NC0000272_Addtl_Color_Removal_Opportunities_20010803

August 3, 2001
Memorandum
Subject: Additional Color Removal Opportunities, Blue Ridge Paper's (BRP) Canton,NC
Bleached Kraft Paper Mill, 2001 NPDES Permit Renewal
From: Technology Review Workgroup
Donald Anderson, Chair, EPA
Karrie-Jo Shell, EPA Region IV
Paul Davis, Tennessee
David McKinney,Tennessee
David Goodrich, North Carolina
Forrest Westall,North Carolina
To: North Carolina Division of Water Quality and the NC Environmental
Management Commission's NPDES Sub-Committee
In accordance with the 1997 NPDES Permit Agreement for the Canton Mill, the Technology
Review Workgroup (TRW) has examined the progress made at the facility in relation to reducing
the color content of the Mill's effluent and the potential for additional color reduction at the
plant. The focus of this examination includes a review of reports submitted by Blue Ridge Paper
(BRP), a visit to the Mill on March 14, 2001 by EPA's Tech Team, consultation among the EPA
Tech Team and the Workgroup's members, consideration of the separate Mill evaluation and
Licbergott report (Bleach Environmental Process Evaluation and Report) dated June 8, 2001, and
comments from environmental interest and other stakeholder groups (including Clean Water
Fund of North Carolina, American Canoe Association), and EPA's Tech Team Memorandum on
this subject dated July 25, 2001.
It is the finding of the TRW that the EPA Tech Team Memorandum represents an appropriate
evaluation of the potential for additional color reduction at the Mill over the next permit cycle
(December 1, 2001 through November 2006). As a result of this finding, the TRW includes with
this memorandum a copy of the subject report for use by the Division of Water Quality and the
Environmental Management Commission's NPDES Sub-Committee as guidance for the
development of the effluent limitations for color and related special conditions of the draft
NPDES Permit renewal and North Carolina's Effluent Color Variance.
As the purpose of the TRW is to provide a review of the possible technology options available to
the Mill to further reduce the color discharge to the Pigeon River, the EPA Tech Team

Memorandum provides a solid foundation for developing specific conditions and limitations for
the Mill's next NPDES permit. In making this point, the TRW recognizes that not all of the
options outlined in the Tech Team Memorandum can be predicted to achieve specific color
reductions with complete accuracy. Consequently the Memorandum provides estimates of
possible reductions and in some cases a range of likely color reduction from the application of
specific technologies. The TRW also notes that several individuals and organizations provided
alternate estimates to the EPA Tech Team. Again, the difference between"technological
likelihood" and "regulatory limit" is an important distinction that must be considered in
"enforcing"permit conditions. When considering the potential color reduction options provided
in the Tech Team Memorandum in developing a draft NPDES Permit and Color Variance, the
TRW recommends that the following points be considered:
1. The highest priority for additional color reduction moving toward achieving the North
Carolina water quality standard for color rests with additional in-mill improvements,
particularly considering the success already achieved by continuing improvements in leak
and spill prevention and control (Best Management Practices—BMPs) and process
modifications. End-of-pipe technologies reflect significant economic, technical, and non-
water quality environmental impact problems at this mill.
2. The Tech Team Memorandum identifies by degree the "certainty" of three possible
categories of options that the Mill could undertake to further reduce color in the mill's
effluent. The "regulatory risk" of being able to achieve the reductions under these
categories increases as the certainty decreases. Any regulatory limitations/conditions
need to reflect this consideration.
3. The TRW recommends that the options identified in the Tech Team Memorandum as
having the "highest certainty"(i.e., improvements in reliability of the existing bleach
filtrate recycle system (BFR) and leak and spill prevention and control -BMPs, and
process optimization) should be implemented first and the permit/variance should reflect
a very specific level of reduction. The time necessary for the Mill to implement these
"primary" options should realistically reflect the ability of BRP to design, fund and install
the outlined options to achieve these color reductions. The TRW recommends up to two
years as a reasonable period of time for implementing these options. In determining the
actual color reduction"limit"to be placed in the permit the recommendations of the Tech
Team Memorandum should form the general basis of that decision. It may be appropriate
to consider the second tier of options identified in item 4 in setting the limitation
applicable to the implementation of the"highest certainty"options.
4. The process improvement options needing further study and identified as having
"reasonable certainty"of success (second stage oxygen delignification on the softwood
fiber line; ozone addition to chlorine dioxide bleaching on the hardwood fiber line)
should be incorporated in the permit/variance as an additional increment of color
reduction to be demonstrated by the Mill. BRP should be required to evaluate the
technologies identified by the Tech Team and to develop an implementation plan that
would either utilize these technologies or identify other options that would result in
similar increments of color reduction. Because the Tech Team could not estimate at this
time with high certainty the color reduction achievable by these options, the

