NC0000272_NPDES_Permit_Report_20030929

"BLUE RIDGE
PAPER PRODUCTS INC.
September 29, 2003
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.
October 1, 2003 Required Report
Dear Mr. Westall:
Attached is the October 1, 2003 Report. This report is submitted to fulfill the
requirements stated in Section A(8),Paragraph 5 of the 2001 NPDES Permit. 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.
Please call me at(828) 646-2033 or Melanie Gardner at(828) 646-6749 if you have any
questions or concerns regarding this report.
Sincerely, l
Bob Williams A-21
Director- Environmental,Health and Safety
Attachment
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716
Phone: [phone] • Fax: [phone]
Raising Your Expectations

October 1,2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
I. Introduction
The following report details the Canton Mill's ability to attain the lowest achievable
annual average and monthly average color loading limits based on the Mill's performance
from December 2001 —August 2003. Section A(8.),Paragraph 5 of the 2001 NPDES
Permit provides in part, as follows:
"...By October 1, 2003, the permittee shall submit to the North Carolina
Division of Water Quality a report including a statistical analysis of the
permittee's monthly average color discharge, mill performance as related
to color, all available data necessary to derive the lowest achievable
annual average and monthly average color loading limits... "
This report is submitted to fulfill the requirements of Section A(8.), Paragraph 5. Based
on the Mill's performance from December 2001 —August 2003 and the Mill's continued
commitment to color improvement, Blue Ridge Paper Products believes an annual
average color limit of 42,000 pounds per day and a monthly average color limit of 52,000
pounds per day are feasible.
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
II. Color Performance
Set forth below is a summary of the actions implemented and planned for further color
improvement at the Canton Mill. These actions satisfy the `Highest Certainty' items
recommended by the Division of Water Quality and the Technology Review Workgroup.
2.1 Process Optimizations Items
The sixteen Process Optimization Items recommended in the Bleach Environmental
Process Evaluation and Report prepared by Liebergott &Associates Consulting Inc. and
GL&V Pulp Group Inc. have all been evaluated and implemented where appropriate.
2.2 Improved Black Liquor Leak and Spill Collection and Control
This recommendation consists of four elements including:
1) Continuous improvement of operating practices so more leaks and spills are recovered
rather than discharged to the sewer;
2) Improvement in preparation for planned outages to maximize capture of tank clean-out
waste and routing to recovery;
3) Reduction of clean water that continuously runs into sewers to prevent dilution of
smaller spills and facilitate recovery of highly colored wastewaters; and
4)Improvement in the equipment used for the handling of knot rejects to prevent black
liquor leaks into the recovery sumps.
The following is a discussion of actions relating to each element.
2.2.1 Continuous Improvement of Operating Practices etc.
A number of Best Management Practices (BMPs)have been implemented to improve the
recovery of colored discharges within the mill. These include: A) Color testing on the
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October 1,2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
Primary Influent every 2 hours; B) The use of the off-line, spare clarifier for process
losses and intentional diversions; C)Piping the Hardwood Brown Spill tank to the Pine
Blow Tower for additional spill collection capability and Hardwood Fiberline outage
management; and D) Implementation of control logic in the Pine Brownstock area to
minimize tank overflows during shutdowns.
The Mill began 24-hour color testing in 2-hour increments on the primary influent in
2001. The purpose of this increased color testing is to improve the mill's ability to
respond to process upsets on an immediate,real-time basis. If high 2-hour color results
are detected, the Wastewater Treatment Plant(WWTP) operators communicate the
information to mill operations and in-mill investigations begin. If necessary, diversion of
the primary influent to the off-line, spare clarifier is initiated. The high color material
that is captured in the off-line clarifier is later discharged into the system at a rate that has
a minimum impact on color and is not disruptive to the W WTP system. The off-line
spare clarifier is also used during outage situations when high color material cannot be
recovered by the in-mill spill control systems due to upset conditions, lack of recycle or
evaporator capacity or intentional diversions.
In order to increase the Hardwood Fiberline's ability to recycle recovered brownstock
material,piping was installed from the Hardwood Brown Spill tank to the Pine Blow
Tower. Prior to installation of this piping, there was no outlet for recycled hardwood
brownstock material when that system was shut down. This design allows for the
Hardwood Brown Spill tank to be recycled into the Pine Blow Tower and is especially
useful in hardwood outage situations when the recycle of additional recovered material is
required. Color savings from this 2001 project are reflected in the improvements seen
around the hardwood brownstock or 2B sewer area as well as improved color
performance.
