NC0000272_Statistical_Evaluation_Report_20010601

COMPARATIVE AND STATISTICAL
EVALUATION REPORTS
Prepared for:
North Carolina
Division Water Quality
4
Prepared by:
Blue Ridge Paper Products Inc.
Canton, North Carolina
May 31 , 2001

BLUE RIDGE
PAPER PRODUCTS INC.
May 29,2001
Mr.Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No. NC0000272,Blue Ridge Paper Products,Inc. Canton Mill
June 1,2001 Required Reports
Dear Mr.Westall:
Attached are the June 1, 2001 Comparative Evaluation Report and the June 1, 2001 Color
Performance Statistical Evaluation. These reports are submitted to fulfill part of the
requirements stated in Part III,Paragraph E 14 of the modified 1997 NPDES Permit.
Please call me at(828) 646-2033 or Derric Brown at(828) 646-2318 if you have any questions or
concerns regarding these reports.
Sincerel-\6k
Bob Williams
Director-Environmental,Health and Safety
Attachment
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

Xc: Keith Haynes
Dave Goodrich
Mikee Myeis

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
I. Introduction
The following report describes the important color reduction activities that have
been accomplished over the term of the modified 1997 NPDES Permit ("1997
Permit") and includes a discussion of technology assessments Blue Ridge has
undertaken to evaluate potential color reduction options. Part III, E. Paragraph
14 of the 1997 Permit provides, in part, that:
"...By June 1, 2001, the permittee will submit a report to the
NPDES Committee and N.C. DENR, Division of Water Quality,
on the comparative evaluation of the above collective efforts as
part of the Variance review process (Triennial Review of North
Carolina Water Quality Standards.)..."
This report is submitted to fulfill this requirement of Part III, E. Paragraph 14.
Permit No. NC0000272
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June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
II. Summary of Color Reduction Activities
Since the issuance of the 1997 NPDES Permit, the Canton Mill has
accomplished the following color reduction activities:
1. Identified and implemented certain Best Management Practices
(BMP's) to reduce color. The following BMP's were implemented
before June 1, 1998, and a report on the implementation was
submitted to DWQ, the TRW and the NPDES Committee on that date.
a. Installation of replacement digester recirculation pumps.
b. Installation of a double-chambered pine courtyard spill collection
sump.
c. Installation of weak black liquor tank containment, and
d. Correction of evaporate set demister clogging, installation of
condensate instrumentation and sampling ports for the
evaporator set and assurance of continued dry conveying of
knot rejects.
2. Submitted Low Flow Contingency Plan to DWQ and TRW by
December 1, 1998 (approved by NPDES Committee in February
1999).
3. Prior to December 1, 1998, complied with a reduced color limit in the
Permit of 60,000 lbs. per day (annual average) and 69,000 lbs. per day
(monthly average).
4. Began implementation of partial Eo stage filtrate recycle on the
hardwood line before January 1, 1999 and submitted a report on the
color reduction benefit resulting from the partial implementation and a
projection of potential color reduction benefit to be gained from full
implementation of BFR on the hardwood line to DWQ, TRW and the
NPDES Committee by December 1, 1999.
5. Submitted a color limit feasibility report to DWQ, TRW and the NPDES
Committee before January 1, 2001, which concluded that the Canton
Mill could comply with a color limit within the range of 48,000-52,000
lbs. per day (annual average).
Permit No. NC0000272
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June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
Implementation of these BMP's, together with improved mill operations and
continued commitment to further reduce color, has reduced color by 32% over
the term of the 1997 Permit. As described in the January 1st, 2001 Report, the
mill has achieved a target annual average color loading of 48,000 — 52,000
pounds per day. On May 1, 2001 the North Carolina Division of Water Quality
reduced the permit limit for annual average color from 60,000 Ibs/day to 48,000
Ibs/day and the monthly average color limitation was reduced from 69,000
Ibs/day to 55,000 Ibs/day. Based on data received from the National Council on
Air and Stream Improvement (NCASI), the Canton Mill has the lowest color of
any mill in its industry category.'
Based on a June 7,2000 Benchmarking Canton Wastewater Effluent Parameters letter from the National
Council for Air and Stream Improvement(NCASI).
Permit No. NC0000272
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June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
III. Additional Color Reduction Studies
3.1 End-of-Pipe Treatment and In-Process Technologies
