NC0000272_2000_Color_Feasibility_Study_20001228

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BLUE RIDGE
PAPER PRODUCTS INC.
December 28, 2000
Mr.Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin-Place — - -
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products,Inc. Canton Mill
January 1,2001 Color Limit Feasibility Report
Dear Mr. Westall:
Attached is the January 1, 2001 Color Limit Feasibility Report required by Part III, Section E 12 of the
Canton Mill's NPDES permit. This report is also required by the Settlement Agreement, paragraph 24,
and the Revised Color Variance, paragraph 5H. Blue Ridge Paper Products is submitting this report to
you in your capacity as Regional Water Quality Supervisor for the Division of Water Quality and as a
member of the Technology Review Workgroup. Blue Ridge Paper Products would appreciate you
distributing the enclosed copies to the members of the Technology Review Workgroup.
Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of
48,000 — 52,000 pounds per day is feasible. Due to the limited data set available, Blue Ridge Paper
Products believes it is appropriate to use a 99°percentile confidence interval to extrapolate long term and
continuing monthly and annual average effluent limitations. Based on this statistical review of the
available data from January 1998 - October 31, 2000 the Canton Mill recommends an annual average
color limit of 49,612 lbs/day and an average monthly color limit of 59,796 lbs/day.
For the June 1, 2001 report, (required by Part III, Section E, paragraph 14, of the Canton Mill's NPDES
Permit),Blue Ridge Paper Products recommends using a 95`h percentile confidence interval to statistically
evaluate the monthly and annual average color discharge. Using a 95a'percentile statistical review of the
limited data available from January 1998—October 31, 2000 the annual average color is 48,388 Ibs/day
and the monthly average color is 55,556 lbs/day. Blue Ridge Paper Products believes the 95 s percentile
confidence interval will be appropriate with the additional color data that will be available for the June 1,
2001 analysis. The attached Table includes the summary of the 99 s and 95 h percentile statistical data.
Please call me at(828) 646-2033 or Derric Brown at(828) 646-2318 if you have any questions regarding
this report.
(2Sincerely,
l`��Oinrte�r�d_.
Bob Williams
Director- Environmental,Health and Safety
Attachments
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

BLUE RIDGE
PAYER PRODUCTS INC.
Copy: Keith Haynes
North Carolina Department of Environment
Health and Natural Resources
59 Woodfin Place
Asheville,NC 28801
Technology Review Workgroup (via Division of Water Quality)

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
I. Introduction
The following report details the Canton Mill's ability to achieve a target annual average
color limit in the 48,000—52,000 lb/day range in accordance with the requirements of the
1997 modified Color Variance and NPDES Permit. Part III, Paragraph E 12 of the 1997
Permit provides in part, as follows:
`...The permittee shall submit to the Division of Water Quality
and the Technology Review Workgroup by January 1, 2001, a
report on the feasibility of achieving a target annual average
color loading limit within the range of 48,000 — 52,000 Ibs/day
based on full implementation of the Near-Teem Package. This
report shall include all available data necessary to derive the
lowest achievable annual average and monthly color loading
limits... "
This report is submitted to fulfill the requirements of Part III, Paragraph E 12. Based on
the Mill's performance from January 1998 through December 2000, Blue Ridge Paper
Products believes that achieving a target annual average color limit within the range of
48,000—52, 000 pounds per day is feasible.
1

January 1, 2001 - Color Limit Feasibility Report
Monthly Average Secondary Effluent Color (Ibs/day)
January 1987 - October 2000
700000
600000
500000
c>s
400000
N
.a
G
O 300000
6
V
200000
100000
0
Aug-85 Apr-88 Jan-91 Oct-93 Jul-96 Apr-99
--*—SE Color Ibs/day
Blue Ridge Paper Products, Inc. Figure 1
Canton Mill page 2

