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NC0000272_USEPATechReviewWorkgroup_20010314
i 1 Canton Mill Environmental Performance Update Prepared by: Blu.e-Ridge Paper Products Inc. Canton Mill Prepared For , USEPA Technology Review Workgroup March 14, 2001 ' 4 I i ` i 1 I I BLUE RIDGE PAPER PRODUCTS INC. v March 5, 2001 Mr. Don Anderson U.S. Environmental Protection Agency Mail Code 4303 Room 195A, East Tower 401 M Street, SW Washington, D.C. 20460 Re: Technology Review Workgroup's request dated February 23, 2001 Dear Mr. Anderson: Enclosed is the information you requested for the Technology Review Workgroup's March 14, 2001 meeting with Blue Ridge Paper Products Inc. We are pleased to share our progress and look forward to your visit to the Canton Mill. Per your request,pulp production for the Canton Mill averagl d 1,317 ADTP (Air Dry Tons Pulp)for 1999 and 2000 and paper and paperboard production averaged 1,543 tons per day. Pulp production capacity is 1,420 ADTP. Please do not hesitate to contact me at(828) 646-2033 if there are any questions. Sincerely, a e4*V, w� Robert V. Williams Director—Environmental, Health and Safety Affairs- xc: Technology Review Workgroup 175 Main Street • P.O. Box 4000 Canton, North Carolina 28716 • Phone:828-646-2000 Raising Your Expectations ,. � ; �, , .,r , . BLUE RIDGE PAPER PRODUCTS INC. Copy: Betsy Bicknell Eastern Research Group Avion Lakeside Dr. 14555 Avion Parkway Chantilly,VA 20151-1102 I Dan Bodien 10048 138`h Avenue NE Kirkland, WA 98033 i Neil McCubbin N.McCubbin Consultants,Inc. 140 Fisher's Point I Foster, Quebec CANDA,JOE IRO Mr.Paul Davis,Director TN Department of Environment and Conservation 1 Division of Water Pollution Control 6thFloor,L&C Annex 401 Church Street Nashville,TN 37243-1534 I Mr. Dave Goodrich NPDES Unit Supervisor NC Division of Environment and Natural Resources 512 North Salisbury Street Raleigh,NC 27604 Mr.Keith Haynes Water Quality Section Asheville Regional Office 59 Woodfin Place Asheville,NC 28802 Mr.Dave McKinney TN Wildlife Resources Agencies Ellington Agricultural Agency Center P.O.Box 40747 Nashville,TN 37204 Karrie-Jo Shell EPA—Region IV 61 Forsyth Street SW Atlanta, GA 30303-3104 Mr.Forrest Westall Water Quality Section Asheville Regional Office 59 Woodfm Place Asheville,NC 28802 1 I �1; I --- I -!-9/9--733�sa�-3.�rJ- 6083 YSoB - ----- �Di)1/e_.G'oop�!c•H - -—,��t/C1//�/�DG's� �9/9 733-�3�. 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Canton Mill C i Prepared For USEPA Technology Review Workgroup March 14, 2001 i Table of Contents Executive Summary Canton Mill Secondary Effluent Color Performance Ciart Section 1: Wastewater Characteristics Monthly Average Data Summary for 2000 - Figure 1.1: Secondary Effluent Color Performance Figure 1.2: Secondary Effluent Color(Ibs/day) - Figure 1.3: Secondary Effluent Flow (MGD) - Figure 1.4: Primary, Influent Color (Ibs/day) - Figure 1.5: True Color in the Pigeon River I t State Line - Figure 1.6: True Color in the Pigeon River at Hepco - Figure 1.7: Primay Influent BOD (Ibs/day) - Figure 1.8: Secondary Effluent BOD (Ibs/day) - Figure 1.9: Secondary Effluent AOX (kg/tonne) - Figure 1.10: Primary, Influent TSS (Ibs/day) - Figure 1.11: Secondary Effluent TSS (Ibs/day) - Figure 1.12: Secondary Effluent COD (Ibs/day) - Figure 1.13: Secondary Effluent Chronic To: (NOEC %) Section 2: Mill Color Balance— 1996—2000 Annual Average PI, SE and Unaccounted Color (Ibs/i ay), 1996 -2000 - Figure 2.1: 1996 Mill Sewer Color Pie Figure 2.2: 1997 Mill Sewer Color Pie i �! Figure 2.3: 1998 Mill Sewer Color Pie - Figure 2.4: 1999 Mill Sewer Color Pie - Figure 2.5: 2000 Mill Sewer Color Pie - Figure 2.6: New NCASI Color Method vs I ill Sewer Data Section 3: In-Mill Sewer Areas i Color Reductions in Mill Sewer Areas over 1996 NPDES Permit term Canton Mill Sewer Diagram i - Figure 3.1: #1 Sewer Color(1,000 Ibs/day) - Figure 3.2: #2 Sewer Color Concentrationi(mg/1) - Figure 3.3: Combined Condensate Color(Ibs/day) - Figure 3.4: Contaminated Condensate Color(Ibs/day) - Figure 3.5: 213 Sewer Color (Ibs/day) - Figure 3.6: 3A Sewer Color (Ibs/day) - Figure 3.7: Hardwood Eo Recycle Rate (gpm) - Figure 3.8: 513 Sewer Color(1,000 Ibs/day) - Figure 3.9: 6A Sewer Color (1,000 Ibs/day) 1 Section 4: BFRTM Update - Figure 4.1: BFR % Closure Figure 4.2: MRP % Uptime - Figure 4.3: CRP Sewer Color(Ibs/day) - Figure 4.4: CRP Purge Rate (gpm) I March 14, 2001 TRW Visit I Canton Mill Blue Ridge Paper Products Inc. i I Section 5. June 11 1998 Report - Section 6:Low Flow Contingency Plan Section 7: Eo Recycle Evaluation Section 8:January 1, 2001 Color Limit Feasibility Report i I I i I _ I i I i I March 14, 2001 TRW Visit Canton Mill Blue Ridge Paper Products Inc. i i Executive Summary Blue Ridge Paper Products Inc. - Ca ton Mill March 14, 2001 Technology Review Workgroup Visit i This information summarizes the! important color reduction activities that have been accomplished over the term of the 1996 NPDES, Permit. The information focuses on effluent color and is responsive to the Technology Review Workgroup's requests. Since the issuance of the Permit, the Canton Mill has unldertaken 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. ' I 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 Ito 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 I � I i Mill could comply with a color limit within the range of 48,000-52,000 C1, : lbs. per day (annual average). + Implementation of these BMP's, together with improved (mill operations, has reduced color by 32% over the term of this NPDES Permit (see attached graph and Section 3). As described in the January 1st, 2001 Report, the mill has achieved a target annual average color loading of 48,000 —52,000 pounds per day. Based on data received from the National Council on Air and Stream Improvement (NCASI), the Canton Mill has the lowest color of any mill in our industry category. i In addition to the aforementioned activities, Blue Ridge has conducted the following activities: In an effort to identify either al breakthrough improvement in color removal --efficiency-or-reduction-in-cost,-Ihe-mill-has-evaluated-end=of=pipe-color-reduction technologies three times in the past thirteen years. It is clear that, among these prescribed end-of-pipe color removal technologies; no breakthrough in economic or technical feasibility is likely to occur. During this same thirteen year period, however, f alternative technologies (including oxygen delignification Elemental Chlorine[ Free bleaching, Bleach f _ Filtrate Recycle and those technologies comprising the "Near-Term" package) ( were implemented resulting in significant improvements. (See Section 2, Mill Color Balance.) Therefore, based upon this record, it is Blue Ridge's intention in the future to focus primarily on the potential treatment of selected, colored wastewater streams before they enter the wastewater treatment plant (VWVfP). These wastewater streams (See Section 3, In-Mill Sewer Areas) hold the greatest likelihood of success for future color reduction, and Blue Ridge believes its time and resources would be better devoted to in-mill treatment of particular wastewater streams. Polyamine trials have recently been conducted at the primary clarifier, secondary clarifier, and colored in-mill wastewater streams. Numerous trial approaches were conducted to comprehensively study the effectiveness of polyamine for color removal. While treating colored wastewater streams in the pulping and recovery area appeared to remove color, the color bodies re-solubilized and there was no significant reduction in secondary effluent color. Treating the primary clarifier resulted in color reductions, but sludge quality declined to an unmanageable condition and recycled belt press filtrate solids increased significantly. Treating the secondary effluent resulted in color reductions; however, this type of treatment would require the installation of equipment and increased operating costs. � I Canton Mill Secondary Effluent Color Performance Annual Averages: 1988 -2000 400,000 Including Permit Limitations Peffnit Limitations: 350,000 1-258.945#1d Monthly Ave,off.4114/94 2-172,368#/d Annual Ave.off.4/14194 3-125,434#/d Monthly Ave.off.12/12/96 4-98,168#/d Annual Ave elf.12/12/96 6-95,000#/d Monthly Ave eff.1/1198 300,000 6-69,000#/d Monthly Ave.off.1211198 a 7-60,000#/d Annual Ave.off.12/1/98 7 8-48.000-52,000#1d Target Annual Ave N _250,000_ 0 u d 200,000 0 E w . 9 150,000 2 C 0 u 100,000 T - -- 50,000 6 7 8 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 Permit Limitaions t SE Color Annual Ave. #/d Blue Ridge Paper Products, Inc. Canton Mill 3/5/01 Section 1 Wastewater Characteristics i i The attached graphs review the Canton Mill's primary influent and secondary effluent monitoring data for the past year (2000). There are also graphs of true color in the Pigeon River at the Hepco station (River Mil i 42.6) and the NC/TN state line (River Mile 24.7). Since October of 1996, true color in the Pigeon River at Hepco has been less than 50 mg/I at all monthly average river flows greater than 330 cfs (as described in paragraph 25 of the Settlement Agreement). At the state line, true color in the Pigeon River has a monthly, average of 22.8 color units and has been less tharr 50 color units for the i ntire 1996 NPDES Permit term. I I ! ! i ! i Section 1 -Wastewater Characteristics Monthly Average Secondary Effluent and Primary Influent Data Jan -Dec 2000 PI TSS Ibs/day SE TSS Ibs/day PI BOD Ibs/day SE BOD Ibs/day SE AOX kg/kkg SE Color(Ibs/day) Jan-00 157,309 3,951 78,034 1,401 0.080 42,326 Feb-00 144,998 2,496 71,587 991 0.064 43,418 Mar-00 136,228 3,696 76,249 1,277 0.134 45,449 Apr-00 140,561 3,330 82,344 1,191 0.074 43,099 May-00 164,232 3,686 86,704 1,312 0.241 53,019 Jun-00 161,731 2,891 81,506 1,174 0.095 58,009 - Jul-00 134,064_ _ 3,183 81,621 940 0.088 43,296 Aug-00 141,122 2,623 - - - 76,012 -- -- ---- 1,188 - -- 0.092- - 41-;290- - -- --- - _ Sep-00 143,061 2,023 44&,41*4 867 0.091 39,670 Oct-00 184,592 2,226 72,748 923 0.058 38,793 Nov-00 190,217 2,327 68,099 733 0.040 33,693 Dec-00 171,201 2,705 78,053 1,270 0.202 38,564 Blue Ridge Paper Products Inc. Canton Mill 3/5101 Canton Mill Secondary Effluent Color Performance Annual Averages: 1988 - 2000 400,000 Including Permit Limitations Permit Limitations: - 350,000 1-258,945#id Monthly Ave,off.4114194 2-172.368 Wd Annual Ave.off.4114194 3-125.434#1d Monthly Ave.off.12/12/96 4-98,168#/d Annual Ave eft.12112/98 6-95,000#/d Monthly Ave off.1/1198 306,000 6-69,000#/d Monthly Ave,elf.12/1198 r 7-60.000#/d Annual Ave.off.12/1198 7 8-48.00052.000#/d Target Annual Ave N 250,000 o --- -- -- - - -- - - --- -- - ---- - - - --- G d 200,000 0 IK w v150,000 2 c u w- —3- 100,000 50,000 6 7 8 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 Permit Limitaions t SE Color Annual Ave.#/d Blue Ridge Paper Products, Inc. Figure 1.1 Canton Mill 314/01 Secondary Effluent Color (Ibs/day) from Daily Composite 1996 - 2000 300000 "Pre" (1996 and 1997)Average=72,585 Ibs/day "Post'(1999 and 2000)Average=42,221 Ibs/day See Section 3 for Pre to Post discussion. 250000 200000 R 'O N a 150000 0 6 n 100000 50000 - 0 6 6 6 0 0 0 1 \ \ l 1 O O O m 0 0 0 9 9 °� 0 0 0 O O O O O NO ^\9 NO ^\q ^\9 N\9 ^\9 N\9 NO ^\9 �`\� �`\� 4 Ks ^\q ^\q ^\q N\9 ^\9 N\q ^\9 ^\9 ^\9 ^\9 ^\O ^\O ^\O ^\O ^\O ^\O N\ 3\ y\ A\ g\ ^,\ N\ 4 4 A\ o,\ ^\ ^\ 3\ y\ A\ e,\ ^,N\ N\ 'b\ y\ t\ e,\ .\ �\ y\ y\ �\ �\ ^^\ —39-Sec Eff Color Blue Ridge Paper Products Inc. 3/5/01 Figure 1.2 Canton Mill Secondary Effluent Flow in mgd for the Canton Mill Monthly Averages from 1/88-12/00 50.0 45.0 ----- -- ----- ---- -- ---- -- ---------------------------------------------------------- ---------------------------------------------------------------------- ................ 40.0 -------------------------------------------------------- ------------------ ------------------------------------------------------------------------------------------------------------------------------ ----- — ----- -- Q 35.0 ----------------------------------------- ------------------------------- --------------------------------------------------------------------------------------------------------------------- a - 0 F` Permit Limit = 29.9 mgd as of 1/1/97 30.0 -------------------------------------------------------------------------------------- -------------------- ------------------------------------------------------------------------------------------- 25.0 -------------------------------------------------------------------------- ------------------------- -- --- -------------- ----- ------------------- ........... ----- 20.0 mob\ 01 90 A0 00 00 9P°P'P'b )°0�)acPQ�)J\�°�)QCPQ�)J\0�)°cPQ�)J`0�)9cPQ�)J`0�)acPQ�)J 0�)acPQ�)J\o�)acPQ�)J\0�)0cQQ�)J\0�A, )J\0�)9cPQ�)J`0�)OCPQ�)J`0�)9cP�� Blue Ridge Paper Products, Inc. Canton Mill Figure 1.3 MSH 3/4/01 Primary Influent Color (Ibs/day) from Daily Composite 1996 -2000 500000 "Pre"(1996 and 1997)Average= 94,345 Ibs/day 450000 "Post"(1999 and 2000)Average;55,998 Ibs/day See Section 3 for Pre to Post discussion. 400000 350000 300000 - - - - -- --- -- -- --- m 9 N a 250000 0 u 200000 150000 100000 50000 00- 0 ^\90^\9h ^\gh ^\0j6 ^\96 ^\�b ^\�A ^\9A ^\9A �\�A ^\�A ^\9,t ^\5P^\XP ^\5P ^\5P ^\5P ^\5P ^\CP^\4b ^\4b ^\4b ^Op ^\9g ^\oo^\oo ^\oo ^\oo ^\oo ^\oo ^\ ey\ h\ A\ 0§ ^^\ ^\ y\ h\ \\ o,\ ^^\ ^\ h\ h\ A\ 0\ ^^\ ^\ `y\ h\ �\ g\ ^\ \ "'\ h\ �\ °'\ ^�\ —38-Pri Inf Color Blue Ridge Paper Products Inc. 3/5101 Figure 1.4 Canton Mill i r TN 140 & SLc Actual Measured Color in the Pigeon River at the NC/TN Line for the Canton Mill 225 Including Background River Color(Upstream of Mill) Monthly Averages from 1/88-12/00 200 175 J E 150 v C 0 _ 125 - - - r c m 100 0 U `0 75 0 U — ------50- 25 0 00 O W O O O N N (M CM R C' LO LO (O r�- rh O Ou O m O O 00 O O O m W O 111 T W d) O O O O m O T O O O O O O O C > C > C > C > C C C > C > C C ] C > C C C C OJ � N -� O7 ' O7 -� (0 � fQ ' IO ' f0 ...� (0 ' OJ ' 0 � Co ' 07 � -w-ACTUAL MEASURED TN140 CLR ST mg/1 mon avg --*--Canton Color Blue Ridge Paper Products, Inc. Figure 1.5 Canton Mill MSH 3/4/01 Pigeon River True Color (mg/L) Hepco Monthly Average Data: 1988 - 2000 360 300 250 m 200 - E 0 0 150 100 50 0 RP R0 a 9�90 90 p�^ ary 9ry CP (P OIN 9b 9h 96 90 96 5' a' q1, q1) 41 90 A O 00 �a� ��� �aK ��� lac ��� ��� ��� �a� �w ��� �w lac ��� lac —Hepco Sp.T Color Blue Ridge Paper Products Inc. Figure 1.6 Canton Mill 3/5/01 Primary Influent Biochemical Oxygen Demand (BOD) Ibs/day Daily Values: January - December 2000 160000 140000 120000 --- --- --- -- - -- - -- ----- 100000 - - -- - - --- — - - ---- - A 9 60000 O O Go 60000 40000 — — 20000 0 ^\^\pp\^\ppOO�`16\p�\^^\ppry\`th\pp p\$\pp �pp�\6\O`tp\pp6\\p6\^\pp^\^\p�\^h\p0\�9\pp�\^�pp�\�6\pp°j\9\po,\ry5\pOp�\ppp\�N ^\p�pp\^��p0�\ry�p0'6�p0Cj —�Pri Inf BOD Ibs/day Blue Ridge Paper Products Inc. Figure 1.7 Canton Mill 3/4/01 -n co m � BOD Ibs/day I OD coO CD CAc. N N W W A A CD Cn O CA O CYI0 O Cn O Cn ,I CD 0) O O O I O O O O O O O (D 1/1/00 0 1/15/00 o. CO) N 1/29/00 ,0 2/12/00 I d 2/26/00 I 3/11/00 I m 3/25/00 4/8/00 � W 4/22/00 CD 0 m 5/6/00 co C � 3 5/20/00 0 y O 0 6/3/00 L 6/17/00 C 7/1/00 (D i7/15/00 p cn CD 7/29/00 0 CD 8/12/00 a 0 8/26/00 CD ' N ca 9/9/00 c p 9/23/00 10/7/00 I Q i sv 10/21/00 . sv 11/4/00 Q 11/18/00 12/2/00 12/16/00 12/30/00 O (n �I, j N N CA) W A A Cn O, Cn O Cn O m O Cn O La BOD mg/1 . � I 0 Blue Ridge Paper Pruuuids,Inc: Canton,NC Adsorbable Organic Halide Levels in Secondary Effluent Once per Week Data from 1/95- 12/96 Monthly from 1/97- 11/00 1.000 0.900 ------------------- Cluster Rule Daily Max = 0.951 kg/tonne --------------------------------------------------- -------------------------------------------------- 0.s0o ------------------------------------- -------------------------------------------------------------------------------- -------------------------------- -------- _------- ------------------------------------------------------ 0.700 ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- - 0.600 --__ _-_—- --------------------------------------- ------------- - ----------------------------------- .......