboard Machine to improve product quality and yield. No. 19 Paperboard Machine manufactures over half of the total daily production of the Canton Mill. As of June 14, 2001, this machine is still under -performing, which limits pulp mill production by as much as 100 to 150 tons per day. During November 2000, an equivalent of one fiberline was out of service. Please call me at (828) 646.2318 if you have any questions or concerns regarding these reports. Sincerely, Derric Brown Manager — Environmental Affairs Xc: Don Anderson Keith Haynes Mike Meyers 175 Main Street • P.O. Box 4000 Canton, North Carolina 28716 • Phone: 828-646-2000 Raising Your Expectations OF W ArFR Michael F. Easley JF pG Governor ij William G. Ross, Jr., Secretary > Department of Environment and Natural Resources O Y Kerr T. Stevens Division of Water Quality MEMORANDUM To: Jimmie Overton 5 Forrest Westall q 2001 I_, Through: Trish MacPherson'""— QQ From: Bryn H. Tracy T ASHEVILLEURFG SIE oIiCE JALO Subject: Comments on the NPDES Permit No. NC0000272, Blue Ridge Paper Products Inc., Canton Mill, Balanced and Indigenous Species Study for the Pigeon River I have reviewed this study and my comments are provided herein: 1. This study was required by NPDES permit, but the work was not performed by a NCDWQ-certified laboratory. 2. in a letter from Ms. Coleen Sullins to Mr. Robert Williams (Blue Ridge Paper Products, Inc, (BRP)), it was specifically stated: "Task 1 --It is important to select species for modeling, which are native to the Pigeon River basin." And in an e-mail from me to Keith Haynes (dated March 17, 2000), 1 specifically requested: "Task 1 -- Species chosen for study should be those native species currently inhabiting the Pigeon River or species that were known or suspected to have occurred in the river prior to mill operation but no longer occur in the river due to mill operation. The importance of modeling species native to the French Broad River and Pigeon River basins can not be over emphasized." Two of the species (common carp and redbreast sunfish) which were modeled are not native to the basin and should not have been modeled. Other species, such as the river chub, mottled sculpin, and banded sculpin should have been. NC DWQ was not given the opportunity to comment on the species chosen for modeling. 3. In the same letter and e-mail, it was stated: "It is our findings that there are currently no nuisance species in the river. And, ... "to my knowledge, there are no commercially important or nuisance species in the river. Common carp should not be modeled as a nuisance species. Consultant should define nuisance species". The consultant never defined nuisance species prior to the study and common carp should not have been modeled as a representative important species. My use of the word: "nuisance" was based upon their study plan, where they stated: "... and one species that has the potential to become a nuisance species". My definition or understanding of "nuisance" was different than BRP's definition. 4. In the same letter and (more emphatically) in the same e-mail it was stated: "The NCIBI should not be used as its metrics were not calibrated nor was it correctly designed for streams the size of the Pigeon River". Despite this, the 1995/1997 version of the Index was used. Conclusions based upon the 1995/1997 Index and its metric criteria were not and are not currently valid. 5. Page 1-2 --"By the mid-80's the aquatic life in the river was consistent with the expectations for a Class C stream in North Carolina (EA 1988)". This statement, which was repeated in 1990s reports, was pointed out in 1996 to BRP (at that time Champion International Corp.) that their interpretation of the regulations was in error and this statement was . not true. ' NCOEN'R Customer Service 1 800 623-7748 Environmental Sciences Branch 1621 Mail Service Center Raleigh, NC 27699-1621 (919) 733-9960 W A rFR Michael F. Easley PG Governor William G. Ross, Jr., Secretary Department of Environment and Natural Resources Kerr T. Stevens -." Division of Water Quality 6. Page 3-1 -- If recolonization sources are lacking downstream of the mill and because the darter fauna in the Pigeon River has been severely impacted for many decades, would BRP (and other responsible entities and interested parties) fund efforts to reintroduce species that were eradicated by the mill's effluent and prevented from recolonization by the Walters Dam? 7. Pages 3-2 and 3-3 --"Species richness in the most thermally affected zone (Fiberville) is comparable to upstream of the mill and better than the NC zones further downstream" -- this maybe true, but the species (and their abundances) above and below the mill are entirely different. Later (buried in the report), Table 4-7 shows that the fauna of the most thermally affected site is only 16% similar to that of the reference site. Equating equal species richness at the two sites with having no thermal impact and indicative of a balanced fish community below the mill is not valid. 8. Pages 3-2 and 3-3 -- common carp and redbreast sunfish are not native to the Pigeon River basin and both species are considered tolerant. Nuisance species, as requested in an earlier correspondence, was never defined. 9. Pages 3-2, 3-3, and 3-9 -- redbreast sunfish is a thermally tolerant fish whose percent abundance progressively declines the further removed from the mill (refer to Table 4-2). Above the mill, the species constitutes only 2.5% of the fauna, at Fiberville 64%, and at River Mile 19.3, 0%. Contrary to the report, this species clearly indicates that nuisance species are dominant and the community, at certain sites, is dominated by thermally tolerant species. Likewise, biomass data (page 4-15) also show the dominance of these two species in the nearfield areas (53%-68%). 10. Page 3-3 -- YOY (young -of -year) should not be collected and -should not be considered when using the NC IBI (or any other version). 11. Page 3-4 -- as earlier stated, the NC IBI should not have been used as a measure of community health or as a tool to assess thermal impacts. 12. Page 3-4 -- if the upstream site is used as the reference site (a thermally unimpacted site), then downstream sites clearly show spatial faunal differences that can be attributed, at least in part, to temperature differences. 13. Page 3-5 -- what is BRP's evidence (basis) that the river below the mill should not be cool water system, like it is above the mill? The elimination of darters and other species was most likely due to extremely poor water quality (in the broadest sense including chemical and thermal pollutants). The recovery below the mill in North Carolina of the greenside darter, greenfin darter, tangerine darter, and other species will likely take a long time, if ever. 14. Page 3-9 -- species richness conclusion -- this is clearly a misinterpretation of the data. 15. Page 3-10 -- Competitive Advantage to Certain Species -- Redbreast sunfish seemed to dominate the communities below the mill. Would not this species decrease and rockbass increase if the temperature below the mill was cooler? 16. Page 3-11 -- Community Dominated by Thermally Tolerant Species -- "Furthermore, most citizens and anglers probably consider the presence of large numbers of redbreast sunfish to be a positive attribute of the fish community rather than a negative one." This clearly is an opinion and not supported by any published facts. The redbreast sunfish is not native to the mountain streams and is a indicator of some past alteration to the stream and community. In eastern Tennessee, this species is implicated in out -competing and displacing the native longear sunfish (Etnier and Starnes 1993. This presence and abundance of the redbreast sunfish in mountain waters should not be viewed as a positive attribute. VA Customer Service Environmental Sciences Branch 1621 Mail Service Center Raleigh, NC 27699-1621 (919) 733-9960 1 800 623-7748 F WArF \Oct RQG Michael F. Easley Governor rWilliam G. Ross, Jr., Secretary ,i Department of Environment and Natural Resources O * Y Kerr T. Stevens Division of Water Duality 17. Page 3-13 --Common Carp --"The state has already stated that common carp is not a nuisance species in the Pigeon River (memo from Bryn Tracy dated 17 March 2000)." The exact wording of my memorandum was: "To my knowledge, there are no commercially important or nuisance species in the river. Common carp should not be modeled as a nuisance species. Consultant should define nuisance species." I believe my words were taken out of context and meaning. 18. Page 3-15 -- Redbreast sunfish -- "Since this is a popular species with anglers, it is expected that most people would view its increased abundance downstream of the mill as a positive rather than an adverse impact." Clearly, this is an opinion and not based upon published facts. 19. Pages 3-15 and 3-16-- Darters -- The presence of one or two individuals of any species of darters (or any other species) downstream of the mill does not equate with viable populations and with improving and tolerable conditions. 20. Appendix A, Page 1-1 -- "The North Carolina Division of Water Quality (NCDWQ) does not have an established protocol for conducting 316 (a) demonstrations (email from Mr. Bryn Tracy date 116100). Nonetheless, biological sampling was conducted in accordance with standard NCDWQ field protocols." The precise wording of my e-mail was: "The North Carolina Division of Water Quality does not have a formal protocol for conducting 316 (a) demonstrations such as the one being proposed for the Pigeon River. Typically, the Division handles the study design on an informal communicative basis. You would, however, be safe in using the federal protocol and having us approve the study design before the actual sampling is to be conducted later this year. In terms of the benthic invertebrate community, the thermal effluent is treated just like any other WWTP effluent and upstream -downstream type studies are done." In a later email (dated 03/17/200) and in a letter from Ms. Sullins, BRP was instructed not use the NCIBI in its 316 (a) demonstration. 21. Appendix A, Page 2-12 -- "For this report, the IBI is used only to compare the 1995 and 2000 results". This statement is not valid. The inaccurately -derived Index is used to support BRP's position that a continuation of the variance is warranted. 22. Appendix A, Page 4-8 -- "No single species dominate the mainstream catch." The redbreast sunfish's abundance, below the mill in North Carolina, constituted 64% (near field) to 17% (far field) of all the fish collected. Approximately 25% of all the fish collected from the entire river were the tolerant redbreast sunfish. 23. Appendix A, Page 4-11 -- Percent Similarity -- as mentioned earlier, the thermally affected sites below the mill were very dissimilar to the thermally unimpacted reference site. 24. Appendix A, Page 4-26 -- Life Stage and Spawning Activity -- This assessment should have been made on a site -by - site basis, not for the entire river from River Mile 64.5 to River Mile 19.3. Young -of -year should also not be included in the analyses. BHT/bht PC: Dave Goodrich &Keif .'Haynes;,* Michael Meyers AVIA NCDM Customer Service 1 800 623-7748 Environmental Sciences Branch 1621 Mail Service Center Raleigh, NC 27699-1621 (919) 733-9960 BLUE RIDGE PAPER PRODUCTS INC. bxc: Mike Ferguson Dave Goodrich Melanie Hager C:Ke`itFHaynes---) Terry Huskey Mike Meyers Steve Single Forrest Westall Bob Williams BLUE RIDGE PAPER PRODUCTS INC. July 17, 2001 Mr. Don Anderson U.S. Environmental Protection Agency Mail Code 4303 Room 195A, East Tower 401 M Street, SW Washington, D.C. 20460 Re: Response to EPA Tech Team's July 10, 2001 Draft Final Report Dear Mr. Anderson: Attached are Blue Ridge Paper Products Inc. (Blue Ridge) comments on the July 10, 2001 EPA Tech Team Report. These comments are in addition to Bob William's July 13, 2001 email to you. This information is consistent with Blue Ridge's May 18, 2001 and June 4, 2001 response to the EPA Tech Team and the Liebergott and Associates and GL&V Pulp Group, Inc. Bleach Environmental Process Evaluation and Report. Incorporation of these technical comments in the Final EPA Tech Team Report is important to Blue Ridge Paper Products Inc. Please call me at (828) 646-2318 or Bob Williams at (828) 646-2033 if you have any questions or need additional information. Sincerely, Derric Brown Manager — Environmental Affairs Blue Ridge Paper's Response to Tech Team's 7/10/01 Draft Report 7/18/01 1 175 Main Street • P.O. Box 4000 Canton, North Carolina 28716 • Phone: 828-646-2000 Raising Your Expectations BLUE RIDGE PAPER PRODUCTS INC. Table 1: Summary of Process Improvements and Associated Color Reductions Process Improvement Influent Final Color Effluent Reduction Color (lbs/day) Reduction (lbs/day) 1 BFR reliability improvement Tech Team: --- 1,000-1,200 Blue Ridge: 1,000-1,200 23 Improved black liquor leak & spill collection and control Tech Team: --- > 5,000 Blue Ridge: 2,800-8,300 1,000-3,000 6 Process Optimization Tech Team: 1,700 1,400 Blue Ridge: 1,100 900 TOTAL FINAL EFFLUENT COLOR REDUCTION Tech Team: >7,400 Blue Ridge: 2,900-5,100 aBlue Ridge agrees there are additional opportunities to reduce color from black liquor leaks and spills. However, the draft final EPA tech team effluent color reduction estimate is too high and is not reasonably achievable. In 2000 there was approximately 12,000 pounds per day of color from all black liquor sources (excluding CRP). Based on previous studies conducted at the Canton Mill by Duke University graduate students, an average of 64% of brown color was removed across the simulated wastewater treatment plant. A 5,000 pound per day final effluent color reduction as shown in the draft Tech Team Report would require 13,900 pounds of influent color treated at the average level of 64%. There is not 13,900 pounds of influent brown color available; therefore, it is unreasonable to achieve a >5,000 pound per day effluent color reduction. Blue Ridge estimates a 1,000 — 3,000 pound per day reduction in brown color is achievable and would require a 2,800 — 8,300 pound per day reduction in influent color based on a 64% wastewater treatment efficiency. bThe Bleach Environmental Process Evaluation and Report (BEPER) prepared by Liebergott and Associates and GL&V Pulp Group, Inc. states the color reduction from process optimization may potentially be up to 1,100 pound per day. The Tech Team estimated an additional color reduction from the CRP purge stream of 600 pounds per day resulting from the decreased chlorine dioxide usage. As Blue Ridge has stated previously, a reduction in chlorides does not necessarily translate into a reduction in the amount purged from the CRP or to a reduction in color in the CRP purge. While reduced liquor system chlorides may translate into a reduced CRP purge rate, a reduced purge rate would not be expected to result in a reduction of the total mass of color in the CRP purge. Chloride purging and CRP color are independent variables. The amount of color in the precipitator -CRP loop is independent of chloride loading. Therefore, any reduction in volumetric flow rate of the purge stream made possible by reduced chloride loading will not reduce the amount of color "purged" from the CRP. Since the absolute mass of color would not change, the concentration of color in the purge stream would be expected to increase accordingly, resulting in no change in the total mass of color purged. Therefore, Blue Blue Ridge Paper's Response to Tech Team's 7/10/01 Draft Report 7/18/01 2 BLUE RIDGE PAPER PRODUCTS INC. Ridge supports an estimated influent color reduction of 1,100 pounds per day and a final effluent color reduction of 900 pounds per day from process optimization. Table 2: Summary of Process Improvements and Associated Additional Color Reductions Needing Further Study Process Improvement Influent Final Effluent Color Color Reduction Reduction (lbs/day) (lbs/day) 3` Ozone/Chlorine Dioxide stage for hardwood bleach line Tech Team: 3,000-6,400 3,000-6,400 Blue Ridge: 3,550 3,550 4 2 "d stage OD for pine line Tech Team: 1,500-2,000 1,100-1,400 Blue Ridge: 1,500-2,000 1,100-1,400 TOTAL FINAL EFFLUENT COLOR REDUCTION NEEDING FURTHER STUDY Tech Team: 4,100 - 7,800 Blue Ridge: 4,650 — 4,950 Table 2A: Continued Evaluation of CRP Purge Stream Color Treatment Opportunities Process Improvement Influent Final Effluent Color Color Reduction Reduction (lbs/day) (lbs/day) 5 d Color Treatment of CRP Purge Stream Tech Team: 6,000 3,300 Blue Ridge: 0-5,000 0-2,300 TOTAL POTENTIAL FINAL EFFLUENT COLOR REDUCTION Tech Team: 3,300 Blue Ridge: 0-2,300 `Based on an extensive analysis of the operating conditions and equipment at the Canton Mill, the BEPER estimated a color reduction of 3,550 pounds per day from the use of an ozone/chlorine dioxide (ZD) stage for the hardwood bleach line. Therefore, the 3,000 — 6,400 pound per day range should be revised to 3,000 — 4,000 pounds per day. dThe Tech Team assumes that color treatment of the purge stream will be feasible. Blue Ridge conducted laboratory tests using polyamine and various sources of lime or calcium to remove color from the CRP stream. While color was removed in the laboratory at very high dosages, the cost for coagulants and/or precipitants would be very high. In addition, for this low flow stream, Blue Ridge Paper's Response to Tech Team's 7/10/01 Draft Report 7/18/01 BLUE RIDGE PAPER PRODUCTS INC. large-scale equipment would be required to handle the solids and significant quantities of additional solid waste would be generated. Blue Ridge recommends removing Item 5, Color Treatment of the CRP Purge Stream, from Table 2. While Blue Ridge supports conducting a study of potential CRP color removal options, there are no known feasible options available at this time. Based on actual test data the CRP purge averages approximately 4,500 — 5,000 pounds per day of influent color. Assuming CRP color is treated similarly to brown color, a 64% reduction in CRP color currently achieved across the WWTP would result in approximately 2,300 pounds per day of final effluent color. Table 3: Estimated Costs Process Improvement Capital Annual O&M Cost ($/year) ($) 1 BFR reliability improvement Tech Team: $1,300,000 $85,000 Blue Ridge: $1,300,000 $85,000 2 Improved black liquor leak & spill collection and control Tech Team: $100,000 $50,000 Blue Ridge: $100,000 $50,000 3 Ozone/Chlorine Dioxide stage for hardwood bleach line Tech Team: $1,500,000 ($350,000) savings Blue Ridge: $1,500,000- ($350,000) 2,000,000''r 4 2" stage OD for pine line Tech Team: $2,000,000 ($3,100,000) Blue Ridge: $2,500,000 ($800,000- -3,000,000 r 1,200,000)9 'Installed costs for the Ozone generation and power supply systems are estimated to be in excess of an additional $3,000,000. rAdditional cost is required due to the constructability of this system in this area of the mill. gAppendix 4 of the July 10, 2001 draft final Tech Team Report correctly adjusted the oxygen delignification stage input kappa number to 24. However, the yield credit of 1.5% is still shown for the proposed two -stage oxygen delignification system. The yield credit for a 2-stage oxygen delignification system at Canton is zero (0). Therefore, the annual O&M cost should be adjusted down from a $3,100,000 savings as shown in the draft final Tech Team Report to an $800,000 - $1,200,000 annual savings. Blue Ridge Paper's Response to Tech Team's 7/10/01 Draft Report 7/18/01 STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION Division of Water Pollution Control 6°' FI. L & C Tower 401 Church Street Nashville, Tennessee 37243 - 1534 PHONE: (615) 532-0632; FAX: (615) 532-0503 April 16, 2001 The Honorable Charles Lewis Moore Cocke County Executive Room 146, Court House Annex 360 East Main Street Newport, Tennessee 37821 RE: Pigeon River Joint Watershed Advisory Committee Meeting May 8, 2001 Dear Mr. Moore: Lo! a n- ��f APR 9�Bf V' �TE4 p Y ASHn,. E1QF At our March meeting of the Pigeon River Joint Watershed Advisory Committee, we agreed that we would like to invite the EPA technical experts on pulp and paper to visit with the committee and discuss about pollution control and wastewater treatment technology. I am pleased to report that this meeting has been scheduled, and that EPA has committed to have their national experts meet with both our committee and the Community Advisory Committee in Newport. Bob Williams with Blue Ridge Paper Products will contact the other committee. The meeting will be from 9:00 am to noon at the Newport Community Center. That's located on Highway 321, the Cosby Highway, about a mile or so north ofI-40 at exit 435. The Community Center will be on the right as you go north. It has plenty of parking and you will want to use the upper entrance. We have the upstairs meeting room reserved. Please contact me at 615/531-0632 if you have.any questions. Sincerely, a.� Paul E. Davis Director Division of Water Quality Control PED/gss STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION Division of Water Pollution Control 6`h Fl. L & C Tower 401 Church Street Nashville, Tennessee 37243 - 1534 PHONE: (615) 532-0632; FAX: (615) 532-0503 April 16, 2001 Mr. David Dudek Haywood Community College 185 Freedlander Drive Clyde, North Carolina 28716 RE: Pigeon River Joint Watershed Advisory Committee Meeting May 8, 2001 Dear Mr. Dudek: 117 4: APR 19 2001 At our March meeting of the Pigeon River Joint Watershed Advisory Committee, we agreed that we would like to invite the EPA technical experts on pulp and paper to visit with the committee and discuss about pollution control and wastewater treatment technology. I am pleased to report that this meeting has been scheduled, and that EPA has committed to have their national experts meet with both our committee and the Community Advisory Committee in Newport. Bob Williams with Blue Ridge Paper Products will contact the other committee. The meeting will be from 9:00 am to noon at the Newport Community Center. That's located on Highway 321, the Cosby Highway, about a mile or so north of I-40 at exit 435. The Community Center will be on the right as you go north. It has plenty of parking and you will want to use the upper entrance. We have the upstairs meeting room reserved. Please contact me at 615/531-0632 if you have any questions. Sincerely, Paul E. Davis Director Division of Water Quality Control PED/gss STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION Division of Water Pollution Control 6'h Fl. L & C Tower 401 Church Street Nashville, Tennessee 37243 - 1534 PHONE: (615) 532-0632; FAX: (615) 532 April 16, 2001 Mr. Tim Dockery Newport Parks and Recreation 433 Prospect Avenue Newport, Tennessee 37821 RE: Pigeon River Joint Watershed Advisory Committee Meeting May 8, 2001 Dear Mr. Dockery: qr� IF I APR 1 9 2001I At our March meeting of the Pigeon River Joint Watershed Advisory Committee, we agreed that we would like to invite the EPA technical experts on pulp and paper to visit with the committee and discuss about pollution control and wastewater treatment technology. I am pleased to report that this meeting has been scheduled, and that EPA has committed to have their national experts meet with both our committee and the Community Advisory Committee in Newport. Bob Williams with Blue Ridge Paper Products will contact the other committee. The meeting will be from 9:00 am to noon at the Newport Community Center. That's located on Highway 321, the Cosby Highway, about a mile or so north of I-40 at exit 435. The Community Center will be on the right as you go north. It has plenty of parking and you will want to use the upper entrance. We have the upstairs meeting room reserved. Please contact me at 615/531-0632 if you have any questions. Sincerely, c� LL—o Paul E. Davis Director Division of Water,Quality Controb- - PED/gss -" STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION Division of Water Pollution Control 6`h Fl. L & C Tower 401 Church Street Nashville, Tennessee 37243 - 1534 PHONE: (615) 532-0632; FAX: (615) 532-3503 April 16, 2001 Mr. Kenny Sutton Post Office box 1772 Canton, North Carolina 28716 RE: Pigeon River Joint Watershed Advisory Committee Meeting May 8, 2001 Dear Mr. Sutton: fir'!/,;✓ .''� �` 7 19 0 At our March meeting of the Pigeon River Joint Watershed Advisory Committee, we agreed that we would like to invite the EPA technical experts on pulp and paper to visit with the committee and discuss about pollution control and wastewater treatment technology. I am pleased to report that this meeting has been scheduled, and that EPA has committed to have their national experts meet with both our committee and the Community Advisory Committee in Newport. Bob Williams with Blue Ridge Paper Products will contact the other committee. The meeting will be from 9:00 am to noon at the Newport Community Center. That's located on Highway 321, the Cosby Highway, about a mile or so north of I-40 at exit 435. The Community Center will be on the right as you go north. It has plenty of parking and you will want to use the upper entrance. We have the upstairs meeting room reserved. Please contact me at 615/531-0632 if you have any questions. Sincerely, Paul E. Davis Director Division of Water Quality Control PED/gss STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION Division of Water Pollution Control 61h Fl. L & C Tower 401 Church Street Nashville, Tennessee 37243 - 1534 PHONE: (615) 532-0632; FAX: (615) 532-0503 April 16, 2001 Mr. Jerry Wilde 402 West Broadway Newport, Tennessee 37821 RE: Pigeon River Joint Watershed Advisory Committee Meeting May 8, 2001 Dear Mr. Wilde: At our March meeting of the Pigeon River Joint Watershed Advisory Committee, we agreed that we would like to invite the EPA technical experts on pulp and paper to visit with the committee and discuss about pollution control and wastewater treatment technology. I am pleased to report that this meeting has been scheduled, and that EPA has committed to have their national experts meet with both our committee and the Community Advisory Committee in Newport. Bob Williams with Blue Ridge Paper Products will contact the other committee. The meeting will be from 9:00 am to noon at the Newport Community Center. That's located on Highway 321, the Cosby Highway, about a mile or so north of I-40 at exit 435. The Community Center will be on the right as you go north. It has plenty of parking and you will want to use the upper entrance. We have the upstairs meeting room reserved. Please contact me at 615/531-0632 if you have any questions. Sincerely, Paul E. Davis Director Division of Water Quality Control PED/gss STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION Division of Water Pollution Control 6`h Fl. L & C Tower 401 Church Street Nashville, Tennessee 37243 - 1534 PHONE: (615) 532-0632; FAX: (615) 532-0503 April 16, 2001 Mr. Jack Horton, County Manager Haywood County Manager's Office 215 North Main Street Waynesville, North Carolina 28786 Newport, Tennessee 37821 RE: Pigeon River Joint Watershed Advisory Committee Meeting May 8, 2001 Dear Mr. Horton: At our March meeting of the Pigeon River Joint Watershed Advisory Committee, we agreed that we would like to invite the EPA technical experts on pulp and paper to visit with the committee and discuss about pollution control and wastewater treatment technology. I am pleased to report that this meeting has been scheduled, and that EPA has committed to have their national experts meet with both our committee and the Community Advisory Committee in Newport. Bob Williams with Blue Ridge Paper Products will contact the other committee. The meeting will be from 9:00 am to noon at the Newport Community Center. That's located on Highway 321, the Cosby Highway, about a mile or so north of I-40 at exit 435. The Community Center will be on the right as you go north. It has plenty of parking and you will want to use the upper entrance. We have the upstairs meeting room reserved. Please contact me at 615/531-0632 if you have any questions. Sincerely, Paul E. Davis Director Division of Water Quality Control PED/gss BLUE RIDGE PAPER PRODUCTS INC. December 28, 2000 Mr. Forrest Westall Regional Water Quality Supervisor North Carolina Department of Environment and Natural Resources 59 Woodfin Place Asheville, NC 28801 RE: NPDES Permit No. NC0000272, Blue Ridge Paper Products, Inc. Canton Mill January 1, 2001 Color Limit Feasibility Report Dear Mr. Westall: Attached is the January 1, 2001 Color Limit Feasibility Report required by Part III, Section E 12 of the Canton Mill's NPDES permit. This report is also required by the Settlement Agreement, paragraph 24, and the Revised Color Variance, paragraph 5H. Blue Ridge Paper Products is submitting this report to you in your capacity as Regional Water Quality Supervisor for the Division of Water Quality and as a member of the Technology Review Workgroup. Blue Ridge Paper Products would appreciate you distributing the enclosed copies to the members of the Technology Review Workgroup. Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of 48,000 — 52,000 pounds per day is feasible. Due to the limited data set available, Blue Ridge Paper Products believes it is appropriate to use a 99 s percentile confidence interval to extrapolate long term and continuing monthly and annual average effluent limitations. Based on this statistical review of the available data from January 1998 - October 31, 2000 the Canton Mill recommends an annual average color limit of 49,612 Ibs/day and an average monthly color limit of 59,796 lbs/day. For the June 1, 2001 report, (required by Part III, Section E, paragraph 14, of the Canton Mill's NPDES Permit), Blue Ridge Paper Products recommends using a 95's percentile confidence interval to statistically evaluate the monthly and annual average color discharge. Using a 95 h percentile statistical review of the limited data available from January 1998— October 31, 2000 the annual average color is 48,388 lbs/day and the monthly average color is 55,556 lbs/day. Blue Ridge Paper Products believes the 95 ° percentile confidence interval will be appropriate with the additional color data that will be available for the June 1, 2001 analysis. The attached Table includes the summary of the 99 ° and 95 ° percentile statistical data. Please call me at (828) 646-2033 or Derric Brown at (828) 646-2318 if you have any questions regarding this report. Sincerely, Bob Williams Director - Environmental, Health and Safety Attachments 175 Main Street • P.O. Box 4000 Canton, North Carolina 28716 • Phone: 828-646-2000 Raising Your Expectations BLUE RIDGE Copy: Keith Haynes North Carolina Department of Environment Health and Natural Resources 59 Woodfin Place Asheville, NC 28801 Technology Review Workgroup (via Division of Water Quality) January 1, 2001— Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina I. Introduction The following report details the Canton Mill's ability to achieve a target annual average color limit in the 48,000 — 52,000 lb/day range in accordance with the requirements of the 1997 modified Color Variance and NPDES Permit. Part III, Paragraph E 12 of the 1997 Permit provides in part, as follows: "...The permittee shall submit to the Division of Water Quality and the Technology Review Workgroup by January 1, 2001, a report on the feasibility of achieving a target annual average color loading limit within the range of 48,000 — 52,000 lbs/day based on full implementation of the Near -Term Package. This report shall include all available data necessary to derive the lowest achievable annual average and monthly color loading limits... " This report is submitted to fulfill the requirements of Part III, Paragraph E 12. Based on the Mill's performance from January 1998 through December 2000, Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of 48,000 — 52, 000 pounds per day is feasible. I 700000 500000 400000 U) .0 o 300000 0 U 100000 All Aug-85 January 1, 2001 - Color Limit Feasibility Report Monthly Average Secondary Effluent Color (Ibs/day) January 1987 - October 2000 Apr-88 Jan-91 Oct-93 -+ SE Color Ibs/day Jui-96 Apr-99 Blue Ridge Paper Products, Inc. Figure 1 Canton Mill page 2 January 1, 2001—Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina II. Color Performance The Canton Mill has achieved a color reduction of over 85% since 1988 in the annual average amount of color discharged, as illustrated in Figure 1. The improved color performance is due to the Canton Modernization Project, full implementation of the "Near -Term Package" and continuous color management by the mill. The Near -Term Package includes the installation of BFRm on the mill's pine fiberline, implementation of best management practices (BMPs) detailed in the June 1, 1998 Color Technology Report, and partial BFR (Eo filtrate recycle) on the hardwood fiberline. These collective efforts have contributed to the mill's continuous and significant reduction in effluent color. The 1998 average annual color discharged was 50,386 lbs/day and the 1999 average annual color discharged was 41,048 lbs/day. The 2000 average annual color (through October) is 44,837 lbs/day. All of these values are within or below the target annual average color range of 48,000 — 52,000 lbs/day specified in Part III, Paragraph E 12 of the 1997 Permit. The 48,000 - 52,000 target range was selected because it was projected to result in significant mitigation in the occurrence and degree of color at the Hepco gage. Based upon North Carolina's minimum flow criterion (30Q2), historical flow records, and the January 1998 — October 2000 annual average color value of 45,458 lbs/day, it is expected that color in the Pigeon River at the Hepco gage will be less than 50 scu's (standard color units) 100% of the time at all flows above 30Q2. At all monthly average flows greater than the 30Q2 since January 1999, average monthly color at Hepco has been less than 50 scu's. Therefore, Blue Ridge Paper Product's actual color performance has resulted in significant mitigation in the occurrence and degree of color at the Hepco gage as projected by the 1997 Permit and Settlement Agreement. January 1, 2001— Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina III. Recommended Color Limits The January 1998 — October 2000 actual average annual color of 45,458 lbs/day and the January 2000 — October 2000 actual average annual color of 44,837 lbs/day are both below the target annual average color range of 48,000 — 52,000 lbs/day specified in Part III, Paragraph E 12 of the 1997 Permit. It was anticipated, and has now been demonstrated, that full implementation of the Near -Term package would achieve an annual average color within the 48,000 — 52,000 lbs/day range. 3.1 Review of Color Performance Data Based on a statistical evaluation of the mill's annual color, Blue Ridge Paper Products believes an annual average effluent color limit in the 48,000 — 52,000 lb/day range is achievable. Due to the limited data set available, it is appropriate to use a 99% confidence interval to extrapolate long term and continuing monthly and annual average effluent limitations. The January 1998 — October 2000 annual color average using a 99a' percentile distribution is 49,612 lbs/day. The January 2000 — October 2000 annual color average using a 990' percentile distribution is 48,911 lbs/day. These values are both within the 48,000 — 52,000 lb/day range. Based on a statistical review of the data and the limited data set available, Blue Ridge Paper Products, Inc. recommends an annual average effluent limit of 49,612 lbs/day. The January 1998 — October 2000 monthly color average using a 99`s percentile distribution is 59,796 lbs/day. The January 2000 — October 2000 monthly color average using a 99a' percentile distribution is 58,953 lbs/day. Based on a statistical review of the data and the limited data set available, Blue Ridge Paper Products recommends a monthly average effluent limit of 59,796 lbs/day. January 1, 2001— Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina III. Conclusion Blue Ridge Paper Products, Inc. believes it is feasible to achieve a target annual average color limit within the range of 48,000 — 52, 000 lbs/day. The Canton Mill recommends an average annual colorlimitof49,612.1bs/day and_an average monthly color limit of 59,796 lbs/day. These recommended color limits demonstrate the Canton Mill's commitment toward color reduction and continued color management. Using North Carolina's governing flow criteria (30Q2), historical flow records, and the recommended annual average color limit of 49,612 lbs/day, it is expected that color in the Pigeon River at the Hepco gage will be less than 50 true color units approximately 97% of the applicable time. TABLE January 1, 2001 Color Limit Feasibility Report Monthly Average Data - Max Month Calc Data Set = KS Normality test Autocorrelation= no. of obs. _ xbar stddev 95th safe MONTH from normal dist 99th safe MONTH from normal dist 95th safe YEAR from normal dist 99th safe YEAR from normal dist Ranked observations 95th percentile for max MONTH 100th percentile for max MONTH 111 /98-10/3112000 111 /2000-10131 /2000 normal normal 0.61 34 10 45478.5 44836 6145 6059 55556 54773 59796 58953 48388 47704 49612 48911 56809 55514 58542 58009 BLUE RIDGE PAPER PRODUCTS INC. December 28, 2000 Mr. Forrest Westall Regional Water Quality Supervisor North Carolina Department of Environment and Natural Resources 59 Woodfin Place Asheville, NC 28801 RE: NPDES Permit No. NC0000272, Blue Ridge Paper Products, Inc. Canton Mill January 1, 2001 Color Limit Feasibility Report Dear Mr. Westall: Attached is the January 1, 2001 Color Limit Feasibility Report required by Part III, Section E 12 of the Canton Mill's NPDES permit. This report is also required by the Settlement Agreement, paragraph 24, and the Revised Color Variance, paragraph SH. Blue Ridge Paper Products is submitting this report to you in your capacity as Regional Water Quality Supervisor for the Division of Water Quality and as a member of the Technology Review Workgroup. Blue Ridge Paper Products would appreciate you distributing the enclosed copies to the members of the Technology Review Workgroup. Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of 48,000 — 52,000 pounds per day is feasible. Due to the limited data set available, Blue Ridge Paper Products believes it is appropriate to use a 99 h percentile confidence interval to extrapolate long term and continuing monthly and annual average effluent limitations. Based on this statistical review of the available data from January 1998 - October 31, 2000 the Canton Mill recommends an annual average color limit of 49,612 Ibs/day and an average monthly color limit of 59,796 lbs/day. For the June 1, 2001 report, (required by Part III, Section E, paragraph 14, of the Canton Mill's NPDES Permit), Blue Ridge Paper Products recommends using a 95'h percentile confidence interval to statistically evaluate the monthly and annual average color discharge. Using a 95'h percentile statistical review of the limited data available from January 1998 — October 31, 2000 the annual average color is 48,388 lbs/day and the monthly average color is 55,556 lbs/day. Blue Ridge Paper Products believes the 95`h percentile confidence interval will be appropriate with the additional color data that will be available for the June 1, 2001 analysis. The attached Table includes the summary of the 99'h and 95'h percentile statistical data. Please call me at (828) 646-2033 or Derric Brown at (828) 646-2318 if you have any questions regarding this report. Sincerely, ��a''rt�IfYOL, Bob Williams Director - Environmental, Health and Safety Attachments 175 Main Street • P.O. Box 4000 Canton, North Carolina 28716 • Phone: 828-646-2000 Raising Your Expectations BLUERIDGE Copy: Keith Haynes North Carolina Department of Environment Health and Natural Resources 59 Woodfin Place Asheville, NC 28801 Technology Review Workgroup (via Division of Water Quality) January 1, 2001— Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina 1. Introduction The following report details the Canton Mill's ability to achieve a target annual average color limit in the 48,000 — 52,000 lb/day range in accordance with the requirements of the 1997 modified Color Variance and NPDES Permit. Part III, Paragraph E 12 of the 1997 Permit provides in part, as follows: "...The permittee shall submit to the Division of Water Quality and the Technology Review Workgroup by January 1, 2001, a report on the feasibility of achieving a target annual average color loading limit within the range of 48,000 — 52, 000 Ibs/day based on full implementation of the Near -Term Package. This report shall include all available data necessary to derive the lowest achievable annual average and monthly color loading limits... " This report is submitted to fulfill the requirements of Part III, Paragraph E 12. Based on the Mill's performance from January 1998 through December 2000, Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of 48,000 — 52, 000 pounds per day is feasible. 1 700000 500000 400000 N .0 o 300000 0 V 200000 100000 A Aug-85 January 1, 2001 - Color Limit Feasibility Report Monthly Average Secondary Effluent Color (Ibs/day) January 1987 - October 2000 Apr-88 Jan-91 Oct-93 --*—SE Color Ibs/day Jul-96 Apr-99 Blue Ridge Paper Products, Inc. Figure 1 Canton Mill page 2 January 1, 2001— Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina II. Color Performance The Canton Mill has achieved a color reduction of over 85% since 1988 in the annual average amount of color discharged, as illustrated in Figure 1. The improved color performance is due to the Canton Modernization Project, full implementation of the "Near -Term Package" and continuous color management by the mill. The Near -Term Package includes the installation of BFRm on the mill's pine fiberline, implementation of best management practices (BMPs) detailed in the June 1, 1998 Color Technology Report, and partial BFR (Eo filtrate recycle) on the hardwood fiberline. These collective efforts have contributed to the mill's continuous and significant reduction in effluent color. The 1998 average annual color discharged was 50,386 lbs/day and the 1999 average annual color discharged was 41,048 lbs/day. The 2000 average annual color (through October) is 44,837 lbs/day. All of these values are within or below the target annual average color range of 48,000 — 52,000 lbs/day specified in Part III, Paragraph E 12 of the 1997 Permit. The 48,000 - 52,000 target range was selected because it was projected to result in significant mitigation in the occurrence and degree of color at the Hepco gage. Based upon North Carolina's minimum flow criterion (30Q2), historical flow records, and the January 1998 — October 2000 annual average color value of 45,458 lbs/day, it is expected that color in the Pigeon River at the Hepco gage will be less than 50 scu's (standard color units) 100% of the time at all flows above 30Q2. At all monthly average flows greater than the 30Q2 since January 1999, average monthly color at Hepco has been less than 50 scu's. Therefore, Blue Ridge Paper Product's actual color performance has resulted in significant mitigation in the occurrence and degree of color at the Hepco gage as projected by the 1997 Permit and Settlement Agreement. 3 January 1, 2001— Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina III. Recommended Color Limits The January 1998 — October 2000 actual average annual color of 45,458 lbs/day and the January 2000 — October 2000 actual average annual color of 44,837 lbs/day are both below the target annual average color range of 48,000 — 52,000 lbs/day specified in Part III, Paragraph E 12 of the 1997 Permit. It was anticipated, and has now been demonstrated, that full implementation of the Near -Term package would achieve an annual average color within the 48,000 — 52,000 lbs/day range. 3.1 Review of Color Performance Data Based on a statistical evaluation of the mill's annual color, Blue Ridge Paper Products believes an annual average effluent color limit in the 48,000 — 52,000 lb/day range is achievable. Due to the limited data set available, it is appropriate to use a 99% confidence interval to extrapolate long term and continuing monthly and annual average effluent limitations. The January 1998 — October 2000 annual color average using a 99`h percentile distribution is 49,612 lbs/day. The January 2000 — October 2000 annual color average using a 99'h percentile distribution is 48,911 lbs/day. These values are both within the 48,000 — 52,000 lb/day range. Based on a statistical review of the data and the limited data set available, Blue Ridge Paper Products, Inc. recommends an annual average effluent limit of 49,6121bs/day. The January 1998 — October 2000 monthly color average using a 991h percentile distribution is 59,796 lbs/day. The January 2000 — October 2000 monthly color average using a 99`h percentile distribution is 58,953 lbs/day. Based on a statistical review of the data and the limited data set available, Blue Ridge Paper Products recommends a monthly average effluent limit of 59,7961bs/day. 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 49,6121bs/day, it is expected that color in the Pigeon River at the Hepeo gage will be less than 50 true color units approximately 97% of the applicable time. TABLE January 1, 2001 Color Limit Feasibility Report Monthly Average Data - Max Month Calc Data Set = KS Normality test Autocorrelation= no. of obs. _ xbar stddev 95th safe MONTH from normal dist 99th safe MONTH from normal dist 95th safe YEAR from normal dist 99th safe YEAR from normal dist Ranked observations 95th percentile for max MONTH 100th percentile for max MONTH 1 /1198-10131 /2000 1 /112000-10131 /2000 normal normal 0.61 34 10 45478.5 44836 6145 6059 55556 54773 59796 58953 48388 47704 49612 48911 56809 55514 58642 58009 BLUE RIDGE PAPER PRODUCTS INC. December 28, 2000 Mr. Forrest Westall Regional Water Quality Supervisor North Carolina Department of Environment and Natural Resources 59 Woodfin Place Asheville, NC 28801 RE: NPDES Permit No. NC0000272, Blue Ridge Paper Products, Inc. Canton Mill January 1, 2001 Color Limit Feasibility Report Dear Mr. Westall: Attached is the January 1, 2001 Color Limit Feasibility Report required by Part III, Section E 12 of the Canton Mill's NPDES permit. This report is also required by the Settlement Agreement, paragraph 24, and the Revised Color Variance, paragraph 5H. Blue Ridge Paper Products is submitting this report to you in your capacity as Regional Water Quality Supervisor for the Division of Water Quality and as a member of the Technology Review Workgroup. Blue Ridge Paper Products would appreciate you distributing the enclosed copies to the members of the Technology Review Workgroup. Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of 48,000 — 52,000 pounds per day is feasible. Due to the limited data set available, Blue Ridge Paper Products believes it is appropriate to use a 99 h percentile confidence interval to extrapolate long term and continuing monthly and annual average effluent limitations. Based on this statistical review of the available data from January 1998 - October 31, 2000 the Canton Mill recommends an annual average color limit of 49,612 lbs/day and an average monthly color limit of 59,796 lbs/day. For the June 1, 2001 report, (required by Part III, Section E, paragraph 14, of the Canton Mill's NPDES Permit), Blue Ridge Paper Products recommends using a 95'h percentile confidence interval to statistically evaluate the monthly and annual average color discharge. Using a 95'1' percentile statistical review of the limited data available from January 1998— October 31, 2000 the annual average color is 48,388 lbs/day and the monthly average color is 55,556 Ibs/day. Blue Ridge Paper Products believes the 95 h percentile confidence interval will be appropriate with the additional color data that will be available for the June 1, 2001 analysis. The attached Table includes the summary of the 99 h and 95`h percentile statistical data. Please call me at (828) 646-2033 or Derric Brown at (828) 646-2318 if you have any questions regarding this report. Sincerely, C.1�►� eir`-°ItYOL Bob Williams Director - Environmental, Health and Safety Attachments 175 Main Street • P.O. Box 4000 Canton, North Carolina 28716 • Phone: 828-646-2000 Raising Your Expectations BLUE RIDGE PAPER PRODUCTS INC Copy: Keith Haynes North Carolina Department of Environment Health and Natural Resources 59 Woodfin Place Asheville, NC 28801 Technology Review Workgroup (via Division of Water Quality) January 1, 2001— Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina I. Introduction The following report details the Canton Mill's ability to achieve a target annual average color limit in the 48,000 — 52,000 lb/day range in accordance with the requirements of the 1997 modified Color Variance and NPDES Permit. Part III, Paragraph E 12 of the 1997 Permit provides in part, as follows: "...The permittee shall submit to the Division of Water Quality and the Technology Review Workgroup by January 1, 2001, a report on the feasibility of achieving a target annual average color loading limit within the range of 48,000 — 52,000 Ibs/day based on full implementation of the Near -Term Package. This report shall include all available data necessary to derive the lowest achievable annual average and monthly color loading limits... " This report is submitted to fulfill the requirements of Part III, Paragraph E 12. Based on the Mill's performance from January 1998 through December 2000, Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of 48,000 — 52, 000 pounds per day is feasible. 1 700000 .rrrrrr•rr 500000 A 400000 rn L- 0 300000 0 V 200000 100000 Aug-85 January 1, 2001 - Color Limit Feasibility Report Monthly Average Secondary Effluent Color (Ibs/day) January 1987 - October 2000 Apr-88 Jan-91 Oct-93 —.—SE Color Ibs/day Jul-96 Apr-99 Blue Ridge Paper Products, Inc. Figure 1 Canton Mill page 2 January 1, 2001— Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina Il. Color Performance The Canton Mill has achieved a color reduction of over 85% since 1988 in the annual average amount of color discharged, as illustrated in Figure 1. The improved color performance is due to the Canton Modernization Project, full implementation of the "Near -Term Package" and continuous color management by the mill. The Near -Term Package includes the installation of BFRTM on the mill's pine fiberline, implementation of best management practices (BMPs) detailed in the June 1, 1998 Color Technology Report, and partial BFR (Eo filtrate recycle) on the hardwood fiberline. These collective efforts have contributed to the mill's continuous and significant reduction in effluent color. The 1998 average annual color discharged was 50,386 lbs/day and the 1999 average annual color discharged was 41,048 lbs/day. The 2000 average annual color (through October) is 44,8371bs/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. January 1, 2001— Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina III. Recommended Color Limits The January 1998 — October 2000 actual average annual color of 45,458 lbs/day and the January 2000 — October 2000 actual average annual color of 44,837 lbs/day are both below the target annual average color range of 48,000 — 52,000 lbs/day specified in Part III, Paragraph E 12 of the 1997 Permit. It was anticipated, and has now been demonstrated, that full implementation of the Near -Term package would achieve an annual average color within the 48,000 — 52,000 lbs/day range. 3.1 Review of Color Performance Data Based on a statistical evaluation of the mill's annual color, Blue Ridge Paper Products believes an annual average effluent color limit in the 48,000 — 52,000 lb/day range is achievable. Due to the limited data set available, it is appropriate to use a 99% confidence interval to extrapolate long term and continuing monthly and annual average effluent limitations. The January 1998 — October 2000 annual color average using a 990' percentile distribution is 49,612 lbs/day. The January 2000 — October 2000 annual color average using a 99 h percentile distribution is 48,911 lbs/day. These values are both within the 48,000 — 52,000 lb/day range. Based on a statistical review of the data and the limited data set available, Blue Ridge Paper Products, Inc. recommends an annual average effluent limit of 49,612 lbs/day. The January 1998 — October 2000 monthly color average using a 99"' percentile distribution is 59,796 lbs/day. The January 2000 — October 2000 monthly color average using a 990' percentile distribution is 58,953 lbs/day. Based on a statistical review of the data and the limited data set available, Blue Ridge Paper Products recommends a monthly average effluent limit of 59,796 lbs/day. 0 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. TABLE January 1, 2001 Color Limit Feasibility Report Monthly Average Data - Max Month Calc Data Set = KS Normality test Autocorrelation= no. of obs. _ xbar- stddev 95th safe MONTH from normal dist 99th safe MONTH from normal dist 95th safe YEAR from normal dist 99th safe YEAR from normal dist Ranked observations 95th percentile for max MONTH 100th percentile for max MONTH 1 /1198-10/3112000 1 /112000-10/3112000 normal normal 0.61 34 10 45478.5 44836 6145 6059 55556 54773 59796 58953 48388 47704 49612 48911 56809 55514 58542 58009 , BLUE RIDGE PAPER PRODUCTS INC. December 28, 2000 Mr. Forrest Westall Regional Water Quality Supervisor North Carolina Department of Environment and Natural Resources 59 Woodfin Place Asheville, NC 28801 RE: NPDES Permit No. NC0000272, Blue Ridge Paper Products, Inc. Canton Mill January 1, 2001 Color Limit Feasibility Report Dear Mr. Westall: Attached is the January 1, 2001 Color Limit Feasibility Report required by Part III, Section E 12 of the Canton Mill's NPDES permit. This report is also required by the Settlement Agreement, paragraph 24, and the Revised Color Variance, paragraph 5H. Blue Ridge Paper Products is submitting this report to you in your capacity as Regional Water Quality Supervisor for the Division of Water Quality and as a member of the Technology Review Workgroup. Blue Ridge Paper Products would appreciate you distributing the enclosed copies to the members of the Technology Review Workgroup. Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of 48,000 — 52,000 pounds per day is feasible. Due to the limited data set available, Blue Ridge Paper Products believes it is appropriate to use a 99u' percentile confidence interval to extrapolate long term and continuing monthly and annual average effluent limitations. Based on this statistical review of the available data from January 1998 - October 31, 2000 the Canton Mill recommends an annual average color limit of 49,612 Ibs/day and an average monthly color limit of 59,796 lbs/day. For the June 1, 2001 report, (required by Part III, Section E, paragraph 14, of the Canton Mill's NPDES Permit), Blue Ridge Paper Products recommends using a 95a' percentile confidence interval to statistically evaluate the monthly and annual average color discharge. Using a 95`s percentile statistical review of the limited data available from January 1998— October 31, 2000 the annual average color is 48,388 lbs/day and the monthly average color is 55,556 Ibs/day. Blue Ridge Paper Products believes the 95's percentile confidence interval will be appropriate with the additional color data that will be available for the June 1, 2001 analysis. The attached Table includes the summary of the 99"' and 95i' percentile statistical data. Please call me at (828) 646-2033 or Derric Brown at (828) 646-2318 if you have any questions regarding this report. Sincerely, Bob Williams Director - Environmental, Health and Safety Attachments 175 Main Street • P.O. Box 4000 Canton, North Carolina 28716 • Phone: 828-646-2000 Raising Your Expectations BLUE RIDGE .AMEX PEGDUCTf INC Copy: Keith Haynes North Carolina Department of Environment Health and Natural Resources 59 Woodfin Place Asheville, NC 28801 Technology Review Workgroup (via Division of Water Quality) January 1, 2001— Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina I. Introduction The following report details the Canton Mill's ability to achieve a target annual average color limit in the 48,000 — 52,000 lb/day range in accordance with the requirements of the 1997 modified Color Variance and NPDES Permit. Part III, Paragraph E 12 of the 1997 Permit provides in part, as follows: "...The permittee shall submit to the Division of Water Quality and the Technology Review Workgroup by January 1, 2001, a report on the feasibility of achieving a target annual average color loading limit within the range of 48,000 — 52,000 Ibs/day based on full implementation of the Near -Term Package. This report shall include all available data necessary to derive the lowest achievable annual average and monthly color loading limits... " This report is submitted to fulfill the requirements of Part III, Paragraph E 12. Based on the Mill's performance from January 1998 through December 2000, Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of 48,000 — 52, 000 pounds per day is feasible. 1 700000 500000 400000 rn .O L- o 300000 O V 200000 100000 m Aug-85 January 1, 2001 - Color Limit Feasibility Report Monthly Average Secondary Effluent Color (Ibs/day) January 1987 - October 2000 Apr-88 Jan-91 Oct-93 SE Color Ibs/day Jul-96 Apr-99 Blue Ridge Paper Products, Inc. Figure 1 Canton Mill page 2 January 1, 2001—Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina Il. Color Performance The Canton Mill has achieved a color reduction of over 85% since 1988 in the annual average amount of color discharged, as illustrated in Figure 1. The improved color performance is due to the Canton Modernization Project, full implementation of the "Near -Term Package" and continuous color management by the mill. The Near -Term Package includes the installation of BFRTM on the mill's pine fiberline, implementation of best management practices (BMPs) detailed in the June 1, 1998 Color Technology Report, and partial BFR (Eo filtrate recycle) on the hardwood fiberline. These collective efforts have contributed to the mill's continuous and significant reduction in effluent color. The 1998 average annual color discharged was 50,386 lbs/day and the 1999 average annual color discharged was 41,048 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 occumnce and degree of color at the Hepco gage as projected by the 1997 Permit and Settlement Agreement. January 1, 2001— Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina III. Recommended Color Limits The January 1998 — October 2000 actual average annual color of 45,458 lbs/day and the January 2000 — October 2000 actual average annual color of 44,837 lbs/day are both below the target annual average color range of 48,000 — 52,000 lbs/day specified in Part III, Paragraph E 12 of the 1997 Permit. It was anticipated, and has now been demonstrated, that full implementation of the Near -Term package would achieve an annual average color within the 48,000 — 52,000 lbs/day range. 3.1 Review of Color Performance Data Based on a statistical evaluation of the mill's annual color, Blue Ridge Paper Products believes an annual average effluent color limit in the 48,000 — 52,000 lb/day range is achievable. Due to the limited data set available, it is appropriate to use a 99% confidence interval to extrapolate long term and continuing monthly and annual average effluent limitations. The January 1998 — October 2000 annual color average using a 99u' percentile distribution is 49,6121bs/day. The January 2000 — October 2000 annual color average using a 99u' percentile distribution is 48,911 lbs/day. These values are both within the 48,000 — 52,000 lb/day range. Based on a statistical review of the data and the limited data set available, Blue Ridge Paper Products, Inc. recommends an annual average effluent limit of 49,612 lbs/day. The January 1998 — October 2000 monthly color average using a 991' percentile distribution is 59,796 lbs/day. The January 2000 — October 2000 monthly color average using a 99 h percentile distribution is 58,953 lbs/day. Based on a statistical review of the data and the limited data set available, Blue Ridge Paper Products recommends a monthly average effluent limit of 59,796 lbs/day. 0 January 1, 2001 — Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina III. Conclusion Blue Ridge Paper Products, Inc. believes it is feasible to achieve a target annual average color limit within the range of 48,000 — 52, 000 lbs/day. The Canton Mill recommends an average annual color limit of49,612_lbs/day and an average monthly color limit of 59,796 lbs/day. These recommended color limits demonstrate the Canton Mill's commitment toward color reduction and continued color management. Using North Carolina's governing flow criteria (30Q2), historical flow records, and the recommended annual average color limit of 49,612 lbs/day, it is expected that color in the Pigeon River at the Hepco gage will be less than 50 true color units approximately 97% of the applicable time. TABLE January 1, 2001 Color Limit Feasibility Report Monthly Average Data - Max Month Calc Data Set = KS Normality test Autocorrelation= no. of obs. _ xbar stddev 95th safe MONTH from normal dist 99th safe MONTH from normal dist 95th safe YEAR from normal dist 99th safe YEAR from normal dist Ranked observations 95th percentile for max MONTH 100th percentile for max MONTH 1 /1 /98-10/31 /2000 1 /1 /2000-10/31 /2000 normal normal 0.61 34 10 45478.5 44836 6145 6059 55556 54773 59796 58953 48388 47704 49612 48911 56809 55514 58542 58009 r, BLUE RIDGE 1 PAPER PRODUCTS INC. December 28, 2000 Mr. Forrest Westall Regional Water Quality Supervisor North Carolina Department of Environment and Natural Resources 59 Woodfin Place Asheville, NC 28801 RE: NPDES Permit No. NC0000272, Blue Ridge Paper Products, Inc. Canton Mill January 1, 2001 Color Limit Feasibility Report Dear Mr. Westall: Attached is the January 1, 2001 Color Limit Feasibility Report required by Part III, Section E 12 of the Canton Mill's NPDES permit. This report is also required by the Settlement Agreement, paragraph 24, and the Revised Color Variance, paragraph 5H. Blue Ridge Paper Products is submitting this report to you in your capacity as Regional Water Quality Supervisor for the Division of Water Quality and as a member of the Technology Review Workgroup. Blue Ridge Paper Products would appreciate you distributing the enclosed copies to the members of the Technology Review Workgroup. Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of 48,000 — 52,000 pounds per day is feasible. Due to the limited data set available, Blue Ridge Paper Products believes it is appropriate to use a 99`' percentile confidence interval to extrapolate long term and continuing monthly and annual average effluent limitations. Based on this statistical review of the available data from January 1998 - October 31, 2000 the Canton Mill recommends an annual average color limit of 49,612 lbs/day and an average monthly color limit of 59,796 lbs/day. For the June 1, 2001 report, (required by Part III, Section E, paragraph 14, of the Canton Mill's NPDES Permit), Blue Ridge Paper Products recommends using a 95`h percentile,confidence interval to statistically evaluate the monthly and annual average color discharge. Using a 95`h percentile statistical review of the limited data available from 4anuary 1998— October 31, 2000 the annual average color is 48,388 lbs/day and the monthly average color is 55,556 Ibs/day. Blue Ridge Paper Products believes the 95'h percentile confidence interval will be appropriate with the additional color data that will be available for the June 1, 2001 analysis. The attached Table includes the summary of the 99 h and 95°1 percentile statistical data. Please call me at (828) 646-2033 or Derric Brown at (828) 646-2318 if you have any questions regarding this report. Sincerely, E&a,rL61rio- Bob Williams Director - Environmental, Health and Safety Attachments 175 Main Street • P.O. Box 4000 Canton, North Carolina 28716 • Phone: 828-646-2000 Raising Your Expectations BLUE RIDGE PAPER PRODUCTS INC. Copy: Keith Haynes North Carolina Department of Environment Health and Natural Resources 59 Woodfin Place Asheville, NC 28801 Technology Review Workgroup (via Division of Water Quality) January 1, 2001— Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina I. Introduction The following report details the Canton Mill's ability to achieve a target annual average color limit in the 48,000 — 52,000 lb/day range in accordance with the requirements of the 1997 modified Color Variance and NPDES Permit. Part III, Paragraph E 12 of the 1997 Permit provides in part, as follows: "...The permittee shall submit to the Division of Water Quality and the Technology Review Workgroup by January 1, 2001, a report on the feasibility of achieving a target annual average color loading limit within the range of 48,000 — 52,000 Ibs/day based on full implementation of the Near -Term Package. This report shall include all available data necessary to derive the lowest achievable annual average and monthly color loading limits... " This report is submitted to fulfill the requirements of Part III, Paragraph E 12. Based on the Mill's performance from January 1998 through December 2000, Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of 48,000 — 52, 000 pounds per day is feasible. 1 700000 500000 A t� $ 400000 N J? C 0 300000 O U 200000 100000 A Aug-85 January 1, 2001 - Color Limit Feasibility Report Monthly Average Secondary Effluent Color (Ibs/day) January 1987 - October 2000 Apr-88 Jan-91 Oct-93 SE Color Ibs/day Jul-96 Apr-99 Blue Ridge Paper Products, Inc. Figure 1 Canton Mill page 2 January 1, 2001— Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina II. Color Performance The Canton Mill has achieved a color reduction of over 85% since 1988 in the annual average amount of color discharged, as illustrated in Figure 1. The improved color performance is due to the Canton Modernization Project, full implementation of the "Near -Term Package" and continuous color management by the mill. The Near -Term Package includes the installation of BFRM on the mill's pine fiberline, implementation of best management practices (BMPs) detailed in the June 1, 1998 Color Technology Report, and partial BFR (Eo filtrate recycle) on the hardwood fiberline. These collective efforts have contributed to the mill's continuous and significant reduction in effluent color. The 1998 average annual color discharged was 50,3861bs/day and the 1999 average annual color discharged was 41,048 Ibs/day. The 2000 average annual color (through October) is 44,8371bs/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. January 1, 2001— Color Limit Feasibility Report Blue Ridge Paper Products, Inc. Canton, North Carolina M. Recommended Color Limits The January 1998 — October 2000 actual average annual color of 45,4581bs/day and the January 2000 — October 2000 actual average annual color of 44,837 lbs/day are both below the target annual average color range of 48,000 — 52,000 lbs/day specified in Part III, Paragraph E 12 of the 1997 Permit. It was anticipated, and has now been demonstrated, that full implementation of the Near -Term package would achieve an annual average color within the 48,000 — 52,000 lbs/day range. 