permit/variance needs to include a mechanism of application similar to that used in the
1997 Permit Agreement. That procedure involves review of a proposed plan from the
Mill, approval of the plan, a schedule for placing selected option(s) into service, a period
of demonstration of the effectiveness of the option(s), followed finally by setting
limitations considering the"target"reduction range but consistent with the actual effluent
color loadings achieved (see paragraph 6). The TRW recommends the option(s) selected
should be installed, operational, and appropriate limits developed within the next permit
term.
5. The potential additional color reduction in treatment of the Chloride Reduction Process
(CRP) purge stream was considered as an option with"lowest certainty" of success.
While this conclusion is supported by the preliminary treatability study already attempted
by BRP to remove color from this waste stream, the TRW recommends that the
permit/variance include requirements that the Mill continue to evaluate all technologies
that might result in significant reduction of this source of color in the Mill's sewers.fiffi—EN
rpproacMereristdirecteditEUcuriDgiwhateve aaddirionalrreductions;ate possible based-on3i
ra idemonstratedtechnologythat works :one. otential,technology in[the.L'iebergotty,
report-,was suggested).and,-can-bezeconomicallynayplied tmthis=color source Full-scale
implementation of'the results of this evaluation should logically follow those options
considered to have higher certainty of success.
6. It should remain the objective of the regulatory agency to monitor, evaluate and apply the
color reduction performance achieved at the Mill from application of pollution prevention
process technologies and BMPs. As the color reduction efforts outlined in the
permit/variance are put into operation at the Mill, the actual performance as measured by
daily effluent color loadings should be statistically evaluated to develop appropriate
limitations for the Mill including a long term average and a revised maximum monthly
average which captures actual variability. The Division of Water Quality should apply
those limitations under the permit through formal notification.
7. The permit/variance should continue to require BRP to report on or identify any
"breakthrough" color reduction technologies developed at the Mill or that become
available within the industry or the research community.
8. To the extent possible, the TRW recommends to North Carolina that the in-stream
compliance point for color be moved as close to the point of discharge as possible (e.g.,
Fiberville Bridge). This compliance point must be related to the end-of-pipe color
loadings to be achieved by the technologies identified in this recommendation or
alternative technologies identified by the Mill as reflected in limitations included in the
permit/variance. The TRW further recommends that the compliance point ultimately be
moved to the Mill's end-of-pipe discharge point to the Pigeon River, and the format of
the limitations also be reviewed as it relates to capturing effluent variability.
9. The TRW believes it is important for the re-issued permit/variance to require a formal
evaluation by BRP of the Mill's efforts during this cycle (2001-2006) to comply with
North Carolina's water quality standard for color. This evaluation should be an important
part of the reporting requirements of the permit/variance.
10. The role of the TRW should continue through the next permit cycle, the re-issuance
process in 2006, and until the Mill has achieved compliance with North Carolina's in-

stream color standard (a variance is no longer needed). As a"clearinghouse" for the
reports and information submitted by BRP under the reissued permit, the TRW provides
an objective view that is useful to the two States, the parties to the 1997 Permit
Agreement, and other stakeholders. This advisory role is important to fostering the
cooperative completion of the color reduction process at the Mill.
In presenting these recommendations to the Division of Water Quality and the Environmental
Management Commission's NPDES Sub-Committee, the TRW wishes to acknowledge the
excellent success achieved since the 1997 Settlement Agreement and the continued effort ofBRP
to improve on this excellent record. The substantial decrease in effluent color since the 1997
Settlement Agreement to the current levels of color observed day to day both at the Canton Mill
and downstream in Tennessee is a testament to the efforts of everyone involved in this process.
While the Canton Mill is among world leaders in the pulp and paper industry as measured by the
quality of its treated effluent, the commitment of the Company and the continued interest and
participation in this process by the regulatory agencies, stakeholder public and environmental
interest groups, and the general public makes additional improvement possible, ultimately
leading to elimination of the variance.
If there are questions concerning this recommendation, please feel free to contact the TRW.
Attachment: Memorandum from EPA Tech Team to the TRW, entitled, Additional Color
Removal Technologies and Their Economic Impacts on Blue Ridge Paper
Products, Canton,NC, dated July 25, 2001

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON,D.C.20460
'SgIeD sN 'le
A
MEMORANDUM
DATE: July 25, 2001
SUBJECT: Additional Color Removal Technologies and Their Economic Impacts on Blue
Ridge Paper Products, Canton,NC
FROM: EPA Tech Team'
TO: Technology Review Workgroup
Purpose of this Analysis
As required by the 1997 Settlement Agreement, this memorandum presents a summary of an
analysis of available technologies that may be employed to further reduce color discharges from
the Blue Ridge Paper Products, Inc. (Blue Ridge) mill in Canton, NC. The analysis also includes
a summary of the economic impact("gross margin test") of the cost of implementing identified
color reduction technologies.
Members of the Tech Team visited the Canton mill on March 14, 2001 to observe and gather
information and data on the status of technologies implemented and color discharges at the mill
since the 1997 evaluation. This final memorandum incorporates analyses of the data gathered
from that visit, and Blue Ridge's response to EPA's follow-up request for additional technical
and financial data. This final memorandum is based on the May 4, 2001 preliminary draft
memorandum, and revisions to the July 10, 2001 draft final memorandum, based on a review of
Blue Ridge's comments, the June 8, 2001 Bleach Environmental Process Evaluation and Report
(BEPER) and subsequent comments by Liebergott and Associates and GL&V Pulp Group, Inc,
and additional comments from the Clean Water Fund of North Carolina, and the States of
Tennessee and North Carolina. This memorandum presents to the Technology Review
' EPA Tech Team is comprised of--Mark Perez,EPA/EAD;Karrie-Jo Shell,EPA Region 4;Don Anderson,
EPA/EAD;Betsy Bicknell,ERG,contractor;Neil McCubbin,subcontractor to ERG;Dan Bodien,subcontractor to
ERG.