--.....------------ ----------------- ----------------- q 0 0.500 ------------------------------------------------------------------------------------------------ -------------------------------------------------------------------------------------------------------------------=------------ 0 0.400 ------------------------------------------------------------------------------------------------ ------------------------------------------------------------------------------------------------------------------------------- 0.300 ------------------------ ------------------------------------ ---------------------------- - -------------------------- --------------------------------------------------------------------------------------------------- 0.200 1 r-------------- ------ - --= - .--- ----- --------- ---- ----- --------------- - ---------- 0.100 - ------ ------- --------- - ----- -- - ----- ------------------------------ ------ ------- ---- - . .... .......... 0.000 t SE AOX kg/tonne pulp —Final Cluster Rule Figure 1.9 MSH 3/4/01 Primary Influent Total Suspended Solids (TSS) Ibs/day Daily Values: January - December 2600 a0000o 700000 600000 --- ----- - —----- ----- --- - m 9 a_ 400000 y 300000 200000-. - - A- — 100000 0 �Ory�`LrO\oo„���^\O3�`lh\OO P��\o0�`Laoo�i�rO\Oyu`i�\oo6��\06�'`\OO'1�^\O��'`h\O��`19\OO��'`�OO��`16\000��'\o9�`v�\oo0�\00��`'^\OO �\OO��`�\OO�ry\OOOO �Pri InfTSS Ibs/day Blue Ridge Paper Products Inc. Figure 1.10 Canton Mill 3/4/01 Secondary Effluent Total Suspended Solids (TSS) Ibs/day Daily Values: January - December 2000 25000 20000 m v Vi N N ~ 10000 5000 0 ^\^\000\ry ^`�o,�ry6\o�\^^\o�\ry`'\oo p\�\oo\ry ooy\6\oy\ry°\oo6\b\06\^A\4z, N\cj <O\o�\ry9\o�\^o�\ry6\, 0,\o 'b 9\ry <c\oo\ry^\oo^\b\oo\^�\00'��0�^6\0��4, +Sec Eff TSS Ibs/day Blue Ridge Paper Products Inc. Figure 1.11 Canton Mill 3/4/01 Secondary Effluent Chemical Oxygen Demand (COD) Ibs/day 2000 Data 120000.00 100000.00 80000.00 A L 60000.00 0 0 L) 40000.00 20000.00 - 0.00 ^\r000\ryo\ooao\(Z- X\4z, 00\P \^013 \'50\00\^14 0 A\o \^11 \13 \�h\o, 0136\ry1P ro\lj (30, 15\13 A\oo\^\000\^a\000\ry�\000\^�000\ry6\oo^\9\00\���0o��\ory\ry^\oo +Sec Eff COD Ibs/day Blue Ridge Paper Products Inc. Figure 1.12 Canton Mill 3/4/01 Summary of Historical,Toxicity Data from 1998-2000 Results of 7-Day Ceriodaphnia Survival and Reproduction No Observable Effect Concentration (NOE6 Sample Date NOEC % Effluent 3/23/98 100 618/98 100 9/7/98 100 12/14198. 100 3/8/99 100 6/14/99 ; 100 10/14/99' 100 12/6199 75 12/28/99, 100 2/14/00 100 3/10100 100 6/5/00 100 9/11/00 100 12/11/00 100 I Testing performed by Burlington Research Laboraoty 1302 Belmont Street Burlington, NC 27215-6935 (336) 670-6935 i Blue Ridge Paper Products Inc. I Canton Mill Figure 1.13 i i I Section 2 Mill' Color Balance j 1996 — 2000 Annual Average Color (Ibs/day) Primary Influent Secondary Effluent Unaccounted Color' 1996 101,205 82,851 38,824 1997 87,485 62,318 33,601 1998 69,204 50,123 21,847 1999 54,437 41,086 3,740 2000 57,558 43,355 10,732 New NCASI Method 9/00 — 12/00 43,853Z 0 (-2,463)Z I 'Unaccounted Color is comprised of: sewer generated color (SGC), turbidity interference and unmeasured color. 2Using the newly developed NCASI Color test method to remove the interference of turbidity on the Primary Influent, the unaccounted color for this period is actually -6% (-2,463 Ibs/day). Using the standard NCASI color test method, unaccounted color for this same period is 6% (2,968 Ibs/day). Note: Figure 2.6 average Primary Influent and Secondary Effluent colors given for 9/00 through 12/00 are from the standard NCASI Method. The attached graphs demonstrate the Canton Mill's coli r performance per sewer area since 1996. i I I 1996 Average Measured Color in Mill Sewers as a Percentage of Primary Influent Color Annual Average PI Color= 101,205 Ibs/day •~Potential Sources of Annual Average SE Color= 82,851 Ibs/day Unaccounted Color: 1. Sewer Generated Color 2. Turbidity interference 15% 3. Unmeasured areas of the Mill. Z - � V op ri 02B- Digesters, No. 1 FL: 15,493 ppd lN•y _y3 J 14% M 3A- No. 1/2 Eo, No.2FL BSW, 02 Delig: 14,398 ppd a 0 PM's- 11 & 12: 3,358 ppd p E 513- Recovery, BLO,CRP: 6,773 ppd Ak€ ■ 1&2 FL's D1 + Pine D2: 22,359 ppd -- --- -3%0 Unaccounted:_38,824-ppd_—__ x _ O �\} 7% 22% Blue Ridge Paper Products Inc. Figure 2.1 1996-00 in-mill colors MSH 3/4/01 1997 Average Measured Color in Mill Sewer Areas as a Percentage of Primary Influent Color Annual Average PI Color= 87,485 Ibs/day Annual Average SE Color= 62,318 Ibs/day Potential Sources of Unaccounted Color: 1. Sewer Generated Color 2. Turbidity interference 0% 3. Unmeasured areas of 12% the mill. ; W �R � �� c� � ■2B- Digesters, No. 1 FL: 10,34.2 ppd _ 39% a ;� 16% ■ 3A- No. 1/2 Eo, No.2FL BSW, 02 Delig: x: 14,122 ppd S PM's- 11 & 12: 5,120 ppd -;' �� x t 19 513- Recovery, BLO,CRP: 10,871 ppd n, ■ 1&2 FL's D1 + Pine D2: 13,407 ppd 6% E3 Unaccounted: 33,601 ppd 12% 15% Blue Ridge Paper Products Inc. Figure 2.2 1996-00 in-mill colors MSH 3/4/01 1998 Average Measured Color (Ibs/day) in Mill Sewers as a Percentage of Primary Influent Color PI Color = 69,204 Ibs/day Potential Sources of Unaccounted Color; SE Color= 50,123 Ibs/day 1. Sewer Generated Color 2. Turbidity interference 3. Minor, unmeasured areas of the mill. 10% a r t 3, 111111213- Digesters, No. 1 FL: 7,222 ppd 32% - N 3A- No. 1/2 Eo, No.2FL BSW, 02 Delig: 12,715 ppd 0 Lb 3(fi� t 4 18% El PM's- 11 & 12: 2,658 ppd e , N 5B- Recovery, BLO,CRP: 9,787 ppd E ■ 1&2 FL's D1 + Pine D2: 11,128 ppd ■Contaminated Condensate: 2,780 ppd -- ----- - -- — 4% 2% 0Combined Condensate: 1,066 ppd 4% 0 Unaccounted: 21,847 ppd 14% 16% Blue Ridge Paper Products Inc. Figure 2.3 Canton Mill MSH 3/6/01 1999 Average Measured Color(Ibs/day) in Mill Sewers as a Percentage of Primary Influent Color *" Potential Sources of Unaccounted Color: PI Color = 64,437 Ibs/day 1. Sewer Generated Color SE Color = 41,086 Ibs/day 2. Turbidity interference 3. Minor, unmeasured areas of the mill. 1% 7% 10% 4% ' ■2B- Digesters, No. 1 FL: 6,566 ppd ■ 3A- No. 1/2 Eo, No.2FL BSW, 02 Delig: 12,316 ppd a 3is`e M PM's- 11 & 12: 2,090 ppd 23% ® @B- Recovery, BLO,CRP: 13,320 ppd 27% ■ 1&2 FL's D1 + Pine D2: 14,819 ppd —_ ■Contaminated Condensate: 2,039 ppd ❑Combined Condensate: 547 ppd 4% ❑Unaccounted: 3,740 ppd 24% Blue Ridge Paper Products Inc. Figure 2.4 Canton Mill MSH3/4/01 fJ G :7 rl .- 4KN 2000 Average Measured Color(Ibs/day) in Mill Sewers as a Percentage of Primary Influent Color PI Color= 57,558 Ibs/day Potential Sources of Color = 43 355 Ibs/da Unaccounted Color: SE C � Y 1. Sewer Generated Color 2. Turbidity interference 6% 3. Minor, unmeasured areas of the mill. 19% r s, 028- Digesters, No. 1 FL: 3,687 ppd 19% h N 3A- No. 1/2 Eo, No.2FL BSW, 02 Delig: 11,021 a o d - - 3% O PM's- 11 & 12: 2,666 ppd i 4v M 513- Recovery, BLO,CRP: 11,500 ppd 0 1&2 FL's D1 + Pine D2: 15,671 ppd 5% ■Contaminated Condensate: 1,976 ppd IaCombined Condensate: 304 ppd ❑Unaccounted: 10,732 ppd 27% 20% Blue Ridge Paper Products Inc. Figure 2.5 Canton Mill MSH3/4/01 a � � ca c� _� � r� , -..-..., - t, ,E. _ ,: ;� r,. �• � � ^ + � K 1 � �� ti . ••. �ti ; �� * s �<, fir e I �c� '' �i :�} tea,. :r.` �., "� 1 ,$� • v� �•� `', ., / . , �r•' / � '„ �. ` ��! �, - �. �,` a`i:� Y '` 2 ' � . .'15� T i '.�- i,�J1-.�.,'.. �_�•.< Average Measured Color of Sewer Areas as a Percentage of New NCASI Color Method for Primary Influent Using the newly developed NCASI Color 9/1/00 - 12/31/00 Primary Influent = 49,284 Ibs/day test method to remove the interference of turbidity on the Primary Influent, the Secondary Effluent = 37,696 Ibs/day unaccounted color for this period is actually-6% (2,463 lbs/day). Using the 3% 1% standard NCASI color test method, 9% unaccounted color for this same period is 6%(2,968 Ibs/day). ■2B- Digesters, No. 1 FL: 4,323 ppd M 3A- No. 1/2 Eo, No.2FL BSW, 02 Delig: 12,954 ppd 38% 0 PM's- 11 & 12: 1,991 ppd 28% ■ 513- Recovery, BLO,CRP: 7,852 ppd ■ 1&2 FL's D1 + Pine D2: 17,345 ppd ■Contaminated Condensate: 1,591 ppd ❑Combined Condensate: 260 ppd 4% **Potential Sources of Unaccounted Color: 1. Sewer Generated Color 17% 2. Turbidity interference 3. Minor, unmeasured areas of the mill. Blue Ridge Paper Products Inc. Figure 2.6 Canton Mill MSH 3/4101 i i Section 3 In-Mill Sewer Areas Color Reductions in Mill Sewer Areas i The table below shows the color reductions in mill sewe l areas that resulted from implementation of numerous Best,Management Practices (BMP's) and additional color reduction measures outlined;below in the process changes by sewer area. The "Pre" period is that period prior to implementation of referenced BMP's, and the "Post" period includes 1999 and 2000. Most color reduction measures were performed in 1998, therefore, data collected in that yearlrepresents a period of transition and is not used in the Pre to Post averages shown below. (lbs/day) 3A Sewer 213 Sewer 6A Sewe_r�#1 Sewer Unaccounted* Pre Color 14,260 12,9181 17,894 4239 36,213 Post Color 11,669 4,627 15,245 21378 7,236 % Reduction 18.2% 64.2% 14.8% 4I.9% 80.0% *Unaccounted Color includes sewer generated color, turbidity interferences and unmeasured color. Process Changes by Sewer Area #1 Sewer Hardwood weak liquor tank containment 2B Replacement of Digester Recirculation Pumps Feb/97 Double-Chambered Pine Courtyard Spill Collection Sump 6/98 Relocation of hardwood secondary knotter accepts tan i overflow line to sump 12/98 Sewer monitoring (conductivity, color and flow) Assurance of Continued Dry Conveying of Knot Rejects Fiberline Spill Tank Level Management Plan Non-Contact Cooling water Diversion (from Pine Courtyard Sump) project Blue Ridge Paper Products Incl Canton Mill 3/5/01 i i {f 3A Sewer monitoring (conductivity, color and flow) Hwd Eo recycle 12/99 Hardwood Eo recycle was instituted in December 1999. Due to outages (scheduled and unscheduled), the average recycle rate for[Eo filtrate since December 1999 is approximately 140 gpm (see Figure). The Canton Mill's target recycle rate is 150 gpm, which is achieved when there are no hardwood fiberline outages. The approximate color savings from recycling Eo filtrate for this period is 1,700 Ibs/day. Fiberline Spill Tank Level Management Plan I 5B Oxidation Blower Coolers Project 6/98 Sewer monitoring (conductivity, color and flow) I - 6A BFRTm on the Pine Fiberline 10/98 Sewer monitoring (conductivity, color, pH and flow) Automatic flow meter installation Condensates Not monitored prior to 1998 Correction of Evaporator Demister Set Clogging late 1997 reason to believe "Pre" Condensate Color was higher than 1998 —2000 average data x Installation of Condensate Instrumentation and Sampling Ports for Evaporator Set—Jan 1998 I General Use of#1 Primary Clarifier for Spill Control Operator Skills Training and On-the-Job Training E & I Basic Care Checksheet Program I I I 1 I Blue Ridge Paper Products Inc. Canton Mill i 3/5/01 Ut Rider, papt''IirO£JUCtS t'1C �✓ 7,3 � j.'�M 2 8 d b e " aN •re£ pverutew Milt et erw p: Son,, oral mIt ent voom �� �• h�M,W`t• VAI`A` ° � w. � Y d �AN (� ha � E 111111111IMM 8 i G.!S rpignt ^� a . • 8 " g 3 . x £agl i • a°.E � &` �� 5 i..nd s�°L a� e �� a �i9x3° �`' • y ��,- �'3wo+ s' 0.�. �ii yy�� yp� °T g P•, *3: R-T e e;� wet, 412 lTRP- 't4R8a- :a 3�sya9olfatm •• � � _ RR6t t s ag: a3s en �a, a � " ' ��; e ��:� � S a � x 41. 8�q ___ 3 ,�•9...w-r osk �w4,a..S,�^��i �.aw �. � �, aw•z �� «$3 m�mW�°' °A°*�,3 '`" `fie 8�a». �,�.. w a._ 1 CZ Aw -- � s 'm.4 •` aurt $ INAR�. 'cs6 ia, d.v`" :ia i S`" �f.'" %m` •. 3 �a 'a s:. �§ "`\'�. A�u d> � 8 3S� � A 'i� 4 V.G. CBCp �►pW11 �A i '• �� �R .� `� ♦i .f A'-� #1 Sewer Color (1,000 Ibs/day) from Daily Composite 1996 - 2000 50 45 40 35 a -30 - -- - -- - --- - — — --- - — -- - - --- -- — N a 0 25 0 e� 0 20 0 v 15 10 5 0 ^�96 n�96 ��96 ^Orb �0q, ^Orb �01 '�41 '��91 ��01 ^�9� '���^ ^�9b ��9� ^�g� ^�9� ���� ���$ ^��9 ^�99 ��99 ^�99 ^�99 �\�9 �0 �\OO ^\OO ^\oo —480-Color#1 Blue Ridge Paper Products Inc. Figure 3.1 Canton Mill 3/5/01 #2 Sewer Color Concentration (mg/l) 1996 - 2000 12000 10000 I ei 8000 E e 6000 m u c 0 V o 4000 U 2000 - 0 dL il W rn rn rn rn rn rn rn rn rn rn � rn rn rn rn rn rn rn rn rn rn rn rn rn o 0 0 0 0 0 \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ —479-Color#2 Blue Ridge Paper Products Inc. Figure 3.2 Canton Mill 3/4101 I T m f0 C I Color(lbs/day) w ri [O N w A cn W V co CD o w m o 0 CO 0 0 0 o 0 0 0 o 0 0 0 0 0 0, 0 0 0 0 1/24/98 CD � I I C 3/24/98 N I I '0 5/24/98 7/24/98 n 9/24/98 I 3 i o• I 11/24/98 I ! c n 0 1/24/99 I a m • i � N 3/24/99 I Z o n 5/24/99 I m N o a�ofnO 7/24/99 I c N o D 0. 0 9/24/99 v 0 0 CD 11/24/99 v 1/24/00 n 0 3 3/24/00 10 O N 5/24/00 I rD i 7/24/00 I 9/24/00 I 11/24/00 w A O I Contaminated Condensate Color (lbs/day) from Daily Composite No. 2 Sewer Area 1998 - 2000 16000 14000 12000 - — — -- 10000 m v N a 8000 r 0 6 V 6000 4000_ 2000 () op op w a rn rn rn m rn o 0 0 0 0 0 rn rn rn rn rn rn rn rn rn rn rn rn o 0 0 0 0 0 N N N N N N N N N N N N N N N N N N —Contaminated Blue Ridge Paper Products Inc. Figure 3.4 Canton Mill 3/4/01 2B Sewer Color(1,000 Ibs/day) from Daily Composite 1996 - 2000 200 180 160 140 !. A ro 120 O. 0 O 0 100 V 0 a c 80 0 0 r' 60 20 0 rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn o 0 0 0 0 0 \ M r Q\i \ \ M 7- n m \ —477-Color 2B Blue Ridge Paper Products Inc. Figure 3.5 Canton Mill 3/4/01 3A Sewer Color (1,000 Ibs/day) from Daily Composite 1996 - 2000 150 130 110 m r m a 0 o 70 U N 0 50 0 —— 30— — — — — 10 -10 co co cc c0 co co � r � � � � � ao co ao ao m rn rn rn rn rn rn o 0 0 0 0 0 rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn a rn rn rn rn rn rn o 0 0 0 0 0 \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ ^ —478 -Color 3A Blue Ridge Paper Products Inc. Figure 3.6 Canton Mill 3/4/01 LL/I Monthly Average Hardwood Eo Filtrate Recycle Rate 3A Sewer Area December 1999 - December 2000 200 Target Eo Recycle Rate is 750 gpm during normal operation.This data includes all hours in a month (running and downtime). 180 160 -- 140 -- - a. 120 t9 Ti 100 Semi-Annual Outage was held in November 2000. p 80 w 60 - 4V 40 20 rn o 0 0 0 0 0 0 0 0 0 0 0 rn o 0 0 0 0 0 0 0 0 0 0 0 0 Blue Ridge Paper Products Inc. Canton Mill 3/5/01 Figure 3.7 5B Sewer Color (1,000 Ibs/day) from Daily Composite 1998 - 2000 100 90 80 70 T a 60 — -- N L 0 50 0 `0 40 0 U 30 20 10 0 ^\�'� ^\90 \9$ \9� '�\�� \�� \�9 '`\C '`\�9 \�9 \�9 \99 �`01 1Z \OO ^\oo ^\Oo ^\OO ^\ .\\ p�\ ^^\ ^\ ,y\ h\ .\\ —481 -Color 5B Blue Ridge Paper Products Inc. Figure 3.8 Canton Mill 3/4/01 y - 6A Sewer Color (1,000 Ibs/day) from Daily Composite 1996 - 2000 100 90 80 70 a --- -9 -60-- --- — -- - -- - - M a 0 50 0 o 40 0 V 30 20 10 0 co n co c0 cc cfl � r � � � r` w ao 0o m � ao rn rn rn m rn rn o 0 0 0 0 0 rn rn rn rn rn rn rn rn a> m rn rn rn rn rn rn rn rn � rn � rn � rn o 0 0 0 0 0 \ \ M r —482-Color 6A Blue Ridge Paper Products Inc. Figure 3.9 Canton Mill 3/4/01 - Sec`tion 4 Update on BFRTm Performance BFWm continues to operate on the ill's Pine fiberline. Average % Uptime for MRP since October 1998 is approximately 86% (see Figure 4.2). However, the Canton Mill continues to have capacity and reliability issues with the operation of the Metals Remova Process (MRP) due to the following factors: • Media filters plugging • Softener screens plugging a d scaling • Laterals failing in filters • Strainer failures • Whole system plugging • Regeneration pump failures i •—Softener-Resin-failing-from-fiber-andscale accumulation The Canton Mill has established a task group to comprehensively assess these recurring problems. The goal of this group is to manage the above issues to consistently achieve the target clos re of 80%. Average % Closure on the Pine Fiberline since October 1.998 is approximately 74% (see Figure 4.1 ). Operation of the Chloride Removal Process (CRP) has been extremely reliable, though it contributes approximately 6,000 Ibs of color to 5B sewer per day on average (see Figure 4.3). Average purge rate since September 1999 is 9.1 gpm (see Figure 4.4). Blue Ridge Paper Products Inc. Canton Mill 3/6/01 BFR % Closure October 1998 - December 2000 90.00% so.ao°io 70.00% 60.00% U 40.00% 2 9 i i 30.00% " g 20:00%` A 10.00/0 L 0.00°/( S 4° �� Q `sm 'mac �� O° O 20 O° q 4? 