In an effort to identify either a breakthrough improvement in color removal
efficiency or reduction in cost, the mill has evaluated end-of-pipe color reduction
technologies three times in the past thirteen years, including a 2001 study by
Jacobs Engineering Group, Inc. (2001 Color Removal Technology Assessment,
the "Jacobs Report"). The Jacobs Report evaluated 16 end-of-pipe technologies.
It is clear that no breakthrough in economic or technical feasibility has or is likely
to occur in end-of-pipe color removal technologies. Such technologies have not
been commercially demonstrated and are generally not economically feasible
because they require a significant initial capital investment with continued
operating costs and no associated savings.
During this same thirteen-year period, however, the Canton Mill implemented
alternative in-process pollution prevention technologies including oxygen
delignification, Elemental Chlorine Free bleaching, Bleach Filtrate Recycle TM and
those technologies comprising the "Near-Term" package, resulting in a significant
reduction in the color discharged.
Therefore, based upon this record, it is Blue Ridge's intention in the future to
focus on in-process pollution prevention technologies and the potential treatment
of selected, colored wastewater streams before they enter the wastewater
treatment plant (WWTP) and, in particular, the Chloride Removal Process (CRP).
Blue Ridge believes in-process pollution prevention and treatment of selected
wastewater streams hold the greatest likelihood of success for further color
reduction. In the future, Blue Ridge believes its time and resources would be
Permit No. NC0000272
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June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
better devoted to in-mill treatment of particular wastewater streams rather than
end-of-pipe, secondary effluent color removal approaches.
3.2 Polyamine Trials
Polyamine addition trials were conducted in January 2001 at the primary clarifier,
secondary clarifier, and colored in-mill wastewater streams, and were not
successful-.-The concept of polyamine addition is to reduce color through
precipitation of color bodies, which attach to the polyamine, coagulate, and settle
in primary clarification. Numerous trial approaches were conducted to study
comprehensively the effectiveness of polyamine for color removal. While
treatment of colored wastewater streams in the pulping and recovery areas
appeared to remove color, the color bodies re-solubilized in the wastewater
collection system and there was no significant net reduction in secondary effluent
color. Treating the primary clarifier resulted in color reductions, but wastewater
treatment plant sludge quality declined to an unmanageable condition and
recycled belt press filtrate solids increased significantly. Treating the secondary
effluent resulted in minimal color reductions; in addition, this type of treatment
would require the installation of equipment and increased operating costs as
described in the Jacobs Report , and might have adverse effects on the chronic
toxicity of the wastewater discharge.
3.3 CRP Treatment with Lime
Laboratory studies were recently performed on the Chloride Removal Process
(CRP) purge stream, a relatively high color, low flow stream,associated with the
BFRTM process. The purge stream was treated with various sources of calcium
in an effort to precipitate color bodies. Lime precipitation was concluded to be
Permit No. NC0000272
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June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
infeasible due to the massive quantities necessary to partially reduce color and
the large quantities of solid waste generated.
3.4 Third Party Evaluation of Canton Mill
As part of Blue Ridge's commitment to continued color reduction, the Canton Mill,
in collaboration with a coalition of environmental groups, engaged Dr. Norm
-Liebergott,—President of--Liebergott—&Associates Consulting Inc., and Lewis
Shackford, Vice president of Technology for GL&V Pulp Group Inc., a major
supplier to the pulp and paper industry, to undertake a thorough evaluation of the
mill's pulping and bleaching operation. The evaluation is focusing on potential
process and equipment modifications targeted at environmental performance
improvements. Liebergott and Shackford will identify options for consideration
that may lead to decreased effluent load, in particular color, with technologies
that will not increase effluent toxicity. Blue Ridge plans to submit this information
to the Division of Water Quality for its consideration in conjunction with the
information from the Technology Review Workgroup (TRW) to evaluate options
for potential reductions in effluent color over the term of the next NPDES Permit.
Permit No. NC0000272
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June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
