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HomeMy WebLinkAboutNC0000272_Compartative_Stat_Eval_Report_20010531 r r � COMPARATIVE AND STATISTICAL EVALUATION REPORTS Prepared for: North Carolina Division Water Quality Prepared by: Blue Ridge Paper Products Inc. Canton, North Carolina May 31 , 2001 t BLUE RIDGE. PAPER PRODUCTS INC. May 29,2001 Mr. Forrest Westall Regional Water Quality Supervisor North Carolina Department of Environment and Natural Resources 59 Woodfin Place Asheville,NC 28801 RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products,Inc. Canton Mill June 1,2001 Required Reports Dear Mr.Westall: Attached are the June 1, 2001 Comparative Evaluation Report and the June 1, 2001 Color Performance Statistical Evaluation. These reports are submitted to fulfill part of the requirements stated in Part III,Paragraph E 14 of the modified 1997 NPDES Permit. Please call me at(828) 64&2033 or Derric Brown at(828) 646-2318 if you have any questions or concerns regarding these reports. Sincerel Bob Williams Director-Environmental,Health and Safety Attachment 175 Main Street o P.O. Box 4000 Canton, North Carolina 28716 • Phone:828-646-2000 Raising Your Expectations Xc: I th Haynes9 Dave Goodrich Mike Myers June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina I. Introduction The following report describes the important color reduction activities that have been accomplished over the term of the modified 1997 NPDES Permit ("1997 Permit") and includes a discussion of technology assessments Blue Ridge has undertaken to evaluate potential color reduction options. Part III, E. Paragraph 14 of the 1997 Permit provides, in part, that: "...By June 1, 2001, the permittee will submit a report to the NPDES Committee and N.C. DENR, Division of Water Quality, on the comparative evaluation of the above collective efforts as part of the Variance review process (Triennial Review of North Carolina Water Quality Standards.)..." This report is submitted to fulfill this requirement of Part III, E. Paragraph 14. Permit No. NC0000272 Page 1 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina li. Summary of Color Reduction Activities Since the issuance of the 1997 NPDES Permit, the Canton Mill has accomplished the following color reduction activities: 1. Identified and implemented certain Best Management Practices (BMP's) to reduce color. The following BMP's were implemented before June 1, 1998, and a report on the implementation was submitted to DWQ, the TRW and the NPDES Committee on that date. a. Installation of replacement digester recirculation pumps. b. Installation of a double-chambered pine courtyard spill collection sump. c. Installation of weak black liquor tank containment, and d. Correction of evaporate set demister clogging, installation of condensate instrumentation and sampling ports for the evaporator set and assurance of continued dry conveying of knot rejects. 2. Submitted Low Flow Contingency Plan to DWQ and TRW by December 1, 1998 (approved by NPDES Committee in February 1999). 3. Prior to December 1, 1998, complied with a reduced color limit in the Permit of 60,000 lbs. per day (annual average) and 69,000 lbs. per day (monthly average). 4. Began implementation of partial Eo stage filtrate recycle on the hardwood line before January 1, 1999 and submitted a report on the color reduction benefit resulting from the partial implementation and a projection of potential color reduction benefit to be gained from full implementation of BFR on the hardwood line to DWQ, TRW and the NPDES Committee by December 1, 1999. 5. Submitted a color limit feasibility report to DWQ, TRW and the NPDES Committee before January 1, 2001, which concluded that the Canton Mill could comply with a color limit within the range of 48,000-52,000 lbs. per day (annual average). Permit No. NC0000272 Page 2 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina Implementation of these BMP's, together with improved mill operations and continued commitment to further reduce color, has reduced color by 32% over the term of the 1997 Permit. As described in the January 1st, 2001 Report, the mill has achieved a target annual average color loading of 48,000 — 52,000 pounds per day. On May 1, 2001 the North Carolina Division of Water Quality reduced the permit limit for annual average color from 60,000 Ibs/day to 48,000 Ibs/day and the monthly average color limitation was reduced from 69,000 Ibs/day to 55,000 Ibs/day. Based on data received from the National Council on Air and Stream Improvement (NCASI), the Canton Mill has the lowest color of any mill in its industry category.' Based on a June 7,2000 Benchmarking Canton Wastewater Effluent Parameters