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
During the first quarter of 2003, additional control logic was developed and implemented
on the pine brownstock system to prevent high colored filtrate tanks (15`, 2"d, and 3`d stage
Pre-OZ filtrate tanks) from overflowing and potentially reaching the sewer. The control
logic is designed to alert the operator when the brownstock filtrate tank(s) reach 85%
with audible and visual alarms. If the tank level(s) continues to rise to 90%, the pine
brownstock operators receive a"high-high"level alarm and warning text on their
monitors. The control logic then automatically interlocks (i.e., shuts down) the washer
stock feed pump that is associated with the high-level filtrate tank. Further, additional
controls have been built into the logic for the Pine Brown Spill tank. The alarm logic for
this tank checks the tank level at various times each day. If the tank level is greater than
50% at either time period, the Pine Brownstock Operator will receive an audible alarm as
well as a text message stating that the "Pine Brown Spill tank level is high." The control
logic will then check the level three hours later and if the level is still above 50%, the
operator will receive another alarm stating that the "Pine Brown Spill tank level is still
too high." In addition, if the Brown Spill tank level exceeds 80%, the operator receives a
high level alarm on his/her Digital Control System (DCS) graphic. All of these control
system improvements have enhanced the operator's ability to monitor the system and
prevent spills and losses from these processes.
2.2.2 Improvement in Preparation for Planned Outages
Color management of planned outages has improved significantly as a result of the
following practices:
• Increasing color testing from 2 hours to one hour before outages, during outages
and upon start-up;
• Improved communication between the Wastewater Treatment Plant and mill
operations;
• Utilization of the off-line, spare clarifier;
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
• Developing tank draining schedules where only the necessary vessels are emptied
for inspection and scheduled maintenance;
• Reducing tank levels to the lowest level possible prior to shutdown.
To effectively monitor color performance during maintenance outages, the W WTP
operators begin hourly color testing on the primary influent when the Recovery operation
initiates its shutdown procedure. The hourly color data is posted on the mill's Plant
Information(PI) System where it is widely available to operations and support personnel.
If a result is greater than 300 color units, it is immediately communicated to the Recovery
and Pulp Mill foremen via the mill radio system and they institute investigative action to
pinpoint the source. The appropriate corrective action is then taken. The Pulp Mill and
Recovery foremen also communicate their investigative findings with one another to
ensure effective troubleshooting is in place.
If an hourly color result is elevated and mill operations communicates that there has been
a process loss, the W WTP operators will divert the primary influent flow to the 1 million
gallon off-line, spare clarifier for temporary storage. There have also been instances
when the W WTP operators diverted the primary influent flow without direct
communication of a spill. The WWTP operators are trained to take action and route high
colored primary influent to the off-line, spare clarifier when necessary. The high color
material is later fed into the WWTP system at a slow, non-disruptive rate. Such a slow
feed rate minimizes the material's impact on secondary effluent color and does not
disrupt the W WTP process. For very high colored material captured in the off-line
clarifier,polyamine may be added in small amounts. Small amounts of polyamine aid in
the color removal of the concentrated material captured in the clarifier without negatively
affecting the sludge quality as larger amounts of polyamine have been demonstrated to
do. During normal mill operations, full-scale application of polyamine was not proven to
be effective and it created unmanageable sludge conditions; however, polyamine has
been effective on these higher color concentration events captured in the off-line clarifier.
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
Also, if at any time high colored material is seen in the primary influent, or if mill
operations communicates a process loss/intentional diversion, the WWTP operators can
immediately divert the primary influent flow into the off-line, spare clarifier. Improved
communications between the WWTP and mill operations have allowed for optimal use of
the off-line clarifier, especially in outage situations when overall spill system capacity is
in demand.
Tank draining schedules are developed in preparation for planned maintenance outages.
