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HomeMy WebLinkAboutNC0000272_Annual Progress Report on Color_20120702 evergreen. Canton Office packaging 175 Main Street• Canton, NC 28716 PSD 42-12 July 2,2012 CERTIFIED MAIL RETURN RECEIPT REQUESTED 7008 3230 0002 2595 1454 Chuck Cranford Regional Supervisor Division of Water Quality, Surface Water Protection r` North Carolina Department of Environment and Natural Resources Asheville Regional Office 2090 U.S.Highway 70 r ^� Swannanoa,North Carolina 28778 i 3 Re: Annual Progress Report on Color y NPDES Permit No. NC0000272 Blue Ridge Paper Products Inc. dba Evergreen Packagingi :: L V`- V, , _ T N t Canton Mill ss ❑ -^r L 7. FiCE Dear Mr. Cranford— a Enclosed is the Annual Progress Report on Color required by Part I A.(8.)item 8 of the May 26,2010 NPDES permit. This report covers the second year of the permit(July 2011 through June 2012). Very truly yours, BLUE RIDGE PAPER PRODUCTS INC. DOING BUSINESS AS EVERGREEN PACKAGING By: Paul Dickens Nick McCracken Manager—Environmental Affairs Water Compliance Coordinator 828-646-6141 828-646-2874 oaul.dickens c everoack.com nick.mccracken0,everpack.com Enclosure: July 2012 Annual Progress Report on Color cc: NC DWQ—Complex NPDES Permitting Unit,Raleigh Billy Clarke, Roberts and Stevens Internal distribution fresh by design.. / EOHS\Share\Water\Color Reports 2010 Print Doing easiness n coin«nia us Evergreen jeveroge Fuck agng July.2012 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 I. Introduction Part I A.(8.) item 8 of the May 2010 NPDES permit states — The facility will provide annual progress reports to the Division on the color reduction efforts. This report fulfills requirements of Part I A.(8.) item 8 for the second year of the permit July 2011 through June 2012. Specifically, the report documents completion of technical evaluations related to the TRW"A List" recommendations and updates the summary of projects and best management practice(BMP)refinements by the Canton Mill Color Team since May 2010. The report also documents the April 24, 2012 Partial Settlement of the Contested Cases concerning color and temperature conditions in the May 2010 NPDES permit [NC OAH 2O12]. Color-related reports previously submitted to the NC Division of Water Quality(DWQ) under terms of the May 2010 NPDES permit include the following: o July 2011 Annual Progress Report on Color[Evergreen 2011] o February 2012 Update to the Color Reduction Implementation Plan [Evergreen 2012a] The content of these reports is incorporated by reference. II. Background Levels of color in the wastewater effluent from the Canton Mill are among the best of Kraft pulp and paper mills in the world[EKONO 2005,NCASI 2006]. This high level of / Pagel \; July 2012 —Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 color performance is achieved by in-process controls and best management practices. The mill will continue to operate the controls and practices proven successful for color prevention. These controls and practices go well beyond the requirements of the EPA Cluster Rule for Pulp and Paper (40 CFR 430, Subpart B). Many, such as the Bleach Filtrate Recycling ProcessTm,are unique to the Canton MilL* The May 2010 NPDES permit includes a daily maximum effluent true color limit of 105,250 Ibs,per day. The permit also specifies a monthly average true color limit of 52,000 lbs perday and an annual average (calendar year) true color limit of 38,020 lbs per day. Compliance with these effluent limits requires significant management of mill operations related to color. Prevention of wastewater effluent color is a priority for mill operations everyday. III. Color Performance Figure 1 illustrates the color performance of the Canton Mill since 1997. The mill has sustained and continued the color reductions achieved under the 1997 and 2001 NPDES permits. Annual average effluent true color in Figure 1 Js presented in units of 1000 lbs per day. The calculation of effluent color as a daily mass (lbs) is defined in Part I A.(8.) items 2&3 of the permit: color (lbs/day) = effluent flow (mgd) x effluent true color (platinum cobalt units) x 8.34. Effluent true color is measured using NCASI method ' { 253 (1971). Page 2 July 2012 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 ------------ Figure 1 - Annual Average Effluent Color Blue Ridge Paper Canton Mill, 1997 thru 2011 m 70 - - 62 60 BFR & Cluster Rule Color Improvement Projects 0 c 50 48 1 45 41 43 41 40 3y 0 40 37-36-36-38-36-36 U 30 w 20 - — - 0A 00 00 Op O^ Oy 00 O� Oh Oro 01 00 �� �o' �� �O ,LO rL0 ry0 ti� r10 ti0 rL0 rb0 ti� rb0 ti0 The best color performance for the Canton Mill occurs during normal, or full,production. At full production, the internal recycling and recovery of process filtrates,pulping liquors and other process wastewaters are balanced. Color materials are contained within the Kraft pulping process at efficiency greater than 99 percent. Color performance is affected by process variability. Color materials can be lost during startup and shutdown associated with a process upset,production curtailment or unplanned outage. The Canton Mill has an environmental and economic incentive to maintain process reliability and operate at full production level. Page 3 l _ July 2012 —Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 Effluent color performance in 2011 was generally good and consistent with prior year color performance associated