letter from the National Council for Air and Stream Improvement(NCASI). Permit No. NC0000272 Page 3 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina III. Additional Color Reduction Studies 3.1 End-of-Pipe Treatment and In-Process Technologies In an effort to identify either a breakthrough improvement in color removal efficiency or reduction in cost, the mill has evaluated end-of-pipe color reduction technologies three times in the past thirteen years, including a 2001 study by Jacobs Engineering Group, Inc. (2001 Color Removal Technology Assessment, the "Jacobs Report"). The Jacobs Report evaluated 16 end-of-pipe technologies. It is clear that no breakthrough in economic or technical feasibility has or is likely to occur in end-of-pipe color removal.technologies. Such technologies have not been commercially demonstrated and are generally not economically feasible because they require a significant initial capital investment with continued operating costs and no associated savings. During this same thirteen-year period, however, the Canton Mill implemented alternative in-process pollution prevention technologies including oxygen delignification, Elemental Chlorine Free bleaching, Bleach Filtrate Recycle-rm and those technologies comprising the "Near-Term" package, resulting in a significant reduction in the color discharged. Therefore, based upon this record, it is Blue Ridge's intention in the future to focus on in-process pollution prevention technologies and the potential treatment of selected, colored wastewater streams before they enter the wastewater treatment plant (WWTP) and, in particular, the Chloride Removal Process (CRP). Blue Ridge believes in-process pollution prevention and treatment of selected wastewater streams hold the greatest likelihood of success for further color reduction. In the future, Blue Ridge believes its time and resources would be Permit No. NC0000272 Page 4 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina better devoted to in-mill treatment of particular wastewater streams rather than end-of-pipe, secondary effluent color removal approaches. 3.2 Polyamine Trials Polyamine addition trials were conducted in January 2001 at the primary clarifier, secondary clarifier, and colored in-mill wastewater streams, and were not eopmine aon isCo reduce color throughsuccessful�heconcpt d precipitation of color bodies, which attach to the polyamine, coagulate, and settle in primary clarification. Numerous trial approaches were conducted to study comprehensively the effectiveness of polyamine for color removal. While treatment of colored wastewater streams in the pulping and recovery areas appeared to remove color, the color bodies re-solubilized in the wastewater collection system and there was no significant net reduction in secondary effluent color. Treating the primary clarifier resulted in color reductions, but wastewater treatment plant sludge quality declined to an unmanageable condition and recycled belt press filtrate solids increased significantly. Treating the secondary effluent resulted in minimal color reductions; in addition, this type of treatment would require the installation of equipment and increased operating costs as described in the Jacobs Report , and might have adverse effects on the chronic toxicity of the wastewater discharge. 3.3 CRP Treatment with Lime Laboratory studies were recently performed on the Chloride Removal Process (CRP) purge stream, a relatively high color, low flow stream associated with the BFRTrm process. The purge stream was treated with various sources of calcium in an effort to precipitate color bodies. Lime precipitation was concluded to be Permit No. NC0000272 Page 5 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina infeasible due to the massive quantities necessary to partially reduce color and the large quantities of solid waste generated. 3.4 Third Party Evaluation of Canton Mill As part of Blue Ridge's commitment to continued color reduction, the Canton Mill, in collaboration with a coalition of environmental groups, engaged Dr. Norm -Lieberrgott,- President -of-Liebergott-&Associates-Consulting- Inc.,- and Lewis Shackford, Vice President of Technology for GL&V Pulp Group Inc., a major supplier to the pulp and paper industry, to undertake a thorough evaluation of the mill's pulping and bleaching operation. The evaluation is focusing on potential process and equipment modifications targeted at environmental performance improvements. Liebergott and Shackford will identify options for consideration that may lead to decreased effluent load, in particular color, with technologies that will not increase effluent toxicity. Blue Ridge plans to submit this information to the Division of Water Quality for its consideration in conjunction with the information from the Technology Review Workgroup (TRW) to evaluate options for potential reductions in effluent color over the term of the next NPDES Permit. Permit No. NC0000272 Page 6 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina IV. Commitments to Further Color Reduction The Canton Mill is committed to further discharge color reduction. In conjunction with the Technology Review Workgroup (TRW), the Canton Mill believes further color improvements may be achieved utilizing the following options. 