Workgroup (TRW) process improvements evaluated by the Tech Team and considered to be
available technologies and briefly addresses relevant technologies evaluated in the BEPER.
Background and History
Blue Ridge operates a bleached papergrade kraft pulp and paper mill in Canton,NC, which it
purchased from Champion International Corporation in May 1999. Operations at the mill began
in 1908, but the mill has been extensively modernized, most recently in 1993. The mill currently
operates an 800 tpd hardwood pulping line and a 600 tpd softwood pulping line. After cooking,
pulp from each line is further delignified in single-stage oxygen delignifrcation systems installed
in 1993. Hardwood pulp is subsequently bleached with a DEoD sequence; pine pulp is bleached
with a DEopD sequence. Target brightness is 85 ISO. Up to 80 percent of the filtrate flow from
the pine bleach line is returned to the recovery cycle using the unique bleach filtrate recovery
(BFRTM)process, developed by Champion. A portion of the hardwood line bleach plant Eo-
stage filtrate flow is also recovered. Blue Ridge produces 250,000 tons per year of uncoated
paper including offset, tablet and envelope grades. The mill also produces 281,000 tons per year
of bleached paperboard used for liquid packaging and paper cups, including FDA approved
grades for milk and juice cartons. Since November 2000, pulp production has been reduced by
approximately 30 percent as the result of a major project to upgrade the No. 19 bleached
paperboard machine.
Continued Color Reduction Opportunities Since the 1997 NPDES Permit
The Canton Mill's 1997 NPDES permit included a schedule requiring continued study,
evaluation, and pursuit of effluent color reduction opportunities. Champion and Blue Ridge
submitted a series of reports to the NC Department of Environment and Natural Resources,
Division of Water Quality, evaluating the performance of the BFRTm process, end-of-pipe color
reduction technologies, and practices for minimizing color losses from manufacturing processes.
Since 1997 Blue Ridge has:
• continued full-scale operation of BFR for the pine line;
• concluded that full-scale BFR is not feasible for the hardwood line, but
implemented partial reuse of a portion of the Eo-stage filtrate as an effective
color-reduction approach;
• identified and implemented several practices for reducing losses of highly-colored
black liquor from manufacturing processes; and
• evaluated 16 end-of-pipe color removal technologies and determined that they
were presently economically and/or technically infeasible for the Canton mill.

Page 3
Process Improvements Analyzed by the Tech Team
The Tech Team identified five mill improvements capable of further reducing the discharge of
color in the mill effluent. For each of these improvements, technical feasibility, capital and
operating costs, and potential color reduction were reviewed. Each improvement can be
implemented independently of the others or in any combination. The costs incurred to
implement the improvements are additive,however separate evaluations are necessary to
accurately estimate the associated color reduction achieved by implementing any combination of
improvements. End-of-pipe color treatment technologies (e.g., chemically assisted clarification
with sludge dewatering and disposal)typically require initial capital investment and ongoing
operating expenses,not savings, and are likely to incur non-water quality environmental impacts.
For this reason, the Tech Team focused on pollution prevention approaches that offer the
potential to be more cost-effective: color reduction in low flow, highly color-concentrated
wastestreams, through manufacturing process changes or in-process treatment.
The first two process improvements, discussed below (improvements in BFR reliability and leak
and spill prevention and control -Best Management Practices (BMPs)), are improvements which
the Tech Team concludes offer the highest certainty for technical feasibility and color reduction.
Blue Ridge also identified these technologies as feasible color reduction opportunities that will
be implemented, but differed from the color reduction estimates included in this memorandum.
The next two process improvements (ozone addition to an existing chlorine dioxide bleaching
stage on the hardwood fiber line; adding a second stage to the current oxygen delignification
system on the softwood fiber line) also were evaluated by Liebergott, et. al., as feasible color
reduction opportunities. Additional technical evaluation and/or laboratory testing would be
appropriate to reliably determine the technical details of how to incorporate these processes into
the existing fiber lines and to more accurately predict their achievable color reduction, and the
relationship of these technologies to BFR. Additional analyses would be appropriate to
determine the most cost-effective design and the most economically feasible schedule for
implementing one or both of these improvements.
The fifth process improvement, color treatment for the chloride removal process (CRP)purge
stream (one of the two key components of the BFR process), has the potential for additional
color reduction. However, based upon initial bench-scale treatability studies by Blue Ridge,
further study of additional color treatment technologies is necessary. Process optimization on
both the hardwood and softwood fiber lines, as recommended in the BEPER, is anticipated to