with periods of stable, full production operation of the Canton Mill. In May 2011,the mill executed a successful cold mill outage,the first since April 2003. The mill, and in particular the evaporator portion of the,black liquor recovery cycle,ran exceptionally well following the cold mill outage. Color performance in 2011 reflects this extended period of stable, fnll production operation. IV. Color Pro Wets and Refinements to Best Management Practices The Canton Mill has a standing Color Team that routinely meets to review color performance. The Color Team members include managers, supervisors and engineers involved with production,maintenance,wastewater treatment and regulatory affairs. The Color Team scope includes: • Monitor color performance and the effectiveness of mill systems to prevent effluent color • Identify and track corrective actions related to Cluster Rule BMP color events • Plan and review process trials related to effluent color • Plan and. review the effectiveness of capital and expense projects related to effluent color • Review other production and wastewater treatment issues that may affect operating reliability and effluent color. The Color Team evaluates projects, trials and process initiatives. Not all are successful. The July 2011 Color Progress Report [Evergreen 20111 documented significant Color t Page 4 July 2012 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000212 Team activities between May 2006 and May 2011 including the period between the application to renew the NPDES permit and DWQ issuance of the permit in May 2010. Significant activities since 2010 are outlined in Tables 1 and 2. Capital projects in Table 1 are identified by Capital Improvement Project (CIP) number. Other projects were completed on operations and maintenance expense. Direct spending on Color Team related projects, trials and initiatives identified in Tables 1 and 2 during the period May 2010 through May 2012 exceeded $1.9 MM capital and expense. These costs are in addition to the on-going cost to operate and maintain color prevention systems at the Canton Mill and are also in addition to funds spent to evaluate the TRW A List recommendations [Evergreen 2012]. Table 1 Color Team Capital and Maintenance Projects 2010 - Forward Year Project Description and Cost Information for Capital Projects 2010 East Heavy/Tall Oil Sump transfer line repair. This was a proactive measure to prevent color material losses from this transfer line. BMP sustaining measure. o Completed August 2010, cnsd* Replaced decant line from Turpentine loading to 4A manhole.This is a proactive measure to prevent losses from this transfer line. BMP sustaining measure. o Completed 2010 o CIP—315223 o Cost- $275,000 Page 5 July 2012 —Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 Table 1 Color Team Capital and Maintenance Projects 1010 - Forward Year Project Description and Cost Information for Capital Projects 2010 Repair and recoating of west side of Camp Branch compound. Project to maintain integrity of spill containment. BMP sustaining measure. o Completed 2010 o CIP—315588 o Cost-$235,000 Several black liquor transfer line replacements including East Heavy storage tank and West GB Discharge. BMP sustaining measure. o Completed 2010, cnsd* _ Replaced conductivity and level switches in East Heavy compound with new,more reliable type.,BMP improvement. o Completed3Q2010, cnsd* ( Relocation of sewer conductivity meter below Digester Area sumps. BMP optimization in this area. o Completed November 2010, cnsd* West Heavy Liquor.(fonner. Red Liquor Tank) shell replacement/repairs. BMP sustaining measure. o Completed May 2010 o CIP— 266446 o Cost—$265,0 00 Mini-Hoods on No. 11 Smelt Dissolving Tank(SMDT). Allows substitution of weak wash for clean water in SMDT demister creating more process demand for weak wash and reducing high pH material discharged to sewer. Related to the weak wash purge strategy(Table 2)and TRW Recommendations regarding prevention of sewer-generated color—high pH. o Completed 3Q 2010, cnsd* o A similar project is planned for the No. 10 recovery furnace in May 2013 �� Page 6 i July 2012 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 Table 1 Color Team Capital and Maintenance Projects 2010 - Forward Year Project Description and Cost Information for Capital Projects 2010 Installation of spray bar on the'5t'effect of the Swenson evaporator set. Spray allows the 5 effect chevrons to be cleaned on the run reducing the amount of carryover color in the condensate system during normal operation between evaporator outages. Color material carry over from evaporators into condensates is related to TRW Recommendations to prevent sewer-generated color. o CompletedOctober2010, cnsd* North White Liquor Tank shell replacement/repairs. BMP sustaining measure and project related to TRW Recommendations regarding prevention of sewer-generated color—high pH white liquor. o Completed Dec 2010 o CIP—322435 o Cost—$724,000 2011 Process lines to allow front-end boil out of West GB evaporator set. Allows more frequent,less intense evaporator cleaning. BMP improvement for process reliability to avoid carryover of color material into condensate systems. Reduces the volume of color material generated by evaporator boil out during outages. Color material carry over from evaporators into condensates is related to TRW Recommendations to prevent sewer-generated color. o Completed May 