3.1 Review of Color Performance Data Based on a statistical evaluation of the mill's annual color, Blue Ridge Paper Products believes an annual average effluent color limit in the 48,000 — 52,000 lb/day range is achievable. Due to the limited data set available, it is appropriate to use a 99% confidence interval to extrapolate long term and continuing monthly and annual average effluent limitations. The January 1998 — October 2000 annual color average using a 99`h percentile distribution is 49,6121bs/day. The January 2000 — October 2000 annual color average using a 991h percentile distribution is 48,911 lbs/day. These values are both within the 48,000 — 52,000 lb/day range. Based on a statistical review of the data and the limited data set available, Blue Ridge Paper Products, Inc. recommends an annual average effluent limit of 49,6121bs/day. The January 1998 — October 2000 monthly color average using a 99`h percentile distribution is 59,796 lbs/day. The January 2000 — October 2000 monthly color average using a 99`h percentile distribution is 58,953 lbs/day. Based on a statistical review of the data and the limited data set available, Blue Ridge Paper Products recommends a monthly average effluent limit of 59,796 lbs/day. Ll 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. TABLE January 1, 2001 Color Limit Feasibility Report Monthly Average Data - Max Month Calc Data Set = KS Normality test Autocorrelation= no. of obs. _ xbar- stddev 95th safe MONTH from normal dist 99th safe MONTH from normal dist 95th safe YEAR from normal dist 99th safe YEAR from normal dist Ranked observations 95th percentile for max MONTH 100th percentile for max MONTH 1/1/98-10/31/2000 111/2000-10/3112000 normal normal 0.61 34 10 45478.5 44836 6145 6059 55556 54773 59796 58953 48388 47704 49612 48911 56809 55514 58542 58009 2000B Applications Project ID 2000E-402 Applicant Name Haywood Waterways Asso. & Haywood SWCD Applicant Type Non-profit Purpose Restoration Request S $677,555 Total$ $1,077,810 Duration (months) 24 Watershed French Broad Region Western `l County Haywood Contact Mr. Gordon Small Title Organization Name Haywood Waterways Asso. & Haywood SWCD Address 1496 Fern Trail City Waynesville state NC Postal Code 28786- Work Phone (828) 452-5190 Mobile Phone Fax Number (828) 452-3323 E-Mail gordons891@aol.com 4.4r � V�v�•� 1 /aL d ��� / y v Tuesday, January 01, 1001 • now HAYWOOD WATERWAYS ASSOCIATION, INC. NARRATIVE PROPOSAL Project Description: This project is focused on restoring degraded waters by sediment reduction and storm water management in two sub - watersheds of the Pigeon River Watershed The water quality improvement goals are: (1) reducing sediment deposition in Richland Creek and Lake Junaluska, (2) reducing erosion and sedimentation from eroding river banks in the Canton Recreation Park at Canton, NC, and (3) improving sediment monitoring in the Richland Creek watershed There are 5 parts to this application — (a) restoring eroding creek banks and pastures, and reducing animal access points in the Richland Creek watershed; (b) a demonstration project to control storm water runoff and erosion from a small subdivision at the headwaters of Richland Creek (c) improved monitoring in the Richland Creek watershed; (d) restoring eroding river banks and managing storm water runoff at the Canton Recreation Park,(e) public information and awareness. The application is requesting $677,555. A campaign is underway to find the money to remove sediment from Lake Junaluska. However, the long-term answer is to reduce the rate of sedimentation. In order to effectively address this issue, the primary sources of the sedimentation had to be identified HWA had previously entered into a cooperative agreement with the Tennessee Valley Authority (TVA) for an Integrated Pollutant Source Identification (IPSI) project in 1999. The project was funded with a Pigeon River Fund grant. This $140,000 color infrared aerial survey and non -point source inventory generated a digital geographic database with information on landscape features that are sources of non -point pollution. Computer models provided estimates of soil loss and pollutant loading by sub -watershed Using the IPSI data, it was learned that eroding stream banks contribute 47% of the sediment to streams in the Richland Creek Watershed. Eroding roads, ditches, and road banks contribute 32%. Pastures contribute 9%, other uses 6%. animal PO BOX 389 • WAYNESVILLE, NC • 28786 PHONE: 828-452-5198 OR 828-456-5195 • FAX: 828.452-8829 access 5%, and cropland I%. Based on the IPSI data, and other water quality information, the TAC is developing a Watershed Action Plan to reduce non - point source pollution in the Pigeon River Watershed. The Richland Creek sub -watershed has been identified as a priority sub -watershed because of the impacts of sediment on Lake Junaluska and the rapidly changing land uses in this sub - watershed The draft plan incorporates a schedule to reducing the current sources of sediment by 37% in 5 years, based on available resources and anticipated landowner response. This application in the first of several to request funds to accomplish this 5-year sediment reduction goal. Subsequent applications will be submitted as landowners are contacted and specific projects developed Integrating Haywood County's Land Records GIS information with the TVA data identified parcels of land with eroding stream banks. Limiting the potential contact list to larger parcels with significant percentages of eroding stream banks refined the list to 35 landowners. The GIS information also identified which of the 35 landowners had eroding pasture lands and animal access issues. The Haywood Soil and Water Conservation District contacted several landowners identified in this database. The District personnel discussed opportunities to improve pasture conditions when talking to landowners about their eroding stream banks. All work was proposed on the basis of a 20% match from the landowners. Eleven landowners agreed to participate. These 11 properties include 11,500 feet of eroding stream banks, or about 20% of the eroding stream banks in the Lake Junaluska watershed The work to be done to stabilize these banks include whole -tree revetments, rock veins, some bank hardening and shaping, installation of root wads, and establishing riparian buffers. An additional 12 acres of pasture will be restored on one property, and 5 animal access points will be eliminated The GIS data was also used to identify roads with erosion problems — the second major cause of sedimentation in Richland Creek streams. A field review was conducted to identify opportunities to demonstrate practices that effectively manage storm water and reduce erosion from roads in mountainside subdivisions. Many eroding road banks were located within current developments and industrial projects where the developer is still responsible for limiting erosion. In some cases, the scope and scale of the needs were too large to serve as an initial demonstration project. However, the Balsam Meadows subdivision is a small, private development on the headwaters of Richland Creek. It is well suited for demonstrating erosion control practices along unpaved roads. The original developer did a poor job of locating roads and installing appropriate drainage and storm water controls. The development went bankrupt, and was subsequently purchased by a local Realtor who has been selling the unsold lots. The homeowners are completing the formation of a non-profit property owners association. The landowners are willing to participate in this demonstration. The road conditions represent common issues for mountainside development in the Pigeon River Watershed There are 2400 feet of gravel road in this small development. The work includes installing 10 culverts and energy dissipating structures, reshaping and revegetating eroding cut banks, hardening about 1,000 feet of ditch lines, installing water dispersion structures, and otherwise directing concentrated storm water flows out of problem areas. The application includes funds for sediment monitoring stations above and below Lake Junaluska as well as 10 WIN sites in the Richland Creek Watershed Sediment monitoring is a new -effort to track changes over time in sediment loads in the most impacted Pigeon River sub -watersheds. It will include bed load and proportional sampling. Staff from the Coweeta Hydrologic Laboratory will install the proportional samplers. This enhanced monitoring will provide needed information about the nature of the sediment; how much is being trapped by the lake; help develop sediment models; track trends; and assess the effectiveness of BMPs over time. Part of this application provides funding to reduce sedimentation and erosion from stream banks in the Canton Recreation Park. This popular site has about 1,000 feet of eroding stream banks adjacent to the Pigeon River. The proposed practices include stabilizing the eroding banks with appropriate structures, managing storm water, and revegetating eroding banks by planting trees and shrubs. The cooperation by the town of Canton at this popular site will greatly increase awareness of non -point pollution issues within the Pigeon River Watershed The public information component of this application includes printing and distribution of the Haywood County Watershed Action Plan, currently being completed. It will also provide funding for development and publication of a "user-friendly" introduction to BMPs in Haywood County, reprinting of a HWA publication entitled "It's Not Just Dirt", and several public forams focused on the results of the watershed action plan planning process. This component is an on -going effort to increase public awareness and support, encourage landowner participation, and action by local units of government to develop practices and procedures that will reduce future non -point pollution problems. Water quality objectives and how they will be achieved The primary objective of all the proposed practices and actions will be to reduce sedimentation in the Pigeon River Watershed, with a focus on Richland Creek and Lake Junaluska as well as the Upper Pigeon sub -watershed. This will be done by applying BMPs to eroding stream banks, pastures, animal access points, and eroding roads where landowners have agreed to participate. The staff of the HS&WCD and NRCS will manage the design and application of practices. The draft of the watershed action plan proposes to reduce the sediment load from current sources in the Richland Creek sub - watershed by 37% over the next 5 years. This application will address about a third of this sedimentation reduction goal (10%). In addition, these practices will serve as demonstration projects for other landowners with similar erosion problems. The above work addresses current problems. However, it is also necessary that future sediment sources are prevented if this work is to have lasting value Carrying out these projects on the Lake Junaluska watershed and the Canton Recreation Park will serve as visible reminders of the care we need to take of our watershed. Local newspapers have demonstrated an eagerness to highlight any conservation efforts in this area. These projects over the next two years will provide numerous opportunities for newspaper articles, tours, conservation columns, and other media to focus on the situation in the Pigeon River Watershed Lake Junaluska is a high profile issue focused squarely on the consequences of accelerated erosion and sedimentation Following through with prompt action from the conservation community demonstrates a level of commitment that can help lead the way for the more difficult changes by local governments and others. The monitoring stations will provide information as to the nature, source, and rate of change of sedimentation over time in the Richland Creek Watershed. This information is needed to not only assess the effects of practices, but to effectively characterize the problem with the public as well as various levels of government. Total funds required for the project: The total funds required for this project are $1,077,810, with $677,555 of that total being requested by this application. Other possible funding sources for the project We anticipate receiving funds from an EPA Section 319 Grant in April of 2001. These funds are earmarked for Fines Creek and Hyatt Creek. The work in Hyatt Creek will help accomplish the proposed 37% sediment reduction goal over the next 5 years. The North Carolina Agriculture Cost Share Program can provide funds for BMPs. Since only about a maximum of $80,000 has been available in any given year from this source, it has limited capability to make substantive impacts. It is not earmarked for the Richland Creek Watershed The work is normally distributed throughout Haywood County. The North Carolina Wetland Restoration Fund is another source of funding, particularly for stream bank stabilization. There is one Wetland Restoration project currently under consideration at this time — the 303(d) listed Hurricane Creek watershed in the Lower Pigeon sub -watershed Depending on the outcome of that project, additional funds may be requested for other needs. Need for the project: Lake Junaluska is an important water resource for western North Carolina. Completed in 1914, this 200-acre lake hosts thousands of visitors to the area each year. The annual economic contribution to Haywood County from payroll, general expenditures, and tourist monies exceeds $30 million. The lake is a place of beauty that is a major recreation center for visitors and residents alike. It is a part of the "sense of place" for this part of North Carolina. All this is at risk. As with any reservoir, sedimentation is a fad of life. In the case of Lake Junaluska, all sediment arriving in the lake is generated by activities within the Richland Creek Watershed However, the sediment loads being delivered to Lake Junaluska far exceed natumlly occurring levels. Over the years, the Assembly has spent hundreds of thousands of dollars removing sediment from the Lake. However, sediment is arriving at such a rate that this work does not keep up with deposition. This grant application is the first in a series to focus specifically on this problem. Richland Creek is a State designated trout stream. It is also the most heavily impacted and changing sub -watershed in the Pigeon River Watershed Current V WIN data is indicating declining water quality in some segments of the stream. This trend needs to be reversed. The Richland Creek Watershed and the Lake Junaluska problems provide an outstanding opening for exploring the best ways to maintain economic development without destroying our natural resources. However, in order to participate in that debate, the conservation community needs to demonstrate that these problems can be addressed in a positive way. This application is a commitment to work with the community in cleaning up the waterways. Sincere Ronald J. Moser Director, Haywood Waterways Association, Inc. November 30, 2000 CLEAN WATER MANAGEMENT TRUST FUND 2313-B Executive Park Circle CW,yN Greenville, North Carolina 27834 (252) 830-3222 q APPLICATION FORM �F� whey Application Closing: December 1, 2000 cat Proposals postmarked on or before December 1, 2000 will be considered during this funding cycle. (A postage meter tape from an agency or business is not adequate to verify mailing by the due date). Proposals postmarked after December 1, 2000 will be considered during the subsequent cycle scheduled to close on June 1, 2001. CWMTF is not able to accept applications by facsimile. Application materials should not be bound in any way, and all materials should be suitable for photocopy in black and white. FOR OFFICE USE: APPLICANT NUMBER: (Detailed instructions on page 2) Project: Objective: Restoration of degraded water Primary use: Restore degraded lands for their ability to protect water quality Secondary use:_ Improve stormwater controls and management Funding sought from CWMTF: $677,555 Total Cost of Project: 1,077,810 Duration: 2 years Location: Region of NC: (circle one) estern Central Eastern County: Haywood River Basin: French Broad Stream Segment: Pigeon River (Richland Creek & Upper Pigeon River) Latitude/Longitude: 35029'/82059' Project Street Address (if applicable): Applicant: Organization Name: Haywood Waterways Association. Inc. and Haywood Soil & Water Conservation District Eligible Applicant Type: Non-profit (HWA) Fed Tax ID#: 56-2108874 (HWA) Contact: Name: Gordon Small Mailing Address: 1496 Fern Trail City: Waynesville Zip code: 28786 Phone: 828-452-5190 Fax: 828-452-3323 E-mail: Fordons891Aaol.com "Most of this application will be evaluated according to CWMTF quantitative criteria, and will yield a "score" from 0-165 points; however, Trustees will also consider non -quantitative criteria that are identified in CWMTF published guidelines. Answers should he direct, thorouglt and concise. Please limit responses to space available an the form. Project: (Up to 135 points**) 045 points: (1) To what extent will the proposed project either (a) restore degraded waters, or (b) protect relatively unpolluted waters. This application is the first step in a 5-year program to reduce sedimentation in the Lake Junaluska watershed from existing sources by 37%. The practices included in this 2-year project will reduce pollution from existing sources by 10%. This demonstrated commitment by conservation agencies and organizations will focus attention on the need to prevent future problems, provide landowner information and incentives, and provide improved sediment monitoring information. The work at the Canton Recreation Park will restore 1000 feet of eroding river bank and provide a daily demonstration to hundreds of residents as to the source of much of the sediment in area streams. 0-25 points: Describe any special significance of waters (in terms of NC-DWQ water quality classification, a g. High Quality or Impaired) to be enhanced, restored or protected by the project. Note also any special recreational, educational or economic values of specific waters. Lake Junaluska is a 200-acre body of water drawing thousands of visitors to the area each year. The annual economic contribution to Haywood County from payroll, general expenditures, and tourist monies exceeds $30 million. There are 750 privately owned residences around the lake that contribute $74,000,000 to the tax base of Haywood County, and about $370,000 in tax revenue each year. It provides summer employment for over 400 people, and has about 190 on staff during the winter months. The lake is a place of beauty that is a major recreation center for visitors and residents alike. It is a clean industry, depending on the continued presence of the water resource that is Lake Junaluska. 0-20 points: What does the NC -Division of Water Quality Basinwide Management Plan say about the specific waters, which will be restored or protected by your project? (Make page specific references to the plan and explain how your project will solve documented problems and ensure protection or restoration). Page 98 of the French Broad River Basinwide Water Quality Plan describes Lake Junaluska as having problems with sedimentation and eutrophication. The report states that sedimentation has increased primarily because of residential and commercial growth in the watershed. This application directly addresses the concern in the Basinwide Plan by reducing sedimentation. The primary sources of sedimentation have been identified and landowners contacted The project addresses eroding stream banks and the roads associated with development — the two most significant sources of sedimentation in this watershed. 0-20 points: What will be the measurable and enduring outcomes of the project? An immediate reduction of 10% in sedimentation from existing sources in the Lake Junaluska (LJ) watershed Increased public and landowner support for achieving the 5-year goal of a 37o/u reduction in sedimentation in the LJ watershed Over 12,000 feet of eroding stream banks, 2,400 feet of eroding road banks will be stabilized Sediment monitoring will provide conservation agencies and local governments with a needed assessment and planning tool. Public awareness of and participation in water quality issues will be increased BMP examples will provide effective technology transfer to residents of western North Carolina. The completed watershed action plan will provide focus to efforts to reduce non -point pollution in the Pigeon River Watershed 0-5 points: Does the project employ innovative procedures or technology? If so, what are the implications for water quality? There are three significant new technologies being introduced in the Pigeon River Watershed. The IPSI GIS model contains an unprecedented level of specificity about known or suspected sources of non -point pollution as well as a data analysis identifying the condition of the riparian zone, potential sources of sediment and pollutant loads to streams. This innovative tool substantially enhances planning and project implementation provides an assessment and monitoring tool, and is an outstanding means of communicating information about watershed conditions to the public, elected officials, and others. The second innovation is addressing the issue of sediment from private roads in mountain subdivisions. It is one of the most significant sources of sediment in many watersheds in western North Carolina. Initiating the Balsam Meadows demonstration project will help refine practices, draw attention to the issue, and encourage private landowners and developers to apply improved practices during development. Installing proportional monitoring and bed load samplers willprovide needed information about the nature, quantity, and timing of sediment movement in this watershed In addition, this data will assess the effects of changing land uses and the effectiveness of BMPs, while improving sediment delivery modeling. 0-20 points: Does the project establish functional riparian buffers or greenways? If so, provide details of buffer design and estimates of pollution reduction. The project establishes functional riparian buffers in 2 sub -watersheds. The total length of these riparian buffers is over 12,000 feet. These buffers are generally 35' wide. Trees will be planted in these buffers to stabilize stream banks and reduce water temperatures. There will be no intensive agricultural uses or development within these buffers. Longterm maintenance agreements with incentive rentals or easements will be used to assure protection of these riparian buffers. Applicant: (Up to 30 points") 0-20 points: Describe other resources committed towards this project: There are over 25 volunteers gathering water quality data in support of this effort. The Pigeon River Fund has provided $73,300 in funding to initiate the IPSI effort. Tens of thousands of dollars worth of time from professionals from TVA. NRCS, HS&WCD, SWNC RC&D Council, DENR, HWA and Haywood Community College are contributed to the HWA Technical Advisory Committee each year. Private landowners will contribute thousands of dollars of cost share money and in -kind services as the BMPs are put on the ground 0-10 points: Briefly describe organization's qualifications to accomplish the proposed project: HWA is a 50l(c) 3 non-profit corporation under North Carolina law. The Board includes decades of experience in administering a wide variety of grants. The President is also the Director of Environmental Programs for the Land of Sky Regional Council. The two staff administering these projects are both professionals with over 50 years cumulative experience. One was a former District Director for Farmer's Home Administration — the other a forester who had previously served as the Watershed Director for the Eastern Region of the USDA -Forest Service. The Technical Advisory Committee is composed of over a dozen professional staff from federal, state and local agencies. The HS&WCD, NRCS, and the NC Extension Service have trained and experienced engineers and conservationists committed to insuring the BMPs are properly placed on the ground Is there a long-term management plan to which this proposed project is strategically related? (Explain) A Watershed Action Plan has been drafted by the HWA Technical Advisory Committee to guide watershed improvement work in the Pigeon River Watershed for years to come. The proposed work is among the highest priority projects identified in this draft plan. Is there a local land use plan for the county or municipality in which the project will occur? What assurance can you provide regarding long term management of the project? There is no local land use plan affecting the project area. The riparian zones will be made subject to conservation easements or 15-year maintenance agreements. Easements will be transferred to a qualified land trust, such as the Southern Appalachian Highlands Conservancy, for administration. The 15-year agreements will allow the trees in the riparian corridors to become large enough that it would generally be impractical to remove them at that point. The watershed improvements made to homeowner association roads will reduce maintenance costs for the association, thus insuring their longevity. Is this project eligible for funding under other state or federal grant programs? If so, elaborate. The project is eligible for Section 319 Grants from EPA. Such a grant was approved by the State, and money is anticipated in April of 2001. However, those funds are committed to the Fines Creek and Hyatt Creek areas, and do not address some of the highest priority sources in the Lake Junaluska watershed and do nothing for correcting problems at the Canton Recreation Park The North Carolina Agriculture Cost Share Program funds BIv1Ps. However, only about $80,000 are available in any give year, thus limiting the effectiveness of that source. In addition, those resources are generally not targeted to the Lake Junaluska watershed The North Carolina Wetland Restoration Fund also provides funds for such practices as stream bank stabilization. These monies, whether from the Fund or the DOT, may be a beneficial supplement to this project. Is the property wherein the project will be located subject to any environmental laws, rules or regulations (existing or pending) which impose obligations or restrict the use or marketability of the property? (If yes, please explain) [Please do not exceed 4 pages!] No. Budget Summary Applicant: Haywood Waterways Association 8 Haywood Soil 8 Water Conservation District Date: November 29, 2000 Two Year Proiect Budget Summary Local CWMTF Total Staff $ 174,600.00 $ 89,960.00 $ 264,560.00 Travel $ 19,800.00 $ 3,900.00 $ 23,700.00 Monitoring & Evaluation $ 10,924.00 $ 17,650.00 $ 28,574.00 Public Education $ 10,400.00 $ 2,180.00 $ 12,580.00 Equipment $ 22,214.00 $ 2,267.00 $ 24,481.00 Supplies $ 2,500.00 $ - $ 2,500.00 Easements & Management Agreements $ - $ 25,000.00 $ 25,000.00 Best Management Practices $ 134,608.00 $ 403,827.00 $ 538,435.00 BMPs & Storm Water Management $ 22,000.00 $ 88,000.00 $ 110,000.00 Storm Water Management $ 3,209.00 $ 12,836.00 $ 16,045.00 Construction Contingency $ - $ 19,935.00 $ 19,935.00 Contract & Project Management $ - $ 12,000.00 $ 12,000.00 Total Project Cost: $ 400,255.00 $ 677,555.00 $ 1,077,810.00 CWMTF Grant Request = $677,555 Note: Pursuant to the instructions, a one page summary is provided. To adequately itemize costs a threepage budget was necessary. Please see attached two year budget and notes. Page 1 M-M, ''I'll � I :, 40 d • V o f� Watershed Boundary Streams - Roads 0 4 8 Wiles 082° 55'10.00" W I I I PII1*5TjO-WWI I 1 1 PIT 5G 0.00" W omn eefltCCti• } 0 ref sae`. 6 ter mama pI,'IE tF�ftB kdc a ^' c .�� _ �ir t soul f 1':?w''�%�'➢`4 n'�l �' M 4 ((j yl \ jJ1jj% � k'�.', `�x^ S l 'M ^i�4 pit`+.-...s kh � N.✓ i}'\ • . f 5Cld1y 17- r; Z C `4 4k; � 'v�< � yN '"� i • � :'��"f��`1 ,y 0. �X y r�'a� x'��{ j �. � � j ^�, i r' ra.�. t { E +..r'�i � '�' i• ,{ � �, �,„,,, ' 1,S '. 1 �X 1 i 1 5:.r '...-= w� i( ,�l f/ ^"°"..� �.x� �' �� ��� r�# / � e� g.+✓ le `' <i„� ��°-i � � j �,,.",�� r.�, %''t f � � �'y' ;'"`. t4......o-'" 'a,�aj w sue°-,i,�r t i.'p� s�"-�...w•-R, "i.�. 4� A) ✓' x �,^!. 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"1wa- V._�«• isa�1� � 1 '' � ' fy�K ; Y?. f �l t i�?''"'�'" t`1$m.`, �`..'"..!` ti ^`•. 7v� 1 `''y,``'"""'°' 43 ,rV,,.§:1�'ctls�hT1'f �.�x \2+"�'�K" 1�t ,,�ia•'' %YI ��, M`s,`""-'��°-v, '�-.�jk"r`r�,•'+"-j! .��„r-�, t�>;—�.=•-.-,< st `"`•''�„ °�Q , Ii'�' �°/°� 3.sw t;:=°,- ,�;�`�.�. ..iwf G "Av t } } 1 3 1 �^a., '• 1�� x%� �`..a_d I�Yr"`vy'�L , � i ��Yi lam~ �� ���„�, tl 5° W .`,:.. ., . 62° 58' 0.00" I 2° ST 0.00" 1M1f� Q82° 56 0.40" W Name: WAYNESVILLE Location: 035° 39 09.8" N 082057' 11.7' W Date: 1113012000 Caption: Location Map Scale: 1 inch equals 2000 feet Lake Junaluska, John Queen, Perry Morrow, JN Hyatt, Elise Palmer, Edgar McElroy CopAigM (C)1997, Pbpbach, iru. 1 107`10FI°t0°i NII I I I 14§3I`P4 4.497Y I I I 11R1°fl a9°1WI I I I I 4� V TV• I I I 110P°140l60i WN I I If Mi 4z •49'N4 I m.�1 tea '� � -- r /. i1 r" ''i �✓"/ ! `� ; rF ,7 O •---. S t f { J �tg�tkj jl�{ � r^� '1�I� ,�' v.v i � fib\ .\ !� �t•� {�:�� nj�3}1� �� ��i �r�� .r{'^",p�✓� y'7�Q y� LV N jJr ,; C i .'. ,�, x�hi ,v"f _�,�d� t�-. ✓ :`. ll / Z Ilk ( 'Jr ? .jz � � m j /,.._—/ f 1 1 1�\•a o � Qi, �`�t-f• - '��-j � �` r�ts � III � �� Ai : J •V G" lA t� �u�PYI �ry'y..\ 1 `X Y {' .A y.F., _ A i .. ♦ y � f l� �yV'� �h\ �� � �".-li.)'T �i t 1 Y� )l ��z00 � ,. � •� � o � - • '' ate',, 1 } ` 1- f , � � � �� ti, >�'! T. i4h• C289flti$AtB.'l,In •4' �A o ;. ./l/ 1.,- hPc� �k / \151) I ���+yyy��������! ° Jl 1 (/ t'�t ♦ n � a r r X , i n,S� J ,P ,—� '. � Ye( \ �'-.. ! , hh J 3 1�.¢u5 , r---.«,p� �`s5 ..• 11 r • Y a!4 %/ ,fie c /F uPr_.. �✓ `fir •Ry}, � J •. 1. ly R 9i� Yr1Y' '�. / 4!`✓ A 1...Y! t� OM /- � l -t ai � 1 d iriJ �% 7 � Alt '>� � ' ` O N! A a� \- �K �, ri5.. r � i� ^..� __ w,1 m •' v. / ui m .?:.�' :i X J i t g6Nr. '� {�� s�,,, t va,/,'Y �'•k1 Y fir./-' --!+ 1 . r=a�`� � r r��� V � y r r � � a• i .: .! f 38 � It '..y�i kr7 / '`}.. � I �� 1 � � �.,� 7�^-� ice(' J'�.0 J. ! � �r�1=3)1� J .C. 1 %' ,• � I y� t77 �� 7(`� Hc623A/d 9 N�l i .. ,,s 1 /� \. .i✓_�.` 'ti .J P� � �e�' p \ L n`NA��TC\ � L"•�}y>,i tdj� l�rA\ IJ "N'� ,c, i r n a .! rJ.i�A \.r r^1/a !1•�(! , .--y T r .�' tea; 41 O N e lSe �., m zn ` 5°W `Ud3"u6' U.u01 VVI I I I I OH3- uq• .00" yy I 11083'104'IO'.001 W I I 1 1 083" 03' 0.00" W I I I 11083>10B]11001 WI I I I 1083" 02' .00" W I I Name: HAZELWOOD Location: 035' 27' 15.3" N 083' 03' 43.9" W Date: 1113000 02Caption: Location Map Scale: 1 inch equals 2000 feet Balsam Meadows Subdivision, John Francis and Bill Cochran Mapped and edited by Tennessee Valley Authority Location map - Canton Rec Park Stream Bank Restoration Published by the Geological Survey Control by NOSNOAA. USGS, and TVA "" lop GN � Revised by TVA in 1967 by photogrammetric methods using I aerial photographs taken 1966 and by reference to TVA•USGS a• F quadrangle dated 1941, Map field checked by TVA, 1967 n was` iroa' 05/6`3%26o1 11:30 G475770489 IES PAGE 02 Serving the Legal and Insurance communitias • Investigating I Auditing y Consulting May 3, 2001 Attn.- Keith Haynes NC Dept of Environment & Natural Resources Asheville Itegioeal Office Division of Water Quality 59 Woodfui. Place Asheville, NC 28801 FAX 828/251-6452 RE: Champion Paper Min, Canton, NC - FUe Review Dear Mr. Haynes, I wanted to thank you again for your time the other day in discussing the information that I am Iooldng for regarding the above -mentioned site. As I mentioned durittg our phone conversation, I will be in Asheville from May 14-17, 2001, and I am sending this letter to coufi rm my appointment for a file review for Wednesday, May 16t5 at 9;00am. Please do not hesitate to contact me at 847/577-0022 with any questions, or if you need to change our appointment time. Thank you again, and I look forward to meeting you in May. Very Truly Yours, Nadine L. Burg, ) xecutive Consultant IES — Claims Services 3315 Algonquin Road, Suite 105 • Rolling Meadows, IL 60008 . Voice 847.577.0022 fax 847577.0489 05/03/2001 11:30 8475770499 IES PAGE 01 IES = Claims. Services 3315 West Algonquin Road Suite 105 Rolling Meadows, IL 60008 Phone: 8471577-0022 faes • • e tmmmitrai Keith Haynes To: Division of Water Quality NCpBNR From: Nadine L. Burg Fax: 828/251.6452 Data: 513/01 Re: File Review— Champion Paper Mill Pages: Two, including cover sheet . . . . . . . . . . . . . . . . . . . . . . . STATE OF NORTH CAROLINA Department of Environment and Natural Resources 59 Woodfin Place, Asheville, NC 28801 828/251-6208 FILE ACCESS RECORD Guidelines For Access: The staff of the Asheville Regional Office are dedicated to making public records in our custody readily available to the public for review and copying. We also have the responsibility to the public to safeguard these records and to carry out our day-to-day program obligations. Please read carefully the following guidelines before signing this form: 1. We prefer that you call at least a day in advance to schedule an appointment to ,review the files. Appointments will be schedule between 9:00 am and 3.00 pm. Viewing time ends at 5:00 pm Anyone arriving without an appointment may view the files to the extent that time and staff supervision is available. 2. You must specify files you want to review by facility name. The number of files that you may review at one time will be limited to five. 3. You may make copies of a file when the copier is not in use -by the staff and if time permits. The cost per copy is 15 cents: payment may be make 4. FILES MUST BE KEPT IN THE ORDER YOU FOUND THEM. Files may hot be taken from the office. To remove, alter, deface, mutilate or destroy material is one of these files is a misdemeanor for which you $500.00. can be fined up to 5. In accordance with General statute 25-3-512 a $20.00 processing fee will be charged and collected for checks on which payment has been refused. FACILITY NAME COUNTY 1. 2. 3. 4. 5. NAME of reviewer: Signature: NAME of reviewer: Signature: REPRESENTING: I ES — ' Please Attach a Business Date: S/S D( A1,4121AI-5 �02(— — 1 ES GJlii�rs set-v�ic 1 /ai4.s Card to Time In: Form Time Out: ^L _ STATE OF NORTH CAROLINA Department of Environmental and Natural Resources Water Quality Section 59 Woodfin Place, Asheville, NC 28801 828/251-6208 File Access Record FACILITY NAME COUNTY have been provided (print ngdne/s) (print name/s) access to the above -named file by personnel of the Water Quality Section. I understand that this statement shall be made a permanent part of any file which is viewed under the Freedom of Information provision of the North Carolina General Statutes. ture) e\ name/initials permit number /(r- (date) (date) COMPARATIVE AND STATISTICAL Prepared for: North Carolina Division Water Quality Prepared by: Blue Ridge Paper Products Inc. Canton, North Carolina May 31, 2001 C- BLUE RIDGE. PAPER PRODUCTS INC. May 29, 2001 Mr. Forrest Westall Regional Water Quality Supervisor North Carolina Department of Environment and Natural Resources 59 Woodfin Place Asheville, NC 28801 RE: NPDES Permit No. NC0000272, Blue Ridge Paper Products, Inc. Canton Mill June 1, 2001 Required Reports Dear Mr. Westall: Attached are the June 1, 2001 Comparative Evaluation Report and the June 1, 2001 Color Performance Statistical Evaluation. These reports are submitted to fulfill part of the requirements stated in Part III, Paragraph E 14 of the modified 1997 NPDES Permit. Please call me at (828) 64&2033 or Derric Brown at (828) 646-2318 if you have any questions or concerns regarding these reports. Sincerel Bob Williams Director - Environmental, Health and Safety Attachment 175 Main Street o P.O. Box 4000 Canton, North Carolina 28716 • Phone: 828-646-2000 Raising Your Expectations Xc: I th Haynes9 Dave Goodrich Mike Myers June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina I. Introduction The following report describes the important color reduction activities that have been accomplished over the term of the modified 1997 NPDES Permit ("1997 Permit") and includes a discussion of technology assessments Blue Ridge has undertaken to evaluate potential color reduction options. Part III, E. Paragraph 14 of the 1997 Permit provides, in part, that: "...By June 1, 2001, the permittee will submit a report to the NPDES Committee and N.C. DENR, Division of Water Quality, on the comparative evaluation of the above collective efforts as part of the Variance review process (Triennial Review of North Carolina Water Quality Standards.)..." This report is submitted to fulfill this requirement of Part III, E. Paragraph 14. Permit No. NC0000272 Page 1 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina li. Summary of Color Reduction Activities Since the issuance of the 1997 NPDES Permit, the Canton Mill has accomplished the following color reduction activities: 1. Identified and implemented certain Best Management Practices (BMP's) to reduce color. The following BMP's were implemented before June 1, 1998, and a report on the implementation was submitted to DWQ, the TRW and the NPDES Committee on that date. a. Installation of replacement digester recirculation pumps. b. Installation of a double -chambered pine courtyard spill collection sump. c. Installation of weak black liquor tank containment, and d. Correction of evaporate set demister clogging, installation of condensate instrumentation and sampling ports for the evaporator set and assurance of continued dry conveying of knot rejects. 2. Submitted Low Flow Contingency Plan to DWQ and TRW by December 1, 1998 (approved by NPDES Committee in February 1999). 3. Prior to December 1, 1998, complied with a reduced color limit in the Permit of 60,000 lbs. per day (annual average) and 69,000 lbs. per day (monthly average). 4. Began implementation of partial Eo stage filtrate recycle on the hardwood line before January 1, 1999 and submitted a report on the color reduction benefit resulting from the partial implementation and a projection of potential color reduction benefit to be gained from full implementation of BFR on the hardwood line to DWQ, TRW and the NPDES Committee by December 1, 1999. 5. Submitted a color limit feasibility report to DWQ, TRW and the NPDES Committee before January 1, 2001, which concluded that the Canton Mill could comply with a color limit within the range of 48,000-52,000 lbs. per day (annual average). Permit No. NC0000272 Page 2 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina Implementation of these BMP's, together with improved mill operations and continued commitment to further reduce color, has reduced color by 32% over the term of the 1997 Permit. As described in the January 1st, 2001 Report, the mill has achieved a target annual average color loading of 48,000 — 52,000 pounds per day. On May 1, 2001 the North Carolina Division of Water Quality reduced the permit limit for annual average color from 60,000 Ibs/day to 48,000 Ibs/day and the monthly average color limitation was reduced from 69,000 Ibs/day to 55,000 Ibs/day. Based on data received from the National Council on Air and Stream Improvement (NCASI), the Canton Mill has the lowest color of any mill in its industry category.' 1 Based on a June 7, 2000 Benchmarking Canton Wastewater Effluent Parameters letter from the National Council for Air and Stream Improvement (NCASI). Permit No. NC0000272 Page 3 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina III. Additional Color Reduction Studies 3.1 End -of -Pipe Treatment and In -Process Technologies In an effort to identify either a breakthrough improvement in color removal efficiency or reduction in cost, the mill has evaluated end -of -pipe color reduction technologies three times in the past thirteen years, including a 2001 study by Jacobs Engineering Group, Inc. (2001 Color Removal Technology Assessment, the "Jacobs Report"). The Jacobs Report evaluated 16 end -of -pipe technologies. It is clear that no breakthrough in economic or technical feasibility has or is likely to occur in end -of -pipe color removal. technologies. Such technologies have not been commercially demonstrated and are generally not economically feasible because they require a significant initial capital investment with continued operating costs and no associated savings. During this same thirteen -year period, however, the Canton Mill implemented alternative in -process pollution prevention technologies including oxygen delignification, Elemental Chlorine Free bleaching, Bleach Filtrate Recycle-rm and those technologies comprising the "Near -Term" package, resulting in a significant reduction in the color discharged. Therefore, based upon this record, it is Blue Ridge's intention in the future to focus on in -process pollution prevention technologies and the potential treatment of selected, colored wastewater streams before they enter the wastewater treatment plant (WWTP) and, in particular, the Chloride Removal Process (CRP). Blue Ridge believes in -process pollution prevention and treatment of selected wastewater streams hold the greatest likelihood of success for further color reduction. In the future, Blue Ridge believes its time and resources would be Permit No. NC0000272 Page 4 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina better devoted to in -mill treatment of particular wastewater streams rather than end -of -pipe, secondary effluent color removal approaches. 3.2 Polyamine Trials Polyamine addition trials were conducted in January 2001 at the primary clarifier, secondary clarifier, and colored in -mill wastewater streams, and were not eopmine aon isCo reduce color throughsuccessful�heconcpt d precipitation of color bodies, which attach to the polyamine, coagulate, and settle in primary clarification. Numerous trial approaches were conducted to study comprehensively the effectiveness of polyamine for color removal. While treatment of colored wastewater streams in the pulping and recovery areas appeared to remove color, the color bodies re-solubilized in the wastewater collection system and there was no significant net reduction in secondary effluent color. Treating the primary clarifier resulted in color reductions, but wastewater treatment plant sludge quality declined to an unmanageable condition and recycled belt press filtrate solids increased significantly. Treating the secondary effluent resulted in minimal color reductions; in addition, this type of treatment would require the installation of equipment and increased operating costs as described in the Jacobs Report , and might have adverse effects on the chronic toxicity of the wastewater discharge. 3.3 CRP Treatment with Lime Laboratory studies were recently performed on the Chloride Removal Process (CRP) purge stream, a relatively high color, low flow stream associated with the BFRTrm process. The purge stream was treated with various sources of calcium in an effort to precipitate color bodies. Lime precipitation was concluded to be Permit No. NC0000272 Page 5 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina infeasible due to the massive quantities necessary to partially reduce color and the large quantities of solid waste generated. 3.4 Third Party Evaluation of Canton Mill As part of Blue Ridge's commitment to continued color reduction, the Canton Mill, in collaboration with a coalition of environmental groups, engaged Dr. Norm -Lieberrgott,- President-of-Liebergott-& Associates -Consulting- Inc.,- and Lewis Shackford, Vice President of Technology for GL&V Pulp Group Inc., a major supplier to the pulp and paper industry, to undertake a thorough evaluation of the mill's pulping and bleaching operation. The evaluation is focusing on potential process and equipment modifications targeted at environmental performance improvements. Liebergott and Shackford will identify options for consideration that may lead to decreased effluent load, in particular color, with technologies that will not increase effluent toxicity. Blue Ridge plans to submit this information to the Division of Water Quality for its consideration in conjunction with the information from the Technology Review Workgroup (TRW) to evaluate options for potential reductions in effluent color over the term of the next NPDES Permit. Permit No. NC0000272 Page 6 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina IV. Commitments to Further Color Reduction The Canton Mill is committed to further discharge color reduction. In conjunction with the Technology Review Workgroup (TRW), the Canton Mill believes further color improvements may be achieved utilizing the following options. 4.1 BFR Improvements - — mce October 1998,-the average BFR closure rateof-the pine fiberline D1 and Eo stages has averaged approximately 74%. This rate is lower than the targeted BFR closure rate of 80%. The obstacles to achieving a sustained pine fiberline closure of 80% are related to the operational reliability of the BFR equipment, primarily the Metals Removal Process (MRP). Blue Ridge is committed to undertake improvements to the MRP in order to achieve an 80% pine fiberline closure rate. These improvements include a new media filter and softener, rebuilding piping and valves, and changing materials of construction to better withstand the harsh environment (corrosivity, erosion and deposition). Blue Ridge estimates the cost of these improvements to be up to $1,300,000 and the estimated discharge color reduction from these upgrades to be 1,000 — 1,200 Ibs/day. The other component of the BFR process is the Chloride Removal Process (CRP). The CRP system purges chloride and potassium from the mill's chemical recovery system. This purge is a low flow, relatively high color stream that contributes an average of 6,000 Ibs of color per day to the wastewater treatment plant primary influent (or less than 4,000 Ibs/day in the discharge). The Canton Mill will investigate potential technologies that may reduce this source of color. Permit No. NC0000272 Page 7 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina 4.2 Additional Black Liquor Leak and Spill Control The Canton Mill has extensive equipment to reduce black liquor leaks and spills. Additional improvements to further manage black liquor losses to the wastewater collection system are currently under evaluation. The first improvement involves diversion of clean water from the digester area sump. This diversion of clean water will prevent dilution of concentrated brown color, thereby allowing the sump to capture a greater percentage of the brown color from the digester area. Another upgrade is to collect the filtrate from the knotter bins to reclaim color that is leached from knots. An evaluation of alternatives to reduce screen room color will also be conducted. Blue Ridge estimates the cost of these improvements to be in excess of $100,000. The discharge color reduction could be in the range of 1,000 — 3,000 Ibs/day. 4.3 Evaluation of Potential In -Process Color Reduction Technologies As described in Section 3.4, Liebergott and Shackford are evaluating technologies that may result in reduced discharge color. While this report is not yet complete, Blue Ridge can provide an overview of Liebergott's and Shackford's scope of work. The scope of the Liebergott and Shackford study involves evaluation of potential process modifications to see if such modifications are technically, operationally and economically feasible. The report will consider impacts on process control, production capability and pulp production cost and quality. Liebergott and Shackford will consider changes to each fiberline, 2-stage oxygen delignification, strategic use of hydrogen peroxide and the alternative use of peracetic acid Permit No. NC0000272 Page 8 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina and/or ozone in the bleaching stages.. An evaluation of whole mill effluent and segregated higher color wastewater streams will also be conducted. A final report will be issued summarizing the technical, economic and operational feasibility of the technologies reviewed, including a discussion of commercially demonstrated use. This report will be provided to the Division of Water Quality. --In addition -to this third party assessment, —the USEPA Was -a dedicated Technology Review Workgroup that is studying additional color reduction technologies. This report is also expected to be available to the Division of Water Quality in the second quarter of 2001. Permit No. NC0000272 Page 9 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina V. Conclusion The Canton Mill has successfully reduced color from 83,000 lbs/day to less than 48,000 Ibs/day over the term of the 1997 NPDES Permit. Blue Ridge is committed to further improvements to the BFR process, the digester area spill control systems and to the knotter and screen operations, which will further reduce discharge color. Blue Ridge is also committed to evaluating other process technologies, which may reduce color, over the term of the-2001 NPDES Permit. Permit No. NC0000272 Page 10 June 1, 2001 Statistical Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina I. Introduction The following report describes the statistical evaluation of the Canton Mill's color discharge since completion of the color reduction activities required by the modified 1997 NPDES Permit and Settlement Agreement. Part III, E. Paragraph 14 of the revised 1997 Permit provides, in part, the following: Further, based on the continued development of color discharge information from the reconfigured mill, the permittee will statistically evaluate its monthly average color discharge, its annual average color discharge, and the performance of the mill in relation to color discharged..." This report is submitted to fulfill this requirement of Part III, E. Paragraph 14. Permit No. NC0000272 Page 1 June 1, 2001 Statistical Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina II. Discussion The Canton Mill has achieved a color reduction of over 88% since 1988 in the annual average amount of color discharged, as illustrated in Figure 1. The improved color performance is due to the Canton Modernization Project, full implementation of the "Near -Term Package" and continuous color management by the mill. The Near -Term Package included the installation of BFRTm on the mill's pine fiberline, implementation of best management practices (BMPs) detailed in the June 1, 1998 Color Technology Report, and partial BFR (Eo filtrate recycle) on the hardwood fiberline. Partial hardwood Eo recycle was still being evaluated and optimized through December 1999, and therefore, the January 2000 — December 2000 time period was used as the basis for the statistical evaluation. This period is representative of mill discharge color performance after implementation of all activities (i.e. "the reconfigured mill") required in the 1997 NPDES Permit. However, it is important to note that November and December 2000 are not representative of typical mill pulp production. This is due to the No. 19 Paperboard Machine outage and start-up, when pulp production was very low compared to normal operation. Permit No. NC0000272 Page 2 Figure 1: Canton Mill Secondary Effluent Color Performance Annual Averages: 1988 - 2000 400000 T Including Permit Limitations Permit Limitations: 350000 1-258,945 #/d Monthly Ave, off. 4114/94 2-172,368 Wd Annual Ave. off. 4/14194 3-125,434 #/d Monthly Ave. eff. 12112/96 4 - 98.168 #/d Annual Ave eff. 12/12/96 6 - 95,000 Wd Monthly Ave eff. 111198 300000 6 - 69,000 #/d Monthly Ave. eff. 1211198 T 7 - 60,000 #/d Annual Ave. eff. U/1/98 t0 8 - 48,000 #/d Annual Ave. eff. 5/1/01 9 N a 250000 0 1 0 U v 200000 D E W 9 150000 0 2 u W 100000 4 50000 no 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 Blue Ridge Paper Products, Inc. Permit Urnitaions t SE Color Annual Ave. #/d E Canton Mill 5/31/01 June 1, 2001 Statistical Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina III. Statistical Evaluation of Color Performance Data The attached Table summarizes the statistical evaluation. Based on January 2000 — December 2000 color data, the 95th percentile expected annual average is 46,475 Ibs/day. This 95th percentile annual average is representative of the reconfigured mill's performance. The monthly average numbers were calculated, using the same data as above, by two different statistical methods. The expected monthly color average based on a 95th percentile distribution is 54,089 Ibs/day. Using a 95th percentile distribution and interpolation from ranked observations, the expected monthly color average is 55,003 Ibs/day. These two 951h percentile monthly average numbers represent current mill performance. The maximum monthly average observed during this time period was 58,009 Ibs/day. 1 Interpolated numbers come from the empirical (i.e. the actual ranked values) data using the calculated percentile by assuming it lies linearly between the closest smaller percentile and the closest larger percentile within the cumulative percentage distribution. Due to the limited data set available, an interpolated statistical evaluation is only possible for a monthly value, not for an annual value. Permit No. NC0000272 Page 3 June 1, 2001 Statistical Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina IV. Conclusion Based upon color discharge data during the period after the Mill had implemented all improvements required by the 1997 NPDES Permit, the expected annual average is 46,475 Ibs/day. Expected monthly color averages using the same data from two different statistical evaluations are 54,089 and 55,003 Ibs/day. Using North Carolina's governing flow criteria (30Q2), historical flow records, and the 2000 annual average color discharge of 43,386 Ibs/day, it is expected that color in the Pigeon River at the Hepco gage will be less than 50 true color units 100% of the time at all flows above 30Q2. Permit No. NC0000272 Page 4 Table 1: June 1, 2001 Statistical Evaluation Monthly Average Data - Max Month/Annual Calculation Data Set n= X-bar std dev 95th percentile for Month 99th percentile for Month Max month 95th percentile for Year from normal distribution 99th percentile for Year from normal distribution Ranked observations - by interpolation 95th percentile for max month 99th percentile for max month January 2000 - December 2000 12 43,386 6527 54,089 58,593 58,009 46,475 47,775 BRPP Inc. Canton Mill June 1, 2001 Statistical Evaluation Attachment 55,003 57,408 BLUE RIDGE PAPER PRODUCTS INC. CQ VI LO 0-4 July 1, 2004 ATT: Central File Mr. Bradley Bennett ;1 Supervisor, Stormwater and General Permits North Carolina Department of Environment and Natural Resources 1617 Mail Service Center Raleigh, NC 2.7699-1617 Subject: Request for Designation of Representative Outfall Status. Blue Ridge Paper Products Inc., Canton Mill, Haywood County Stormwater Permit NCS000105 Dear Mr. Bennett: The purpose of this letter is to request representative status for stormwater outfall 6-18 with 6-4 and 6-10 being considered typical for our landfill, as granted in our permit for analytical sampling. Also to give notice that 6-5 Outfall located at the No. 6 Landfill no longer exists as the drainage from this area was inside the now active 6A-West cell and has been tied -in to the leachate collection system. Outfall 6-5 has been removed from our Stormwater Program. Outfall 6-18 is a new outfall. This outfall collects stormwater from the gravel road at the North West comer of the 6A-West Cell in accordance with the Division of Solid Waste approved plans at the No. 6 Landfill. Our "Stormwater Pollution Plan" has been revised (see attachments) to reflect the addition of the new outfall and to include the outfall in our qualitative and facility inspections. If you have any questions or need additional information, please contact Louie Justus at 828-646-2372. Sincer Loouie\Justus / Paul Dickens Senior Environmental Engineer Manager, Environmental Affairs 175 Main Street • P.O. Box 4000 • Canton, North Carolina 28716 Phone:828-646-2000 Raising Your Expectations BLUE RIDGE PAPER PRODUCTS INC. July 1, 2004 Certification for Permit No NCS000105 I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate and complete. I am aware that there are significant penalties or submitting false information, including the possibility of fines and imprisomnent for knowing violations. Respectfully, Mr. Robert M. Shanahan Vice President — Operations Manager BLUE RIDGE PAPER PRODUCTS INC. Xc: t M Forest_Westall NCDENR Division of Water Quality 2090 US 70 Hwy. Swannanoa, NC 28778 Canton Mill: Bob Williams — Director, Regulatory Affairs D\: New 6-18.doe Outfall A (I EXISTINd AR I H, 4 'EXISTINfi.._ ARM IC J'a. d7--. I A, A r t Landfill '16 General Location.11ap ®�Outfall # 18 ma -..o 00 01 0 OR MI AO C . 550 . L AFTZ tt t IAn 4ET 14-7 F675 REPLACEMENT FOR 4A77, RI P , 3,� AE ABA DONE A t AP QiW'.7 0769 /+APK/ B AP26 Outfall #6-18 am k See LEGEND next page EXISTING 200 0 200 400 loo 12 Drawing Legend: Outfall # 18 (Landfill # 6 ) Total Drainage Area: 6,000 Square Feet (See Note, Below) Drainage Area Outline: Drainage and Discharge Structures: Drop Basins Culvert Pipes Impervious Surfaces: Roads Buildings Stormwater Structural Control Measures: Rip -Rap Springs Hazardous Waste Storeage Area HW Satellite Hazardous Waste Storage Area Materials Loading and Access Areas LOAD Note: New Outfall established 5/20/04. A47j"LAo�i�5W�T WC®ENR AUG - 6 bond North Carolina Department of Environment and Natural eso rces Division of Water Quality LARORATORY SECTION Michael F. Easley, Governor AIAssRJr, Secret&y- -- Alan W. Klimek, P.E., Director. August 5, 2004 198 Mr. John J. Pryately Blue Ridge Paper Products Inc. WTP P.O. Box 4000 Canton, NC 28716 SUBJECT: Laboratory Certification Maintenance Inspection Dear Mr. Pryately: Enclosed is a report for the inspection performed on July 21, 2004 by Mr. Gary Francies. No deficiencies or lettered comments and/or recommendations are cited in this report, a response is not required. We appreciate the fine job you and your staff are doing. As a certification requirement, your laboratory must continue to carry out the requirements set forth in 15A NCAC 2H .0800. Copies of the checklists completed during the inspection may be requested from this office. Thank you for your cooperation during the inspection. If you wish to obtain an electronic copy of this report by email, or if you have questions or need additional information please contact us at 919-733-3908. Sincerely, James W. Meyer Laboratory Section Enclosure cc: Gary Francies Laboratory Section 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 4405 Reddy Creek Road, Raleigh, North Carolina 27609 Phone: 919-733-3908 / FAX: 919-733-6241 / Internet: www.dwqlab.org An Equal Opportunity/Affirmative Action Employer —50% Recycledl10% Post Consumer Paper NorthCarolina Naturally On -Site Inspection Report LABORATORY NAME: Blue Ridge Paper Products WWTP Lab ADDRESS: P.O. Box 4000 Canton, NC 28716 CERTIFICATE NO: 198 DATE OF INSPECTION: 7/21/04 TYPE OF INSPECTION: Maintenance EVALUATOR: Gary Francies LOCAL PERSON(S) CONTACTED: Mr. Paul Dickens, Mr. John Pryately, Ms. Lori Cooper IV VA INTRODUCTION: This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. GENERAL COMMENTS: The staff is congratulated for doing a good job of maintaining the laboratory program. The laboratory is spacious and well equipped. Since the last inspection a new laboratory dishwasher has been obtained. All equipment is well maintained. Records are well kept and most data appeared accurate. DEFICIENCIES. REQUIREMENTS, COMMENTS, AND RECOMMENDATIONS: No deficiencies or comments were noted. PAPER TRAIL INVESTIGATION: No paper trail was performed because the facility had performed its own internal audit of Discharge Monitoring Reports (DMR) from April 2003 through April 2004. Amended DMRs were submitted for all errors noted. CONCLUSIONS: No deficiencies were found during the inspection. No response is required. Report prepared by: Gary Francies Date: 7/29/04 BLUE RIDGE PAPER PRODUCTS INC 12 July 2004 Mr. D. Keith Haynes Environmental Specialist North Carolina Department of Environment and Natural Resources Asheville Regional Office Division of Water Quality 2090 US Highway 70 Swannanoa, North Carolina 28778 Subject: NPDES NCS000105 Non-Stormwater Discharge to Storm Drain Blue Ridge Paper Products, Inc. Canton Mill CERTIFIED MAIL RETURN RECEIPT REQUESTED 7099 3220 0007 0371 5184 AUG 14 2Q04 Eb DIVISION ASHEVILLE This follows our telephone call to you today at 1315. At 1045 today, we confirmed a non-stormwater discharge to our stormdrain system. The discharge occurred between 1500 and 1700 on 6 July 2004 and involved less than 1000 gallons of washwater associated with coal handling equipment maintenance. The water contained turbidity and coal fines. At the time of discovery on 6 July, we checked the Camp Branch discharge to the Pigeon River (stormwater outfall #7) . This discharge and was clear. We concluded that the washwater was routed to and contained in our coal pile stormwater pond. Water in the coal pile stormwater pond is pumped to the Canton Mill sewer system for treatment. After discussion with knowledgeable persons and tracing stormdrains this morning, we discovered that washwater observed on 6 July entered the stormdrain system below the coal pile stormwater pond. There was a release to the river through stormwater outfall #8. The outlet of stormwater outfall #8 is not readily accessible and is hidden by weeds along the river bank. The stormdrain routing is not obvious from the ground, which is the reason we were mislead on 6 July when we investigated the washwater discharge. As corrective action, the Canton Mill will use portable hoses, a vacuum truck and other means in the future to collect all washwater associated with coal handling equipment maintenance. This water will be diverted to the mill sewer system. Paul S. Dickens Environmental Manager 828-646-6413 dickep@blucridgepai)er.com F. Louie Justus \1-1/ Senior Environmental Engh 828-646-2372 W ustul@blueridizepaper.com Environmental Group 175 Main Street • PO Box 4000 Canton, North Carolina 28716 • 828-646-2000 Raising Your Expectations BLUE RIDGE PAPER PRODUCTS INC. CERTIFIED MAIL RETURN RECEIPT REQUESTED 7099 3220 0007 0371 5313 22 September 2004 Mr. Forrest Westall Water Quality Supervisor North Carolina Department of Environment and Natural Resources Asheville Regional Office Division of Water Quality 2090 US Hwy 70 Swannanoa, North Carolina 28778 Subject: NPDES NC0000272 Ivan - Flood Event of 17 September 2004 Unanticipated Bypass of Treatment Sanitary Sewer Overflow Blue Ridge Paper Products, Inc. Town of Canton, North Carolina Dear Forrest — This is the written report required under the subject permit documenting flood damage and loss of wastewater treatment associated with Hurricane Ivan on the morning of 17 September 2004. The wastewater treatment plant operated by Blue Ridge Paper Products also treats sewage from the Town of Canton. This report is submitted for both Blue Ridge Paper Products and the Town of Canton. The Ivan flood came 9 days after flooding and damage from Hurricane Frances. These back-to-back floods are unprecedented. Both floods set records for river stage in Canton, NC at 21 feet and 23 feet respectively. The dike system protecting our wastewater treatment plant was designed to withstand floods of -- 20 feet river stage, which is above the historic flood level for Canton. Both floods overtopped our dike. Floodwaters from Ivan were deeper and more violent than Frances. We notified DENR by telephone at 0650 on the morning of 17 September 2004 that our wastewater plant was flooded and shut down. Mill operations were still curtailed as a result of Frances. We subsequently provided' daily updates on progress towards restoring Environmental Group 175 Main Street • PO Box 4000 Canton, North Carolina 28716 • 828-646-2000 Raising Your Expectations Forrest Westall, NC DENR ARO DWQ 22 Sep 2004, Page 2 wastewater treatment for the town's wastewater. Wastewater treatment was restored on the afternoon of 21 September 2004. During the period that wastewater treatment was down, untreated sewage from the town entered the Pigeon River, both from the mill's influent lift station and from the town's sewage pump stations that were submerged and damaged by floodwater. Since mill operations were already down before Ivan and remained down, there was no release of untreated industrial wastewater. Chemicals and oil storage on the Blue Ridge site remained secure. Flood Event The remnants of Hurricane Ivan passed through Western North Carolina on 16 and 17 September 2004. The mill revised its flood protection plan based on experience with the Frances flood and began aggressive preparations for Ivan on 11 September 2004. These advance preparations included installation of large diesel pumps to keep the wastewater plant and mill dry during a storm event similar in magnitude to Frances. Blue Ridge Paper began a formal flood watch on the morning of 16 September and completed installation of floodgates and dike reinforcements protecting the mill and wastewater treatment plant. The plan for Ivan was to run power boilers and generate mill power to keep wastewater influent pumps running and the wastewater plant dry. If the river stage rose to the point of flooding our secondary clarifiers, we would cut off the effluent discharge and bypass pump over the dike into the river using the diesel pumps. Between midnight and 0400 on the morning of 17 September, floodwaters backed up into the wastewater treatment area and overtopped the secondary clarifiers. During this period, the diesel bypass pumps were able to keep up with both influent and floodwater flow. The river stage stabilized at — 19 feet from 0330 until 0400, and we felt that we might succeed in surviving Ivan. In hindsight, the pause in river stage rise was the result of flooding into the Town of Canton upstream of the mill. When the town filled with floodwaters, the river stage quickly jumped to 21 feet, then peaked at 23 feet - a new record for Canton. At 0408, the mill lost CP&L power. We were generating mill power at that time and keeping pace with floodwater infiltration, but the surge from loss of external power tripped out the mill's internal power distribution system. Our influent wastewater pumps stopped, and the wastewater plant began flooding at the influent lift station. At about 0440, the river overtopped the dike protecting the wastewater plant. Floodwaters rushed in. By 0500, there was 7 to 8 feet of water in the wastewater treatment area, 3 to 4 feet higher than the Frances flood. This water flooded the influent lift station, sludge pump room, secondary clarifiers and switchgear rooms as well as the wastewater control room, lab and offices. The lower aeration basins also flooded. Only the primary clarifiers and upper aeration basins remained above flood level. Floodwaters running through the Environmental Group 175 Main Street • PO Box 4000 Canton, North Carolina 28716 a 828-646-2000 Raising Your Expectations Forrest Westall, NC DENR ARO DWQ 22 Sep 2004, Page 3 wastewater plant cut a temporary channel along the river side of the aeration basins and washed out a section of dike between the aeration basins and river. Downtown Canton was severely flooded, and the town's sewage pump stations along the Pigeon River were submerged. The town's disinfection pretreatment system located at the headworks of the Blue Ridge wastewater plant was also submerged. Recovery Flood waters started to recede on the afternoon of 17 September 2004. By the morning of 18 September, Blue Ridge was able to drain and pump remaining floodwater from the wastewater area and start work to restore wastewater treatment. The Town of Canton also began work to repair and restore sewage pump stations damaged by the flood. To drain remaining floodwaters from the wastewater treatment plant and from the mill, diesel pumps were installed at the influent low lift pumps to the mill's wastewater treatment system. These pumps discharged to the river. On the evening of 18 September 2004, the Town of Canton began pumping