0 BFR% closure Blue Ridge Paper Products Inc. Figure 4.1 Canton Mill 3/4/01 � I a Chloride Removal Process (CRP) Sewer Color (lbs/day).from Daily Composite 1998 - 2000 18000 16000 14000 12000 v 10000 N a c IL 6 n 6000 8000 4000 -- - — - — - 2000 0 \CP '`\CP \CP `\411 �011, —272-CRP Color Blue Ridge Paper Products Inc. Figure 4.3 Canton Mill 3/4/01 Monthly Average CRP Purge Rate, GPM September 1999 - January 2001 (note: flowmeter was not installed on purge stream until Sep. 99) 14 12 - 10 Semi-Annual Outage held in November 2000. a 8 t, m m ° 6 a 4 - 2 - 0 rn rn rn rn o 0 0 0 0 0 0 0 0 0 0 0 rn rn rn rn o 0 0 0 0 0 0 0 0 0 0 0 0 Blue Ridge Paper Products Inc. Figure 4.4 Canton Mill 3/4/01 i May 27, 1998 i I Mr. Forrest Westall NC Department of Environment and Natural Resources Division of Water Quality 59 Woodfin Place Asheville, NC 28801 RE: NPDES Permit Modification - Permit No. NC0000272 Dear Mr. Westall: I In accordance with the above referenced permit, we are forwarding herewith the report to meet the requirements of Part III-E, Paragraphs 7, 8 and 19. Included with this is a progress report on Champion's Bleach Filtrate Recycling (BFRTm) technology demonstration. i If you have any questions regarding this submittal, pleas)contact me at (828)646-2033. Sincerely, _ Robert V. Williams Manager Environmental, Occupational Health& Safety I Enclosure xc: EPA Technology Review Workgroup (Please see attached list) I datakbobwXnpdes1modiAwest598 i I i i I � 1998 COLOR TECHNOLOGY MEASURES REPORT I I � I PREPARED FOR ; I NORTH CAROLINA DIVISION OF ENVIRONMENTAL MANAGEMENT 512 NORTH SALISBURY STREET- RALEIG , NORTH CARO12INA. AND I TECHNOLOGY REVIEW WORK,GROUP I I r I . are ion I Champio International Corporation i MAIN STREET CANTON, NC 2871'j6 JUNE 11 1998 I i I � I I i Table of Contents i Executive Summary 1.0 Introduction j 1 1.1 Purpose 1 1.2 Historical Background 2 2.0 1997 NPDES Permit Part III,Paragraph E 8 Requirements - 5 June 1, 1998 Report Submittal 3.0 1997 NPDES Permit Part III, Paragraph E 9 Requirements - 6 BMPs i ! I 3.1 Part III,Paragraph E 9- Best Management Practices(BMP)Required Projects 6 i 3.2 General Discussion I 6 3.3 Replacement of Digester Recirculation Pumps i 6 3.4 Double-Chambered Pine Courtyard Spill Collection Sump 7 3.4.1 Project Description 7 3.4.2 Project Justification 9 3.5 Weak Black Liquor Tank Containment Project 9 3.6 Additional Operational Measures- 3.6.1 Correction of Evaporator Demister Set Clogging 11 3.6.2 Installation of Condensate Instrumentation i and Sampling Ports for 12 Evaporator Set 3.6.3 Assurance of Continued Dry Conveying of Knot Rejects 12 4.0 1997 NPDES Permit Part III,Paragraph E 7 Require)eats - 14 Additional Color Reduction Measures 4.1 Part III,Paragraph E 7-Additional Color Reduction Measures 14 4.2 General Discussion 14 4.3 Further Upgrading and Integrating of Sewer Monitoring 16 4.3.1 Sewered Condensates 16 4.3.2 Chloride Removal Process (CRP) 17 4.3.3 Pine Bleach Plant Automatic Flow Meters 18 i i i I I 4.4 Automated Mill Process Control Systems ... 19 4.4.1 Electrical and Instrumentation tE&1) 19 4.4.2 Fiberline Spill Tank Level Management Plan 20 4.5 Continued Operator Training I 22 4.5.1 Pulp Mill 22 a) Operator Skills Training(OS7) Program 22 b) On-the-Job Training(OJ7) Program 23 4.5.2 Recovery I 25 a) Operator Skills Training(OS7) Program 25 b) On-the-Job Training(OJ7) Program 25 or 4.6 Additional Controls for Unmeasured Sources of Liqu Losses 27 4.6.1 Hardwood Secondary Knotter Accepts Tank Overflow 27 4.6.2 Miscellaneous Field Work 28 i i 4.7 Diverting Clean Water Discharges 29 4.7.1 Digester Area Project 29 4.7.2 Oxidation Blower Coolers Project 29 4.8 Capturing&Recycling Liquors During Fiberline Disruptions 30 4.8.1 Detailed Scheduling of Planned Outages I 30 4.8.2 Contingency Planning far Unplanned Outages 32 s4.9 Primary Influent Turbidity Interference Study 33 4.10 Sewer Generated Color 35 4.10.1 General Discussion j 35 4.10.2 Previous Research&Find(ngs 36 4.10.3 Research Plan for 1998 i 37 5.0 Bleached Filtrate Recycling (BFRTm) Process on Pine Fiberline 39 6.0 Conclusion 41 i i i 1 I i 1 June 1, 1998 NPDES Report Executive Summary I - I The folloxing report on color reduction measures details the Canton MiWs progress to fulfill the requirements of the i997 modified Color Variance and NPDES Permit. .although the BFR m demonstration is not complete. the mill is currently meeting thl effluent limits set forth in Part III. Paragraph E 10 of the 1997 Permit. Figure One illustrates!Champion's success in reducing color discharges to the Pigeon River since 1988 including the I onthly average performance for 1998. The 1998 color performance improvement is discussed through lout this report. In addition to the on-going BFR'%4 demonstration project, the mill has compl Ited implementation of all Best Management Practices projects required by Part III, Paragraph E 9: BMP Prolects Total Cost SDigester Recirculation Pump Replacement Stains Double-Chambered Pine Courtyard Spill Collection Sum 5 ,000 Complete Weak Black Liquor Tank Containment P $27575,000 Complete $96,500 Complete Additional Operational Measures: i• Status Correction of Evaporator Demister Set Clogging f Complete • Installation of Condensate Instrumentation&Evaporator Set Sampling_Ports Com lete • Assurance of Continued Dry Conveving of Knot Rejects P Complete The additional color reduction requirements listed in Part III, P I ragraph E i of the 1997 Permit are either completed or currently under study. The report review s the additional color reduction measures completed including: enhanced sewer monitoring, diverting clean water discharges and planned and unplanned outage contingency planning. Operatorltraming has been conducted on operational color impacts and permit compliance, BMP operati In and outage planning. Studies i on primary influent turbidity interference, known to have a false positive effect on influent true color,and sewer generated color are continuing. t Champion International' Poration - Canton, NC Figure 1: Canton Mill Secondary Effluent (SE) Color Performance Annual Averages: 1988- 1998 YTD Monthly Averages:Jan 98-April 98 400,000 350,000 0 300,000 M SE Color N 069000 Monthly 250,000 - -s 60000 Annual 0 o • U 200,000 W 150,000 -- 0 cn 100,000 - - - -- — -- 50,000 - it CQ CMS 5/27/98 i June 1, 1998 NPDES Report 1:0 Introduction 1.1 Purpose i This report on in-mill color reduction measures at Champion International Corporation's Canton, North Carolina integrated pulp and paper mill is submitted in accordance with the requirements of Part III, Section E, Paragraph 7, 8 and 9 of the mill's 1997 NPDES Permit(the 1997 Permit). Following a brief historical background of the 1997 modification of the NPDES permit and associated ColoriVariance, Sections 2.0, 3.0 and 4.0 of this report cover the specific requirements listed in Part III, Section E, Paragraphs 7, 8 and 9 of the 1997 Permit. All four Best Management Practices (BMP) projects required by Paragraph 9 of the 1997 Permit have been completed and are discussed in Section 3.0. Each of they projects listed in Paragraph 7 have been completed by the mill and are discussed in Section 4.0 of this report. The status of the Bleached Filtrate Recycling (BFRTm) process on the mill's pine fiber line is discussed in Section 5.0. Finally, the report concludes in Section 6.0, with a summary of the mill's overall i color reduction efforts. The report identifies a strategy and timeline for each project to further reduce color discharges from the Canton Mill. C91or reduction (projects completed include: gathering more extensive and detailed data on sources of color within the Mill to substantially improve the accuracy of measurements; improvI ments in the Mill's existing Best Management Practices (BMP) program and completion of efforts to identify, quantify and improve the accuracy of a mass balance of sources of process black.liquor losses, including unmeasured sources and discharges during' periods of fiber line disruption. Each section includes an explanation of and rationale for the strategy being I implemented. Although the BFRTm:demonstration is not coImplete, the mill is currently meeting the effluent limitations set forth in Part III, Section E. Paragraph 10 of the 1997 Permit. I i I I I t � I , i I 1.2 Historical Background Champion's Canton Mill discharges treated wastewater from pulp and paper production processes at the %,fill to the Pigeon River about 37 miles upstream from the North Carolina-Tennessee border. In ithe mid-1980s. the State of Tennessee objected to the issuance of an NPDES permit for the Mill because of color in the effluent. As a result of Tennessee's objections, EPA withdrew permitting authority from North Carolina and proposed a true color limit of 50 platinum cobalt units at the'pioint of discharge. Because there was no demonstrated and cost-effective technology capable of meeting such a limit at the point of discharge, Champion sought variances from the North Carolina and Tennessee water quality standards for color, both of which are narrative rather than numerical standards. North Carolina granted a variance in July 1988 (the 1988 Variance), but Tennessee did not. The North Carolina variance required the Canton Mill to meet the Tennessee water quality standard for color at the Tennessee border, using a predictive model. EPA approved the North Carolina variance in August 1988, and incorporated it into the federal NPDES permit issued to Champion in Octotier 1989 (the 1989 Permit). Following administrative appeals filed by third parties representing a citizen group in Tennessee, the 1989 permit was upheld in 1992. In March 1990, prior to final approval of the 1989 pi rinit, Champion began the Canton Modernization Project (CMP), a $330 million effort to dramatically improve the mill's effluent quality and meet the stringent new require i ents of the variance and permit. The project, among other improvements. involved the elimination of elemental chlorine in the bleaching process with the complete substitution of chlorine dioxide and oxygen delignifrcation. Additional process changes were implemented to "tighten up" the Mill with regard to losses of colored'process waters. Once completed in 1994, the CMP reduced the mill's wastewater discharge from an average ofi45 Million gallons per day (mgd) to an average of less than 29 mgd, as well as reducing color in the Mill's effluent by almost 80 percent. Figure One illustrates the reduction in color discharges to the Pigeon River since 1988. Of particular note are the more (recent reductions following successful implementation of the CMP in 1994. I 2 i Under the terms of the 1988 Variance. Champion vas required to submit an annual review of developments in color reduction technologies to the North Carolina Department of Environmental Management (NCDEM). The I1988 Variance called for the establishment of a Variance Review Committee (VRC), consisting of water quality staff and experts in the pulp and paper industry, after startup and completion of the CMP. The VRC was charged with reviewing the variance and reporting to the North Carolina NPDES Committee regarding adequacy of the existing variance.Ice. The NPDES Committee reviewed the variance in 1993 and made no changes to it. In May 1995, in conjunction with the first triennial review of water quality standards following the completion of CMP. the NPDES C lmmittee appointed the VRC to review the adequacy of the variance. After reviewing the variance in late 1995 and early 1996, the VRC recommended in March 1996 that the effluent limit for color at the I point of discharge be reduced by 23 percent from the 'variance and 1989 Permit. Following public hearings on the recommended changes to the variance and draft NPDES permit, the NPDES Committee adopted the hearing officer's recommendations and I modified the variance, establishing new limits for color discharge of 124,933 pounds per day (daily average on annual basis) and 132,341 pounds per day (monthly average) decreasing from 172,368 and 258,945 pounds, respectively. The modification of the variance was transmitted to EPA on Ocfober 17, 1996 and EPA advised the State of North Carolina that the agency would approve the variance modification. On December 11, 1996, following further discussions between Champion. •EPA and the States of North Carolina and Tennessee, the NPDES Committee adopted an amended order for modification of the color variance, further reducing the dischl ge limit for color to 98,168 pounds per day (daily average on annual basis) and 125,434 pounds per day (monthly average). The amended order included numerous additional requirements for further I color reduction. The Division of Water Quality issued the NPDES permit the next day, incorporating the variance as modified and amended. OA December 26, 1996, EPA finally approved the changes to the variance. i On January 13, 1997, the State'of Tennessee filed a petition for a contested case in ® the North Carolina Office of Administrative Hearings challenging the NPDES permit and 3 i i the variance. Tennessee's objections,i and those of other intervenors were resolved by issuance of the February 20. 1998. Settlement Agreement in State of Tennessee et al. v. :North Carolina Dept of Environment and Matural Resources et al. Pursuant to that agreement. the 1996 permit was further modified providing fir. beginning December 1, 1998. an annual average true color not to exceed 60,000 you Ids per day and a monthly average not to exceed 69.000 pounds per day. unless Ch Ipion's patented Bleached Filtrate Recycling (BFRTn technology is not successful, with an ultimate target annual average true color loading within the range of 48,000 - 52,000 pounds per day. Additional study and reporting requirements, as stated in the (Settlement Agreement and 1997 modified NPDES permit, are covered in Sections 2.0, 3.0 and 4.0 of this report, i i Y, i i i 1 4 I 2.0 1997 NPDES Permit Part III, Paragraph E 8 Requirements - June 1. 1998 Report Submittal The language of this paragraph of the 1997 Permit provides that: "The permittee shall provide a report to the Division of Water Quality, the Technology Review Workgroup and the NPDES Committee no later than June 1. 1998. This report will identify a strategy and timeline for implementing those color reduction measures identified in Paragraph E 7 until the target effluent limitations in Paragraph E 12 [48-52,000 lbs/dav annual average] are met or all measures in Paragraph E 7 have been fully implemented. The report will include an explanation of add rationale for both the implementation strategy and the proposed time line. The report will also identify f those measures which will be implemented in the event that the effluent limitations set out in Paragraph E 10 [60,000 lbs/dav annual. 