Page 4
provide additional color reduction and is identified as the sixth process improvement. It was
concluded that the process optimization option was among those with the highest certainty for
technical feasibility and color reduction.
All color reductions resulting from the mill improvements are estimates based solely on available
data and information. While the Tech Team has concluded that these technologies would reduce
the color discharge from the Canton mill,there is a lack of directly comparable operating
experience with these technologies in other bleached papergrade kraft mills that can be used to
develop precise predictions of the extent of the color reduction benefits.
The BEPER evaluated additional in-process technology options for color discharge reduction
potential, including the implementation of a hot pressurized peroxide-enhanced extraction stage
in both fiber line bleach plants. At this time, the Tech Team does not have sufficient information
to confirm the applicability of this technology at the Canton mill nor relevant data to predict its
potential color discharge reduction capabilities. Therefore,while this memorandum does not
address this technology option, it may be feasible for implementation by Blue Ridge and
contribute to reducing color. In addition,the Tech Team did not analyze nor did the BEPER
recommend a Totally Chlorine-Free (TCF) bleaching option because of the high cost of this
technology and the lack of experience in producing and successfully marketing products made
by Blue Ridge at the Canton mill.
1. BFR reliability improvement. One of the two key elements in BFR is the Metals Removal
Process (MRP). Blue Ridge has found that this process element has been more challenging and
expensive to maintain than originally planned. The target BFR recycle rate (percent closure) for
the pine line is 80 percent. Due to unforeseen equipment failures (e.g., ion exchange media) and
metallurgy problems (e.g., erosion of multi-media filtration tank lining) in the MRP, however,
the pine line closure has averaged only 74 percent from October 1998 to the present. Blue Ridge
has undertaken improvements to the MRP system in order to maintain the process closure rate
and increase operating time. Improvements include rebuilding piping and valves, and changing
construction materials and metallurgy to better withstand the chemical and physical stress
experienced in the BFR system. Blue Ridge estimates that if BFR closure is maintained at 80
percent, annual average final effluent color discharge will be reduced by 1,000 to 1,200 lbs/day.
At this time, the Tech Team has no means of making an alternative quantitative prediction of
final effluent color reduction to compare to the Blue Ridge estimate.

Page 5
2. Improved black liquor leak&spill collection and control (BMPs). The Canton mill has an
extensive spill recovery system. Sumps in this system, including one sump added in the court
yard adjacent to the digester house as required by the 1997 Settlement Agreement, are equipped
with pumps that are activated automatically when sensors detect wastewaters with high
conductivity and color. High conductivity material is routed to the recovery system. Further
improvements to the black liquor collection system include:
• continuous improvement of operating practices so more leaks and spills are
recovered rather than discharged to sewer;
• further improvement in preparation for planned outages to maximize capture of
tank clean-out waste and routing to recovery;
• further reducing clean water that continuously runs into sewers to prevent dilution
of smaller spills and facilitate recovery of highly colored wastewaters; and
• further improvement in the equipment used for handling of knots rejects to
prevent black liquor leaks into the recovery sumps.
The plot below shows the color of wastewater treatment influent at the Canton mill. The
variability of influent color discharge to wastewater treatment is attributed to color discharge
peaks that represent, in part, unplanned spills or leaks discharged to sewers or intentional
diversions of highly-colored black liquor or other color sources routed to sewers during mill
equipment shutdowns.
100
kg/t
Figure 1
75 Daily color at influent to W WTP for Canton
so
25
0 30 60 90 120 150 180

Page 6
Due to the nature of the manufacturing processes and practical equipment operation and
reliability, all spills and color losses to sewers cannot be fully anticipated, predicted, and
completely contained. However, a comparison of the variability of the Canton mill influent color
data to available primary influent color data at another bleached papergrade kraft mill indicate
that a detailed review of the spill prevention and recovery system at the Canton mill (by mill
staff or external consultants), including involvement by the mill operators, can further uncover
the causes of and better quantify black liquor losses and other color sources that can be avoided
or recovered. This will result in an overall reduction in color discharge,both in long-term
average and variability. Through improved planning of mill equipment shutdowns, continuing
efforts to minimize process operation variability, and increased recovery of highly-colored leaks
and spills, discharges of highly colored material to the wastewater treatment system can be
reduced more consistently below existing levels.
Further reducing peaks in color discharges within the mill and preventing highly colored flows
from reaching the wastewater treatment system will further reduce the variability of color
discharges from the wastewater treatment system to the Pigeon River. For example, limiting the
color of the primary clarifier influent to less than 70,000 lb/day through continuing efforts to
improve the mill's BhV system and process operations would reduce the color loadings from
mill processes to the end-of-pipe wastewater treatment system by more than 8,000 lb/day. The
Canton mill operated under this primary clarifier influent color threshold approximately 74
percent of 2000, excluding November through December 2000. This time period was considered
not to be representative of steady-state operations because of the reduced pulp production
resulting from upgrading the No. 19 bleached paperboard machine. Assuming the average
reduction of 45 percent across this wastewater treatment system for"brown" color derived from
black liquor, this would result in a minimum decrease of 4,400 lb/day in the average final
effluent color load.
Clean water, such as packing gland water,presently flows in several sewers with recovery
sumps. These colorless streams dilute other colored wastestreams, such as small black liquor
leaks and spills, to the point where the in-stream conductivity is too low to trigger recovery. By
eliminating clean water streams or diverting them away from sewers that collect black liquor
leaks and spills, wastewater streams with elevated color can be recovered more readily, resulting
in a reduction in color discharge to the end-of-pipe wastewater treatment system. Also, the
unintentional but intermittent discharge to the sewer of filtrate from knots and screen rejects can
be recovered.