sewage back to the mill's wastewater headworks. These waters were then bypass pumped into the river. On the afternoon of 19 September, the Town of Canton was able to restore the disinfection pretreatment system. The disinfected wastewater was then pumped into the river. These interim sewage handling and treatment arrangements had been discussed with DENR staff and were agreed to be the best measures for public health protection until full wastewater treatment could be restored. Work by Blue Ridge personnel to restore wastewater treatment continued non-stop after floodwaters were drained from the wastewater area. This was truly a heroic effort by our electricians, mechanics, wastewater operators and contractors. Blue Ridge was able to restart wastewater treatment operations on the afternoon of 21 September 2004. Discharge of untreated and partially treated sewage from the Town of Canton through diesel pumps at the mill's wastewater headworks stopped at 1145 on 21 September 2004. Blue Ridge resumed compliance monitoring of the wastewater plant effluent that night. Sanitary Sewer Overflows The Blue Ridge wastewater treatment facilities were down from 0408 on 17 September 2004 until the afternoon of 21 September 2004. During this period, untreated sewage from the Town of Canton was discharged to the Pigeon River, both from overflows at damaged pump stations owned by the town and from the influent of the mill's wastewater treatment system. Floodwaters and cleaning water from the mill and town were also discharged to the river. Environmental Group 175 Main Street • PO Box 4000 Canton, North Carolina 28716 • 828-646-2000 Raising Your Expectations Forrest Westall, NC DENR ARO DWQ 22 Sep 2004, Page 4 The quantity of sewer system overflow is difficult to estimate, but is greater than 15,000 gallons. The majority of the overflow was floodwater and cleaning water necessary to restore sewage pump stations and wastewater treatment. The mill locked restrooms and installed portable toilets during the wastewater treatment outage to avoid discharge of domestic sewage to the river from the mill. A SSO reporting form is enclosed for the period of wastewater treatment outage. Summary The Ivan flood was worse than Frances, which was the worst flood event in Canton, NC for at least 60 years. These back-to-back floods were truly severe acts of nature and overwhelmed the flood protection structures at the Blue Ridge Paper Products mill. Mill operations prior to Ivan were still curtailed from Frances. We took aggressive additional flood protection measures to prepare for Ivan, but the Pigeon River ultimately rose higher than these extra measures could protect. The Ivan flood and second loss of wastewater treatment resulted in overflow of untreated sewage from the Town of Canton into the Pigeon River. We will learn from both floods and prepare a strategy to strengthen flood protection at the mill. Blue Ridge Paper Products and the Town of Canton worked diligently and non-stop to restore treatment of the town's wastewater following the Ivan flood. We were able to restore essential wastewater services within 4.25 days of the flood event. The Town restored wastewater disinfection within 2.5 days of the flood event. We greatly appreciate DENR's assistance and understanding with the emergency recovery efforts. In particular, we appreciate the multiple site visits by Keith Haynes of your staff to assess flood damage and recovery efforts for wastewater treatment. Sincerely — Paul S. Dickens Manager, Environmental Affairs 828-646-6141 dickep@blueridgepaper.com Enclosure: SSO Form for Ivan flood event Environmental Group 175 Main Street • PO Box 4000 Canton, North Carolina 28716 • 828-646-2000 Raising Your Expectations OF VJATF9 Form CS-SSO Collection System Sanitary Sewer Overflow Reporting Form P ^C PART I This form shall be submitted to the appropriate DWQ Regional Office within five days of the first knowledge of the sanitary sewer overflow (SSO). Permit Number: NC 0000272 (WQCS# if active, otherwise use treatment plant NC/WQ#) Facility: Blue Ridge Paper Products, Inc. -Wastewater Treatment Plant Incident # — Owner: Blue Ridge Paper Products, Inc. City: Mill also treats wastewater for Town of Canton, NC Source of SSO (check applicable) : 0 Sanitary Sewer 0 Pump Station Region: Asheville County: Haywood Co. SPECIFIC location of the SSO (be consistent in description from past reports or documentation - i.e. Pump Station 6, Manhole atWestallBBragg Street, etc,): Multple werflows to Pigeon River In Cantan, NC dudng and after Ivan flood until flood damage cculd be repaired. Latitude (degrees/minute/second): 35132/06 Longitude(degrees/minute/second) 82/50/34 Incident Started Dt: 09-17-2004 Time, 4:08 am (mm-dd-yyyy) hh:mm AM/PM Estimated volume of the SSO: unknown > 15,000 gallons Incident End DT09-21-2004 Time, 11:45 am (mm-dd-yyyy) hh:mm AM/PM Estimated Duration (Round to nearest hour); Describe how the volume was determined: Flood conditions, overflows mixed with flood waters, total volume unknown Weather conditions during SSO event: Hurricane Ivan, record flood on Pigeon River in Canton, NC, 2nd flood in 9 days Did SSO reach surface waters? El Yes❑No❑ Unknown Volume reaching surface waters (gallons): unknown Surface water name: Pigeon River Did the SSO result in a fish kill? ❑ Yes ❑✓ No ❑ Unknown If Yes, what is the estimated number of fish killed? SPECIFIC cause(s) of the SSO: ❑✓ Severe Natural Condition ❑ Grease ❑ Roots ❑ Inflow and Infiltration ❑ Pump Station Equipment Failure ❑ Power outage ❑ Vandalism ❑ Debris in line ❑ Other (Please explain in Part II) Immediate 24-hour verbal notification reported to: DENR 1-800 number at 06:50 on 9/17, follow-up with Keith Haynes ARO 0 DWQ ED Emergency Mgmt. Date (mm-dd-yyyy): 09-17-2004 Time (hh:mm AM/PM): 6:50 am If an SSO is ongoing, please notify Regional Office on a daily basis until SSO can be stopped. Per G.S. 143-215.1 C(b), the responsible party of a discharge of 1,000 gallons or more of untreated wastewater to surface waters shall issue a press release within 48-hours of first knowledge to all print and electronic news media providing general coverage in the county where the discharge occurred. When 15,000 gallons or more of untreated wastewater enters surface waters, a public notice shall be published within 10 days and proof of publication shall be provided to the Division within 30 days. Refer to the referenced statute for further detail. The Director, Division of Water Quality, may take enforcement action for SSOs that are required to be reported to Division unless it is demonstrated that: 1) the discharge was caused by severe natural conditions and there were no feasible alternatives to the discharge; or 2) the discharge was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the Permittee and/or owner, and the discharge could not have been prevented by the exercise of reasonable control. Part II must be completed to provide a justification claim for either of the above situations. This information will be the basis for the determination of any enforcement action. Therefore, it is important to be as complete as possible. WHETHER OR NOT PART II IS COMPLETED, A SIGNATURE IS REQUIRED AT THE END OF THIS FORM. CS-SSO Form October 9, 2003 Page 1 �o� wnr�y G 9 Form CS-SSO Collection System Sanitary Sewer Overflow Reporting Form PART I I ANSWER THE FOLLOWING QUESTIONS FOR EACH RELATED CAUSE CHECKED IN PART I OF THIS FORM AND INCLUDE THE APPROPRIATE DOCUMENTATION AS REQUIRED OR DESIRED COMPLETE ONLY THOSE SECTIONS PERTAINING TO THE CAUSE OF THE SSO AS CHECKED IN PART I In the check boxes below, NA = Not Applicable and NE = Not Evaluated A HARDCOPY OF THIS FORM SHOULD BE SUBMITTED TO THE APPROPRIATE DWQ REGIONAL OFFICE UNLESS IT HAS BEEN SUBMITTED ELECTRONICALLY THROUGH THE ONLINE REPORTING SYSTEM Severe Natural Condition (hurricane, tornado, etc.) Describe the" severe natural condition" in detail. Passage of Hurricane Ivan resulted in record flood, overtopped flood dikes and flooded WTP. How much advance warning did you have and what actions were taken in preparation for the event? Activated revised flood plan on 9/16 and took all reasonable precautions to prevent flood of WTP Comments: Blue Ridge Paper WTP also treats sewage from Town of Canton. Mill shutdown, sewage from town overflowed. When was the last time this specific line (or wet well)was cleaned? Do you have an enforceable grease ordinance that requires new or retrofit of grease traps/interceptors? Have there been recent inspections and/or enforcement actions taken on nearby restaurants or other nonresidential grease contributors? Explain. Not applicable []Yes[] No UNA❑NE []Yes[] No U (NA Have there been other SSOs or blockages in this area that were also caused by grease? ❑Yes❑ No UNA ❑NE When? If yes, describe them: Have cleaning and inspections ever been increased at this location? []Yes[:] No bNA FINE Explain. CS-SSO.Form October 9, 2003 Page 2 Have educational materials about grease been distributed in the past? When? and to whom? Explain? If the SSO occurred at a pump station, when was the wet well and pumps last checked for grease accumulation? Were the floats clean? Comments: Roots Do you have an active root control program? Describe ❑Yes❑ No W NA ❑ NE []Yell] No NA❑NE ❑Yes❑ No NA❑NE Have cleaning and inspections ever been increased at this location because of roots? ❑Yes❑ No MINAUNE Explain: What corrective actions have been accomplished at the SSO location (and surrounding system if associated with the SSO)? What corrective actions are planned at the SSO location to reduce root intrusion? Has the line been smoke tested or videoed within the past year? ❑Yes❑ No NA❑NE If Yes, when? Comments: Inflow and Infiltration Are you under an SOC (Special Order by Consent) or do you have a schedule in any permit that []Yes[:] No NA❑NE addresses I/I? CS-SSO Form October 9, 2003 Page 3 Explain if Yes: What corrective actions have been taken to reduce or eliminate I & I related overflows at this spill location within the last year? Has there been any flow studies to determine 1/1 problems in the collection system at the SSO location? ❑Yes1--I[] No NA❑NE If Yes, when was the study completed and what actions did it recommend? Has the line been smoke tested or videoed within the past year? ❑Yes❑ No LZINA ❑NE If Yes, when and indicate what actions are necessary and the status of such actions: Are there 1/1 related projects in your Capital Improvement Plan? LJYeL1 No L&NA NE If Yes, explain: Have there been any grant or loan applications for 1/1 reduction projects? ❑Yes❑ No BNA ❑NE If Yes, explain: Do you suspect any major sources of inflow or cross connections with storm sewers? ❑Yes[] No UNA ❑NE If Yes, explain: Have all lines contacting surface waters in the SSO location and upstream been inspected recently? ❑Yes❑ No NA❑NE If Yes, explain: What other corrective actions are planned to prevent future 1/1 related SSOs at this location? Comments: Pump Station Equipment Failure (Documentation of testing records shoul be provided upon request.) What kind of notification/alarm systems are present? Auto-dialer/telemetry (one-way communication) ❑✓ Yes CS-SSO Form October 9, 2003 Page 4 Audible aes Visual ❑Yes SCADA (two-way communication) ❑Yes Emergency Contact Signage ❑Yes Other ❑Yes Describe the equipment that failed? Flood waters submerged WTP and sewage pump stations, power was lost as result of flooding What kind of situations trigger an alarm condition at this station (i.e. pump failure, power failure, high water, etc.)? high level Were notification/alarm systems operable? Yes❑ NoENA NE If no, explain: If a pump failed, when was the last maintenance and/or inspection performed? What specifically was checked/maintained? If a valve failed, when was it last exercised? Were all pumps set to alternate? Did any pump show above normal run times prior to and during the SSO event? Were adequate spare parts on hand to fix the equipment (switch, fuse, valve, seal, etc.)? Was a spare or portable pump immediately available? If a float problem, when were the floats last tested? How? If an auto -dialer or SCADA, when was the system last tested? How? Comments: ❑Yes[]No[ INA❑NE ❑Yes❑ No UNA❑NE ❑Yes❑ No NA❑NE ❑Yen No NA❑NE CS-SSO Form October 9, 2003 Page 5 etc.. should be What is your alternate power or pumping source? •Generator Did it function properly? ❑Yes❑ No BNAFINE Describe? When was the alternate power or pumping source last tested under load? If caused by a weather event, how much advance warning did you have and what actions were taken to prepare for the event? Activated revised flood plan on 9/16 and took all reasonable precautions to prevent flood of WTP Comments: Vandalism Provide police report number: �-ry Was the site secured? DYes❑No NA❑NE If V.. hn,. ) Have there been previous problems with vandalism at the SSO location? UYesLI No LJNA UNE If Yes, explain What security measures have been put in place to prevent similar occurrences in the future? []Yes[--] No t_{I NA ❑ NE Comments: Debris in line (Rocks, sticks, rags and other items not allowed in the collection system, etc.) What type of debris has been found in the line? How could it have gotten there? Are manholes in the area secure and intact? UYesU No UNA NE CS-SSO Form October 9, 2003 Page 6 When was the area last checked/cleaned? Have cleaning and inspections ever been increased at this location due to previous problems with debris? ❑Yes❑ No MINA ❑NE Explain: Are appropriate educational materials being developed and distributed to prevent future similar ❑Yes[] No occurrences? Comments: Other (Pictures and a police report should be available upon request.) Describe: Were adequate equipment and resources available to fix the problem? ❑Yes❑ No LANA ❑NE If Yes, explain: If the problem could not be immediately repaired, what actions were taken to lessen the impact of the SSO? Comments: For DWQ Use Only: DWQ Requested an Additional Written Report: If Yes, What Additional Information is Needed: Comments: ❑Ye ^ No /NA❑NE SSOs were result of 2nd major flood event in 9 days that damaged wastewater treatment plant owned by Blue Ridge Paper Products and also damaged sewage pump stations owned by Town of Canton. See letter from Blue Ridge Paper Products dated 22 Sep 2004. CS-SSO Form October 9, 2003 Page 7 As a representative for the responsible party, I certify that the information contained in this report is true and accurate to the best of my knowledge. Person submitting claim: Bob Shanahan Signature: /� Title: Telephone Number. 828-646-2840 Date: 22 Sep 2004 VP and Mill Manager Any additional information desired to be submitted should be sent to the appropriate Division Regional Office within rive days of first knowledge of the SSO with reference to the incident number (the incident number is only generated when electronic entry of this form is completed, if used). Reference letter from Blue Ridge Paper Products dated 22 September 2004. CS-SSO Form October 9, 2003 Page 8 contact: Robert Williams, Director -Regulatory Affairs Blue Ridge Paper Products Inc. Phone: (828) 646 —2033 Email:,Mllib@blueddqepaper.com For Immediate Release BLUE RIDGE PAPER PRODUCTS INC. City of Canton's Municipal Waste Returned to Full Treatment Canton, NC -- September 22, 2004 -- On September 16, 2004 Haywood County and Western North Carolina again received floodwaters. Hurricane Ivan caused the shutdown of Blue Ridge Paper Products' wastewater treatment plant. Manufacturing operations at the Canton Mill were still in curtailment from the floods associated with Hurricane Frances that occurred on September 8`b' The Blue Ridge wastewater treatment plant also receives municipal waste from the Town of Canton. As a result of this shut down untreated waste from the Town of Canton was released to the Pigeon River. On September 21, 2004 Blue Ridge Paper Products was able to fully restore wastewater treatment operations. Town of Canton and Blue Ridge Paper personnel worked diligently and non-stop to restore wastewater services following the flood. Representatives of the Haywood County Health Department, the North Carolina Department of Environment and Natural Resources, and Haywood County Emergency Services were notified of flood damage to Canton and Blue Ridge wastewater treatment systems. These agencies closely monitored actions to restore essential wastewater services and provided valuable assistance with the flood response effort. Sep-14-2004 07:50pm Ffwr6LLE RIDGE PAPER 8286466892 T-068 P.001 F-384 c BLUE RIDGE PAPER PRODUCTS IMc 175 MAIN STREET CANTON, NC 28716 FACSIMILE TEANSIAITTAL SHEET `ro: FROM: COMPANY: DATE: rLA SAP zo0LI FAX NUMBER: <9Zj:? 24q -404 3 TOTAL NO. OP PAGES iNCLUWNG COVER: - 11FIOME NETMER: SENOFR'S REFERENCE 14U9ffiERv yzs - 291'--L["so0 ItE_ YO[E' REFERENCE NUbIBER: sL �-P�•-�- El URGENT Al FOR REVIEW ❑ PLEASE COMMENT [I PLEASE REPLY ❑ PLEASE RECYCLE (VOTES/COMMENTS, `: rJ7�1., (7A.!L S�11 do <? s� -zoo 4, eI q 1 IAI>IflatltlfQ6Rn irpruirildtai Ijymelw.saraeeurltiivmmmrtrrim return, by mail, the original message to us. Thank you.' Serr14-2004 07:50pm FrurBLUE RIDGE PAPER 8286466892 T-068 P.002 F-384 Paul To keith.haynes@ncmall.net DickenslCerdon/BlueRidge fonest.westall@ncmailmet. John 09/14/2004 0722 PM Pryately/Canton/BlueRtdge@BlueRidgePaper, Bob William K-antonlBlueRidge@BlueRidgePaper, Daryl 4YhitUCantonlBImRidge@BlueRidgePaper, Michael KoerscbnerlCantonA31ueRidge@BlueRidgePaper, Steve hcc Si ngl e/Canto n/BlueRidge@BlueRidg ePaper Subject Blue Ridge Flood Outage Letter and Status Update 14 Sep 2004 Keith Haynes, NC DENR ARO DWO - An electronic copy of our flood outage letter is attached. I will also fax a copy with the enclosure tonight. We serit this out by certIfled mail this morning, and tonight I found one typo on the last page. We were able to restore full treatment of the town of Canton wastewater within 3.5 days or 82 hours of the time that we lost wastewater treatment to floodwaters. This is corrected on the electronic copy and fax. Blue Ridge Paper Products greatly appreciates your help and assistance with restoring wastewater treatmcmt after the flood. Your visits an 8 September and today were great. Thanks also for your guidance on replacing our flood damaged strip chart recorders with more modem data trend loggers. I think this is the coat, we will go. As you are aware, Blue Ridge contracted with PACE Labs to inn our dally process and compliance wastewater samples. This will continue until we are able to restore our former wastewater lab capability. We have restored on -site capability for pH, DO, conductivity, temperature and color monitoring. Compliance sampling and the dally river inn resumed on 12 September, or within 4 days of the flood. Yesterday, we restored our wastewater flow totalizer. We continue to take 4-hr manual flow readings as well as pH and DOs to check that our instrumentation is reading correctly. We do not yet have continuous flow or pH recording although the instruments are working and providing readouts IocaRy or In our control room. ,NubDmaUc data recording capability will take a while to restore. We will have a gap In our wastewater compliance monitoring from 7 September thru 11 September 2004 due to the flood. I previously sent you an e-mail documenting the samples in our refrigerator that were lost to the flood. I also sent you information on our flood protection plan for Ivan expected this Friday. Keith, cote again, thank you so much for DENR's help and assistance with the flood. Paul Dickens Manager, Environmental Affairs Blue Ridge Paper Products, Inc. dickepdpblueridgepaper.com 828-64141i-6141 FAX 828-646-6892 l FITI fI=dlvN,U994.doc Sep-14-2004 07:51pm From -BLUE RIDGE PAPER 8286466892 T-068 P.003 F-384 BLUE RIDGE rwren rrzoouars ixr. CERTIFIED MAIL RETURN RECEIPT REQUESTED 14 September 2004 7099 3220 0007 0371 5306 Mr. Forrest Westal Water Quality Supervisor North Carolina Department of Environment :md Natural Resources Asheville Regional Office Division of Water Quality 2090 US Hwy 70 Swannanoa, North Carolina 28778 SuiDject: NPDES NC0000272 Flood Event of 8 September 2004 Unanticipated Bypass of Treatment Sanitary Sewer Overflow Blue Ridge Paper Products, Inc. Town of Canton, North Carolina Dear Forrest — Th is is the written report required under the subject permit documenting flood damage and loss of wastewater treatment associated with hurricane Frances on the morning of 8 September 2004. The wastewater treatment plant operated by Blue Ridge Paper Products also treats sewage from the Town of Canton. This report is submitted for both Blue Ridge Paper Products and the Town of Canton. Wt: notified DENR by telephone at 0745 on the morning of 8 September that the mill was shut down and that our wastewater plant was flooded. We subsequently provided daily updates on progress towards restoring wastewater treatment for the town's wastewater. Wastewater treatment was restored on the afternoon of 11 September 2004. During the period that wastewater treatment was down, untreated sewage from the town entered the Pigeon River, both from the mill's influent lift station and from the town's sewage pump stations that were submerged and damaged by floodwater. Since mil operations were curtailed in advance of the flood and remained down, there was no release of untreated industrial wastewater. Chemicals and oil storage on the Blue Ridge site remained secure. Environmental Group 175 Maio Street . PO Box 4000 Canton, North CarolIna 28716 • 828-646-2000 Raising Your Expectations Sep-14-2004 07:51pm Frmn-BLUE RIDGE PAPER 8236466892 T-068 P.004/015 F-384 Forrest Westall, NC DENR ARODWQ 14 Sep 2004, Page 2 Flood Event The remnants of hurricane Frances passed through Western North Carolina on 7 and 8 September 2004. The mill began a flood watch early on the morning of 7 September. Based on water levels in Pigeon River, the mill activated its flood protection plan at 1600 on 7 September and installed floodgates in the dikes protecting the mill and wastewater treatment plant. At - 1900 the mill began a controlled shutdown of the backend of the mi:11- recovery and pulp production - as a precaution against flcwding. At .- 2200 based on rapid river rise, we began a controlled shutdown of paper production as a precaution agadnst flooding. We also started a controlled shutdown of power boilers. At 0253 on the morning of 8 September, floodwaters backed up into the wastewater treatment area and overtopped the secondary clarifiers. At that time, the low lift pumps to wastewater treatment were stopped. This started an unanticipated bypass of treatment necessary to prevent severe property damage. At this time all mill operations were down, and chemical and oil tanks were secure. Aerators in the aeration basins were turned off to !tebde and store activated sludge. At 0330 on 8 September, power to the mill site including wastewater treatment was turned off to prevent damage to electrical substations and switch gear from flood water. The mill went cold at that time, and all industrial wastewater generation stopped. At - 0600 on 8 September, the Pigeon River crested at 21 feet, a record for Canton. The mi I1's protective dike system was overtopped. There was 4 to 5 feet of water in the wastewater area. This water flooded the influent lift station, secondary clarifiers and sw..tch gear rooms as well as the wastewater control room, lab and offices. The aeration basins and primary clarifiers remained above flood level. Downtown Canton was severely flooded, and the town's sewage pump stations along the Pigeon River were submerged. The towns disinfection pretreatment system located at the head -works of the Blue Ridge wastewater plant was also submerged. Recovery Flood waters started to recede on the afternoon of 8 September. By the morning of 9 September, Blue Ridge was able to drain and pump remaining floodwater from the wastewater area and start work to restore wastewater treatment. The Town of Canton also began work to repair and restore sewage pump stations damaged by die flood. To drain retraining floodwaters from the wastewater treatment plant and from the mill, portable diesel pumps were installed at the influent low lift pumps to the mill's wastewater treatment system. These pumps discharged to the river. Environmental Group 175 Main Street . PO Box 4000 Canton, North Carolina 28716 • M-646-2000 Raising Your ExPOctalfons Sep-14-2004 07:52pm From -BLUE RIDGE PAPER 8286466992 T-068 P.005/015 F-384 Forrest Westall, NC DENR ARO DWQ 14 Sep 2004, Page 3 Ont the morning of 10 September 2004, the Town of Canton was able to restore the disinfection pretreatment system. At that time, the town began plumping sewage back to the: mill's wastewater headworks. The disinfected wastewater was then pumped into the river. This interim treatment had been discussed with DENR staff and was agreed as the best measure for public health protection until full treatment could be restored. Work by Blue Ridge personnel to restore wastewater treatment continued non-stop after floodwaters were drained from rite wastewater area. Blue Ridge was able restart wastewater treatment operations on the afternoon of 11 September 2004. Discharge of untreated and partially treated sewage from the Town of Canton through diesel pumps at the mill's wastewater headworks stopped at — 1250 on I 1 September. Blue Ridge resumed compliance monitoring of the wastewater plant effluent that night. Sanitary Sewer Overflows The Blue Ridge wastewater treatment facilities were down from 0300 on 8 September 2004 until the afternoon on 11 September 2004. During this period, untreated sewage from the Town of Canton was discharged to the Pigeon River, both from overflows at damaged pump stations owned by the town and from the influent of the mill's wastewater treatment system. Floodwaters and cleaning water from the mill and town were also discharged to the river. The quantity of sewer system overflow is difficult to estimate, but is greater than 15,000 gallons. The majority of the overflow was floodwater and cleaning water necessary to restore sewage pump stations and wastewater treatment The mill locked restrooms and installed portable toilets during the wastewater treatment outage to avoid discharge of domestic sewage to the river from the mill. An SSO reporting form is enclosed for the period of wastewater treatment outage Summary Th'..s event was truly a severe act of nature and overwhelmed the flood protection structures at the Blue Ridge Paper Products mill in Canton, North Carolina. We executed a controlled shutdown of the mill in advance of the flood and prevented release of untreated industrial wastewater, chemicals or oil. The flood and loss of wastewater treatment did result in overflow of untreated sewage from the Town of Canton into the Pigeon River. We will leam from this event and make revisions to the mill's flood protection plan. Environmental Group 175 Main Street • PO Box 4000 Canton, North Carolina 28716 • 1328-646-2000 Raising Your Expectations Sep-14-2004 07:52pm Frmn-BLUE RIDGE PAPER 8286466892 T-068 P.006/015 F-384 Forrest Westall, NC DENR ARO DWQ 14 Sep 2004, Page 4 President Bush declared Western North Carolina as a Federal disaster area as a result of the hurricane Frances flood. Blue Ridge Paper Products and the Town of Canton. worked diligently and non-stop to restore treatment of the town's wastewater following the flood. We: were able to restore essential wastewater services within 3.5 days of the flood event. We greatly appreciate DENR's assistance and understanding with the emergency recovery efforts. In. particular, we appreciate the site visit by Keith Haynes and Roy Davis of your staff on 8 September to assess flood damage to our wastewater plain. Sincerely — Paul S. Dickens Manager, Environmental Affairs 823-646-6141 dickep@blueridgepaper.com Enclosure: SSO Form for flood event Environmental Group 175 Main Street . PO Box 4000 Canton, North Carolina 28716. 828-646-2000 Raising Your Expectations Contact: Robert Williams, Director- Regulatory Affairs BLUE RIDGE Ridge Paper Products Inc. Phone: (828) 646 —2033 PAPER PRODUCTS INC. Email: willib®blueridceoaoer.com For Immediate Release City of Canton's Municipal Waste Returned to Full Treatment Canton, NC -- September 22, 2004 -- On September 16, 2004 Haywood County and Western North Carolina again received floodwaters. Hurricane Ivan caused the shutdown of Blue Ridge Paper Products' wastewater treatment plant. Manufacturing operations at the Canton Mill were still in curtailment from the floods associated with Hurricane Frances that occurred on September 8th The Blue Ridge wastewater treatment plant also receives municipal waste from the Town of Canton. As a result of this shut down untreated waste from the Town of Canton was released to the Pigeon River. On September 21, 2004 Blue Ridee Paper Products was able to fully restore wastewater treatment operations. Town of Canton and Blue Ridge Paper personnel worked diligently and non-stop to restore wastewater services following the flood. Representatives of the Haywood County Health Department, the North Carolina Department of Environment and Natural Resources, and Haywood County Emergency Services were notified of flood damage to Canton and Blue Ridge wastewater treatment systems. These agencies closely monitored actions to restore essential wastewater services and provided valuable assistance with the flood response effort. YCCz . H-%,VLr, Temporary Results Summary - Wastewater Treatment BRPPI 22-Sep-04 Flow PI Color SE Color MLSS MLVSS Wst Sludge PI TSS PE TSS SE BOD-5 SE TSS SE NH3-N Date mad DOM lbs/day DOM Ibs/da m mgfL m m mgfL m lbstday mgn lbstday mqA Limits Max day 3,205 12,459 Month avg 29.9 52,000 10,897 49,560 9/7 - 9/11/04 Frances flood, WTP down or samples / data lost 9/12/2004........................12:0....................371,..,,,,,,,,,,37,130,.__...,..,,,,,.....190...,,,,,,.,..19,015......____,2;000__............1,560,,,,,,,,,,,,,.. .... no waste ... _...... ..... 610 .............................................................................................................................................................................................. 140 14 1,401 49 4,904 9/13/2004 _13_6 , .504 _ 57,166 ....._........... __..... _. _ 147 16.673 _..._............................................................. 2,700 2,120 6,900 ._................................................................._._..._..___......_.........................._.. 1,600 110 9 1,021 ..._...................._..._.......................................................... 38 4,310 9/14/2004 .16. .326 44,589 184 ........_ 25,167 ._.._.................................................. 2,500 1.790 no waste __..............................................____ 1,800 140 __._..._._....._..._ 10 __..............................._._.................. 1,368 58 ._ 7,933 _.......__............. .................... _ 9/15/2004..._ ............................. .._.._..........._501..............73.957 ............... 231. I ....................... .............._2.700 __2.060 ............._no,waste ............ ..........._.._ 6. __............_280 ........___.__.........................._...._......................._ .. _....._3.100 ............._�.:14 9/16/2004......................._Po:e..................._403.............69.909..................._293..........._50,827 samples.losttolvan.flood............................................._.................................... 9/17/2004........_SeoonU,flood from Ivan. WTP down .................................................................................................................................................................................................................................................................. .................. .............................. ............................. ......................... 9/18/2004 ............................................................................................................................................................................................................................................................................................................................................................................................................................................................................................. Second flood from Ivan, WTP down 9/1912004 ............................................................................................................................................................................................................................................................................................................................................................................. Second flood from Ivan, WTP down -............................ .............................. .......... _................. ........................ . 9/20/2004 Second flood from Ivan, WTP down ................................. __................................. .............................. .............. .. ............................. .............................. .___...___............. ............................. ...................... __. _...... ..................... .......... _................ ...... .._.._._............ _................ _......... . ....................... 9/21/2004 , _Second flood. from. Ivan, WTP down (restarted at - 12 noo........... . 9/22/2004 _......... _........ __ _...................... ............................. .... _._.................................... .......................... _... .........._..._.__ 9/2 3/2004 ..........................................................................................................................................................................................._.._............................................................................................................ ............................ ........ _................... ............................... .............. .... ........... ............................. ............ ...__...... 9/24/2004 ............................. .................................................................................................................................................................................................................................................................................................................................................................................................................................... I........................ 9/25/2004 .............................. ............................. ............................. ............................... .............................. ............................. ............................. .............................. ................................... ............................... ............................. ........ .................... ............................... ..... .... ..................... ............................. ............... -........ 9/26/2004 .............................. .............................. ............................. .............................. .............................. .......... _..-..__...... ............... _............. .............................. ................................... ............................... ............................. ........ .................... .............................. .............................. ............................. ......................... 9/27/2004 ...................._._ ..............................._..._.._......_..........................................-...... ............... _. _. ___. _. __.......... 9/28/2004 9/29/2004 ....._ ..................................................... _........ _._W__.._...........__ _.... _._... _............. ............................. ........... __.__ 9/30/2004 Ibs/day = flow (mgd) x conc (ppm or mg/1) x 8.34 tempflowcolor.xls, Temp Sum Pace 1 of 1 Printpri a/22/2004 9/22/2004 7:55:54 AM Morning Report - WTP Canton Mill WWTP Database 9/1/2004 TO 9/30/2004 Date Flw. 12MN SE.TSS SE.TSS SE.BOD SE.BOD SE.COD SE Col ST SE.Color SE.DO SE.pH SE.pHI.Min an d mg/1 lb/daym /1 Ib/da mg/1 mg/1 °lb/day' mg/1 H H a/I2uu4 404.01 Z/.uu b,b18.3Ld /.b8 1,b49.bZ 234.00 47,834.59 7.81 7.70 7.60 9/2/2004 24.27 8.00 1,619.03 6.78 1,372.13 213.00 43,106.61 7.78 7.70 7.60 9/3/2004 23.74 8.00 1,583.93 197.00 39,004.35 8.54 7.70 7.50 9/4/2004 22.74 8.00 1,517.21 185.00 35,085.55 7.76 7.80 7.70 9/5/2004 23.70 8.00 1,581.00 211.00 41,698.80 8.46 7.70 7.60 9/6/2004 24.62 19.00 3,900.65 205.00 42,085.98 10.39 7.30 7.10 9/7/2004 33.21 12.00 3,323.86 260.00 72,016.90 8.97 7.30 7.30 9/12/2004 10.56 9/13/2004 9.03 9/14/2004 9.64 9/15/2004 10.98 9/16/2004 7.08 Average 25.25 12.86 2,720.72 7.18 1,460.82 215.00 45,833.27 8.92 7.60 7.49 Total 176.78 90.00 19,045.07 14.36 2,921.64 0.00 1,505.00 320,832.86 107.00 53.20 5240 Minimum 22.74 8.00 1,517.21 6.78 1,372.13 185.00 35,085.55 7.08 7.30 7.10 Maximum 33.21 27.00 5,519.39 7.58 1,549.52 260.00 72,016.90 10.98 7.80 7.70 Page 1 9/22/2004 7:55:54 AM Morning Report - WTP Canton Mill WWTP Database 9/1/2004 TO 9/30/2004 Page 2 Date SE.pH.Max SENH3comp SE.Res.P SE DS PI.TSS PI.TSS PI.BOD PI.BOD PI Col ST PI.Color PI.Temp H m /I mg/1 Ibs/da m /1 Ib/da m /1 Ib/da mg/1 "Ib/da " de C 9/1/2004 7.70 0.11 1.09 642.00 131,238.76 256.83 52,501.64 280.00 57,238.09 44.50 9/2/2004 7.70 0.08 1.39 548.00 110,903.39 290.42 58,774.75 321.00 64,963.48 46.40 9/3/2004 7.70 0.09 1.04 602.00 119,190.94 287.00 56,823.59 46.20 9/4/2004 7.80 0.07 0.51 596.00 113,032.35 367.00 69,602.14 45.80 9/5/2004 7.80 0.06 0.43 622.00 122,922.53 369.00 72,923.49 46.60 9/6/2004 7.60 0.08 1.79 474.00 97,310.99 381.00 78,218.32 47.80 9/7/2004 7.60 0.08 1.06 604.00 167,300.80 264.00 73,124.85 44.10 9/12/2004 19.00 9/13/2004 19.10 9/14/2004 19.00 9/1512004 25.00 Average 7.70 0.08 1.04 584.00 123 128.54 273.63 55,638.19 324.14 67,656.28 36.03 Total 53.90 0.57 7.31 0.00 4,088.00 861,899.75 547.25 111,276.38 2,269.00 472,893.96 432.40 Minimum 7.60 0.06 0.43 474.00 97,310.99 256.83 52,501.64 264.00 56,823.59 19.00 Maximum 7.80 0.11 1.79 642.00 167,300.80 290.42 58,774.75 381.00 78,218.32 47.80 9/22/2004 7:55:55 AM Morning Report - WTP Canton Mill W WTP Database 9/1 /2004 TO 9/30/2004 Date PE.TSS PE.TSS PE.BOD PE.BOD Waste.SS WasIa.SS MLSS MLVSS ML.%Vol F/M.BOD MCRT m /1 Ib/da mg/1 Ib/da mg/1 Ib/da mg/1 mg/1 % days `J/l/ZVU4 63A0 lb,9b/.00 186.6U J8,14b.1u 1,912.00 11, 162.2u 2,213.00 1,874.00 84.68 0.37 5.23 9/2/2004 62.00 12,547.46 178.20 36,063.84 2,136.00 19,239.38 2,155.00 1,835.00 85.15 0.36 5.69 9/3/2004 46.00 9,107.61 2,040.00 13,610.88 2,101.00 1,774.00 84.44 7.61 9/4/2004 69.00 13,085.96 1,920.00 12,810.24 2,043.00 1,755.00 85.90 7.85 9/5/2004 49.00 9,683.61 1,844.00 12,303.17 2,101.00 1,855.00 88.29 8.33 9/6/2004 63.00 12,933.74 2,332.00 15,559.10 2,100.00 1,860.00 88.57 5.94 9/7/2004 58.00 16,065.31 1,904.00 12,703.49 2,053.00 1,796.00 87.48 7.05 Average 61.43 12 912.96 182.40 37 104.47 2,021.14 14 855.49 2,109.43 1,821.29 86.36 0.36 6.81 Total 430.00 90,390.70 364.80 74,208.93 14,148.00 103,988.46 14,766.00 12,749.00 604.52 0.73 47.70 Minimum 46.00 9,107.61 178.20 36,063.84 1,844.00 12,303.17 2,043.00 1,765.00 84.44 0.36 5.23 Maximum 83.00 16,967.00 186.60 38,145.10 2,332.00 19,239.38 2,213.00 1,874.00 88.57 0.37 8.33 Page 3 9/22/2004 7:55:55 AM Morning Report - WTP Canton Mill WWTP Database 9/1/2004 TO 9/30/2004 Date SVI.30 % Recycle Pri%BODrm BOD.T.%Rm Plymr-Sec Poly SDMs %WAS->SDM CaFlw Avg Ca.BOD CA DO Avg mU % % % m Ibs/ton 9/1/2004 355.63 27.34 97.05 5.30 11.92 119.57 7.59 9/2/2004 365.20 38.64 97.67 6.80 14.78 216.52 7.41 9/3/2004 384.10 5.66 10.25 193.90 7.98 9/4/2004 427.31 7.98 10.18 140.90 7.80 9/5/2004 418.85 6.37 9.10 122.80 7.45 9/6/2004 382.38 9.01 13.78 124.09 7.28 9/7/2004 386.26 3.66 7.06 7.61 9/12/2004 8.54 9/13/2004 8.76 9/14/2004 8.65 9/16/2004 8.68 Average 388.53 32.99 97.36 6.40 11.01 152.96 8.00 Total 2,719.73 0.00 65.99 194.71 0.00 44.78 77.07 917.78 0.00 96.05 Minimum 355.63 27.34 97.05 3.66 7.06 119.57 728 Maximum 427.31 38.64 97.67 9.01 14.78 216.52 8.76 Page 4 9/22/2004 7:55:55 AM Morning Report - WTP Canton Mill WWTP Database 9/1/2004 TO 9/30/2004 Date Ca.pH I Ca Col ST Ca.Temp Delta T. Fi.Temp FLpH FLBOD AC DO Avg BC DO Avg I HeFlow Av HE Col ST 9/1/2004 7.20 19.00 20.40 2.70 23.10 7.50 6.06 245.60 66.00 9/2/2004 6.90 18.00 19.50 0.30 19.80 7.00 6.44 442.08 34.00 9/3/2004 6.90 18.10 1.20 19.30 7.10 7.87 383.91 9/4/2004 6.80 18.70 2.10 20.80 7.10 7.51 286.96 9/5/2004 6.90 19.10 2.50 21.60 7.30 7.08 255.30 9/6/2004 6.40 18.80 4.00 22.80 6.80 6.50 241.08 9/7/2004 7.00 17.40 3.80 21.20 7.10 6.95 9/12/2004 7.70 15.70 0.10 15.80 7.80 9.09 9/13/2004 7.50 15.00 -0.40 14.60 7.40 9.21 9/14/2004 7.20 14.40 0.10 14.50 7.50 8.91 9/15/2004 7.20 9.00 14.90 -0.10 14.80 7.60 9.01 8.00 9/16/2004 7.20 17.00 16.40 0.70 17.10 7.60 8.21 - 12.00 Average 7.08 15.75 17.37 1.42 18.78 7.32 7.74 309.16 30.00 Total 84.90 63.00 208.40 17.00 225.40 87.80 0.00 92.83 0.00 1,854.93 120.00 Minimum 6.40 9.00 14.40 -0.40 14.50 6.80 6.06 241.08 8.00 Maximum 7.70 19.00 20.40 4.00 23.10 7.80 9.21 442.08 66.00 Page 5 9/22/2004 7:55:56 AM Morning Report - WTP Canton Mill W WTP Database 9/1 /2004 TO 9/30/2004 Page 6 Date 140Col ST T140CoIST SE Tot N IF DO 1st FI DO 2nd Fi DO 3rd AC DO 1st AC DO 2nd AC DO 3rd SC DO 1st BC DO 2nd m/1 m/l m/l m/I mA mA m/I m/I m /I m/l mA 9/1/2004 13.00 13.00 7.64 6.06 6.05 9/2/2004 14.00 14.00 7.88 6.45 6.43 9/3/2004 8.49 7.88 7.86 9/4/2004 8.30 7.52 7.50 9/5/2004 8.60 7.07 7.09 9/6/2004 8.71 6.52 6.48 917/2004 8.92 6.96 6.94 9/12/2004 9.17 9.08 9.10 9/13/2004 9.29 9.22 9.20 9/14/2004 9.18 8.90 8.91 9/15/2004 10.00 10.00 9.44 9.02 8.99 Total 48.00 48.00 0.00 104.04 0.00 0.00 92.88 92.77 0.00 0.00 0.00 Minimum 10.00 10.00 7.64 6.06 6.05 Maximum 14.00 14.00 9.44 9.22 9.20 9/22/2004 7:55:56 AM Morning Report - WTP Page 7 Canton Mill WWTP Database 9/1/2004 TO 9/30/2004 Date BC DO 3rd H3PO4 Fed FI Temp 1 FI Temp 2 FI Temp 3 m /I lb/daydeg. C deg. C de . C 9/1/2004 0.00 23.10 9/2/2004 0.00 19.80 9/3/2004 0.00 19.30 9/4/2004 0.00 20.80 9/5/2004 0.00 21.60 9/6/2004 2,063.25 22.80 9/7/2004 0.00 21.20 9/12/2004 15.80 9/13/2004 14.60 9/14/2004 14.50 9/15/2004 14.80 9/16/2004 17.10 Average 294.75 18.78 Total 0.00 2,063.25 225.40 0.00 0.00 Maximum 2,063.25 23.10 State of North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross Jr., Secretary Alan W. Klimek, P.E., Director September 2, 2004 CANTON MILL ATTN: LOUIE JUSTUS, OR SUCCESSOR PO BOX 4000 CANTON. NC 28716 NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES Subject: NPDES Stormwater Permit Renewal Canton Mill Permit Number NCS000105 Haywood County Dear Permittee: Your facility is currently covered for stormwater discharge under NPDES Permit NCS000105. This permit expires on Apri130, 2005. North Carolina Administrative Code (15A NCAC 2H.0105(e)) requires that an application for permit renewal be filed at least 180 days prior to expiration of the current permit. In order to assure your continued coverage under your permit, you must apply to the Division of Water Quality (DWQ) for renewal of your permit. To make this renewal process easier, we are informing you in advance that your permit will be expiring. Enclosed you will find an individual permit renewal application form, supplemental information request, and Stormwater Pollution Prevention Plan certification. Filing the application form along with the requested supplimental information will constitute your application for renewal of your permit. As stated above, the application form must be completed and returned along with all requested information by in order for the permit to be renewed by April 30, 2005. Failure to request renewal by may result in a civil assessment of at least $500.00. Larger penalties may be assessed depending on the delinquency of the request. Discharge of stormwater from your facility without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and could result in assessments of civil penalties of up to $25,000 per day. If you have any questions regarding the permit renewal procedures please contact Bill Mills of the Stormwater and General Permits Unit at (919) 733-5083, ext. 548. cc: Central Files Stormwater and General Permits Unit Files Asheville -Regional Office Sincerely, Bradley Bennett, Supervisor Stormwater and General Permits Unit SEP - 7 2004 WAT`— ER QUALITY SECTIONO 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone 919-733 508ASjF@gl�[9RM gg An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% - onsumer paper January 15, 2003 To: Derrick Brown From: Bobby Cogdill Subject: Leachate Haul Record Derrick: Here are the leacbate haul records for 1999 through December 2002. July -December 1999 50 300,000 gals. January -June 2000 96 576,000 gals. July -December 2000 27 162,000 gals. January -June 2001 60 360,000 gals. July -December 2001 70 420,000 gals. January -June 2002 166 996,000 gals. July -December 2002 174 1,044,000 gals. This is a total of 643 loads for a total of 3,858,000 gallons. We are currently on track to pull at least 174 loads over the next six months unless something changes. I hope this along with the leachate analysis reports will be the information you need . Please call if you need additional information. My number is 627-8042. Thank You, Bobby Cogdill aceAnalXicale www.pacelabs.com Lab Sample No: 931351829 Client Sample ID: LEACHATE Pace Analytical Services, Inc. 2225 Riverside Drive Asheville, NC 28804 Phone: 828.254.7176 Lab Project Number: 9332954 Fax: 828.252.4618 Client Project ID: WHITE OAK LANDFILL Project Sample Number: 9332954-004 Date Collected: 09/2b/u2 1s:1u Matrix: Water Date Received: 09/27/02 09:00 Parameters Results Units Report Limit Analyzed By CAS No. Qual ReaLmt Field Services Monitoring Well Data Method: Field pH 7.48 09/27/02 MPS Field Specific Conductance 3700 09/27/02 MPS Field Temperature 18.4 09/27/02 MPS Metals Mercury, CVAAS Method: EPA 245.1 Mercury ND mg/l 0.00020 10/08/02 EWS 7439-97-6 x. Metals, ICP, trace -level Chromium Lead Selenium Date Digested Thallium, AAS Furnace Thallium Date Digested Wet Chemistry Total Dissolved Solids Total Dissolved Solids Cyanide, Total, Water Cyanide Total Kjeldahl Nitrogen Nitrogen, Kjeldahl, Total Prep/Method: EPA 3010 / EPA 6010 0.034 mg/l 0.0050 10/11/02 EWS 7440-47-3 NO mg/l 0.010 10/11/02 EWS 7439-92.1 NO mg/l 0.020 10/11/02 EWS 7782-49-2 10/09/02 10/09/02 Prep/Method: EPA 3020 / EPA 7841 NO mg/l 0.0020 10/08/02' - 10/08/02 10/08/02, Method: EPA 160.1 3000 mg/l Method: EPA 335.4 0.0025 mg/l Method: EPA 351.2 130 mg/l 10. 10/02/02 0.0020 10/10/02 1.0 10/04/02 EWS 7440-28.0 WCB ALA 57-12.5 WWB Nitrogen. Nitrate plus Nitrite Method: EPA 353.3 Nitrogen. NO2 plus NO3 NO mg/l 0.10 10/08/02 ALA Biochemical Oxygen Demand. 5 d Prep/Method: / EPA 405.1 BOD, 5 day 210 mg/l 2.0 10/02/02 DEJ Date Prepared 09/27/02 09/27/02 Chemical Oxygen Demand Method: EPA 410.4 Chemical Oxygen Demand 1300 mg/l 50. 09/30/02 WCB Date: 10/17/02 I aborato y Certification IN REPORT OF LABORATORY ANALYSIS NC Wastewater 40 This report shall not be reproduced, except in full, NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. �`nlelac:� 1.2 Page: 4 of 23 Laboratory Certification IDs TN Drinking Water 02980 SC Environmental 99030 aceAnalytical® www.paceiabs.com Pace Analytical Services, Inc. 2225 Riverside Drive Asheville, NC 28804 Phone: 828.254.7176' Lab Project Number: 9332954 Fax 828.252.4618 Client Project ID: WHITE OAK LANDFILL. Lab Sample No: 931351829 Project Sample Number: 9332954-004 Date Collected: D9/2b/D2 13:1u Client Sample ID: LEACHATE. __ ___ __ Matrix: Water Date Received: 09/27/02 09:00 Parameters Results Units Report Limit Analyzed By CAS No. Qual ReoLmt Nitrogen, Total Method: Standard Methods Nitrogen 130 mg/l 0.20 10/09/02 ALA 7727-37-9 Date: 10/17/02 Laboratory Certification IDs REPORT OF LABORATORY ANALYSIS NC Wastewater 40 This report shall not be reproduced, except in full, NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. "01 I Page: 5 of 23 Laboratory Gertification IDs TN Drinking Water 02980 SC Environmental 99030 aceAnalyticale www.pacelabs.com Lab Sample No: 931351829 Client Sample ID: LEACHATE Pace Analytical Services, Inc. 2225 Riverside Drive Asheville, NC 28804 Phone: 828.254.7176 Lab 'Project Number: 9332954 Fax: 828.252.4618 Client Project ID: WHITE OAK LANDFILL Project Sample Number: 9332954.004 Date Collected: 09/26/02 13:10 Matrix:_Water___ _ ___Date Received_ 09/27/02 09:00 Parameters Results Units Report Limit Analyzed By CAS No. Dual ReaLmt Field Services Monitoring Well Data Field pH Method: 7.48 09/27/02 09/27/02 MPS/ MPS (G (%per/J Field Specific Conductance 3700 Field Temperature 18.4 09/27/02 MPS �i &M ;' c414~: Metals Mercury, CVAAS Mercury Metals, ICP, trace -level Chromium Lead Selenium Date Digested Thallium, AAS Furnace Thallium Date Digested Wet Chemistry Total Dissolved Solids Total Dissolved Solids Cyanide, Total. Water Cyanide Total Kjeldahl Nitrogen Nitrogen, Kjeldahl, Total Method: EPA 245.1 ND mg/l 0.00020 10/08/02 EWS 7439.97-6 Prep/Method: EPA 3010 / EPA 6010 0.034 mg/1 0.0050 10/11/02 EWS 7440.47-3 ND mg/l 0.010 10/11/02 EWS 7439.92-1 ND mg/l 0.020 10/11/02 EWS 7782-49.2 10/09/02 10/09/02 Prep/Method: EPA 3020 / EPA 7841 ND mg/l 0.0020 10/08/02� - 10/OB/02 10/08/0i Method: EPA 160.1 3000 mg/l Method: EPA 335.4 0.0025 mg/l Method: EPA 351.2 130 mg/l Nitrogen, Nitrate plus Nitrite Method: EPA 353.3 Nitrogen. NO2 plus NO3 NO mg/l Biochemical Oxygen Demand, 5 d Prep/Method: / EPA 405.1 BOD, 5 day 210 mg/l Date Prepared 09/27/02 Chemical oxygen Demand Chemical oxygen Demand Date: 10/17/02 Method: EPA 410.4 1300 mg/l 10. 10/02/02 0.0020 10/10/02 1.0 10/04/02 0.10 10/OB/02 2.0 50. EWS 7440-28.0 WCB ALA 57.12.5 WWB ALA 10/02/02 DEJ 09/27/02 09/30/02 WCB Laboratory Certification ID s REPORT OF LABORATORY ANALYSIS NC Wastewater 40 This report shall not be reproduced, except in full, NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. O 6 1.2 !I � Page: 4 of 23 Laboratory Certification IDs TN Drinking Water 02980 SC Environmental 99030 aceAnalyticale www.pacelabs.com Pace Analytical Services, Inc. 2225 Riverside Drive Asheville, NC 28804 Phone: 828.254.7176 Lab Project Number: 9332954 Fax: 828.252.4618 Client Project ID: WHITE OAK LANDFILL Lab Sample No: 931351829 Project Sample Number: 9332954-004 Date Collected: 09/26/02 13:10 Client Sample ID: LEACHATE .Matrix: Water Date Received: 09/27/02 09:00 Parameters Results Units Report Limit Analyzed By CAS No. Qual RegLmt Nitrogen, Total Method: Standard Methods Nitrogen 130 mg/l 0.20 10/09/02 ALA 7727-37-9 Date: 10/17/02 Laboratory Certification IDs REPORT OF LABORATORY ANALYSIS NC Wastewater 40 This report shall not be reproduced, except in full, NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. .. CEO, nelac Page: 5 of 23 Laboratory Qgrtification IDs TN Drinking Water 02980 SC Environmental 99030 ace Analytical' www.pacelabs.com Lab Sample No: 931187264 Client Sample ID: LEACHATE 4/15 Pace Analytical Services, Inc. 54 Ravenscroff Drive Asheville, NC 28801 Phone: 828.254.7176 Fax: 828.254.4618 Lab Project Number: 9328608 Client Project ID: White Oak Landfill Project Sample Number: 9328608-012 Date CoIiectea: u4/i5/uz iz:su Matrix: Water Date Received: 04/16/02 16:40 Parameters Results Units Report Limit Analyzed by CAS No. Ftnote Reg Limit Field Services Monitoring Well Data Method: Field pH 6.71 Std. Units 04/16/02 MPS Field Specific Conductance 265 umhos/cm 04/16/02 MPS ^ Field Temperature 20.1 deg C 04/16/02 MPS®Q� Metals Mercury, CVAAS Mercury Metals, ICP, trace -level Chromium Lead Selenium Date Digested Thallium, AAS Furnace Thallium Date Digested Wet Chemistry Total Dissolved Solids Total Dissolved Solids Cyanide, Total, Water Cyanide Total Kjeldahl Nitrogen Nitrogen., Kjeldahl, Total Prep/Method: EPA 245.1 / EPA 245.1. ND mg/l 0.00020 04/29/02 TRW 7439.97-6 Prep/Method: EPA 3010 / EPA 6010 0.034 mg/l 0.0050 NO mg/l 0.010 ND mg/1 0.020 - Prep/Method: EPA 3020 / EPA 7841 NO mg/l 0.0020 Prep/Method: EPA 160.1 /,EPA 160.1 2300 mg/l 10. Prep/Method: EPA 335.2 / EPA 335.4 0.0060 mg/1 0.0020 Prep/Method: EPA 351.2 / EPA 351.2 96. mg/l 1.0 Nitrogen, Nitrate plus Nitrite Prep/Method: EPA 353.2 / EPA 353.3 Nitrogen, NO2 plus NO3 0.30 mg/1 0.10 Biochemical Oxygen Demand, 5 d Method: EPA 405.1 BOD, 5 day 740 mg/l 2.0 Date Prepared Chemical Oxygen Demand Prep/Method: EPA 410.4 / EPA 410.4 Date: 05/03/02 04/25/02 21:05 TRW 7440-47.3 04/25/02 21:05 TRW 7439-92-1 04/25/02 21:05 TRW 7782-49.2 04/25/02 04/30/02 TRW 7440-28-0 04/29/02 04/19/02 AAB 04/29/02 JDA 57-12-5 04/24/02 JDA 04/30/02 JDA 04/22/02 KHJ 04/17/02 Laboratory Certification IDs REPORT OF LABORATORY ANALYSIS NC Wastewater 40 This report shall not be reproduced, except in full, NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. Page: 12 Laboratory Certification IDs TN Drinking Water 02980 SC Environmental 99030 Pace Analytical Services, Inc. 54 RavenscroR Drive Analytical Asheville, NC 28801 Phone., 828.254.7176 www.pacelabs.com Fax: 828.254.4618 Lab Project Number: 9328608 Client Project ID: White Oak Landfill -ab Sample No: 931187264 Project Sample Number: 9328608-012 Date Collected: 04/15/02 12:30 :lient Sample ID: LEACHATE 4/15 Matrix: Water Date Received: 04/16/02 16:40 Darameters Results Units Report Limit Analyzed by .CAS No. Ftnote Reg Limit Chemical Oxygen Demand 1400 mg/l 50. 04/24/02 AAB Nitrogen, Total Nitrogen Date: 05/03/02 Method: Standard Methods 96. mg/l 0.20 04/30/02 JDA 7727-37-9 Laboratory Certification IDs REPORT OF LABORATORY ANALYSIS NC Wastewater 40 This report shall not be reproduced, except in full, NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. 00a Page: 13 Laboratory Certification IN TN Drinking Water 02980 SC Environmental 99030 aceAnalyticalm www.pacelabs.com ab Sample No: 93986412 lient Sample ID: LEACHATE Pace Analytical Services, Inc. 54 Ravenscroft Drive Asheville, NC 28801 Phone: 828.254.7176 Fax: 828.254.4618 Lab Project Number: 9323432 Client Project ID: White Oak Project Sample Number: 9323432-018 Date Collected: 09/18/01 13:10 Matrix: Water Date Received: 09/18/01 16:00 arameters Results Units Report Limit Analyzed CAS No. Ftnote Reg Limit Petal s Mercury, CVAAS Prep/Method: EPA 245.1 / EPA 245.1 Mercury NO mg/l 0.00020 09/26/01 TRW 7439.97-6 �® Metals. ICP, trace -level Prep/Method: EPA 3010 / EPA 6010 Chromium 0.023 mg/l 0.0050 09/26/01 16:05 TRW 7440-47.3 Lead NO mg/l 0.010 09/26/01 16:05 TRW 7439-92-1 Selenium 0.034 mg/l 0.020 09/26/01 16:05 TRW 7782.49.2 >. Date Digested 09/21/01 Thallium, AAS Furnace Prep/Method: EPA 3020 / EPA 7841 Thallium NO mg/l 0.0020 09/27/01 TRW 7440-28.0 Date Digested 09/26/01 Wet Chemistry Total Dissolved Solids - Prep/Method: EPA 160.1 / EPA 160.1 Total Dissolved Solids 2700 mg/l 10. 09/25/01 AAB Cyanide, Total, Water Prep/Method: EPA 335.4 / EPA 335.4 Cyanide 0.0060 mg/l 0.0020 09/25/01 JDA 57.12-5 Total Kjeldahl Nitrogen Prep/Method: EPA 351.2 / EPA 351.2 Nitrogen, Kjeldahl, Total 160 mg/l 0.10 09/25/01 JDA Nitrogen, Nitrate plus Nitrite Prep/Method: EPA 353.3 / EPA 353.3 Nitrogen, NO2 plus NO3 NO mg/l 0.10 09/26/01 JDA Biochemical Oxygen Demand. 5 d Method: EPA 405.1 BOO. 5 day 200 mg/l 2.0 09/24/01 KHJ Date Prepared 09/19/01 Chemical Oxygen Demand Prep/Method: EPA 410.4 / EPA 410.4 Chemical Oxygen Demand 510 mg/l 50. 09/25/01 AAB Nitrogen. Total Method: Standard Methods Date: 10/03/01 Laboratory Certification IDS REPORT OF LABORATORY ANALYSIS NC Wastewater 40 This report shall not be reproduced, except in full, NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. 1� LC[py Page: 18 Laboratory Certification IDs TN Drinking Water 02980 SC Environmental 99030 aceAnalXjcal" www.pacelabs.com Lab Sample No: 93986412 Client Sample ID: LEACHATE Pace Analytical Services, Inc. 54 Ravenscrolf Drive Asheville,,NC 28801 Phone: 828.254.7176 Fax: 828,254.4618 Lab Project Number: 9323432 Client Project ID: White Oak Project Sample Number: 9323432-018 Date Collected: 09/18/01 13:10 Matrix: Water Date Received: 09/18/01 16:00 Parameters Results Units Report Limit Analyzed CAS No. Ftnote Reg Limit Nitrogen 160 mg/l 0.20 10/01/01 JDA 7727-37.9 Date: 10/03/01 Laboratory Certification IN REPORT OF LABORATORY ANALYSIS NC Wastewater 40 This report shall not be reproduced, except in full, NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. 1M ��CCpyO' C�M1�� =i W�;_i'_ I. a 00 1 Page: 19 Laboratory Certification IDs TN Drinking Water 02980 SC Environmental 99030 aceAnalytical� www.pacelabs.com Lab Sample No: 93837094 Client Sample ID: LEACHATE Parameters Field Services Field Grab Data Field pH Field Temperature Field Specific Conductance Wet Chemistry Mercury. CVAAS Mercury Metals, ICP, trace -level Chromium Lead Selenium Date Digested Thallium. AAS Furnace Thallium Date Digested Pace Analytical Services, Inc. 54 Ravenscrolt Drive Asheville, NC 28801 Phone: 828.254.7176 Fax:828.252.4618 Lab Project Number: 9319558 Client Project ID: White Oak Landfill Project Sample Number: 9319558-012 Date Collected: 04/09/u1 112u Matrix: Water Date Received: 04/09/01 17:10 Results Units PRL Analyzed Analyst CAS# Ftnote Limit Total Dissolved Solids Total Dissolved Solids Cyanide. Total, Water Cyanide Total Kjeldahl Nitrogen Nitrogen, Kjeldahl, Total Nitrogen. Nitrate plus Nitrite Nitrogen, NO2 plus NO3 Biochemical Oxygen Demand, 5 d BOD. 5 day Date: 04/24/01 Method: 8.1 Std. Units 15 deg C 3600 umhos/cm Method: EPA 245.1 ND mg/l Method: EPA 6010 0.010 mg/l NO mg/l 0.21 mg/1 Method: EPA 7841 ND mg/l Method: EPA 160.1 5000 mg/l . Method: EPA 335.4 NO mg/l Method: EPA 351.2 120 mg/l Method: EPA 353.3 NO mg/1 Method: EPA 405.1 240 mg/l 04/09/01 MPS 04/09/01 MPS 0 04/09/01 MPS Prep Method: EPA 245.1 0.00020 04/11/01 TRW 7439-97-6 Prep Method: EPA 3010 0.0050 04/12/01 11:47 TRW 7440-47-3 0.010 04/12/01 11:47 TRW 7439-92-1 0.020 04/12/01 11:47 TRW 7782-49.2 04/10/01 Prep Method: EPA 3020 0.0020 04/18/01 TRW 7440-28.0 04/13/01 Prep Method: EPA 160.1 10. 04/16/01 MPS Prep Method: EPA 335.4 0.0020 04/18/01 JDA 57-12-5 Prep Method: EPA 351.2 0.10 04/18/01 JDA Prep Method: EPA 353.3 0.10 04/20/01 JDA 2.0 04/16/01 08:30 KHJ .2. 00 l Page: 12 Laboratory Certification IDs REPORT OF LABORATORY ANALYSIS Laboratory Certification ID& NC Wastewater 40 TN Drinking Water 02980 NC Drinking Water 37712 This report shall not be reproduced, except in full, SC Environmental 99030 without the written consent of Pace Analytical Services, Inc. (�5a'ceAnalytjcalw www.pacelabs.com Lab Sample No: 93837094 Client Sample ID: LEACHATE Parameters Date Prepared Chemical Oxygen Demand Chemical Oxygen Demand Nitrogen, Total Nitrogen Date: 04/24/01 Pace Analytical Services, Inc. 54 Ravenscroft Drive Asheville, NC28801 Phone: 828.254.7176 Fax., 828.252.4618 Lab Project Number: 9319558 Client Project ID: White Oak Landfill Project Sample Number: 9319558-012 Date Collected: 04/09/01 11:20 Matrix: Water Date Received: 04/09/01 17:10 Results Units PRL Analyzed Analyst CAS# Ftnote Limit 04/11/01 Method: EPA 410.4 430 mg/l 50. Method: Standard Methods 120 mg/l 0.20 Prep Method: EPA 410.4 04/12/01 MPS 04/24/01 JDA 7727.37-9 �®al Page: 13 Laboratory Certification IDs REPORT OF LABORATORY ANALYSIS Laboratory Certification IDs NC Wastewater 40 TN Drinking Water 02980 NC Drinking Water 37712 This report shall not be reproduced, except in full, SC Environmental 99030 without the written consent of Pace Analytical Services, Inc. ;aceAnalyfical' www.pacelabs.com Pace Analytical Services, Inc. 54 Ravenscrolt Drive Asheville, NC 28801 Phone: 828.254.7176 DATE: 10/04/00 Fax:828.252.4618 PAGE: 14 Pace Project Number: 9315373 Client Project ID: White Oak Landfill Pace Sample No: 93666501 Date Collected: 09/18/00 Matrix: Water Client Sample ID: LEACHATE Date Received: 09/18/00 Parameters Results Units PRL Analyzed Analyst CAS# Footnotes --------------------------------- ---------- --------- -------- ----- ---------- . Metals Mercury, CVAAS Mercury Metals, ICP, trace -level Chromium Lead Selenium Date Digested Thallium, AAS Furnace Thallium Date Digested Wet Chemistry Total Dissolved Solids Total Dissolved Solids Cyanide. Total, Water Cyanide Total Kjeldahl Nitrogen Nitrogen, Kjeldahl, Total Method: EPA 245.1 Prep Method: EPA 245.1 NO mg/l 0.0002 10/03/00 TRW 7439-97-6 Method: EPA 6010 0.012 mg/l NO mg/l NO mg/l Prep Method: EPA 3010 0.005 10/02/00 TRW 7440-47.3 0.01 10/02/00 TRW 7439.92.1 0.02 10/02/00 TRW 7782-49-2 09/22/00 Method: EPA 7841 0.002 mg/l 0.002 Method: EPA 160.1 2500 mg/l 1 Method: EPA 335.4 0.007 mg/l 0.002 Method: EPA 351.2 140 mg/l 0.1 Nitrogen, Nitrate plus Nitrite Method: EPA 353.3 Nitrogen, NO2 plus NO3 0.10 mg/l 0.1 Biochemical Oxygen Demand, 5 d Method: EPA 405.1 Biochemical Oxygen Demand, 5d 170 mg/l 2 Date Prepared Chemical Oxygen Demand Chemical Oxygen Demand Nitrogen, Total Nitrogen Method: EPA 410.4 760 mg/l 50 Method: Standard Methods 140 mg/l 0.2 , Prep Method: EPA 3020 10/02/00 JDA 7440-28-0 09/20/00` Prep Method: EPA 160.1 09/21/00 JMS Prep Method: EPA 335.4 09/27/00 JDA 57-12-5 Prep Method: EPA 351.2 09/29/00 JDA Prep Method: EPA 353.3 09/26/00 JDA Prep Method: 09/25/00 JMS 09/20/00 Prep Method: EPA 410.4 10/02/00 AAB Prep Method: 10/02/00 JDA 7727-37-9 �000 Laboratory Certification IDs REPORT OF LABORATORY ANALYSIS Laboratory Certification IDs NC Wastewater 40 TN Drinking Water 02980 NC Drinking Water 37712 This report shall not be reproduced, except in full, SC Environmental 99030 without the written consent of Pace Analytical Services, Inc. ;5ceAnalyfical' Pace Analytical Services, Inc. 54 Ravenscrolt Drive Asheville; NC 28801 Phone: 828.254.7176 DATE: 05/16/00 Fax.828.252.4618 PAGE: 8 Pace Project Number: 9312454 Client Project ID: White Oak Landfill Pace Sample No: 93538015 Date Collected: 04/24/00 Matrix: Water Client Sample ID: LEACHATE Date Received: 04/24/00 Parameters Results Units PRL Analyzed Analyst CAS# Footnotes --------------------------------- ---------- --------- ---------- -------- ----- ---------- ---------- Field Services Monitoring Well Data Field pH Field Specific Conductance Field Temperature Metals Mercury, CVAAS Mercury Metals, ICP, trace -level Chromium Lead Selenium Date Digested Thallium, AAS Furnace Thallium Date Digested Wet Chemistry Total Dissolved Solids Total Dissolved Solids Cyanide, Total, Water Cyanide Total Kjeldahl Nitrogen Nitrogen, Kjeldahl, Total Method: 7.8 Std. Units 2600 umhos/cm 11 deg C Method: EPA 245.1 0.0003 mg/l 0.0002 Method: EPA 6010 0.013 mg/l ND mg/1 NO mg/l Prep Method: 04/24/00 MPS 04/24/00 MPS 04/24/00 MPS Prep Method: EPA 245.1 05/04/00 TRW 7439-97.6 Prep Method: EPA 3010 0.005 05/03/00' TRW 7440-47-3 0.01 05/03/00 TRW 7439-92-1 0.02 05/03/00 TRW 7782-49-2 05/01/00 Method: EPA 7841 0.002 mg/l 0.002 Method: EPA 160.1 2700 mg/1 1 Method: EPA 335.4 0.013 mg/l 0.002 Method: EPA 351.2 95 mg/l 0.1 Nitrogen, Nitrate plus Nitrite Method: EPA 353.3 Nitrogen, NO2 plus NO3 0.30 mg/1 0.1 Prep Method: EPA 3020 05/09/00 TRW 7440-28-0 05/04/00 Prep Method: EPA 160.1 04/25/00 JMS Prep Method: EPA 335.4 05/02/00 JDA 57-12-5 Prep Method: EPA 351.2 05/04/00 JDA Prep Method: EPA 353.3 04/27/00 JDA Biochemical Oxygen Demand. 5 d Method: EPA 405.1 Prep Method: Biochemical Oxygen Demand. 5d 190 mg/1 2 05/01/00 JMS Date Prepared 04/26/00 Laboratory Certification IDs REPORT OF LABORATORY ANALYSIS NC Wastewater 40 This report shall not be reproduced, except in full, NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. 