69.000 lbs/dav monthly] are not achieved by the color reduction measures specified in that paragraph." This report fulfills the requirements of Part 111, Paragraph E 8. Each of the projects listed in Paragraph E 7 has been completed or is currently under study. Although the BFRT� demonstration is not yet complete, the mill is currently achieving the effluent limitations set forth in Part 111, Section E, Paragraph 10 of the 1997 Permit. The requirement listed in Paragraph E 11 of the 1997 Pe I it [Hardwood Eo Recycle] will be completed in 1999 as a part'of the continuing effo to meet the target effluent limitations established in Paragraph E 12. I I i i 5 i ® 3.0 1997 NPDES Permit Part III, Paragraph E 9 Requirements - BMPs 3.1 Part III. Paragraph E 9 - Best Management Practices (BMP) Required Projects The language of this paragraph of the 1997 Permit provides that: "Four BMPs which have alreadv been identified as having both a high potential for achieving color reduction and a high level of implement ability are: (a) installation of replacement digester recirculation pumps and a spill collection i sump:- (b) [installation of d double-chambered courtvard sump]* • "(c) installation of weak black liquor tank containment. and; (d) correction of evaporate set demister clogging , installation of condensate instrumentation and sampling ports for the evaporator set, and assurance of continued dry.conveying of knot rejects. The permittee shall fully implement all four of these BMPs by June I, 1998." 3.2 General Discussion Part III. Paragraph E 7 of the 1997 Permit requiresi the implementation of four Best Manaeement Practices (BMP) ,projects by June 1, 1998. All four of the BMP's listed above were completed before June 1". The digester spill collection sump and pine courtyard Parshall flume slide gate were combined into a 'single project involving the installation of a double-chambered sump in the pine courtyard and is discussed in Section 3.4. The color reduction benefits from these projects will be evaluated after collection of sufficient operational data. 3.3 Replacement of Digester Recirculation Pumps Approval to replace the black liquor recirculation pumps for all 18 batch digesters was received in early March 1996. Installation of these pu I ps began in April 1996 and took place during the annual inspection for each digester.I All 18 recirculation pumps were installed and operating by February 1997 for a total cost of$537,000. The previous recirculation pumps were 1950's vintage centrifugal units unique to the Canton Mill. The I I • Justification and Technology Review Workgroup approval of this project are provided in Appendix A2. i I 6 replacement of these pumps has reduced the quantity of concentrated colored material from the digester area as shown in the secondary effluent trend in Figure 1. i i I 3.4 Double-Chambered Pine Courtyard Spill Collection Sump 3.4.1 Project Description The pine courtyard and digester area of the mill did not have spill collection systems; such systems were incorporated as a BMP requirement of the 1997 Permit. The pine courtyard and digester area (2B area) includes the following source areas: the digester building including portions of the hardwood blow(tank and accumulator, the i hardwood brownstock building including the hardwood oxygen delignification area and I the pine blow tank and accumulator area. Based on a short-term color contribution mass balance performed within this area: in April 1997, the digester area and hardwood ® brownstock area each contribute approximately 25% of the color while the remaining 50% of the color comes from the courtyard area. Therefore, two BMP projects for the I digester and courtyard area were included in the 1997 Permit as covered in Section 3.1 of i this report. The two projects were to install a digester spill collection sump and install a pine courtyard Parshall flume slide gate. In early 1998, with the approval of EPA, North Carolina and Tennessee, these two projects were combined lino one project, a double- . j chambered courtyard sump. The justification for this project is discussed in the following section. Funding for the two-chambered pine courtyard sump was approved in February 1998 at a total cost of $275,000. The sump provides a system to detect, collect and reclaim colored materials from the digester building and pine courtyard area based on 7 i conductivity control. The completed sump is located in the (pine courtyard area. The sump is 8 ft. square x 10 ft. deep and constructed of reinforce d concrete. The sump is divided into three sub-compartments. Two of the three sub-compartments are designed as pump compartments with the third serving as a discharge weir into the U-drain flowing to the 2B Parshall flume. The two pump compartments are the collection points for the two sources of flow in this area. One compartment receives flow from the digester building and the other compartment'receives flow from the courtyard and hardwood brownstock area. Engineering drawings of this sump and U-drain system can be found in Appendix Al. i The digester compartment and,the pine courtyard compartment have independent conductivity monitoring. The digester area is typically a low volume, high concentration color contributor whereas the courtyard area is typically a low concentration, high I volume contributor. Each compartment is designed to pump a maximum of 400 gallons per minute. Manual slide gates were installed�which allow cross-connection of the sumps to facilitate maintenance activity in 'one of the compartments. In the event of upset conditions the manual gates may also be configured to briefly increase the total sump collection capacity to 800 gallons per minute. However, total typical flow from both the digester and courtyard area is approximately 425 gallons/minute. The sump is covered with a steel plate to allow maintenance traffic to pass over the(sump area. The sump pumps for each of the two compartments are equipped with independent conductivity probes which are connected to the Distributive Control System S (DCS). The conductivity set points trigger the sump pumps to turn on to minimize the loss of detected colored material. Collected material from the sump is pumped to the 8 hardwood brownstock spill collection' tank. The sump compartments will normally overflow the third compartment's discharge weir to a U-drain flowing to the 213 Parshall flume. It is important to note that 50-100 gallons of clean. Ion-contact cooling (NCC) water no longer flow through the co i urtyard due to the diversion project discussed in Section 4.7.1. Details on this sump project are located in Appendix A. I 3.4.2 Project Justification I As stated in the 1997 modified NPDES Permit, the mill was required to install a - - I digester spill collection sump and a pine courtyard Parshall flume slide gate by June 1, 1998. The mill concluded the above design was an improvement to the sump and Parshall flume slide gate conceptual design and submitted thil design to the Technology Review Workgroup for approval. A copy of the documentalffion sent to NCDWQ and TRW in February 1998 for approval of the new sump design is located in Appendix A2. While this sump configuration cost more than the original conceptual design, it offers better operational performance and maintenance reliability. I 3.5 Weak Black Liquor Tank Containment Project I i With the completion of the Canton Modernization Project in 1994, all of the black liquor storage tanks are contained and have reclaim sum i s on conductivity control, with the exception of the hardwood weak liquor storage tankl. Due to the potential for i colored losses from this tank, a containment system was identified as a BMP during the 1 1997 Permit discussions. Funding to construct the hardwood weak black liquor(IWBL) containment system was approved in January 1998 at a total cost of $96,500. Work on this project 9 i commenced immediately following'project approval and was completed in May 1998. The containment volume is sufficient to contain most lossi based on historical events. Additional containment capacity is constrained by existing process equipment in this area and maintenance of the WBL tank. This project provides a concrete containment wall for the WBL storage tank as well as the associated Soap tank. Within the containment area a new stainless steel sump was installed as a designed low point. Additional concrete work was required on the existing slab to control the direction of flow toward the new sump. A four inch Stainless Steel pipe connects the sump to the mill sewer. A manual valve and an automatic valve i were installed in the sewer overflow connection to prevent released material from entering the mill sewer. i The control systems for this'project are a sump level switch, sump conductivity probe and tank overflow temperature switch. A level switch is installed on the containment wall above the sump in;order to detect any fluid level within the area above the top of the sump and alarm the operators.'The conductivity probe was installed in the sump to determine the presence df black liquor and initiate an operator alarm. A temperature switch was installed inithe tank overflow line as an early warning of tank overflow. The operator alarms for all of the instrumentation are sent by the DCS to the Evaporator Control Room as well as the Hardwood Fiber Line Brownstock Operator's Station. The DCS simultaneously closes the sewer connect Iion automatic control valve. I The manual valve is a backup to the automatic valve and allows for maintenance of the automatic valve. � l0 i I ' I A piping connection for a portable sump pump was installed from the sump to the top of the %�BL tank. This project provides detection. operator alarm(s), containment and reclaim capability to manage the infrequent colored losses from the weak black liquor storage tank. The engineering drawings for this BMP project are located in Appendix B. I I i 3.6 Additional Operational Measures f 3.6.1 Correction of Evaporator Demister Set Clogging { I Evaporator condensates are generated as a result of" iling" the water out of the black liquor entering the evaporator, set. Periodically, color is carved over into the I evaporator condensates as a results of entrained black liquor in the water vapor (condensate) driven off the evaporator in the vapor dome. The ,primary source of the I entrained black liquor is fouling of the leading-edge of the evaporator set demisters. When the demisters were washed, the evaporator condensate color concentration i decreased. I Is Operations determined that I the black liquor fiber filter performance was important to prevent demister leading; edge fouling. The ze�Iclfllh overy area operations staff addressed this issue and corrected the problem during the last quarter of 1997. Due to i improved management of fiber filter up-time, communication and monitoring of the fiber I filters, condensate color has decreased as demonstrated by the reduction in secondary effluent color. In addition, manways were installed in the evaporator vapor domes to provide access to wash the evaporator demisters. I I i I I I 11 i �. 3.6.2 Installation of Condensate Instrumentation & Sampling,Ports for Evaporator Set I i As discussed above. evaporai or condensates can periodically carry over colored material as a result of entrained black liquor in the water vapor (condensate) driven off the evaporator in the vapor dome. The individual contribution s of color from the sewered combined and contaminated condensates were previously unmeasured. To quantify the daily color contribution from these! sources, automated solenoid valve samplers were i installed on both the combined and contaminated evaporator condensate sewered streams in January 1998. These samplers collect a 24-hour composite which is analyzed for color i concentration and incorporated into ;the mill's Plant Information (PIT°A) System for data i analysis and trending. There are also eight conductivity probes within the evaporator condensate ® collection and segregation system that provide operations notification of any change in i operation that can cause an increase in sewered color. Corte l tive action to minimize the loss of colored material is initiated based on these internal conductivity readings. However, these probes cannot necessarily indicate gradual increases in sewered color from evaporator condensates. To! identify such problems requires the information generated via the continuous samplers discussed above. The conductivity probes support the daily sewered condensate color data by providing the mill with information to respond to the performance of the evaporator systems and m i age color for this source. 3.6.3 Assurance of Continued Dry Conveying of Knot Rejects Sealed pressure knotters were;installed during the CIA in 1993 to minimize color • losses from the knot system. The "otter is not designed to fuse water to transport knots 12 I ® to the rejects bin. The cause of a stream of discolored water from the Hardwood fiber line Secondary Knotter into the rejects bin was identified and corrected in eariv 1998. Occasionally, a piece of foreign material would hang in the throat of the valve and damage the valve seat. A spare valve is maintained on-site)for the Hardwood fiber line secondary knotter and the knotter is inspected during each shift in order to assure the valve is properly closing and sealing completely. In addition. flow from this area is discharged to the new double-chambered pine courtyard spill collection sump. I I I I I I I I 13 I � 4.0 1997 NPDES Permit Part III, Paragraph E 7 Requirements - Additional Color Reduction Measures 4.1 Part III. Paragraph E 7 - Additional Color Reduction Measures The language of this paragraph of the 1997 Permit provides that: "Working with the Technology Review Workgroup, Champion has already begun the process of identifying and implementing possible prevention and control measures which can be taken to further reduce color discharges from the mill. The permittee is directed to further evaluate mill operation so as to fully identify opportunities for preventing and controlling measurable black liquor leaks and spills (best management practices - BMPs),I This evaluation will include gathering more extensive and detailed data on sources of color within the mill to substantially improve the accuracy of measurements, to improve the - mill's existing BMP program. and to complete efforts to identify, quantify and substantially improve the accuracy of a mass balance of sources of leaks and spills of black liquors. including unmeasured sources land discharges during periods of fiber line disruption. Such BMPs include: I further upgrading and integrating of sewer monitoring (e.g., additional flow measurement and sampling stations to facilitate more comprehensive and daily monitoring of sources) and automated mill process control systems with operational 'procedures and management oversight to reduce black liquor leaks land spills; continuing operator training; identifying and implementing additional controls for known but unmeasured sources (e.g., evaporator set, knot rejects bin, etc.) of liquor losses; modifying the digester area to facilitate capturing leaks and spills; diverting clean water discharges; and capturing and recycling liquors during fiber line disruptions through detailed scheduling of planned outages and contingency planning for unplanned outages. The permittee also isldirected to thoroughly evaluate additional measures to modify its process operations and controls to remove or reduce sewer generated color." 