Page 7
At this time, the Tech Team has no basis for determining an accurate correlation between
unaccounted color and sewer generated color, as reported in Section 2 of the Canton Mill
Environmental Performance Update presented by Blue Ridge during the March 14, 2001 Tech
Team Canton mill visit. During the March 14 visit, Blue Ridge staff indicated that results of
studies of sewer generated color showed a relationship between bleach plant filtrate pH and
temperature and unaccounted color generated in mill sewers. By operating within the range of
pH and temperatures identified during the studies the Canton mill has had some success in
controlling this source of unaccounted color. Based on this information, the Tech Team
concludes that by further reducing process operation variability, including operating within the
pH and temperature range identified during the studies, the mill can continue to also minimize
sewer generated color, thereby reducing one source of unaccounted color. Reducing overall
color discharges through BMPs and other management practices will likely further reduce
remaining unaccounted color. However, additional studies are necessary to further develop any
relationship between accounted and unaccounted color sources.
As noted above, analysis of primary clarifier influent color loading data demonstrates that color
loading to the wastewater treatment system of lower than 70,000 lbs/day is possible during
steady-state operations. Through continuing efforts to minimize unplanned spills and leaks and
intentional discharges of colored streams and continuing efforts to minimize process operation
variability, the Canton mill can achieve further reduced primary clarifier influent color loads and
subsequent final effluent color discharge within this range on a more consistent basis than
demonstrated in 2000 (i.e., more than 74 percent of the time). On this basis, the Tech Team
concluded it is feasible to reduce final effluent color by more than 5,000 lbs/day through
improved black liquor leak and spill collection and control.
3. Ozone/Chlorine dioxide stage for hardwood bleach line. Ozone is used in more than ten kraft
mills around the world to bleach pulp, including two in the US and one in Canada. There are
several process configurations,but the most common is to operate an ozone (Z) mixer and
reactor immediately upstream of a chlorine dioxide reactor,without any washing between the
application of the two chemicals. This is known as a"ZD" stage. A system of this type was
retrofitted in the Domtar mill at Espanola, Ontario, Canada in 1999.' Bleaching with ozone on
the hardwood line, one of the Domtar mill's two pulp lines, resulted in a 27 percent reduction in
the discharge of color in the combined mill treated effluent.' The conversion to a ZD stage
Z Munro,Fred and John Griffiths,Operating Experience with an Ozone-based ECF Bleaching Sequence,Tappi,2000.
Ibid.

Page 8
would reduce the use of chlorine dioxide and caustic chemicals for bleaching in exchange for
ozone. The energy requirements for ozone production would be offset by the energy savings
from less chlorine dioxide and caustic production, resulting in a net reduction in energy
consumption with the ZD stage.
As of September 2000, the long-term average color discharge from Canton's hardwood bleach
line was 12,800 pounds/day'. The Espanola experience suggests that implementation of a ZD
stage in the hardwood bleach plant at the Canton mill could reduce the filtrate color discharge by
3,000 to 6,400 lbs/day. Based on comments received, the Tech Team acknowledges that
operating parameters, such as wood species processed and technology supplier performance
guarantees, may influence the practical color reduction achievable through implementation of a
ZD stage at the Canton mill, in comparison to the Espanola experience. These estimates are
based solely on the demonstrated performance and the Tech Team's assumption of color sources
at the Espanola mill, confirmed at the recent Pulp and Paper Technical Association of Canada
(PAPTAC)meeting in Thunder Bay, Ontario. Laboratory bleaching trials and possible
communication between Blue Ridge and Domtar staff would be necessary to reliably predict the
achievable color reduction possible with this option for the Canton mill.
The technical evaluation of this process improvement included in the BEPER yielded a
hardwood filtrate color discharge reduction within the range of Tech Team estimates.
4. 2"d stage OD for pine line. Oxygen delignification (OD) on the Canton Mill pine line is a
single stage system installed in 1993. It has been concluded that retrofitting a second OD stage
for the pine line could contribute to reduced color discharges in two ways. The first would be a
reduction in color for those filtrates presently not captured and reused in the BFR process. The
second would be a color reduction in the Chloride Removal Process (CRP) purge stream as a
result of less chloride from chlorine dioxide used for bleaching.
Costs were estimated for a reactor with oxygen mixer and chemical charge equipment installed
upstream of the existing reactor. Previously, the Tech Team anticipated increasing the kappa
number(lignin content) of the cooked pulp from 24 to 32 and utilizing a two-stage OD system to
reduce kappa number from 32 to 11, an approximate 65 percent kappa reduction across the two-
stage system. Based upon comments from BRP and further technical analysis, and review of the
BEPER, it was concluded that it is technically feasible for a two-stage OD system at the Canton
4 Jacobs Engineering Group,2001 Color Removal Technology Assessment,February 2001.