2011, cnsd* Repaired drain valves on No.2 and 3 Primary Clarifiers. Allows reliable isolation of one of these larger volume clarifiers as the spare clarifier for high color material diversion during semi-annual outages. BMP sustaining measure. o Completed March 2011, cnsd* Pine Weak Liquor Tank shell replacement/repairs. BMP sustaining measure. o Completed May 2011 o CIP— 331985 o- Cost—$349,000 Page 7 July 2012 —Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 Table 1 Color Team Capital and Maintenance Projects 2010- Forward Year Project Description and Cost Information for Capital Projects 2011 Installed soft start on motors for the hardwood weak black liquor transfer pumps and hardwood blow tower dilution pumps. Project reduces pump start water hammer in pipes containing black liquor and reduces risk of gasket failure,valve failure and/or pipe hanger failure from water hammer pipe movement. Project was identified by a water hammer valve failure in May 2011 that was contained within the process and did not reach the wastewater plant. o Completed May 2011 on hardwood blow tower dilution pumps o Completed Jul 201 lon hardwood weak black transfer pumps o 4 soft starts at$7540 each,project cost of$30,160 plus installation cost on maintenance expense 2012 Replaced shower bars on hardwood East Decker with improved design matching shower bars previously installed on hardwood brownstock washers. These shower bars improve washing and reduce carryover of color materials into the bleach plant. Liebergott Recommendation. o Completed during May 2012 hardwood semi-annual outage as part of larger East Decker vat repair project o CIP—358168 o Cost— $32,000 for shower bar portion of project Replaced level controls on condensate flash tanks on the West GB evaporator set. The new controls are more reliable and less prone to plugging and false level indication that can cause color material carryover into the combined condensate system,which contributes to sewer generated color. Related to TRW Recommendations regarding prevention of sewer generated color. o Completed during May 2012 semi-annual outage 0 2 capillary level elements and isolation valves at$9500 each,project cost of$29,000 including installation on maintenance expense *cnsd—cost not separately determined, completed on operations and maintenance expense Page 8 r July 2012 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 Table 2 Color Team BMP Refinements, Trials and Process Improvements 2010 forward Year(s) Refinement,Trial and/or Improvement 2010 Weak wash purge strategy to minimize potential sewer-generated color on-going during process upset, outage or reduced pulp mill production when demand for weak wash is out of balance with supply in causticizing. 2011 When both fiberlines are down,process contents of one of the spill tanks through the evaporators to free up spill tank volume before starting up. Was used successfully during and after the May 2011 cold mill outage to minimize loss of dilute color material to the W WTP. 2011 Alternative polymer study by Chemtreat at W WTP. Compared against, current polyamine polymer in use for batch treatment of black color materials.No difference in color performance. Existing batch treatment of amine polymer was retained. 2011 West GB Evaporator partial boil out strategy. Ability to clean process during on-going short outages as opportunity arises. Improves process reliability and reduces l / volume of color material to recover during outages. 2012 Reliability focus- 8 to 9 week planned maintenance outage cycle for on-going recovery furnaces and fiberlines. Prior to 2012,planned outage cycle was 10 to 12 weeks and additional unplanned outages were often necessary. Mill experience is that more frequent planned outages result in more reliable process operation between outages and lower color. Color associated with planned outages is also generally lower than color associated with an unplanned outage. 2012 Color prevention MOC/pre-task review process for outage and maintenance. on-going tasks associated with black liquor. This is.in addition to the permit-required review of modifications to systems managing black liquor,turpentine and soap. During 2012,the Color Team is evaluating alternative methods of cleaning black liquor evaporator sets during outages with the goal of both reducing the volume of dilute color materials created during evaporator boil out and also improving evaporator performance between outages for maintenance cleaning. The Color Team has associated periods of (� r Page 9 r July 2012 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 good effluent color performance with periods of reliable evaporator operation when evaporator condensates have low concentration of color material carryover. Exceptionally good mill color performance following the May 2011 cold mill outage was associated with an extended period of exceptionally good evaporator process performance. The period following the May 2011 cold mill outage to the date of this report illustrates that when the Canton Mill runs well at full production capacity, effluent color is good. When the mill experiences a process upset,and in particular an upset requiring an unplanned process outage to correct, effluent color performance is not as good. V. TRW"A List"Recommendations A primary focus of Color Team work in 2010 and 2011 was "expedited" evaluation of the EPA Technology Work Group (TRW) "A List' recommendations incorporated into Part I A.