4.2 General Discussion The Canton Mill has one of the most extensive se er monitoring programs for color in the industry. The mill monitors, on a daily basis, the color load (lbs/day) contributions from the following sewer areas: 2B (Hardwood Brownstock washing, Digesters and Pine Blow Heat Recovery area), 3A (Pine and Hardwood Eo filtrate and Pine Brownstock washing and Oxygen Delignifrcation), 5B (Recovery, Black Liquor I Oxidation and Chloride Removal Process (CRP)), No. 1 (Nd 11 and 12 Paper Machines), Hardwood and Pine Acid and Alkaline bleach plant filtrates and Combined and 14 I i Contaminated Condensates. Other areas of the mill are measured on a concentration basis. The "unquantified" fraction ov Primary Influent color vas a focal point during the 1997 Permit discussions. The mill defines unquantified color as a component of primary influent color resulting from turbidity, sewer generated color and minor contributions from unmeasured areas of the mill. The discussions) focused on quantifying "unquantified" color in order to evaluate the potential for additional color reduction activities. This "unquantified" portion accounts for approximately 40% of the mill's primary influent color. The "unquahtified" fraction is attributed to three independent reasons; 1) turbidity (color test method interference which is a false-positive representation of true color), 2) sewer generated color and 3) color from unmeasured areas of the mill. In order to quantify this fraction, the mill increased its color monitoring program. i Automated samplers were installed on the black liquor ievaporator combined and I contaminated condensates. Samples' also are collected from the CRP purge stream. Automated flow meters were installed on the Pine D1 and E I stages to provide sewered flow measurements for calculating bleach plant color loads to the wastewater treatment plant rather than using a mass balance approach. This new color data has reduced unquantified color. All major process areas now have daily color monitoring. The four BMPs discussed in Section 3.0 have addressed the evaporat�r set, knot rejects bin and i digester area requirements. Current data indicates that the! majority of the remaining i "unquantified" primary influent color is due to the effects of turbidity and sewer generated color. Plans to further quantify and characteriz turbidity interference and 15 i I I i I I sewer generated color are discussed in Sections 4.9 and 4.M Turbidity interference and sewer generated color research projects, are scheduled for the summer of 1998. In i addition, the mill is currently working in cooperation with NCASI on an industry sponsored turbidity interference study. i i 4.3 Further Upgrading and Integrating of Sewer Monitoring 4.3.1 Sewered Condensates Evaporator condensates are generated as a result of"Iboiling" the water out of the black liquor entering the evaporator set. Periodically, color is carried over into the evaporator condensates as a result of entrained black liquor in the water vapor (condensate) driven off the evaporator in the vapor dome. Historically, sewered i combined and contaminated condensate were discharged toi the main No. 4 sewer line where only the color concentration was measured. Therefore the'color contribution from these condensate streams was not independently quantified. To quantify the daily color loadings from these streams, continuous samplers were in ledon both the combined and contaminated condensate streams. Automated solenoid valve samplers were installed on both the combined and contaminated condensate sewered stieams in the black liquor evaporator area in January 1998. These samplers collect a 24-hour composite which is analyzed for color I concentration on a daily basis. The samples are analyzed for color concentration by wastewater treatment plant personnel, recorded in the laboratory data files and entered into the mill's PITm System. The color concentration is then multiplied by the calculated dailyaverage sewer flow in i 16 i order to generate the daily combined)and contaminated condensate color contribution in pounds per day. This value is monitored daily by both Operations and Environmental personnel. Data trends are available on the PIT" System. 1 4.3.2 Chloride Removal Process (CRP) The Chloride Removal Process (CRP) is an integral(component of the Bleached Filtrate Recycle (BFRT`� process at the Mill. Details of the' BFRTu process, including CRP, are included in Appendix H. The Chloride Removal Process is designed to separate chlorides and potassium from the recovery boiler ash solution that contains primarily saltcake and black liquor. Colored material from the recovery boiler ash carves over into the salt cake filtrate which is then sewered to purge chloride and potassium. The salt cake is returned to the recovery boilers as a make-up chemical for the kraft process. In order to meet the required process levels of potassium and chlorides while maintaining an overall low level of process equilibrium, up to 15 gallons per minute of this filtrate is sewered. Since the amount of color from the CRP is variable, it is important to monitor the amount of color that enters the sewer from the CRP process. Color monitoring of this purge is accomplished in two ways. The first method looks at the amount of color in the 5B sewer before and aft Ir the CRP U-drain and uses I the difference to calculate CRP color. The second method)is to collect a grab sample from the "purge stream" daily and measure both the color concentration and sewered flow rate. A daily color mass (lbs/day) is calculated, trended and monitored. The CRP samples are analyzed for color concentrat ion by wastewater treatment plant personnel, recorded in the laboratory data files and entered into the PT'T" System. I I 17 I i i As with the condensates. an automated solenoid valve sample i was installed on the purge stream within the CRP building in S 4 eptember 1997. The sampler collected a 24-hour composite which was analyzed for color concentration on a daily basis. However, due to I the nature of the purge stream the sampler became plugged and difficult to maintain after several months of operation. Based on insignificant differences between single grab and 24-hour composite sample color data, it was concluded thct grab samples adequately characterized the color contributions from CRP. Thus, the usie of the automated sampler was discontinued in March 1998. The concentration is then multiplied by the daily average CRP purge rate within the PITH System in order to gel erate a daily loading value i in pounds of true color per day. This value is monitored land trended daily by both Operations and Environmental personnel. i a 4.3.3 Pine Bleach Plant Automatic Flow Meters Automatic flow meters were installed on the D 100 and Eo stages of the Pine fiber Y; line in June 1997. The flow meters measure the sewered flows from the pine fiber line I D100 and Eo filtrates. Data collection from the flow meters began in July 1997 and was integrated into the Pine fiber line's DCS. The flow data allows the Pulp Mill to control the degree of BFRTM closure by selecting the sewered flow of both DIN and Eo stage filtrates. Previously, the D100 and Eo sewered daily average flow rates were calculated based on filtrate mass flow balances. Direct measurement(provides an accurate daily average flow rate to calculate the Pine-bleach plant color loading. The BFRTM control strategy adjusts these flows through process operation and control in order to achieve a target closure on the Pine fiber line and simultaneously 18 i ® prevent filtrate tank overflow during normal operation. The mill currently targets for 80% closure of the first two bleaching filtrate stages in the Pine fiber line. Higher closure I rates introduce process variability which have resulted in an overall increased level of I bleach plant color. The configuration of controlling the ratio of sewered DIN to Eo filtrate, and associated filtrate tank level override control, allows the mill to change the closure target and prevent filtrate tank overflow. The benefit to the mill is improved accountability of color discharge from the Pine bleach plant and the operation of a much I more stable bleach plant and fiber line filtrate system. I 4.4 Automated Mill Process Control Systems ... 4.4.1 Electrical and Instrumentation (E & I) Preventativ I Maintenance Plan The Electrical and Instrumlentation (E & I) Section of the Canton Mill's e Maintenance and Engineering Department is responsible for the maintenance and calibration of all control instrumentation within the mill such as conductivity probes, flow meters, temperature probes, level .transmitters, etc. Some of these instruments are important for management of the process to minimize mill color losses. In order to assure this instrumentation is operating properly, the Canton Mill E & I Section developed a preventative maintenance program which is located in Appendix C: The program addresses two key elements: 1) the identification of equipment to minimize color losses and 2) a specific preventative maintenance progr1am for such equipment. For the program the E & I, Environmental, Pulp Mill and Recovery Operations Departments developed a list of color control instrumentation including: conductivity transmitters, level transmitters, temperature probes and overflow alarms. The program 19 I © consists of a computerized instrument calibration system and routine check sheets for routine calibration which should increase the reliability of the instrumentation. The computerized instrument calibration system will store calibration specifications for each instrument. including calibration range and acceptable tolerance. Routine calibration schedules and manufacturer's specifications allow the technicians to determine the drift in each instrument and re-calibrate if necessarv. The check lists will be used to schedule and document E & I preventative maintenance tasks and will! be kept on file by the area i maintenance planner. This program will be implemented by July 1, 1998. 4.4.2 Fiberline Spill Tank Level Management Plan Over the past two years the reduction in brown color losses from the pine fiber line has contributed to decreased effluent color as illustrated in Figure 1. Pulp Mill Operations and Environmental personnel worked on two projects to further minimize and I control brown color losses from the pine fiber line. These projects are a spill tank level I t. management plan and reconfiguration of the pine fiber line's spill-collection sump. The final configuration of the spill collection sump was compl Ited and operational during mid-November 1997 while the Spill,Tank Level Managem Int Plan went into effect in early December 1997. Both projects have resulted in reduced brown color losses from i the pine fiber line. Data collected on color losses from the pine fiber litre indicate that some of the mill's losses occur during mechanical failures (i.e. the primary knotter). Therefore, the availability of brownstock spill tank capacity is important to spill recovery and recycle. 20 I As of December 1997, a spill tank management plan was implemented for the pine fiber line operators. The Spill Tank Level Management Plan requires the brownstock operators, at the first of each shift, to log the spill tank level on their daily logsheet. If the level is high, the operators will start slowly lowering the level in the tank bl pumping its contents back into the process. This daily task was automated in March 1998. The operators are alarmed at the beginning of each sEft!by the DCS if the spill lank level exceeds the alarm level. The DCS checks-the-operators response three hours II ter by rechecking the tank level to assure that the tank level was addressed. By maintaim'ng low spill collection tank i levels, there should be adequate collection capacity in the tank. This management plan was incorporated into the Operator, Training Program (Slction 4.5.1) for the pine brownstock operators. i As mentioned above, the success of the Spill Tank Level Management Plan is closely related to the performance of the sump pump as well as operator.awareness. The i east brownstock sump pump for the pine fiber line was recoInfigured in mid-November 1997. Pulp Mill Operations felt the performance of the pump was critical prior to initiating the Spill Tank Level Management Plan. The redesigned sump pump now runs continuously so pump priming is no longer an inherent problem to reliable pump operation. The control system logic provides for recovery of material based on conductivity control. The conductivity probe is mounted within a newly installed I recirculation line to improve the performance of the probe I d reduce the potential for fiber to "blind" the probe. When i the conductivity in the sump is low the pump recirculates flow back into the sump through the newly installed recirculation line. When i 21 I conductivity is above the set point. a newly installed automatic valve within the recirculation line will close and divert the material to the brownstock spill collection tank i for recvcle and recovery. Overall. the mill has seen a decrease in the daily brownsiock color from the pine fiber line contributing to reduced secondary effluent color as shown in Figure 1. The new sump design and management plan have resulted in a reduction of color losses from the pine fiber line. 4.5 Continued Operator Training, 4.5.1 Pulp Mill 4.5.1 a) Operator Skills Training (OST) Program The Pulp Mill Operator Skills Training (OST) Program has been updated to reflect the activities in this report. This program typically involves the operators studying and self-checking written material contained in manuals which cover specific components of Pulp Mill Operations. The pulp mill is currently reiising the manuals covering processes which may contribute color to the sewer. The revisions will incorporate both general color reduction information as well as any new systlems or procedures. Systems and procedures include, for examplethe pine fiber line spill I ank level management plan, new 3A sewer sump configuration ;and a new multi-charn ered pine courtyard sump. I Each process manual will discuss the implications of the specific process operation on colored discharges. The operators train on how to effectively minimize their area's impact on color discharges. Examples of such manuals include: 22 i • Digester Contingency Operations • Explain and Operate Hardwood Brownstock Spill Collection System • Explain Hardwood Brownstock System Operating (Concepts • Explain Hardwood Bleaching Operating Concepts • Explain and Operate Bleach Plant Spill Collection ISvstem I " • Explain Blow Heat System I • Explain Pine Brownstock System In addition to updating the individual'process manuals, the p rlp mill is creating two new OST manuals for operator training. A learning guide was developed to explain the operation and logic for the multi-chambered pine courtyard sump system discussed in Section 3.4. Another learning guide was developed to outline the color impacts from the operation of the pulp mill in general. The "Explain Pulp I ill Area Compliance and I Color ControP' learning guide summary is located in Appendix D1. The learning guide covers the pulp mill's operating plan regarding color losses during normal operations as I i well as managing non-routine events., This learning guide provides training on the impact of the pulp mill on color variance; compliance. This ove fall OST effort provides a foundation for color control and awareness which will be reinforced during the Pulp I Mill's On-the-Job Training Program discussed below. 