1 Laboratory Certification I Ds TN Drinking Water 02980 SC Environmental 99030 ;5ceAnalyfical' Pace Sample No: 93538015 Client Sample ID: LEACHATE Pace Analytical Services, Inc. 54 Ravenscrolt Drive Asheville, NC 28801 Phone: 828.254.7176 DATE: 05/16/00 Fax:828.252.4618 PAGE: 9 Pace Project Number: 9312454 Client Project ID: White Oak Landfill Date Collected: 04/24/00 Matrix: Water Date Received: 04/24/00 Parameters Results Units PRL Analyzed Analyst CAS# Footnotes ----- ---------- .......... --------------------------------- Chemical Oxygen Demand ---------- --------- Method: EPA 410.4 ---------- -------- Prep Method: EPA 410.4 Chemical Oxygen Demand 670 mg/l 50 05/01/00 AAB Nitrogen, Total Method: Standard Methods Prep Method: Nitrogen 95 mg/l 0.2 05/09/00 JDA 7727-37-9 J O Y O Laboratory Certification IDS REPORT OF LABORATORY ANALYSIS Laboratory Certification IDs NC Wastewater 40 TN Drinking Water 02980 NC Drinking Water 37712 This report shall not be reproduced, except in full, SC Environmental 99030 without the written consent of Pace Analytical Services, Inc. Pace Analytical Services, Inc. 54 Ravenscrofl Drive Asheville, NC 28801 Tel: 828-254-7176 Fax: 828-252-4618 DATE: 10/11/99 PAGE: 12 Pace Project Number: 938071 Client Project to: White Oak Pace Sample No: 93362077 Date Collected: 09/21/99 Matrix: Water Client Sample ID: LEACHATE Date Received: 09/21/99 Parameters --------------------------------- Results ---------- Units --------- PRL ---------- Analyzed -------- Analyst CAS# Footnotes --------------- .......... Metals l Mercury, CVAAS Method: EPA 245.1 Prep Method: EPA 245.1 Mercury NO mg/l 0.0002 09/27/99 TRW 7439-97-6 Metals, 1CP, trace-levet Method: EPA 6010 Prep Method: EPA 3010 Atrmlinun 1.7 mg/l 0.25 09/30/99 TRW 7429-90-5 Antimony ND mg/1 0.01 09/30/99 TRW 7440-36-0 Arsenic NO mg/1 0.01 09/30/99 TRW 7440-38-2 Barium 0.18 mg/l 0.005 09/30/99, TRW 7440-39-3 Beryllium ND mg/1 0.002 09/30/99 TRW 7440-41-7 Boron - 1.1 mg/l 0.01 09130/99F TRW 7440-42-8 Cadmium 0.0018 mg/L 0.001 09/30/99 TRW 7440-43-9 Calcium 27 mg/l 0.1 09/30/99 TRW 7440-70-2 .Chromium 0.043 mg/1 0.005 09/30/99 TRW 7440-47-3 Cobalt 0.0097 mg/l 0.005 09/30/99 TRW 7440-48-4 Copper NO mg/1 .0.005 09/30/99 TRW 7440-50-8 Iron 9.9 mg/L 0.02 09/30/99 TRW 7439-89-6 Lead NO mg/1 0.01 09/30/99 TRW 7439-92-1 Magnesium 75 mg/l 0.1 09/30/99 TRW 7439-95-4 Manganese 1.8 mg/L 0.005 09/30/99 TRW 7439-96-5 Molybdenum 0.01 mg/1 0.005 09/30/99 TRW 7439-98-7 Nickel 0.041 mg/1 0.005 09/30/99 TRW 7440-02-0 Potassium 18 mg/l 0.5 09/30/99 TRW 7440-09-7 Selenium NO mg/l 0.02 09/30/99 TRW 7782-49-2 Silicon 0.61 mg/L 0.1 09/30/99 TRW 7440-21-3 Silver NO mg/1 0.002 09/30/99 TRW 7440-22-4 Sodium 15 mg/l 0.25 09/30/99 TRW 7440-23-5 Thallium NO mg/l 0.02 09/30/99 TRW 7440-28-0 Tin 0.01 mg/l 0.01 09/30/99 TRW 7440-31.5 Titanium 0.13 mg/1 0.005 09/30/99 TRW 7440-32-6 Vanadi urn 0.011 mg/1 0.005 09/30/99 TRW 7440-62-2 Zinc 0.086 mg/1 0.01 09/30/99 TRW 7440-66-6 Date Digested 09/24/99 Thallium, AAS Furnace Method: EPA 7841 Prep Method: EPA 3020 Thallium NO Wt. 0.002 09/24/99 TRW 7440-28-0 Date Digested 09/24/99 Wet Chemistry f aboraiory Certification IDS laboratory Certifirztion IDS NC Wastewater 40 REPORT OF LABORATORY ANALYSIS TN Drinking Water 02980 NC Drinking Water 37712 This report shall not be reproduced, except in full, SC Environmental 99030 ...af..,.n 6. -ANen of Pere 0nnlNlcal Re rvirAR Inn. Pace Analytical Services. Inc. 54 Ravenscrolt Drive Pace Analytical Asheville. NC28801 Tel: 828-254-7176 Fax:828-252-4618 DATE: 10/19/99 PAGE: 13. Pace Project Number: 938071 Client Project ID: White Oak Pace Saapte No: 93362077 Date Collected: 09/21/99 Matrix: Water Client Sample ID: LEACHATE Date Received: 09/21/99 Parameters Results Units PRL Analyzed Analyst CAS# --'"""----------- --------------- Footnotes ._-------- --------------------------------- Total Dissolved Solids ---------- ......... Method: EPA 160.1 Prep Method: EPA 160.1 A y` Total Dissolved SoLids 1900 mg/l 1 09/28/99 PJS I Q I Total Kjeldahl Nitrogen Method: EPA 351.2 Prep Method: EPA 351.2 Nitrogen, Kjeldahl, Total 41 mg/l 0.1 09/24/99 JDA ` Nitrogen, Nitrate plus Nitrite Method: EPA 353.3 Nitrogen, NO2 plus NO3 ND mg/l 0.1 Biochemical Oxygen Demand, 5 d Method: EPA 405.1 Biochemical Oxygen Demand, 5d 105 mg/L 2 Date Prepared Chemical Oxygen Demand Method: EPA 410.4 Chemical Oxygen Demand 600 mg/1 50 Nitrogen, Total Nitrogen Method: Standard Methods 41 mg/L 0.2 Prep Method: EPA 353.3 09/29/99 JDA Prep Method: 09/27/99 PJS 09/22/99, Prep Method: EPA 410.4 09/27/99 AAB Prep Method: 10/11/99 WB 7727-37-9 1 L.aboralory Certification IDS I aboratory Certification IDe NC Wastewater 40 REPORT OF LABORATORY ANALYSIS TN Drinking Water 02980 NC Drinking Water 37712 This report shall not be reproduced, except in full. SC Environmental 99030 ,.:,rm,— a rho w,inen rnneent of Pare Analvliral Services_ Inc. Pace Analytical Services, Inc. 54 Ravenscr0fl Drive Pace Analytical Asheville, NC28801 Tel. 828-254-7176 Fax: 828-252-4618 DATE: 05/12/99 PAGE: 37 Pace Project Number: 935303 Client Project ID: White Oak Pace Sample No: 93244481 Date Collected: 04/27/99 Matrix: Water Client Sample ID: WO LEACHATE Date Received: 04/27/99 Parameters Results Units PRL Analyzed Analyst CAST: Footnotes _________________________________ __________ _________ __________________ _____ __________ _________ Metals Metals, ICP Method: EPA 6010 Prep Method: EPA 3010 0.30 mg/l 0.1 05/11/99 KEK 7440-39-3 Barium Cobalt ND mg/L 0.05 05/11/99 KEK 7440-48-4 NO mg/l 0.01 05/11/99 KEK 7440-50-8 Copper 63 mg/l 0.1 05/11/99 KEK 7439-95-4 Magnesium Nickel NO mg/l 0.05 05/11/99 KEK 7440-02-0 Silver NO mg/l 0.05 05/11/99 KEK 7440-22-4 Vanadium NO mg/L 0.04 05/11/99 KEK 7440-62-2 NO mg/I. 0.01 05/11/99 KEK 7440-66-6 zinc Date Digested - 04/28/99 Antimony, AAS Furnace Method: EPA 7041 Prep Method: EPA 3020 NO mg/l 0.005 05/11/99 KEK 7440-36-0 Antimony Date Digested 05/03/99 Arsenic, AAS Furnace Method: EPA 7060 Prep Method: EPA 3020 mg/1 0.005 05/11/99 KEK 7440-38-2 Arsenic NO Date Digested 05/03/99 Beryllium, AAS Furnace Method: EPA 7091 Prep Method: EPA 3020 Beryllium NO mg/1 0.001 05/11/99 KEK 7440-41-7 Date Digested 05/03/99 Cadmium, AAS Furnace Method: EPA 7131 Prep Method: EPA 3020 Cadmium NO mg/l 0.001 05/11/99 KEK 7440-43-9 Date Digested 05/03/99 Chromium Furnace Method: EPA 7191 Prep Method: EPA 3020 Chromium 0.006 mg/l 0.002 05/11/99 KEK 7440-47-3 Date Digested 05/03/99 , Lead, AAS Furnace Method: EPA 7421 Prep Method: EPA 3020 Lead NO mg/l 0.005 05/11/99 KEK 7439-92-1 Date Digested 05/03/99 !rcury in Water Method: EPA 7470 Prep Method: EPA 7470 NO mg/l 0.0002 05/03/99 KEK 7439-97-6 Mercury Laboratory Certification IDs OF LABORATORY ANALYSIS NC Wastewater 40 REPORT NC Drinking Water 37712 This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc. r. L-aboratory Certification IDS TN Drinking Water 02980 SC Environmental 99030 Pace Analytical Services, Inc. 54 Ravenscroft Drive Para Analytical Asheville, NG 28801 Tel: 828.264-7176 Fax: 828-252-4618 Pace Sample No: 93244481 Client Sample ID: WO LEACHATE DATE: 05/12/99 PAGE: 38 Pace Project Number: 935303 Client Project ID: White Oak Date Collected: 04/27/99 Matrix: Water Date Received: 04/27/99 Parameters Results Units PRL Analyzed Analyst CAS# Footnotes ---------------------------------------------------------------------- ----- ---------- ---------- Selenium, AAS Furnace Method: EPA 7740 Prep Method: EPA 3020 Selenium 0.008 mg/1 0.005 05/11/99 KEK 7782-49-2 q Date Digested 05/03/99 ` Thallium, AAS Furnace Thallium Date Digested Wet chemistry Total Dissolved Solids Total Dissolved Solids :yanide, Total, Water Cyanide Total Kjeldahl Nitrogen Nitrogen, Kjeldahl, Total Method: EPA 7841 NO mg/l 0.002 Method: EPA 160.1 1200 mg/1 1 Method: EPA 335.4 NO mg/l 0.002 Method: EPA 351.2 90 mg/1 0.5 Nitrogen, Nitrate plus Nitrite Method: EPA 353.3 Nitrogen, NO2 PLUS NO3 NO mg/1 0.1 Biochemical Oxygen Demand, 5 d Method: EPA 405.1 Biochemical Oxygen Demand, 5d 100 mg/L 2 Date Prepared Chemical Oxygen Demand Chemical Oxygen Demand Nitrogen, Total Nitrogen Method: EPA 410.4 310 mg/l 50 Method: Standard Methods 90 mg/l 1 Prep Method: EPA 3020 05/05/99 KEK 7440-28-0 05/03/99 Prep Method: EPA 160.1 04/30/99 SLG Prep Method: EPA 335.4 05/04/99 TRW 57-12-5 Prep Method: EPA 351.2 05/06/99 TRW Prep Method: EPA 353.3 04/30/99 TRW Prep Method: 05/03/99 KEK 04/28/99 Prep Method: EPA 410.4 05/05/99 KEK Prep Method: 05/10/99 TRW 7727-37-9 1 1 Laboratory Certification IDS Laboratory Certification IDs NC Wastewater 40 REPORT OF LABORATORY ANALYSIS TN Drinking Water 02980 NC Drinking Water 37712 SC Environmental 99030 - This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc. BLUE RIDGE PAPER PRODUCTS INC. CERTIFIED MAIL RETURN RECEIPT REQUESTED 7099 3220 0007 0371 5320 19 Oct 2004 Forrest R. Westall, PE Water Quality Regional Supervisor North Carolina Department of Environment and Natural Resources Division of Water Quality 2090 US Highway 70 Swannanoa, NC 28778 _.Subject: NPDES NC 0000272 CRP Color Report — Extension Request Due to Floods Blue Ridge Paper Products, Inc. fl� Canton, NC Dear Forrest: p E ""' OCT 2 0 2004 D WATER QUALITY SECTION ASHEVILLE REGIONAL OFFICE Part I, Condition A.(8).9 of the subject permit requires that Blue Ridge Paper Products evaluate color reduction technologies associated with the Chloride Removal Process (CRP) wastestream and submit a report by December 1, 2004. Because of the September 2004 floods, we will not be able to meet the 1 December deadline. We respectfully request an extension until lApril 2005 to complete this work and submit the CRP Color Reduction Report. As you are aware, the Blue Ridge Paper Products mill in Canton, NC was hit by the remnants, of three hurricanes (Frances, Ivan and Jeanne) and by back-to-back historic floods during the month of September 2004. Our wastewater plant and parts of the mill were flooded twice. Mill operations were disrupted for several weeks and all of our resources since Hurricane Frances on 8 September 2004 have been devoted to flood repairs, additional flood preparations and recovery. We are only now getting back to normal operation of our process and wastewater treatment systems. The floods destroyed our wastewater lab, and we have not yet restored all the lab capability that we need to support color trial work. Blue Ridge Paper has been working on evaluations for the CRP report since 2002. Our technology review, bench scale tests and preliminary field trials led to a pilot -scale field trial in July and August 2004 for chlorine dioxide bleaching of the CRP wastestream. Our goal was to operate for a least 30 days with the pilot system in continuous operation. However, the July and August field trials experienced various operational issues with chemical feed and chloride dioxide generation that prevented a sustained period of continuous operation. The longest Environmental Group 175 Main Street • PO Box 4000 Canton, North Carolina 28716 • 828-646-2000 Raising Your Expectations stall, NC DENR ARO DWQ 14, Page 2 contmuous run obtained was 4 days. As a result, no conclusions could be drawn on the exact technical, economic and operational feasibility of this technology. The field trial was terminated on 27 August 2004. The field test plan was modified and enhanced to overcome the operational issues associated with chlorine dioxide generation that prevented a successful trial during August. Hurricane Frances hit on 8 September 2004. We had to postpone restart of the CRP bleaching field trial until we are able to restore normal mill operations. We are currently in discussions with the supplier of the field chlorine dioxide generator to see what dates this equipment and operators are available. In summary, the floods of September 2004 interrupted our schedule for completing field trials on color reduction from our CRP waste stream. We need the field trial data to complete the CRP color report required by permit conditions. We request an extension until 1 April 2005 to complete this work and submit the CRP Color Reduction Report. Sincerely Paul S. Dickens Manager, Environmental Affairs 828-646-6141 dickei)@blueridgepaper.com Environmental Group 175 Main Street • PC Box 4000 Canton, North Carolina 28716 • 828-646-2000 Raising Your Expectations BLUE RIDGE PAPER PRODUCTS INC. CERTIFIED MAIL RETURN RECEIPT REQUESTED 7099 3220 0007 0371 5337 Forrest R. Westall, PE Water Quality Regional Supervisor North Carolina Department of Environment and Natural Resources Division of Water Quality 2090 US Highway 70 Swannanoa, NC 28778 Subject: NPDES NC 0000272 BOD Excursion 14 Oct 2004 Wastewater Treatment Plant Recovery from Floods Blue Ridge Paper Products, Inc. Canton, NC Dear Forrest: This is the 5-day written report documenting a BOD excursion on 10/4/04. Verbal and e-mail notifications of the BOD result were provided to Keith Haynes of your office on 10/14/04. This letter also updates the status of permit -required equipment and instrumentation that was destroyed by recent floods. As you are aware, the Blue Ridge Paper Products mill in Canton, NC was hit by the remnants of three hurricanes (Frances, Ivan and Jeanne) and by back-to-back historic floods during the month of September 2004. Our wastewater plant and parts of the mill were flooded twice. Wastewater treatment operations resumed on 9/11 after the 9/8 Frances flood and on 9/21 after the 9/17 Ivan flood. Compliance monitoring after the two floods resumed on 9/12 and 9/22. Mill operations were disrupted for several weeks and all of our resources since Hurricane Frances on 9/8 have been devoted to flood repairs, additional flood preparations and recovery. We are only now getting back to normal operation of our process and wastewater treatment systems. The floods destroyed our wastewater lab, and we have not yet restored all the lab capability that we need to do compliance monitoring in-house. We contracted with PACE Lab to analyze wastewater process control and compliance samples during the flood recovery period. Environmental Group 175 Main Street • PO Box 4000 Canton, North Carolina 28716 • 828-646-2000 OCT 2 0 2004 WATER QUALITY SECTION Raising Your Expectations Forrest Westall, NC DENR ARO DWQ 19 Oct 2004, Page 2 BOD Excursion On 10/13, Blue Ridge Paper Products received the analytical report from PACE Lab for the 10/4 secondary effluent (SE) composite BOD. The data were entered into our compliance database on the morning of 10/14, and we determined that we had a BOD excursion based on mass. There was an error on the QA portion of the PACE Lab report, so we requested that PACE review and revise the report as appropriate. We also looked at wastewater operating data for 10/3, 10/4 and 1015. PACE Lab provided a corrected lab report and a copy of their lab bench sheet on the afternoon of 10/14. These data confirm the previous report. Results are as follows: Date Flow, mgd PI BOD, m PE BOD, m SE BOD, m SE BOD, Ibs/day SE TSS, m 10/3 27.03 1200 300 45 10,144 57 10/4 25.11 660 450 110 23,036 70 10/5 23.54 370 260 48 9423 56 Our operating data indicate a DO sag in our aeration basins that started on the evening of 10/3 and continued until the afternoon of 10/4. PI and PE BODs were also elevated for these days. We believe that the 10/4 SE BOD result is correct. River run results for downstream DO show no impact. Our permit max day BOD limit is 10,897 lbs/day. Blue Ridge Paper experienced a secondary treatment upset on the morning of 9/30/04 from a high pH swing when a scheduled acid delivery for wastewater neutralization failed to arrive when planned. Between 9/29 and 10/2, we also experienced an episode of high secondary effluent color related to restart of pulp mill operations following the unplanned and extended cold mill outage caused by the Frances and Ivan floods. We reported these events to Keith Haynes by telephone on 9/30 and 10/1 and with follow-up written reports on 10/1 and 10/3. On 10/5, you personally visited the Blue Ridge mill and toured the wastewater treatment plant to confirm flood damage and the status of recovery. Based on operating data for the past two weeks, we believe that the secondary treatment plant has recovered from upset conditions earlier in the month. Effluent parameters and color have returned to normal range. However, because of elevated BODs and color during the first week of October, we may have difficulty meeting the monthly average limits for these parameters. Status of Permit -Required Equipment and Instrumentation Blue Ridge Paper worked diligently and non-stop to restore essential wastewater treatment facilities following the Frances and Ivan floods. The following items are now being addressed: Environmental Group 175 Main Street • PO Box 4000 Canton, North Carolina 28716 • 828-646-2000 Raising Your Expectations Forrest Westall, NC DENR ARO DWQ 19 Oct 2004, Page 3 Wastewater samplers. The Frances flood on 9/8 damaged three of our five refrigerated wastewater samplers. The Ivan flood on 9117 destroyed two remaining units salvaged from Frances. We collected manual 24-hr composites using 4-hr grab samples until we could get replacement samplers installed. As of today, we have replaced 3 wastewater samplers and 2 additional are on order. The flow -pacing signal for the secondary effluent samplers remains down. We are running time composite samples until the effluent flow signal can be repaired. Strip Chart Recorders. Our wastewater control room and lab were twice inundated by floodwaters during September 2004. Totalizers and strip chart recorders for flow, pH and other permit parameters were destroyed. Many of the flood -damaged strip charts are obsolete, and replacements are very expensive with a long delivery time. Based on discussion with Keith Haynes, Blue Ridge will replace strip chart recorders with electronic data logging systems that have trend display and printing capability. This is a faster and more economical flood damage repair. For the interim period, we established a new data -logging interface to totalize effluent flow and are keeping a manual log for other data. Oxygen Stations on Pigeon River. The back -to -black floods in September 2004 severely damaged the two downstream oxygen injection stations owned by Blue Ridge Paper — Station D in Fiberville 0.9 miles downstream and Station E in West Canton 2.1 miles downstream. These oxygen injection stations are specified in Part I.A.10 of our NDPES permit. The stations are not operational at this time. We notified Keith Haynes by e-mail on 9/23 that the oxygen stations were damaged. Blue Ridge is evaluating options for repair and if two stations are still required. We have not operated the D station for a number of years and have only operated the E station for limited periods during flow stream flow. We have not needed any in -stream oxygen injection during the past 2 years. Because of high stream flow, we do not anticipate needing the downstream oxygen injection stations for water quality compliance during this fall and winter. The oxygen post aeration system at the wastewater treatment plant is fully functional and is operating. Wastewater Compliance Lab. The Frances flood on 9/8 destroyed most of the equipment in our wastewater compliance lab. Blue Ridge Paper put together a temporary lab for pH, DO, color, conductivity and temperature and made arrangements with PACE Labs for other wastewater process control and compliance sample analysis. As of this date, all equipment needed to restore our wastewater lab is delivered or on order. Lab cabinets are being replaced this week and next. We hope within the next 4 to 6 weeks to have our previous in-house capability for solids, BOD and ammonia restored. We created and are using temporary wastewater operating logs and bench sheets for the interim period until the former wastewater lab QA program can be restored. Many of our original lab records for the past 5 years were flooded and destroyed. Compliance data are kept in an electronic database that survived the floods. We also had duplicate copies of monthly discharge monitoring reports stored in the EHS office on high ground. Environmental Group 175 Main Street • PO Box 4000 Canton, North Carolina 28716. 828-646-2000 Raising Your Expectations Forrest Westall, NC DENR ARO DWQ 19 Oct 2004, Page 4 Summary Blue Ridge Paper is making good progress on recovery from the September 2004 floods. Our mill operations and wastewater treatment performance are returning to normal. We truly appreciate your help and that of Keith Haynes with flood recovery efforts. Sincerely Paul S. Dickens Manager, Environmental Affairs 828-646-6141 dickey@blueridgenaper.com Environmental Group 175 Main Street • PO Box 4000 Canton, North Carolina 28716 • 828-646-2000 Raising Your Expectations BLUE RIDGE PAPER PRODUCTS INC. CERTIFIED MAIL RETURN RECEIPT REQUESTED 7099 3220 0007 0371 5306 14 September 2004 Mr. Forrest Westall Water Quality Supervisor North Carolina Department of Environment and Natural Resources Asheville Regional Office Division of Water Quality 2090 US Hwy 70 Swannanoa, North Carolina 28778 Subject: NPDES NC0000272 Flood Event of 8 September 2004 Unanticipated Bypass of Treatment Sanitary Sewer Overflow Blue Ridge Paper Products, Inc. Town of Canton, North Carolina Dear Forrest — This is the written report required under the subject permit documenting flood damage and loss of wastewater treatment associated with hurricane Frances on the morning of 8 September 2004. The wastewater treatment plant operated by Blue Ridge Paper Products also treats sewage from the Town of Canton. This report is submitted for both Blue Ridge Paper Products and the Town of Canton. We notified DENR by telephone at 0745 on the morning of 8 September that the mill was shut down and that our wastewater plant was flooded. We subsequently provided daily updates on progress towards restoring wastewater treatment for the town's wastewater. Wastewater treatment was restored on the afternoon of 11 September 2004. During the period that wastewater treatment was down, untreated sewage from the town entered the Pigeon River, both from the mill's influent lift station and from the town's sewage pump stations that were submerged and damaged by floodwater. Since mill operations were curtailed in advance of the flood and remained down, there was no release of untreated industrial wastewater. Chemicals and oil storage on the Blue Ridge site remained secure. Environmental Group 175 Main Street • PO Box 4000 Canton, North Carolina 28716 • 828-646-2000 Raising Your Expectations Forrest Westall, NC DENR ARO DWQ 14 Sep 2004, Page 2 Flood Event The remnants of hurricane Frances passed through Western North Carolina on 7 and 8 September 2004. The mill began a flood watch early on the morning of 7 September. Based on water levels in Pigeon River, the mill activated its flood protection plan at 1600 on 7 September and installed floodgates in the dikes protecting the mill and wastewater treatment plant. At — 1900 the mill began a controlled shutdown of the backend of the mill — recovery and pulp production — as a precaution against flooding. At — 2200 based on rapid river rise, we began a controlled shutdown of paper production as a precaution against flooding. We also started a controlled shutdown of power boilers. At 0253 on the morning of 8 September, floodwaters backed up into the wastewater treatment area and overtopped the secondary clarifiers. At that time, the low lift pumps to wastewater treatment were stopped. This started an unanticipated bypass of treatment necessary to prevent severe property damage. At this time all mill operations were down, and chemical and oil tanks were secure. Aerators in the aeration basins were turned off to settle and store activated sludge. At 0330 on 8 September, power to the mill site including wastewater treatment was turned off to prevent damage to electrical substations and switch gear from flood water. The mill went cold at that time, and all industrial wastewater generation stopped. At — 0600 on 8 September, the Pigeon River crested at 21 feet, a record for Canton. The mill's protective dike system was overtopped. There was 4 to 5 feet of water in the wastewater area. This water flooded the influent lift station, secondary clarifiers and switch gear rooms as well as the wastewater control room, lab and offices. The aeration basins and primary clarifiers remained above flood level. Downtown Canton was severely flooded, and the town's sewage pump stations along the Pigeon River were submerged. The town's disinfection pretreatment system located at the headworks of the Blue Ridge wastewater plant was also submerged. Recovery Flood waters started to recede on the afternoon of 8 September. By the morning of 9 September, Blue Ridge was able to drain and pump remaining floodwater from the wastewater area and start work to restore wastewater treatment. The Town of Canton also began work to repair and restore sewage pump stations damaged by the flood. To drain remaining floodwaters from the wastewater treatment plant and from the mill, portable diesel pumps were installed at the influent low lift pumps to the mill's wastewater treatment system. These pumps discharged to the river. Environmental Group 175 Main Street • PO Box 4000 Canton, North Carolina 28716 • 828-646-2000 Raising Your Expectations Forrest Westall, NC DENR ARO DWQ 14 Sep 2004, Page 2 On the morning of 10 September 2004, the Town of Canton was able to restore the disinfection pretreatment system. At that time, the town began pumping sewage back to the mill's wastewater headworks. The disinfected wastewater was then pumped into the river. This interim treatment had been discussed with DENR staff and was agreed as the best measure for public health protection until full treatment could be restored. Work by Blue Ridge personnel to restore wastewater treatment continued non-stop after floodwaters were drained from the wastewater area. Blue Ridge was able restart wastewater treatment operations on the afternoon of 11 September 2004. Discharge of untreated and partially treated sewage from the Town of Canton through diesel pumps at the mill's wastewater headworks stopped at — 1250 on 11 September. Blue Ridge resumed compliance monitoring of the wastewater plant effluent that night. Sanitary Sewer Overflows The Blue Ridge wastewater treatment facilities were down from 0300 on 8 September 2004 until the afternoon on 11 September 2004. During this period, untreated sewage from the Town of Canton was discharged to the Pigeon River, both from overflows at damaged pump stations owned by the town and from the influent of the mill's wastewater treatment system. Floodwaters and cleaning water from the mill and town were also discharged to the river. The quantity of sewer system overflow is difficult to estimate, but is greater than 15,000 gallons. The majority of the overflow was floodwater and cleaning water necessary to restore sewage pump stations and wastewater treatment. The mill locked restrooms and installed portable toilets during the wastewater treatment outage to avoid discharge of domestic sewage to the river from the mill. An SSO reporting form is enclosed for the period of wastewater treatment outage. Summary This event was truly a severe act of nature and overwhelmed the flood protection structures at the Blue Ridge Paper Products mill in Canton, North Carolina. We executed a controlled shutdown of the mill in advance of the flood and prevented release of untreated industrial wastewater, chemicals or oil. The flood and loss of wastewater treatment did result in overflow of untreated sewage from the Town of Canton into the Pigeon River. We will learn from this event and make revisions to the mill's flood protection plan. Environmental Group 175 Main Street • PO Box 4000 Canton, North Carolina 28716 • 828-646-2000 Raising Your Expectations Forrest Westall, NC DENR ARO DWQ 14 Sep 2004, Page 2 President Bush declared Western North Carolina as a Federal disaster area as a result of the hurricane Frances flood. Blue Ridge Paper Products and the Town of Canton worked diligently and non-stop to restore treatment of the town's wastewater following the flood. We were able to restore essential wastewater services within of the flood event. We greatly appreciate DENR's assistance and understanding with the emergency recovery efforts. In particular, we appreciate the site visit by Keith Haynes and Roy Davis of your staff on 8 September to assess flood damage to our wastewater plant. Sincerely — Paul S. Dickens Manager, Environmental Affairs 828-646-6141 dickep@blueridgepaper.com Enclosure: SSO Form for flood event Environmental Group 175 Main Street • PO Box 4000 Canton, North Carolina 28716 • 828-646-2000 Raising Your Expectations Paul To keith.haynes@ncmail.net Dickens/Canton/BlueRidge forrest.westall@ncmail.net, Bob 10/01/2004 07:10 PM Williams/Canton/BlueRidge@BlueRidgePaper, Daryl Whitt/Canton/BlueRidge@BlueRidgePaper, John Pryately/Canton/BlueRidge@BlueRidgePaper, Bob cc Shanahan/Canton/BlueRidge@BlueRidgePaper, Steve Single/Canton/BlueRidge@BlueRidgePaper, Michael Koerschner/Canton/BlueRidge@BlueRidgePaper, George G a rten/Canton/B IueRidge @ B I ueRi dge Pa per bcc Subject Wastewater Excursions - Blue Ridge Paper 1 Oct 2004 Subject: Permit Excursions 30 Sep 2004 — secondary effluent pH September 2004 - monthly average color NPDES NC 0000272 Blue Ridge Paper Products, Inc. Keith Haynes, NC DENR ARO DWQ — Pr( ducts �U a cn m> I� �� o m0 m > I rfGll 0 rn 0 Cmf 01 4o T 0 Ir� A m This written report follows our telephone notifications for the permit excursions reported on 9/30 and 10/1/2004. As you aware, the Blue Ridge Paper Products mill is restarting process operations after 3-weeks of unscheduled cold outage caused by Hurricanes Frances and Ivan. During the last three days, we restarted pulp mill operations and have experienced a number of process problems related to the flood outage. Specifically, when the mill executed the emergency shutdown for the Frances flood on the night of 9/7, we did not have time to purge the pulping process and empty digesters and other tanks. On restart this week, we had soft pulp and fiber that washed poorly in brown stock and bleaching stages of the mill. We tried as best we could to process and recover the fiber and pulping chemicals left in tanks from before the floods. However, we lost an abnormal amount of pulping materials resulting in a high pH and high color load to our wastewater treatment plant. We had anticipated the high pH load to wastewater treatment and scheduled round -the clock deliveries of acid for pH neutralization. On the night of 9/29, an acid delivery scheduled for 6 pm did not arrive on time. We began to run low on acid for neutralization at the same time that the pulp mill experienced several process upsets related to the flood. We slowed down the pulp mill restart and began adding acid to the mill sewer from inside the mill to help control pH at our wastewater treatment plant. At 12 midnight, the wastewater plant ran out of acid. We continued to add acid to the mill sewer to control wastewater plant pH. The acid delivery to wastewater treatment originally scheduled for 6 pm on 9/29 finally arrived at 2:40 am on the morning of 9/30. We resumed acid addition for pH control at wastewater treatment by 4 am. Additional loads of acid were received on schedule during the morning of 9/30. Wastewater pH based on grab samples for the period above is as follows: Date and time 9/29 7 pm 9/29 11 pm 9/30 3 am 9/20 7 am 9/20 8:30 am PI PE SE 11.4 10.7 8.2 11.5 10.8 9.0 2.9 10.4 9.5 2.8 7.8 9.2 8.7 For the period between 11 pm on 9/29 until about 8:30 am on 9/30, we had secondary effluent (SE) pH greater than 9.0. Our permit specifies a discharge pH limit of 6.0 to 9.0. Wastewater flow during the pH excursion period was — 27 mgd. The river flow on 9/29 was 1015 mgd and on 9/30 was 782 mgd. Our effluent during the pH excursion period was less than 5 percent of stream flow. Our river run and visual inspection of the river downstream on the morning of 9/30 found no evidence of fish kill or other environmental harm. As you are also aware, the back-to-back floods in Canton during September 2004 caused a total of 9 days of wastewater plant outage and 3 weeks of pulp mill outage. We only operated secondary treatment and monitored our wastewater discharge for 21 of the 30 days in September. Wastewater plant operations were restored before we attempted restart of paper and pulp production. Secondary effluent color on 9/29 and 9/30 was high and took our monthly average color based on wastewater operating days above the permit limit of 52,000 lbs/day. Specifically, based on 21 operating days our monthly average secondary effluent true color discharge was 58,097 lbs/day. Based on 30 days in the month of September, the monthly average true color discharge was 40,6881bs/day, below both the annual average and monthly max color limits in the permit. Our effluent was less than 5 percent of river flow on the high color days during September. Based on river run samples, the true color at the Fiberville bridge on 9/29 was 25 ppm and on 9/30 was 44 ppm. A preliminary summary of our September 2004 wastewater flow and color discharge monitoring results is attached for your evaluation. The formal and QC -verified data will be submitted with our September DMR. Lpt sep04wpt.xls � Paul Dickens Manager, Environmental Affairs Blue Ridge Paper Products, Inc. dickep@blueridgepaper.com 828-646-6141 FAX 828-646-6892 Temporary Results Summary- Wastewater Treatment BRPPI 22-Sep-04 Flow PI Color SE Color MLSS MLVSS Wst Sludge PI TSS PE TSS SE BOD-5 SE TSS SE NH3-N Date an d PPM lbs/day PPM Ibs/da m m anm L mgfL m9fi Ibs/da m lbstday m gfl Limits Max day 3,205 12,459 Month avg 29.9 52,000 10.897 49,560 9/1/2004 24.5 280 .57,236 234 see OPS 32 database 9/2/2004.,,,.,,,, 24.3 321 64,974 213 .47,833 43,114 9/3/2004.,.,.,,,. .............................. 23.7 287 56.824 197 .......................04' ,,,,.,..... 39.004 samples lost Frances flood 9/4/2004 22.7 267 .50,637 185 ..........35.086 samples lost Frances flood B/5/2004 .._....,.._- 23.7 369 72.'36 211 41,706 _..___.__....... samples lost Frances ilootl 9/6/2004........, 24.6 381 .............70.231 205 42,093 ............... .............. ........... ............_... samples last Frances flood 9/7/2004 33.2 264 73,120 260 72.013 ,samples lost to Frances flood samples lost Frances flood 9/e 9/11/04 Frances flood, WTP down or samples /data lost 9/1212004 12.0 ..................._371 37,130 ...,190 . ___...._................................_..._..__".____....................._......................._..........__..............._............._.........................._....... _._...._.................___.__......._..........._.24 9/13/2004 . _........_.......... ................_73:6..................._504............_57.166......................147............_76;673.............._2.700..............._2�120......................6t900..............._1;600 ..................._1.1.0 .... 9 ........................................................................................................................................... 1,021 38 4,310 <0.10 9/14/2004...... ...................... ..................._326.............................. ......._25.167 ............................ .............._1,790.............._no. waste................_?,800 .................._740 10 ....... _._........... 1,368 58 ..................__........................_.._.. 7,933 0.18 _.._........_..... 9/15/2004 _ __.__...17.7 50.1 ._......__73,957 231 ......_..._____ . 34,100 2.700 2,060 no waste W._..._._.__..._...._._.._......___..._ 690 ._._......__._. 280 ..__8.__ 1.181 ...._..............._21 ._._...__3,100 ___ 0.14 9.116/2004 ............._...................................._-___..............._.........................._...........................................__ 20.8 403 69,909 293 50,827 samples lost to Ivan flood .__.................._..........................................._..............__....._..............................................................._....................................................................................................................................... 0 0 9/17/2004 ......................................................................................_.............................................................................................................................................................................................................................................................._....................................................................................................................................... Second flood from Ivan, WTP down 9/18/2004 Second flood from Ivan, WTP down .._._.._........................_............._..._._..__..................._..._._.._._._._............ ................. .__....-_.._......................................... _ ..__.____ __�_..... _-_.... ............... _....._ 9/19/2004 ........................ _.... Second flood from Ivan, WTP down .......... _.._....................................................._.___........................................ ............................. ................. ._........................................................................... ....... _-.._._._"'.......__......_.........._....._.............. _............................ .............................. ............_..-... __.........._......... 9/2012004...... ....... Second. flood, from, Ivan:. WTP, tlown................................... ............................. .... _... ....................................................____....__............._.................................................................................................................... ................... ................................... 9/21/2004 ...__._ ......._ .Second, flood from Ivan. WTP down, re started . ..................._.. _........ ......... ( 12 noon, co liance.and ,rocess.monitorin resumed p P 9 an.9/22 !__ _..... _..... _... __ . ....................... _..................... _._.. ......... __._..... ..__.... _.... _ ........ .... _................. _ 9/22/2004 ................_...0_�....................220.._.._..__79.632................... .._.................................................. 9/23/2.... ..... ......... ............_72.0 ................695 ........69.556 ............... 109 ......... ........... ......... ......... .......,10.909 ......... ........._2.584 .,,-....3.847 ......... no, waste ......... ......... ......... no,sample.? ................1.500 fi .............................................................. 600 40 _............................ 4,003 .. 0.55 ........................ 9/24/2004_..... ___..._ 15_? ........__..... 837 ........._706.105__._.._.__651............_82.526 3,800..............._2.110....._.._._no waste ___7 �000 ......_. 88 --"-'---4 ..............__._507 ............._....._ 25 -__........._3,169 0.61 9/25/2004 ........................... ._16:4..................._231............._29.669..._..............._180..........._23,118.............._2.600...............2.230............._nowaste..................._710 ....................._31 ..........._._.._..__.._ 0 40 .................2 5,137 ...................................................... 0.24 9/26/2004 /26/.............. ........-......_16:0....................420............._63.050......................._65.............12.760......................................................................................................................................_........................................................................0 ......................................................................................... 0 9/27/2004 ...... .. 24.4 ,._................ 143 29,100 .............._,.. 150 ,_... 30,524 ,__„� 3,900 2,520 no wasteA ._................._..._................._._..__ 70 __._..__.._......._....................................................'-'-'-_....................._.__ 3 610 25 5,087 < 0.10 .._................... 9/28/2004 ........?6_? .___...__.._150 _.__._. 35.904..._.................121 ..........28.982 _.__3,800 ..............._2.4...... no waste ......................34 ._..................................................._0._.................._34 .............._8,138 _...__<. 0.109/29/2004 .27.3 731 166,436 1,034 .........199.881 .....',409..........312,578.............'2.800 235,423 3,000 1,980 no waste .................1,938 340 .....................500 ....... .... .. ................... 0 .................... 44 10,018 ................... 019 ..........0... 9/30/2004 26.6 ............. 901 no waste. .........._..........�_. 0 98 21,741 <0.10 Monthly Avc 20.7 69,335 58,097 Ibs/day = flow (mgd) x conc (ppm or mg/I) x 8.34 sep04wpt.xls, Sep 04 WTP Temp Sum Page 1 of 1 Printed 10/3/2004 Paul To Keith Haynes (DENR DWQ) Dickens/Canton/BlueRidge forrest.westall@ncmail.net, Bob 10/03/2004 02:02 PM Williams/Canton/BlueRidge@BlueRidgePaper, Bob Shanahan/Canton/BlueRidge@BlueRidgePaper, Eddie Plemmons/Canton/BlueRidge@BlueRidgePaper, Steve Single/Canton/BlueRidge@BlueRidgePaper, John cc Pryately/Canton/BlueRidge@BlueRidgePaper, Daryl Whitt/Canton/BlueRidge@BlueRidgePaper, Michael Koerschner/Canton/BlueRidge@BlueRidgePaper, George Garten/Canton/BlueRidge@BlueRidgePaper, Lori Cooper/Canton/BlueRidge@BlueRidgePaper, Michael Ferguson/Canton/BlueRidge@BlueRidgePaper, Kevin Hennessy/Canton/B I u e R i d g e @ B l u e R i d g ePap er, bcc Subject Process and Wastewater Treatment Upset - Blu Ridge Paper y [lam 3 Oct 2004 < m 0 Subject: NPDES NC 0000272 M c: ln�n Process and Wastewater Treatment Upset cmi 29 and 30 Sep 2004 o Blue Ridge Paper Products � m cn C Q Canton, Mill 00 o Z n�n1 Keith Haynes, NC DENR ARO DWQ - m The back-to-back floods impacting Blue Ridge Paper Products in September 2004 are unprecede`n e�Tc. With heroic effort we repaired flood damage and restarted wastewater treatment and mill process operations. The pulp mill restart after the unplanned 3-week cold outage is proving to be a challenge. Because flood waters rose quickly, we were not able to execute a normal mill shutdown. The cold pulp and fiber left in digesters for 3 weeks are well beyond the operating experience of any pulp mill. The quantity of dissolved color materials is much greater than during normal mill operations. We have had great difficulty processing fiber and pulp left in tanks from before the floods and have lost an abnormal amount of color to the mill sewers. The mill restart after Frances and Ivan is absolutely not a normal operating situation and does not reflect the normal color performance of the mill. This note provides written notice required under the NPDES permit that we experienced a process and wastewater treatment upset following restart our pine pulping process on the night of 9/29 and morning of 9130. We previously notified you about the pH excursion on the morning of 9/30 and monthly average color results for September 2004. We confirmed on 10/1 that the 9/30 pH excursion also caused a partial kill of our activated sludge plant. The secondary effluent (SE) color on 10/1 was also high. As a result, Blue Ridge Paper will likely not meet the monthly color discharge limit for October 2004 and may not meet the annual average color limit for 2004. Color data summary for last 5 days is as follows Date Flow PI PE SE River at Fiberville Bridge 9/28 28.7 mgd 150 ppm 456 ppm 121 ppm no color sample, 35,904 #/day 109,147 #/day 28,962 #/day not a river color sample day 9/29 27.3 mgd 731 ppm 1448 ppm 1034 ppm 25 ppm, flow 1015 mgd 166,436 #/day 329,683 #/day 235,423 #/day 9/30 26.6 mgd 901 ppm 2452 ppm 1409 ppm 44 ppm, flow 782 mgd 199,881 #/day 543,961 #/day 312,578 #/day 10/1 28.6 mgd 267 ppm 1101 ppm 2266 ppm 92 ppm, flow 590 mgd 63,686 #/day 262,615 #/day 540,945 #/day 10/2 28.30 mgd 296 ppm 553 ppm 622 ppm 53 ppm at 0919, flow 428 mgd 69,862 #/day 130,520 #/day 146,806 #/day 25 ppm at 1450, flow 492 mgd The daily river run checks DO conditions at Fiberville and at Clyde. The river run on 9/29 and 9/30 included HEPCO and Waterville. Downstream DO levels for the process and wastewater upset period are well above minimum levels. DO readings for the activated sludge plant indicate that treatment continued throughout the upset period and that our bugs are recovering. We will report 5-day BODs for the upset period when PACE Labs has completed these analyses. The mill's average secondary effluent color performance for the period January through August 2004 was 39,737 Ibs/day. We have demonstrated the ability to meet the annual average color limit of 42,000 Ibs/day under normal mill operating conditions. Blue Ridge Paper is working hard to complete the mill restart and return as quickly as possible to pre -flood color performance. Bob Williams - the Blue Ridge Director of Regulator Affairs - will contact Forrest Westall this week to discuss the effect of the floods and unplanned cold mill outage on our monthly and annual average effluent color limits. Paul Dickens Manager, Environmental Affairs Blue Ridge Paper Products, Inc. dickep@blueridgepaper.com 828-646-6141 FAX 828-646-6892 BLUE RIDGE PAPER PRODUCTS INC. 3 November 2004 Forrest R. Westall, PE Water Quality Regional Supervisor North Carolina Department of Environment And Natural Resources Division of Water Quality 2090 US Highway 70 Swannanoa, NC 28778 Subject: NPDES NC0000272 Dear Forrest, CERTIFIED MAIL Return Receipt Requested 7099 3220 0007 0371 1650 Monthly Max Secondary Effluent Color Excursion Wastewater Treatment Plant Recovery from Floods Blue Ridge Paper Products, Inc. Canton, NC NOV - 4 2004 WATER QUALITY SECTION SHEVILLE REGIONAL OFFICE This is the 5-day written report required to notify your office of an excursion. The monthly SE average color for October 2004 was 59,539 lbs/day. The permit monthly max color limit is 52,000 lbs/day. Lori Cooper of Blue Ridge Paper notified Keith Haynes via voice mail and with a follow-up email on 1 Nov 2004 concerning the October color result. The elevated monthly color for October was a result of the unexpected process and wastewater treatment upset that occurred during restart of the Blue Ridge Paper Products mill following the September 2004 floods. The upset led to an elevated color discharge between 9129 and 10/2 and to elevated effluent BOD concentrations during the first week of October. We notified Keith Haynes via telephone and with follow-up written reports concerning these events. The treatment plant quickly recovered from upset conditions. Color and effluent BOD performance since the first week of October have been good. We will report the monthly average BOD result for October when these data are available from PACE Lab. Blue Ridge Paper is making great progress towards restoring our on -site wastewater lab that was destroyed in the September floods. We greatly appreciate DENR's help and understanding with the flood recovery efforts. Sincerely, �Vv on W. Cooper WWTP/Lab Services Coordinator 828-646-2480 coopel@blueridgepa ep r.com Paul S. Dickens Manager, Environmental Affairs 828-646-6141 dickep@blueridgepaper.com 175 Main Street • PO Box 4000 Canton, North Carolina 28716 • 828-646-2000 Raising Your Expectations BLUE RIDGE PAPER PRODUCTS INC. 28 Oct 2004 Forrest R. Westall, PE Water Quality Regional Supervisor North Carolina Department of Environment and Natural Resources Division of Water Quality 2090 US Highway 70 Swannanoa, NC 28778 CERTIFIED MAIL RETURN RECEIPT REQUESTED 7099 3220 0007 1643 pICIOd�D NOV 3 2004 WATER OLIALITY SECTION ASHEVILLE REGIONAL OFFICE Subject: NPDES NC 0000272 Omitted Page - September 2004 Discharge Monitoring Report Blue Ridge Paper Products, Inc. Canton, NC Dear Forrest: We realized today that when producing the September 2004 DMR, the back page certification to the first effluent sheet was not photocopied. A replacement page with the omitted back page is enclosed. Please substitute this page in the DMR package submitted on 10/26. Sincerely - Paul S. Dickens John J. Pryately Manager, Environmental Affairs Waste Treatment and Lab Supervisor 828-646-6141 Operator in Responsible Charge dicken@bluerideeuaoer.com 828-646-2480 pryati @blueridgepaper.com Enclosure: Replacement First Page with Signature Backpage for September 2004 Discharge Monitoring Report Distribution: NC Division of Water Quality, Environmental Sciences Branch NC Division of Water Qulaity, Central File (2 copies) TN Dept of Environment and Conservation Progress Energy Keith Haynes, NC DENR ARO 175 Main Street • PO Box 4000 Canton, North Carolina 28716 • 828-646-2000 Raising Your Expectations I/We, STATE OF NORTH CAROLINA Department of Environment, Health, and Natural Resources Water Quality Section 59 Woodfin Place, Asheville, NC 28801 704-251-6208 File Access Record FACILITY NAME COUNTY (print name) (print name) have been provided access to the above -named file by personnel of the Water Quality Section. I understand that this statement shall be made a permanent part of any file which is viewed under the Freedom of Information provision of the North Carolina General Statutes. (signature) (signature) name/initials of WQ staff member 115 0 date) (date) permit number Canto Sox C - C�gica3?�.: on Chamcso❑ 's-.=.cronai Corocrauon October 5, 1998 Mr. Donald Anderson U. S. EPA Engineering and Analysis Division 401 M Street, S. W. Washington, D. C. 20460 Re: BFR TM - STATUS REPORT Champion International Corporation - Canton Mill Dear Mr. Anderson: As you are aware, Champion has been demonstrating its patented Bleach Filtrate Recycle (BFRTM) process at the Canton Mill in order to meet the December 1, 1998 color reduction objectives set forth in Part Ill, Section E, Paragraph 10 of NPDES Permit No. NC0000272. This paragraph begins as follows: "Beginning December 1, 1998, the annual average discharge of true color shall not exceed 60, 000 Ibs/day and the monthly average true color loading shall not exceed 69, 000 Ibs/day. However, ifby October 1, 1998, in accordance with the Settlement Agreement and the Revised Color Variance, the Technology Review Workgroup determines, and the NPDES Committee agrees, that there are overwhelming technical, economic or operational barriers to the permittee's ability to attain the above -stated color loading limits, the Technology Review Workgroup shall recommend to the NPDES Committee the alternate interim limits to become effective December 1, 1998. " The color limitations set forth in this paragraph are contingent upon the successful operation of the BFR TM technology on the mill's pine line. Specifically, paragraph 7 of the permit reads: "Based on the results of the demonstration effort, the permittee shall continue the full operation ofthe BFRTM technology on the mill's pine line on a continuing basis, subject to the process set forth in Paragraph E 10" CFamccr - —nonal Coroornon, Mr. Donald Anderson page 2 In 1998, the mill's monthly and annual daily average effluent color discharge has been consistently below the limitations set forth in the Paragraph 10. Champion is committed to operating BFRTM on a continuing basis. This is to advise the Technical Review Workgroup that, at this point in the demonstration, no technical, operational or economic issues have surfaced that are viewed as insurmountable obstacles to the continuous operation of the technology. One issue remains outstanding, however, to assure the continuous operation of BFRTM. That issue is an air permit determination by the Western North Carolina"Regional Air Pollution Bureau (WNCRAPB). In order for that determination to be completed certain data must be collected and analyzed. To support that determination, Champion is currently finishing its final round of required air emissions testing on both recovery boilers. Although Champion expects to be able to obtain appropriate air operating permits for the BFRTM process, this evaluation remains to be completed. Champion intends to complete the permitting process as soon as the air emissions testing and analysis is complete. The timing for the completion of this emission analysis and determination is the end of 1998 or early 1999. The BFRTM process can not be deemed to be operational on a continuous basis until the permit determination is complete and any appropriate authorization is received from the WNCRAPB. If you have any questions, please feel free to contact me at (828) 646-2033. Sincerely, Robert Williams Manager, Environmental, Occupational Health and Safety - Canton Mill xc: Mr. Forrest Westall Regional Supervisor Division of Water Quality NC Department of Environmental and Natural Resources 59 Woodfin Place Asheville, NC 28801 Page 2 December 1, 1986 - US District Court Judge Sentelle ruled that EPA had jurisdiction to assume authority over Champion's NPDES Permit. March 4, 1987 - Champion appeal of Sentelle ruling. April 9, 1987 - First EPA Draft (public notice) of Champion NPDES Permit with 50 unit color limit applicable to Champion immediately downstream of discharge at Fiberville Bridge. May 22, 1987 - January 14, 1988 - January 21, 1988 - Second EPA public notice for permit issuance. First Public Hearing in Asheville Civic Center for NPDES Permit issuance. First Public Hearing in Knoxville, Tennessee Civic Center. March 9, 1988 - Tennessee, North Carolina, Champion, and EPA agree on change in proposed permit from 50 Apparent Color units at NC/TN state line (proposed as applicable at the Fiberville Bridge immediately downstream of the Champion Mill) to 85 True Color Units at the State line. .North Carolina and Tennessee to grant variance from color stream standard to allow permit issuance. May 5, 1988 - Champion formally requests water quality color standard variance from EMC NPDES subcommittee at public hearing in Raleigh. June 24, 1988 - Champion appeal of Sentelle decision denied by three judge panel of 4th US Circuit Court of Appeals - verifying EPA authority over Champion's NPDES permit. Ron Levine, Director, Division of St of North Carolina MICHAEL F. EASLEY Department of Justice ATrONNEY GENEML P. G. BOX 629 RALEIGH 276020629 MEMORANDUM TO: Secretary Wayne McDevitt FROM: Daniel C. Oakley-P(,0 DATE: October 13, 1998 RE: Pigeon River Joint Watershed Advisory Committee REPLY TO: Daniel C. Oakley Environmental Division doakley@mail.jus.state.nc.us Telephone: 919/716-6600 Fax: 919/716-6767 The attached correspondence will remind you of North Carolina's commitment to the Joint Watershed Advisory Committee (JWAC), as one of the provisions in the settlement of the Champion Paper matter. Forrest Westall and I have recently discussed the establishment of the JWAC and the appointment of the North Carolina representatives, and wanted to bring it back to your attention. Please review this correspondence and advise whether you are in agreement with the outline of the committee as set out in the exchan-e between Tennessee Deputy Attorney General Barry Turner and myself. If the basic format is acceptable to you, Forrest and I feel we should try to get the JWAC up and running in early 1999. This will require four (4) appointments to be made by North Carolina. As DENR Secretary, you are the appropriate person to make those appointments. Please advise as to how Forrest and I should proceed. Thanks. /dw cc: Bill Holman Preston Howard Forrest Westall attachment wp/28143 OCI 2 2 lcaq REPLY TO: Daniel C. Oakley Environmental Division doakley@maii.jus.state.nc.us Telephone: 919/716-6600 Fax: 919/716-6767 MEMORANDUM TO: Secretary Wayne McDevitt FROM: Daniel C. Oakley DATE: October 13, 1998 RE: Pigeon River Joint Watershed Advisory Committee The attached correspondence will remind you of North Carolina's commitment to the Joint Watershed Advisory Committee (JWAC), as one of the provisions irthe settlement of the Champion Paper matter. Forrest Westall and I have recently discussed the establishment of the JWAC and the appointment of the North Carolina representatives,4�-.J ww� =1 t d -t- C J� Ju r . ZtU_.Cu-- Please review this correspondence and advise whether you are in agreement with the outline of the committee as set out in the exchange between Tennessee Deputy Attorney General Barry Turner and myself. If the basic format is acceptable to you, Forrest and I feel we should try to get the JWAC up and running n early 1999. This will require four (4) appointments to be made by North Carolina. YPc�iy�pt,�s DENR Secretary, are the appropriate person to make those appointments. Please advise as to how Forrest and I should proceed. IioTnam /dw cc: Bill Holman Preston Howard Forrest Westall attachment wp/23 143 STATE OF TENNESSEE Office of the Attorney General RECEIVED SEP 1 41993 I A d. :n u`ncucu ti.C. Af iORMEY GENERAL .... . Envimnmental Division JOHN KNOX WALKUP ATTORNEY GENERAL AND REPORTER ANDY D. BENNETT MICHAEL E. MOORE CHIEF DEPUTY ATTORNEY GENERAL SOLICITOR GENERAL LUCY HONEY HAYNES CORDELL HULL BUILDING ASSOCIATE CHIEF DEPUTY NASHVILLE. TN 37243-043S ATTORNEY GENERAL September 10, 1998 74 FACSIMI EE(6115))741'20091 BY FACSIMILE TRANSMISSION Daniel C. Oakley Senior Deputy Attorney General State of North Carolina Department of Justice P.O. Box 629 Raleigh, North Carolina 27602-0629 Re: Joint Watershed Advisory Committee Dear Dan: I recently met with Justin Wilson, Paul Davis and David McKinney, and what follows are our thoughts regarding the Joint Watershed Advisory Committee the Settlement Agreement requires Tennessee and North Carolina to establish. We think the focus of this Committee is to be on both economic and environmental issues within the watershed. Information relating to such issues would be provided to the. Committee by the States. With regard to Tennessee, economic information would come from the state Department of Tourism and the Department of Economic and Community Development. We have not yet determined what types of economic information these agencies would provide to the Committee. Environmental information would come from the Tennessee Department of Environment and Conservation, the Tennessee Wildlife Resources Agency, and the Tennessee Department of Agriculture. While not an exclusive list, we think the following environmental information relating to the watershed could be provided to the Committee: water quality monitoring reports; biological monitoring reports; NPDES-related planning and actual discharge information; non - point source activities; soil and water conservation programs; and other environmental program information, e.g., RCRA and air. In response to the information provided by the state agencies, the Committee would consider any specific proposals involving the watershed, and if it chose to do so, could prepare comments or other materials regarding such proposals. These would be considered by the appropriate state agency or agencies. We envision state agency support for the Committee to involve supplying the Committee with copies of the information noted above, and reviewing comments or other documents submitted to the agencies by the Committee. Although officials from these agencies would not be regularly attending Committee meetings, officials could be available to meet with the Committee from time -to -time to discuss specific matters if the Committee requests this. From Tennessee's perspective, we do not have resources available to provide funds or agency staff to assist with the operations of the Committee. We would, however, be able to make office space in Knoxville available to the Committee for meetings, and in conjunction with those meetings, we also could make a copy machine and a telephone available for the Committee's use. Tennessee would support the Committee seeking grant assistance from EPA for funds to operate. Concerning Committee membership, we think four members should be appointed by each State. The members would have overlapping service periods, and one of each State's appointments would be a co-chair of the Committee. The Tennessee appointees would be: (1) a government official from a municipality situated on the Pigeon River; (2) a government official of Cocke County; (3) a member of the rafting outfitters' association in Cocke County; and (4) a member of an environmental citizens' group in Cocke County. After you have had a chance to review this, please give me a call to discuss further. I look forward to hearing from you. Sincerely, BARRYI"TURNER Depu ,�Attomey General (615)�32-2586 xe: Justin Wilson Paul Davis David McKinney MICHAEL F. EASLEY ATTORNEY GENERAL State of North Carolina Department of .justice Mr. Barry Turner Deputy Attorney General 425 Fifth Avenue North Nashville, Tennessee 37243-0495 P. O. BOX 629 RALEIGH 2 7 602-0629 July 23,1998 RE: Joint Watershed Advisory Committee REPLY TO: Environmental Division doakley@mai1Jns.statc.nc.us mail.jus.state.nc.us Telephone: 919/716-6600 Fax: 919/716-6767 Pursuant to Paragraph 32 of the Settlement Agreement Regarding 1996 Water Quality Color Variance and 1996 NPDES Permit Issued to Champion International Corporation, North Carolina and Tennessee are required to establish a Joint.Watershed Advisory Committee. The agreement is silent as to the details for setting up and operating the Committee, but the goal is to "foster joint planning and public input on decisions affecting the Pigeon River." Both states need to establish the initial requirements for membership and operation, and it appears you and I are in the best positions to move the committee along legally. Forrest Westall, Paul Davis, Mike McGhee and others have had a general discussion of this on May 12, 1998; and at that time North Carolina suggested several principles to follow. They may be summarized as follows: North Carolina and Tennessee should appoint three or four members each (with concurrent or overlapping service periods), with one of each State's appointments being a co-chair of the Committee (a partnership in direction). The criteria for appointment would have to be established, but would likely include folks that live in the basin and that have some special local interest or leadership role (political, educational, or interest group affiliation). Staffing support of the Committee would have to be agreed to by the two states. Since the basic objective of this section of the Agreement seems to be to foster community interest in the River and the management decisions affecting the River, it is anticipated that the Committee. after completing its initial meetings and organization efforts, would develop its own path. E IN Mr. Barry Turner Page 2 July 23, 1998 It would initiate its own agenda for interaction with federal, State and local agencies having land and water management responsibilities within the watershed. The Committee would develop its own "independent" view of these decisions or proposals and would comment directly to those agencies. It should have broad latitude to determine its role. The purpose of this letter is to initiate a process under which the two states can agree on Committee membership criteria and any staffing or logistics issues. Appointments may then be made and the Committee charged with going forward as it determines appropriate. Please consider this proposal and call me to discuss, at your convenience. I look forward to working with you again on this matter. With best wishes, I am Very truly yours, jovv, 00 Daniel C. Oakley Senior Deputy Attorney General DCO/dw cc: Secretary Wayne McDevitt Preston Howard Forrest Westall wp26431 Effluent NPDES No.: NC 0000272 IDischarge No.: 001 Month: November Year: 1998 Facility Name: Champion Intemational Corporation Class: IVI lCounty: Haywood Operator in Responsible Charge (ORC): David M. Cody Grade: IV I Phone 704-646-2382 Certified Laboratories: (1)Champion Int'I #198; (2) Pace #40,#12, (3) Brooks Rand #546 (4) Burlington Research #002 Check Box if ORC Has Changed Person(s) Collecfing Samples: Operators on Duty Mall a nu L + 1 uuNy to: Attn: Central Files Div. of Environmental Mgt DEHNR P.O. 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O o /y�� (��T�r4 J70n � E TF/ , m'•„ / �1/ tr ® 0 O w T a w 5y� 5 z F HRS YIN MGD °C Std Units Sid Units lb./day- " IbJday #1100ml mg/L mg/L t, 07.00 22LM �N4 . 22.80$+ L33E L1) 212 a$E 2 0700 24 Y 23.684 32.8 7.9 7.8 2773 < 0.082 " 4346 2 12.80 L_YL =628? 4 0700 24 Y 22.413 33.3 7.8 7.8 2882 0.239 5982 12.14 Z-,U io 0, 2d 1 �,11 3.2Tx7?d, i29 1, 7:$ `., i%8;, ;3-67 6 0700 24 Y 22.710 33.0 7.9 7.8 3597 0.173 5493 11.67 1~947 -�AL L1L gTO ?a920 8 0700 24 N 21.721 28.8 8.0 8.0 2389 0.099 4348 11.13 10 0700 24 Y 22.926 31.0 7.9 7.9 2407 < 0.082 4971 10.63 11': _0700. r}.24ic:? _� Y > `A7121 �'1 13 _;;$()x 9 °" . 16 v EQ 1,40 , 12 0700 24 Y 23.158 29.7 8.1 7.9 1215 < 0.082 3476 9.87 23i Lm 22E .�W� 23' 49.%Mz a,$0t mo S 1 . „}` K0082� . M0W1 6SHr 14 0700 24 Y 2233.(5110 331(.g2 8.0 7.9 0{.0(8y2j 392�11 10.83 { � V16 0700 24 Y 23.582 30.7 8.1 8.0 0.082 2360 1 9.78 31545< 18 0700 24Y 24.5011 3300.5 8.18.0 0ry.082 326910.1220 0700 24 Y 24.110 31.4 8.2 7.9 0.082 3217 9.98 21; 2700< 'r24> =$23:fl89<= = .,2 9 + ,� 9A132='' 423W IL� A55 W 22 0700 24 N 22.848 29.4 8.0 7.9 1000 < 0.082 1906 10.43 230700V` = r4,, 4 ,+1;. B �,, 4 ,22,$7$`t'^�i Y.Q.SI,�M1 krO.kt�A Ak;l.\ixrD.�y.. f!{{UVn'd .9..'^ffl�! n i:A�h'Y �?EJM Fi4Y 24 0700 24 B 23.622 31.5 7.9 7.9 1194 < 0.082 2561 10.80 2 . `W,00, „24' k0 '= ,23A20 6 ;79 '2.8t,.h "1403 26 0700 24 N 23.122 30.4 8.0 7.9 2108 < 0.082 5014 11.10 W" ,07001 -,k24 ,N . ;23159a 2$<7 86 7"t7 i038= 124 322833 sx h1184: 28 0700 24 N 23.558 29.6 8.0 7.9 1183 0.099 2358 11.21 •29' 4700 24 : .0V 723238: w29,41 4a `k _7:9 ` xf1452 _ 0082, "2713 1 112 r 30 0700 24 Y 24.548 29.4 8.0 7.9 1402 0.091 2866 2 12.03 K �..'s't£E, u.�^`i- 1 m %x�[p .r �E i'.*.L :4w,R.+' !P ..? :„%A+ 2, f ��a't. b Average P3.112 30.9 1869 0.11 3719 3 10.86 4.60 Maldmgm x, _.. ; ; x 24548. °; 38, ;rt12,., .8:1_ : ,v 3673 V sk 0 24 m 5982 n 23� .,1280 460 Minimum 20.528 28.8 7.8 7.8 1000 < 0.08 1906 1 9.68 4.60 Comp (C)/Gr'ab"(G); Monthly Limit 29.9 9 6 3,598 '12,549 200 6 Facility Status: (Please check one of the following) All monitoring data and sampling frequencies meet permit monitoring requirements. Compliant All monitoring data and sampling frequencies do NOT meet permit monitoring requirements. Noncompliant If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc. and a time table for improvements to be made. 'I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel property gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible forgathering the information, the information submitted Is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations' P.O. Box C-10 Canton, NC 28716 William R. Manzer Permittee (Please print or type) Signature of Perrnittee" Date Parameter Codes 704-646-2840 Permit Expires Nov. 30, 2001 00010 Temperature 00556 Oil & Grease 00951 Total Fluoride 01067 Nickel 50060 Total 00076 Turbidity 00600 Total Nitrogen 01002 Total Arsenic 01077 Silver Residual 00080 Color (Pt -Co) 00610 Ammonia Nitrogen 01092 Zinc Chlorine 00082 Color (ADM[) 00625 Total IGeldahl 01027 Cadmium 01105 Aluminum 00095 Conductivity Nitrogen 01147 Total Selenium 71880 Formaldehyde 00300 Dissolved Oxygen 00630 NidateslNrdites 01032 Hexavalent Chromium 31614 Fecal Colifonn 71900 Mercury 00310 BOD5 01034 Chromium 32730 Total Phenolics 81551 Xylene 00340 COD 00665 Total Phosphorus 34235 Benzene 00400 pH 00720 Cyanide 01037 Total Cobalt 34481 Toluene 00500 Total Solids 00745 Total Sulfide 01042 Copper 38260 MBAs 00530 Tot Suspended 00927 Total Magnesium 39516 PCBs Residue 00929 Total Sodium 01045 Total Iron 50050 Flow 00545 Settleable Matter 00940 Total Chloride 01051 Lead Parameter Code assistance may obtained by calling the Water Quality Compliance Group at (919) 733-5083, extension 581 or 534. The monthly average for fecal coliform is to be reported as a GEOMETRIC mean. Use only units designated in the reporting facility's permit for reporting data. ORC must visit facility and document visitation of facility as required per 15A NCAC 8A .0202 (b) (5) (B). "If signed by other than the permittee, delegation of signatory authority must be on file with the State per 15A NCAC 2B.0506 (b). Aity Name: vi tC : David M on lvwvlllw. t , t.qu EFFLUENT CON'T DO 65 00500 70301 00900 00340 M5 00080 00080 71900 01092 m E g o o d. s F $ 2 O O Z. m a c N x O HRS mg/L mg/L mg/L mg/L mg/L umhos/cm mg/L mg/L ug1L ug/L mgA 9AISM., 2 0700 2040 2074 3826 324 423 4 0700 2046 2060 3768 268 409 1.8 FIR l H UNA .. 6 0700 2107 2038 186 3019 242 397 t? 0 N 20 in M 8 0700 2146 2068 3298 294 423 10 0700 1851 1739 3444 277 396 12 0700 1781 1834 208 3114 246 338 <0.2 20 14 0700 1800 1842 2806 239 308 W 16 0700 1848 1857 2920 272 324 18 0700 2223 2219 3168 301 390 20 0700 1986 1946 176 3011 313 412 E oou 3 22 0700 1712 1648 2421 319 399 OQ,MEOW 24 0700 1868 1878 2666 356 493 r25 �.-Mm I' 26 0700 1885 1885 2926 496 808 ,, oxo .. ,_ 19 .. �. 218F 0700 1732 1706 2790 274 398 -2O � u x � , �°U p'�"^}Y ti.,,s9 .F's= .iL+�Y�t'� Yts'S. k i :S Yf_13� t+ rv, ry,D Et'iA p 1§ 2 aY 1. i.�.W_. �°a, s,.Y�a3 ? t ,lstfi: k -# Y '_..su..wu.z t �#�.' .'�'� 30 0700 1722 1736 2394 268 326 rMai,Average 0.31 1958 1935 218.00 178 3060 303 413 <0.2 20 1.8 rituri%]_64!8 Minimum 0.31 1712 208 170 2394 234 290 <0.2 20 1.8 coa c Granc Cxs77 ~ Monthly Limit 0.014 Influent NPDES No.: NC 0000272 I Influent to WW rP Month: November IYear. 1998 Facility Name: Champion International Corporation County: Haywood 00310 00530 00080 00080 o Y x O N m E � � o N n m 32 � y o 2 y 0 a y� y 0 HRS HRS mglL mg/L mg/L mglL NXI 7 29� �ir 2 735 24 366.0 600 431 2498 3 . 4 1 .7,7 2422 4 720 24 408.0 710 276 1998 x"gmm! 630 24 _ v!C i 362.9 WON 748 lWom 312 3100 6 8 630 24 408.7 758 447 1654 10 725 24 384.3 802 403 2290 1i 12 840 24 424.3 746 470 3040 7 2 y 14 900 24 350.4 468 321 1182 16 715 24 380.0 598 477 1773 18 715 24 474.4 764 774 3033 9 20 0 715 24 319.8 666 397 2104 22 m99 900 i9n9 24 336.1 562 322 2174 1.— 24 730 24 429.3 460 438 1495 I 30 .Wit„ 26 930 24 346.4 592 43yp(1� 1820 `1 4 $y 28 755 24 351.7 540 318 1592 �3022 30 720 24 347.4 500 2658 T v'=aiUB- ^}..Gi � i`1"i . 5 ,rj u Y d i &r t jyXyya��(.� sF •'Yr y 1.�FY�p^"3i--� +,T <'+ i ml�,+' Y $ ' Average 392.9 668 396 2042 ion,L 1Na 4 626 i28Q'a 16{T 3100 �' � s a 7,S : .,. Monthly Min. 289.2 460 177 1182 �k. c' i, . A - UPSTREAM �dti131`•'�i - ��°'-�i.L 1d �A��ax�. " _y °'i=�i__��:.i _t __'_ry h � : f l • e 1 :. . I f .-, : • ' -'. ' . ^i' a . tl.� ;.4 . � ♦ 1 t -S, . -5 i..k a` ' �a..`� R DOWNSTREAM ISHI •,: i. �v 'tY, j l•�Yry p} _.'"�iii�aY)'� �.' lf. as .Il. � '_ 1 __a _ M';. mm�`�� 1 mM a t�11 11 a' 1 m®m_ ' Il�".. ®:- p ' 8 • ! • 1 4J !�1 x "J i_ + s' -�_ a a:" w k 5....-..,_.. _-_ J 1 8 � FI .• A 6..:. i 9. �`.., 1. '".'.: Ji. ..�._�%e4'✓° .. .8 4."`�fL13�r.�'I m�_®1 11 1 1� 1 1� m 1• 1 _____ iit.rg�»y,c.�elem:lurrr� . MSLH;�� rla• STREAM: Pigeon River - DN2 LOCATION: Above Clyde (RNer Mlle 57.7) Downstream 00010 003DO 00300 q E CJ N P- y V o 0 a O 0 d 0 O HRS 'C mgn mgll 2 835 17.90 6.25 6.25 820. jM 5M ffT5fa 4 830 18.60 5.98 5.98 5u ° 9 MM 8 6 855 14.50 6.38 6.38 A '0,16N m$- 8 1000 13.90 7.34 7.34 M 0,, 10 815 16.40 6.64 6.64 Mj :' 780 ,4 12 925 12.80 8.24 8.24 a k1 Novaf 14 955 14.80 8.08 8.08 16 815 14.60 8.57 8.57 } rm635 mmmummm 18 815 12.40 9.18 9.18 8• 20 810 14.90 8.16 8.16 22 955 11.50 8.91 8.91 M 24 830 5mi9_ 15.60 _. . 7.64 7.64 I... z 1 1Q..... .ND �M�.... 26 1020 13.90 8.28 8.28 28 850 12.60 8.43 8.43 A 30 900 12.90 7.78 7.78 gga, Avwap 14.65 7.74 7.74 ear"aa `19E ME 7 wmm M 11.50 5.89 5.89 "b+amq•itms 5 00 ,74 STREAM: Pigeon River- DN3 LOCATION: Below Clyde (River Mile 55.5) Downstream U- 1 r 'a 0 : rl MM 11 ®_- MIMI r�E_ t 11�•si e F.ir 1L1Ln__ 16- It 11 . la STREAM: Pigeon River - ON4 LOCATION: Crabtree (River Mile 53.5) Downstream �t�000t•t• EEL m_______ W=NMM2====j m_______ EIMMEMEMMEMMUMEM m—______ -- STREAM: Pigeon River- DN5 LOCATION: Hepco (River Mile 42.6) Downstream t•ot�000t•t• t�t�0000t•t• i^ 7 . cal Try a l =' (m��®mmmm{m_ M®_____- j T it ;r..4 4 Sri— C 'T 1 9 STREAM: Pigeon River - DN6 _LOCATION: Above Big Creek (River Mile 26) Downstream ©fir—�^---{(•^����__ ram_ _ R PD - Powerhouse Down STREAM: Pigeon River - BC LOCATION: Mouth Big Creek (River Mile -26) Downstream F — —lF �C_-JAL-_, C-F_7-1 . _ • VI ��--__- ____- - Ji�L-_I� STREAM: Pigeon River- DN7 LOCATION: 1-40 Bridge (River Mile 24.7) Downstream OW10 OWID W" om 0= om L Z5 Sl E 2 &M 0 E FIRS C nigA imNgA rrigA mgA rtgn 2 4 1015 15.4 <2 8.47 48 96 LE M 6 1 8 10 955 58 128 EMMEM — M .