Increased attention has been given to draining only the tanks and lines requiring
inspection and/or maintenance rather than draining entire sequences. Draining the entire
sequence was a routine approach in the past so that vessels would be empty and available
for maintenance if problems were detected. The schedule has been optimized so that
inspections are rotated between outages, thereby ensuring that all tanks are inspected
while reducing the frequency that individual tanks must be emptied. However, issues
may arise where more frequent maintenance is required on certain vessels and
appurtenances and in these cases, the tanks must be drained before a scheduled inspection
is due. In preparation for all scheduled outages, it is standard practice to focus on
reducing tank levels to minimize the amount of material to be drained. This practice also
reduces potential losses in the event of an upset process condition during shutdown,
outage, or start-up periods.
These practices have measurably improved outage color performance. Specifically,
reductions in the color losses are demonstrated by the 2002 semi-annual shutdowns
(outages performed twice per year, lasting approximately one week with each outage
involving half of the mill operations). In a comparison of semi-annual outage primary
influent color data,the 2002 data showed an average 38%reduction in the maximum
daily primary influent color from historical performance (1996—2001). These
improvements are significant given that the majority of the spill recovery systems were
implemented in 1997 and 1998.
i
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
2.2.3 Reduction of Clean Water that Continuously Runs into Sewers
There has been a greater than 90,000 gallon per day reduction in the amount of clean
water being sewered, primarily in the mill's digester courtyard. This reduction in flow
was achieved by implementing customized Double Mechanical Seals and Water
Management Systems on the 18 digester re-circulation pumps. This project has involved
extensive trialing of different types and combinations of specially designed mechanical
seals over the past several years. The decrease in flow from the mechanical seals is at
least 3 to 4 gallons per minute per pump,which equates to a daily flow savings greater
than 90,000 gallons. The removal of non-mechanical seal pump packing water from the
digester sewers has also contributed to improved color performance for the area. Since
complete implementation of the mechanical seals, measured color in the area has been
reduced by approximately 60%. This is due in part to the removal of seal water that
could be contaminated by black liquor leaks on the non-mechanical seal packing and
from the recovery sumps operating more efficiently. With less clean water dilution in the
sewers leading to the recovery sumps, the effective conductivity of the material increases
and can be captured for re-use in the process at a greater efficiency. Customized Double
Mechanical Seals and Water Management Systems have also been installed on the
Knotter feed pumps for both the Pine and Hardwood Fiberlines, to further reduce water
infiltration to the sewer.
2.2.4 Improvement in Equipment used for Handling Knot Rejects
Two projects have been completed to improve the equipment used for handling knot
rejects. Black liquor from the Knot Rejects Collection bins is routed to a dedicated U-
drain,which flows to a dedicated knot bin sump pump for each Fiberline. The flow from
the knot bin areas is collected and pumped to the Brown Spill tank for each respective
Fiberline. Recovery of this material has contributed to improved color performance, as
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October 1,2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
demonstrated by Figure 1 below. The Hardwood Fiberline Brownstock sewer color has
shown the most dramatic reduction in color, which results from:
• Having the flexibility to send contents from the Hardwood Brown Spill tank to
the Pine Blow Tower during shutdown and start-up from an outage;
• Reducing the amount of clean water dilution by installing the Double Mechanical
Seals and Water Management Systems;
• Capturing the black liquor from the knot rejects system and;
• Improved communication and color monitoring.
Monthly Average Hardwood Brownstock and Digester Area Color
Since Installation of Double Mechanical Seals and
Water Management Systems
12000
10000
m 8000
O
N
6000
O
4000
2000
F Z=� I
N N N N N4 4 N N N �'l M M w N n N M
O O O O O O Q O O O O Q O O Q O
Q vj O Z° p _ 4v Q > > C
+Hardwood Brownstock and Digester Area Color
Figure 1
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
III. Improvements in BFRTm Reliability
Approximately$1.5 Million has been spent on Bleach Filtrate Recycle process
improvements for 2002—2003. This has resulted in improved BFRTm closure rates over
the past year and operational variability is also showing improvement in the Metals
Removal Process (MRP). In August 2003, the monthly average closure rate reached
targeted levels with improved MRP uptime and equipment reliability matching Fiberline
reliability. To improve process variability, a new media filter and a new ion exchange
softener were installed in the MRP. Due to accelerated degradation of the original three
media filters over recent months, they will also be replaced by the end of 2003. With this
additional equipment,metallurgy changes and other process improvements, MRP
downtime is expected to be reduced significantly. Having four media filters and three ion
exchange softeners will provide enough capacity for the MRP to remain online while
repairs are made to an individual media filter or softener. These projects are beginning to
demonstrate improved closure rates,reduced operational variability of the MRP, and
increased mechanical reliability of the MRP, all of which should aid in reducing both
measured and unaccounted color. As was expected, a recent statistical evaluation
demonstrated that lower closure rates are a major contributor to elevated secondary
effluent color and unaccounted color, individually as a main effect and also combined
with other factors as an interaction effect. These effects will be discussed in a later
section.