(8) item 10 of the May 2010 NPDES permit. More than $350,000 USD were expended on this effort which involved both laboratory scale and full scale trials of enhanced bleached plant extraction and laboratory trials of second stage oxygen delignification on the pine fiberline. The evaluations completed were designed to address EPA comments on prior similar evaluations completed under the 2001 NPDES permit. The results and conclusions of the 2010 and 2011 work were submitted to the NC DWQ on February 20, 2012 in the' February 2012 Update to the Color Reduction r Implementation Plan[Evergreen 2012a]. 1 Page 10 July 2012 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 Overall, Evergreen Packaging concluded that enhanced extraction(peroxide fortification) on both the pine and hardwood fiberlines and second stage oxygen delignification on the pine fiberline are not technically, operationally or economically feasible retrofits for the existing Canton Mill pulp bleaching process, which is optimized for the commercial fiber-based liquid packing products manufactured by Evergreen. The EPA reviewed and commented on the conclusions of the February 2012 report on March 22, 2012. Evergreen submitted a detailed response to the EPA comments on April 10, 2012 [Evergreen 2012b]. A copy of the Evergreen response is attached in Appendix A. 4 t In the February 2012 Color Reduction Implementation Plan, Evergreen Packaging documented a discrepancy between laboratory and full-scale trials of enhanced extraction with hydrogen peroxide on the hardwood fiberline. The first series of laboratory bleaching trials in August 2011 on samples of hardwood pulp from the Canton Mill showed a potential reduction of effluent color and bleach plant chemical use. This contradicted full-scale hardwood E stage peroxide fortification trial results from 3 s quarter of 2011 that showed no color benefit and increased bleach plant chemical cost. The discrepancy in results was attributed to carryover of mineral hardness and color materials between pre-bleach and bleach plant stages in the full-scale hardwood fiberline compared to complete washing with no carryover in the laboratory trial simulations of the process. Page 11 July 2012 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 In March 2012, Evergreen Packaging commissioned a second series of laboratory bleaching trials at the Pruyn's Island Technical Center (PITC) to simulate the effect of carryover between pre-bleach and bleach plant washing stages on the performance of hardwood enhanced extraction with peroxide fortification. The second series laboratory trials simulating hardwood bleaching with no carryover reproduced the first series results. The second series laboratory trials simulating hardwood bleaching with carryover reproduced the full-scale trial results from 3 a Quarter 2011.. When the effect of carryover between hardwood bleach plant stages was evaluated, the discrepancy between laboratory and full-scale results was resolved. The conclusions regarding enhanced extraction stages from February 2012 remain valid— this technology has no additional color reduction benefit and is not a technically, operationally or economically feasible retrofit for the Canton Mill. The final reports [PITC 2012 and McDonough 2012] documenting the first and second series laboratory bleaching simulations with enhanced extraction (peroxide fortification) on Canton Mill pine and hardwood pulp are attached as Appendix B. The cost of the second laboratory series bleach plant simulations of enhanced extraction including carryover was $10,000 USD. 1. Page 12 July 2012 —Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 VI. Partial Settlement of Wastewater Contested Cases In July 2010, Cocke County, Tennessee and a coalition of environmental groups, represented by the Southern Environmental Law Center (SELC), filed a Petition for Contested Case.in the NC Office of Administrative Hearings (OAH) — 10 EHR 4341, challenging color and temperature limits in the May 2010 NPDES permit. The Petitioners also filed a second Petition for Contested Case challenging the revised Color Variance for the Canton Mill — 10 EHR 4982. The two cases were consolidated in October 2010. } Discovery in the Contested Cases was conducted from October 2010 through June 2011. Dispositive motions were filed in July 2011. A hearing on dispositive motions was held in Haywood County, North Carolina on September 30, 2011. Following that hearing, Adminstrative Law Judge (ALJ) Randall May entered an order dismissing all but one of the Tennessee Petitioners for failure to show harm. The Contested Cases where scheduled for administrative hearing in April 2012. Discussions between Evergreen legal counsel and legal counsel for the NC DWQ and the SELC began in January 2012 and resulted in a Partial Settlement [OAH 2O12] to the Contested Cases on April 24, 2012. A copy of the agreement is attached in Appendix C. In the Partial Settlement, Evergreen Packaging agreed to fund a Color Perception Study as outlined in the EPA letter of February 22, 2010 objecting to the December 2009 Draft Page 13 July 2012 —Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 NPDES permit proposed by the NC DWQ for the Canton Mill. Evergreen Packaging,the NC DWQ and the petitioners agreed fo stay the hearing on color issues in the Contested Cases until 2013 after completion of the Color Perception