Page 9
mill to achieve an overall reduction of 50 percent in kappa number, rather than 65 percent as
previously anticipated. Therefore,with the Canton mill continuing to pulp to a kappa number of
24, the new two-stage OD system would reduce pulp kappa number into the bleach plant from
the current output of 16 to about 12, corresponding to a 50 percent kappa number reduction from
the current digester output of 24. The quantity of color released from the bleach plant will be
reduced in proportion to the reduction of the input kappa number.
By decreasing the kappa number of the pulp fed to the bleach plant from kappa 16 to 12 with a
two-stage OD system, the quantity of chemicals required in the first two stages of the bleach
plant can be reduced, because there is less lignin present in the incoming pulp to remove by
bleaching. The reduction in chlorine dioxide used for bleaching would result in a proportional
reduction in chloride load to the CRP and reduce color discharged from the purge stream in
proportion to the reduction in chloride being treated.
In response to comments received, it has been concluded that implementing a two-stage OD
system without increasing the kappa number of the cooked pulp from 24 to 32 would not achieve
a 1.5 percent pulp yield gain as anticipated with increasing digester kappa number and achieving
greater delignification with the proposed two-stage OD system. However, operating a two-stage
OD system with a higher than 50 percent delignification rate and a digester kappa number higher
than currently employed at the Canton mill is commonly seen at comparable bleached
papergrade kraft mills. Therefore,the Tech Team anticipates that additional process engineering
will maximize the benefits of a two-stage OD system at the Canton mill and enable the mill to
capture the increased delignifeation and yield gain potential of this technology and achieve
annual wood cost savings of up to approximate $950,000 from up to a 1.5 percent yield increase
across the proposed two-stage OD system.
Based on additional information supplied by Blue Ridge regarding operational limitations of the
BFR system, the Tech Team concludes that a two-stage OD system would not have a significant
impact at this time on the Canton mill's ability to increase BFR closure rate above 80 percent on
a day-to-day basis.
For this analysis, it was estimated preliminarily that a second OD stage could reduce total
influent color-discharge to the wastewater treatment system by 1,500 to 2,000 lb/day from
reductions in pine line bleach plant filtrate color and CRP purge stream color.

Page 10
The technical evaluation of two-stage OD included in the BEPER yielded reduction in color
discharge influent to the wastewater treatment system within the range of the Tech Team
estimates.
5. Color Treatment of CRP purge stream. The Chloride Removal Process (CRP)purge is a low
flow, highly concentrated waste stream. Color is typically 50,000 pcu, in a 10 gpm (0.01 MGD)
flow. The CRP purge contributes up to approximately 5,000 lbs/day (13 percent) to the total mill
loading to the wastewater treatment system influent,but only 0.06 percent of the discharge flow.
It was originally speculated that it may be feasible to reduce the color in this stream by
precipitating the colored organic material with lime at a dosage of 20 g/L5, and burning the
resulting sludge with the main lime mud stream fed to the mill's lime kiln. Laboratory trials
would be necessary to test the feasibility of color removal from the CRP purge stream by lime
treatment.
Blue Ridge subsequently conducted laboratory trials of color precipitation using four calcium
compounds, including lime mud, fresh lime, calcium chloride, and milk of lime. The
preliminary results of these trials show that at a dosage of 20 g/L,none of the compounds tested
reduced color in the CRP purge stream. Although color removal was demonstrated at higher
dosage rates, increased chemical usage would result in substantially higher operating costs,
require larger sized equipment at higher capital cost, and also result in a higher production rate of
sludge to be burned in the mill's lime kiln. Excess sludge produced from this process that is not
burned must be landfilled at additional cost.
Based on preliminary laboratory trials, Blue Ridge concluded that lime treatment of the CRP
purge is not a feasible color reduction option for the Canton mill. However, the Tech Team
recommends additional review of other innovative technologies for treatment of color in the CRP
purge stream, such as the application of the X-Filter process recently implemented at a totally
chlorine free (TCF) mi116. By minimizing color contributions from this stream, the potential
exists to achieve a significant reduction in primary influent color discharge of up to 5,000
lbs/day.
5 NCASI Technical Bulleting No.239,The Mechanisms of Color Removal in the Treatment of Pulping and Bleaching
Effluents with Lime.1. Treatment of Caustic Extraction Stage Bleaching Effluent July, 1970.
6 Comments on the Draft Report on Additional Color Removal Technologies and Economic Impacts for BRPP,Hope
Taylor,Clean Water Fund of North Carolina,July 18,2001

Page 11
6. Process Optimization. The BEPER identified sixteen recommendations for optimizing the
hardwood and softwood fiber lines, focusing mainly on the current OD systems and bleaching
operations. It was estimated that a reduction could be achieved in chlorine dioxide use in the
first bleaching stage of up to 27 percent for the hardwood line and 18 percent for the softwood
line. The reduction in chlorine dioxide use would result in a bleach plant filtrate color reduction
of up to 700 lbs/day from the hardwood line and up to 4001bs/day from the softwood line. The
Tech Team estimated an additional color reduction from the CRP purge stream of 600 lbs/day
resulting from the decreased chlorine dioxide usage. At this time, the Tech Team has no means
of making an alternative quantitative prediction of bleach filtrate color reduction to compare to
estimates presented in the BEPER. Therefore, it is estimated that through efforts by mill staff to
maximize the color reduction benefits from the process optimization opportunities identified by
Licbergott, et, al., the Canton mill would achieve a total color reduction of 1,700 lbs/day in
wastewater treatment system influent.
Color Reduction Summary
The Tech Team estimates that by improving BFR reliability and black liquor leak and spill
collection and control, the Canton mill final effluent will be reduced by more than 5,000 lbs/day.
Process optimization, as outlined in the BEPER,would result in a further final effluent color
reduction of approximately 1,400 lbs/day. This assumes the average color reduction of 45
percent across the existing wastewater treatment for the CRP purge stream and other"brown"
color sources derived from black liquor and no reduction in color from bleach plant filtrates.
Table 1 presents a summary of the estimated reductions in final effluent color attainable with the
highest certainty by implementing improved BFR reliability, improved BMPs, and process
optimization.