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
IV. Color Challenges in 2002—2003
As a result of many years of color reduction activities and those discussed herein, the
monthly average secondary effluent color for the period December 2001 through October
2002 was 39,833 lbs/day. However, due to unforeseen and complex issues discussed in
this report, secondary effluent color increased in late 2002.
In November 2002, secondary effluent color variability began to increase. The
contributing source(s) were not readily evident. Out of the 15 sewer and process areas
measured daily, there were no measured sources that were statistically out of control
except for the Pine Eo filtrate, and that influent contribution was less than 5,000 lbs/day
over the in-control average. Two major sewer areas, the Bleach Plant Filtrate Acid Sewer
and the Hardwood Brownstock/Digester Area Sewer were actually operating below their
average level of performance. The unaccounted color averaged about 23,000 lbs/day for
the month(compared to a 2002 YTD average of approximately 10,000 lbs/day). A
thorough review of all sewered, color-contributing sources revealed that the hardwood
screen rejects were not being quantified in the daily in-mill color analysis. Data has been
collected and the average color contribution from the hardwood screen rejects is 3,000
lbs/day. This source has been a small portion of the mill's unaccounted color since 1996;
therefore, it is not a significant contribution to the elevated unaccounted color seen during
this period. Further, the Wastewater Treatment Plant Color removal effect was dropping.
Elevated unaccounted color and reduced WWTP color removal are indicators that
support the presence of Sewer Generated Color(SGC),yet closure was averaging 77%
and the color contribution from the Bleach Plant Filtrates, the historical pre-cursors of
SGC, were running below average as illustrated in Figure 2 below.
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
Monthly Average Color In the Bleach Plant Acid Sewer
Jan•02 through Jan•03
16000
14000
12000
0
10000
B
a
u 0000
0000
4000
c g m u
a z o°
�t Color 6A
Figure 2
As the Canton Mill has reduced releases of brown colored material, a greater percentage
of the primary influent color has become unaccounted color. Color is a pH dependent
parameter and Blue Ridge is in un-charted territory with such low brown color effluents
and the BFRTm technology. The result of increasing the pH of an acidic bleach plant
filtrate in the laboratory shows a visually significant increase in color. The Sewer
Generated Color phenomenon has been duplicated on the bench in multiple studies and
the National Council on Air and Stream Improvement (NCASI) supports that color is a
pH dependent phenomenon. Sewer Generated Color does not disappear when the pH is
adjusted from alkaline back to neutral conditions.
Duke University graduate level internship and thesis studies performed at the Canton Mill
in 19941 and 19952 showed, on average, Sewer Generated Color for Pine D 1 filtrate was
an increase of 32-47% above the original sample color and Sewer Generated Color for
Hardwood D1 filtrate was 64-88%. Regarding WWTP color removal, data suggested
t "A Laboratory Analysis of Color Removal Across a Pulp and Paper Mill Wastewater Treatment Facility"
by Aimee Winter McCord
2 "A Laboratory Analysis of the Color Removal Mechanism Occurring Across the Wastewater Treatment
Plan"by Chad Salisbury
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
some hardwood Sewer Generated Color may be removable across the WWTP (3%
reduction in color after WWTP process),but pine filtrates showed an average increase in
color of21% in the simulated WWTP process. Data from this study show brown source
color removal up to 70% and the long-term average color removal across the W WTP
from primary influent to secondary effluent is 25%. The annual Color Pies showing the
breakdown of mill sewers compared to primary influent color support the presence of
Sewer Generated Color as unaccounted color has averaged 25% (19,081 lbs/day) since
1996. Of this 25%, the hardwood screen rejects contribute a small amount(currently
about 2,7001bs/day). The period from November 2002 through April 2003 is evidence
that specific interactions and operational conditions can significantly intensify the Sewer
Generated Color effect. Bench scale studies are planned to better understand the various
types and magnitudes of the major interaction effects pinpointed during the period of
elevated color. It is recognized that these conditions may change and new effects may
need to be studied in the future.