Study work. On February 20, 2012 Evergreen Packaging submitted a Color Perception Study Plan to the NC DWQ. The proposed study subsequently became part of the Partial Settlement agreement. The DWQ coordinated review of the plan with the EPA. After several rounds of comments and revisions, the plan was approved. The Color Perception Study Plan revision dated April 17,2012[Evergreen 2012c]was approved by the DWQ on June 1, 2012. A copy of the approved study plan is attached in Appendix D. Field work for the Color Perception Study is targeted for the summer and fall of 2012. The estimated cost to complete the approved Color Preception Study is on the order of$200,000 USD. Because the outcome of the Contested Cases may affect the color limits in the Permit and Color Variance as well as the technologies and/or processes that the Canton Mill may use to reduce color, the company has not yet determined the technical approach and associated time frames and capital investment it will employ to achieve additional reductions in color. r� Page 14 July 2012 —Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 VII. Summary The Canton Mill will continue to utilize the processes and practices proven successful for wastewater effluent color prevention. Prevention of effluent color is a priority for mill operations every day. The primary focus of work during the second year of the May 2010 NPDES permit (July 2011 through June 2012) was completing "expedited" evaluation of TRW "A List' recommendations in Part I A.(8.) item 10 of the permit. The A List recommendations concerning enhanced extraction stages and addition of second stage oxygen delignification on pine are not technically, operationally or economically feasible retrofits for the Canton Mill. In April 2012, Evergreen Packaging and the NC DWQ achieved a Partial Settlement of the Contested Cases related to third party challenge of the May 2010 NPDES permit. Color-related work during the third year of the NPDES permit (July 2012 through June 2013) will include tasks related to the Partial Settlement agreement. �� Page 15 July 2012 —Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 REFERENCES NC OAH 2O12 — Partial Settlement Agreement and Joint Stipulation to Stay, 10 EHR 4341 and 10 EHR 4982, North Carolina Office of Administrative Hearings, April 24, 2012. Evergreen 2011 — Annual Progress Report on Color, submitted to NC DWQ to meet requirements of Part I A.(8) item 8 of the May 2010 NPDES Permit, Evergreen Packaging,July 1,2011. Evergreen 2012a—February 2012 Update to the Color Reduction Implementation Plan, submitted to NC DWQ to meet requirements of Part I A.(8) item 11 of the May 2010 NPDES Permit,Evergreen Packaging, February 20,2012. EKONO 2005—Environmental Performance, Regulations and Technologies in the Pulp and Paper Industry, EKONO Inc,August 2005. NCASI 2006—Technical Bulletin No. 919—Review of Color Control Technologies and Their Applicability to Modem Kraft Pulp and Paper Mill, National Council for Air and Stream Improvement,August 2006. PITC 2012 — Report 2011-054 (2012-13) — Evergreen Packaging Bleaching, Canton NC, Pruyn's Island Technical Center, August 3,2011,Amended March 2,2012 McDonough 2012 - Laboratory Study of Likely Effects of Oxidatively Intensifying the Extraction States at Evergreen Packaging's Canton,NC Mill, Progress Report—FINAL REPORT,Thomas J. McDonough,consultant to Evergreen Packaging,June 11,2012. Evergreen 2012b — Response to EPA Comments dated 22 March 2012 concerning February 2012 Update to the Color Reduction Implementation Plan, letter to NC DWQ Complex NPDES Permitting Unit from Evergreen Packaging dated April 10,2012. Evergreen 2012c — April 2012 Color Perception Study Plan and Response to EPA Comments dated 28 March 2012 concerning the March 2012 Revised Color Perception Study Plan, submitted to NC DWQ Complex NPDES Permitting Unit by Evergreen Packaging on April 17, 2012. Page 16 July 2012 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 APPENDICES Appendix A—Evergreen Packaging response dated April 10, 2012 to EPA comments dated March 22,2012 concerning the February 2012 Update to the Color Reduction Implementation Plan Appendix B—Final Reports documenting laboratory bleaching simulations with enhanced extraction(peroxide fortification) on Canton mill pine and hardwood pulp o PITC 2012—Report 2011-054 (2012-13) —Evergreen Packaging Bleaching, Canton NC, Pruyn's Island Technical Center, August 3,2011,Amended March 2,2012 o McDonough 2012- Laboratory Study of Likely Effects of Oxidatively Intensifying the Extraction States at Evergreen Packaging's Canton,NC Mill, Progress Report—FINAL REPORT,Thomas J. McDonough,consultant to Evergreen Packaging,June 11,2012. Appendix C—April 24,2012 Partial Settlement Agreement Appendix D—April 2012 Color Perception Study Plan approved by NC DWQ on June 1, 2012 Page 17 Appendix A Evergreen Packaging response dated April 10,2012 to EPA comments dated March 22, 2012 concerning the February 2012 Update to the Color Reduction Implementation Plan evergreen .0/ °S"• packaging j '175 75 "'M°;^ street Canton, NC 28716 PSD 28-12 10 April 2012 CERTIFIED MAIL Tom Belnick RETURN RECEIPT REQUESTED Supervisor,Complex NPDES Permitting Unit 7008 3230 0002 2591 1656 Division of Water Quality North Carolina Department of Environment and Natural Resources 1617 Mail Service Center Raleigh,North Carolina 27699-1617 Subject: Response to EPA Comments dated 22 March 2012 February 2012 Update to the Color Reduction Implementation Plan NPDES Permit NC0000272 Blue Ridge Paper Products Inc. Canton Mill Dear Mr. Belnick— Attached is our response to EPA comments received by the DWQ on 22 March 2012 and forwarded to us for evaluation. The EPA comments concern the expedited evaluation of TRW "A List"Recommendations under Part 1 Condition A.