Page 12
Table 1: Summary of Process Improvements and Associated Color Reductions
(Highest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (lbs/day)
1 BFR reliability improvement --- 1,000-1,200
2 Improved black liquor leak & spill collection and --- > 5,000
control
6 Process Optimization 1,700 1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION >7,400
Additional potential mill improvements to reduce color discharge at the Canton mill were also
identified. These process improvements require further study to more accurately determine
achievable color reduction and thus are not recommended at this time for immediate
implementation. These improvements include a ZD stage in the hardwood bleach plant, with a
preliminary estimate of a 3,000 to 6,400 lbs/day color load reduction in influent to the
wastewater treatment system, and a second OD stage for the pine line, with a preliminary
estimate of a 1,500 to 2,000 lb/day color load reduction in influent to the wastewater treatment
system. Table 2 presents a summary of preliminary estimates of color reductions for these two
additional process improvements that need further study. Reductions presented in Table 2 are
preliminary estimates with reduced certainty compared to those presented in Table 1, but are
based upon identified technology options available for the Canton mill.

Page 13
Table 2: Summary of Process Improvements and Associated Additional Color Reductions
Needing Further Study (Reasonable Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (lbs/day)
3 Ozone/Chlorine Dioxide stage for hardwood bleach 3,000-6,400 3,000-6,400
line
4 2 d stage OD for pine line 1,500-2,000 1,100-1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION 4,100 - 7,800
Table 3 presents a preliminary estimate of color reduction potential for the removal of color from
the CRP purge stream. The Tech Team recommends this stream for additional review of
potential color reduction technologies but cannot identify a particular technology option at this
time. Potential for additional color load reduction up to 2,750 lbs/day in final effluent to the
Pigeon River. Table 3 presents potential color reduction estimates with the lowest certainty.
Table 3: Summary of Additional Potential Color Reductions Needing Further Study
(Lowest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (lbs/day)
5 1 Color Treatment of CRP Purge Stream #5,000 #2,750
TOTAL ADDITIONAL POTENTIAL FINAL EFFLUENT COLOR #2,750
REDUCTION

Page 14
Economic Analysis
The estimated capital and operating costs for the process improvements one through four were
estimated and are summarized below. Costs could not be developed at this time for process
optimization or CRP treatment and thus are not presented. However, costs for these
improvements should be modest.
Table 3: Estimated Costs
Process Improvement Capital Cost Annual O&M
($) ($/year)
1 BFR reliability improvement $1,300,000 $85'0006
2 Improved black liquor leak & spill collection and $100,000 $50,000
control
3 Ozone/Chlorine Dioxide stage for hardwood bleach $1,500,000 ($350,000)
line savings
4 2"a stage OD for pine line $2,000,000 ($2,100,000)
savings
Blue Ridge Paper Products Inc. was formed in May 1999 with the purchase of seven
plants (including the Canton Mill) from Champion International Corporation. Blue Ridge Paper
Products is owned 55 percent by KPS Special Situations Fund, L.P. and 45 percent by the
employees of Blue Ridge Paper through an employee stock ownership plan. At the time of the
1997 report EPA documented substantial losses over five years for the Canton Mill and
Champion had just announced its intention to sell or close the mill. However, because of the sale
of the mill to the Blue Ridge, the previous data are not comparable to the more recent data.
Further, the data submitted by Blue Ridge is still confidential, so this report cannot present as
much detail as the 1997 report.
The current analysis is based on information submitted by Blue Ridge covering part of
1999 (May-December) and all of 2000 (all of the existing financial data for the company). The
results may be relatively uncertain because of the lack of data and the company may be too
young for the current data to reflect its ultimate financial health. EPA used three measures of
financial health (gross profit test, discounted cash flow, and Altman's Z)7 to assess the impact of
'See Interim Economic Guidance for Water Quality Standards: Workbook,EPA 823-B-95-002,March 1995,and
Economic Analysis for the National Emission Standards for Hazardous Air Pollutants for Source Category:Pulp and
Paper Production;Effluent Lim tations Guidelines,Pretreatment Standards,and New Source Performance
Standards: Pulp,Paper, and Paperboard Category—Phase 1.