- 121 031 amil 'WWW"W" - m, - WA 14 16 18 1100 12.5 <2 9.98 37 62 ag W"mmxvzjam 20 ;fflffgffim� 22 W ?F N=FMMM 24 1010 41 69 26 28 =7 7 30 "age 13.1 <2 9.25 45 84 29.00 2 11.5 <2 8.47 34 62 7= -777,7�7 7 t7 7.7 1 747 PD - Powerhouse Down STREAM: LOCATION: Downstream HRS MR MA XtTilrv�vl'l 777- i No.: NC 0000272 Discharge No.; 001 Name: Champion Intemational Corporation David M. Codv Irators on Duty QA / QC DATA SPECIFICATIONS o O O a �C 2 6 tCC � p n C� Q Q y Q n O O 6`� 8 � 0 .t L MA I ffVl MA 2 ` Ra 4 f 6s( '}y�� '•`S;?Hl.Stl :+3#" TStG+�i, A?:.". f ., u�yy� Y`C312 ".' a] .' � k:amNW.n .i 22 8 ' 10 ' 12 14 233.15 16 ME.. 18 ` M91 Mg u 20 5 �22 24 a 26 7p • 'Yx J 'k • ¢ L� m yy�µµ ^ 'b^ 75 �i n"""'a 77, F,7 p1- 28 '+'� �rV''ex4 }.;¢Y,� w`.�Yfl.; �`; :� 'y?<�; �^��, `T+C < ..7%s��` .„ `✓�'! M7 M'� �Yya>i.f �A;���4 �kyvf z, Uk,� trierL ix' t� jr`! 30 { M j M. ^X �Fj R b TIM C Bux "-10 Canton. North Carolina 28716 (U Champion Champion International Corporation December 15, 1998 Forrest R. Westall Regional Water Quality Supervisor NC Department of Environment and Natural Resources Division of Water Quality, Asheville Regional Office 59 Woodfin Place Asheville, NC 28801 RE: NPDES Permit No. NC0000272 Dear Mr. Westall: Champion International Corporation's Canton Mill has an on -going process improvement effort to reduce effluent color emissions. In support of this commitment, an additional opportunity for color reduction has been identified for the hardwood secondary knotter accepts tank overflow. The control strategy for minimizing color losses from the hardwood secondary knotter accepts tank overflow line is detailed in Section 4.6.1 of the June 1,"1998 Color Technology Measures Report", that was submitted to you on May 27, 1998. The current control strategy on this tank employs a temperature probe in the overflow line. If a tank overflow occurs, the increase in temperature is detected by the temperature probe and a process signal immediately alarms the hardwood brownstock operator station and appropriate action is taken. Planned improvements are underway to relocate the accepts tank overflow line into an existing sump in the hardwood brownstock washing building. This will improve color containment and the temperature probe will no longer be required for operator notification. A sump conductivity probe will be used for operator notification in the future. Please accept this as notification of the removal of the temperature probe and implementation of an improvement to mill color -control. If you have any questions or concerns, please contact me at (828) 646-2033 by January 6, 1999. Since�relly,, j _ p Robert V. Williams Manager �6 , Environmental, Occupational Health and Safety 1(7 MICHAEL F. EASLEY ATTORNEY GENERAL Mr. Barry Turner Deputy Attorney General 425 Fifth Avenue North Nashville, Tennessee 37243-0495 �R..� g w � .� State of North Carolina Department of Justice FUM.EIGH 27602-0629 November 17, 1998 RE: Joint Watershed Advisory Council Dear Barry: REPLY TO: Daniel C Oakley Environmental Division Doakley@mailjus.state.nc.us Telephone: 919/716-6600 Fax: 919/716-6767 Thanks for your September 10, 1998. letter regarding the formation of the Pigeon River Joint Watershed Advisory Council. I have discussed our exchange of correspondence with Secretary McDevitt and Forrest Westall, and North Carolina is in agreement with you on the broad, general goals for the Council. We have not taken the step of further discussions with EPA. For initial membership, the four (4) North Carolina representatives will be as follows: l) a member of a local environmental citizens group; 2) a local government representative; 3) a person with pulp and paper knowledge and experience; and 4) a Departmental employee in the DENR Western Regional Office, Asheville, North Carolina. The Secretary is ready to make his appointments. and will ask one of the representatives to act as Co -Chair. We are also agreeable to overlapping service periods. Do you have a' mechanism you prefer? It would be timely to have the Council schedule a formation meeting in early 1999, in either Asheville or Knoxville. Please give me a call at your convenience to discuss our next steps. Sincerely, % /J(/(l�,v� �P /&'�/ Daniel C. Oakley Senior Deputy Attorney General DCO/so cc: Secretary Wayne McDevitt Preston Howard Forrest Westall Laura DeVivo /28866 i,V 2 0 1998 MIN Canton Mill Box C-1 C Canton, North Carolina 28716 V ChaTJ'9plon \J Champion International Corporation November 20, 1998 Mr. Forrest Westall Regional Water Quality Supervisor North Carolina Department of Health and Natural. Resources Water Quality Section Division of Environmental Management 59 Woodfin Place Asheville, NC 28801 Re: NPDES Permit No. NC0000272 r Dear Mr. Westall: As required under the, referenced permit, Part III - Special Conditions, Section E - Requirements for Compliance and Analysis, Paragraph 13, Champion International, Canton Mill is submitting the attached "Low Flow Contingency Plan". If you have any questions, please call me at (828) 646-2033. Sincerely; Robert V. Williams Manager Environmental, Occupational Health & Safety December 1, 1998 Report - Low Flow Contingency Plan Champion International Corporation Canton, North Carolina I. Introduction The following report on the low flow contingency plan details the Canton mill's progress to fulfill the requirements of the 1997 modified Color Variance and NPDES Permit. Part III, Paragraph E 13 of the 1997 Permit provides that: "As the 1997 Revised Color Variance recognizes, there could still be some periods of time, corresponding to periods of lower flows in the river, when color at the Hepco gage might exceed 50 true color units. i The permittee shall develop a contingency plan for mitigating the occurrence and degree of these potential exceedances which correlates measures designed to achieve mitigation with periods of lowest flow, with particular attention being given to periods of higher recreational use in the river. In developing the plan, the permittee shall evaluate any reasonable means, including scheduling of maintenance, intermittent treatment, and production curtailment, which would achieve additional color reductions during temporary periods of lower flows in the river when color at the Hepco gage might exceed 50 true color units. " This plan fulfills the requirements of Part III, Paragraph E 13. December 1, 1998 Report - Low Flow Contingency Plan Champion International Corporation Canton, North Carolina II. Color Performance Review The mill's commitment toward continuous management of color is illustrated in Figure 1, which shows a color reduction of over 85% from the 1988 secondary effluent annual average. The improved color performance is due to the Canton Modernization Project and mill -wide efforts detailed in the June 1, 1998 Color Technology Measures Report. The January 1998 - August 1998 average secondary effluent color discharge of 50,524 pounds per day is well below the 60,000 pound per day effluent limitation specified in Part III, Paragraph E 10 of the 1997 Permit. During the same period, the measured monthly averages for true color at the Hepco bridge are all below 50 standard color units (scu's), even at flows less than the 30Q2 occurring in August. Using North Carolina's governing flow criteria (30Q2), historical flow records, and the 1998 January - August secondary effluent color discharge, it is expected that color in the Pigeon River at the Hepco gage will be less than 50 scu's 97% of the applicable time. Therefore, Champion's actual color performance results in significant mitigation of the occurrence and degree of color at the Hepco gage. 2 December 1, 1998 Report - Low Flow Contingency Plan Champion International Corporation Canton, North Carolina M. Contingency Plan Discussion Based on the current color performance, the mill is below 50 scu's 97% of the applicable time, using North Carolina's 30Q2 flow criteria. The sustained level of low secondary effluent color discharges has been achieved through extensive and ongoing mill -wide efforts. However, in accordance with Part III, Paragraph E 13, the scheduling of maintenance, intermittent treatment, and production curtailment were evaluated for further color reduction benefit during loAiest flow periods. 3.1.1 Scheduling of Maintenance The loss of excess color during outages and upon start-up continues to be a focus of the mill's color minimization activity as detailed in the June I, 1998 Color Technology Measures Report. To minimize color discharges during periods of lowest river flow and higher recreational use in the river, no major maintenance outages will be scheduled during the months of June, July and August. 7 December 1, 1998 Report - Low Flow Contingency Plan Champion International Corporation Canton, North Carolina 3.1.2 Intermittent Treatment A Primary Clarifier will normally be empty and available for outage or unplanned brown colored material storage. When color cannot be reclaimed by the mill's extensive sump system, or when unplanned process losses occur, colored material will be stored in the primary clarifier for managed, intermittent release to the secondary wastewater treatment system. The clarifier will be utilized for managing colored material storage and release based on information provided by continuous sewer conductivity monitoring, daily sewer color monitoring, and normal milk operations communication. This management tool will allow the mill to provide a relatively stable color load to the activated sludge system and subsequent optimization of the activated sludge color removal effect. 3.1.3 Production Curtailment Production curtailment through reduced pulp manufacturing is not a viable color reduction option for the Canton Mill. The mill is designed to achieve the most effective and efficient color control at normal production rates and maximum fiberline"turndown" capacity is approximately 80% of normal production. Therefore, complete fiberline shutdown would be required to effectively reduce pulping process effluent color during periods of lowest flow. Capital expenditures to install a dry furnish system to replace the pulp production for one fiberline would 4 December 1, 1998 Report - Low Flow Contingency Plan Champion International Corporation Canton, North Carolina total several million dollars in addition to dry furnish pulp costs. Production curtailment is neither a technically nor economically reasonable option for intermittent color reduction. W. Conclusion The Canton mill's January 1998 - August 1998 average secondary effluent color discharge of 50,524 pounds per day, coupled with the measures detailed in the June 1, 1998 Color Technology Measures Report, demonstrate the Canton Mill's commitment toward brown colored material management. Using North Carolina's governing flow criteria (30Q2), historical flow records, and the January 1998 - August 1998 secondary effluent color discharge, it is expected that color in the Pigeon River at the Hepco gage will be less than 50 true color units 97% of the applicable. time. The mill's commitment to not schedule major maintenance outages during June, July and August, the months of greatest recreational river use, and optimizing use of the primary clarifier for brown colored material storage and management will result in mitigation of the occurrence and degree of color during periods of lowest river flow. 5 350000 R w 300000 a- 0 250000 0 U y 200000 w .1 150000 v o 100000 d FBI Champion International Corporation - Canton, NC Figure 1: Canton Mill Secondary Effluent Color Performance Annual Averages: 1988 -1997 Monthly Averages: January 98 October 98 WM SE Color December 1, 1998 Limits: —60000 Annual —+r-69000 Monthly 0o 01 O r N M 1* W W n 00 00 Co 00 00 00 Co 00 00 Co 00 00 0) 0) 0) 0) O) 0) 0) O) 03 0) 0) 0) 0) 0) 0) O) a) 0) O) O) O) Q) (1) 0) O) O O) 0)C �. - >1 0) >+ 0) Q "' r r r r r r r r r r 10 10 C M 0 M V LL Q 0 Q W 0 December 1, 1998 Report - Low Flow Contingency Plan NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY November 23, 1998 198 Mr. John J. Pryately Champion International WWTP Lab. P.O. Box 4000 Canton, NC 28716 SUBJECT: Deleting Parameter(s) from Certificate COD Dear Mr. Pryately: Per your request we are deleting the above parameters from your certificate. Enclosed is an updated certificate reflecting this change which is effective on November 23, 1998. If you have questions or we can be of any further assistance, please contact us at (919) 733 3908. Sincerely, 9 Bernard E. Sims, Ph.D. Chief, Laboratory Section BES:mod Enclosure cc James W. Meyer Gary W. Francies Marilyn O. Deaver LABORATORY SECTION 4405 REEDY CREEK ROAD, RALEIGH, NORTH CAROLINA 27607-6445 PHONE'D19-733-3906 FAX 919-733.6241 AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 50 X RECYCLED/10% P09T-CONSUMER PAPER Attachmentl North Carolina Wastewater/Groundwater Laboratory Certification Certified Parameters Listing Champion International WWTP Lab. Certificate Number. 198 F�-� P.O. Box 4000 Effective Date: 1/1/96 rCanton, NC 28716 Expiration Date: 12/31/98 Date of Last Amendment: 11/23/98 The above named laboratory, having duly met the requirements of 15A NCAC 2H.0e00, is hereby certified for the measurement of the parameters listed below I CERTIFIED PARAMETERS I INORGANIC SOD COLOR, PLATINUM COBALT CONDUCTIVITY AMMONIA NITROGEN pH RESIDUE, TOTAL RESIDUE, DISSOLVED 180 C RESIDUE, SUSPENDED This certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are subject to civil penalties and/or decertification for infractions as set forth in 15A NCAC 2H. oam Canton Mill Box C-10 Canton. North Carolina 28716 Champion �J Champion International Corporation November 16, 1998 Mr. Bradley Bennett Supervisor, Stormwater and General Permits North Carolina Department of Environment and Natural Resources P. O. Box 27687 Raleigh, NC 27611-7687 Subject: Request for Designation of Representative Outfall Status. Champion International Corporation, Canton Mill, Haywood County Stormwater Permit NCS000105 Dear Mr. Bennett: The purpose of this letter is to request representative status for stormwater outfall 6-16 with 5C-17 and 513-20 being considered typical for closed landfills, as granted in our permit for analytical sampling. Outfall 6-16 is a new outfall. This outfall collects stormwater from the closed and capped in accordance with the Division of Solid Waste approved plans Cell H at the No. 6 Landfill (see attachments ). Our "Stormwater Pollution Plan" has been revised to reflect the addition of the new outfall and to include the outfall in our facility inspection. If you have any questions or need additional information, please contact me at (704)646- 2372. Sincerely,� Louie Justus Senior Environme al Engineer xc: Mr. Forest Westall NCDENR Water Quality Section 59 Woodfin Place Asheville, NC 28801 Mr. William R. Manzer Vice-Pres./Operations Manager Champion International Corp. 175 Main Street, P.O. Box 4000 Canton, NC 28716 �•T� Xzeai.6 1y i Xz i - X=6a6.8' i XzeBa= X ma �\ '+ zBoo 'zees. X2651.9 Xzesa.a \� ` lB.l LANDFILL F \ i \ \\ / 9 xS \ \ Cx * r ' Xze a x xP.e x X �� ffi X=ax + ih�fijS ., .. Xlli m.rIUrr.> .➢ � I Xarr. Xlera. x }' *� elf Nart. is '.'�X .a• Xlm . I Xlro / $ X eao x Xnaal + +/ Xzmz➢ � x X16 .> X2e71.1 IV Xze 8 + �• ;Xl a I Xl i 'r ♦ ! B.0 83.9 i I x Landfill #6 General Location Map Outfall # 16 ■ m Drawing Legend: Outfall # 16 (Landfill # 6 ) Total Drainage Area: 230,868 Square Feet (See Note, Below) - Drainage Area Outline: Drainage and Discharge Structures: Drop Basins Culvert Pipes Impervious Surfaces: Roads Buildings - Stormwater'Structural Control Measures: Rip -Rap Springs Hazardous Waste Storeage Area Satellite Hazardous Waste Storage Area Materials Loading and Access Areas LOAD Note: New outfall added 11/10/98 due to capping of cell H at landfill No. 6 r i. y (:G L)V-)I �lll1)I�I�iS P.O. BOX 37564 . RALEIGH, NORTH CAROLINA 27627 September 26, 1997�n~'�� Governor James B. Hunt, Jr.. The Capitol Raleigh, N.C. 27611 Re: CHAMPION PAPER MILL -- Canton Dear Governor: The U.S. Environmental Protection Agency is presently reviewing the variance granted by the State to the Champion International Paper Mill in Canton. I am writing today to Carol Browner to deny the variance as EPA has done before. The Pigeon River will never begin the long restoration process it needs for fish, wildlife and people without a significant change in the way Champion does business. Compliance with the relevant wastewater discharges should be at the discharge pipe, not several miles downstream. A recent study shows that can reduce its pollution discharges by almost 50% without any significant cost to the company. I hope you and your staff had an opportunity in Europe to visit some of the paper mills there. They use much more efficient, less polluting processes. North Carolina could be a leader in bringing this technology to the rest of this country, n Thank you for your consideration. IN ���� U OCT 0 6 1997 Sincerely, John D. Runkle President CC. Wayne McDevitt Preston Howard Dan Oakley VVA I kr� QUALIN SCCTIpN G� State of North Carolina ` Department of Environment, Health and Natural Resources 1 • Division of Water Quality James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary p E HIV R A. Preston Howard, Jr., P.E., Director Asheville Regional Office WATER QUALITY SECTION August 21, 1997 Mr. Glen Goodrich 1863 Barnard Road Marshall, North Carolina 28753 Subject: Requested Information Pigeon River Color Data Haywood County Dear Mr. Goodrich: Per your request, please find attached the data concerning improvements in the color of the Pigeon River before and after modernizations to Champion's Canton Mill. Hopefully, this is enough information for your needs. If it is not, or if you have questions concerning what the numbers actually indicate, please do not hesitate to contact me at 251-6208. Si erelyZ � + �- 21 D. Keith Hayne Environmental Specialist Interchange Building, 59 Woodfin Place UP FAX 704-251-6452 Asheville, North Carolina 28801 An Equal Opportunity/Affirmative Action Employer Voice 704-251-6208 500/6 recycles/100/6 post -consumer paper GHnmpION EDHS I0:704-646-6892 AUG 20'97 14:20 No.008 P.02 R' Fall co �E m 0(} m m m m' l w" M m M N NNNMcm V'O'IT LO Lt N pCDm 2' O m m � a`) ~ rn c m CD 4 WLo (�O OD 000 Sp � r c + ❑ �MCD in []NNQW V; �tNr d; o md a r r C4 CO CO V? M co co 0 .- a-rr rrrNrrr U p U ❑ 2 Q 2 - � Qm 47 a- r- 00 u7 t❑ O m m 1- O N d � G ❑ r2 == Ll OCZ. EoEE �-3 7da)008 z o co Canton Mill -- Box C-10 Canton, North Carolina 28716 V Champion Champion International Corporation u September 10, 1998 Mr. Keith Haynes North Carolina Department of Environment and Natural Resources Division of Water Quality 59 Woodfin Place Asheville, NC 28801 RE: Petroleum Release at Champion International Corporations Canton Mill on September 7, 1998 Dear Mr. Haynes: Champion .International Corporation is providing written notification of a release''- of approximately 5 galloffs of hydraulic fluid. The release was discovered on September 7, 1998, at approximately 5:00 a.m. This letter is a follow-up to our telephone notification on September 7, 1998 at 9:55 a.m. to the NCDENR in Raleigh. Hydraulic fluid leaked from a pump coupling at the Beaverdam Creek pump system. The pump system automatically shut-off on low hydraulic fluid as designed. Most of the fluid was contained behind the underflow pump intake structure. A contractor (NEO Corporation) used absorbent booms and pads to absorb the fluid. No sheen was observed downstream of the pump. The coupling was tightened and a permanent system of oil booms was installed around and downstream of the pump. On Tuesday, September 9, 1998, McAusland, the pump supplier/manufacture was dispatched from Florida and a new type of coupling was installed on the hydraulic line to the pump to further prevent any future losses. If you need further information regarding this release please contact me at (828) 646-2372 or Jim Giauque at (828) 646-2028. Sincerely, Louie, Justus - - - Senior Environmental Engineer Jim Giauque Senior Environmental Engineer Canton Mill Box C-10 Canton, North Carolina 28716 V Champion Champion International Corporation October 6, 1998 Mr. Keith Haynes NCDENR Division of Water Quality 59 Woodfin Place Asheville, NC 28801 1 11W1 r s„ OCT —� 1998 Subject: Petroleum Release at Champion's Canton Mill on October 6, 1998. Dear Mr. Haynes: Champion International Corporation is providing written notification of a release of approximately 450 gallons of lubricating fluid (machine oil) at the Canton Mill. The release was discovered on October 6, 1998, at approximately 1:15 AM. Machine oil from the Canton Mill 19 Paper Machine had been leaking from a containment area sump designed to return it to the storage tank but this pump was not functioning. The sump filled and overflowed to the in mill sewer. Upon discovery at 1:15 AM on October 6, the machine oil storage area re -circulation pump was repaired by 2:00 AM. The machine oil traveled through mill sewers to the Waste Treatment Plant. Waste Treatment Plant personnel have not seen evidence of a machine oil spill on the clarifiers or on the river. If you need further information regarding this release please contact me at 704-646-6814 or Jim Giauque at 704-646-2028. Sincerely, s Leitsch Air Group Coordinator Jim Giauque Senior Environmental Engineer Canton Mill Box C-10 Canton, North Carolina 28716 V Champion Champion International Corporation September 25, 1998 Mr. Keith Haynes North Carolina Department of Environment and Natural Resources Division of Water Quality 59 Woodfin Place Asheville, NC 28801 RE: Petroleum Release at Champion International Corporation's Canton Mill on September 22, 1998 Dear Mr. Haynes: Champion International Corporation is providing written notification of a release of less than 800 gallons of paper machine lubrication oil. The release was discovered on September 22, 1998, at approximately 7:50 a.m. This letter is a follow-up to our telephone conversation on September 23, 1998. The oil was released from the overflow line of a 6000 gallon bulk storage tank. The overflow line shutoff valve had been inadvertently left in the open position. The oil flowed into the tank containment where most of the oil was contained. The released oil flowed out of the containment to the mill sewer system through an open drain line. The contained oil was removed by a contractor. The open drain line will be permanently closed. No oil was observed at the Wastewater Treatment Plant as a result of this release. If you need further information regarding this release please contact me at (828) 646-2318 or Jim Giauque at (828) 646-2028. Sincerely, Derric Brown Environmental Supervisor Jim Giauque Senior Environmen ?alEngineer (� Canton Mill (j►`t/''� Box C-10 4 Canton, North Carolina 28716 �� V Champion Champion International Corporation August, 31, 1998 Mr. Gary Francies NCDENR Division of Water Quality Laboratory Section 59 Woodfin Place Asheville, NC 28801-2414 Subject: Total Nitrogen & Total Phosphorus sample out of hold time. Dear Mr. Francies, This letter is notification that the July 1998, sample for total nitrogen and total phosphorus did not meet sample holding time requirements. The sample was collected, preserved, and refrigerated on July 16, 1998. The sample was left in the refrigerator and not sent for analysis until the error was discovered August 20, 1998. No other preserved sample was available that met the 28 day holding time requirement. The test results from this sample were qualified on the July DMR as not meeting holding time requirements. Corrective action taken to prevent this problem for future samples is to match retained chain of custody forms for periodic testing done by contract laboratories to the posted schedule for periodic testing. Taking this action will bring to our attention in a timely manner any deviations from the testing schedule established to meet regulatory requirements. If you have any questions, comments, or need additional information please contact me at 704-646-6720. Sincerely, JPryately Laboratory Supervisor cc: Derric Brown, Mike Cody, Joe Deschene, Bob Williams, Bill Manzer, Keith Haynes, James W. Meyer, Marilyn Deaver yf NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY ASHEVILLE REGIONAL OFFICE WATER QUALITY SECTION September 4, 1998 Mr. Derric Brown Champion - Canton Mill BOX C-10 Canton, North Carolina 28716 Subject: Acceptance of Activated Sludge Canton Mill NPDES Permit No. NC0000272 Haywood County Dear Mr. Brown: This Office does not foresee a problem with your waste water treatment accepting activated sludge from the Town of Maggie Valley. It is suggested that you maintain a record of all sludge received including the date and number of gallons. If you have any questions concerning this matter or if you require additional information, please do not hesitate to contact me at 251-6208. Sin rel , D. Keith Haynes Environmental Specialist xc: Al Matthews champmv.let INTERCHANGE BUILDING, 59 WOOOFIN PLACE, ASHEVILLE, NC 28801-2414 PHONE 828-251.8208 FAX828-251-8452 AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER -50%RECYCLED/10q POST -CONSUMER PAPER Canton Mill Box C-10 Canton, North Carolina 28716 UChampion Champion International Corporation September 2, 1998 Mr. Keith Haynes Environmental Specialist Division of Environmental Management Water Quality Section 59 Woodfin Place Asheville, NC 28802 RE: Bark Boiler Ash/Clinker Handling System Overflow at Champion's Canton Mill on August 29, 1998 Dear Mr. Haynes: Champion International is providing written notification of a release of approximately 8,500 gallons of bark boiler ash/clinker system sluicing water that occurred on August 29, 1998. Your office was notified of the release at approximately 10:05 a.m., August 30, 1998 and this is a follow-up to our conversation. Attached is the Water Quality Section report with additional details. If you have any questions or require additional information, please call Jim Giauque at (828) 646- 2028. Sincerely, m Giauque Senior Environme al Engineer copy: Derric Brown Dick Carlow Louie Justus Sanitary, Sewer, Pump Station and WWTP Spill or Bypass Report Form (Please Print or Type - Use Attachments if Needed) Permittee; Champion International Corp_ Permit Number, NC0000272 County: Haywood Incident Started: Date: 8/29/98 Thye: After 9 p.m. Incident Ended: Date: 8/30/98 Time: Approx. 7 a.m. Source of Spill/Bypass (Check One): O Sanitary Sewer X Pump Station O Waterwater Treatment Plant Level of Treatment (Check One): O None A Primary Treatment O Secondary Treatment O Chlorination Only Estimated Volume of Spill/Bypass: Approx.8,500 gallons (A volume must be given even if it is a rough estimate.) Did the Spill/Bypass reach the Surface Waters? O Yes g No If yes, please list the following: Volume Reaching Surface Waters: AJ1A_ Surface Water Name: Did the the Spill/Bypass result in a Fish Kill ? O Yes O No A,, ,— Location of the Spill/Bypass: The bark boiler ash/clinker handling system. Due to the designed nature of this system the heavier solids would settle and would not be present in the overflow. Cause of the Spill/Bypass: The primary sump pump was pumping slow and was unable to keep up with the influent ash sluicing water. Describe the Repairs Made: A contractor was mobilized with a portable sump pump to pump water from the settling system. Action taken to contain spill, clean-up waste and remediate the site: The water was pumped (still in process at 10 a.m. 8/30/98) and the ash/clinkers will be removed by the normal procedure for disposal in the Champion Landfill. Action taken or proposed to be taken to prevent future spills at this location: The spare emergency pump was out of service for maintenance repair. A back-up spare emergency pump will be maintained to minimize the possibility of future spills. Other Agencies Notified: Voice mail to Keith Haynes @ 10:05 a.m., 8/30/98 Person Reporting Spill/Bypass: Derric Brown Phone Number: (828) 646-2318 Signature : Date: 8/30/98 For DWQ Use Only: Oral Report Taken By: Report Taken: Date: —Time: DWQ Requested an Additional Written Report: O Yes O No If Yes, What Additional Information is Needed : e 1 4 y- ��: LABORATORY SECTION August 26, 1998 TO: Forrest Westall FROM: Gary W. Francies (, w �G Laboratory Section, ARO SUBJECT: Holding Time Compliance Violation Please be advised that Pace Analytical has analyzed Total Nitrogen and Total Phosporus samples, at the clients request, which were out of holding time. Per 15A NCAC 2H .0805 (a) (7) (N) any time a sample is received which does not meet sample collection, holding time, or preservation requirements, the laboratory must notify the sample collector or client and secure another sample if possible. If another sample cannot be secured, the original sample may be analyzed but the results reported must be qualified with the nature of the infraction(s) and the laboratory must notify the State Laboratory about the infraction(s). The following information was supplied by Pace Analytical: Client name: Champion, International Contact person: John Pryately Address: P. O. Box 4000 Canton, NC 28716 Telephone: 828-646-6720 Sample dates: 7/16/98 The client has been notified by the enclosed letter. Please let me know if I can be of further assistance. If you have questions or need additional information contact me at (828) 251-6208 extension 285. Attachment cc: James W. Meyer Marilyn Deaver ;.� NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY ASHEVILLE- REGIONAL OFFICE August 26, 1998 198 MR. JOHN PRYATELY CHAMPION INTERNATIONAL WWTP LAB P.O. BOX 4000 CANTON, NC 28716 Dear Mr. Pryately: We have been notified that on August 20, 1998, you submitted Total Nitrogen and Total Phosphorus sample(s) for analysis of to Pace Analytical Laboratory. At your request the sample was analyzed out of holding time. Please be advised that under provisions of N. C. Regulations 15A NCAC .0805 (a) (7) (N), anytime a laboratory receives samples that do not meet sample collection, holding time, or preservation requirements, the laboratory must notify the sample collector or client and secure another sample if possible. If another sample cannot be secured, the original sample may be analyzed but the results reported must be qualified with the nature of the infraction(s), and the laboratory must notify the State Laboratory about the infraction(s). The notification must include a statement indicating corrective actions taken to prevent the problem for future samples. We are requesting that you take the appropriate steps to avoid recurrence of this in the future. All sample preservation and holding requirements must be met in accordance with the Federal Register, July 1, 1995; 40 CFR 136. Thank you again for your cooperation. Contact us at (828)-251- 6208 extension 285 if you have questions. Sincerely, Gary ancies Laboratory Section cc: James W. Meyer Maril n Deaver sLS.%iF i L'g A .ye INTERCHANGE BUILDING, 59 WOOOFIN PLACE, AsHEVILLE, NC 28801-2414 PHONE 828-261.6200 FAX828-251-5452 AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/1 O% POST -CONSUMER PAPER i - 1 .- NORTH CAROLINA DEPARTMENT OF / ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY ASHEVILLE REGIONAL OFFICE August 26, 1998 198 MR. JOHN PRYATELY CHAMPION INTERNATIONAL WWTP LAB P.O. BOX 4000 CANTON, NC 28716 Dear Mr. Pryately: Your letter dated August 13, 1998 that describes corrective actions for your analytical procedures has been received and reviewed. The actions taken are acceptable for your North Carolina Was laboratory certification. We can accept your MDL (Method Detection Limit) study. 'It is recommended that this MDL study be done annually along with the verification of the standard curve stored in the memory of the spectrometer. Thank you again for your cooperation. Contact us at (828)-251- 6206 extension 285 if you have questions. Sincerely, Gary Francies . Laboratory Section cc: James W. Meyer INTERCHANGE BUILDING, S9 WOODFIN PLACE, ASH EVILLE, NC 28SO1-2414 PHONE 828-251-6208 FAX 828-251-6452 AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER -50q RECYCLED/10% POST -CONSUMER PAPER FAX COVER SHEET ENVIRONMENTAL, OCCUPATIONAL, HEALTH AND SAFETY CHAMPION INTERNATIONAL CORPORATION CANTON MILL TO: h\ Qv4• �\t �P S FROM: DATE: S 130�916 NUMDER OF PAGES: (INCLUDING COVER) NOTE: 1 'the material contained in this communication is intended only for the use of the addressee. It may contain information that Is confidential, proprietary, attorney -privileged, and exempt from disclosure under applicable law. If the reader of this communication Is not the intended recipient, you are hereby notified that any dissemination, distribution or duplication of this communication is prohibited. If you have received this communication In error, please notify us immediately by telephone and return, by mail, the original message to us. Thank you, SENDERS PHONE NUMBER: (828) 04"700 FAX NUMBER: (828) 646.6892 FAX PROBLEMS: (828) 64"700 10'd i00'oN 25:6 86.0£ 9f1H Z689-9V9-bOL:OI SH03 NDI&1UH3 Permitter: :identStartca:rate Incidentended:Date _=Q4a Time d2n.,., In Source of Spfllleypass (Check One)::C Sanitary Sewer Pumo Stanon C Wastewater'Prcatment P ant Level of Treatment (Check One)::^, Nono Primary Treatment C Secondarvi reatment -�; Chlorination Only Estimated Volume of SpilllBvpass: 8 W , ('A volume must be given even if it is a tough estimate.) Did the Spill/Bypass reach the Surface Waters' Yes No : If yes, please list the following: Volume Reaching Surface Waters: _- Surface Water Name: Did the Spill/Bypass result in a Fish Kill? ^� ems ;D No ; Location t 1 "\` 1 Ike. bark bo.\e.r asti.i C�inker Y",a`:d, 5 Je ko e aPs vent s'�er-., na�ore aF kh;s 5,s�em {he heaa;er`�so15 of the,$gill/Ryp-cs: A4v`e rwPr-\oa. Te%0- �r,.nar� 50^-\9 t7a'n�j tAGS` Pom?"?"3 S�o.a o.r\a zc,% .3.CM'C ko keep 'j P va:,V. � e '.nJCn Y as1, S�u3N ' rch L'1C' •er De5cribe the Repni]M 1oMp Watea �w+tn ]che 5e�.1-cam SvJS�@rn. Acdo— non M Contain58 an Un Waste and Rem djat the Site: I-V\t~ wo.-�er v�c,s` �ornPea LSD:\\ ��ocess a� `tDa«, 8�30) and 'Y`e_ as\!!+, I el: u`,k4_r-s yeor-eO.Jre _iNr p:.sOOSa1 :n 5s'r.¢. C.l�c....�P:a✓, Gwn��'•l\ Action Taken or Pro ced to hq Taken to Prevent Fu��� W'.\\ �'o\\o..�- uP or, � act �r•.�c�.-• 'r'e(ao.�' o., -�i.5 i�£?v1. Other Agencies Notf Person Reporting Sp 11 lu�oso. DP_rr'L 16'b,�3^ Phone Number: Date'//r1( For DWQ fjae Only: Ural Report Taken by: Report Taken: Date Time WQ Requested an Additional Written Report: es O o If Yes, What Additional information is Needed: Spill/Bypass Repotting FQM 9197 Z0'd i"0 ON 8S:6 86,0£ 9n1 Z689-9b9-D0L=9I SH03 N0IdHUH9 NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY ASHEVILLE- REGIONAL OFFICE WATER QUALITY SECTION September 4, 1998 Mr. Derric Brown Champion - Canton Mill Box C-10 Canton, North Carolina 28716 Subject: Acceptance of Activated Sludge Canton Mill NPDES Permit No. NC0000272 Haywood County Dear Mr. wn: This Office does not foresee a problem with your waste water treatment accepting activated sludge from the Town of Maggie Valley. It is suggested that you maintain a record of all sludge received including the date and number of gallons. If you have any questions concerning this matter or if you require additional information, please do not hesitate to contact me at 251-6208. xc: Al Matthews Sin rel , D. Keith Haynes Environmental Specialist Post -it® Fax Note 7671 Date 5 pages TO From K�, ICES CoMept. Co. -DW Phone # Phone # 151 _ (qz C3 o� l b Fax # / 1. � Fax # champmv.1et _ -- INTERCHANGE BUILDING, 58 WOODFIN PLACE, ASHEVILLE, NC 28801-2414 PHONE 820-251.6208 FAX 828-251-6452 - AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - SO,p RECYCLED/10% POST -CONSUMER PAPER Canton Mill G pox ^ Canton, North Carolina 28716 GY VA' 7 vv Champion Champion International Corporation Certification Number 198 Mr. James W. Meyer NCDENR, Division of Water Quality Laboratory Section 4405 Reedy Creek Road Raleigh, North Carolina 27607-6445 v AUG 18 1998 L!L'� LA=C/'.'TORY SECTION August 13,1 Subject Laboratory Certification Maintenance Inspection Resl July 16, 1998 Letter and Attached Inspection Report. Dear Mr. Meyer. rG The laboratory inspection report from July '2, 1998 by Mr. Gary W. Francies contained a comment that needed a reply. This correspondence is the response,,to your letter dated July 16,1998 and received July 21, 1998 that includes the reply to the comment. COLOR COMMENT: The signal reading on the low standard is not sufficiently greater than the blank (.002 absorbance units obtained on a 10.c.u. standard). This makes the lower limit of detection or reporting limit questionable due to inviable signal readings. REQUIREMENT: The lab must obtain a signal in which the constituent concentration in reagent water is 2(1.645)s above the mean of blank analysis (Lower Limit of Detection). The constituent concentration that produces a signal sufficiently greater :: than the blank, that it can be detected within specified limits, by good laboratories, during routine operating conditions, is the Limit of Quantitation. Typically it is the concentration that produces a'signal 10s above the reagent water blank signal. In most cases, this requires an absorbance value greater than .005 units, preferably greater than .010 units. Reference: Standard Methods, 18th Edition - Method 1010 C. And 1030 E. RESPONSE: The Hach DR4000 instrument used to perform the color tests has a very sensitive detector that enables the user to perform low level color tests that are statistically valid. Replicate blank analysis were performed to determine the mean and standard deviation of the blank, this data was used to calculate the ( Lower Limit of Detection ) and the ( Limit of Quantitation ) see Table 1 for raw data. Champion International Corporation Table 1 Hach DR4000 Color Test Replicate Blank Analysis Test Replicate Color Units Set Up Blank 0.00 1 0.30 2 0.35 3 1.05 4 0.70 5 0.56 6 1.05 7 0.48 The mean of the blank analysis is 0.64 c.u., the standard deviation is 0.309 c.u., and the highest blank value is 1.05 c.u.. The Lower Limit of Detection is 2(1.645)(0.309) + 0.64 = 1.66 c.u. The Limit of Quantitation is 10(0.309) + 1.05 = 4.14 c.u. The statistical analysis based on the Hach DR4000 replicate blank testing demonstrates that the low standard of 10 c.u. is a viable standard sufficiently greater than the blank. Based on this information the Canton mill will continue to use 10 c.u. as the low standard for DMR reporting. If. you have any questions, comments, or need additional information, I can be contacted by phone at 704-646-6720 or by fax at 704-646-2993. Sincerely, /0/,7,/,/ John J. Pryately Laboratory & WWfP Supervisor Canton Mill Box oCanton,on, North Carolina 28776 �/- l�J Champion Champion International Corporation August 26, 1998 Mr. Keith Haynes North Carolina Department of Environment and Natural Resources Division of Water Quality 59 Woodfin Place Asheville, NC 28801 RE: Petroleum Release at Champion International Corporations Canton Mill on August 22, 1998 Dear Mr. Haynes: Champion International Corporation is providing written notification of a release of approximately 10 gallons of hydraulic fluid. The release was discovered on August 22, 1998, at approximately 7:00 a.m. This letter is a follow-up to our telephone conversation on August 24, 1998. Hydraulic fluid leaked from the pump head of the Beaverdam Creek pump system. The pump system automatically shut-off on low hydraulic fluid as designed. Most of the fluid was contained behind the underflow pump intake structure. A contractor used absorbent booms to absorb the fluid. No sheen was observed on the creek, nor was there any effect observed on aquatic life. If you need further information regarding this release please contact me at (828) 646-2318 or Jim Giauque at (828) 646-2028. Sincerely, butam Derric Brown Environmental Supervisor Jim Giauque Senior Environmental Engineer NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY JAMES B. HUNTJR., GOVERNOR WAYNE MCDEVITT, SECRETARY A PRESTON HOWARD,JR., P.E., DIRECTOR July 16, 1998 198 Mr. John J. Pryately Champion International WWTP Lab. P.O. Box 4000 Canton, NC 28716 SUBJECT: Laboratory Certification Maintenance Inspection Dear Mr. Pryately: Enclosed is a report for the inspection performed on July 2, 1998 by Mr. Gary W. Francies. A response is not required if there were no violations cited. A response is not required for comments or recommendations unless specifically requested. We appreciate the fine job you and your staff are doing. As a certification requirement, your laboratory must continue to carry out the requirements set forth in 15A NCAC 2H .0800. Copies of the checklists completed during the inspection may be requested from this office. Thank you for your cooperation during the inspection. Please contact us al 919-733-3908, if you have questions or need additional information. Sincerely, /' /-�/%,l�p,{ James W. Meyer Laboratory Section Enclosure cc: Gary W. Francies Marilyn O. Deaver LABORATORY SECTION 4405 REEDY CREEK ROAD, RALIIOM, NORTH CAROLINA 27607-6443 PHONE 919-733-39O8 FAX 919-733.6241 AN EOU4LOPPORTUNITY/AFPIRMATIVEACTION EMPLOYER-30 RECYCLZWIO% POST -CONSUMER PAPER ON -SITE INSPECTION REPORT LABORATORY NAME: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: EVALUATOR(S): LOCAL PERSON(S) CONTACTED: I. INTRODUCTION: Champion International Corp. WWTP Laboratory P. O. Box 4000 'Canton,NC 28716 198 7/2/98 Maintenance Gary Francies John Pryately, Derric Brown Mike Cody, Chad Salisbury, Heather Hager This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. II. GENERAL COMMENTS: The laboratory is spacious and well equipped. All equipment is well maintained. Two new desiccators have been obtained. Records are well kept and most data appeared accurate. The lab analyzes quarterly performance evaluation samples for all parameters. Since the last inspection, control limits have been set for duplicate sample analyses for all parameters. Also, most of the forms, logs, and bench sheets have been updated. The staff has done an excellent job of maintaining the laboratory certification program. III. VIOLATIONS, REQUIREMENTS, RECOMMENDATIONS, and COMMENTS: COLOR COMMENT: The signal reading on the low standard is not sufficiently greater than the blank (.002 absorbance units obtained on a 10 c.u. standard). This makes the lower limit of detection or reporting limit questionable due to inviable signal readings. We request a reply to this comment. REQUIREMENT:- The lab must obtain a signal in which the constituent concentration in reagent water is 2(1.645)s above the mean of blank analyses (Lower Limit of Detection). The constituent concentration that produces a signal sufficiently greater than the blank, that it can be detected within specified limits, by good laboratories, during routine operating conditions, is the Limit of Quantitation. Typically it is the concentration that produces a signal 10s above the reagent water blank signal. In most cases, this requires an absorbance value Page 2 greater than .005 units, preferably greater than .010 units. Ref: Standard Methods, 18th Edition - Method 1010 C. And 1030 E. IV. PAPER TRAIL: A review of data was conducted. This consisted of comparing laboratory bench sheets and contract lab reports to DMRs submitted to this Division. Data were reviewed for these months: March, April, and May 1998. No errors were noted. It appears the facility is doing a good job of accurately transcribing data. V. CONCLUSION: This laboratory is doing a good job overall. The staff is cRn.gratulated for doing an excellent job of maintaining the laboratory program. Report prepared by: Gary Francies Date: 7/6/98 M61160 NORTH CAROLINA DEPARTMENT OF ��. ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY ASHEVILLE REGIONAL OFFICE WATER QUALITY SECTION Mr. Derric Brown Champion International Canton Mill Post Office Box C-10 Canton, North Carolina Dear Mr. Brown: August 11, 1998 Corporation 28716 Subject: Performance Audit PAI Grade: "A" Canton Mill WWTP NPDES Permit No. Haywood County Inspection NC0000272 On July 2, 1998 Mr. Gary Francies of the Division's Regional Office Laboratory and I conducted a Performance Audit Inspection on Champion's Canton Mill wastewater treatment program. Personnel present from the Mill during the inspection were: Derric Brown, Chad Salisbury, John Pryately, Melanie Hager, and Mike Cody. It should be noted that the effluent samples were collected on July 22, 1998. The purpose of this inspection was to determine the quality of the self -monitoring program being conducted by the Mill and assess the reliability of its reported data. The inspection consisted of evaluation of the following: flow monitoring equipment, sample collection and preservation techniques, and of laboratory analytical techniques, record keeping and data reporting procedures. The self -monitoring program being conducted by the Mill was shown to be operating according to applicable standards. Flow measurement and sampling procedures were acceptable. The Performance Audit Inspection (PAI) rating for this facility is "A". A PAI rating sheet is attached for your review. INTERCHANGE BUILOING, 59 VVOODFIN PLACE, ASHEVILLE, NC 28801-2414 PHONE828-251-6208 FAX 828-251-6452 AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER -80q RECYCLED/10% POST -CONSUMER PAPER Mr. Derric Brown August 11, 1998 Page Two A. FIELD EVALUATION 1. FLOW MEASUREMENT: Flow is measured prior to the 001 covered discharge structure using an eight foot free flow Parshall flume in conjunction with a Fischer & Porter Ultra -sonic flow meter with Foxboro recorder and totalizer. The effluent sampling devices for outfall 001 are three ISCO model 3710 composite samplers with refrigeration. Proportional composite samples are collected for every 250,000 gallons of effluent. One of the samplers is used for special studies. Sampler tubing is changed on a monthly basis. The two influent composite samplers are both ISCO model 3170 with refrigeration. The temperature in each of the samplers was 40C or less.' RECORD MAINTENANCE: Records and data handling procedures appear to be satisfactory and consistent with self -monitoring requirements contained in the NPDES Permit. 4. PERMIT VERIFICATION: The Permit was issued with an effective date of January 1, 1997. B. LABORATORY EVALUATION FACILITIES AND EQUIPMENT: Laboratory space is adequate for testing performed for the facility. All equipment is well maintained. The lab routinely conducts NPDES testing for temperature, ammonia nitrogen, pH, five-day biochemical oxygen demand (BODS), dissolved oxygen, total suspended solids, total dissolved solids, total solids, chemical oxygen demand (COD), total hardness, color, and settleable matter. Burlington Labs, performs testing for effluent toxicity. Dioxin analysis is performed at Quanterra. Zinc, hardness, nitrite, nitrate, fecal coliform and TKN- analyses are performed at Pace Labs in Charlotte, NC. AOX is performed by Galbriath in Knoxville, Tennessee. Mercury by Brooks Rand. Mr. Derric Brown August 11, 1998 Page Three 2. METHODOLOGY: All testing procedures are based upon Standard Methods 18th edition. Any concerns are discussed in detail in the attached ON -SITE INSPECTION REPORT completed by Mr. Francies as part of the Laboratory Certification Program. 3. RECORDS KEEPING: Laboratory record keeping generally was appropriate and consistent with good laboratory practice. - Should you have any questions concerning the Report, please do not hesitate to contact me at 251-6208. The assistance provided to me by all Mill personnel involved during the inspection was greatly appreciated. S' R94 D. Envecialist Attachment xc: Roger Pfaff, EPA Gary Francies ' United States Environmental Protection Agency Form Approvev, ... Washington, D.C. 20460 OMB No. 2040-0003 PA Approval Expires 7-31-85 NPDES Compliance Inspection: Report -Section A: National Data System Coding - Transaction Code NPDES yr/mo/day Inspection Type inspector Fac Type 1 IN 1 215 I 3 1 NC0000272 11 12 98/07/03 17 18 Iq I u u u 19 20 �z u u Remarks I I I I I I I I -I I I I I I I I I I I I I I I I I I I 31 Reserved Facility Evaluation Rating BI QA Reserved 67LI69 70 J 71 IonI 72) ] 73LJ 74 J 75L LL80 Section B: Facility Date Name and Location of Facility Inspected Entry Time Permit Effective Date Champion International Corp. 9:00 am 970101 Canton Mill Exit Time/Date Permit Expiration Date Canton, Haywood County 3:30 pm 011130 Name(s) of On -Site Representative(s)/Title(s) Phone No(s) Derric Brown - Environ. Supervisor 704-646-2318 Name, Address of Responsible Official Title Mr. William Manzer Vice-PresidentlOperations Mgr. PO Box 10-C Phone No. Contacted Canton, NC 28716 No Section C: Areas Evaluated During Inspection CODES S---Satisfactory M - Marginal U - Unsatisfactory N - Not evaluated/Not applicable $ Permit Site Review $ Flow Measurement Laboratory Waters Pretreatment Compliance Schedules Self -Monitoring Program $. Operations & MaintenanceRecords/Reports Sludge Disposal Other: $ qS $ SFacility E$Effluent/Receiving Section D: Summary of Findings/Co; menfs (Attach additional sheets if necessary) Effluent Data ARO Mill Permit Limits (Daily Avg / Mon Avg) BOD, — 6.1 mg/I 4.26 mg/I 30.0 mg/I - 45.0 mg/I TSS — 6 mg/I 7 mg/I 30.0 mg/I - 45.0 mg/I TDS — 1400 mg/I 1280 mg/I TR — 1400 mg/I 1304 mgA NH, — 0.60 mg/I 0.63 mg/I Fecal Coliform 12/100 ml 13/100 ml Three of the four aeration basins were in operation, with the other one in the digester mode. The remainder of the plant was in full operation. The Parshall Flume/flow meter is calibrated quarterly. Effluent flow at the time of sampling was26.3 MGD. Maintenance records are kept by computer in the treatment maintenance shop. Effluent samples were split with the facility on July 22. All sampler refrigeration units were operating at or below the proper temperature. Twc of the four belt presses were in operation. Name(s) and Signature(s) Inspector(s) Agency/Office/Telephone Date i- D. Keith Haynes DWQ/ARO 828-251-6208 Signatur Rev' wer ' DWQ/ARO 828-251-6208 Date C Regulatory Office Use Only Action Taken Date Compliance Status 13 Noncompliance Compliance State of North Carolina MICHAEL F. EASLEY Department of Justice ATTORNEY GENERAL P. O: BOX 629 RALEIGH 27602-0629 July 23, 1998 Mr. Barry Turner Deputy Attorney General 425 Fifth Avenue North Nashville, Tennessee 37243-0495 RE: Joint Watershed Advisory Committee Dear Barry: REPLY TO: . Environmental Division doakIey@maiIJw.state.nc.us Telephone: 919n l6-6600 Fax: 919nl6-6767 Pursuant to Paragraph 32 of the Settlement Agreement Regarding 1996 Water Quality Color Variance and 1996 NPDES Permit Issued to Champion International Corporation, North Carolina and Tennessee are required to establish a Joint Watershed Advisory Committee. The agreement is silent as to the details for setting up and operating the Committee, but the goal is to "foster joint planning and public input on decisions affecting the Pigeon River." Both states need to establish the initial requirements for membership and operation, and it appears you and I are in the best positions to move the committee along legally. Forrest Westall, Paul Davis, Mike McGhee and others have had a general discussion of this on May 12, 1998; and at that time North Carolina suggested several principles to follow. They may be summarized as follows: North Carolina and Tennessee should appoint three or four members each (with concurrent or overlapping service periods), with one of each State's appointments being a co-chair of the Committee (a partnership in direction). The criteria for appointment would have to be established, but would likely include folks that live in the basin and that have some special local.interest or leadership role (political, educational, or interest group affiliation). Staffing support of the Committee would have to be agreed to by the two states. Since the basic objective of this section of the Agreement seems to be to foster community interest in the River and the management decisions affecting the River, it is anticipated that the Committee, after completing its initial meetings and organization efforts, would develop its own path. 4:1 Mr. Barry Turner Page 2 July 23, 1998 It would initiate its own agenda for interaction with federal, State and local agencies having land and water management responsibilities within the watershed. The Committee would develop its own "independent" view of these decisions or proposals and would comment directly to those agencies. It should have broad latitude to determine its role. The purpose of this letter is to initiate a process under which the two states can agree on Committee membership criteria and any staffing or logistics issues. Appointments may then be made and the Committee charged with going forward as it determines appropriate. Please consider this proposal and call me to discuss, at your convenience. I look forward to working with you again on this matter. With best wishes, I am Very truly yours, Daniel C. Oakley Senior Deputy Attorney General DCO/dw cc: Secretary Wayne McDevitt Preston Howard .Forrest Westall wp26431 @C, s.. NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALM, July 22, 198 Mr. John J. Pryately Champion International WWTP Lab. P.O. Box 4000 Canton, NC 28716 SUBJECT: Deleting Parameter(s) from Certificate RESIDUE, SETTLEABLE Dear Mr. Pryately: Per your request we are deleting the above parameters from your certificate. Enclosed is an updated certificate reflecting this change which is effective on July 22, 1998. If you have questions or we can be of any further assistance, please contact us at (919) 733 3908. Sincerely, Bernard E. Sims, Ph.D. Chief, Laboratory Section . BES:mod Enclosure cc James W. Meyer Gary W. Francies Marilyn O. Deaver LABORATORY SECTION 4405 REEDY CREEK ROAD, RALEIGH, NORTH CAROLINA 27607-6445 PHONE 6I D-733- 300B FAX 91B-733-6241 AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/109o' POST-CONBUMER PAPER -;_ Attachment I North Carolina Wastewater/Groundwater Laboratory Certification Certified Parameters Listing Lab Name: Champion International W WTP Lab. Certificate Number. 198 Address: P.O. Box 4000 Effective Date: 1/1196 Canton, NC 28716 Expiration Date: 12/81/98 Date of Last Amendment: 7/22198 The above named laboratory, having duly met the requirements of 15A NCAC 2H.0800, is hereby certified for the measurement of the parameters listed below I CERTIFIED PARAMETERS INORGANIC BOD COD COLOR, PLATINUM COBALT CONDUCTIVITY AMMONIA NITROGEN pH RESIDUE, TOTAL RESIDUE, DISSOLVED 180 C RESIDUE, SUSPENDED This certification requires maintance of an acceptable quality assurance program, use of approved methodology. and satisfactory performance on evaluation samples. Laboratories ere subject to civil penahiss endtor deceWfiration for Infractions as set form in 15A NCAC 2H.0807. -.0 NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY ASHEVILLE REGIONAL OFFICE WATER QUALITY SECTION Kr. Derric Brown Champion International Canton Mill Post Office Box C-10 Canton, North Carolina Dear Mr. Brown: August 11, 1998 Corporation 28716 Subject: Performance Audit Inspection PAI Grade: "All Canton Mill WWTP NPDES Permit No. NC0000272 Haywood County On July 2, 1998 Mr. Gary Francies of the Division's Regional Office Laboratory and I conducted a Performance Audit Inspection on Champion's Canton Mill wastewater treatment program. Personnel present from the Mill during the'' inspection were: Derric Brown, Chad Salisbury, John Pryately,--Melanie Hager, and Mike Cody. .It should be noted that'the'effluent samples were -collected on July 22, 1998. The purpose of this inspection was to determine the quality of the self -monitoring program being conducted by the Mill and assess the reliability of its reported data. The inspection consisted of evaluation of the following: flow monitoring equipment, sample collection and preservation techniques, and of laboratory analytical techniques, record keeping and data reporting procedures. The self -monitoring program being conducted by the Mill was shown to be operating according to applicable standards. Flow measurement and sampling procedures were acceptable. The facility review. Performance Audit Inspection (PAI) rating for this is "A". A PAI rating sheet is attached for your INTERCHANGE BUILDING. 39 WOOOFIN PLACE, ASHEVILLE, NC 28801-2414 PHON9028-231-6208 FAX628-231-6432 AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 30% RECYCLED/10% POST -CONSUMER PAPER Mr. Derric August 11, Page Two = , FIELD EVALUATION , ti ;;` 1. FLOW MEASUREMENT:. Flow .is measured prior,to%,the 001 covered discharge structure using an eight'a` foot free flow Parshall flume in conjunction wit a Fischer & Porter Ultra -sonic flow meter with Foxboro recorder and totalizer. 2- The effluent sampling devices for outfall 001 are three ISCO model 3710 composite samplers with refrigeration. Proportional composite samples are collected for 'every 250,000 gallons of effluent. One of the samplers is used for special studies. Sampler tubing is changed on a monthly basis. The two influent composite samplers are both ISCO model 3170 with refrigeration. The temperature in each of the samplers was 40C or less. 3. :.,RECORD MAINTENANCE: Records and data handling t' - procedures-appear'to.be.satisfactory and consistent with self -monitoring requirements ?contained in the NPDES-Permit. 4. PERMIT VERIFICATION: The.Permit was issued with an effective date of January 1, 1997. B. LABORATORY EVALUATION 1. FACILITIES AND EQUIPMENT: Laboratory space is adequate for testing performed for the facility. All equipment is well maintained. The lab routinely conducts NPDES testing for temperature, ammonia nitrogen,- pH, five-day biochemical oxygen demand (SODS), dissolved oxygen, total suspended solids, total dissolved solids, total solids, chemical oxygen demand (COD), total hardness, color, and settleable matter. Burlington Labs, performs testing for effluent toxicity. Dioxin analysis is performed at Quanterra. 'Zinc, hardness, nitrite, nitrate, fecal coliform and TKN— analyses are performed at Pace Labs in Charlotte, NC. AOX is performed by Galbriath in Knoxville, Tennessee. Mercury by Brooks Rand.' .. .. is ..� ... ,. _ • Mr. Derric Brown August 11,'1998 Page Three 2. METHODOLOGY: All testing procedures are based upon Standard Methods 18th edition. Any concerns are discussed in detail in the attached ON -SITE INSPECTION REPORT completed by Mr. Francies as part of the Laboratory Certification Program. 3. RECORDS KEEPING: Laboratory record keeping generally was appropriate and consistent with good laboratory practice. - Should you have any questions concerning the Report, please do not hesitate to contact me at 251-6208. The assistance provided to me by all Mill personnel involved during the inspection was greatly appreciated. D. Keith Hayne�. Environmental Specialist Attachment xc: Roger Pfaff, EPA Gary Francies United States Environmental Protection Agency Form Approvea'� Washington, D.C. 20460 OMB No. 2040-0003 ' PA NPDES Compliance Inspection -Report Approval Expires 7-31.85 —Section A: National Data System Coding Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 215 3 NC0000272 11 12 98/07/03 17 18 u t� 19 U 20IJ Remarks II I I I I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I I I r' Reserved Facility Evaluation Rating _ _ BI CA Reserved 66 67 69 ! 70L� 71 72 at73 LLJ74- -75 80 Section B: Facility Date Name and Location of Facility Inspected Entry Time Permit Effective Date Champion International Corp. 9:00 am 970101 Canton Mill Exit Time/Date Permit Expiration Date Canton, Haywood County .. 3:30 pm 011130 Name(s) of On -Site Repmsentative(s)/Title(s) Phone No(s) Derric Brown - Environ_ Supervisor 704-646-2318 Name, Address of Responsible Official Title _ Mr. William Manzer Vice-President/Operations Mgr. PO Box 10-C Phone No. Contacted Canton, NC 28716 11 No Section C: Areas Evaluated During Inspection - • CODES r+ S - Satisfactory M - Marginal U - Unsatisfactory N - Not evaluated(Not applicabl $ Permit Records/Reports $ ,, Flow Measurement Laboratory :3. S Pretreatment Compliance Schedules $ Operations & Maintenant Sludge Disposal $ $ S Facility Site Review - Effluent/Receiving Waters Self -Monitoring Program Other. $ $ $ Section D: Summary of Findings/Comments (Attach additional sheets if necessary) , Effluent Data ARO Mill Permit Limits (Daily Ave / Mon Avg) BODs - 6.1 mgA 4.26 mgA 30.0 mg/I - 45.0 mgA T55 - 6 mgA 7 mg/I 30.0 mgA - 45.0 mgA TDS - 1400 mgA 1280 mg/1 TR - 1400 mg/I 1304 mgA NH, - 0.60 mgA 0.63 mgA Fecal Coliform 12/100 ml 13/100 ml ' Three of the four aeration basins were in operation, with the other one in the digester mode. The remainder of the plant was in full operation. The Parshall Flume/flow meter is calibrated quarterly. Effluent Sow at the time of sampling was 26.3 MGD. Maintenance records are kept by computer in the treatment maintenance shop. Effluent samples were split with the facility on July 22. All sampler refrigeration units were operating at or below the proper temperature. Tv of the four belt presses were in operation. Name(s) and Signatur s) Inspector(s) Agency/Office/relephone Date .tj. D. Keith Haynes _ DWQ/ARO 828-251-6208 Signatur Rev' wer Agency/Office Date - • DWQ/ARO 828-251-6208 B Regulatory Office Use Only 14 Action Taken Date Compliance Status Noncompliance ' Compliance �,r NCDENR JAMES B. HUNTJR., GOVERNOR WAYNE MCDKVITT. SECRETARY A. FRESTON HOWARD,JR., P.E., DIRECTOR 198 Mr. John J. Pryately Champion International WWrP Lab: P.O. Box 4000 Canton, NC 28716 NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES July 16, 1998 SUBJECT: Laboratory Certification Maintenance Inspection Dear Mr. Pryately: DIVISION OF WATER QUALITY Enclosed is a report for the inspection performed on July 2, 1998 by Mr. Gary W. Francies. A response is not required if there were. no violations cited. A response is not required for comments or recommendations unless soecifically requested. We appreciate the fine job you and your staff are doing. As a certification requirement, your laboratory must continue to carryout the requirements set forth in 15A NCAC 2H .0800. Copies of the checklists completed during the inspection may be requested from this office. Thank you for your cooperation during the inspection. Please contact us at 919-733-3908, if you have questions or need additional information. Sincerely, v v -o� James W. Meyer Laboratory Section Enclosure �111 cc: —Gary W. Francies Marilyn O. Deaver -1 \i LABORATORY SECTION 4405 REEDY CREEK ROAD, RALEIGM, NORTH CAROLINA 27607-644S PHOHE919-733-3908 FAX 919-733-6241 AN EQUAL OPPORTUNITY / ARPI RNATI V E ACTION EMPLOYER - 50% RECYCLED/10% "ST-COHOUMER PAPER ON -SITE INSPECTION REPORT LABORATORY NAME: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: EVALUATOR(S): Champion International Corp. WWTP Laboratory P. O. Box 4000 Canton, NC 28716 198 7/2/98 Maintenance Gary Francies LOCAL PERSON(S) CONTACTED: John Pryately, Derric Brown Mike Cody, Chad Salisbury, Heather Hager I. INTRODUCTION: This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. II. GENERAL COMMENTS: The laboratory is spacious and well equipped.- All equipment is well maintained. Two new desiccators have been obtained. Records are well kept and most data appeared accurate. The lab analyzes quarterly performance evaluation samples for all parameters. Since the last inspection, control limits have been set for duplicate sample analyses for all parameters. Also, most of the forms, logs, and bench sheets have been updated. The staff has done an excellent job of maintaining the laboratory certification program. III. VIOLATIONS, REQUIREMENTS, RECOMMENDATIONS, and COMMENTS: COLOR COMMENT: The signal reading on the low standard is not sufficiently greater than the blank (.002 absorbance units obtained on a 10 c.u. standard). This makes the lower limit of detection or reporting limit questionable due to inviable signal readings. We request a reply to this comment. REQUIREMENT: The lab must obtain a signal in which the constituent concentration in reagent water is 2(1.645)s above the mean of blank analyses (Lower Limit of Detection). The constituent concentration that produces a signal sufficiently greater than the blank, that it can be detected within specified limits, by good laboratories, during routine operating conditions, is the Limit of Quantitation. Typically it is the concentration that produces a signal 10s above the reagent water blank signal. In most cases, this requires an absorbance value Page 2 greater than .005 units, preferably greater than .010 units. Ref: Standard Methods, 18th Edition - Method 1010 C. And 1030 E. IV. PAPER TRAIL: A review of data was conducted. This consisted of comparing laboratory bench sheets and contract lab reports to DMRs submitted to this Division. Data were reviewed for these months: March, April, and May 1998. No errors were noted. It appears the facility is doing a good job of accurately transcribing data. V. CONCLUSION: This laboratory is doing a good job overall. The staff is congratulated for doing an excellent job of maintaining the laboratory program. Report prepared by: Gary Francies Date: 7/6/98 ;a' August 3, 2001 Memorandum Subject: Additional Color Removal Opportunities, Blue Ridge Paper's (BRP) Canton, NC Bleached Kraft Paper Mill, 2001 NPDES Permit Renewal From: Technology Review Workgroup Donald Anderson, Chair, EPA Karrie-Jo Shell, EPA Region IV Paul Davis, Tennessee David McKinney, Tennessee David Goodrich, North Carolina Forrest Westall, North Carolina To: North Carolina Division of Water Quality and the NC Environmental Management Commission's NPDES Sub -Committee In accordance with the 1997 NPDES Permit Agreement for the Canton Mill, the Technology Review Workgroup (TRW) has examined the progress made at the facility in relation to reducing the color content of the Mill's effluent and the potential for additional color reduction at the plant. The focus of this examination includes a review of reports submitted by Blue Ridge Paper (BRP), a visit to the Mill on March 14, 2001 by EPA's Tech Team, consultation among the EPA Tech Team and the Workgroup's members, consideration of the separate Mill evaluation and Liebergott report (Bleach Environmental Process Evaluation and Report) dated June 8, 2001, and comments from environmental interest and other stakeholder groups (including Clean Water Fund of North Carolina, American Canoe Association), and EPA's Tech Team Memorandum on this subject dated July 25, 2001. It is the finding of the TRW that the EPA Tech Team Memorandum represents an appropriate evaluation of the potential for additional color reduction at the Mill over the next permit cycle (December 1, 2001 through November 2006). As a result of this finding, the TRW includes with this memorandum a copy of the subject report for use by the Division of Water Quality and the Environmental Management Commission's NPDES Sub -Committee as guidance for the development of the effluent limitations for color and related special conditions of the draft NPDES Permit renewal and North Carolina's Effluent Color Variance. As the purpose of the TRW is to provide a review of the possible technology options available to the Mill to further reduce the color discharge to the Pigeon River, the EPA Tech Team Memorandum provides a solid foundation for developing specific conditions and limitations for the Mill's next NPDES permit. In making this point, the TRW recognizes that not all of the options outlined in the Tech Team Memorandum can be predicted to achieve specific color reductions with complete accuracy. Consequently the Memorandum provides estimates of possible reductions and in some cases a range of likely color reduction from the application of specific technologies. The TRW also notes that several individuals and organizations provided alternate estimates to the EPA Tech Team. Again, the difference between "technological likelihood" and "regulatory limit" is an important distinction that must be considered in "enforcing" permit conditions. When considering the potential color reduction options provided in the Tech Team Memorandum in developing a draft NPDES Permit and Color Variance, the TRW recommends that the following points be considered: 1. The highest priority for additional color reduction moving toward achieving the North Carolina water quality standard for color rests with additional in -mill improvements, particularly considering the success already achieved by continuing improvements in leak and spill prevention and control (Best Management Practices — BMPs) and process modifications. End -of -pipe technologies reflect significant economic, technical, and non - water quality environmental impact problems at this mill. 2. The Tech Team Memorandum identifies by degree the "certainty" of three possible categories of options that the Mill could undertake to further reduce color in the mill's effluent. The "regulatory risk" of being able to achieve the reductions under these categories increases as the certainty decreases. Any regulatory limitations/conditions need to reflect this consideration. 