IV. Commitments to Further Color Reduction
The Canton Mill is committed to further discharge color reduction. In conjunction
with the Technology Review Workgroup (TRW), the Canton Mill believes further
color improvements may be achieved utilizing the following options.
4.1 BFR Improvements
-Since October 1998, the average-BFR closure rate of the pine fiberline D1 and
Eo stages has averaged approximately 74%. This rate is lower than the targeted
BFR closure rate of 80%.
The obstacles to achieving a sustained pine fiberline closure of 80% are related
to the operational reliability of the BFR equipment, primarily the Metals Removal
Process (MRP). Blue Ridge is committed to undertake improvements to the
MRP in order to achieve an 80% pine fiberline closure rate. These
improvements include a new media filter and softener, rebuilding piping and
valves, and changing materials of construction to better withstand the harsh
environment (corrosivity, erosion and deposition). Blue Ridge estimates the cost
of these improvements to be up to $1,300,000 and the estimated discharge color
reduction from these upgrades to be 1,000 — 1,200 Ibs/day.
The other component of the BFR process is the Chloride Removal Process
(CRP). The CRP system purges chloride and potassium from the mill's chemical
recovery system. This purge is a low flow, relatively high color stream that
contributes an average of 6,000 Ibs of color per day to the wastewater treatment
plant primary influent (or less than 4,000 Ibs/day in the discharge). The Canton
Mill will investigate potential technologies that may reduce this source of color.
Permit No. NC0000272
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June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
4.2 Additional Black Liquor Leak and Spill Control
The Canton Mill has extensive equipment to reduce black liquor leaks and spills.
Additional improvements to further manage black liquor losses to the wastewater
collection system are currently under evaluation. The first improvement involves
diversion of clean water from the digester area sump. This diversion of clean
water will prevent dilution of concentrated brown color, thereby allowing the sump
to capture a greater percentage of the -brown color from the digester area.
Another upgrade is to collect the filtrate from the knotter bins to reclaim color that
is leached from knots. An evaluation of alternatives to reduce screen room color
will also be conducted. Blue Ridge estimates the cost of these improvements to
be in excess of$100,000. The discharge color reduction could be in the range of
1,000 — 3,000 Ibs/day.
4.3 Evaluation of Potential In-Process Color Reduction Technologies
As described in Section 3.4, Liebergott and Shackford are evaluating
technologies that may result in reduced discharge color. While this report is not
yet complete, Blue Ridge can provide an overview of Liebergott's and
Shackford's scope of work.
The scope of the Liebergott and Shackford study involves evaluation of potential
process modifications to see if such modifications are technically, operationally
and economically feasible. The report will consider impacts on process control,
production capability and pulp production cost and quality. Liebergott and
Shackford will consider changes to each fiberline, 2-stage oxygen delignification,
strategic use of hydrogen peroxide and the alternative use of peracetic acid
Permit No. NC0000272
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June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
and/or ozone in the bleaching stages.. An evaluation of whole mill effluent and
segregated higher color wastewater streams will also be conducted.
A final report will be issued summarizing the technical, economic and operational
feasibility of the technologies reviewed, including a discussion of commercially
demonstrated use. This report will be provided to the Division of Water Quality.
In addition to- this third -party assessment, the USEPA has a dedicated
Technology Review Workgroup that is studying additional color reduction
technologies. This report is also expected to be available to the Division of
Water Quality in the second quarter of 2001.
Permit No. NC0000272
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June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
V. Conclusion
The Canton Mill has successfully reduced color from 83,000 Ibs/day to less than
48,000 Ibs/day over the term of the 1997 NPDES Permit. Blue Ridge is
committed to further improvements to the BFR process, the digester area spill
control systems and to the knotter and screen operations, which will further
reduce discharge color. Blue Ridge is also committed to evaluating other
process technologies, which may reduce color, over the term of the 2001 NPDES
Permit.
Permit No. NC0000272
Page 10