(8.),Item 10 of the NPDES permit as documented in the February 2012 Update to the Color Reduction Implementation Plan. Very truly yours, BLUE RIDGE PAPER PRODUCTS INC. DOING BUSINESS AS EVERGREEN PACKAGING Paul Dickens Nick McCracken Manager—Environmental Affairs Water Compliance Coordinator 828-646-6141 828-646-2874 paul.dickensna everoack.com nick.mccracken(a)evgMack.com Attachment: Response to EPA comments dated 22 March 2012 concerning the February 2012 Update to the Color Reduction Implementation Plan cc(wlenclosure): DWQ ARO Color Team, Internal Distribution fresh by design_ / Dana Boslness in CaPbin,a as Evergreen Beverage Fockoging F:\SHARE\Water Files\Color Reports 2010 Prmt\Color Reduction Implementation Plan\E-Sign Response to EPA Comments on the Updated Color Reduction Implementation Plan Apr 2012.doc evergreen,. Canton Office packaging I 175 Mom Street• Conton, NC 28716 Attachment — 10 April 2012 Blue Ridge Paper Products Inc. dba Evergreen Packaging(BRPP)response to EPA comments dated 22 March 2012 concerning the February 2012 Update to the Color Reduction Implementation Plan EPA Comment— First regarding BMPs • We continue to believe in the importance we have always accorded to BMPs, as noted below. However, it is puzzling that the list of BMPs shows hardly any improvements in the long term reductions of color, as one would anticipate. Moreover,we do not see estimates or data addressing any benefits that may accrue to implementing the evaluated BMPs and in so doing reduce variability/spikes in effluent color. BRPP Response— Prevention of wastewater effluent color is a priority for Canton Mill operations every day. Evergreen Packaging and the Canton Mill Color Team agree that Best Management Practices (BMPs) are critical to this priority. BMPs are most effective when they are mill specific,and are tracked,evaluated and implemented on an ongoing basis. In response to the EPA comment,"... it is puzzling that the list of BMPs shows hardly any improvements in the long term reduction of color,as one would anticipate." Evergreen Packaging would note that at the high level of effluent color prevention the Canton Mill has already achieved,new BMPs contribute more to operational reliability and control of process variability than to significant effluent color reduction. BMPs implemented during the period 2006- 2011 have improved process variability compared to the period 2001 - 2005 as indicated by the standard deviation in secondary effluent color for these periods (table below). Specifically, BMP improvements since 2006 resulted in tighter (less variable) color performance during normal operating conditions and during planned outages. Period Standard Deviation of Canton Mill Secondary Effluent Color, Ibs da 2001 - 2005 17,318 2006- 2011 10,843 fresh by design. [sineB,rslnessin Ca!itcmio.,Evergreen Beverage?.c .ng Attachment-BRPP Response Page 2 EPA Comment- Second, regarding process changes • There appear to be notable differences in what was accomplished in lab studies(e.g., PITC) versus mill trials.We most certainly understand that lab results don't always successfully translate to full scale. However, the differences in changes in wastewater color are neither well explained nor documented, beyond assertions that they will not work. For example, the PITC work omits the inevitable increase in pulp yield due to the higher Kappa number at the digester exit with 2-stage OD.This would reduce bleaching chemical use as noted by McDonough (caustic and CIO2)and thus operating costs, not increase them; moreover the reduction in color was asserted to be less than 1000 Ibslday, but there is no basis for this improbable assertion; McDonough shows noticeable reduction in color formation but there is not sufficient data available to calculate the impact on final effluent. • An appreciable amount of color is from the CRP;with less chemical usage in bleaching due to 2- stage OD, noted just above, CRP will have less to remove; this was not considered BRPP Response- Concerning results of the full scale-trials of enhanced extraction (peroxide fortification) compared to laboratory simulation of this process,the 90-day trials in 3rd quarter of 2011 clearly did not reduce bleach plant effluent color or result in bleach plant chemical cost savings. �1 ( Concerning the laboratory studies of second stage oxygen delignification on pine,the mill took care to simulate how this technology might be applied as a retrofit to the existing pulp digestion,washing and bleach plant systems-including the Minerals Removal Process- without causing adverse effect on bleached pulp strength. To quantify the potential color benefits from 2-stage 02 delignification (00) compared to single stage delignification (0), an independent lab (Pruyn's Island Technical Center or PITC) was utilized to simulate the process using Canton Mill wood chips.and brown stock pulp. A third party expert (McDonough) was retained to validate and summarize the outcome of the work. For the lab study plan,two operating strategies for digester wood cooking were considered-26 kappa and 30.5 kappa. 