4.5.1 b) On-the-Job Training (OJT) Program ' I Pulp Mill Operations developed an operator On-the-Job Training (OJT) Program which began in April 1998. The OJT operator program expands upon the new OST information to communicate the environmental impact of their operations in addition to the training programs currently in place. A training session was developed by the Pulp 23 i Manufacturing and Environmental Departments to transfer general knowledge from the 1997 Permit and operational color impacts to the Pulp opel ators. The training session program is found in Appendix D2. Throughout the month I f April 1998 each operating i crew received this training. The training session begins rvith an overview of the 1997 Permit including the compliance limits and dates. This provides a timeline for the operators to understand mill effluent color limitations and future requirements. A performance history on brown and bleach plant color losses from each fiber line is comp I ed to the current level of I performance. This provides a benchmark for operating performance and the performance level required to maintain compliance. The current BMP projects are discussed to update the operators on progress, environmental impact and operad Inal impact. The training session continues with a discussion of the potential sources of color in the pulp mill such as pump packing in the brownstock I d digesters, screen rejects, bleach plant color (i.e. MRP operability), etc. The purpose of this is to stress the importance of day-to-day awareness of operations and maintenance issues which have the potential to result in colored discharges. The session covers the sources of color which contribute the greatest color loading to the treatment ilant ' and the difference in wastewater treatment of bleach vs. brown color. Shift manal ers will periodically review new plans and procedures with their operators. This trailing allows the operators to understand the regulatory implications of the permit and their roles in managing and i i minimizing colored losses. 24 4.5.2 Recovery_ 4.5.2 a) Operator Skills Training (OST) Program The Recovery Area Operator Skills Training Program (OST) has been updated to reflect the activities in this report. This program typically involves the operators studying and self-checking on materials contained in manuals which cover specific components of Recovery Operations. In order to incorporate the color reduction activities discussed in this report, a learning guide was developed which covers recoveiv area processes which can contribute color to the sewer. The "Explain Recovery I rea Compliance and Color Control" learning guide summary is located in Appendix Eli The learning guide covers the recovery area's color sources; monitoring and control systems, preventative maintenance measures, spill collection systems and operating plans regarding color losses during normal operations and non-routine events. This learning guide provides an overall lesson on the impact of the recovery area on color variance compliance. This overall OST effort provides a sound environmental foundation which will be further enhanced in the Recovery Operations On-the-Job Training Program covered below. 4.5.2 b) On-the-Job Training (OJT) Program Recovery Operations developed an operator On-the-Job Training Program (OJT) which began in May 1998. The program expands upon the new OST guide information to communicate the environmental impact of their operations in addition to the traditional training programs currently in place. A training session was developed by the Recovery and Environmental Departments to transfer general knowledge from the 1997 Permit and ® operational color impacts to the recovery operators. The trai I ng session program can be 25 I found in Appendix E3. Throughout the month of May each operating crew received this training. I I The training session begins with an overview of the 1997 Permit including the compliance limits and dates. This provides a timeline for the operators to understand the mill effluent color limitations and i future requirements. A performance history on Recovery, CRP and condensate color is compared to the cur-rent level of performance. This provides a benchmark for operating performance and the performance level required -to maintain compliance. The current BMP projects are disc Issed to update the operators on progress_ environmental impact land operational impact. This training allows the operators to understand the regulatory implications of the permit and their role to i I minimize color losses. I The training session continues with a discussion of the potential sources of color in the recovery area such as pump pa i king, CRP and evaporator boilouts, sump operation, etc. The purpose of this is to stress the importance of day-to Iday awareness of operations and maintenance issues which havelthe potential to result in colored discharges. The l session covers the sources of color that have the potential to contribute the greatest color loading to the wastewater treatment plant. Shift managers will periodically review new plans and procedures with their operators. This training allows the operators to understand the regulatory implications of the permit and their role to manage and minimize color losses. l l l 26 I I i i 4.6 Additional Controls for Unmeasured Sources of Liquor Losses 4.6.1 Hardwood Secondary Knotter Accepts Tank Overflow The Secondary Knotter Accepts Tank for the hardwood fiber line overflowed to the sewer twice in the past several years resulting in elevated color discharges. The overflows occurred when the tank level transmitter failed. In addition to the level transmitter preventative maintenance discussed in Section 4.4.1, the mill has installed a temperature probe with operator alarm lfor direct indication of tank overflow. The Secondary Knotter Accepts Tank overflow line runs from the tank, which is inside the hardwood fiber line brownstock washing building, to the sewer discharge point I just upstream of the 2B Parshall flumie. Due to its piping configuration this potential color source will not be collected by the new courtyard sump discussed in Section 3.4. An engineering solution to this potential color source was identified in early I January 1998 and incorporated into the pine courtyard sump BI MP project. The solution was to install a temperature probe in'the overflow line. 0 Itput from the temperature probe is tied into the DCS. Under normal tank level conditions the temperature probe will read the ambient temperature indicating no tank overflow. If a tank overflow occurs, the increase in temperature will be detected by the temperature probe and the DCS will i trigger an alarm at the hardwood brownstock operator station. This will give the operators notification to react to the situation and minimize p locess losses. This project I was completed at the end of May 1998. I 27 I i 4.6.2 Miscellaneous Field Work Miscellaneous field work was conducted to improve) the quantification of color contributions from several known color sources within the mill which flow to the sewer i unmeasured. Between February 1997 and April 1997 flow measurements and color concentrations were collected to provide estimates of coloredi material from several areas of the mill including the Hardwood Bleach Plant overflow to' the No. 4 sewer, 2B sewer constituents (which are measured iri total by the 2B sampler), sewered black,liquor condensates, Hardwood Accumulator losses to No. 4 sewer and both fiber line secondary knotters. The sewered condensates are now measured daily (Section 4.3.1) and the digester sump project provides for recovery of the 2B court and contributions (Section 3.4). Color contributions from the remaining color sources tested are minimal. ® The pine secondary knotter contribution can be pilked up by the redesigned brown spill collection system (Section 4.4.2). The hardwood secondary knotter color contributions have been reduced by the project discussed in Se ction 3.6.3 and are diverted into the new courtyard sump discussed in Section 3.4. The hardwood bleach plant contribution is typically less than 160 pounds of true color per day. The hardwood accumulator losses are typically less than 100 pounds of true color per day, but can at times be greater. However, most of the flow from the hardwood accumulator area is either diverted into the new digester , reclaim sump or the e I istirig weak liquor storage reclaim sump. 28 4.7 Diverting Clean Water Discharges 4.7.1 Digester Area Project As part of the two-chambered Pine Courtyard Sump Project discussed in Section 3.4, a new U-drain was installed to divert 50-100 gallons per minute (gpm) of clean, non- contact cooling (NCC) water away from the new courtyard sump. This clean cooling water would have previously diluted any colored material flowing from the digester area. The new U-drain was installed to connect the existing clean cooling water U-drain outside of the digester building to the existing U-drain in the I ourtyard area downstream i of the new digester sump. This connection eliminates 50-100 gpm of clean cooling water from diluting any colored material entering the digester arca and the new sump. A permanent plug was installed to prevent the clean cooling water flow from entering the Sdigester building. The diversion of this clean water source reduces the dilution of colored material from the digester area resulting in a higher concel tration, lower volume of I colored material for reclaim by the new digester sump. Therefore the amount of material to be reclaimed by the sump and recycled into the process as well as additional load to the black liquor evaporators are reduced. 4.7.2 Oxidation Blower Coolers Project i A second clean water segregation project will soon be complete in the recovery boiler area. The Black Liquor Oxidation blowers each have Ian associated oil cooling system. These oil coolers together contribute approximately 50�gpm of clean, non-contact cooling water to the recovery boiler sump system. This source of dilution water will be hard-piped from each cooler into a common header downstriam of the recovery boiler 29 • ® sumps. Completion of this project will eliminate approximately 50 gpm of clean water from the reclaim sump and recovery systems. This segregation project will be installed and operational in June 1998. 4.8 Capturing & Recycling Liquors During Fiberline Disruptions 4.8.1 Detailed Scheduling of Planned Outages Scheduled outages are standard industry practice for i ainiaining the performance ry area operations. Fiber line outages occur about once every of the pulp mill and recove four weeks. Detailed and extensive outages are periodically scheduled whereby one-half of the pulping and recovery area is shut down for up to one leek. Planning occurs prior to each outage regardless of the duration or complexity of the outage. Maintenance work schedules are prepared and flow-charts are prepared which illustrate when equipment is to be shut down, repaired and started;back up. Semi-annual outage information and lists of personnel involved are generated and distributed t I oughout the mill. Key Performance Indicators (KPI) targets for Safety, Environmental, Planning, Execution and Cost are established before the outage, tracked to monitor outage performance and reviewed after the outage in order to identify key ]earnings. lolored losses are a focus of the outage planning. A tank draining schedule is generated prior to the start•of any outage and includes the tank(s) to be drained including yolume(s). Tanks and associated piping must be periodically cleaned for inspection and maintenance. Provisions are made to reduce the tank level as low as possible before shut down. Piping is e I ptied as much as possible prior to cleaning. I 30 i Tank level and inventory management is a kev tool the mill uses to minimize colored losses during outages. The color impact of various sIources of colored losses has i been estimated and incorporated into:the OST learning guides for Pulp Mill and Recovery Operations areas as discussed in S I i ctions 4.5.1 (a) and 4.5.2 (a). These color loss estimates are combined with the planned outage tank drainine schedule to estimate the I total outage color loss. The mill is currently developing a procedure to evaluate the color loss estimate based on the actual tatilc level(s) prior to the lutage. This information is then communicated to the operations I areas and wastewater treatment. Adherence to the established schedule and detailed communication of any schedule changes are important to minimize outage color. I I The mill is incorporating the existing kraft pulping chemical inventory management strategy as a component of the overall color management philosophy. The E & I preventative maintenance plan discussed in Section 414.1 addresses the reliability of critical color control instrument;tion fb{ outages. This equipment is inspected, calibrated and cleaned a week prior Ito each major annual I semi-annual outage. The i i mill began collecting hourly primary influent color measurements during specific outage i periods in September 1997. The color concentration values are entered into the mill's PI'M System and verbally communicated to the recovery and pulp mill shift supervisors. Currently, a tiered/triggered response;procedure is under development to determine color levels of concern based on the measured values with associi ted iesponse actions. This I will focus mill resources on detecting and identifying sources of color to minimize colored losses. i I i 31 I i The above mentioned efforts are incorporated into the Pulp Mill and Recovery area On-the-Job Training Program covered in Sections 4.5.1 (b) and 4.5.2 (b). These efforts are being incorporated into the outage planning process and will be refined with experience. Many of the above procedures and strategies are also integral to address non- routine events and unplanned outages. 4.8.2 Contingency Planning for Unplanned Outages A variety of non-routine events can occur which require an unscheduled outage for repair. Events such as power and steam supply problem) and mechanical issues are examples of such occurrences. Tank level and inventory management is a key tool the mill uses to minimize the color losses from such unplanned events. Minimizing tank levels reduces the loss of colored material and increases the capacity for capturing colored material. The Fiber Line Spill Tank Level Management Plan discussed in Section 4.4.2 addresses this by controlling the level in the spill collection tanks. Tank Y levels are controlled by the management of chemical inventories between the pulp mill and recovery area operations. Targets are set for the weak liquor inventory for operators to adjust the feed rates to the black liquor evaporators to maintain recovery operations during upset conditions. Together, these two operational tools maintain the flow of black I liquor through the recovery system to minimize the loss of colored material during non- routine events. I In order to successfully manage color through an unplanned outage, clear and concise communication must be maintained between the pIrup mill, recovery and the wastewater treatment plant. A release of colored material may require hourly monitoring 32 of the primary influent for color in order to enhance management of the situation. The wastewater treatment plant operators must remain aware of primary influent color and respond to elevated color. The operator must be able to respond to the situation at the treatment plant as well as notifV supervision and operatoi s of the problem via radio communication. Utilization of the DCS and PITH Sistem in addition to radio communication with operations are important to minimize coIlored losses. 