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products,Inc.
Canton,North Carolina
H. Color Performance
The Canton Mill has achieved a color reduction of over 85%u since 1988 in the annual
average amount of color discharged, as illustrated in Figure 1. The improved color
performance is due to the Canton Modernization Project, full implementation of the
"Near-Term Package" and continuous color management by the mill.
The Near-Term Package includes the installation of BFRTM on the mill's pine fiberline,
implementation of best management practices (BMPs) detailed in the June 1, 1998 Color
Technology Report, and partial BFR(Eo filtrate recycle) on the hardwood fiberline.
These collective efforts have contributed to the mill's continuous and significant
reduction in effluent color.
The 1998 average annual color discharged was 50,386 lbs/day and the 1999 average
annual color discharged was 41,048 lbs/day. The 2000 average annual color(through
October) is 44,837 lbs/day. All of these values are within or below the target annual
average color range of 48,000—52,000 lbs/day specified in Part III,Paragraph E 12 of
the 1997 Permit.
The 48,000 - 52,000 target range was selected because it was projected to result in
significant mitigation in the occurrence and degree of color at the Hepco gage. Based
upon North Carolina's minimum flow criterion (30Q2), historical flow records, and the
January 1998—October 2000 annual average color value of 45,458 lbs/day, it is expected
that color in the Pigeon River at the Hepco gage will be less than 50 scu's (standard color
units) 100% of the time at all flows above 30Q2. At all monthly average flows greater
than the 30Q2 since January 1999, average monthly color at Hepco has been less than 50
scu's. Therefore, Blue Ridge Paper Product's actual color performance has resulted in
significant mitigation in the occurrence and degree of color at the Hepco gage as
projected by the 1997 Permit and Settlement Agreement.
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 Ibs/day and the
January 2000—October 2000 actual average annual color of 44,837 lbs/day are both
below the target annual average color range of 48,000—52,000 Ibs/day specified in Part
III, Paragraph E 12 of the 1997 Permit. It was anticipated, and has now been
demonstrated, that full implementation of the Near-Term package would achieve an
annual average color within the 48,000—52,000 lbs/day range.
3.1 Review of Color Performance Data
Based on a statistical evaluation of the mill's annual color,Blue Ridge Paper Products
believes an annual average effluent color limit in the 48,000—52,000 lb/day range is
achievable. Due to the limited data set available, it is appropriate to use a 99%
confidence interval to extrapolate long term and continuing monthly and annual average
effluent limitations.
The January 1998—October 2000 annual color average using a 99`h percentile
distribution is 49,612 Ibs/day. The January 2000—October 2000 annual color average
using a 99`h percentile distribution is 48,911 Ibs/day. These values are both within the
48,000— 52,000 lb/day range. Based on a statistical review of the data and the limited
data set available, Blue Ridge Paper Products, Inc. recommends an annual average
effluent limit of 49,612 lbs/day.
The January 1998—October 2000 monthly color average using a 990,percentile
distribution is 59,7961bs/day. The January 2000—October 2000 monthly color average
using a 99`h percentile distribution is 58,953 lbs/day. Based on a statistical review of the
data and the limited data set available,Blue Ridge Paper Products recommends a monthly
average effluent limit of 59,796 lbs/day.
4

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
III. Conclusion
Blue Ridge Paper Products, Inc. believes it is feasible to achieve a target annual average
color limit within the range of 48,000—52, 000 lbs/day. The Canton Mill recommends
_an average annual color limit of 49,612 lbs/day and an average monthly color limit of
59,796 lbs/day. These recommended color limits demonstrate the Canton Mill's
commitment toward color reduction and continued color management.
Using North Carolina's governing flow criteria(30Q2), historical flow records, and the
recommended annual average color limit of 49,612 lbs/day, it is expected that color in the
Pigeon River at the Hepco gage will be less than 50 true color units approximately 97%
of the applicable time.
5

TABLE
January 1, 2001 Color Limit Feasibility Report
Monthly Average Data - Max Month Calc
Data Set= 1/1198-10/31/2000 1/112000-10/3112000
KS Normality test normal normal
Autocorrelation= 0.61
no. of obs. = 34 10
xbar - 45478.5 44836
stddev 6145 6059
95th safe MONTH from normal dist 66556 54773
99th safe MONTH from normal dist 59796 58953
95th safe YEAR from normal dist 48388 47704
99th safe YEAR from normal dist 49612 48911
Ranked observations
95th percentile for max MONTH 56809 55514
100th percentile for max MONTH 58542 58009