Page 15
air emissions control technologies and devices (not addressed in this memorandum, such as
MACT H and regional NOX control) and wastewater compliance costs (separate and combined)
on the mill and company. The costs for the wastewater control options presented in Table 3 do
not change the financial status of the mill or company. However, the costs for some of the air
emissions control options do impact the health of one or both entities. When the wastewater
costs are added to costs for air emissions control, the impacts of the water costs do not change
the financial status of either the mill or company when compared to the impact of the air costs
alone.
References
Blue Ridge Paper Products, Inc. Canton Mill Canton Mill Environmental Performance Update,
Prepared for U.S. EPA Technology Review Workgroup. March 14, 2001.
Blue Ridge Paper Products, Comments on and Transmittal of Financial Data for Economic
Analysis of Blue Ridge Paper Products, from Bob Williams, May 18, 2001 (CBITS 00003911-
01)
Comments on Preliminary Draft Final Tech Team Report, email from Derric Brown, Blue Ridge,
to Don Anderson, EPA, May 18, 2001
Comment Clarification of May 18, 2001 Blue Ridge Responses to EPA Questions, from Derric
Brown, Blue Ridge, June 4, 2001
Comments on Draft Final Tech Team Report, from Bob Williams,Blue Ridge, to Don Anderson,
EPA, July 13, 2001
Comments on Draft Final Tech Team Report, from Derric Brown, Blue Ridge, to Don Anderson,
EPA, July 17, 2001
Comments on Draft Final Report, email from Forrest Westall,North Carolina DENR, to Don
Anderson, EPA, July 17, 2001
Comments on Draft Final Report on Additional Color Removal Technologies and Economic
Impacts for BRPP, Hope Taylor, Clean Water Fund of North Carolina, July 18, 2001

Comment on Draft Final Tech Team Report, email from Paul Davis, State of Tennessee, to Don
Anderson, Julyl8, 2001
Comment on Draft Final Tech Team Report, email from Lew Shackford and Norm Liebegott, to
Don Anderson, EPA, July 19, 2001
Jacobs Engineering Group, 2001 Color Removal Technology Assessment, Blue Ridge Paper
Products Inc. Prepared for The North Carolina Division of Water Quality. February 2001.
Liebergott,Norm, and Lew Shackford, Bleach Environmental Process Evaluation and Report,
June 8, 2001
McCord, Aimee,A Laboratory Analysis of Color removal Across a Pulp and Paper Mill
Wastewater Treatment Facility, Canton, North Carolina, Duke University, School of the
Environment, 1995
Munro, Fred and John Griffiths, Operating Experience with an Ozone-based ECF Bleaching
Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press.
NCASI Technical Bulletin No. 239, The Mechanisms of Color Removal in the Treatment of
Pulping and Bleaching Effluents with Lime. I. Treatment of Caustic Extraction Stage Bleaching
Effluent. July, 1970.
Salisbury, Chad A Laboratory Analysis of Color Removal Mechanism Across the Wastewater
Treatment Facility of a Pulp and Paper Mill, Canton, North Carolina, Duke University, School
of the Environment, 1996
Springer, Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry. Page 182
Wiley Interscience, 1986.
Springer, Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry, 3 d edition.
Page 286. TAPPI Press, 2000.

Appendix 1: Color Balance (911100 to 12/31/00)
Figure 2.6, Presented by Blue Ridge on March 14, 2001
Sewer Description Color Load
ID (lbs/day)
213 Digester area sewer: Digesters, HW 4,323
line, knot rejects
3A Alkaline sewer: Pine and HW Eo, 12,954
Pine line BSW, 02 Delig
1 PMs11 & 12,HW weak liquor tank 1,991
513 Recovery,BLOx, CRP* 7,852
6A Acid sewer: Pine and HW D1 17,345
filtrate+Pine D2 filtrate
Contaminated Condensate 1,591
Combined Condensate 260
Total 46,316
Primary Influent (PI) 49,284**
Unaccounted Color 2,968
(PI minus Total)
Secondary Effluent 37,696
Percent Removal in Treatment 23 %
* CRP contributes 5,000 to 6,0001bs/day to 5B sewer
** Measured using test method in NCASI Tech. Bull. 803, An Update of Procedures for the
Measurement of Color in Pulp Mill Wastewaters,May 2000.

Appendix 2: Table of Effluent Color Limits, 1997 to Present
Color Limit True Color(Ibs/day)
Monthly Average Annual (Long-term)
Average
1997 Permit 125,434 98,168
Settlement Agreement, February 1998 69,000 60,000
(starting December 1, 1998)
Settlement Agreement, February 1998 --- 48,000 to 52,000
(Ultimate Target)
Interim Limits, May 2001* 55,000 48,000**
* As recommended by Technology Review Workgroup (TRW) and incorporated by NC in
BRP's NPDES permit.
** Reduced end-of-pipe color discharges since November 2000 reflect, in part, reduced pulp
production (approximately 30 percent) during this period because of the ongoing project to
upgrade the No. 19 paper machine used to produce bleached paperboard.

Appendix 3: Ozone Bleaching
Munro, Fred and John Griffiths, Operating Experience with an Ozone-based ECF Bleaching
Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press.

Appendix 4: Two-Stage Oxygen Delignification
Comparison of one- and two-stage oxygen delignification systems
Item Current Single-Stage System Proposed Two-Stage System
Oxygen Reactors One two
Input Kappa Number 24 24
Output Kappa Number 16 12
Total C102 Used 28 kg/ton* 22 kg/ton*
Oxygen Used 23.4 kg/ton* 28.3 kg/ton*
Total NaOH Used 45 kg/ton* 37 kg/ton*
* air-dried metric ton of bleached pulp