26 kappa cooking strateev The first strategy was to maintain the current kappa number out of the digesters (26) for both 0 and 00 and take the benefits from the additional 02 delignification stage to target a 3-4 kappa number reduction entering the bleach plant.. With this option,the data showed that color was reduced in the Do stage and Eo stage by 295 and 550 units,respectively (McDonough report Table 2,pages 2-3). The color reduction in the D1 stage was minimal (McDonough report Table 2,pages 2-3). [Note-the Do and D1 stages referred to in the PITC and McDonough reports simulate the D1 and D2 stages at the Canton Mill. The Eo stage in the lab studies simulates the Eo stage at the Canton Mill.] l Attachment—BRPP Response Page 3 Bleaching chemicals were reduced as reported in the same table referenced above. The final pulp viscosity was reduced from 17.4 for 0 pulp to 14.5 for 00 pulp (McDonough report Table 2 pages 2-3). McDonough states on page 12 of report,"Analysis of mill data suggests that the viscosity reduction that would result from adding a second stage of oxygen delignification is likely to have pulp strength implications. Utilization of two-stage oxygen mill pulp may be expected to lead to lower final viscosity than the current 11.3 — 11.5 mPa.s and correspondingly lower physical strength properties." Based on the tests for physical properties,the following quote from page 5 of McDonough's report summarizes the results: "Figure 3 shows the relationship between tearing resistance and tensile strength for each of four pulp types. It is apparent that,at a tensile index of 70 N.m/g the 26 Kappa pulp after two oxygen stages had a roughly 15% lower tear relative to the base case (single-oxygen stage applied to 26 Kappa pulp). The"mill bleached" pulp had lower tear strength than the lab single-oxygen stage pulp. This may be explained by the harsher physical treatment of mill pulp due to blow valves,pumps and other process equipment" McDonough summarizes the lower strength implications on page 12 as follows: the 26 kappa 00 pulp developed lower tensile and tear tests resulting from reduced specific bond strength of the fibers,leading to increased beating requirements and denser sheets. The 15%reduction in pulp strength from applying second stage oxygen delignification to the existing Canton Mill process has serious commercial implications. Evergreen customer requirements for product specifications would be negatively impacted,to the point of losing business for unacceptable quality. Therefore,the 26 kappa strategy is not a viable option. 30.5 kappa cooking strategy The second strategy was to raise the Kappa number out of the digesters to 30.5 and utilize the 00 delignification process to reduce the Kappa number to its current level entering the bleach plant. With this strategy,the color in Do and Eo was reduced by 250 and 190 units, respectively(McDonough report Table 2,pages 2-3). This small reduction in color was with pulp that was one (1) Kappa unit below single stage delignification (12.4 vs 13.4). At this rate of approximately 60% delignification (McDonough report Table 1,page 2),we don't expect it to be obtainable with the viable second stage delignification system designs commercially available to retrofit to the existing Canton Mill process.The 16% C102 reduction referenced by the first full paragraph on page 12 of McDonough's report is again based on the 1 Kappa unit lower 00 pulp entering the bleach plant. The C102 chemical savings would not be realized for a targeted 13.4 Kappa number 00 pulp entering the bleach plant. The 00 stage also increased NaOH charge by 50%over 0 stage (McDonough report Table 1,page 2) ultimately increasing overall chemical costs for the process. The 30.5 kappa strategy did produce pulp that has virtually the same viscosity and strength properties as compared to the 0 pulp (McDonough report page 12). However, at this kappa range the unbleached yield increase out of the digesters would be minimal and "the increase in unbleached yield would be at least partially lost in the more extensive 4 delignification that results from increased degree of oxygen delignification associated with Attachment-BRPP Response Page 4 the switch from single-stage oxygen to two-stage oxygen' (McDonough e-mail,3/30/12). On the lab data basis,this strategy would not provide the significant color benefit that is desired. Calculation of Bleach Plant Effluent Color Reduction The following table outlines calculation of potential bleach plant effluent color reduction and secondary effluent color reduction based on the laboratory simulations of second stage oxygen delignification on pine. The laboratory results must be adjusted for the effect of pine bleach filtrate recycling with the Minerals Removal Process(MRP). The minimum closure and internal recycling rate is 50% and is used as a conservative(low) estimate in the calculation table. The average NW closure rate in 2011 was 80.8%, substantially greater than the conservative calculation. The McDonough report and discussion above demonstrate that the 26 kappa strategy is not commercially viable due to adverse effect on pulp strength. The calculation of potential filtrate and effluent color reduction documented below demonstrate that the potential secondary effluent color reduction benefit of second stage oxygen delignification on pine with both the 26 kappa strategy(not commercially viable) and 30.5 kappa strategy is less than 1000 lbs per day. Digester Cooking Strategy 26 kap a-00 30.5 kappa- 00 Canton Mill Pine Bleach Filtrate D1 stage Eo Stage D1 Stage Eo Stage �} Color reduction compared to existing 295 550 250 190 single stage delignification, PCUs. 2011 filtrate flow, m d 0.25 . 