4.1 BFR Improvements — mce October 1998,-the average BFR closure rateof-the pine fiberline D1 and Eo stages has averaged approximately 74%. This rate is lower than the targeted BFR closure rate of 80%. The obstacles to achieving a sustained pine fiberline closure of 80% are related to the operational reliability of the BFR equipment, primarily the Metals Removal Process (MRP). Blue Ridge is committed to undertake improvements to the MRP in order to achieve an 80% pine fiberline closure rate. These improvements include a new media filter and softener, rebuilding piping and valves, and changing materials of construction to better withstand the harsh environment (corrosivity, erosion and deposition). Blue Ridge estimates the cost of these improvements to be up to $1,300,000 and the estimated discharge color reduction from these upgrades to be 1,000 — 1,200 Ibs/day. The other component of the BFR process is the Chloride Removal Process (CRP). The CRP system purges chloride and potassium from the mill's chemical recovery system. This purge is a low flow, relatively high color stream that contributes an average of 6,000 Ibs of color per day to the wastewater treatment plant primary influent (or less than 4,000 Ibs/day in the discharge). The Canton Mill will investigate potential technologies that may reduce this source of color. Permit No. NC0000272 Page 7 June 1, 2001 Comparative Evaluation Report . Blue Ridge Paper Products Inc. Canton, North Carolina 4.2 Additional Black Liquor Leak and Spill Control The Canton Mill has extensive equipment to reduce black liquor leaks and spills. Additional improvements to further manage black liquor losses to the wastewater collection system are currently under evaluation. The first improvement involves diversion of clean water from the digester area sump. This diversion of clean water will prevent dilution of concentrated brown color, thereby allowing the sump to capture a greater percentage of the brown color from the digester area. Another upgrade is to collect the filtrate from the knotter bins to reclaim color that is leached from knots. An evaluation of alternatives to reduce screen room color will also be conducted. Blue Ridge estimates the cost of these improvements to be in excess of$100,000. The discharge color reduction could be in the range of 1,000 — 3,000 Ibs/day. 4.3 Evaluation of Potential In-Process Color Reduction Technologies As described in Section 3.4, Liebergott and Shackford are evaluating technologies that may result in reduced discharge color. While this report is not yet complete, Blue Ridge can provide an overview of Liebergott's and Shackford's scope of work. The scope of the Liebergott and Shackford study involves evaluation of potential process modifications to see if such modifications are technically, operationally and economically feasible. The report will consider impacts on process control, production capability and pulp production cost and quality. Liebergott and Shackford will consider changes to each fiberline, 2-stage oxygen delignification, strategic use of hydrogen peroxide and the alternative use of peracetic acid Permit No. NC0000272 Page 8 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina and/or ozone in the bleaching stages.. An evaluation of whole mill effluent and segregated higher color wastewater streams will also be conducted. A final report Will be issued summarizing the technical, economic and operational feasibility of the technologies reviewed, including a discussion of commercially demonstrated use. This report will be provided to the Division of Water Quality. --In addition-to this third party assessment,—the USEPA Was-a dedicated Technology Review Workgroup that is studying additional color reduction technologies. This report is also expected to be available to the Division of Water Quality in the second quarter of 2001. Permit No. NC0000272 Page 9 June 1, 2001 Comparative Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina V. Conclusion The Canton Mill has successfully reduced color from 83,000 lbs/day to less than 48,000 Ibs/day