4.9 Primary Influent Color Turbidity Interference Studv The Canton Mill has an intensive color monitoring program both within the mill and at the wastewater treatment plant. The in-mill sewer monitoring program provides color data used to break down the mill's process contributions to the primary influent. Primary influent color consists of contributions from 213 (Hardwood Brownstock washing, Digesters and Pine Blow .Heat Recovery area), .3A (Pine and Hardwood Eo filtrate and Pine Brownstock washing), 5B (Recovery, Black'Liquor Oxidation and CRP), No. 1 (No I I and 12 Paper Machines), Acid Filtrate and Combined and Contaminated i Condensates. As previously discussed, the remaining fraction' of primary influent color is "Unquantified" color and consists of contributions from turbidity interference and sewer i generated color. The turbidity interference occurs while measuring primary influent color concentration in the laboratory. The EPA approved standard NCASI test method for true I color measurement requires sample filtration. There are various materials present in the mill environment that, when present in the primary influent, are suspended in the filtered I 33 I solution and scatter light. This scattered light is not read by the spectrophotometer and is interpreted as true color by the test method. These particles ido not contribute to effluent color due to the fact that most of the turbidity interference is removed across the i wastewater treatment plant. Therefore, the true color concentration of the primary influent is high biased by the turbidity interference effects and is not representative of the actual true color in the sample. Material such as Precipitated Calcium Carbonate (PCC), lime mud, dregs, Titanium Dioxide (T'02), paper machine fillers, etc. contribute to this turbidity interference. I A study will be conducted throughout the summer of 1998 to quantify the impact of various turbidity levels on primary influent color. The ultl mate goal of this study is to account for the impact of turbidity i interference on primary influent color in order to quantify a portion of the unquantifed color. In addition o this mill study, the mill participated in an industry sponsored turbidity study with NCASI from February 1998 through April 1998. The goal of the study, is to modify the current test procedure to reduce and/or eliminate the current;turbidity interference present in the test. A draft synopsis of the purpose, objectives, approach and outcomes of this work is included in i Appendix F of this report. NCASI's final assessment will be published as a technical bulletin by late 1998 or early 1999. During the summer of 1998, the Canton Mill will conduct an independent r turbidity study. The purpose of this study will be to evaluate 1) The turbidity contributions from each of the individual in-mill sewers; 2) The turbidity contributions from various in-mill materials (i.e. dregs, Ti02, PCC, ® lime mud, etc.); and 34 i 3) The portion of primary influent color attributed to primary influent turbidity. Baseline in-mill sewer turbidity data is currently being collected and analvzed. The project will consist of laboratory bench-scale studies to determine the influence of turbidity on the color test method using known turbid materials such as dregs, TiO2, PCC, lime mud and paper machine headbox feed solutions. The collected data will be I evaluated to quantify the effect of turbidity on primary influent color. A final turbidity report will be generated combining Champion's and NCASI'I I research. i I 4.10 Sewer Generated Color 4.10.1 General Discussion Sewer Generated Color (SGC) is a phenomenon which occurs due to wastewater interactions in the mill sewer system. SGC results in a highel color than is accounted for i by the color contributions of all the individual wastewater streams. This phenomenon is attributed to chemical reactions that occur as,the mill's acid sewer(Pine D1, Pine D2 and Hardwood DI bleach plant filtrates) is introduced to the main mill sewer system. These acid filtrates react under elevated pH(10-11) and elevated to Iperature (120 °F) within the sewer system prior to the wastewater treatment plant. The q I tity of this "unmeasured" SGC color source is an issue for closure of the mill color balance. The Canton Mill has done most of the research on this relatively unknown color phenomenon within the industry. Canton's research efforts have included both mill and Corporate Technical engineers, summer interns and two Graduate students from Duke University's Nicholas School of the Environment. During the summer of 1998 additional research will be 35 I I conducted at the Canton Mill. The study plan is outlined in Section 4.10.3. A brief i discussion of past SGC research is presented in the following section. i i 4.10.2 Previous Research & Findings Champion's research into the SGC phenomenon be in the early 1990's. I I Champion showed that when acid filtrates from the bleach plant mix with the alkaline sewer effluent, the color of the resultant effluent was greater than expected based on a mass balance. Further work showed that irreversible color is created in the acid stream by raising the pH and temperature. Simultaneously, Canton Mill environmental engineer Susanne Koelsch began a series of experiments to analyze the impact of the wastewater treatment plant on color removal as well as probing into the phenomenon of SGC. These i two concepts were brought together in the summers of 1994, 1995 and 1997 for further • experimentation. Research during the summer of 1994 was conducted by Aimee McCord while the 1995 research was conducted by Chad Salisbury. Both research efforts covered a variety of color issues beyond SGC, however only the findings rele lant to SGC are discussed. McCord's work determined that the color removal mechanil m across the wastewater I treatment plant acts primarily on brown color sources, not on bleach plant color. ' I Salisbury's research was designed to address two questions: I 1) What is the maximum potential impact of sewer generated color on color loads to the wastewater treatment plant? 2) Is sewer generated bleach color removed at the wastewater treatment plant? A small portion of SGC for all bleach plant filtrate combinations was found to be removed at the wastewater treatment plant. However pine, Hardwood and total bleach i 36 I I I ® plant effluent flows experienced a net color increase across' the sewer and wastewater treatment plant system. An undergraduate summer intern project during the summer of 1997 began the process of assessing the impact of SGC on primary influent color loads i to the wastewater treatment plant and how to minimize SGC. The objective of this work was to determine if pH adjustment of the acid sewer prior tI mixing with the alkaline sewer would: 1) minimize the effect of the sewer generated color phenomenon on primary influent color; and i i 2) result in an equivalent decrease in secondary effluent color after wastewater treatment. I I The operation of the BFRT'd process at the Canton Mill was i'highly variable during this project. Limited laboratory data suggested possible color reduction benefits at both the primary influent and secondary effluent by specific wastewater stream pH adjustment. However, more laboratory work needs to be conducted, a Ipecially since the BFRTm process is currently stabilized at 80%,bleach plant closure. I e impacts of current, and possible increased, operational levels require further study. A graduate student began conducting additional research on sewer generated color in May 1998. 4.10.3 Research Plan for 1998 As stated in previous sections, the Canton Mill has conducted experimental bench scale work on the sewer generated color mechanism for three summers with the aid of summer college interns. This cooperative effort continues this summer with another • graduate degree candidate conducting -the research. The student will spend the summer 37 i i i I conducting laboratory experiments to evaluate two questions raised through previous research: I 1) What effect does the colon removal mechanism across the wastewater treatment facility have on sewer generated color? i 2) What is the potential impact on sewer generated color of pH adjustment of the acid sewer prior to mixing with the mill's main alkaline sewer? er? The goal of this project is to quantify the percentage, if any, of sewer generated color which is removed across the wastewater treatment facility and to understand better if pH I I adjustment is a feasible option to reduce this color source. A description of the 1998 i summer study plan is listed in Appendix G. I I I I I I I i I i I I I I 38 5.0 Bleach Filtrate Recycling (BFRT") Process on Pine Fiberline A full scale demonstration of Champion's Bleach Filtrate Recycling (BFRTM) process was begun at the Canton Mill in 1995. Details of; the BFRTM demonstration project are in Appendix H. The process has two major new components, the Chloride Removal Process (CRP) and Metals Removal Process (MRP). For the BFRTm demonstration the CRP and MRP become integral parts of the bleached kraft pulping and recovery process. Both processes are integral in the overall' goal of BFRTm to achieve and sustain closure of the D100 and EoP bleach stages of the Pine fiber line at Canton. The CRP provides a system to purge chloride and potassium from the recovery boiler precipitator ash while the MRP removes minerals such as calcium, magnesium, etc. from the D100 stage filtrate. The CRP is utilized to keep Ithe liquor cycle chloride concentrations similar to or less than pre-BFRTm levels. The MRP is designed to reduce/control scale forming minerals;while recycling bleach{plant filtrates. The BFRTm I X process components were brought on-line and independently demonstrated by the mill prior to full BFRTm implementation. The various stages included: f 1) Start-up of CRP in August 1995; 2) Initial start-up of MRP in November 1995 - D100 filtrate treated and sewered;_ 3) EoP filtrate recycle commenced in March 1996; 4) MRP-treated D100 filtrate bleach plant recycle began i I August 1996. r Tbroughout the remainder of 1996 and through 1998 the mill continues the BFRTM demonstration process. Mechanical and process issues!encountered continue to be addressed. The mill operated for 'several months at various closure levels while ® i r i 39. I attempting to attain full closure. Td stabilize the BFRTM process, the mill currently targets for 80% closure of the first two bleaching filtrate stageslof the pine fiber line. Two papers on the BFRT" process demonstration are located in Appendix H. One article is written by Bob Caron of Champion's Applied Technologies while the other article, written by Stratton (Champion;AT) and Ferguson (Canton Mill Pulp Operations), received the Canadian Pulp and Paper Association's 1997 Douglas Jones Award. These I articles cover the BFRTM process mechanics, operational history and environmental performance. i I i i I I S 40 i 6A Conclusion The contents of this June 1, 1998 report fulfill all of the requirements of Part 111, Section E. Paragraphs 7, 8 and 9 of the mill's modified f 1997 `dater Quality Color Variance and 1997 NPDES Permit effective December 31, 1997. All four of the Best Management Practices (BMP) Projects required by Paragrap� 9 were completed by the mill before June 1" and are discussed in Section 3.0. A list of projects, discussed in Section 4.0, was developed and implemented by the mill to satisfy all in-mill color reduction measures identified in Paragraph 7. Together with the continued . demonstration of the Bleached Filtrate Recycling (BFR"m) Process on the mill's pine I fiber line, these color reduction measures have resulted in color reductions in the I secondary effluent as illustrated in Figure 1. 1 I II ® I 41 i _amon mm _x C -r mon. Norm C:ar L;;ra I +i V �yhampion . :amoion mternanona;ccrocrancr. November 20, 1998 I I 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. NCOOOi0272 Dear Mr. Westall: As required under the referenced permit, Part III - Special I 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 i I I i December 1, 1998 Report - Low Flow Contingency Plan Champion International CorporIation 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. 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 ceed 50 true color units." i This plan fulfills the requirements of Part�III,Paragraph E 13. I 1 I ® I I I I i December 1, 1998 Report - Low Flow Contingency Plan Champion International Corporation i Canton, North Carolina t I H. Color Performance Review I The mill's commitment toward continuous management of color ig 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. i The January 1998 - August 1998 average secondary effluent col I 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 I 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. 'I I 2 I December 1, 1998 Report - Low Flow Contingency Plan Champion International Corporation Canton,North Carolina IF III. Contingency Plan Discussion i 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 If low secondary effluent color discharges has been achieved through extensive and ongoing i ill-wide efforts. However, in accordance with Part III, Paragraph E 13, the scheduling of maintenanl e, intermittent treatment, and production curtailment were evaluated for further color reduction benefit during lowest flow periods. 3.1.1 Scheduling of Maintenance ® The loss of excess color during outages and upon start-up continues to be a focus of the mill's I color minimization activity as detailed in the June 1, 1998 Color Technology Measures Report. To minimize color discharges during periods of lowest river flow)and higher recreational use in the river, no major maintenance outages will be scheduled during the months of June, July and August. I 40 3.1.2 Intermittent Treatment i I 3 December 1, 1998 Report - Low Flow Contingency Plan Champion International Corporation Canton, North Carolina I I i 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 storeld inithe primary clarifier for I managed, intermittent release to the secondary wastewater treatment system. The clarifier will be i utilized for managing colored material storage and release based onlinformation provided by continuous sewer conductivity monitoring, daily sewer color monitoring, and normal mill operations communication. This management tool will allow the mill to provide a relatively stable color load to,the activated sludge system and subsequent optimization of the activated sludge color removal effect. 3.1.3 Production Curtailment Production curtailment through reduced pulp manufacturing is not a viable color reduction option for the Canton Mill. The mill is designed to achieve the most effective and efficient color control at normal production rates and maximum fiberline "turndown capacity is approximately 80% of normal production. Therefore, complete fiberline shitdown 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 I I i total several million dollars in addition to dry furnish pulp costs. Production curtailment is neither a technically nor economically reasonable option for intermittent color reduction. 