3. The TRW recommends that the options identified in the Tech Team Memorandum as having the "highest certainty" (i.e., improvements in reliability of the existing bleach filtrate recycle system (BFR) and leak and spill prevention and control - BMPs, and process optimization) should be implemented first and the permit/variance should reflect a very specific level of reduction. The time necessary for the Mill to implement these "primary" options should realistically reflect the ability of BRP to design, fund and install the outlined options to achieve these color reductions. The TRW recommends up to two years as a reasonable period of time for implementing these options. In determining the actual color reduction "limit" to be placed in the permit the recommendations of the Tech Team Memorandum should form the general basis of that decision. It may be appropriate to consider the second tier of options identified in item 4 in setting the limitation applicable to the implementation of the "highest certainty" options. 4. The process improvement options needing further study and identified as having "reasonable certainty" of success (second stage oxygen delignification on the softwood fiber line; ozone addition to chlorine dioxide bleaching on the hardwood fiber line) should be incorporated in the permit/variance as an additional increment of color reduction to be demonstrated by the Mill. BRP should be required to evaluate the technologies identified by the Tech Team and to develop an implementation plan that would either utilize these technologies or identify other options that would result in similar increments of color reduction. Because the Tech Team could not estimate at this time with high certainty the color reduction achievable by these options, the permit/variance needs to include a mechanism of application similar to that used in the 1997 Permit Agreement. That procedure involves review of a proposed plan from the Mill, approval of the plan, a schedule for placing selected option(s) into service, a period of demonstration of the effectiveness of the option(s), followed finally by setting limitations considering the "target" reduction range but consistent with the actual effluent color loadings achieved (see paragraph 6). The TRW recommends the option(s) selected should be installed, operational, and appropriate limits developed within the next permit term. The potential additional color reduction in treatment of the Chloride Reduction Process (CRP) purge stream was considered as an option with "lowest certainty" of success. While this conclusion is supported by the preliminary treatability study already attempted by BRP to remove color from this waste stream, the TRW recommends that the permit/variance include requirements that the Mill continue to evaluate all technologies that might result in significant reduction of this source of color in the Mill's sewers. fiffi-E rpproacMereristdirecteditEUcuriDgiwhateve aaddirionalrreductionsiate possible based-on3i implementatoof the -results of this evaluation should logically follow those options considered to have higher certainty of success. 6. It should remain the objective of the regulatory agency to monitor, evaluate and apply the color reduction performance achieved at the Mill from application of pollution prevention process technologies and BMPs. As the color reduction efforts outlined in the permit/variance are put into operation at the Mill, the actual performance as measured by daily effluent color loadings should be statistically evaluated to develop appropriate limitations for the Mill including a long term average and a revised maximum monthly average which captures actual variability. The Division of Water Quality should apply those limitations under the permit through formal notification. 7. The permit/variance should continue to require BRP to report on or identify any "breakthrough" color reduction technologies developed at the Mill or that become available within the industry or the research community. 8. To the extent possible, the TRW recommends to North Carolina that the in -stream compliance point for color be moved as close to the point of discharge as possible (e.g., Fiberville Bridge). This compliance point must be related to the end -of -pipe color loadings to be achieved by the technologies identified in this recommendation or alternative technologies identified by the Mill as reflected in limitations included in the permit/variance. The TRW further recommends that the compliance point ultimately be moved to the Mill's end -of -pipe discharge point to the Pigeon River, and the format of the limitations also be reviewed as it relates to capturing effluent variability. 9. The TRW believes it is important for the re -issued permit/variance to require a formal evaluation by BRP of the Mill's efforts during this cycle (2001-2006) to comply with North Carolina's water quality standard for color. This evaluation should be an important part of the reporting requirements of the permit/variance. 10. The role of the TRW should continue through the next permit cycle, the re -issuance process in 2006, and until the Mill has achieved compliance with North Carolina's in- stream color standard (a variance is no longer needed). As a "clearinghouse" for the reports and information submitted by BRP under the reissued permit, the TRW provides an objective view that is useful to the two States, the parties to the 1997 Permit Agreement, and other stakeholders. This advisory role is important to fostering the cooperative completion of the color reduction process at the Mill. In presenting these recommendations to the Division of Water Quality and the Environmental Management Commission's NPDES Sub -Committee, the TRW wishes to acknowledge the excellent success achieved since the 1997 Settlement Agreement and the continued effort ofBRP to improve on this excellent record. The substantial decrease in effluent color since the 1997 Settlement Agreement to the current levels of color observed day to day both at the Canton Mill and downstream in Tennessee is a testament to the efforts of everyone involved in this process. While the Canton Mill is among world leaders in the pulp and paper industry as measured by the quality of its treated effluent, the commitment of the Company and the continued interest and participation in this process by the regulatory agencies, stakeholder public and environmental interest groups, and the general public makes additional improvement possible, ultimately leading to elimination of the variance. If there are questions concerning this recommendation, please feel free to contact the TRW. Attachment: Memorandum from EPA Tech Team to the TRW, entitled, Additional Color Removal Technologies and Their Economic Impacts on Blue Ridge Paper Products, Canton, NC, dated July 25, 2001 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 'SgIeD sN 'le A MEMORANDUM DATE: July 25, 2001 SUBJECT: Additional Color Removal Technologies and Their Economic Impacts on Blue Ridge Paper Products, Canton, NC FROM: EPA Tech Team' TO: Technology Review Workgroup Purpose of this Analysis As required by the 1997 Settlement Agreement, this memorandum presents a summary of an analysis of available technologies that may be employed to further reduce color discharges from the Blue Ridge Paper Products, Inc. (Blue Ridge) mill in Canton, NC. The analysis also includes a summary of the economic impact ("gross margin test") of the cost of implementing identified color reduction technologies. Members of the Tech Team visited the Canton mill on March 14, 2001 to observe and gather information and data on the status of technologies implemented and color discharges at the mill since the 1997 evaluation. This final memorandum incorporates analyses of the data gathered from that visit, and Blue Ridge's response to EPA's follow-up request for additional technical and financial data. This final memorandum is based on the May 4, 2001 preliminary draft memorandum, and revisions to the July 10, 2001 draft final memorandum, based on a review of Blue Ridge's comments, the June 8, 2001 Bleach Environmental Process Evaluation and Report (BEPER) and subsequent comments by Liebergott and Associates and GL&V Pulp Group, Inc, and additional comments from the Clean Water Fund of North Carolina, and the States of Tennessee and North Carolina. This memorandum presents to the Technology Review ' EPA Tech Team is comprised of -- Mark Perez, EPA/EAD; Karrie-Jo Shell, EPA Region 4; Don Anderson, EPA/EAD; Betsy Bicknell, ERG, contractor; Neil McCubbin, subcontractor to ERG; Dan Bodien, subcontractor to IaMel Workgroup (TRW) process improvements evaluated by the Tech Team and considered to be available technologies and briefly addresses relevant technologies evaluated in the BEPER. Background and History Blue Ridge operates a bleached papergrade kraft pulp and paper mill in Canton, NC, which it purchased from Champion International Corporation in May 1999. Operations at the mill began in 1908, but the mill has been extensively modernized, most recently in 1993. The mill currently operates an 800 tpd hardwood pulping line and a 600 tpd softwood pulping line. After cooking, pulp from each line is further delignified in single -stage oxygen delignifrcation systems installed in 1993. Hardwood pulp is subsequently bleached with a DEoD sequence; pine pulp is bleached with a DEopD sequence. Target brightness is 85 ISO. Up to 80 percent of the filtrate flow from the pine bleach line is returned to the recovery cycle using the unique bleach filtrate recovery (BFRTM) process, developed by Champion. A portion of the hardwood line bleach plant Eo- stage filtrate flow is also recovered. Blue Ridge produces 250,000 tons per year of uncoated paper including offset, tablet and envelope grades. The mill also produces 281,000 tons per year of bleached paperboard used for liquid packaging and paper cups, including FDA approved grades for milk and juice cartons. Since November 2000, pulp production has been reduced by approximately 30 percent as the result of a major project to upgrade the No. 19 bleached paperboard machine. Continued Color Reduction Opportunities Since the 1997 NPDES Permit The Canton Mill's 1997 NPDES permit included a schedule requiring continued study, evaluation, and pursuit of effluent color reduction opportunities. Champion and Blue Ridge submitted a series of reports to the NC Department of Environment and Natural Resources, Division of Water Quality, evaluating the performance of the BFRTm process, end -of -pipe color reduction technologies, and practices for minimizing color losses from manufacturing processes. Since 1997 Blue Ridge has: • continued full-scale operation of BFR for the pine line; • concluded that full-scale BFR is not feasible for the hardwood line, but implemented partial reuse of a portion of the Eo-stage filtrate as an effective color -reduction approach; • identified and implemented several practices for reducing losses of highly -colored black liquor from manufacturing processes; and • evaluated 16 end -of -pipe color removal technologies and determined that they were presently economically and/or technically infeasible for the Canton mill. Page 3 Process Improvements Analyzed by the Tech Team The Tech Team identified five mill improvements capable of further reducing the discharge of color in the mill effluent. For each of these improvements, technical feasibility, capital and operating costs, and potential color reduction were reviewed. Each improvement can be implemented independently of the others or in any combination. The costs incurred to implement the improvements are additive, however separate evaluations are necessary to accurately estimate the associated color reduction achieved by implementing any combination of improvements. End -of -pipe color treatment technologies (e.g., chemically assisted clarification with sludge dewatering and disposal) typically require initial capital investment and ongoing operating expenses, not savings, and are likely to incur non -water quality environmental impacts. For this reason, the Tech Team focused on pollution prevention approaches that offer the potential to be more cost-effective: color reduction in low flow, highly color -concentrated wastestreams, through manufacturing process changes or in -process treatment. The first two process improvements, discussed below (improvements in BFR reliability and leak and spill prevention and control - Best Management Practices (BMPs)), are improvements which the Tech Team concludes offer the highest certainty for technical feasibility and color reduction. Blue Ridge also identified these technologies as feasible color reduction opportunities that will be implemented, but differed from the color reduction estimates included in this memorandum. The next two process improvements (ozone addition to an existing chlorine dioxide bleaching stage on the hardwood fiber line; adding a second stage to the current oxygen delignification system on the softwood fiber line) also were evaluated by Liebergott, et. al., as feasible color reduction opportunities. Additional technical evaluation and/or laboratory testing would be appropriate to reliably determine the technical details of how to incorporate these processes into the existing fiber lines and to more accurately predict their achievable color reduction, and the relationship of these technologies to BFR. Additional analyses would be appropriate to determine the most cost-effective design and the most economically feasible schedule for implementing one or both of these improvements. The fifth process improvement, color treatment for the chloride removal process (CRP) purge stream (one of the two key components of the BFR process), has the potential for additional color reduction. However, based upon initial bench -scale treatability studies by Blue Ridge, further study of additional color treatment technologies is necessary. Process optimization on both the hardwood and softwood fiber lines, as recommended in the BEPER, is anticipated to Page 4 provide additional color reduction and is identified as the sixth process improvement. It was concluded that the process optimization option was among those with the highest certainty for technical feasibility and color reduction. All color reductions resulting from the mill improvements are estimates based solely on available data and information. While the Tech Team has concluded that these technologies would reduce the color discharge from the Canton mill, there is a lack of directly comparable operating experience with these technologies in other bleached papergrade kraft mills that can be used to develop precise predictions of the extent of the color reduction benefits. The BEPER evaluated additional in -process technology options for color discharge reduction potential, including the implementation of a hot pressurized peroxide -enhanced extraction stage in both fiber line bleach plants. At this time, the Tech Team does not have sufficient information to confirm the applicability of this technology at the Canton mill nor relevant data to predict its potential color discharge reduction capabilities. Therefore, while this memorandum does not address this technology option, it may be feasible for implementation by Blue Ridge and contribute to reducing color. In addition, the Tech Team did not analyze nor did the BEPER recommend a Totally Chlorine -Free (TCF) bleaching option because of the high cost of this technology and the lack of experience in producing and successfully marketing products made by Blue Ridge at the Canton mill. 1. BFR reliability improvement. One of the two key elements in BFR is the Metals Removal Process (MRP). Blue Ridge has found that this process element has been more challenging and expensive to maintain than originally planned. The target BFR recycle rate (percent closure) for the pine line is 80 percent. Due to unforeseen equipment failures (e.g., ion exchange media) and metallurgy problems (e.g., erosion of multi -media filtration tank lining) in the MRP, however, the pine line closure has averaged only 74 percent from October 1998 to the present. Blue Ridge has undertaken improvements to the MRP system in order to maintain the process closure rate and increase operating time. Improvements include rebuilding piping and valves, and changing construction materials and metallurgy to better withstand the chemical and physical stress experienced in the BFR system. Blue Ridge estimates that if BFR closure is maintained at 80 percent, annual average final effluent color discharge will be reduced by 1,000 to 1,200 lbs/day. At this time, the Tech Team has no means of making an alternative quantitative prediction of final effluent color reduction to compare to the Blue Ridge estimate. Page 5 2. Improved black liquor leak & spill collection and control (BMPs). The Canton mill has an extensive spill recovery system. Sumps in this system, including one sump added in the court yard adjacent to the digester house as required by the 1997 Settlement Agreement, are equipped with pumps that are activated automatically when sensors detect wastewaters with high conductivity and color. High conductivity material is routed to the recovery system. Further improvements to the black liquor collection system include: • continuous improvement of operating practices so more leaks and spills are recovered rather than discharged to sewer; • further improvement in preparation for planned outages to maximize capture of tank clean -out waste and routing to recovery; • further reducing clean water that continuously runs into sewers to prevent dilution of smaller spills and facilitate recovery of highly colored wastewaters; and • further improvement in the equipment used for handling of knots rejects to prevent black liquor leaks into the recovery sumps. The plot below shows the color of wastewater treatment influent at the Canton mill. The variability of influent color discharge to wastewater treatment is attributed to color discharge peaks that represent, in part, unplanned spills or leaks discharged to sewers or intentional diversions of highly -colored black liquor or other color sources routed to sewers during mill equipment shutdowns. 100 kg/t Figure 1 75 Daily color at influent to W WTP for Canton so 25 0 30 60 90 120 150 180 Page 6 Due to the nature of the manufacturing processes and practical equipment operation and reliability, all spills and color losses to sewers cannot be fully anticipated, predicted, and completely contained. However, a comparison of the variability of the Canton mill influent color data to available primary influent color data at another bleached papergrade kraft mill indicate that a detailed review of the spill prevention and recovery system at the Canton mill (by mill staff or external consultants), including involvement by the mill operators, can further uncover the causes of and better quantify black liquor losses and other color sources that can be avoided or recovered. This will result in an overall reduction in color discharge, both in long-term average and variability. Through improved planning of mill equipment shutdowns, continuing efforts to minimize process operation variability, and increased recovery of highly -colored leaks and spills, discharges of highly colored material to the wastewater treatment system can be reduced more consistently below existing levels. Further reducing peaks in color discharges within the mill and preventing highly colored flows from reaching the wastewater treatment system will further reduce the variability of color discharges from the wastewater treatment system to the Pigeon River. For example, limiting the color of the primary clarifier influent to less than 70,000 lb/day through continuing efforts to improve the mill's BhV system and process operations would reduce the color loadings from mill processes to the end -of -pipe wastewater treatment system by more than 8,000 lb/day. The Canton mill operated under this primary clarifier influent color threshold approximately 74 percent of 2000, excluding November through December 2000. This time period was considered not to be representative of steady-state operations because of the reduced pulp production resulting from upgrading the No. 19 bleached paperboard machine. Assuming the average reduction of 45 percent across this wastewater treatment system for "brown" color derived from black liquor, this would result in a minimum decrease of 4,400 lb/day in the average final effluent color load. Clean water, such as packing gland water, presently flows in several sewers with recovery sumps. These colorless streams dilute other colored wastestreams, such as small black liquor leaks and spills, to the point where the in -stream conductivity is too low to trigger recovery. By eliminating clean water streams or diverting them away from sewers that collect black liquor leaks and spills, wastewater streams with elevated color can be recovered more readily, resulting in a reduction in color discharge to the end -of -pipe wastewater treatment system. Also, the unintentional but intermittent discharge to the sewer of filtrate from knots and screen rejects can be recovered. Page 7 At this time, the Tech Team has no basis for determining an accurate correlation between unaccounted color and sewer generated color, as reported in Section 2 of the Canton Mill Environmental Performance Update presented by Blue Ridge during the March 14, 2001 Tech Team Canton mill visit. During the March 14 visit, Blue Ridge staff indicated that results of studies of sewer generated color showed a relationship between bleach plant filtrate pH and temperature and unaccounted color generated in mill sewers. By operating within the range of pH and temperatures identified during the studies the Canton mill has had some success in controlling this source of unaccounted color. Based on this information, the Tech Team concludes that by further reducing process operation variability, including operating within the pH and temperature range identified during the studies, the mill can continue to also minimize sewer generated color, thereby reducing one source of unaccounted color. Reducing overall color discharges through BMPs and other management practices will likely further reduce remaining unaccounted color. However, additional studies are necessary to further develop any relationship between accounted and unaccounted color sources. As noted above, analysis of primary clarifier influent color loading data demonstrates that color loading to the wastewater treatment system of lower than 70,000 lbs/day is possible during steady-state operations. Through continuing efforts to minimize unplanned spills and leaks and intentional discharges of colored streams and continuing efforts to minimize process operation variability, the Canton mill can achieve further reduced primary clarifier influent color loads and subsequent final effluent color discharge within this range on a more consistent basis than demonstrated in 2000 (i.e., more than 74 percent of the time). On this basis, the Tech Team concluded it is feasible to reduce final effluent color by more than 5,000 lbs/day through improved black liquor leak and spill collection and control. 3. Ozone/Chlorine dioxide stage for hardwood bleach line. Ozone is used in more than ten kraft mills around the world to bleach pulp, including two in the US and one in Canada. There are several process configurations, but the most common is to operate an ozone (Z) mixer and reactor immediately upstream of a chlorine dioxide reactor, without any washing between the application of the two chemicals. This is known as a "ZD" stage. A system of this type was retrofitted in the Domtar mill at Espanola, Ontario, Canada in 1999.' Bleaching with ozone on the hardwood line, one of the Domtar mill's two pulp lines, resulted in a 27 percent reduction in the discharge of color in the combined mill treated effluent.' The conversion to a ZD stage Munro, Fred and John Griffiths, Operating Experience with an Ozone -based ECF Bleaching Sequence, Tappi, 2000. Ibid. Page 8 would reduce the use of chlorine dioxide and caustic chemicals for bleaching in exchange for ozone. The energy requirements for ozone production would be offset by the energy savings from less chlorine dioxide and caustic production, resulting in a net reduction in energy consumption with the ZD stage. As of September 2000, the long-term average color discharge from Canton's hardwood bleach line was 12,800 pounds/day'. The Espanola experience suggests that implementation of a ZD stage in the hardwood bleach plant at the Canton mill could reduce the filtrate color discharge by 3,000 to 6,400 lbs/day. Based on comments received, the Tech Team acknowledges that operating parameters, such as wood species processed and technology supplier performance guarantees, may influence the practical color reduction achievable through implementation of a ZD stage at the Canton mill, in comparison to the Espanola experience. These estimates are based solely on the demonstrated performance and the Tech Team's assumption of color sources at the Espanola mill, confirmed at the recent Pulp and Paper Technical Association of Canada (PAPTAC) meeting in Thunder Bay, Ontario. Laboratory bleaching trials and possible communication between Blue Ridge and Domtar staff would be necessary to reliably predict the achievable color reduction possible with this option for the Canton mill. The technical evaluation of this process improvement included in the BEPER yielded a hardwood filtrate color discharge reduction within the range of Tech Team estimates. 4. 2"d stage OD for pine line. Oxygen delignification (OD) on the Canton Mill pine line is a single stage system installed in 1993. It has been concluded that retrofitting a second OD stage for the pine line could contribute to reduced color discharges in two ways. The first would be a reduction in color for those filtrates presently not captured and reused in the BFR process. The second would be a color reduction in the Chloride Removal Process (CRP) purge stream as a result of less chloride from chlorine dioxide used for bleaching. Costs were estimated for a reactor with oxygen mixer and chemical charge equipment installed upstream of the existing reactor. Previously, the Tech Team anticipated increasing the kappa number (lignin content) of the cooked pulp from 24 to 32 and utilizing a two -stage OD system to reduce kappa number from 32 to 11, an approximate 65 percent kappa reduction across the two - stage system. Based upon comments from BRP and further technical analysis, and review of the BEPER, it was concluded that it is technically feasible for a two -stage OD system at the Canton Jacobs Engineering Group, 2001 Color Removal Technology Assessment, February 2001. Page 9 mill to achieve an overall reduction of 50 percent in kappa number, rather than 65 percent as previously anticipated. Therefore, with the Canton mill continuing to pulp to a kappa number of 24, the new two -stage OD system would reduce pulp kappa number into the bleach plant from the current output of 16 to about 12, corresponding to a 50 percent kappa number reduction from the current digester output of 24. The quantity of color released from the bleach plant will be reduced in proportion to the reduction of the input kappa number. By decreasing the kappa number of the pulp fed to the bleach plant from kappa 16 to 12 with a two -stage OD system, the quantity of chemicals required in the first two stages of the bleach plant can be reduced, because there is less lignin present in the incoming pulp to remove by bleaching. The reduction in chlorine dioxide used for bleaching would result in a proportional reduction in chloride load to the CRP and reduce color discharged from the purge stream in proportion to the reduction in chloride being treated. In response to comments received, it has been concluded that implementing a two -stage OD system without increasing the kappa number of the cooked pulp from 24 to 32 would not achieve a 1.5 percent pulp yield gain as anticipated with increasing digester kappa number and achieving greater delignification with the proposed two -stage OD system. However, operating a two -stage OD system with a higher than 50 percent delignification rate and a digester kappa number higher than currently employed at the Canton mill is commonly seen at comparable bleached papergrade kraft mills. Therefore, the Tech Team anticipates that additional process engineering will maximize the benefits of a two -stage OD system at the Canton mill and enable the mill to capture the increased delignifcation and yield gain potential of this technology and achieve annual wood cost savings of up to approximate $950,000 from up to a 1.5 percent yield increase across the proposed two -stage OD system. Based on additional information supplied by Blue Ridge regarding operational limitations of the BFR system, the Tech Team concludes that a two -stage OD system would not have a significant impact at this time on the Canton mill's ability to increase BFR closure rate above 80 percent on a day-to-day basis. For this analysis, it was estimated preliminarily that a second OD stage could reduce total influent color -discharge to the wastewater treatment system by 1,500 to 2,000 lb/day from reductions in pine line bleach plant filtrate color and CRP purge stream color. Page 10 The technical evaluation of two -stage OD included in the BEPER yielded reduction in color discharge influent to the wastewater treatment system within the range of the Tech Team estimates. 5. Color Treatment of CRP purge stream. The Chloride Removal Process (CRP) purge is a low flow, highly concentrated waste stream. Color is typically 50,000 pcu, in a 10 gpm (0.01 MGD) flow. The CRP purge contributes up to approximately 5,000 lbs/day (13 percent) to the total mill loading to the wastewater treatment system influent, but only 0.06 percent of the discharge flow. It was originally speculated that it may be feasible to reduce the color in this stream by precipitating the colored organic material with lime at a dosage of 20 g/L5, and burning the resulting sludge with the main lime mud stream fed to the mill's lime kiln. Laboratory trials would be necessary to test the feasibility of color removal from the CRP purge stream by lime treatment. Blue Ridge subsequently conducted laboratory trials of color precipitation using four calcium compounds, including lime mud, fresh lime, calcium chloride, and milk of lime. The preliminary results of these trials show that at a dosage of 20 g/L, none of the compounds tested reduced color in the CRP purge stream. Although color removal was demonstrated at higher dosage rates, increased chemical usage would result in substantially higher operating costs, require larger sized equipment at higher capital cost, and also result in a higher production rate of sludge to be burned in the mill's lime kiln. Excess sludge produced from this process that is not burned must be landfilled at additional cost. Based on preliminary laboratory trials, Blue Ridge concluded that lime treatment of the CRP purge is not a feasible color reduction option for the Canton mill. However, the Tech Team recommends additional review of other innovative technologies for treatment of color in the CRP purge stream, such as the application of the X-Filter process recently implemented at a totally chlorine free (TCF) mi116. By minimizing color contributions from this stream, the potential exists to achieve a significant reduction in primary influent color discharge of up to 5,000 lbs/day. NCASI Technical Bulleting No. 239, The Mechanisms of Color Removal in the Treatment of Pulping and Bleaching Effluents with Lime. 1. Treatment of Caustic Extraction Stage Bleaching Effluent July, 1970. 6 Comments on the Draft Report on Additional Color Removal Technologies and Economic Impacts for BRPP, Hope Taylor, Clean Water Fund of North Carolina, July 18, 2001 Page 11 6. Process Optimization. The BEPER identified sixteen recommendations for optimizing the hardwood and softwood fiber lines, focusing mainly on the current OD systems and bleaching operations. It was estimated that a reduction could be achieved in chlorine dioxide use in the first bleaching stage of up to 27 percent for the hardwood line and 18 percent for the softwood line. The reduction in chlorine dioxide use would result in a bleach plant filtrate color reduction of up to 700 lbs/day from the hardwood line and up to 4001bs/day from the softwood line. The Tech Team estimated an additional color reduction from the CRP purge stream of 6001bs/day resulting from the decreased chlorine dioxide usage. At this time, the Tech Team has no means of making an alternative quantitative prediction of bleach filtrate color reduction to compare to estimates presented in the BEPER. Therefore, it is estimated that through efforts by mill staff to maximize the color reduction benefits from the process optimization opportunities identified by Liebergott, et, al., the Canton mill would achieve a total color reduction of 1,700 lbs/day in wastewater treatment system influent. Color Reduction Summary The Tech Team estimates that by improving BFR reliability and black liquor leak and spill collection and control, the Canton mill final effluent will be reduced by more than 5,000 lbs/day. Process optimization, as outlined in the BEPER, would result in a further final effluent color reduction of approximately 1,400 lbs/day. This assumes the average color reduction of 45 percent across the existing wastewater treatment for the CRP purge stream and other "brown" color sources derived from black liquor and no reduction in color from bleach plant filtrates. Table 1 presents a summary of the estimated reductions in final effluent color attainable with the highest certainty by implementing improved BFR reliability, improved BMPs, and process optimization. Page 12 Table 1: Summary of Process Improvements and Associated Color Reductions (Highest Certainty) Process Improvement Influent Final Effluent Color Color Reduction Reduction (lbs/day) (lbs/day) 1 BFR reliability improvement --- 1,000-1,200 2 Improved black liquor leak & spill collection and --- > 5,000 control 6 Process Optimization 1,700 1,400 TOTAL FINAL EFFLUENT COLOR REDUCTION >7,400 Additional potential mill improvements to reduce color discharge at the Canton mill were also identified. These process improvements require further study to more accurately determine achievable color reduction and thus are not recommended at this time for immediate implementation. These improvements include a ZD stage in the hardwood bleach plant, with a preliminary estimate of a 3,000 to 6,400 lbs/day color load reduction in influent to the wastewater treatment system, and a second OD stage for the pine line, with a preliminary estimate of a 1,500 to 2,000 lb/day color load reduction in influent to the wastewater treatment system. Table 2 presents a summary of preliminary estimates of color reductions for these two additional process improvements that need further study. Reductions presented in Table 2 are preliminary estimates with reduced certainty compared to those presented in Table 1, but are based upon identified technology options available for the Canton mill. Page 13 Table 2: Summary of Process Improvements and Associated Additional Color Reductions Needing Further Study (Reasonable Certainty) Process Improvement Influent Final Effluent Color Color Reduction Reduction (lbs/day) (lbs/day) 3 Ozone/Chlorine Dioxide stage for hardwood bleach 3,000-6,400 3,000-6,400 line 4 2 d stage OD for pine line 1,500-2,000 1,100-1,400 TOTAL FINAL EFFLUENT COLOR REDUCTION 4,100 - 7,800 Table 3 presents a preliminary estimate of color reduction potential for the removal of color from the CRP purge stream. The Tech Team recommends this stream for additional review of potential color reduction technologies but cannot identify a particular technology option at this time. Potential for additional color load reduction up to 2,750 lbs/day in final effluent to the Pigeon River. Table 3 presents potential color reduction estimates with the lowest certainty. Table 3: Summary of Additional Potential Color Reductions Needing Further Study (Lowest Certainty) Process Improvement Influent Final Effluent Color Color Reduction Reduction (lbs/day) (lbs/day) 5 1 Color Treatment of CRP Purge Stream #5,000 #2,750 TOTAL ADDITIONAL POTENTIAL FINAL EFFLUENT COLOR #2,750 REDUCTION Page 14 Economic Analysis The estimated capital and operating costs for the process improvements one through four were estimated and are summarized below. Costs could not be developed at this time for process optimization or CRP treatment and thus are not presented. However, costs for these improvements should be modest. Table 3: Estimated Costs Process Improvement Capital Cost Annual O&M ($) ($/year) 1 BFR reliability improvement $1,300,000 $85'0006 2 Improved black liquor leak & spill collection and $100,000 $50,000 control 3 Ozone/Chlorine Dioxide stage for hardwood bleach $1,500,000 ($350,000) line savings 4 2"a stage OD for pine line $2,000,000 ($2,100,000) savings Blue Ridge Paper Products Inc. was formed in May 1999 with the purchase of seven plants (including the Canton Mill) from Champion International Corporation. Blue Ridge Paper Products is owned 55 percent by KPS Special Situations Fund, L.P. and 45 percent by the employees of Blue Ridge Paper through an employee stock ownership plan. At the time of the 1997 report EPA documented substantial losses over five years for the Canton Mill and Champion had just announced its intention to sell or close the mill. However, because of the sale of the mill to the Blue Ridge, the previous data are not comparable to the more recent data. Further, the data submitted by Blue Ridge is still confidential, so this report cannot present as much detail as the 1997 report. The current analysis is based on information submitted by Blue Ridge covering part of 1999 (May -December) and all of 2000 (all of the existing financial data for the company). The results may be relatively uncertain because of the lack of data and the company may be too young for the current data to reflect its ultimate financial health. EPA used three measures of financial health (gross profit test, discounted cash flow, and Altman's Z)7 to assess the impact of 'See Interim Economic Guidance for Water Quality Standards: Workbook, EPA 823-B-95-002, March 1995, and Page 15 air emissions control technologies and devices (not addressed in this memorandum, such as MACT H and regional NOX control) and wastewater compliance costs (separate and combined) on the mill and company. The costs for the wastewater control options presented in Table 3 do not change the financial status of the mill or company. However, the costs for some of the air emissions control options do impact the health of one or both entities. When the wastewater costs are added to costs for air emissions control, the impacts of the water costs do not change the financial status of either the mill or company when compared to the impact of the air costs alone. References Blue Ridge Paper Products, Inc. Canton Mill Canton Mill Environmental Performance Update, Prepared for U.S. EPA Technology Review Workgroup. March 14, 2001. Blue Ridge Paper Products, Comments on and Transmittal of Financial Data for Economic Analysis of Blue Ridge Paper Products, from Bob Williams, May 18, 2001 (CBITS 00003911- 01) Comments on Preliminary Draft Final Tech Team Report, email from Derric Brown, Blue Ridge, to Don Anderson, EPA, May 18, 2001 Comment Clarification of May 18, 2001 Blue Ridge Responses to EPA Questions, from Derric Brown, Blue Ridge, June 4, 2001 Comments on Draft Final Tech Team Report, from Bob Williams, Blue Ridge, to Don Anderson, EPA, July 13, 2001 Comments on Draft Final Tech Team Report, from Derric Brown, Blue Ridge, to Don Anderson, EPA, July 17, 2001 Comments on Draft Final Report, email from Forrest Westall, North Carolina DENR, to Don Anderson, EPA, July 17, 2001 Comments on Draft Final Report on Additional Color Removal Technologies and Economic Impacts for BRPP, Hope Taylor, Clean Water Fund of North Carolina, July 18, 2001 Comment on Draft Final Tech Team Report, email from Paul Davis, State of Tennessee, to Don Anderson, Julyl8, 2001 Comment on Draft Final Tech Team Report, email from Lew Shackford and Norm Liebegott, to Don Anderson, EPA, July 19, 2001 Jacobs Engineering Group, 2001 Color Removal Technology Assessment, Blue Ridge Paper Products Inc. Prepared for The North Carolina Division of Water Quality. February 2001. Liebergott, Norm, and Lew Shackford, Bleach Environmental Process Evaluation and Report, June 8, 2001 McCord, Aimee, A Laboratory Analysis of Color removal Across a Pulp and Paper Mill Wastewater Treatment Facility, Canton, North Carolina, Duke University, School of the Environment, 1995 Munro, Fred and John Griffiths, Operating Experience with an Ozone -based ECF Bleaching Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press. NCASI Technical Bulletin No. 239, The Mechanisms of Color Removal in the Treatment of Pulping and Bleaching Effluents with Lime. I. Treatment of Caustic Extraction Stage Bleaching Effluent. July, 1970. Salisbury, Chad A Laboratory Analysis of Color Removal Mechanism Across the Wastewater Treatment Facility of a Pulp and Paper Mill, Canton, North Carolina, Duke University, School of the Environment, 1996 Springer, Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry. Page 182 Wiley Interscience, 1986. Springer, Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry, 3 d edition. Page 286. TAPPI Press, 2000. 1 Appendix 1: Color Balance (911100 to 12/31/00) Figure 2.6, Presented by Blue Ridge on March 14, 2001 Sewer ID Description Color Load (lbs/day) 213 Digester area sewer: Digesters, HW line, knot rejects 4,323 3A Alkaline sewer: Pine and HW Eo, Pine line BSW, 02 Delig 12,954 1 PMs11 & 12, HW weak liquor tank 1,991 513 Recovery, BLOx, CRP* 7,852 6A Acid sewer: Pine and HW D1 filtrate + Pine D2 filtrate 17,345 Contaminated Condensate 1,591 Combined Condensate 260 Total 46,316 Primary Influent (PI) 49, 284 * * Unaccounted Color (PI minus Total) 2,968 Secondary Effluent 37,696 Percent Removal in Treatment 23 % CRP contributes 5,000 to 6,0001bs/day to 5B sewer ** Measured using test method in NCASI Tech. Bull. 803, An Update of Procedures for the Measurement of Color in Pulp Mill Wastewaters, May 2000. Appendix 2: Table of Effluent Color Limits,1997 to Present Color Limit True Color (Ibs/day) Monthly Average Annual (Long-term) Average 1997 Permit 125,434 98,168 Settlement Agreement, February 1998 (starting December 1, 1998) 69,000 60,000 Settlement Agreement, February 1998 (Ultimate Target) --- 48,000 to 52,000 Interim Limits, May 2001* 55,000 1 48,000** As recommended by Technology Review Workgroup (TRW) and incorporated by NC in BRP's NPDES permit. ** Reduced end -of -pipe color discharges since November 2000 reflect, in part, reduced pulp production (approximately 30 percent) during this period because of the ongoing project to upgrade the No. 19 paper machine used to produce bleached paperboard. Appendix 3: Ozone Bleaching Munro, Fred and John Griffiths, Operating Experience with an Ozone -based ECF Bleaching Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press. Appendix 4: Two -Stage Oxygen Delignification Comparison of one- and two -stage oxygen delignification systems Item Current Single -Stage System Proposed Two -Stage System Oxygen Reactors One two Input Kappa Number 24 24 Output Kappa Number 16 12 Total C102 Used 28 kg/ton* 22 kg/ton* Oxygen Used 23.4 kg/ton* 28.3 kg/ton* Total NaOH Used 45 kg/ton* 37 kg/ton* * air-dried metric ton of bleached pulp 1� State of North Carolina e� Department of Environment IVA and Natural Resources Division of Water Quality L Michael F. Easley, Governor NCDENR William G. Ross, Jr., Secretary Gregory J. Thorpe, Acting Director August 3, 2001 Mr. Robert Shanahan Vice President - Mill Manager Blue Ridge Paper Products P.O. Box 4000 Canton, North Carolina 28716 Subject: NPDES Draft Permit Permit No. NC0000272 Blue Ridge Paper Products Inc. Haywood County Dear Mr. Shanahan: Blue Ridge Paper Products Inc. applied for an NPDES permit renewal on February 26, 2001. The Division of Water Quality's original schedule for conducting a public hearing prior to July 31, 2001 was postponed in order to allow the EPA Tech Team and the Technology Review Workgroup the necessary time to incorporate the findings of a third party evaluation of the Canton Mill, sponsored by the Clean Water Fund of North Carolina, American Canoe Association, Western North Carolina Alliance, Dead Pigeon River Council, Appalachian Voices, Tennessee Environmental Council, Southern Appalachian Biodiversity Project, Dogwood Alliance and the National Forest Protection Council. The EPA Tech Team has completed their report and provided the Technology Review Workgroup with the `potential' color reductions available through the application of the identified process improvements. Based on this report, the Technology Review Workgroup developed the `regulatory' basis for additional color reductions in this permit cycle. Now that the EPA Tech Team and the Technology Review Workgroup's color recommendations are final, the Division of Water Quality has prepared this draft permit and scheduled a public hearing for September 6, 2001 (additional details below). After issuing a "pre -draft" permit, the Division of Water Quality prepared this draft permit and is once again soliciting comments from the Environmental Protection Agency, the State of Tennessee, the City of Newport, Cocke County, and other concerned stakeholders. The Division reviewed and considered all comments received during the "pre -draft" comment period and modified the "pre -draft" permit and fact sheet accordingly. The modifications reflected in this draft permit include the following: The dioxin monitoring special condition has been modified. The dioxin monitoring special condition in the pre - draft permit allowed the permittee to split samples. If the analysis of either sample was below the minimum level, then the quality was considered zero for compliance purposes. The Division received concerns over this allowance and has modified the condition accordingly. The decision to split samples is at the discretion of the permittee, if samples are split, the permittee must report both values and compliance shall be judge on each sample independently. ➢ Dates that have passed have been deleted from the Best Management Practices Special Condition. Special Condition A. (8.) Requirements for Color Analysis and Compliance have been added. Based on the recommendations of the Technology Review Workgroup and the EPA Tech Team Report, the Division of Water Quality has developed the recommendations for additional color removal over the term of the permit. The color reductions contained in this condition represent a 19% to 29% reduction in the current permitted color load. After Blue Ridge Paper has implemented the process improvements necessary to achieve color reductions within the targeted range, Blue Ridge Paper will evaluate the feasibility of complying with North Carolina's 1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617 - TELEPHONE 919-733-5083/FAX 919.733-0719 AN EQUAL OPPORTUNITY AFFIRMATIvE ACTION EMPLOYER - 50% RECYCLED/ 10% POST -CONSUMER PAPER VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES Permit Number: NC0000272 color standard. Then during permit renewal process in 2006, the Division of Water Quality and the NPDES Committee will evaluate what additional reduction, if any, are required in order to achieve compliance with North Carolina's color standard. Below are the Division's responses to comments received on the pre -draft permit. There were concerns over the language in the Best Management Practices Special Condition, these include: Special Condition A. (6.) Section A. 1, the wording "to the maximum extent possible as determined by the mill. The language and conditions set forth in the Best Management Practices Special Condition were developed by the EPA as part of the new Effluent Guidelines for the Pulp and Paper Industry. After extensive research and gathering of public comment, the EPA stipulated an industry standard for Best Management Practices. The language contained in Special Condition A. (6.) is consistent with the industry standard as published in the Code of Federal Regulations. Since Blue Ridge Paper meets or exceeds the Best Management Practices standards, the Division does not feel that requiring a higher standard is justified at this time. — Special Condition A. (6.) Section E.3, the language "failure to take the actions required by Section E.2 as soon as practicable will be a permit violation". The comment was made that this language is unenforceable. In addition to the comment made for Special Condition A. (6.) Section E.3, it is the Division's understanding that the language in Section A. (6.) E.3 "failure to take the actions required by Section E.2 as soon as practicable will be a permit violation", is a 'good faith' condition and that any gross violations of this condition are enforceable. Monthly reporting of 'action' level exceedence was recommended. In addition, to the comment made for Special Condition A. (6) Section E.3, please refer to the Best Management Practices Special Condition Paragraph E. This condition requires that Blue Ridge Paper submit an annual report to the Division of Water Quality that summarizes Best Management Practices monitoring and action levels. The longer time frame (annual as opposed to monthly) associated with the annual submittal required in Special Condition A. (7.) provides the Division with a more representative analysis of operations at the mill and is better suited for analysis and conclusions. Therefore, the Division feels that annual reporting is appropriate. Comments were made regarding the daily maximum BOD5 limit proposed in the pre -draft permit. The Division's review of the instream dissolved oxygen data indicates that the limits and conditions in the permit are protecting the dissolved oxygen standard in the River. Additionally, the Division's model predicts and actual data supports that the lowest dissolved oxygen concentrations occur at river mile 57.7, which is above Hepco. The Division received comments regarding the need for nutrient limits in permits above the lake. The Division has no evidence that nutrients are a concern in this watershed. Additionally, Blue Ridge Paper's nutrient loading is relatively low, however, nutrient monitoring will continue as a condition for this permit in order to assess Blue Ridge Paper's nutrient loading to the River. The Division received comments regarding the removal of the monitoring station at river mile 53.5. Blue Ridge Paper currently is monitoring color, temperature, and dissolved oxygen at river mile 53.5. Temperature and dissolved oxygen monitoring at this point is required according to the NPDES permit issued to the City of 'Waynesville. Since Waynesville is already required to monitor this station, it is the Division's recommendation that additional monitoring of temperature and dissolved oxygen by Blue Ridge Paper is not appropriate. The color monitoring at this station was originally implemented in order to assess the impacts from Clyde's, the Waynesville and Richland Creek. With the removal of Clyde's discharge, the Division feels that the continued monitoring of color at river mile 62.9 (Fiberville) and river mile 42.6 (Hepco) is sufficient. D The Division received a request to require dioxin isomer monitoring of the octachlorinated dioxin isomers at the internal outfalls, sludge and landfill leachate. The Division also received opposing comments suggesting that the dioxin and furan monitoring proposed in the pre -draft unnecessary. During the previous permit cycle, Blue Ridge Paper was required to monitor 15 isomers of dioxin and furans. Based on a review of this data and the Permit Number: NCO0OO272 public comments received, the Division recommends continued monitoring of 2,3,7,8, TCDD and 2,3,7,8 TCDF on the effluent, sludge, landfill leachate, and the influent to the wastewater treatment plant. Please review the draft permit and fact sheet carefully and submit comments to DENR— D WQ NPDES Unit. This draft permit should not be interpreted as the Division and NPDES Committee's final decision. A 30-day public comment period follows the release of this draft permit and will close at the discretion of the hearing officer and will be announced at the beginning of the public hearing to be held on September 6, 2001. The details on where and when the hearing will be held is listed below: Public Hearing on regarding the Blue Ridge Paper Products Canton Mill's NPDES discharge will be held: September 6, 2001 @ 7:00 pm at the Tuscola High School Auditorium 564 Tuscola School Road Waynesville, North Carolina Haywood County If you have any questions concerning the draft permit for your facility, please call me at (919) 733-5083, extension 508. Sincerely, Michael S. Myers, EI NPDES Unit cc: Central Files NPDES Files Aquatic Toxicology Unit Marion Dee;hake — North Carolina Environmental Management Commission, NPDES Committee Jerry Wilde — Dead Pigeon River Council 402 W. Broadway Newport, Tennessee 37821 Forrest Westall - Asheville Regional Office/Water Quality Section Dan Oakley — North Carolina Attorney General, Environmental Division Keith Haynes - Asheville Regional Office/Water Quality Section Rob Lang — Compliance and Enforcement Unit Diane Reid — Classification and Standards Unit Roosevelt Childress Jr. — Environmental Protection Agency, Region IV Karrie-Jo Shell — Environmental Protection Agency, Region IV Don Anderson — Environmental Protection Agency, Headquarters Mark Perez — Environmental Protection Agency, Headquarters Justin P. Wilson — Deputy to the Governor Tennessee State Capital, Suite G10 Nashville, Tennessee 37243 Paul Davis — Tennessee Division of Water Pollution Control 6th Floor, L&C Annex 401 Church Street Nashville, TN 37243-1534 Charles Lewis Moore — County Executive Cocke County 360 Main Street, East Newport, Tennessee 37821 David Jenkins — American Canoe Association 7432 Alban Station Boulevard, Suite B-232 Springfield, Virginia 22150-2311 Permit Number: NCO000272 Hope Taylor - Clean Water Fund of North Carolina 29 'h Page Ave Asheville, North Carolina 28801 David McKinney — Tennessee Wildlife Resources Ellington Agricultural Center P.O. Box 40747 Nashville, Tennessee 37204 Jonathon E. Burr — Tennessee Division of Water Pollution Control Regional Environmental Assistance Center 2700 Middlebrook Pike, Suite 220 Knoxville, Tennessee 37921 Robert Williams — Blue Ridge Paper 175 Main Street P.O. Box 4000 Canton, North Carolina 28716 Derric Brown —Blue Ridge Paper 175 Main Street P.O. Box 4000 Canton, North Carolina 28716 Patsy R. Williams — Chairman Newport/Cocke County Tourism Council 360 East Main Street Court House Annex, Suite 141 Newport, Tennessee 37821 Dianne Keys—Newport/Cock County Tourism Council 360 East Main Street Court House Annex, Suite 141 Newport, Tennessee 37821 Timothy L. Dockery — Director City of Newport Parks and Recreation Department 433 Prospect Avenue Newport, Tennessee 37821 A. Dean Williams — Coordinator Newport/Cocke County Economic Development Commission 433 Prospect Avenue Newport, Tennessee 37821 Ray Snader—News Director WNPC Radio AM/FM 377 Graham Street Newport, Tennessee 27821 Permit Number: NC0000272 In STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM ons promitlghted an$ adopted by the IN Federal Water Po lubon-Contr6ll Act. as is �erekh authoriz d to di�scliarge waste watgr fyottr`a facility Statute 1143L215.I other lawful standards and is Environmental Management 64mission, Blue Ridge Paper Products Inc. Canton Mill Wastewater Treatment Plant Off Highway 215 Canton Haywood County to receiving waters designated as the Pigeon River in the French Broad River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This permit shall become effective This permit and authorization to discharge shall expire at midnight on November 30, 2006. Signed this day IRA Gregory J. Thorpe, Acting Director Division of Water Quality By Authority of the Environmental Management Commission Permit Number: NC0000272 SUPPLEMENT TO PERMIT COVER SHEET Blue Ridge Paper Products, Inc. is hereby authorized to: Continue operation of a 29.9 MGD wastewater treatment plant for the treatment of wastewater associated with the Blue Paper Products Inc. pulp and paper mill, the Town of Canton's chlorinated domestic wastewater and landfill leachate. The treatment system consists of the following treatment units: • Grit Chamber • Cascade post aeration with oxygen injection • Instream oxygen injection facilities The facility is located at the Blue Ridge Paper Products WWTP, off Highway 215, Canton, Haywood County, and; 2. Discharge treated wastewater from said treatment works at the location specified on the attached map through outfall 001 into the Pigeon River, which is classified C water, in the French Broad River Basin. . RA • Blue Ridge Paper's Outfall French Broad Hydrography " FS V NR PS ►��ys NLnicipal Boundaries 0 County Boundary N A Blue Ridge Paper Products, NC0000272 Haywood County 0.5 0 0.5 1 Miles m Facility Informati Inc. State Grid: E 7 SE USGS Quad: Canton Subbasin: 04-03-05 Permit Number: NC0000272 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge treated industrial, municipal, stormwater and landfill wastewater through outfall(s) 001. Such discharges shall be limited and monitored by the Permittee as specified below: .QEffltient Characteristks —4. e. . EffluenYLimits .: q.. — ; :Monitoring Retautrements', .fi _: Morithly gver`a a 9 Aaily Maximum Measurement Fre uenc 9, y, Sample Type.. ' _._. __ ,,. _ Sample 1 f Location. y Flow 29.9 MGD Continuous Recording I or El BOD, 5-day, 20°C 3205 lb/day 10897 lb/day Daily Composite I, El Total Suspended Residue 12549 lb/day 49560 lb/day Daily Composite I, El NH3-N Daily Composite El AO? 56,9-Wday 2822.2lb/,day, Daily, —Composite. F-r COor' \ \ , \ Dailyl _ Oomp2site Ei Dissolved Oxygaq \ \ ` / /\ Dailyl I Grab I Ei Temperature \ \ Daily I I Grab I El p I I i I / J / / \ \ Daily Grab I El Conductivity I ( I / / \ Dailyl Grab I El Feeal i oliform J ( I 20GN00,mI 4007 100-m \Weekly Grab I El COD I / / \ \ / Weekly I Composite I El Si14erj / J \ \ / / \Qdarteriy I Composite I E( Zinc / \. / / Quarterly Composite I El Total Nitrogen (NO=-N + NO3-N + TKN) Monthly Composite E, Total Phosphorus Monthly Composite El Chronic Toxicity Quarterly Composite E, Cadmium Quarterly Composite El Trichlorophenol 3.0 pg/L Quarterly Composite El Pentachlorophenol 8.9 pg/L Quarterly Composite El Selenium 10.6 pg/L Quarterly Composite El 2,3,7,8 Tetrachloro-dibenzo- p-dioxin10 0.014 pg/L Quarterly Composite I, E, Conductivity Daily Grab Pigeon River Flow Daily Grab Pigeon River Fecal Coliform Weekly Grab Pigeon River Color Variable Grab Pigeon River Temperature Variable Grab Pigeon River Dissolved Oxygen Variable Grab Pigeon River Footnotes: 1. Sample Location: I- Influent, El — Effluent, Pigeon River - Instream sampling as specified in A. (5.) Instream Monitoring Special Condition. �� n 2. AOX monitoring shall be in accordance p —tlt'e S plin 'Plan fo Cluster hle P ame ers da ed- arc 19, 2001) or subsequent modifications approve, by the,)?�'vi icon. AOX datai�Fail�� a sul)mitted on a qu erly basis along with other Effluent Guideline chemical data; e er to AA: ('1!�ffluet%�t Gui\ i e aming Plan pecial Condition. 3. See A. (8.) Color Analysis and Compliancel Si pecia o d tion.4. The daily average effluent dissolved oxyg,n conce tratigr shall n t �ess than 6.O�ngee A. 1 .) Dissolved Oxygen Special Condition. 5. See A. (13.) Temperature Variance Review Special Condition. 6. The pH of the effluent shall not be less than 6.0 nor greater than 9.0 (on the standard units scale). 7. Chronic Toxicity (Ceriodaphnia) at 90% Effluent Concentration: March, June, September, December (see A. (4.) Chronic Toxicity Permit Limit (Quarterly)). Permit Number: NCOOOO272 8. Trichlorophenol and Pentachlorophenol limits and monitoring are provisionally waived since the facility has certified that chlorophenolic biocides are not used at this facility. If the facility changes operations to include chlorophenolic biocide, the Permittee shall notified the Division prior to use and the limits and monitoring requirements shall become immediately effective. 9. If after 18 months selenium has not been detected, the facility may request that the Division review selenium data for possible removal of the limitation. 10. See A. (9.) Dioxin Monitoring Special Condition. 11. See A. (5.) Instream Monitoring Special Condition. See A. (6.) Best Management Practices (BMP) Special Condition. See A. (11.) Town of Canton Inflow and Infiltration Special Condition. Definitions: MGD — Million gallons per ter lb/day Permit Number: NC0000272 . A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning upon the effective date of the permit and lasting until expiration, the discharge of wastewater from the pine bleach plant to the wastewater treatment plant through outfall(s) 002 (E21), shall be limited and monitored by the Permittee as specified below and in A. (7.) Effluent Guideline Sampling Plan Special Condition: Effluent Characteristics' ti LlrilltS-), r Momtoring:°Requi O-in' S2 r' g F ._ l , w Monthly Average Daily Mazlmum h' Measurement * :Frequency u'fa'..,.' Sample Type3 ; Sample . Location Flo Weekly Calculated E2 Chloroform 5.15 lb/day 8.60lb/day Weekly Grab E2 2,3,7,8 Tetrachloro-dibenzo- p- ioxm TCDD). < 10 pg/L Monthly Composite E2 1 i 2, ,7,8-Tetrachloro liibenzo- p 4ua! (TCDF) 1 31.9 p r t \ \Monthly rColrtppsire =E3 r Trichlbrosyringol , ;:` f /k 2.5 µghLs �' Monthly Composite E# 3,4,5-�richlorocate6hol I l < 5.0 µW \M nthly o`C mpostfe E 3, ,6-' richlorocatechol i —� ` < 5.0,µ dVthly I omposi a E} 3,j,5-Trichloroguaiac9l I N < 2.1µgFb— odthly I I Composite Ej 3,4,6-�richloroguziacol I . \< 2S µ Mon6lI Composite E}g 4,N,6-Trichloroguaiacol I 2.5 � g/L Monthly I Composite El I 2,4,5-Trichlorophenol < 2.5 µg/L5 Monthly Composite E2 2,4,6-Trichlorophenol < 2.5 µg/LS Monthly Composite E2 Tetrachlorocatechol < 5.0 µg/L5 Monthly Composite E2 Tetrachloroguaiacol < 5.0 µg/L5 Monthly Composite E2 2,3,4,6-Tetrachlorophenol < 2.5 pg/L' Monthly Composite E2 Pentachlorophenol < 5.0 µg/L5 Monthly Composite E2 Footnotes: 1. Sample Location: E2—Effluent is composed of Bleach Plant Effluent -acid (acid sewer collected from tap installed on filtrate pump from CI02 bleaching stage D-100 and from tap installed on filtrate pump from C102 bleaching stage D-2) and Bleach Plant Effluent -alkaline (alkaline sewer collected from tap installed on filtrate pump from alkaline extraction stage E.). See A. (7.) Effluent Guideline Sampling Plan Special Condition 2. Monitoring and flow calculations shall be in accordance with the "Sampling Plan for Cluster Rule Parameters" (dated March 19, 2001) or subsequent modifications approved by the Division. Chemical results for Effluent Guideline parameters (Internal Outfall 002 parameters +internal Outfall 003 parameters + AOX from Outfall 001) shall be reported on a quarterly basis or more frequently; refer to A. (7.) Effluent Guideline Sampling Plan Special Condition. 3. Sample Type: Calculated- calculate separate flows for alkaline and acid sewers by water balance, and report total bleach plant flow (acid + alkaline wastestreams) in DMRs. Grab- collect separate grab samples every 4- hours for 24-hour period from both the acid-anda aline streams which w}71 then be-composit d-separatel by the lab, and analyzed as separate 24-hr coin sit % a and alkalmesa Ipl€sl Coin site= colleect3e azat7grab samples every 4 hours for 24-hour period r-?in0oadpin oe laud and alkaline/s{ri a�ris, then prepare and alyze a single flow -proportioned composite of the al,cathie-was%sheari{/ \ 4. For compliance purposes, the permittee musa otai clilo oform masloading ba' sed on addih n of separate acid and alkaline chloroform mass P5. Limits are based on Minimum Levels (Ml.) in J CFR 4,0)�\ I Definitions: lb/day — Pounds per day µg/L — Micrograms per liter pg/L — Picograms per liter Permit Number: NCO000272 A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning upon the effective date of the permit and lasting until expiration, the discharge of wastewater from the hardwood bleach plant to the wastewater treatment plant through outfall(s) 003 (E31), shall be limited and monitored by the Permittee as specified below and in A. (7.) Effluent Guideline Sampling Plan Special Condition: Effluent Charaeteristicsj "e Llmlts' ^ >_ Mon tocfng'`Requfrements_ = Monthly Average Daily Average _Measurement' Frequency SampleType3 £Sample;, Locatipti - '.. Flow Weekly Calculated E3 Chloroform 7.14lb/day 11.93lb/day Weekly Grab E3 2,3,7,8 Tetrachloro-dibenzo- p-gloxm DD), F � < 10 pg/L r Monthly 1 Composite E3 � � 2, ,7,8-Tetrachl ro-Uibenzo- p-Ir (TCDF)1 I 31.9 pg/I/ / \ \Monthly ( �omp-sl —Ej I I Tr ichlbrosyringol 1 4 I / / k 2.5 µWI i4onthly I I Composite E# 3,4,5-richlorocatedhol I /< 5.0 µg/Lt Mpnthly Uomposita E# I 3,4,,6-xrichlorocatedhoj I —\ ` < 5.0 µg dnthly I ompost a E# I 3,4,5-�richloroguaiacol I < 2.�'µ otithly I I Composite Et{ 3,1,6,�richlorogu5iacol �< /I5 µg/L Monthly I , I Composite E# I 4,5�,6-Trichloroguaiacol j2.Srg/L Mo�tthly I Composite E# I 2,4,5-Trichlorophenol < 2.5 µg/L' Monthly Composite E3 2,4,6-Trichlorophenol < 2.5 µg/L' Monthly Composite E3 Tetrachlorocatechol < 5.0 µg/L' Monthly Composite E3 Tetrachloroguaiacol < .5.0 µg/L' Monthly Composite E3 2,3,4,6-Tetrachlorophenol < 2.5 µg/L' Monthly Composite E3 Pentachlorophenol < 5.0 µg/L' Monthly Composite E3 701 Footnotes: 1. Sample Location: E3— Effluent is composed of Bleach Plant Effluent -acid (acid sewer collected from tap installed on filtrate pump from C102 bleaching stage D-100) and Bleach Plant Effluent -alkaline (alkaline sewer collected from tap installed on filtrate pump from alkaline extraction stage E.). See A. (7.) Effluent Guideline Sampling Plan Special Condition. 