Figure 3 below shows the trend of increasing unaccounted color and decreasing WWTP
color removal that began in November 2002.
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
Unaccounted Color and WWTP Color Removal %
30000 Monthly Averages: Jan-02 through Feb-03 35.00%
O 25000 30.00%
`0 20000 25.00%0
O 20.00%;o
CD
15000 3
m 15.00%0<
`= 10000
1o.00°i°o
r 5000 5.00%
n
0 L 0.00%
0 0 0 0 0 0 0 0 0 0 0 0 0 0
j > U C .O
t Unaccounted Color 0 WVVfP Color Removal
Figure 3
The trend of increasing unaccounted color and simultaneous decreasing W w I? color
removal continued in December and a Color Team was formed including representatives
from Operations, Environmental and the Technical Manufacturing Support group. This
team initially audited the color measurement system as well as monitored sewer areas and
related instrumentation for accuracy as well as potential unmeasured sources of color.
When there were no anomalies discovered, the team focused on analyzing process
parameters for shifts and deviations that could contribute to elevated color. Processes in
the Fiberlines and Recovery area were reviewed in most detail while deviations from the
Paper Machines were also considered. The Pine Eo filtrate was consistently the only
color source that was running above its upper control limit but the causes were unknown.
Multiple statistical analyses were performed including CUSUMs or Cumulative Sum
charts to identify if, in fact, statistically significant shifts were occurring. While there
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
were several process parameters that were discovered to be operating outside their normal
ranges of variability,the most notable shifts were seen in the Fiberlines. Specifically, the
Pine Fiberline Bleach Plant and the Hardwood Fiberline Pre-Bleach and D I (first D)
stages. Additional statistical studies were performed and targets were established for the
above parameters as well as others, based on early 2002 when the color performance was
in the 36,000—39,000 lbs/day range. As the Fiberlines began reaching the established
targets, the unaccounted color remained elevated.
During the latter part of 2002, the variability in the White Liquor strength and solids
increased. This change was believed to be negatively impacting the Fiberline operations
by causing increased carryover into the bleach plants. These issues corresponded to the
decreased color performance seen beginning in November 2002. Elevated White Liquor
solids were then identified as an interaction effect contributing to elevated secondary
effluent and unaccounted color and this parameter was added to the Daily Color
Monitoring list. Also during late 2002, the quality of purchased lime for the Causticizing
operation was compromised due to flooding and other issues with the Mill's normal lime
supplier. Negotiations with additional lime suppliers are ongoing to improve the quality
of purchased lime.
Upon startup from the Cold Mill Outage in April 2003,unaccounted color increased even
further to the 35,000—40,000 lbs/day range from pre-Cold Mill levels in the 20,000
lbs/day range. Pine Eo filtrate color was back below the in-control average yet
unaccounted color was still high. Detailed Analysis of Variance(ANOVA)Factorials
were performed in an effort to determine which factors and combinations of factors were
affecting secondary effluent color and unaccounted color significantly. For these
analyses, an alpha of.05 was used. The results of the ANOVAs proved that there were
multiple statistically significant main effects and interaction effects "responsible" for the
elevated secondary effluent color and unaccounted color. This means that the effect
impacting the dependent variables (secondary effluent and unaccounted color) was not
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
doing so by chance. The interaction effects involve relationships between certain
parameters that significantly affect color. Subtle operational changes made in late 2002
had triggered a major Sewer Generated color problem and greater than 30 effects,
including main and interaction effects,were pinpointed. The most significant main
effects were BFRTM Closure,Pulp Mill Flow and Hardwood Pre-Bleach Conductivity.