4 ontingency Plan December 1, 1998 Report - Low Flow C Champion International Corporation ((� Canton, North Carolina tl. � IV. Conclusion The Canton mill's January 1998 - August 1998 average secondary effluent color discharge of 50,524 pounds per day, coupled with the measures detailed in the June I, 1998 Color Technology I Measures Report, demonstrate the Canton Mill's commitment toward brown colored material management. Using North Carolina's governing flow criteria QOQ2), 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 maintenanc i outages during June, July and I - 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 I I i . akingour mark for You. BLUE RIDGE PAPER PRODUCTS INC. November 19,1999 Mr. Forrest Westall North Carolina Department Environmental and Natural Resources Division of Water Quality 59 Woodfin Place y Asheville, NC 28801 Re:— December 1,1999 Report Hardwood Fiberline Color Management Eo Recycle Evaluation and Potential for Full BFRT°" Implementation on the Hardwood Line Dear Mr. Westall: Please find attached the referenced report. With the submission of this report this completes implementation of the technologies collectively referred to in the permit as the "Near Term Package". As you know the Canton Mill is no longer part of Champion International Corporation. As of May 14, 1999 the mill became privately owned and operates under.Blue Ridge Paper Products Inc. Blue Ridge is an employee owned enterprise. The company is comprised of approximately 2200 employees with 70% of these employees residing in Haywood County. Blue Ridge produces uncoated free-sheet paper for printing and- writing applications and paperboard for liquid packaging. The Canton Mill is the primary asset of the new company. If you have any questions regarding this report please contact le at(828) 646-2033. Sincerely, 6 L Robert V.Williams Director,Environmental,Health and Safety Affairs xc: Mr.Don Anderson U.S.Environmental Protection Agency Mail Code 4303 Room 915A,East Tower ® 401 M Street,SW Washington, D.C.Washington,D. 20460 175 Main Street • P.O.Box 4000 • Canton, North Carolina 28716 I. 626-646-2000 i December 1, 1999 Report- Hardwood Fiberline Color Management: Eo Recycle Evaluation and Potential forlFull BFRTM Implementation on the Hardwood Line j BLUE RIDGE PAPER PRODUCTS,INC. I 1 CANTON,NC 1.0 Introduction This report evaluates Blue Ridge Paper Products Canton Mill's implementation of partial Eo filtrate recycle on the hardwood fiberline ind,the potential for color reduction with full BFRTM implementation on the hardw i od fiberline. This report is submitted in accordance with the requirements of Part III, Paragraph E (11) of the 1997 modified Color Variance and NPDES Permit issued to Champion International Corporation for its Canton Mill. The language of this par al graph provides that: "The permittee shall begin implementation of that portion of the BFRTM technology which involves the recycling of the Eo stage of the hardwood line by no later than January 1,1 1999. The permittee further shall provide an evaluation of that implementation as well as the potential for full implementation of the BFRTM technology on the mill's hardwood line to the Division of Water Quality, the Technology Review Workgroup and the NPDES Committee by December 1, 1999. The evaluation will include data reflecting the color reduction benefit gained from the partial implementation and a projection of potential color reduction benefit to be gained ',from full implementation of the BFRTM technology on the hardwood line." �1 1 i December 1, 1999 Report- Hardwood Fiberline Color Management: Eo Recycle Evaluation and Potential fort Full BFRTM Implementation on the Hardwood Line BLUE RIDGE PAPER PRODUCTS,INC. CANTON,NC 2.0 Review of Color Performance at the Canton Mill The Canton Mill's commitment to color reduction is illustratee d in Figure 1. Since 1988, color in the secondary effluent has been reduced by more than 189% (annual average). The color reduction can be attributed to the Canton Modernization Project (CMP) and to continuing mill-wide efforts to reduce color, including those detailed most recently in the June 1, 1998 Color Technology Measures Report. From January 1999 through August 1999, color in the s i condary effluent averaged 40,791 pounds per day, well below the 60,000 pound limit specified in the NPDES Permit. For the same period, as well as that period in 19981, monthly averages for true color at the Hepco bridge were all below 50 standard color units (scu's) even at flows less than the 30Q2 which occurred in August 1998 and August 1999. i Using North Carolina's governing flow criteria (30Q2), historical flow records, and the 1999 January - August secondary effluent color discharge, it is expected that color in the Pigeon River at the Hepco gage will be less than 50 scu's 100 %!of the applicable time. I Therefore, the Canton mill's actual color performance results in significant mitigation of the occurrence and degree of color at the Hepco gage. 2 December 1, 1999 Report- Hardwood Fiberline Color Management: Eo Recycle Evaluation and Potential for lFull BFRr.t Implementation on the Hardwoods Line a ) BLUE RIDGE PAPER PRODUCTS,INC. l CANTON,NC Figure 1:Canton Mill Secondary Effluent Color Per orrna'nce Annual Averages:1988-1998 Monthly Averages:Jan 99-Sep 99 400000 350000 �SE Color 300000 +95,000 Monthly limit-effective 1/l/98-11/31/98 +60,000 Annual limit-etectve 12I1/98-present 250000 - 69,000 Monthly limit-effective 12/1/98-present 0 a U c 200000 a 160000 0 �n 100000 I 50000 0 m Ot O � /7 N t0 [O Of O O1 P m Oa Om, T A Off T 0�1 Obi O�1 O1 q O1 O1 O1 Of Of O1 — A O 3.0 Hardwood Eo Recycle Evaluation 3.1 Project Description All installation work for partial hardwood Eo recycle was completed in mid-September 1998 for a total cost of $112,200. This project involved the installation of piping and controls to pump Eo_filtrate directly to the Decker Filtrate Tank for reuse in the process. Prior to September 1998, Eo filtrate had been sewered and contributed to the Canton Mill's total color discharged to the Wastewater Treatment Plant. Figure 2 details the pre and post-recycle filtrate flows. 3 i I December 1, 1999 Report- Hardwood Fiberline Color Management: Eo Recycle Evaluation and Potential for Full BFRrm Implementation on the Hardwood Line BLUE RIDGE PAPER PRODUCTS,INC. CANTON,NC i Figure 2: Hardwood Eo Recycle Plan-Filtrate Flow Changes for Eo Recycle Pe on w11ao i m Hal D2 Ea Wemr ,D2 Wa@r \JJ// Pro-01 6100 EOP D2 PS 200- Sao ® D100 E. 62 PM © 6• , i 500 i TAW R�PL , Tw MI 3 w1 �� �► PRE Ropli—�—Peimllla� I FiL Wobf Ftl.Cooler � T `l 3.2 Canton Hardwood Eo Recycle Implementation Plan i The Hardwood Eo Recycle Implementation Plan was initiated in 1997. Projected impacts on the hardwood fiberline as well as potential color savings from partial Eo recycle were evaluated. Past filtrate recycling trials on the hardwood fib Irline resulted in significant washer scaling and corrosion problems. To minimize scaling and corrosion problems, and evaluate their potential and rate of occurrence, a systematic approach to partial hardwood Eo recycle was utilized. This systematic approf ch involved incrementally increasing the recycle rate each month, beginning in Octobe 1998. This approach also allowed the mill to identify the optimum recycle rate for maximum color reduction. I r i J I 4 December 1, 1999 Report- Hardwood Fiberline(Color Management: Eo Recycle Evaluation and Potential for,Full BFRTm Implementation on the Hardwood Line i BLUE RIDGE PAPER PRODUCTS,INC. CANTON,NC 3.3 Net Color Reduction Partial hardwood Eo recycle was instituted in mid-September 11998. Due to process control issues, the Eo recycle flow varied more than expectei. A reliable control system was developed and implemented prior to January 1999 that allowed the recycle flow to be set by the hardwood bleach plant operator. The average measured Eo recycle rate for 1999 was approximately 140 gpm with a net measured EI filtrate color reduction of approximately 1,940lbs/day. i Recycle rates during this trial period ranged from 100 gpm to 200 gpm. Eo recycle rates 1 were increased/decreased incrementally each month in order to determine the optimum �J recycle rate for Eo filtrate color reduction with minimum scaling i d corrosion problems. A recycle rate of 150 gpm resulted in the optimum net color seduction with minimal impact thus far from carryover (increased carryover could res Ilt in increasing bleach plant color thereby offsetting decreased color from Eo recycle). The mill will continue to monitor the hardwood fiberline for scaling and corrosion problemss that could result from the recycle of Eo filtrate. The average net Eo filtrate color rl duction was approximately 2,200 lbs/day during the months when the recycle rate was 150 gpm. At recycle rates greater than 150 gpm, washing efficiency declined and the net Eo filtrate color increased. In addition to the color reduction benefit, the pumping of Eo (filtrate and pre-bleach filtrate to the decker filtrate tank reduced the need for fresh I ater•make-up in the decker tank by approximately 225 gpm. 5 i December 1, 1999 Report- Hardwood Fiberline(Color Management: Eo Recycle Evaluation and Potential for,Full BFRTM ® Implementation on the Hardwood Line BLUE RIDGE PAPER PRODUCTS,INC. CANTON,NC 4.0 Potential for Full BFIff on Hardwood Fiberline 4.1 Projected Color Reduction Full implementation of BFRTM technology on the hardwood' fiberline would involve 13- 100 stage filtrate being recycled to the brownstock washing and' oxygen delignification i systems, similar to the pine fiberline. The 1998 average color removal rate from recycling D-100 filtrate via BFRTM on the pine fiberline was applied to the 1998 average D-100 filtrate color load to the mill sewer. A potential primary influent color reduction of approximately, 3,872 lbs/day could result from installing the full BFRT'technology on the hardwood fiberli e. Assumptions made to achieve this color reduction include: 1)The color rem Ival rate for the hardwood fiberline would be consistent with the color removal rate ;seen! on the pine fiberline, 2)Carryover of recycled material into the D2 stage and !paper machines would be manageable, 3)Increased chloride recycled would be managid by the CRP additions to the recovery cycle, and 4)No operational problems would occur in the brownstock washing system. 4.2 Feasibility of Installing Full BFRTM on the Hardwood Fiber I line It has been estimated that full installation of BFRT`technology on'the hardwood fiberline would have a capital cost similar to the capital cost of l$251000,000 (± 25%) for installation of BFRTM on the Pine fiberline (based on 1994 dollars), Capital cost includes construction of another Metals Removal Process (MRP), additions to the existing Chlorides Removal Process (CRP), various piping modifications, provisions for 6 I� f December 1, 1999 Report- Hardwood Fiberline Color Management: Eo Recycle Evaluation and Potential for' 'ull!BFRT" ® Implementation on the Hardwood Line BLUE RIDGE PAPER PRODUCTS,INC. CANTON,NC additional white liquor oxidation and increased black liquor evaporation capacity. The increased operational costs have not been included. Implementation of the full BFRT7' technology on the hard wood 'fiberline is considered cost prohibitive and is not wan-anted. i i I i I • 5.0 Conclusion 7 December 1, 1999 Report- Hardwood Fiberline Color Management: Eo Recycle Evaluation and Potential forlFull, BFRTM Implementation on the Hardwood Line IBLUE RIDGE PAPER PRODUCTS,INC. CANTON,NC The mill's January 1999 - August 1999 average secondary effluent color discharge of 40,791 Ibs/day has been achieved through successful implementation of extensive color reduction projects and measures detailed in the June 1, 1998 Color Technology Measures Report, BFRTM on the pine fiberline and partial hardwood Eo Recycle. Partial recycling of the Eo filtrate on the hardwood fiberline t the optimum rate resulted Y g I P in a color reduction of approximately 2,200 pounds per day. 'The Canton Mill will continue partial hardwood Eo recycle and will continue to el aluate potential impacts to the process. This level of performance demonstrates the Canton mill's commitment toward brown t colored material management and fulfilling the requirements l f thl 1997 modified Color Variance and NPDES Permit. The mill's commitment to continue partial hardwood Eo recycle will result in additional color reduction and mitigation i f the occurrence and degree of color during periods of lowest river flow. Full BFRTM on the hardwood fiberline, due to the potential for minimal color reductions, approximately 3,872 Ibs/day, and the excessive cost, estimated to be $25,000,000 in 1994I dolllars, is considered cost prohibitive and is not warranted. I This completes implementation of the technologies collectively referred to as the "Near- Term Package." Full analysis of seasonal fluctuations in Ithe `Near-Term Package" process operations will be completed by June 1, 2000 and a report submitted by January 1, 2001 on the feasibility of achieving a color loading limit I'thiri the range of 48,000 - 52,000 pounds per day. I 8 I i CBLUE RIDGE IPAPER 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 ProdIucts,ilnc. Canton Mill January 1,2001 Color Limit Feasibility Report Dear Mr. Westall: I 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 IProducts 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, 6 f 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 95th 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 956,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 1950,percentile statistical data. Please call me at(828) 646-2033 orDerric Brown at(828)646-2318 if you have any questions regarding this report. Sincerely, Iarse tyd, Bob Williams Director-Environmental,Health and Safety 1 Attachments 175 Main Street • P.O. Box 4000 Canton,North Carolina 28716 • Phone: 828-646-6000 ' Raising Your Expectations 1 i BLUE RIDGE [GDVCIa iHf. ' I Copy: Keith Haynes North Carolina Department of Environment Health and Natural Resources 59 Woodfin Place Asheville,NC 28801 Technology Review Workgroup (via Division of Water Quality) I I i I i I i I I January 1, 2001— Color Limit Feasibility Report _ Blue Ridge Paper Products, Inc. Canton,North Carolina I i I. Introduction The following report details the Canton Mill's ability to achiev i a taiget 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, Paa lagraph 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 I 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 - I I the Mill's performance from January 1998 through December 2000, Blue Ridge Paper Products believes that achieving a target annual average color limit w I ithin the range of 48,000—52, 000 pounds per day is feasible. i I 1 � - January 1, 2001 -Col, nit Feasibility Report AdIk Monthly Average Secondary Effluent Color (Ibs/day) January 1987 - October 2000 700000 -` 600000 500000 A 400000 N Q G 0 300000 6 V 200000 100000 0 Aug-85 Apr-88 Jan-91 Oct-93 Jul-96 Apr-99 --o.-SE Color Ibs/day Blue Ridge Paper Products, Inc. Figure 1 Canton Mill page 2 i January 1, 2001—Color Limit Feasibility Report Blue Ridge Paper Products,Inc. Canton,North Carolina I1. Color Performance The Canton Mill has achieved a color reduction of over 851A since 1988 in the annual I average amount of color discharged, as illustrated in Figure 1. The improved color performance is due to the Canton Modernization Project, full i 1plementation 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. I The 48,000 - 52,000 target range was selected because it was projected to result in I significant mitigation in the occurrence and degree of color at the Hepco gage. Based upon North Carolina's minimum flow criterion(30Q2),historic a 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 o cu'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 perf Irmance has resulted in significant mitigation in the occurrence and degree of color,at thl Hepco gage as Iprojected 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 44,8371bs/day are both i 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 i 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 i 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 � I 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 valids are both within the 48,000—52,000 lb/day range. Based on a statistical review of thI 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 al 99`hlpercentile 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 alstati'i stical review of the data and the limited data set available, Blue Ridge Paper Products recommends a monthly average effluent limit of 59,796 lbs/day. 4 - I January ], 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 CI nton 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 isI expected that color in the i Pigeon River at the Hepco gage will be less than 50 true color units approximately 97% of the applicable time. 5 I - � - TABLE January 1,2001 Color Limit Feasibility Report Monthly Average Data - Max Month Calc Data Set= 111198-10131/2000 111/2000-1013112000 KS Normality test normal normal Autocorrelation= 0.61 no. of obs. = 34 10 xbar • 45478.5 44836 stddev 6145 6059 95th safe MONTH from normal dist 65556 54773 99th safe MONTH from normal dist 59796- 58953 95th safe YEAR from normal dist 48388 47704 99th safe YEAR from normal dist 49612 48911 Ranked observations 96th percentile for max MONTH 56809 55514 100th percentile for max MONTH 58542 58009