2. Monitoring and flow calculations shall be in accordance with the "Sampling Plan for Cluster Rule Parameters" (dated March 19, 2001) or subsequent modifications approved by the Division. Chemical results for Effluent Guideline parameters (Internal Outfall 002 parameters + internal Outfall 003 parameters + AOX from Outfall 001) shall be reported on a quarterly basis or more frequently; refer to A. (7.) Effluent Guideline Sampling Plan Special Condition. 3. Sample Type: Calculated- calculate separate flows for alkaline and acid sewers by water balance, and report total bleach plant flow (acid + alkaline wastestreams) in DMRs. Grab- collect separate grab samples every 4- hours for 24-hour period from both the acid -and -alkaline streams which will then bc-composited-separately by the lab, and analyzed as separate 24-hr coin�jositei 'd anc('allCal e ampl�sl Composite= collectse rate grab samples every 4 hours for 24-hour periodQm bo a cid and j aline/s arts, tl}e prepare and p alyze a single flow -proportioned composite of the abid and 1'ca] inewastes�re r \ 4. For compliance purposes, the permit ze m t reporrt t e o'-al ctt o ofo load' g based on add [i n of separate acid and alkaline chloroform m oadin�es l i 5. Limits are based on Minimum Levels (Mi spectfiev ( CFR�0,OL�\ I Definitions: lb/day — Pounds per day µg/L — Micrograms per liter pg/L — Picograms per liter Permit Number: NCOOOO272 A. (4.) CHRONIC TOXICITY PERMIT LIMIT (QRTRLY) The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia duhia at an effluent concentration of 90%. The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed during the months of March, June, September, December. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. �� The c' hronic value for multiple n' cemration tests will be dEt mined using a geome ` ' mn£Yh 'ghest_J con�Icentration n g�ro detect ble impairm�ent�f reproduction o)�survival and the lowest concentration that does hai e a detectable pa erit o reproduction on survival/The ref ition of' electable impairment," co lee ion m thods, exposureregimes, anfurther statistical methods � e specified in the `` orthCarolina Phase II Chronic Whole Effluent Toxicity Test Pioc�e are'r(Revised-Febivary 1998) dr subsecuent versions. I testing Tesdlts required as past of, this permit condition will,be entered on the Effluent Discharg6 Form ( I) for t e months in ve tch tuts } ere�perfobrmed using the parameter code TGPIB 'or the ults.and HP3B foi the Chronic Va pe. Ad. itiond ally, DWQ Vorrit AT-3 (original) is to be sent to the Attention: North Carolina Division of Water Quality Environmental Sciences Branch 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address cited above. Should the permittee fail to monitor duri required during the following month. Should any test data from this monitorin; Quality indicate potential impacts to the alternate monitoring requirements or lim modified Water NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. Permit Number: NC0000272 A. (5.) INSTREAM MONITORING SPECIAL CONDITION Stream Mile Location Description Parameter Frequency Designation Marker waste treatment plant outfall D.O. Daily (prior to mixing with the Conductivity Daily discharge) Color' 2/Week Flow Daily Fecal coliform Weekly DNl 62.9 Pigeon River at Fiberville Bridge Temperature Daily D.O. Daily Conductivity Daily Color I 2/Week DN2' 57.7 Pi eon River Above Clyde Temperature Dai D.O. Daily ,' DN3 \ 55\5 Pigeon R}ves Below Clydc\ See Footnote 3 See Footnote 3 DN4 3.5 Pigeon River at NCS71625` See IT I bridge ) .) \ ` othote 3 See Fogto'te I I ` 3 DN5 42.6I —Piged—n Ri dr at Hep%co ( \ \Temperature D.O. Color Flown i Weekl Weekl 2)Wee F Daily Waterville RgservoiV' See Footnote 4 Annually DN�6.0 U Pigeon Ri�er prior tb mixing with Color j Variableu Big Creek BC —26.0 Mouth of Big Creek prior to Color Variable mixing with the Pigeon River DN7 24.7 Pigeon River at Browns Bridge Temperature Weekly (— NC/TN State Line) D.O. Weekly Color Variables All instream samples shall be grab samples. 1. Color (See A. (8.) Color Analysis and Compliance Special Condition) All instream samples collected shall be representative of the Pigeon River and Big Creek, respectively. Both true and apparent color shall be monitored using the methods specified in A. (8.) Color Analysis and Compliance Special Condition. Samples shall be collected at stations DN6, BC, and DN7 only when at least one generator at CP&L is in operation and releasing water to the Pigeon River. 2. Flow monitoring is necessary, as specified above, for the True Color calculation stipulated in A. (8.) Color Analysis and Compliance Special Condition. 3. Dissolved Oxygen. The average daily dissolved oxygen concentration measured at River Mile 62.9 (DNI), 57.7 (DN2), shall not be less than 5.0 mg/1 and the instantaneous minimum dissolved oxygen concentration shall not be less than 4.0 mg/1 (See A. (M) Dissolved Oxygen Special Condition). If the dissolved oxygen drops below 5.0 g/1._ tati n5 — 7— t en mom oring h;Lb�equire at tation; 55.5 (DN3) and 53.5 (DN4). � 4. See A. (12.) Waterville Reservoir Sam ling Spec ial IEGndi"t n. `\ 5. Sampling is required 2/week during t}},,e summer a d on per we�l� unng thewmr. Sum er is defined as the period from April 1 th to 0 c obnler� 31, wh le winis� of] ed as Novem� er 1 through March 31. Permit Number: NC0000272 A. (6.) BEST MANAGEMENT PRACTICES (BMP) SPECIAL CONDITION The permittee must implement the BMPs specified in Section A below. The primary BMP objective is to prevent leaks and spills of spent pulping liquors, soap, and turpentine. A secondary objective is to contain, collect, and recover at the immediate process area, or otherwise control, those leaks, spills, and intentional diversions of spent pulping liquor, soap, and turpentine that do occur. BMPs must be developed according to best engineering practices and must be implemented in a manner that takes into account the specific circumstances at the mill. Section A. BMP Implementation Requirements 1. The permittee must return spilled or diverted spent pulping liquors, soap, and turpentine to the process to the maximum extent practicable as determined by the mill, recover such materials outside the process, or discharge spilled or diverted material at a rate that does not disrupt the receiving 2. The-permit�ee'{nust es tablish­a-prog�ain to identify And�repair leaking -equipment items —This ograin must include}(r Regbla�r daily visual inspections of rocess area if h equipment items in sp nt i t I I i. 7 u �I l pulping liquo ,soap, fn i turpentin�se� ice; (iiImedi ; e repai� o� leaking equipment it m , when possible. Leaking equipment -items tlt at canno b repaired durin normal -operations muss b� identified, te4orarylmeans-for mitigating thf leaks muAe pro ided and-theleaking equipment items repaired during the next maintenance g to e; iii Ideetificatidn of conditions underlwlich production '(VJ11 die curtailed or ha k ko repair eaking equipment items or to prevent pulping liquor, soap,and-t rpentine teal:s and spills- and iv),A means ford racking iepairs over time to idcnt fy those equi _n(Lat.items where upgrade or r� l�a�cement may be warranted based on frequency and seierity of leaks, spills, or failures. 3. The permittee must operate continuous, automatic monitoring systems that the mill determines are necessary to detect and control leaks, spills, and intentional diversions of spent pulping liquor, soap, and turpentine. These monitoring systems should be integrated with the mill process control system and may include, e.g., high level monitors and alarms on storage tanks; process area conductivity (or pH) monitors and alarms; and process area sewer, process wastewater, and wastewater treatment plant conductivity (or pH) monitors and alarms. 4. The permittee must establish a program of initial and refresher training of operators, maintenance personnel, and other technical and supervisory personnel who have responsibility for operating, maintaining, or supervising the operation and maintenance of equipment items in spent pulping liquor, soap, and turpentine service. The refresher training must be conducted at least annually and the training program must be documented. 5. The permittee must prepare a brief report that evaluates each spill of spent pulping liquor, soap, or turpentine that is not contained at the immediate process area and any intentional diversion of spent pulping liquor, soap, or turpentine that is not contained at the immediate process area. The report must describe the equipment items involved, the circumstances leading to the incident, the effectiveness of the corrective actions taken to contain and recover the spill or intentional diversion, and plans to develop changes to equipment and operating and maintenance practices as necessary to prevent recurrence. Discussion of the teportst�ust e-included as part\of the; annual-refreshertr_a_�ning. 6. The permittee must establish a program to rev any planned modifications o theme pulpind chemical recovery facilities and any c� stmcti�rj activitiesiolthe1p�ilp�ir�g and chl emical re very areas before these activities commence. Th urpos f �uch- e iew is tQpleventleaks-a�i d spil s of spent pulping liquor, soap, and turpentine d ring t) la ed mod�fic�tions and to gsure that c struction and supervisory personnel are aware c ossi liq r diverSt s and o erequirement t revent leaks and spills of spent pulping liquors, soap, and urpentine duffing construction. 7. The permittee must install and maintain secondary containment (i.e., containment constructed of materials impervious to pulping liquors) for spent pulping liquor bulk storage tanks equivalent to the . volume of the largest tank plus sufficient freeboard for precipitation. An annual tank integrity testing program, if coupled with other containment or diversion structures, may bd substituted for secondary containment for spent pulping liquor bulk storage tanks. Permit Number: NCOOOO272 8. The permittee must install and maintain secondary containment for turpentine bulk storage tanks. 9. The permittee must install and maintain curbing, diking or other means of isolating soap and turpentine processing and loading areas from the wastewater treatment facilities. 10. The permittee must conduct wastewater monitoring to detect leaks and spills, to track the effectiveness of the BMPs, and to detect trends in spent pulping liquor losses. Such monitoring must be performed in accordance with Section E. Section B. BMP Plan Requirements 1. The permittee must prepare and implement a BMP Plan. The BMP Plan must be based on a detailed engineering review as described in this section. The BMP Plan must specify the procedures and the practices required for the mill to meet the requirements of Section A, the construction the mill determines is necessary to meet those requirements including a schedule for such construction, and the monitoring program (including the statistically derived action levels that will be used to meet the re uirementssof Section E. The BMp lan also m st s ecify the eriod of time that the mill d termmes the�ctio � lej'elr s establishe under Secf� n may be xceeded ut trigger n the rgspo� ec it-ed n Section E. 2. Tpe permitteelmust c6ii uct a detailed/8ngineermprev\iew of the �ul'pinQ and chemical re Iov� ry operations --including but not limi�d �o process gquipr ent, storap tanks, pipelines and pum)mg systems, loading and �unlo�ac i'ng�facities, and other-appurttnant puling and chemical recQve�y equipment items in spe�t pulping�liq or, soap,,and-turpe�tige se;� ice --for the purpose of cjetermining tl a magnitude and routing of poregtia leaks, spills, and i to tional diversions of spent pu p�t{g li r ,soap an tur�eritine during he olfowing periods f �per�ation: (i) Process start-ups and shut owns; (iiyMaintenance; (in) Production -grade changes; iv}Storm or other weather events, (v) Power failures; and (vi) Normal operations. 3. As part of the engineering review, the permittee must determine whether existing spent pulping liquor containment facilities are of adequate capacity for collection and storage of anticipated intentional liquor diversions with sufficient contingency for collection and containment of spills. The engineering review must also consider: (i) The need for continuous, automatic monitoring systems to detect and control leaks and spills of spent pulping liquor, soap, and turpentine; (ii) The need for process wastewater diversion facilities to protect end -of -pipe wastewater treatment facilities from adverse effects of spills and diversions of spent pulping liquors, soap, and turpentine; (iii) The potential for contamination of storm water from the immediate process areas; and (iv) The extent to which segregation and/or collection and treatment of contaminated storm water from the immediate process areas is appropriate. 4. The permittee must amend its BMP Plan whenever there is a change in mill design, construction, operation, or maintenance that materially affects the potential for leaks or spills of spent pulping liquor, turpentine, or soap from the immediate process areas. S. The permittee must complete a review and evaluation of the BMP Plan five years after the first BMP Plan is prepared and, except as provided in Section BA., once every five years thereafter. As a result of this review and evaluation, the permittee must amend the BMP Plan within three months of the review if the mill determines that any new or modified managementpractices and engineered controls are necessary to reduce significantly t liklike��ood o =spent ulping ai nor, Opp, -an rpentne eaks, spills or intentional diversions from t ih mined t rocess a eas /S�u ding a schedule for implementation of such practices and ¢ntrols.) J / / 6. The BMP Plan, and any amendments h reto, mist b� re 16 ed yrtlr&s is cc mcal man ger at the mill and approved and signed by the rii I ma a�er. my p rson Wing he MP Plan or iIs amendments must certify to the Divis onsmder per a ty of l&W Lt the BMP, lan (or its amendments) has been prepared in accordance with good engineering practices and in accordance with this regulation. The permittee is not required to obtain approval from the Division of the BMP Plan or any amendments thereto. Permit Number: NC0000272 Section C. BMP Recordkeeping Requirements 1. The permittee must maintain on its premises a complete copy of the current BMP Plan and the records specified in Section C.2 and must make such BMP Plan and records available to the Division for review upon request. 2. The permittee must maintain the following records for three years from the date they are created: (i) Records tracking the repairs performed in accordance with the repair program described in Section A; (ii) Records of initial and refresher training conducted -in accordance with Section A; (iii) Reports prepared in accordance with Section A; and (iv) Records of monitoring required by Sections A and E. Section D. Establishment of Wastewater Treatment System Influent Action Levels 1. The permittee must conduct a monitoring program per Section D.2, for the purpose of defining wastewater treatmentsysteminfluent characteristics or action levels , described in Section D.3 that will trigger requirements to tmhate investigation on BMP effectiveness and to to a corrective action. 2. The ermtttee must emp oy—the following procedu 4s iil order to a Fe lop the action —level s re uired by S ction D: Monitoring oarameters. The ne ittee must /ollect \2-hour omoosite sarr Dles and anal .ze the samples fora measur'�organic content/(e.'g , Ehehtical Ox�ge' errand (COD) or {otal Organic Carboni OC)). Alt'emutively,t�te�mill mayluse�a measre related to spent ppteing liquor losse�easured continuously na'•average over 24 hours (e. . pecific conductivity r olor). tutoring locations. The permittee must/conduct monitoring a the point influent en ersl the —wastevvvater treatment system. For-thie-purposes of this regIiirement, the permittee =33 select alternate monitoring point(s) in order to isolate possible sources of spent pulping liquor, soap, or turpentine from other possible sources of organic wastewaters that are tributary to the wastewater treatment facilities (e.g., bleach plants, paper machines and secondary fiber operations). 3. By the permit effective date, the permittee must complete an initial six-month monitoring program using the procedures specified in Section D and must establish initial action levels based on the results of that program. A wastewater treatment influent action level is a statistically determined pollutant loading determined by a statistical analysis of six months of daily measurements. The action levels must consist of a lower action level, which if exceeded will trigger the investigation requirements described in Section E, and an upper action level, which if exceeded will trigger the corrective action requirements described in Section E. 4. By January 15, 2002, the permittee must complete a second six-month monitoring program using the procedures specified in Section D and must establish revised action levels based on the results of that program. The initial action levels shall remain in effect until replaced by revised action levels. 5. Action levels developed under this Section must be revised using six months of monitoring data after any change in mill design, construction, operation, or maintenance that materially affects the potential for leaks or spills of spent pulping liquor, soap, or turpentine from the immediate process areas. Lion E. BMP Monitoring, Corrective ction a d Re I o�rti�e uirements The permittee must codduct daily mot'i oring f, h 3nfluen o th1�4 \s\�ewa ertreatment s rtemin accordance with the procedures descnb d in S�c io otthe pddSuse'o�detecti�eaks nh spills, tracking the effectiveness of the BMP$, Hai nd detects tren�st�n p�rentt ppulping tquor losses Whenever monitoring results exceed thelowetacti level %r,e perio�l_ofsune specifie .ih the BMP Plan, the permittee must conduct an investigation to determine the cause of such exceedance. Whenever monitoring results exceed the upper action level for the period of time specified in the BMP Plan, the permittee must complete corrective action to bring the wastewater treatment system influent mass loading below the lower action level as soon as practicable. Although exceedances of the action levels will not constitute violations of an NPDES permit, failure to take the actions required by Section E.2 as soon as practicable will be a permit violation. Permit Number: NC0000272 4. The permittee must report to the Division the results of the daily monitoring conducted pursuant to Section E.1. Such reports must include a summary of the monitoring results, the number and dates of exceedances of the applicable action levels, and brief descriptions of any corrective actions taken to respond to such exceedances. Submission of such reports shall be annually, by March 31" of the following year. Section F. BMP Compliance Deadlines The permittee is subject to the following BMP deadlines: • Prepare BMP Plans and certify to the Division that the BMP Plan has been prepared in accordance with this regulation not later than the permit effective date. • Implement all BMPs specified in Section A that do not require the construction of containment or diversion structures or the installation of monitoring and alarm systems not later than the permit effective date. • Establish4nitial action levels req)tired by SecfionD not later than the permit a fective date. r--� Commence�pper�tlo�t of any new or upgrade c\nt nuous, au omatic monitoring systems that the mill detemroes to be necessaryiinder Section�S (other than ose associated with construction of containmentlor dive Sion structure)) not later (han the permit�effective date. Complete lco�istniction and commence operation o�ar� spen pulping liquor, collection, containment,diversion, or-ot�r facilities; including an associated continuous monitoring s stems a essazy t� fully ii pl� nt BMFsspeei£ \ p Se �tion A not later than the i edit y \b effective da�e. ESta15 is revised action levels requ red b/Section D ads s on as �ossible after fully implementing 11 the B'MPs specified -in Section A�bu�ioC later than January 15; 2002. CJ Submit Annual Reports required by Section EA to the Division by March 31` of the following year. Section G. BMP Definitions 1. Action Level: A daily pollutant loading that when exceeded triggers investigative or corrective action. Mills determine action levels by a statistical analysis of six months of daily measurements collected at the mill. For example, the lower action level may be the 75th percentile of the running seven-day averages (that value exceeded by 25 percent of the running seven-day averages) and the upper action level may be the 90th percentile of the running seven-day averages (that value exceeded by 10 percent of the running seven-day averages). 2. Division: North Carolina DENR, Division of Water Quality, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617. 3. Equipment Items in Spent Pulping Liquor, Soap, and Turpentine Service: Any process vessel, storage tank, pumping system, evaporator, heat exchanger, recovery furnace or boiler, pipeline, valve, fitting, or other device that contains, processes, transports, or comes into contact with spent pulping liquor, soap, or turpentine. Sometimes referred to as "equipment items." 4. Immediate Process Area: The location at the mill where pulping, screening knotting, pip washing, pulping liquor concentration, pulping liquor prgces i g, a�� hem( as recov facilities -ark locAted, generally the battery limits of the afor entioiled r cesse$. 'Imm• etlihte prlo�es: area" ineliides spent pulping liquor storage and spill contr I anks I tAdLLLLLLat they ill, i �et�iei or bt the are 1 �clated in the immediate process area. 5. Intentional Diversion: The planned rerr�� v�I of s e I t pu�lpi I 'uor so c tu' rpentine fr� equipment items in spent pulping liquor soap or trirpe' ntinesede by the;mill for any puip�ose including, but not limited to, maintenance, grade changes, or process shutdowns. 6. Mill: The owner or operator of a direct or indirect discharging pulp, paper, or paperboard manufacturing facility subject to this section. 7. Senior Technical Manager: The person designated by the mill manager to review the BMP Plan. The senior technical manager shall be the chief engineer at the mill, the manager of pulping and chemical Permit Number: NC0000272 recovery operations, or other such responsible person designated by the mill manager who has knowledge of and responsibility for pulping and chemical recovery operations. 8. Soap: The product of reaction between the alkali in kraft pulping liquor and fatty acid portions of the wood, which precipitate out when water is evaporated from the spent pulping liquor. 9. Spent Pulping Liquor: For kraft and soda mills "spent pulping liquor" means black liquor that is used, generated, stored, or processed at any point in the pulping and chemical recovery processes. 10. Turpentine: A mixture of terpenes, principally pinene, obtained by the steam distillation of pine gum recovered from the condensation of digester relief gases from the cooking of softwoods by the kraft pulping process. Sometimes referred to as sulfate turpentine. Permit Number: NC0000272 A. (7.) EFFLUENT GUIDELINE SAMPLING PLAN SPECIAL CONDITION The bleach plant effluent samples (Outfalls 002 and 003) shall be analyzed for 2,3,7,8-TCDD in accordance with EPA Method 1613. A single sample, from each of the bleach plant effluents, may be analyzed to determine compliance with the daily maximum effluent limitation. The bleach plant effluent samples (Outfall 002 and 003) shall be analyzed for the 12 chlorinated phenolic compounds in accordance with EPA Method 1653. A single sample, from each of the bleach plant effluents, may be analyzed to determine compliance with the daily maximum effluent limitation. The Minimum Levels for each of the 12 chlorinated compounds are the same as the Daily Maximum concentrations listed on the effluent pages for the respective outfall(s). The final wastewater treatment plant effluent sample (Outfall 001) shall be analyzed for AOX in accordance with EPA Method 1650, or subsequent test methods approved by the Division. nittee-mna}\reque§t future-manitoriing modificatt ns to the Effluent -Guideline requiren g 1) use,of ECF certification iAeu of moni&ring 1?r chloro form in the bleach plant a s) 002 and 003) wh�n this rubs promulgated by EPA; 2) demonstrating compliance collectedIlesls frequently-tha every four hours; 3),,usinQ aut mated-comoosite volatile tor chloroform sampling; land-4) u \ 9 utomated/co' posit sdmpler for-ehlorephenolic, 2,3, ,8'', an 2�3,7,8 TCDFi sampling. Such tur\Cj'� requests will be evalu ted in accordance with 15A Ct The 14. � �l2 \ I The flow calcpla ions for internal Outfal 2 nd 003 shall not,be subject to accuracy requLrer, specified under Part II, Section D.3. This exclusion is similar to that provided for pump log flow calculations. Chemical data for Effluent Guideline parameters (Outfall(s) 002 and 063 parameters + AOX from Outfall 001) shall be submitted to the Division on a quarterly basis or more frequently (January- March, April - June, July- September, October -December). Quarterly submissions shall be due 60 days following the last day of each quarter (Due dates = May 31, August 31, November 30, and February 28). Chemical data shall be submitted on Division -approved DMR forms, with a separate form provided for each month. Permit Number: NC0000272 A. (8.) REQUIREMENTS FOR COLOR ANALYSIS AND COMPLIANCE SPECIAL CONDITION 1. The average daily discharge of true color for each calendar month shall not exceed 55,000 pounds per day. The annual average effluent true color loading shall not exceed 48,000 pounds per day. For the purpose of this permit/variance only, "pounds of true color" is calculated by the following equation: Effluent Flow (mgd) x Effluent True Color Level (Platinum Cobalt Units) x 8.34. 2. All samples collected for color analysis and for use in the above calculation shall be measured and reported as true color and apparent color using the procedure referenced in FR 39 430.11 (b) (May 29, 1974) - true and apparent color or as amended by the EPA. 3. ul e�2idgePaper has a rea y egu`n he process o�entifying anfl imp ementing pa optimization measures t' Ii clt cah-be taken to fucfhdr reduce colo disehfi ges Prom tl permittee is irected to continue ev +lusting mi1L/ople%att4ons with he goal of fully ide opportunities €onpreventing and controlling measl{rable black liq, or leaks and spills than in preparation for planned odtages to maximize capture of tank clean -out Waste and ➢.eduction of cleanivater that contimi6lIsly runs into sewers t6 prevent dilution of smilller spills and facilitate recovery of highly colored wastewaters; and Improvement in the equipment used for handling of knot rejects to prevent black liquor leaks into the recovery sumps. 4. By October 1, 2003, Blue Ridge Paper shall submit to the North Carolina Division of Water Quality a report including a statistical analysis of the Blue Ridge Paper's monthly average color discharge, mill performance as related to color, all available data necessary to derive the lowest achievable monthly average color loading limits. By November 1, 2003, the Division of Water Quality (in consultation with the Technology Review Workgroup) shall recommend, considering the statistical analysis report submitted by the permittee and the demonstrated performance of the mill, the lowest achievable monthly average color loading effluent limitations. The monthly average effluent limit and the flow criteria used for instream color determined to be achievable shall become effective on December 1, 2003, by written notification from the Director. 5. Beginning December 1, 2003, the annual average discharge of true color shall not exceed 42,000 pounds per day and the monthly average color shall not exceed the limit established according to Special Condition A.(8.) Paragraph 4. However, if by October 1, 2003, the Division -of Water -Quality (DWR), in consultation with-t e nr._..— �—.-1 Technology Review Committee, and the NPD`E1S ommitte� agre4 that therelare overwhelming technical, economic, or operational barriers to th ermittee� abi�ity to�attain the2bove-staied color loading limits, DWQ shall recommenJl o the P S C- nfmittee, alternate interinr�limits tc become effective December 1, 2003. At that tim�, DWlshal recom(rtetid a new effective date for achieving an annual average color loading limit 4t 2-,O potit5ds per`&,�Ahese recommendations 4 all be based on what DWQ concludes Blue Ridge Paper can reasonably achieve, giving consideration to the actual demonstrated color levels discharged and process optimizations implemented pursuant to ' The Technology Review Workgroup shall act in an advisory role to the Nortt Carolina Division of Water Quality, and NC DWQ shall consult with Technology Review Workgroup prior to mig any decisions regarding color reduction activities at the Canton Mill. Permit Number: NC0000272 Special Condition A. (8.) Paragraph 3. Based on DWQ's recommendations, the NPDES Committee will determine the alternate interim limits to become effective on December 1, 2003, and the new effective date for achieving an annual average color loading limit of 42,000 pounds per day. After the NPDES Committee's final decision, the NPDES Permit will be modified in accordance with North Carolina's permitting process. 6. The permittee shall submit to the Division of Water Quality, the Technology Review Workgroup and the NPDES Committee by December 1, 2003, a report on the feasibility of achieving a target annual average color loading within the range of 34,000 pounds per day and 39,000 pounds per day. This report shall include identified process improvements and any other actions that would result in additional color reductions, actions taken by the permittee to reduce color loading (since permit issuance), and the technical, economic, and operational feasibility of implementing the identified process improvements on a continuous or intermittent basis, in order to achieve a target annual avera a within the range of 34 000 pounds per day and 39,000 pounds _1?er dav_The report shall identi speci e economic and impll entation issues ssociated iw th the im royeinents. The re ort shall also protect expected adds i not al c``olor reduciiori� f�Qr each tecnolog}�e evaluated ul ted and max mum color reducti n Possible using the iden `fied tec(indlo ids The re ort shall also include a pro osed schedule for iinp�ementation of pr9Ees5 impro ementss re uired t a hieve an effluent color loading Wit in the targeted range. The pe tt�ee shallj�, gvide �hig evaluaiion/report, together with ar updated report on the ieslts of o�gomg aadditionaf planned col r red�ction a h ties, to the Division of Water Quality, the Technology Review Workg oup aad- e IPDES Committee. By Februar} 1,200 DWQ (ink nsryltation tiith the Te�ehnology Review Workgroup) 3hall approve or modify Mule Ridge Pap�i recommended an for achieving —34,000 — 39,b0O-, ouu per day target annua, average. If the limits determined to be achievable, pursuant to Special Condition A.(8.) Paragraph 7, by the Division of Water Quality (in consultation with the Technology Review Workgroup) are not within the target range, the Permit shall be modified in accordance with North Carolina's permitting process to reflect those limits. By December 1, 2005, Blue Ridge Paper shall submit as related to the implementation of the process improvements evaluated according to Special Condition A. (8.) Paragraph 6, a statistical analysis of Blue Ridge Paper's effluent and a feasibility report on color reduction technologies associated with the Chloride Removal Process. This report shall include a statistical analysis of the Blue Ridge Paper's monthly average and annual average color discharge, mill performance as related to color, all available data necessary to derive the lowest achievable annual average and monthly average color loading limits. By January 1, 2006, the Division of Water Quality (in consultation with the Technology Review Workgroup) shall recommend, considering the statistical analysis report submitted by the permittee and the demonstrated performance of the mill, the lowest achievable annual average and monthly average color loading effluent limitations. If the limits determined to be achievable are within the target range established pursuant to Special Condition A.(8.) Paragraph 6, the limits shall become effective on March 1, 2006, by written notification from the Director. If the limits determined to be achievable by the Division of Water Quality_ (in consultation with the Technology Review Workgroup) are Jo!t...wit i th targ ge, the ermit hale 5e m�fied in accordance with North Carolina's perr�1 ttinQIIr cells to refl'e& those�l wits. I This report also shall evaluate and rep6A of n coygr r'eductio teclni&ogie�asjoci�'ated with t�e Chloride Removal Process (CRP) wastestream.l he_CJiP analysis I cop ec ntrate on the technical, economic, and operational feasibility f._imple�iient4n9 the itleh fied tee tnb(a�ies. The report shall identify specific economic and implementation issues associated with the improvements. The report shall also project expected additional color reduction for each technology evaluated and maximum color reduction possible using the identified technologies. The Division of Water Quality (in consultation with the Technology Review Workgroup) shall evaluate the feasibility of implementing identified technologies for further color reduction and shall submit to the NPDES Committee by Permit Number: NC0000272 December 1, 2005, DWQ's recommendations regarding color reductions associated with the treatment of the CRP wastestream. 8. By March 1, 2006, the permittee shall submit a report to Division of Water Quality, the Technology Review Workgroup and the NPDES Committee on the comparative evaluation of the color reduction efforts as part of the Variance review process (Triennial Review of North Carolina's Water Quality Standards). This report shall also include an evaluation of color in the Pigeon River at the Fiberville Bridge, and an evaluation on the feasibility of complying with North Carolina's Color Standard. 9. The 1997 Settlement Agreement contained provisions to limit color in the Pigeon River at the Hepco USGS gauge station. The new effluent limits in this permit are more stringent than the provisions in the 1997 Permit and Color Variance and will result in reduced color levels in the Pigeon River. It is possible to calculate the monthly flow at the Canton gage station above which instream color at the Fiberville Bridge will not exceed 50 true color units. Using the 55 0,00 pounds per day monthly erage true olor loadin limit implemented on the effective date of the permit) the flow at the I mton Gage s ation, �w ich� vie for color legs han 50 true Dolor units at the Fbervil e Bridge 171.8 MUD. � herefo e, the monthlylaverage/coioi. m�the Pigeon rver at the Fiberville Bridge will less than 54 true c�lo units whenever the monthly�average flow (at the Canton gage station) is eater than 171.E MGD. i \ \ ( I I The governing flow driterion for't�ruccolor at Canton -is 5�8.h,MGD (30Q2 stream flow). Thelflow establishhed4upuant'to §pecial Condition A. (8'.) Paragraph`9, islgreater than this 30Q2 stream flow, ttterrefore, for flows less than the 171,8 � dl) at the Canton Uage tation but greater than 1�9313 MGD (30Q2-flo�t the Hepco gage station,—th�-Tnonthly average-coloriir the Pigeon River at Hepco will be less than 50 true color units. 11. Beginning December 1, 2003, the monthly average color in the Pigeon River at the Fiberville Bridge will be less than 5.0 true color units whenever the flow at Canton is greater than the flow established using the following equation and based on the monthly average effluent limit established per Special Condition A.(8.) Paragraph 4: (Monthlykerage_Efflient—Color Limitjb/day-12468.3) Flow_at_Ca�ton_USGSiNIGD)= — +31.6+2.4 308.58 For flows at the Canton Gage station .less than the flow established here but greater than 193.3 MGD at the Hepco gage station, the monthly average color in the Pigeon River at Hepco will be less than 50 true color units. 12. The potential exist that there could still be periods of time corresponding to periods of lower flow in the river, when color at Fiberville might exceed 50 true color units. Therefore, the permittee shall continue to implement the approved Low Flow Contingency Plan for mitigating the occurrence and degree of these potential exceedences.,_. ,� 13. The permittee shall not increase the mil I's pu unless the permittee can demonstrate ��hat the color loading. In addition, increasing the mil in accordance with North Carolina's DES, g t g term of this permit, a( ie`ve -while reducing in require per It revision 14. The NPDES Permit shall be subject to reopening in order to modify the color requirements based upon the following and in association with the required triennial reviews: Any breakthrough in color removal technologies. Such breakthroughs shall be brought to the NPDES Committee for consideration, by Blue Ridge Paper and the Division of Water Quality, as soon as they are discovered. Permit Number: NC0000272 An acceptable statistical analysis of effluent color discharge data demonstrating significantly better color removal performance than that currently prescribed in the variance and permit. Successful application of end -of -pipe color reduction technology or in -mill color minimization effort that results in significant and measurable reduced mass color discharge. 15. The transfer of this NPDES permit will not proceed until any successor —in —interest to the current owner has agreed to accept the provisions of this permit and request and received from the NPDES Committee a transfer of 2001 Revised Color Variance. Permit Number: NC000O272 A. (9.) DIOXIN MONITORING SPECIAL CONDITION The permittee shall perform the analyses for 2,3,7,8 TCDD and 2,3,7,8 TCDF as outlined below: SamplingPoi Wn"itoring, Re_-tirernents s Measurement, Sampleiype ,-. Fre uenc"i Influent to Wastewater Quarterly Composite Treatment Plant Effluent Quarterly Composite Sludge Annual Composite Landfill Leachate Annual Composite The samples shall 6e analyzed for 2,317;8-TCDD anti 2 7,'8 TCDF 1613.I A single sample ay �be analyzed. �lternatirel , ilte�sample the sample to be split (d+icate.analysis)Jrhe Mi}}tmprn evel in tl 2, I,7,I TCDF by �PA Meth $ 13 io- O pg/l. \ / if P,3,,7,g TCDD or 2,3 7, TCDF e'letecteOn the effluent a Additional Requirements ance with EPA ei may be collected I it-for-2,3,7,8-TC 1 D the quantitdtion le j el the Fill leachal Fish tissue analysis shall be performed in accordance with the Division of Water Quality approved monitoring plan, which will be reviewed as necessary. The monitoring plan is an enforceable part of this permit. All dioxin data collected as part of this monitoring requirement will be reported as required in the plan, no later than 180 days after sampling. Permit Number: NC0000272 A. (10.) DISSOLVED OXYGEN SPECIAL CONDITION The permittee shall maintain an average daily dissolved oxygen concentration of not less than 5.0 mg/1 with a minimum instantaneous value of not less than 4.0 mg/I at River Miles 62.9 (DN1) and 57.7 (DN2). The permittee shall operate oxygen injection facilities at the outfall structure, at 0.9 miles downstream of the discharge, and at 2.1 miles downstream of the discharge, as necessary, to comply with this requirement. These facilities shall be operated in a manner which will maintain the water quality standard for dissolved oxygen in the Pigeon River downstream of the discharge. Blue Ridge Paper shall report the date and duration of oxygen injection use as a supplement to the monthly Discharge Monitoring Report (DMR) forms. If the dissolved oxygen drops below 5.0 mg/L at station DN2 then monitoring shall be required at stations DN3 and DN4. A. (11.) TOWN OF CANTON INFLOW AND INFILTRATION SPECIAL CONDITION to promote -reduction of for Waterville Reservoirshal�e conducted one annually uring2002-tid 2004. Stair erforme d dsring a iow flow�eriods to correspon ,,with the is4-tissue-study (see A. (�.) at Wateru01e�Res/ervoir prior to`L.aii el ranch, Waterville R, Reservoi Tear the dam. Each loco ioq shall be sampled for J e... Temperature Dissolved Oxygen Conductivity pH Total Nitrogen Nitrite + Nitrate Ammonia TKN PO4 Total Phosphorus Chlorophyll -a Secchi Depth All samples shall be collected at 0.1 meters beneath the surface of the water in the lake. A. (13.) TEMPERATURE V During the next permit renewal, Blue Rid; submit a balanced and indigenous species Ridge Paper shall submit a complete temF temperature variance. near CO i� ION an analy i of em er tuTanshall � 1t, 200' . s arty f this an0sis, Blue gcprm ttpg t G need for a CHI tinned The study shall be performed in accordance with the Division of Water Quality approved plan. Request for revisions to this plan shall be submitted for approval no later than March 1, 2005. The temperature analysis and the balanced and indigenous study plan shall conform to the specifications outlined in 40 CFR 125 Subpart H and the EPA's Draft 316a Guidance Manual, dated 1977. 11 ; l Pe ar..fr-';!ent of Enviro(tment and Natural Resources oFv,A*e . ,± ] '''i rv'_° {hj Palltermit NC0000272 � Facility Information Applicant/Facility Name: Applicant Address': Facility Address': Permitted Flow?'''': Type of Waste?,' ': Facility/Permit Status': County?-','-. Miscellaneous Receiving Stream,': Stream Classifications?: 303(d) Listed?': Subbasin2: Drainage Area (mi2�: (calculated] Summer 7Q10 (cfs) . Winter 7Q10 (cfs)': Average Flow (cfs)': IWC (%): Primary SIC Code: Regional Office: USGS Topo Quad: Permit Writer: Date: SUMMARY Blue Ridge Paper Products Inc. P.O. Box 4000 175 Main Street 29.9 MGD Industrial, domestic, stormwater, and landfill leachate Renewal Haywood Pigeon River C Yes - Fish Advisory, Dioxins 04-03-05 130 mil 52 cfs at Canton and 120 cfs at Hepco 63 cfs at Canton and 183 cfs at Hepco 325 cfs at Canton and 677 cfs at Hepco 100% (See Text Below) 2621 Asheville Canton (E 7 SE - State Grid) Michael Myers July 24, 2001 Blue Ridge Paper Products Inc. has requested renewal of their National Pollutant Discharge Elimination System (NPDES) discharge permit NC0000272 allowing discharge of industrial, stormwater, municipal and landfill leachate wastewaters to waters of the state. The NPDES permit will expire on November 30, 2001 and the application for renewal was received on February 23, 2001. This fact sheet summarizes the rationale used to develop the North Carolina Division of Water Quality's recommendations for the draft permit. BACKGROUND Blue Ridge Paper is an employee -owned and operated integrated, elemental chlorine free (ECF) bleached kraft pulp with oxygen deligninifcation and bleach filtrate recycle, and paper mill in Canton, North Carolina. Processes at the mill include a pine bleach line; hardwood bleach line, paperboard and fine paper production lines. Pine and hardwood chips are transported to the site via rail or truck and subsequently processed into pulp for paper or paperboard production. In or around 1990, Champion International Corporation (Champion Paper - now Blue Ridge Paper) initiated a $300 million dollar modernization project termed the Canton Modernization Project. This project eliminated the use of elemental chlorine and implemented significant changes to both the pine and hardwood bleaching lines. The mill upgrade included two changes that dramatically improved the mill's environmental impact. The first major change was the use of oxygen delignification. This process is used to separate the lignin from the fiber. This resulted in significant improvement in the mills environmental performance. The second major change was the implementation of full-scale bleach filtrate recycle (BFR) on the pine bleach line and caustic extration stage (E.) filtrate recycle (-20 %) on the hardwood bleach line. For a Fact Sheet NPDES Renewal Page 1 more detailed description of the mill improvements, refer to the Canton Modernization Project Section below. The Canton Modernization Project greatly reduced the wastewater generated and eventually discharged to the Pigeon River. Even with these improvements, significant quantities of wastewater are generated in the production of pulp and paper and proper treatment prior to discharge is required. Wastewater generated by the Canton Mill, along with the Town of Canton's domestic wastewater, is treated at Blue Ridge Paper's Wastewater Treatment Plant. The treatment plant is a 29.9 MGD wastewater treatment system consisting of the following unit processes: • Grit Chamber • Bar screens • Lift pumps • Polymer addition • pH control (CO2 injection or H2SO4 backup) • Three primary clarifiers (one normally off-line) • Nutrient feed • Aeration basins • Three secondary clarifiers • Residual belt presses • Effluent flow measurement • Cascade aeration (with oxygen injection) • Oxygen injection facilities Solids at this facility are deposited into a dedicated landfill. The history of this mill, under the ownership of Champion Paper and now Blue Ridge Paper, has been controversial. Under Champion Paper, the environmental impacts of the Canton Mill were noted by concerned citizens, environmental groups, the State of Tennessee, State of North Carolina, and the United States Environmental Protection Agency (EPA). The issues raised by these individuals and groups contributed to the Canton Mill's improved environmental performance and resulted in a settlement agreement issued January 8, 1998. Today the relationship among the various stakeholders has evolved to one of cooperation. The Division commends all the groups for their willingness to work together to improve water quality. This permit has centered around four main issues emanating from the mill's discharge: color, temperature, oxygen consuming waste and dioxin, and a brief synopsis follows. Color On July 13, 1988, Champion Paper was granted a variance from North Carolina's narrative water quality standard for color, which the EPA interpreted to be 50 color units. The EPA subsequently issued a NPDES permit to Champion Paper facility in Canton, North Carolina. In 1994, the EPA returned NPDES permitting authority for the Canton Mill back to North Carolina's Division of Water Quality. During the permit renewal the original color variance was modified and both were issued around December 11-12, 1996. As outlined above, over the course of this variance the mill has initiated significant improvements, which have dramatically reduced the color loading and other effluent characteristics. Though the mill has made tremendous strides, color continues to be the focal point surrounding this permit. The EPA chaired Technology Review Workgroup have recommended additional color reduction for the up coming permit cycle. The recommendations issued by the Technology Review Workgroup included the findings of a third party evaluation of Blue Ridge Paper's Canton mill and the report issued by the EPA Tech Team'. The evaluation conducted by Dr. Norm Liebergott was co- sponsored by Blue Ridge Paper and several environmental groups and provided valuable information for the TRW'. In addition, to identifying areas for improvement and available technologies, Dr. Liebergott compared the Canton mill to similar mills around the world. Dr. Liebergott concluded that the Canton mill's environmental performance is among the best in the world. Though incredible work has been done, there continues to be a need to reduce color further. Blue Ridge Paper's openness and willingness to work towards continued improvements has resulted in an atmosphere of trust and cooperation among all the interested parties. This cooperation has been extremely valuable and will continue to be critical as the additional color reductions recommended by the Technology Review Workgroup are implemented (see attached July 24, 2001, memo from the EPA Tech Team to the Technology Review Workgroup). Fact Sheet NPDES Renewal Page 2 I The Technology Review Workgroup report identifies process improvements that will result in permitted color reductions of 6,000 pounds per day. In addition, the report identifies process improvements that will require further study but are likely to result in total color reductions in the range of 9,000 - 14,000 pounds per day. The mill will also evaluate the feasibility of treating the highly colored low flow wastestream from the chloride removal process (CRP). The feasibility of additional color reductions associated with the treatment of the CRP wastestream is highly uncertain and no color reductions have been established for this permit cycle. The result of a feasibility study on the Chloride Removal Process wastestream will be evaluated for possible additional color reductions for the next permit cycle. As shown in Table 1, the 6,000 pound per day annual average color reduction will become effective on December 1, 2003. Additionally, the mill will evaluate additional process improvements in order to achieve an annual average effluent color loading of 34,000 - 39,000 pounds per day. If the limits determined to be achievable are within the target range, the limits shall become effective on December 1, 2005, by written notification from the Director. In the event that the achievable limits are outside of this range then the NPDES will be reopened. At that time, public comments will be.gathered and the permit may be modified. Table 1. Major Dates for Compliance/Reports. Submittal/Compliance ate Requirement 2002 1- is issue Study Report October 1, 2003 Statisticalevaluation ot pertormance tor determination ot the monthly average effluent color limit December 1, 2003 First reduction in effluent color limit December 1, 2003 keasibility report on additional process improvements tor further color reductions 2004 is issue Study Report December 1, 2005 Statisticalanalysis and feasibility report on treatment of UXF wastestream March econ reduction in effluent color limit March omparative Evaluation Report May 1, 2006 Balancedand Indigenous Species Study Report Temperature The facility first requested and received a 316 (a) variance (approved by EPA) for temperature on August 6, 1985. This determination demonstrated that the effluent limitations relating to the thermal .component of the Champion discharge were more stringent than necessary to assure protection and propagation of a balanced indigenous population of shellfish, fish, and wildlife in the Pigeon River. Therefore, the 316(a) determination was approved based on protection of the appropriate use classification of the Pit eon River. The temperature variance was reviewed and renewed as part of the ,t. Triennial Revipm n,l•07. ?1j, 4113lue 2001 variance is appropY, emperature variant jVgen Consuming a Balance and Indigenous Species Study on the Pigeon River on June 1, reviewed the report and concluded that continuance of the temperature grefore, the Division of Water Quality is recommending continuation of the ,;porting requirements consistent with the previous permits (see Table 1). '" fryIP o T)rcdicted that even with a BODS' loading of 1209 lb/day (5.0 mg/L at 29 1I+ �. • Yxx en in the Pigeon River would not be protected. Since Blue Ride Paper f31'sm'cY( trmgent limitations, an instream method was implemented to protect the p cassolved oxygen in th roceiving stream. For further discussion on this subject refer to the conventional pollutant '4ion below. Dioxins Elevated levels of dioxins were found in fish tissue in the Pigeon River (around the late 1980s). Subsequently, a fish consumption advisory was issued for sport fish, catfish and carp. The Canton Mill has not discharged any detectable levels of 2,3,7,8 TCDD to the Pigeon River (since 1989) and dioxin in fish tissue continue to decline. Currently, a fish consumption advisory continues for carp and catfish. North Carolina has lifted the advisory on sport fish. However, the State of Tennessee continues to post a precautionary fish consumption advisory for carp, catfish and red breasted sunfish. ' BOD5 is an analytical method used to estimate the biochemical oxygen demand. Fact Sheet NPDES Renewal Page 3 The fish consumption advisories in North Carolina and Tennessee are currently under review for possible modification of the advisories. The North Carolina Division of Environmental Health (DEH) has initiated a review of the fish consumption advisory on Pigeon River and Waterville Lake. DEH is evaluating dropping the advisory on catfish in the North Carolina portion of the Pigeon River and limiting the advisory on Carp to Waterville Lake. A final determination may not be finalized prior to permit renewal, therefore, recommendations presented in this permit do not reflect this evaluation. STREAM CONDITIONS The facility discharges to the Pigeon River near Canton, North Carolina. The Pigeon Riverii rom Canton to Hurricane Creek is listed as an impaired water, according to North Carolina's 20Draft 303(d) List, due to a fish consumption advisory for dioxins. Recent data indicate that the diin levels in fish tissue continue to decline. There has been no detection of 2,3,7,8 TCDD in sport fissince 1995 and below North Carolina's fish consumption advisory level for 2,3,7,8 TCDD in catfish since 1997, based on Blue Ridge Paper's data. 2,3,7,8 TCDD continues to be detected in carp, though levels continue to decline and are below North Carolina's advisory level. The Pigeon River has been experiencing extremely low flows, due to extended drought conditions in the western part of the state, with flows often less than the 7Q10 flows of 52 cfs (near Canton). Curtis Weaver, with the USGS, provided the updated low flow statistics noted above using data from 1933 through 1999. The low flow statistics at Canton include the influence of Lake Logan, which was constructed in 1932 and the influence of both Lake Logan and Lake Junaluska (constructed in 1913). This reflects the current hydrography within the watershed and does not reflect conditions prior to construction of the lakes. The impact of this reevaluation of the low flow statistics is that the lowest seven day average flow expected once in ten years (7Q10) has been reduced from 54 cfs to 52 cfs. This affects the instream waste concentration which is used to determine the limits for the toxicity testing (discussed later). 1991 Yi�3a7.itri0_GO, Y • t A The current permit requires Blue Ridge Paper to conduct an extensive instream monitoring program consisting of 12 monitoring sites (1-upstream of mill in Pigeon River, 3-Waterville Reservoir, and 7- downstream of mill in Pigeon River and 1-Big Creek; See Figure 1 and Table 2). Instream Monitoring by Parameter Blue Ridge Paper is required to monitor fecal coliform upstream (at station UP) and downstream of the discharge (at station DNI). Analysis indicates no discernable difference between the upstream and downstream fecal coliform levels. Upstream fecal coliform is generally in the range of 100 to 200 /100m1. The same trend is evident at the downstream sampling point. These data suggest that Blue Ridge Paper does not contribute significant levels of fecal coliform. Monitoring of the effluent is sufficient to monitor the mill's impact on the river. Blue Ridge Paper has volunteered to conduct upstream sampling and this requirement will remain as a condition in the permit. Thus, the Division's recommendation is the elimination of the downstream fecal monitoring and once per week fecal monitoring upstream. Blue Ridge Paper is required to monitor conductivity upstream (at station IJP) and downstream (at station DN1). There is a significant increase in conductivity between the upstream and downstream monitoring sites. Conductivity measurements are less than 50 umhos/cm2 at the upstream monitoring station and generally greater than 250 umhos/crn' at the Fiberville Bridge. This increase in conductivity is expected since conductivity is a measure of inorganic material. Thus, the Division's recommends that conductivity monitoring continue as required. by 15A NCAC 2B .0508(d). Fact Sheet NPDES Renewal Page 4 Figure 1. Instream Monitoring Stations for Blue Ridge Paper Products — Canton Mill. /Station w-xcrtxSteov u.. Ste don 25o-ee.e. Big en.. f 01 .dvdi Bolden e].7-Above Clyde to I. andC eh Su0Pn02.e-FbenlN Bride. . B.d-UP.B..m.] 0 W NId.. P.P., USGS Sites Primary Highways Pigeon River Hydrography NPDES Discharger Municipal boundaries The facility is required to monitor 5-day Biochemical Oxygen Demand (BODS) upstream at station UP and downstream of the discharge at the station DN7. Levels of BODS have been less than 2.0 mg/L. Based on this information and the Division's lack of need for the data, it is recommended that instream BOD5 monitoring be eliminated from the permit. Fact Sheet NPDES Renewal Page 5 Table 2. Instream Monitoring Requirements According to the 1997 NPDES Permit and Color Variance. [ream mile Location Description Parameter Frequency Designation Marker waste treatment plant outfall D.O. Daily (prior to mixing with the BOD5 1/Week discharge) Conductivity Daily Color 2/Week Flow Daily Fecal coliform I/Week D.O. Daily Conductivity Daily Fecal Coliform l/Week Color 2/Week u• D.O. 1/Week Color 2/Week Pigeon River at NCSK 1625 TemperatureI/Week bridge D.O. I/Week Color 2/Week igeon River at Hepco emperamrel/Week D.O. l/Week Color 2/Week Mouth of Big Creek prior to Color 2 Week mixing with the Pigeon River (—NC/TN State Line) D.O. I/Week BOD5 1/Week Color 2/Week Blue Ridge Paper monitors temperature upstream at station UP and downstream at all monitoring stations except station DN6 and station BC. Comparing upstream to downstream, see Figure 2, the temperature difference ranged from between 1.78 °C and 11.65 'C. At no time did the monthly average temperature of the Pigeon River exceed the permitted limits of 32 °C (summer) or 29 °C (winter). Blue Ridge Paper monitors dissolved oxygen (DO) at all the instream stations except station DN6 and station BC. Over the period of review (1998 — 2000), dissolved oxygen did not drop below the North Carolina's standard of 5.0 mg/L for Class C streams at any of the instream monitoring locations. Figure 3 summarizes the results of this analysis. During the previous permit cycle, an EPA -approved computer model indicated that BODs limits were required to protect North Carolina's instream dissolved oxygen standard of 5 mg/L for Class C waters. An economically feasible end -of -pipe technology capable of consistently treating to levels necessary to meet the limits specified by the model did not exist. North Carolina agreed with the continuation of the requirement that Blue Ridge Paper meet the instream dissolved oxygen standard by use of sidestream oxygen injection facilities. Blue Ridge Paper maintained these oxygen injection facilities at the effluent and at approximately 0.9, 2.1, and 3.7 miles downstream of the discharge. The previous NPDES permit required Blue Ridge Paper to maintain the oxygen injection facilities located 0.9 and 2.1 miles downstream. To ensure compliance with the above requirement, the average daily instream dissolved oxygen levels at stations DN1, DN2 and DN3 were required to equal or exceed 5.0 mg/L and the minimum instantaneous instream values were required to be greater than or equal to 4.0 mg/l. If dissolved oxygen drops below the prescribed values Blue Ridge Paper shall utilize the instream dissolved oxygen injection stations to increase the dissolved oxygen in the river. Fact Sheet NPDES Renewal Page 6 This method fulfilled the requirements of 40 CFR 125.3 (f) Blue Ridge Paper has compiled an extensive database on instream dissolved oxygen concentrations and stream flow. These data suggest that the dissolved oxygen sag occurs at station DN2. Figure 2. Temperature in the Pigeon River Upstream and Downstream of Blue Ridge Paper's NPDES Discharge. 35 30 25 L 20 0 c 15 t 10 5 0 Permitted Limits NC 1i Summer Uml = arC WutterLimii=29T ar-C2SC PermWD' =13.9T Nov-96 Feb-99 May-99 Aug-99 Deo-99 Mar-00 Jun-00 od-00 Jan-01 Apr-01 Time A Statlon UP - Statlon DNt +Dena T Figure 3. Average and Minimum Dissolved Oxygen in the Pigeon River from River Mile 63.5 to the NC/TN State Line. (Average DO* = In (DO)) 12.00 disebatge 70.00 60.00 50.00 40.00 30.00 20.00 10.00 River Mlle Fact Sheet NPDES Renewal Page 7 10.00 6.00 m E ii '-Average DO 6.000 a -�-Minimum —212ndard a > 'Average DO' 0 w N 4.000 2.00 � 0.00 0.00 Stations DN2 and DN3 were included because the dissolved oxygen model predicted that the DO sag occurred in this area and because they represented monitoring locations upstream and downstream of Clyde's discharge. The Town of Clyde has recently removed their discharge and the Division has received a letter from the Town requesting rescission of the permit. Based on a review of the instream data and the removal of Clyde's discharge, it is recommended that the dissolved oxygen compliance point at station DN3 be eliminated. The Division reviewed the 1998 through 2000 instream dissolved oxygen data. Over this time period, Canton, North Carolina has experienced extreme drought conditions and flow in the Pigeon River has often dropped below the updated 7Q10 stream flow. Under these conditions, the lowest dissolved oxygen level observed in the North Carolina portion of the Pigeon River was 5.0 mg/L and occurred at river mile 57.7. Additionally, a review of the average daily instream dissolved oxygen data and the average over this time period indicates that the dissolved oxygen sag occurs at river mile 57.7. Based on this analysis, the compliance point and monitoring requirement at river mile 55.5 have been dropped. The oxygen injection facilities will continue to be maintained at the effluent, 0.9, and 2.1 miles downstream, and used as necessary to maintain an instream dissolved oxygen level of 5 mg/l. The condition to maintain the instream dissolved oxygen stations shall remain a condition of the permit until such time that the permitted loading of oxygen consuming waste to the Pigeon River is less than or equal to that proposed by an appropriate water quality model. If dissolved oxygen at station 57.7 drops below 5.0 mg/L, the facility is required to monitor dissolved oxygen at river mile 55.5 and 53.5. Instream monitoring continues to be required in order to assess Blue Ridge Paper 's impact on the Pigeon River and to ensure that the dissolved oxygen standard is maintained within the river. • •t The 1997 Settlement Agreement contained provisions to limit color in the Pigeon River at the Hepco USGS gauge station. The new effluent limits in this permit are more stringent than the provisions in the 1997 Permit and Color Variance and will result in reduced color levels in the Pigeon River. It is possible to calculate the monthly flow at the Canton gage station above which instream color at the Fiberville Bridge will not exceed 50 true color units. Using the 55,000 pounds per day monthly average true color loading limit (implemented on the effective date of the permit) the flow at the Canton Gage station, which will provide for color less than 50 true dolor units at the Fiberville Bridge is 171.8 MGD. Therefore, the monthly average color in the Pigeon River at the Fiberville Bridge will be less than 50 true color units whenever the monthly average flow (at the Canton gage station) is greater than 171.8 MGD. North Carolina is recommending that the Fiberville bridge be the basis for the color variance. The governing flow criterion for true color at Canton is 58.1 MGD (30Q2 stream flow). The flow established is greater than this 30Q2 stream flow, therefore, for flows less than the 171.8 MGD at the Canton Gage station but greater than 193.3 MGD at the Hepco gage station, the monthly average color in the Pigeon River at Hepco will be less than 50 true color units. Currently, the basis for the color variance is the Hepco station (DN5) within North Carolina, therefore with the moving of the station from Hepco to Fiberville, DWQ recommends that the mill monitor the Hepco station 2/week during the summer and once per week during the winter. During the permit cycle, the effluent color limit will be reduced, therefore, the instream color criteria will be adjusted accordingly. The monthly average color in the Pigeon River at the Fiberville Bridge will be less than 50 true color units whenever the flow at Canton is greater than the flow established using the following equation and based on the monthly average effluent limit established per Special Condition A.