There were numerous significant interaction effects, some including up to four interacting
factors, which is evidence of the problem's complex nature. To determine if the effects
had been present during periods of"good" color performance, ANOVAs were performed
on those periods as well. The only main effect that was statistically significant in
impacting secondary effluent color from January 2002—July 2002 was Closure and there
were no main effects nor interaction effects that were statistically significant for
unaccounted color during the period of good color performance. As a result of the
ANOVA studies, a daily color monitoring information report was created which tracks
the color-impacting parameters via targets and 30-day trends. Closure was the most
significant main effect contributing to elevated secondary effluent color. Given the
increase in bleach plant filtrate that reaches the mill sewer when closure rates are low,
there is a larger volume of low pH material available to undergo the Sewer Generated
Color effect. Because it has been shown that Sewer Generated Color is not removed
across the Wastewater Treatment Plant, lower closure rates translate into a measurable
increase in secondary effluent color. In addition to being a main effect, closure was a
statistically significant color-impacting variable in 13 different interaction effects as well.
Pulp Mill flow was the second most significant main effect contributing to elevated
secondary effluent color. Similar to closure, elevated flow from the Pulp Mill is likely to
be low pH material,which is a pre-cursor for Sewer Generated Color.
Hardwood Pre-Bleach Conductivity is the measure of conductivity from a pulp filtrate
sample taken off of the Pre-Bleach washer. Elevated conductivity indicates increased
carryover into that stage. Increased carryover from the pre-bleach stage can affect the
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
first stage of bleaching (D1), potentially requiring elevated acid usage on the D1 stage.
This was observed during the period of elevated color and was also a statistically
significant main effect and interaction effect in the ANOVA analyses. Elevated acid use
in the bleach plant could intensify the Sewer Generated Color effect by further reducing
pH.
Also, it was believed that start-up of the entire mill from the Cold Mill outage required
adequate time to reach stable operation. This stable operation was not achieved until
mid-May. Challenges from the Cold Mill start-up had to be managed before the targets
from the ANOVA Factorial analyses could properly be incorporated into the daily
operation. At this point unaccounted color and secondary effluent color finally began
reaching normal ranges.
Incorporation of the results from the ANOVA studies into the Daily Color Monitoring
Information report has proven to be a useful tool for color management at the Canton
Mill. It is recognized that the conditions causing these effects may change in the future
and new effects may need to be studied/evaluated. Since the Daily Color Monitoring
Information report has been in use, the average secondary effluent color has dropped
from 49,0241bs/day(average during November 2002 through April 2003 period of
elevated color) to 42,6691bs/day. The Canton Mill is utilizing this new tool and will
continue to use and develop innovative tools for troubleshooting color in the future.
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October 1,2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
V. Statistical Analysis of Data
The average secondary effluent color from December 2001 through August 2003,
excluding the period of elevated secondary effluent and unaccounted color, is 39,833
lbs/day. Based on a statistical evaluation of the mill's monthly average color
performance, for the same period, the achievable secondary effluent color using a 95`h
percentile distribution is 43,1891bs/day. The 2002 annual average secondary effluent
color was 41,171 lbs/day. Blue Ridge is committed to continued color performance
improvements and recommends an annual average secondary effluent limit of 42,000
lbs/day.
Blue Ridge recommends a monthly average effluent limit of 52,000 lbs/day based on the
color challenges encountered in the past year. Data for the December 2001 through
August 2003 period is attached to this report.
17

Blue Ridge Paper Products Inc.
Monthly Average Secondary Effluent Color: Dec-02 through Aug-03
Attachment 1: October 1, 2003 Report
Monthly Average Ibs/day
Month Secondary Effluent Color
Dec-01 36,821
Jan-02 39,040
Feb-02 39,870
Mar-02 37,886
Apr-02 42,477 Monthly Average Ibs/day
May-02 42,458 Secondary Effluent Color Excluding Nov-02-Apr-03
Jun-02 41,312 Dec-01 36821
Jul-02 41,686 Jan-02 39,040
Aug-02 40,750 Feb-02 39,870
Sep-02 39,480 Mar-02 37,886
Oct-02 36,382 Apr-02 42,477
Nov-02 48,014 May-02 42,458
Dec-02 44,701 Jun-02 41,312
Jan-03 51,269 Jul-02 41,686
Feb-03 48,324 Aug-02 40,750
Mar-03 50,412 Sep-02 39,480
Apr-03 51,423 Oct-02 36,382
May-03 40,955 May-03 40,955
Jun-03 42,458 Jun-03 42,458
Jul-03 44,734 Jul-03 44,734
Aug-03 42,527 Aug-03 42,527
2002 average 41,174 95th percentile 43,189
2003 ytd average 46,513 period average 40,591
95th percentile for 2003 51,369