June 1, 2001 Statistical Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
I. Introduction
The following report describes the statistical evaluation of the Canton Mill's color
discharge since completion of the color reduction activities required by the
modified 1997 NPDES Permit and Settlement Agreement. Part III, E. Paragraph
14 of the revised 1997 Permit provides, in part, the following:
"... Further, based on the continued development of color
discharge information from the reconfigured mill, the permittee
will statistically evaluate its monthly average color discharge, its
annual average color discharge, and the performance of the mill
in relation to color discharged..."
This report is submitted to fulfill this requirement of Part III, E. Paragraph 14.
Permit No. NC0000272
Page 1

June 1, 2001 Statistical Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
II. Discussion
The Canton Mill has achieved a color reduction of over 88% since 1988 in the
annual average amount of color discharged, as illustrated in Figure 1. The
improved color performance is due to the Canton Modernization Project, full
implementation of the "Near-Term Package' and continuous color management
by the mill.
The Near-Term Package included the installation of BFWm on the mill's pine
fiberline, implementation of best management practices (BMPs) detailed in the
June 1, 1998 Color Technology Report, and partial BFR (Eo filtrate recycle) on
the hardwood fiberline. Partial hardwood Eo recycle was still being evaluated
and optimized through December 1999, and therefore, the January 2000 —
December 2000 time period was used as the basis for the statistical evaluation.
This period is representative of mill discharge color performance after
implementation of all activities (i.e. "the reconfigured mill") required in the 1997
NPDES Permit. However, it is important to note that November and December
2000 are not representative of typical mill pulp production. This is due to the No.
19 Paperboard Machine outage and start-up, when pulp production was very low
compared to normal operation.
Permit No. NC0000272
Page 2

Figure 1: Canton Mill Secondary Effluent Color Performance
Annual Averages: 1988 - 2000
400000 Including Permit Limitations
Permit Limitations:
350000 1-258,945#/d Monthly Ave.efi.4114/94
2-172,368#/d Annual Ave.eft.4/14/94
3-125,434#/d Monthly Ave.eH.12/12/96
4-98,168#/d Annual Ave e6.12/12/96
6-95,000 Old Monthly Ave eft.111198
300000 6-69,000 91d Monthly Ave.eR.1211198
T 7-60,000#/d Annual Ave.e8.1211/98
to 8-48,000#/d Annual Ave.eff.5/1/01
9
N
c 250000
ti
0 1
0
U
d 200000
LU
w
D150000
c 2
0
u
rn 100000 3
4
5
50000 6 7
8
0
1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000
Blue Ridge Paper Products, Inc.
®Permit Limitaions i SE Color Annual Ave. Wd
Canton Mill 5/31/01

June 1, 2001 Statistical Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
III. Statistical Evaluation of Color Performance Data
The attached Table summarizes the statistical evaluation. Based on January
2000 — December 2000 color data, the 95th percentile expected annual average
is 46,475 Ibs/day. This 95th percentile annual average is representative of the
reconfigured mill's performance.
The monthly average numbers were calculated, using the same data as above,
by two different statistical methods. The expected monthly color average based
on a 95th percentile distribution is 54,089 Ibs/day. Using a 95th percentile
distribution and interpolation from ranked observations, the expected monthly
color average is 55,003 Ibs/day. These two 951h percentile monthly average
numbers represent current mill performance. The maximum monthly average
observed during this time period was 58,009 Ibs/day.
1 Interpolated numbers come from the empirical (i.e. the actual ranked values) data
using the calculated percentile by assuming it lies linearly between the closest smaller
percentile and the closest larger percentile within the cumulative percentage distribution.
Due to the limited data set available, an interpolated statistical evaluation is only
possible for a monthly value, not for an annual value.
Permit No. NC0000272
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June 1, 2001 Statistical Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
IV. Conclusion
Based upon color discharge data during the period after the Mill had
implemented all improvements required by the 1997 NPDES Permit, the
expected annual average is 46,475 Ibs/day. Expected monthly color averages
using the same data from two different statistical evaluations are 54,089 and
55,003 Ibs/day.
Using North Carolina's governing flow criteria (30Q2), historical flow records, and
the 2000 annual average color discharge of 43,386 Ibs/day, it is expected that
color in the Pigeon River at the Hepco gage will be less than 50 true color units
100% of the time at all flows above 30Q2.
Permit No. NC0000272
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Table 1: June 1, 2001 Statistical Evaluation
Monthly Average Data -Max Month/Annual Calculation
Data Set January 2000- December 2000
n = 12
X-bar 43,386
std dev 6527
95th percentile for Month 54,089
99th percentile for Month 58,593
Max month 58,009
95th percentile for Year from normal distribution 46,475
99th percentile for Year from normal distribution 47,775
Ranked observations-by interpolation
95th percentile for max month 55,003
99th percentile for max month 57,408
BRPP Inc.
Canton Mill
June 1,2001 Statistical Evaluation
Attachment