(8.) Paragraph 4: FlowatCanbnUSGS(MGD) _ (MonthlyAverageEfflueztColorLinit,lb/dcry-12468.3)+31.6+2.4 308.58 For flows at the Canton Gage station less than the flow established here but greater than 193.3 MGD at the Hepco gage station, the monthly average color in the Pigeon River at Hepco will be less than 50 true color units. Compliance Summary The facility has been in compliance with permit conditions during this cycle Fact Sheet NPDES Renewal Page 8 Toxicity Testing Current Requirement: Chronic toxicity limit monitored quarterly @ 87 % In December 1999 the facility reported a chronic level of 81 % (with a state split sample greater than 87 %), with the following two months greater than 100. All other toxicity tests over the past four years were greater than the stipulated 87%. The toxicity testing requirement is placed on all major facilities and other facilities with complex wastestreams. The toxicity limit is based on the instream waste concentration under 7Q10 conditions (52 cfs updated April 2001). For Blue Ridge Paper, the instream waste concentration was determined by also accounting for the out -take of surface water from the facility (31.6 MGD, as per application) and water withdrawal by the Town of Canton (allocated 6.8 MGD). Therefore, the instream waste concentration was determined to be 100% under 7Q10 conditions. The Division has set a ceiling on the toxicity test of 90%. This was done because of difficulties associated with averaging toxicity test with limits of 100%. The Division feels that 90% is sufficiently stringent to assess the chronic toxicity of an effluent, while allowing for the averaging of multiple tests. Recommended Requirement: Quarterly Chronic Toxicity @ 90% Mar, Jun, Sep, Dec Blue Ridge Paper is required to perform the NC Whole Effluent Toxicity Test or an equivalent method (as approved by the Division) on a quarterly basis at 90 %. Any equivalent method shall also be performed on a quarterly basis. Toxicant Analysis Using the self -monitoring data required per the NPDES permit, reasonable potential analyses were d t d llowing toxicants: mercury, zinc, cadmium, selenium and silver. The standards stem with North Carolina standards for a class C waterbod f�C�ll � bl� i � y. athmrum ) ised oft a is46, fist nalysis of self -monitoring data, this discharge does not pose a reasonable pUel finial to cause a vioikiz" a of the North Carolina stream standard for cadmium. Effluent itor_i e dad iu rr hall continue; ince cadmium continues to be detected in the effluent. (I "Me. a III, 11;isl ' ; , Me cur �e the, rvrsjon�lnfalysis of self -monitoring data, this discharge does not pose a A reasonable pote t c ri e a vtol t t f the North Carolina stream standard for mercury. Add'ti Hall ai> uiy s amlest'kt� d since January 1999 have been below North Carolina's < <, T� tin I I I i1Jl I) 7 l �[ 1 e dldt6con levt of b.i µg/L. Inc ults from the Division's 1996 Fish Tissue Mercury <�• "'lnA'�il!q "re Pigeon River indicate, "total mercury results were comparable to 'background' bwis`expe7or fish across North Carolina." Based on the findings in this report and the 'Reasop,W otential' Analysis, it is recommended that mercury monitoring and limitation be removed ro tl)?z permit. SilJer - Based on the Division's analysis of self -monitoring data, this discharge does pose a reasonable potential to cause an exceedence of the North Carolina's Action Level Standard for silver. Numerical limits for silver are not being included since silver is an action level water quality standard and the biomonitoring requirements are adequate to control toxicity due to the presence of silver. Though no limit is proposed, if the facility experiences chronic toxicity violations, the discharge will be re- evaluated and a silver limit may be implemented according to the Division's Action Level Policy. Selenium — The Division's analysis indicates that the maximum predicted concentration for selenium is greater than the allowable concentration. This analysis included only seven data points, with six data points below the quantitation level. One sample indicated the presence of selenium, however the concentration reported was at the quantitation level for the method. Additionally, the QA/QC data questions the validity of this data point. However, the Division has limited Blue Ridge Paper for Selenium. After collecting for one and half years (six data points) of data, the facility can request that the Division review the Selenium data for possible elimination of the limit. Zinc - Based on the Division's analysis of self -monitoring data, this discharge does pose a reasonable potential to cause an exceedence of the North Carolina's Action Level Standard for zinc. Numerical limits for zinc -are not being included since zinc is an action level water quality standard and the biomonitoring requirements are adequate to control toxicity due to the presence of zinc in the facility effluent. Though no limit is proposed, if the facility experiences chronic toxicity violations the discharge will be re-evaluated and a zinc limit may be implemented according to the Division's Action Level Policy. Monitoring requirements for zinc are consistent with 15A NCAC 2H .0508 (d). Fact Sheet NPDES Renewal Page 9 A 11IJe OXYGEN CONSUMING WASTE POLLUTANTS A site -specific Best Available Technology (BAT) based limit was calculated to determine the monthly average 5 - day biochemical oxygen demand (BOD5) limit. A site -specific BAT approach was used because North Carolina's Division of Water Quality continues to agree that an economically feasible end -of -pipe technology capable of reliably meeting the water quality limit specified by the existing model does not exist at this time and no violations.of the dissolved oxygen standard in the river have been observed in recent years. The North Carolina Division of Water Quality's recommendation for the draft permit BODS limit is established based on the demonstrated level of performance for the existing treatment plant. Data on treatment plant performance and influent loading from the Canton Mill (1998 through 2000) was evaluated and examined for outliers. As indicated in the "Bleach Environmental Process Evaluation and Report", the performance of this mill is among the best in the world. The maximum influent loading and lowest treatment plant performance were used to develop the monthly average BOD5 limit. The data set was sufficient to account for the day to day variability of the treatment system. Over the time period evaluated, the treatment plant has performed extremely well. The lowest percent removal was 96.9 % and the highest influent loading was 414.9 mg/L. Based on this analysis, North Carolina's Division of Water Quality recommends a monthly average BOD5 loading of 3205.0 lbs/day. The limit presented in the draft permit represents and a 71-ton per year reduction in BOD5 loading to the Pigeon River. Because Blue Ridge Paper has oxygen injection facilities in place to maintain the instream dissolved oxygen standard should instream dissolved oxygen dictate a need, Blue Ridge Paper complies with the conditions set forth by 40 CFR 125.3 (f). The methodology used for the daily maximum 5 - day biochemical oxygen demand (BODS) limit was recommended during the previous permit cycle. A site -specific daily maximum to monthly average multiplier was used for determination of the recommended daily maximum limit. Using this methodology and reviewing data since the Canton Modernization Project (1998 — 2/2001) the recommended daily maximum limit based on a multiplier of 3.4 (daily maximum/monthly average) is 10897 lb/day. The limit proposed represents an achievable level and approximately a 12.5 % reduction in the daily maximum BOD5 limit. Ammonia monitoring requirements are included in the permit to provide data concerning levels of ammonia discharged to the Pigeon River (which may affect instream dissolved oxygen). Effluent dissolved oxygen is limited at no less than 6 mg/1 based on the above discussion. Daily monitoring is required based on 15A NCAC 2B .0508 (d), Paper and Allied Products, Class IV facility. NUTRIENT POLLUTANT ANALYSIS Total phosphorus and total nitrogen monitoring is required by 15A NCAC 2b .0508 (d) (2) (A). Monthly monitoring is required to assess the contribution of nutrients from Blue Ridge Paper and the potential impact to Waterville Reservoir. Waterville Reservoir is to be monitored once annually (during opposite years of CP&L's montioring) to assist in the continued characterization of nutrient impacts to the lake. a fah consumption advisory due to dioxin for the Pigeon River downstream of the $$�t,�}t5% viN?ry was initially in effect for consumption of all fish species, this t�Ed�Hc B� '�l arp and catfish species only, reflecting continued improvements in the ,ebrrontly, Bfue"P idg"G���5 er i required to monitor dioxin and dibenzofuran isomers quarterly from the influent, sludge, landfitL 'ate, and effluent. Based on an evaluation of the data, the Division is recommending a revisio c ate special condition requiring dioxin and dibenzofuran isomers monitoring. An improve t�Aedge of the dioxin and dibenzofuran isomers indicates that only 2,3,7,8 TCDD and 2,3,7,8 TCDF are pollutants of concern. Therefore, it is recommended that the dioxin isomer special condition be modified to require monitoring only for 2,3,7,8 TCDD and 2,3,7,8 TCDF. Fact Sheet NPDES Renewal n-- I! OXYGEN CONSUMING WASTE POLLUTANTS A site -specific Best Available Technology (BAT) based limit was calculated to determine the monthly average 5 - day biochemical oxygen demand (BOD5) limit. A site -specific BAT approach was used because North Carolina's Division of Water Quality continues to agree that an economically feasible end -of -pipe technology capable of reliably meeting the water quality limit specified by the existing model does not exist at this time and no violations.of the dissolved oxygen standard in the river have been observed in recent years. The North Carolina Division of Water Quality's recommendation for the draft permit BODS limit is established based on the demonstrated level of performance for the existing treatment plant. Data on treatment plant performance and influent loading from the Canton Mill (1998 through 2000) was evaluated and examined for outliers. As indicated in the "Bleach Environmental Process Evaluation and Report", the performance of this mill is among the best in the world. The maximum influent loading and lowest treatment plant performance were used to develop the monthly average BOD5 limit. The data set was sufficient to account for the day to day variability of the treatment system. Over the time period evaluated, the treatment plant has performed extremely well. The lowest percent removal was 96.9 % and the highest influent loading was 414.9 mg/L. Based on this analysis, North Carolina's Division of Water Quality recommends a monthly average BOD5 loading of 3205.0 lbs/day. The limit presented in the draft permit represents and a 71-ton per year reduction in BOD5 loading to the Pigeon River. Because Blue Ridge Paper has oxygen injection facilities in place to maintain the instream dissolved oxygen standard should instream dissolved oxygen dictate a need, Blue Ridge Paper complies with the conditions set forth by 40 CFR 125.3 (f). The methodology used for the daily maximum 5 - day biochemical oxygen demand (BODS) limit was recommended during the previous permit cycle. A site -specific daily maximum to monthly average multiplier was used for determination of the recommended daily maximum limit. Using this methodology and reviewing data since the Canton Modernization Project (1998 — 2/2001) the recommended daily maximum limit based on a multiplier of 3.4 (daily maximum/monthly average) is 10897 lb/day. The limit proposed represents an achievable level and approximately a 12.5 % reduction in the daily maximum BOD5 limit. Ammonia monitoring requirements are included in the permit to provide data concerning levels of ammonia discharged to the Pigeon River (which may affect instream dissolved oxygen). Effluent dissolved oxygen is limited at no less than 6 mg/1 based on the above discussion. Daily monitoring is required based on 15A NCAC 2B .0508 (d), Paper and Allied Products, Class IV facility. NUTRIENT POLLUTANT ANALYSIS Total phosphorus and total nitrogen monitoring is required by 15A NCAC 2b .0508 (d) (2) (A). Monthly monitoring is required to assess the contribution of nutrients from Blue Ridge Paper and the potential impact to Waterville Reservoir. Waterville Reservoir is to be monitored once annually (during opposite years of CP&L's montioring) to assist in the continued characterization of nutrient impacts to the lake. a fah consumption advisory due to dioxin for the Pigeon River downstream of the $$�t,�}t5% viN?ry was initially in effect for consumption of all fish species, this t�Ed�Hc B� '�l arp and catfish species only, reflecting continued improvements in the ,ebrrontly, Bfue"P idg"G���5 er i required to monitor dioxin and dibenzofuran isomers quarterly from the influent, sludge, landfitL 'ate, and effluent. Based on an evaluation of the data, the Division is recommending a revisio c ate special condition requiring dioxin and dibenzofuran isomers monitoring. An improve t�Aedge of the dioxin and dibenzofuran isomers indicates that only 2,3,7,8 TCDD and 2,3,7,8 TCDF are pollutants of concern. Therefore, it is recommended that the dioxin isomer special condition be modified to require monitoring only for 2,3,7,8 TCDD and 2,3,7,8 TCDF. Fact Sheet NPDES Renewal n-- I! It is further recommended that the monitoring frequencies be modified based on the fact that measurable quantities of dioxins and dioxin isomers have not been detected in the influent (since 1997), the effluent (since 1996), sludge (since 1996) and the landfill leachate (since 1996). The effluent limit for 2,3,7,8 TCDD has been reduced. During North Carolina's development of the Total Maximum Daily Load for Dioxins on the Pigeon River, the EPA commented that the chronic standard adopted by North Carolina should be applied as an effluent limit at the end of pipe. North Carolina did not agree with this methodology, since it is inconsistent with the standard and North Carolina rules. In addition, the management strategy implemented by North Carolina to address dioxins in the Pigeon River for several years and the data show that this management strategy is resulting in declining dioxin levels in the Pigeon River. The EPA, NC DWQ and Blue Ridge Paper agreed that the TMDL requirement could be waived as long as Blue Ridge Paper's effluent was limited at 0.014 pg/L. Therefore, the dioxin limit has been reduced to 0.014 pg/L and no TMDL will be developed. Annual fish tissue analysis shall continue to be performed by the facility in accordance with the monitoring plan approved by the Division until such time that the fish advisory is lifted in both Tennessee and North Carolina, according to North Carolina's deciiting procedures. Trichlorophenol/PentacMorophenol limits and monitoring are not required. The permittee has certified that chlorophenolic biocides are not used at the facility. This certification eliminates the requirement to include effluent limits for these two parameters based on 40 CFR 430 H eye , f the facility changes future operations to include chlorophenolic biocides, limits a d In o`iii j 'i required. 1 1 "Y i ) l q ���'� �� 1���111�'I rl . 1��+9�k'���.�in�l �l . t,rr 11 I tl 1, J{. �; � C �Ij11 �U J�1P1 ^nllT": qg„ . ji. llif: IF�ij I ��11 �IU'� s�'..1'; ` 1 e to allsrspende solids SS) ,unt s were calculated using the EPA promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category and compared to existing limits. The TSS limits contained in the current NPDES permit are more stringent than the calculated federal effluent guidelines since the current limits are based on the 1993 proposed guidelines for the oxygen delignification process. The Division recommends that the existing TSS limits remain unchanged for this permit cycle. North Carolina does not have a numeric standard for TSS. The rules specifically regulate floating solids, settleable solids, and sludge deposits [ref. 15A NCAC 2B .0211(3)(c)]. The draft permit restricts floating solids. Both benthic and IBI studies have indicated fiirther improvement to the Pigeon River. Therefore, a monthly average TSS limit of 12,549 lbs/day i*,5j ierommended and a daily t S, imit f19)610 lbs/da is recommended. j P�IJ' li y 1 1 I11 11. i) Il �i� ll� Ili3�, i Mill ,n, �lai1 iit rii g �i��rc�i 6a �iiy A NCA s0) Cl ss acility 11��t�� ! t ,TV �,�' ! ►►jj 1''I ��f��l�l f' I)e1The temperature requiremht is based �, ectli tn.G (a) Variance det, ot] t�s ueQ, t ' 1,P �1 Environmental Management Coi lion October 11, 1984 and approved by A A4t, 6j ]i.; . ,: ff l'li{('v In making the recommendatioiS�t�bi Ire a "�°.he current 316(a) variance, DWQ scientist° ai�r,xted Blue Ridge Paper's Balanced and I jigenou ��^pecies Report and concluded that temperate t'could not be identified as prohibiting a Bal 'nced an Lidigenous population. In addition, DWQ staff reviewed existing temperature data and althougr sulme improvement in the instream temperature has occurred (most likely due to overall effluent fl �Secrease, associated with process improvements reducing temperature impacts), Blue Ridge Pa m�' >r itill cannot meet the North Carolina temperature requirement as indicated in Figure 2 above. Therels`ore, DWQ is recommending that the 316(a) variance continue, with Blue Ridge Paper conducting a Balanced and Indigenous Species Study prior to the next permit renewal. The flow limit is based on Blue Ridge Paper's current flow values and post-CMP production plus 0.9 MGD for the Town of Canton's wastewater. Future plant improvements may reduce the contribution of the mill's wastewater, however the Town of Canton is proposing to increase their contribution to the treatment plant as they expand Canton's municipal boundary. Since flows are currently approximately 80% of the permitted capacity, the Division recommends that the flow limit remain unchanged. During the next permit cycle the flow limit should be re-evaluated j 01, Fact Sheet NPDF-S Renewal Page 11 It is further recommended that the monitoring frequencies be modified based on the fact that measurable quantities of dioxins and dioxin isomers have not been detected in the. influent (since 1997), j F .11t the effluent (since 1996), sludge (since 1996) and the landfill leachate (since 1996). r�Ull 1 tl The of t ,limit for 2,3,7,8 TCDD has been reduced. During North Carolina's development of the I01aI I. +kiiim Daily Load for Dioxins on the Pigeon River, the EPA commented that the chronic -' !standam adopted by North Carolina should be applied as an effluent limit at the end of pipe. North Carolina did not agree with this methodology, since it is inconsistent with the standard and North Carolina rules. In addition, the management strategy implemented by North Carolina to address dioxins the Pigeon River for several years and the data show that this management strategy is resulting 1i;eclining `, dioxin levels in the Pigeon River. The EPA, NC DWQ and Blue Ridge Paper a n, d th e } 1,e TMDL requirement could be waived as long as Blue Ridge Paper's effluent was limited a�p ��P A0— Therefore, the dioxin limit has been reduced to 0.014 pg/L and no TMDL will be Jtl de eiti ed. Annual fish tissue analysis shall continue to be performed by the facility in accordance with the monitoring plan approved by the Division until such time that the fish advisory is lifted in both Tennessee and North Carolina, according to North Carolina's delisting procedures. Trichlorophenol/Pentachlorophenol limits and monitoring are not required. The permittee has certified that chlorophenolic biocides are not used at the facility. This certification eliminates the requirement to include effluent limits for these two parameters based on 40 CFR 430. However, if the facility changes future operations to include chlorophenolic biocides, limits and monitoring will be required. OTHER POLLUTANTS OF CONCERN The total suspended solids (TSS) limits were calculated using the EPA promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category and compared to existing limits The TSS limits contained in the current NPDES permit are more stringent than the calculated federal effluent guidelines since the current limits are based on the 1993 proposed guidelines for the oxygen delignification process. The Division recommends that the existing TSS limits remain unchanged for this permit cycle. North Carolina does not have a numeric standard for TSS. The rules specifically regulate floating solids, settleable solids, and sludge deposits [ref. 15A NCAC 2B .0211(3)(c)]. The draft permit restricts floating solids. Both benthic and IBI studies have indicated further improvement to the Pigeon River. Therefore, a monthly average TSS limit of 12,549 lbs/day is recommended and a daily maximum TSS limit of 49560 lbs/day is recommended. Daily monitoring is required based on 15A NCAC 2B .0508 (d), Class IV facility The temperature requirement is based on a Section 316 (a) variance determination issued by the NC Environmental Management Commission October 11, 1984 and approved by EPA August 6, 1985. In making the recommendation to retain the current 316(a) variance, DWQ scientist evaluated Blue Ridge Paper's Balanced and Indigenous Species Report and concluded that temperature could not be identified as prohibiting a Balanced and Indigenous population. In addition, DWQ staff reviewed existing temperature data and although some improvement in the instream temperature has occurred (most likely due to overall effluent flow decrease, associated with process improvements reducing temperature impacts), Blue Ridge Paper still cannot meet the North Carolina temperature requirement as indicated in Figure 2 above. Therefore, DWQ is recommending that the 316(a) variance continue, with Blue Ridge Paper conducting a Balanced and Indigenous Species Study prior to the next permit renewal. The flow limit is based on Blue Ridge Paper's current flow values and post-CMP production plus 0.9 MGD for the Town of Canton's wastewater. Future plant improvements may reduce the contribution of the mill's wastewater, however the Town of Canton is proposing to increase their contribution to the treatment plant as they expand Canton's municipal boundary. Since flows are currently approximately 80% of the permitted capacity, the Division recommends that the flow limit remain unchanged. During the next permit cycle the flow limit should be re-evaluated Fact Sheet NPDES Renewal Page 11 and if appropriate adjusted. Due to potential inflow/infiltration from the Town of Canton, the Division continues the provision that requires Blue Ridge Paper to work with Canton to reduce III problems. Chemical Oxygen Demand (COD) monitoring is required to assess the potential impact of chemical oxygen demand from the Blue Ridge Paper wastewater effluent. Neither federal guidelines nor NC water quality standards require a limit for COD. Though no limit is proposed, the EPA has reserved COD for potential future limits. Therefore, COD monitoring will be continued. Limitations for fecal coliform are based on the contribution of domestic wastewater from the Town of Canton and the requirements of 15A NCAC 2B .0211 (b) (3) (E). Metals toxicity is a function of water hardness, since Blue Ridge Paper has demonstrated reliable compliance with toxicity, the Division recommends the elimination of hardness monitoring. Conductivity monitoring is required based on 15A NCAC 2B .0508 (d), Paper and Allied Products (Water Quality Limited Facilities), for a Class IV facility. Monitoring for total residue/total dissolved solids is required according to the existing NPDES permit. The required conductivity monitoring is sufficient to assess Blue Ridge Paper's inorganic loading to the Pigeon River. Therefore, the Division recommends removal of total residue and total dissolved solids monitoring from the permit. Limitations for pH 6.0 —9.0 are based on 15A NCAC 2B .0211 (b) (3) (G). ISSUES ASSOCIATED WITH EFFLUENT GUIDELINE IMPLEMENTATION Relevant Background Information Over the past five-year permitting cycle, the maximum 12-month production occurred from May 1999 through April 2000. Table 3 outlines the total production of various products generated at the Canton Mill over this time period. Pulp produced at the Canton Mill is supplemented with pine and hardwood pulp purchased from off -site and pulp produced from trim or broke paper off the paper machines. The pulp is then used in paperboard and fine paper production using one of the four paper machines on -site. Table 3. Itemized Production Fieures for the Maximum 12 Month Average Production Period. Product Total for 12 Month Period Units Pine Pulp 217,634.48 Air Dried Tons Hardwood Pulp 298,833.91 Air Dried Tons Purchased Pine Pulp 24,306.87 Air Dried Tons Purchased Hardwood Pulp 22,252.21 Air Dried Tons Broke Paper or Trim Pulp 46,559.08 Air Dried Tons Paperboard Production 313,625.90 Off Machine Tons Fine Paper Production 321.264.00 Off machine Tons Blue Ridge Paper has not joined the Voluntary Advanced Technology Incentives Program (VATIP) for existing direct or new direct dischargers as outlined in 40 CFR 430 Subpart B. The VATI Program was set up for new or existing direct dischargers whereby mills agree to accept enforceable effluent limitations and conditions in their NPDES permits that are more stringent than the BAT limitations, in exchange for regulatory and enforcement related rewards and incentives. Blue Ridge Paper will use steam stripping to treat process condensates, rather than hardpiping to the WWTP; thus interface with the Division of Air Quality is not necessary. Relevant Issues Daily effluent monitoring for Adsorable Organic Halides (AOX) is required. AOX is an overall test for adsorbable organic halides, which includes chlorinated organics. Trends in concentration changes have been observed between AOX and specific pollutants (dioxins, chlorinated organics) at pulp and Fact Sheet NPDES Renewal Page 12 paper mills. Therefore, any decrease in AOX may also indicate a decrease in chlorinated organics. Limits and daily monitoring for AOX are required in the EPA Cluster Rules. The cluster rules are the combined air and water rules issued by the EPA for the pulp and paper industry. The compliance/monitoring point for the AOX limits shall be as defined in the sampling plan. During the next permit cycle, the Division will review the AOX data for possible reduction in monitoring frequencies. Chloroform monitoring/limits have been added to the permit. During the previous permitting cycle, it was determined that the discharge from Blue Ridge Paper did not have a reasonable potential to exceed the allowable level. Therefore, no effluent limit is proposed. Limits contained in the NPDES permit on the bleach plant effluent are based on the EPA promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category. Since Blue Ridge Paper operates two separate fiber lines, there shall be two compliance points for chloroform as stipulated in the sampling plan. In addition to the dioxin limits and conditions stated, above dioxins shall be limited and monitored on the effluent from the each bleach plant. 2,3,7,8 TCDD and 2,3,7,8 TCDF limits are based on the EPA promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category. The compliance/monitoring points for each bleach plant is required as stipulated in the sampling plan. Best Management Practices (BMPs) have been added for spent pulping liquors, turpentine, and soap. At this time, Blue Ridge Paper is in compliance with the best management practices stipulated in the EPA promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category with one remaining issue. The remaining issue deals with the BMP Plan. As part of the EPA promulgated effluent guidelines, facilities, which fall under subpart B, must develop a BMP Plan. This plan does not require the approval of any regulatory authority, but must be certified by the mill manager. Currently, the BMP Plan is in the development process and it is anticipated that this requirement will be completed prior to issuance of this NPDES permit. Per 40 CFR 430.24, the daily maximum limits for 12 chlorinated phenolics are "less than Minimum Level" (<ML) as specified in 40 CFR 430.01. The compliance/monitoring point shall be set at the effluent from the bleach plants as outlined in the sampling plan. PROPOSED CHANGES FROM THE CURRENT NPDES PERMIT • Monthly average BOD5 limit reduced 71 tons per year to 3205 lb/day. • Daily maximum BOD5 limit reduced 12.5 % to 10897 lb/day. • Toxicity testing concentration increased to 90%. • Removal of downstream fecal coliform monitoring with once per week upstream fecal monitoring. • Removal of instream BOD5 monitoring. • Removal of instream monitoring station 55.5. • Removal of instream monitoring station 53.5. • Reduce monitoring frequency at NC/TN monitoring station. • Eliminate mercury monitoring and limitation. • Add selenium limit. • Trichlorophenol/pentachlorophenol monitoring has been removed. • The upstream river mile marker now indicates that the upstream monitoring location is located at river mile 63.8. • The dioxin special condition has been modified to require 2,3,7,8 TCDD and 2,3,7,8 TCDF individual isomer monitoring and to reduce the monitoring frequency of the sludge and landfill leachate. Fact Sheet NPDES Renewal . Page 13 • The 2,3,7,8 TCDD effluent limit has been modified to 0.014 pg/L. • Two internal outfalls (002 and 003) have been added. • Removal of hardness monitoring. • Removal of total dissolved solids monitoring. • Removal of total residue monitoring. • An AOX limit and daily monitoring has been added to the permit per EPA Cluster Rules. • Dioxin, chlorophenolics and chloroform limits/monitoring have been added for the effluent from the pine and hardwood line bleach plants per EPA cluster rule. • - The BMP special condition has been updated according to the requirements of the EPA Cluster Rule. • For color recommendations refer to the July 24, 2001, memo from the EPA Tech Team to the Technology Review Workgroup. This fact sheet represents North Carolina's recommendations. The Division will review all pertinent comments received during the public comment period and the September 6, 2001 public hearing. After reviewing all public comments, the Director of the Division of Water Quality and the NPDES Committee of the Environmental Management Commission will make their recommendations. PROPOSED SCHEDULE FOR PERMIT ISSUANCE Public Notice Draft Permit, temperature variance, color variance and Public August 3, 2001 Hearing Public Hearing September 6, 2001 ADDITIONAL INFORMATION CANTON MODERNIZATION PROJECT Prior to 1993, knotting hardwood brownstock was washed through one of two brownstock washer lines. After washing brownstock was screened using a two -stage fine screening process and bleached in one of the two bleaching lines. The two bleaching lines were operated independently for 'low' brightness and 'high' brightness. Since 1993, the hardwood fiberline has incorporated numerous modifications designed to increase mill performance from both an environmental and product quality standpoint. Currently, the hardwood fiberline consist of two stage knotting followed by pre -oxygen delignification washers. After pulp is processed through the oxygen delignification unit, it is washed again prior to the four stage pressurized fine screening. After screening, the pulp is bleached through one medium consistency bleach line. Prior to 1992, pine (softwood) pulp was processed through one brownstock washing line prior to the two stage screening process. After screening, pulp was processed through one of the two bleaching lines. Similar to the hardwood fiberline, the softwood fiberline bleaching was operated independently for 'low' brightness and 'high' brightness. Like the hardwood fiberline, the softwood fiberline has incorporated numerous modifications in order to enhance product quality and environmental performance. 'Currently, the softwood fiberline process consist of two stage knotting followed by a brownstock pre -oxygen delignification line. After the initial washing the pulp is processed through the oxygen delignification unit followed by another washing. After the second washing pulp is screened using four stage pressurized fine screen before entering a medium consistency bleach line. In addition to the improvements noted, the facility has implemented full scale bleach filtrate recycle of the pine bleach line and caustic extraction stage (Eo) recycle on the hardwood bleach line. Fact Sheet NPDES Renewal Page 14 References 1. Division of Water Quality's Basinwide Information Management System, April 20, 2001, http://h2o enr.state.ne.us/bims/reportstbasinsandwaterbodies/alpha/Neuse.pdf 2. 1995. NPDES Regional Staff Report for NPDES Permit NC0000272, January 18, 1995, Asheville Regional Office. 3. 2000. French Broad River Basinwide Water Quality Plan. North Carolina Division of Water Quality, Water Quality Section. 4. 2001. NPDES Permit Application EPA Forms 1 and 2C, Blue Ridge Paper Products Inc. 5. 2000. 303(d) List of North Carolina Impaired Waters - Draft. North Carolina Division of Water Quality, Water Quality Section. Copies obtained through Planning Branch, Archdale Building, 512 N. Salisbury St., Raleigh, North Carolina. I J 3 Low Flow Characteristics of Streams in North Carolina, United States Geological 117. tc :f ebc' W t¢ -Su y 1per 2403. Copies obtained at U.S. Geological Survey, Map �2pzj �6L�5 �6 MS306, Federal Center Denver CO 80225. atA �',1Q2 .P iS Permit. Issued to Champion Paper, expiration November 30, 2001. Copts obd rough The Division of Water Quality, Central Files, Archdale Building, 512 N. Sali3 ry St., Raleigh, North Carolina. 8. 2001. Bleach Environmental Process Evaluation and Report. Dr. Norman Liebergott, PhD, ociates Liebergott and AssConsulting, Inc, and Lew Shackford, June 8, 2001. 9. 2001. Additional Color Removal Technologies and Their Economic impacts on Blue Ridge Paper Products_ Canton_ NC_ Julv 25. 2001 Memorandum from EPA Tech -Team to State Contact If you have any questions on any of the above information or on the attached permit, please contact Michael Myers at (919) 733-5038 ext. 508. NAME NPD1 NAMI Fact Sheet NPDES Renewal Page 15 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 J�\t6D STgTFS A �'9C F120iE" MEMORANDUM DATE: July 25, 2001 SUBJECT: Additional Color Removal Technologies and Their Economic Impacts on Blue Ridge Paper Products, Canton, NC FROM: EPA Tech Team' TO: Technology Review Workgroup Purpose of this Analysis As required by the 1997 Settlement Agreement, this memorandum presents a summary of an analysis of available technologies that may be employed to further reduce color discharges from the Blue Ridge Paper Products, Inc. (Blue Ridge) mill in Canton, NC. The analysis also includes a summary of the economic impact ("gross margin test") of the cost of implementing identified color reduction technologies. Members of the Tech Team visited the Canton mill on March 14, 2001 to observe and gather information and data on the status of technologies implemented and color discharges at the mill since the 1997 evaluation. This final memorandum incorporates analyses of the data gathered from that visit, and Blue Ridge's response to EPA's follow-up request for additional technical and financial data. This final memorandum is based on the May 4, 2001 preliminary draft memorandum, and revisions to the July 10, 2001 draft final memorandum, based on a review of Blue Ridge's comments, the June 8, 2001 Bleach Environmental Process Evaluation and Report (BEPER) and subsequent comments by Liebergott and Associates and GL&V Pulp Group, Inc, and additional comments from the Clean Water Fund of North Carolina, and the States of Tennessee and North Carolina. This memorandum presents to the Technology Review 1 EPA Tech Team is comprised of -- Mark Perez, EPA/EAD; Karrie-Jo Shell, EPA Region 4; Don Anderson, EPA/EAD; Betsy Bicknell, ERG, contractor; Neil McCubbin, subcontractor to ERG; Dan Bodien, subcontractor to ERG. Workgroup (TRW) process improvements evaluated by the Tech Team and considered to be available technologies and briefly addresses relevant technologies evaluated in the BEPER. Background and History Blue Ridge operates a bleached papergrade kraft pulp and paper mill in Canton, NC, which it purchased from Champion International Corporation in May 1999. Operations at the mill began in 1908, but the mill has been extensively modernized, most recently in 1993. The mill currently operates an 800 tpd hardwood pulping line and a 600 tpd softwood pulping line. After cooking, pulp from each line is further delignified in single -stage oxygen delignification systems installed in 1993. Hardwood pulp is subsequently bleached with a DEoD sequence; pine pulp is bleached with a DEopD sequence. Target brightness is 85 ISO. Up to 80 percent of the filtrate flow from the pine bleach line is returned to the recovery cycle using the unique bleach filtrate recovery (BFR) process, developed by Champion. A portion of the hardwood line bleach plant Eo- stage filtrate flow is also recovered. Blue Ridge produces 250,000 tons per year of uncoated paper including offset, tablet and envelope grades. The mill also produces 281,000 tons per year of bleached paperboard used for liquid packaging and paper cups, including FDA approved grades for milk and juice cartons. Since November 2000, pulp production has been reduced by approximately 30 percent as the result of a major project to upgrade the No. 19 bleached paperboard machine. Continued Color Reduction Opportunities Since the 1997 NPDES Permit The Canton Mill's 1997 NPDES permit included a schedule requiring continued study, evaluation, and pursuit of effluent color reduction opportunities. Champion and Blue Ridge submitted a series of reports to the NC Department of Environment and Natural Resources, Division of Water Quality, evaluating the performance of the BFRTM process, end -of -pipe color reduction technologies, and practices for minimizing color losses from manufacturing processes. Since 1997 Blue Ridge has: • continued full-scale operation of BFR for the pine line; that full-scale BFR is not feasible for the hardwood line, but of the Eo-stage filtrate as an effective of highly -colored black liquor from evaluated 16 end -of -pipe color removal technologies and determined that they were presently economically and/or technically infeasible for the Canton mill. Page 3 Process Improvements Analyzed by the Tech Team The Tech Team identified five mill improvements capable of further reducing the discharge of color in the mill effluent. For each of these improvements, technical feasibility, capital and operating costs, and potential color reduction were reviewed. Each improvement can be implemented independently of the others or in any combination. The costs incurred to implement the improvements are additive, however separate evaluations are necessary to accurately estimate the associated color reduction achieved by implementing any combination of improvements. End -of -pipe color treatment technologies (e.g., chemically assisted clarification with sludge dewatering and disposal) typically require initial capital investment and ongoing operating expenses, not savings, and are likely to incur non -water quality environmental impacts. For this reason, the Tech Team focused on pollution prevention approaches that offer the potential to be more cost-effective: color reduction in low flow, highly color -concentrated wastestreams, through manufacturing process changes or in -process treatment. The first two process improvements, discussed below (improvements in BFR reliability and leak and spill prevention and control - Best Management Practices (BMPs)), are improvements which the Tech Team concludes offer the highest certainty for technical feasibility and color reduction. Blue Ridge also identified these technologies as feasible color reduction opportunities that will be implemented, but differed from the color reduction estimates included in this memorandum. The next two process improvements (ozone addition to an existing chlorine dioxide bleaching stage on the hardwood fiber line; adding a second stage to the current oxygen delignification system on the softwood fiber line) also were evaluated by Liebergott, et. al., as feasible color reduction opportunities. Additional technical evaluation and/or laboratory testing would be appropriate to reliably determine the technical details of how to incorporate these processes into the existing fiber lines and to more accurately predict their achievable color reduction, and the relationship of these technologies to BFR. Additional analyses would be appropriate to determine the most cost-effective design and the most economically feasible schedule for im en m one or both of se im rove e s V� i1I i P , In �i ul i] � �{III ��'•.,l.7 •. �� �i ii ll,,. .13 I J ` >>I��_' � .I �� l(111�? ,� �1{ �� � ;D111111 l�l ►,l��i �; � llk� l�'"''��;Eh i �� the nim oCessl v .n n color calllerit r � c to de a a� ro s t t• 4 , �i, ,t, p' )� Pr P�' } ,, r i9D, r�.i71111 .1{�• stream (one of the two key components of the BFR process), has the potenti{ l of iiriE]Jh13' �t+a' color reduction. However, based upon initial bench -scale treatability studies by Blue Ridge, further study of additional color treatment technologies is necessary. Process optimization on both the hardwood and softwood fiber lines, as recommended in the BEPER, is anticipated to Page 4 provide additional color reduction and is identified as the sixth process improvement. It was concluded that the process optimization option was among those with the highest certainty for technical feasibility and color reduction. All color reductions resulting from the mill improvements are estimates based solely on available data and information. While the Tech Team has concluded that these technologies would reduce the color discharge from the Canton mill, there is a lack of directly comparable operating experience with these technologies in other bleached papergrade kraft mills that can be used to develop precise predictions of the extent of the color reduction benefits. The BEPER evaluated additional in -process technology options for color discharge reduction potential, including the implementation of a hot pressurized peroxide -enhanced extraction stage in both fiber line bleach plants. At this time, the Tech Team does not have sufficient information to confirm the applicability of this technology at the Canton mill nor relevant data to predict its potential color discharge reduction capabilities. Therefore, while this memorandum does not address this technology option, it may be feasible for implementation by Blue Ridge and contribute to reducing color. In addition, the Tech Team did not analyze nor did the BEPER recommend a Totally Chlorine -Fred (TCF) bleaching option because of the high cost.of this technology and the lack of experience in producing and successfully marketing products made by Blue Ridge at the Canton mill. 1. BFR reliability improvement. One of the two key elements in BFR is the Metals Removal Process (MRP). Blue Ridge has found that this process element has been more challenging and expensive to maintain than originally planned. The target BFR recycle rate (percent closure) for the pine line is 80 percent. Due to unforeseen equipment failures (e.g., ion exchange media) and metallurgy problems (e.g., erosion of multi -media filtration tank lining) in the MRP, however, the pine line closure has averaged only 74 percent from October 1998 to the present. Blue Ridge has undertaken improvements to the MRP system in order to maintain the process closure rate and increase operating time. Improvements include rebuilding piping and valves, and changing construction materials and metallurgy to better withstand the chemical and physical stress experienced in the BFR system. Blue Ridge estimates that if BFR closure is maintained at 80 ,or discharge will be reduced by 1,000 to 1,200 lbs/day. is of making an alternative quantitative prediction of to the Blue Ridge estimate. Page 5 2. Improved black liquor leak & spill collection and control (BMPs). The Canton mill has an extensive spill recovery system. Sumps in this system, including one sump added in the court yard adjacent to the digester house as required by the 1997 Settlement Agreement, are equipped with pumps that are activated automatically when sensors detect wastewaters with high conductivity and color. High conductivity material is routed to the recovery system. Further improvements to the black liquor collection system include: • continuous improvement of operating practices so more leaks and spills are recovered rather than discharged to sewer; • further improvement in preparation for planned outages to maximize capture of tank clean -out waste and routing to recovery; • further reducing clean water that continuously runs into sewers to prevent dilution of smaller spills and facilitate recovery of highly colored wastewaters; and • further improvement in the equipment used for handling of knots rejects to prevent black liquor leaks into the recovery sumps. The plot below shows the color of wastewater treatment influent at the Canton mill. The vari �►v a i uent cold discharge to wastewater treatment is attributed to color discharge pf„I;; , eaks that e t Yn �iii fed spills or leaks discharged to sewers or intentional I jj 1AMitt ogsbol r iquor or other color sources routed to sewers during mill i f11IhUio� 100 kg/t Figure 1 75 Daily color at influent to W WTP for Canton 50 25 0 30 60 90 120 150 180 Due to the nature of the manufacturing processes and practical equipment operation and reliability, all spills and color losses to sewers cannot be fully anticipated, predicted, and completely contained. However, a comparison of the variability of the Canton mill influent color data to available primary influent color data at another bleached papergrade kraft mill indicate that a detailed review of the spill prevention and recovery system at the Canton mill (by mill staff or external consultants), including involvement by the mill operators, can further uncover the causes of and better quantify black liquor losses and other color sources that can be avoided or recovered. This will result in an overall reduction in color discharge, both in long-term average and variability. Through improved planning of mill equipment shutdowns, continuing efforts to minimize process operation variability, and increased recovery of highly -colored leaks and spills, discharges of highly colored material to the wastewater treatment system can be reduced more consistently below existing levels. Further reducing peaks in color discharges within the mill and preventing highly colored flows from reaching the wastewater treatment system will further reduce the variability of color discharges from the wastewater treatment system to the Pigeon River. For example, limiting the color of the primary clarifier influent to less than 70,000 lb/day through continuing efforts to improve the mill's BMP system and process operations would reduce the color loadings from mill processes to the end -of -pipe wastewater treatment system by more than 8,000 lb/day. The . Canton mill operated under this primary clarifier influent color threshold approximately 74 percent of 2000, excluding November through December 2000. This time period was considered not to be representative of steady-state operations because of the reduced pulp production resulting from upgrading the No. 19 bleached paperboard machine. Assuming the average reduction of 45 percent across this wastewater treatment system for "brown" color derived from black liquor, this would result in a minimum decrease of 4,400 lb/day in the average final effluent color load. Clean water, such as packing gland water, presently flows in several sewers with recovery sumps. These colorless streams dilute other colored wastestreams, such as small black liquor leaks {3 spills, to the point where the in -stream conductivity is too low to trigger recovery. By ►,l�r�'' �tre s o d vert3 a av f>o s ers. at GGllee ack quor + s;�,. i,l�l�l{�IF�1�J a '�'l�l`�Ir�. to a r s e e e va c c e e v r_ )m 1 N p �I 1 ! Elf I �I� I��i� in a reduction in color discharJ ' e' c� -6r p pe waste ter lystem. e unintentional but intermittent discharge to the sewer of filtrate from knots and screen rejects can be recovered. PP�4 ;lglf.i),i1�1�i�l �� �II i�lltil'r � I` � �! , yt j I p��:IluuJlla ijJ rSa�I lip, I'llilii,il�)�i 1 �ylbklll.'�a Page 7 At this time, the Tech Team has no basis for determining an accurate correlation between unaccounted color and sewer generated color, as reported in Section 2 of the Canton Mill Environmental Performance Update presented by Blue Ridge during the March 14, 2001 Tech Team Canton mill visit. During the March 14 visit, Blue Ridge staff indicated that results of studies of sewer generated color showed a relationship between bleach plant filtrate pH and temperature and unaccounted color generated in mill sewers. By operating within the range of pH and temperatures identified during the studies the Canton mill has had some success in controlling this source of unaccounted color. Based on this information, the Tech Team concludes that by further reducing process operation variability, including operating within the pH and temperature range identified during the studies, the mill can continue to also minimize sewer generated color, thereby reducing one source of unaccounted color. Reducing overall color discharges through BMPs and other management practices will likely further reduce remaining unaccounted color. However, additional studies are necessary to further develop any relationship between accounted and unaccounted color sources. As noted above, analysis of primary clarifier influent color loading data demonstrates that color loading to the wastewater treatment system of lower than 70,000 lbs/day is possible during steady-state operations. Through continuing efforts to minimize unplanned spills and leaks and efforts to minimize process operation demonstrated in 2000 (i.e., more than 74 percent of the time). In$ d d 1c�)1b]i{�lattr i�IJ p 7'DJ.�l ' I 1 Ozone is used in more than ten kraft mills around the world to bleach pulp, including two in the US and one in Canada. There are several process configurations, but the most common is to operate an ozone (Z) mixer and reactor immediately upstream of a chlorine dioxide reactor, without any washing between the application of the two chemicals. This is known as a "ZD" stage. A system of this type was retrofitted in the Domtar mill at Espanola, Ontario, Canada in 1999.2 Bleaching with ozone on the hardwood line, one of the Domtar mill's two pulp lines, resulted in a 27 percent reduction in the discharge of color in the combined mill treated effluent' The conversion to a ZD stage Munro, Fred and John Griffiths, Operating Experience with an Ozone -based ECF Bleaching Sequence, Tappi, 2000. Ibid. Page 8 would reduce the use of chlorine dioxide and caustic chemicals for bleaching in exchange for ozone. The energy requirements for ozone production would be offset by the energy savings from less chlorine dioxide and caustic production, resulting in a net reduction in energy consumption with the ZD stage. As of September 2000, the long-term average color discharge from Canton's hardwood bleach line was 12,800 pounds/day °. The Espanola experience suggests that implementation of a ZD stage in the hardwood bleach plant at the Canton mill could reduce the filtrate color discharge by 3,000 to 6,400 lbs/day. Based on comments received, the Tech Team acknowledges that operating parameters, such as wood species processed and technology supplier performance guarantees, may influence the practical color reduction achievable through implementation of a ZD stage at the Canton mill, in comparison to the Espanola experience. These estimates are based solely on the demonstrated performance and the Tech Team's assumption of color sources at the Espanola mill, confirmed at the recent Pulp and Paper Technical Association of Canada (PAPTAC) meeting in Thunder Bay, Ontario. Laboratory bleaching trials and possible communication between Blue Ridge and Domtar staff would be necessary to reliably predict the achievable color reduction possible with this option for the Canton mill. The technical evaluation of this process improvement included in the BEPER yielded a hardwood filtrate color discharge reduction within the range of Tech Team estimates. 4 2"d stage OD_for pine line. Oxygen delignifrcation (OD) on the Canton Mill pine line is a single stage system installed in 1993. It has been concluded that retrofitting a second OD stage for the pine line could contribute to reduced color discharges in two ways. The first would be a reduction in color for those filtrates presently not captured and reused in the BFR process. The second would be a color reduction in the Chloride Removal Process (CRP) purge stream as a result of less chloride from chlorine dioxide used for bleaching. Costs were estimated for a reactor with oxygen mixer and chemical charge equipment installed upstream of the existing reactor. Previously, the Tech Team anticipated increasing the kappa number (lignin content) of the cooked pulp from 24 to 32 and utilizing a two -stage OD system to reduce kappa number from 32 to 11, an approximate 65 percent kappa reduction across the two - stage system. Based upon comments from BRP and further technical analysis, and review of the BEPER, it was concluded that it is technically feasible for a two -stage OD system at the Canton Jacobs Engineering Group, 2001 Color Removal Technology Assessment, February 2001. Page 9 mill to achieve an overall reduction of 50 percent in kappa number, rather than 65 percent as pTeviouslvant i te The efore, with the Canton mill continuing to pulp to a kappa number of stda;'uld reduce pulp kappa number into the bleach plant from Eliout o 6ta6 u �j fl � � J "61�� u �t o 1 ,corresponding to a 50 percent kappa number reduction from the current digester output of 24. The quantity of color released from the bleach plant will be reduced in proportion to the reduction of the input kappa number. By decreasing the kappa number of the pulp fed to the bleach plant from kappa 16 to 12 with a two -stage OD system, the quantity of chemicals required in the first two stages of the bleach plant can be reduced, because there is less lignin present in the incoming pulp to remove by bleaching. The reduction in chlorine dioxide used for bleaching would result in a proportional reduction in chloride load to the CRP and reduce color discharged from the purge stream in proportion to the reduction in chloride being treated. In response to comments received, it has been concluded that implementing a two -stage OD system without increasing the kappa number of the cooked pulp from 24 to 32 would not achieve a 1.5 percent pulp yield gain as anticipated with increasing digester kappa number and achieving greater delignification with the proposed two -stage OD system. However, operating a two -stage OD system with a higher than 50 percent delignification rate and a digester kappa number higher than currently employed at the Canton mill is commonly seen at comparable bleached papergrade kraft mills. Therefore, the Tech Team anticipates that additional process engineering will maximize the benefits of a two -stage OD system at the Canton mill and enable the mill to capture the increased delignifcation and yield gain potential of this technology and achieve annual wood cost savings of up to approximate $950,000 from up to a 1.5 percent yield increase across the proposed two -stage OD system. Based on additional information supplied by Blue Ridge regarding operational limitations of the BFR system, the Tech Team concludes that a two -stage OD system would not have a significant impact at this time on the Canton mill's ability to increase BFR closure rate above 80 percent on a day-to-day basis. For this analysis, it was estimated preliminarily that a second OD stage could reduce total influent color discharge to the wastewater treatment system by 1,500 to 2,000 lb/day from reductions in pine line bleach plant filtrate color and CRP purge stream color. Page 10 The technical evaluation of two -stage OD included in the BEPER yielded reduction in color discharge influent to the wastewater treatment system within the range of the Tech Team estimates. 5. Color Treatment of CRP purge stream. The Chloride Removal Process (CRP) purge is a low flow, highly concentrated waste stream. Color is typically 50,000 pcu, in a 10 gpm (0.01 MGD) flow. The CRP purge contributes up to approximately 5,000 lbs/day (13 percent) to the total mill loading to the wastewater treatment system influent, but only 0.06 percent of the discharge flow. It was originally speculated that it may be feasible to reduce the color in this stream by precipitating the colored organic material with lime at a dosage of 20 g/L5, and burning the resulting sludge with the main lime mud stream fed to the mill's lime kiln. Laboratory trials would be necessary to test the feasibility of color removal from the CRP purge stream by lime treatment. Blue Ridge subsequently conducted laboratory trials of color precipitation using four calcium compounds, including lime mud, fresh lime, calcium chloride, and milk of lime. The preliminary results of these trials show that at a dosage of 20 g/L, none of the compounds tested reduced color in the CRP purge stream. Although color removal was demonstrated at higher dosage rates, increased chemical usage would result in substantially higher operating costs, require larger sized equipment at higher capital cost, and also result in a higher production rate of sludge to be burned in the mill's lime kiln. Excess sludge produced from this process that is not burned must be landfilled at additional cost. Based on preliminary laboratory trials, Blue Ridge concluded that lime treatment of the CRP purge is not a feasible color reduction option for the Canton mill. However, the Tech Team recommends additional review of other innovative technologies for treatment of color in the CRP purge stream, such as the application of the X-Filter process recently implemented at a totally chlorine free (TCF) mills. By minimizing color contributions from this stream, the potential exists to achieve a significant reduction in primary influent color discharge of up to 5,000 lbs/day. NCASI Technical Bulleting No. 239, The Mechanisms of Color Removal in the Treatment of Pulping and Bleaching Effluents with Lime. I. Treatment of Caustic Extraction Stage Bleaching Effluent July, 1970. 6 Comments on the Draft Report on Additional Color Removal Technologies and Economic Impacts for BRPP, Hope Taylor, Clean Water Fund of North Carolina, July 18, 2001 Page 11 6. Process Optimization. The BEPER identified sixteen recommendations for optimizing the hardwood and softwood fiber lines, focusing mainly on the current OD systems and bleaching operations. It was estimated that a reduction could be achieved in chlorine dioxide use in the first bleaching stage of up to 27 percent for the hardwood line and 18 percent for the softwood line. The reduction in chlorine dioxide use would result in a bleach plant filtrate color reduction of up to 700 lbs/day from the hardwood line and up to 400 lbs/day from the softwood line. The Tech Team estimated an additional color reduction from the CRP purge stream of 600 lbs/day resulting from the decreased chlorine dioxide usage. At this time, the Tech Team has no means of making an alternative quantitative prediction of bleach filtrate color reduction to compare to estimates presented in the BEPER. Therefore, it is estimated that through efforts by mill staff to maximize the color reduction benefits from the process optimization opportunities identified by Liebergott, et, al., the Canton mill would achieve a total color reduction of 1,700 lbs/day in wastewater treatment system influent. Color Reduction Summary The Tech Team estimates that by improving BFR reliability and black liquor leak and spill collection and control, the Canton mill final effluent will be reduced by more than 5,000 lbs/day. Process optimization, as outlined in the BEPER, would result in a further final effluent color reduction of approximately 1,400 lbs/day. This assumes the average color reduction of 45 percent across the existing wastewater treatment for the CRP purge stream and other "brown" color sources derived from black liquor and no reduction in color from bleach plant filtrates. Table 1 presents a summary of the estimated reductions in final effluent color attainable with the highest certainty by implementing improved BFR reliability, improved BMPs, and process optimization. Page 12 Table 1: Summary of Process Improvements and Associated Color Reductions (Highest Certainty) Process Improvement Influent Final Effluent Color Color Reduction Reduction (Ibs/day) (Ibs/day) 1 BFR reliability improvement -- 1,000-1,200 2 Improved black liquor leak & spill collection and --- > 5,000 control 6 Process Optimization 1,700 1,400 TOTAL FINAL EFFLUENT COLOR REDUCTION >7,400 Additional potential mill improvements to reduce color discharge at the Canton mill were also identified. These process improvements require further study to more accurately determine achievable color reduction and thus are not recommended at this time for immediate implementation. These improvements include a ZD stage in the hardwood bleach plant, with a preliminary estimate of a 3,000 to 6,400 Ibs/day color load reduction in influent to the wastewater treatment system, and a second OD stage for the pine line, with a preliminary estimate of a 1,500 to 2,000 lb/day color load reduction in influent to the wastewater treatment system. Table 2 presents a summary of preliminary estimates of color reductions for these two additional process improvements that need further study. Reductions presented in Table 2 are preliminary estimates with reduced certainty compared to those presented in Table 1, but are based upon identified technology options available for the Canton mill. Page 13 Table 2: Summary of Process Improvements and Associated Additional Color Reductions Needing Further Study (Reasonable Certainty) Process Improvement Influent Final Effluent Color Color Reduction Reduction (Ibs/day) (Ibs/day) 3 Ozone/Chlorine Dioxide stage for hardwood bleach 3,000-6,400 3,000-6,400 line 4 2"d stage OD for pine line 1,500-2,000 1,100-1,400 TOTAL FINAL EFFLUENT COLOR REDUCTION 4,100 - 7,800 Table 3 presents a preliminary estimate of color reduction potential for the removal of color from the CRP purge stream. The Tech Team recommends this stream for additional review of potential color reduction technologies but cannot identify a particular technology option at this time. Potential for additional color load reduction up to 2,750 Ibs/day in final effluent to the Pigeon River. Table 3 presents potential color reduction estimates with the lowest certainty. Table 3: Summary of Additional Potential Color Reductions Needing Further Study Process Improvement (Lowest Certainty) Influent Color Reduction I EFFLUENT COLOR Final Effluent Color Reduction (Ibs/day) #2,750 #2,750 Page 14 Economic Analysis The estimated capital and operating costs for the process improvements one through four were estimated and are summarized below. Costs could not be developed at this time for process optimization or CRP treatment and thus are not presented. However, costs for these improvements should be modest. Table 3: Estimated Costs Process Improvement Capital Cost Annual O&M ($) ($/year) 1 BFR reliability improvement $1,300,000 $85,000' 2 Improved black liquor leak & spill collection and $100,000 $50,000 control 3 Ozone/Chlorine Dioxide stage for hardwood bleach $1,500,000 ($350,000) line savings 4 2"d stage OD for pine line $2,000,000 ($2,100,000) savings Blue Ridge Paper Products Inc. was formed in May 1999 with the purchase of seven plants (including the Canton Mill) from Champion International Corporation. Blue Ridge Paper Products is owned 55 percent by KPS Special Situations Fund, L.P. and 45 percent by the employees of Blue Ridge Paper through an employee stock ownership plan. At the time of the 1997 report EPA documented substantial losses over five years for the Canton Mill and Champion had just announced its intention to sell or close the mill. However, because of the sale of the mill to the Blue Ridge, the previous data are not comparable to the more recent data. Further, the data submitted by Blue Ridge is still confidential, so this report cannot present as much detail as the 1997 report. The current analysis is based on information submitted by Blue Ridge covering part of 1999 (May -December) and all of 2000 (all of the existing financial data for the company). The XgkOP may be relatively uncertain because of the lack of data and the company may be too See data to reflect its ultimate financial health. EPA used three measures of cash flow, and Altman's Z)7 to assess the impact of EPA 823-B-95-002, March 1995, and Pollutants for Source Category: Pulp a and New Source Performance Page 15 air emissions control technologies and devices (not addressed in this memorandum, such as MACT II and regional NOX control) and wastewater compliance costs (separate and combined) on the mill and company. The costs for the wastewater control options presented in Table 3 do not change the financial status of the mill or company. However, the costs for some of the air emissions control options do impact the health of one or both entities. When the wastewater costs are added to costs for air emissions control, the impacts of the water costs do not change the financial status of either the mill or company when compared to the impact of the air costs alone. References Blue Ridge Paper Products, Inc. Canton Mill Canton Mill Environmental Performance Update, Prepared for U.S. EPA Technology Review Workgroup. March 14, 2001. Blue Ridge Paper Products, Comments on and Transmittal of Financial Data for Economic Analysis of Blue Ridge Paper Products, from Bob Williams, May 18, 2001 (CBITS 00003911- 01) Comments on Preliminary Draft Final Tech Team Report, email from Derric Brown, Blue Ridge, to Don Anderson, EPA, May 18, 2001 Comment Clarification of May 18, 2001 Blue Ridge Responses to EPA Questions, from Derric Brown, Blue Ridge, June 4, 2001 Comments on Draft Final Tech Team Report, from Bob Williams, Blue Ridge, to Don Anderson, EPA, July 13, 2001 Comments on Draft Final Tech Team Report, from Derric Brown, Blue Ridge, to Don Anderson, EPA, July 17, 2001 Comments on Draft Final Report, email from Forrest Westall, North Carolina DENR, to Don Anderson, EPA, July 17, 2001 Comments on Draft Final Report on Additional Color Removal Technologies and Economic Impacts for BRPP, Hope Taylor, Clean Water Fund of North Carolina, July 18, 2001 Comment on Draft Final Tech Team Report, email from Paul Davis, State of Tennessee, to Don Anderson, July18, 2001 Comment on Draft Final Tech Team Report, email from Lew Shackford and Norm Liebegott, to Don Anderson, EPA, July 19, 2001 Jacobs Engineering Group, 2001 Color Removal Technology Assessment, Blue Ridge Paper Products Inc. Prepared for The North Carolina Division of Water Quality. February2001. Liebergott, Norm, and Lew Shackford, Bleach Environmental Process Evaluation and Report, June 8, 2001 McCord, Aimee, A Laboratory Analysis of Color removal Across a Pulp and Paper Mill Wastewater Treatment Facility, Canton, North Carolina, Duke University, School of the Environment, 1995 Munro; Fred and John Griffiths, Operating Experience with an Ozone -based ECF Bleaching Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press. NCASI Technical Bulletin No. 239, The Mechanisms of Color Removal in the Treatment of Pulping and Bleaching Effluents with Lime. I. Treatment of Caustic Extraction Stage Bleaching Effluent. July, 1970. Salisbury, Chad A Laboratory Analysis of Color Removal Mechanism Across the Wastewater Treatment Facility of a Pulp and Paper Mill, Canton, North Carolina, Duke University, School of the Environment, 1996 i.d 1y{ ;._"nl_+_ii"ll.il'.k�i'Ili r. �.r _� r�._.:_r ne._�n__—._i n_.i_tort �'11Cy CC I1GC 1700' 1r1 .�{ 1 r:I J(4olX a1 rri , -. r�81Ci1 SI �J �� �, r, 17,' f' (I)}�»,pl�tr W*vlr 1`�!�I''' i I,J11 `1 � ;'=� lj rJ.f i iy�r1 ' ' �l) R9 �° .. " �I, �l rd �Sprin2er Alan M. ed. Industry1't Urot P P. : on 1 i �, o sr 1 1 d 3 a it Il�f ' �� ���(� ����,r(#�N�����������r � v ItO Appendix 1: Color Balance (9/1/00 to 12/31/00) Figure 2.6, Presented by Blue Ridge on March 14, 2001 Sewer ID I Description Color Load (Ibs/day) 213 Digester area sewer: Digesters, HW line, knot rejects 4,323 3A Alkaline sewer: Pine and HW Eo, Pine line BSW, 02 Delig 12,954 1 PMs1 1 & 12, HW weak liquor tank 1,991 513 Recovery, BLOx, CRP* 7,852 6A Acid sewer: Pine and HW D1 filtrate + Pine D2 filtrate 17,345 Contaminated Condensate 1,591 Combined Condensate 260 Total .46,316 Primary Influent (RI) 49,284** Unaccounted Color (PI minus Total) 2,968 Secondary Effluent 37,696 Percent Removal in Treatment 23 CRP contributes 5, 000 to 6, 000 Ibs/day to 5B sewer ** Measured using test method in NCASI Tech. Brill. 803, An Update of Procedures for the Measurement of Color in Pulp Mill Wastewaters, May 2000. Appendix 2: Table of Effluent Color Limits,1997 to Present Color Limit Trite Color (lbs/day) Monthly Average Annual (Long-term) Average 1997 Permit 125,434 98,168 Settlement Agreement, February 1998 (starting December 1, 1998) 69,000 60,000 Settlement Agreement, February 1998 (Ultimate Target) --- 48,000 to 52,000 Interim Limits, May 2001 * 55,000 48,000** As recommended by Technology Review Workgroup (TRW) and incorporated by NC in BRP's NPDES permit. ** Reduced end -of -pipe color discharges since November 2000 reflect, in part, reduced pulp production (approximately 30 percent) during this period because of the ongoing project to upgrade the No. 19 paper machine used to produce bleached paperboard. Appendix 3: Ozone Bleaching Munro, Fred and John Griffiths, Operating Experience with an Ozone -based ECF Bleaching Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press. Appendix 4: Two -Stage Oxygen Delignification Comparison of one- and two -stage oxygen delignification systems Item Current Single -Stage System Proposed Two -Stage System Oxygen Reactors One two Input Kappa Number 24 24 Output Kappa Number 16 12 Total C102 Used 28 kg/ton* 22 kg/ton* Oxygen Used 23.4 kg/ton* 28.3 kg/ton* Total NaOH Used 45 kg/ton* 37 kg/ton*,. * air-dried metric ton of bleached pulp