over the term of the 1997 NPDES Permit. Blue Ridge is committed to further improvements to the BFR process, the digester area spill control systems and to the knotter and screen operations, which will further reduce discharge color. Blue Ridge is also committed to evaluating other process technologies, which may reduce color, over the term of the-2001 NPDES Permit. Permit No. NC0000272 Page 10 June 1, 2001 Statistical Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina I. Introduction The following report describes the statistical evaluation of the Canton Mill's color discharge since completion of the color reduction activities required by the modified 1997 NPDES Permit and Settlement Agreement. Part III, E. Paragraph 14 of the revised 1997 Permit provides, in part, the following: Further, based on the continued development of color discharge information from the reconfigured mill, the permittee will statistically evaluate its monthly average color discharge, its annual average color discharge, and the performance of the mill in relation to color discharged..." This report is submitted to fulfill this requirement of Part III, E. Paragraph 14. Permit No. NC0000272 Page 1 June 1, 2001 Statistical Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina II. Discussion The Canton Mill has achieved a color reduction of over 88% since 1988 in the annual average amount of color discharged, as illustrated in Figure 1. The improved color performance is due to the Canton Modernization Project, full implementation of the "Near-Term Package" and continuous color management by the mill. The Near-Term Package included the installation of BFRTm on the mill's pine fiberline, implementation of best management practices (BMPs) detailed in the June 1, 1998 Color Technology Report, and partial BFR (Eo filtrate recycle) on the hardwood fiberline. Partial hardwood Eo recycle was still being evaluated and optimized through December 1999, and therefore, the January 2000 — December 2000 time period was used as the basis for the statistical evaluation. This period is representative of mill discharge color performance after implementation of all activities (i.e. "the reconfigured mill") required in the 1997 NPDES Permit. However, it is important to note that November and December 2000 are not representative of typical mill pulp production. This is due to the No. 19 Paperboard Machine outage and start-up, when pulp production was very low compared to normal operation. Permit No. NC0000272 Page 2 Figure 1: Canton Mill Secondary Effluent Color Performance Annual Averages: 1988 - 2000 400000 Including Permit Limitations Permit Limitations: 350000 1-258,945#/d Monthly Ave,off.4114/94 2-172,368 Wd Annual Ave.off.4/14194 3-125,434#/d Monthly Ave.eff.12112/96 4-98.168#/d Annual Ave eff.12/12/96 6-95,000 Wd Monthly Ave eff.111198 300000 6-69,000#/d Monthly Ave.eff.1211198 T 7-60,000#/d Annual Ave.eff.U/1/98 t0 8-48,000#/d Annual Ave.eff.5/1/01 9 N a 250000 0 0 U v 200000 E W 9 150000 0 2 0 u fu N 100000 3 4 5 50000 6 7 8 0 1 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 Blue Ridge Paper Products, Inc. Permit Urnitaions t SE Color Annual Ave.#/d 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 95th percentile monthly average numbers represent current mill performance. The maximum monthly average observed during this time period was 58,009 Ibs/day. 1 Interpolated numbers come from the empirical (i.e. the actual ranked values) data using the calculated percentile by assuming it lies linearly between the closest smaller percentile and the closest larger percentile within the cumulative percentage distribution. Due to the limited data set available, an interpolated statistical evaluation is only possible for a monthly value, not for an annual value. Permit No. NC0000272 Page 3 June 1, 2001 Statistical Evaluation Report Blue Ridge Paper Products Inc. Canton, North Carolina IV. Conclusion Based upon color discharge data during the period after the Mill had implemented all improvements required by the 1997 NPDES Permit, the expected annual average is 46,475 Ibs/day. Expected monthly color averages using the same data from two different statistical evaluations are 54,089 and 55,003 Ibs/day. Using North Carolina's governing flow criteria (30Q2), historical flow records, and the 2000 annual average color discharge of 43,386 Ibs/day, it is expected that color in the Pigeon River at the Hepco gage will be less than 50 true color units 100% of the time at all flows above 30Q2. Permit No. NC0000272 Page 4 Table 1: June 1, 2001 Statistical Evaluation Monthly Average Data - Max Month/Annual Calculation Data Set 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