0.11 0.25 0.11 Potential filtrate color reduction 615 505 521 174 without MRP, lbs/da * Total 1120 695 NW closure, percent 50 50 Potential filtrate color reduction 560 348 considering MRP closure, lbs/da Potential secondary effluent color reduction based on 15% color 476 296 removal in activated sludge, lbs/da *Color lbs/day=PCUs x flow (mgd)x 8.34, this is the calculation of color mass used in the Canton Mill NPDES permit, see Permit condition A.(8.) item 2. Summary on cooking and color reduction While two-stage oxygen delignification would certainly be part of any new Kraft pulp mill, retrofit of this technology to an existing process that is optimized for specific commercial products-such as the Canton Mill- requires great care. Addition of a second oxygen delignification stage on pine is not a good retrofit for additional color reduction. Adjustments to cooking for pulp strength necessary to make commercially viable pulp for Attachment—BRPP Response Page 5 ' the fiber-based liquid packaging products manufactured by Evergreen Packaging negate potential chemical use and color benefits from the two-stage oxygen delignification process. The 2010 laboratory work to simulate retrofit of second stage oxygen delignification on pine was specifically designed to address TRW comments on previous work in 2001 as well as update economics and potential color reduction. Based on the simulation of realistic operating strategies to apply this technology to the Canton Mill, Evergreen Packaging concluded that second stage oxygen delignification on pine is not technically,operationally or economically feasible. Chloride Removal Process (CRP) EPA commented that color reduction from reduced CRP purge rate related to bleach-plant chemical reduction should be considered. While this is theoretically correct, the CRP purge rate for chloride control is driven more by MRP closure rate and chemical demand associated with recycled non-process elements than by pre-bleach kappa. Additionally, the 26 kappa cooking strategy outlined above while producing some bleach plant chemical savings is not commercially viable due to adverse effect on pulp strength and final product quality. The 30.5 kappa cooking strategy—which is necessary to preserve pulp strength by holding pre-bleached kappa the same as the existing process—does not reduce bleach plant chemical use and subsequently would not reduce CRP purge rate. l i References from the February 2012 Color Reduction Implementation Plan PITC 2011 a—Report 2010-081 —Laboratory Cooking and Bleaching for Evergreen Packaging Canton,NC, Pruyn's Island Technical Center, January 31, 2011. McDonough 2011 —Laboratory Study of Likely Effects of Installing Two-Stage Oxygen Del ignification at Evergreen Packaging's Canton Mill,Thomas J. McDonough, consultant to Evergreen Packaging; June 29, 2011. T � Appendix B Final Reports documenting laboratory bleaching simulations with enhanced extraction (peroxide fortification) on Canton mill pine and hardwood pulp o PITC 2012 — Report 2011-054 (2012-13) — Evergreen Packaging Bleaching, Canton NC, Pruyn's Island Technical Center, August 3, 2011, Amended March 2,2012 o McDonough 2012 - Laboratory Study of Likely Effects of Oxidatively Intensifying the Extraction States at Evergreen Packaging's Canton, NC Mill, Progress Report — FINAL REPORT, Thomas J. McDonough, consultant to Evergreen Packaging,June 11,2012. AMRMTL Pulp & Paper Evergreen Packaging Bleaching Canton , NC Report: No.2011-054(2012-023) Date issued: Date:August 3, 2011, Amended March 2,2012 Author: Pamela O'Leary Evergreen Packaging Attention:William Miller Contact:Andritz Inc. Division: Pruyn's Island Technical Center Project Manager: Michael Kingsley 13 Pruyn's Island Drive Glens Falls, NY 12801 Phone: (518)745-2999 Fax: (518)745-2971 E-mail: Michael.kingsley@andritz.com www.anddtz.com Confidential document.All rights reserved.No duplication or disclosure to third portions permitted without the written consew of ANDRITZ AG. AWMTL Pulp & Paper Summary Evergreen Packaging supplied Andritz with mill oxygen delignified softwood and hardwood pulps for laboratory bleaching trials. We were to compare the effect on effluent color and fully bleached strength properties by changing the current Eo/E stages to Eop/Ep and pressurized Pht stages. Softwood was bleached using Do-Eo-D, Do-Eop-D and Do-Pht-D to a target 86% ISO brightness. Hardwood was bleached to the same brightness target using Do-E-D, Do-Ep-D and Do-PM-D. Observations • Mill softwood had a kappa number of 14.2 and viscosity of 14.3 mPa•s. • Mill hardwood had a kappa number of 6.8 and viscosity of 13.8 mPa-s. Bleaching Chemicals Con sum tion Summary Bleaching Sequence CI02 H102 Final ISO Final Consumed Consumed Brightness Viscosity K /ADMT K /ADMT % mPa•s Softwood Do-Eo-D 25.2 --- 86.1 11.2(correct- ed Do-Eo -D 23.3 4.5 86.2 10.8 Do-P -D 21.4 5.4 86.4 10.7 Hardwood Do-E-D 17.5 -- 86.1 10.7 Do-E -D 12.6 2.7 86.3 10.8 Do-P -D 8.8 4.5 86.5 11.3 Tear and Tensile Index@ 400 CSF of Fully Bleached Pulps Tensile Index Tear Index LIMS ID Descriptive ID (N•m/g)at 400 (mN•m'/g) at 400 CSF CSF 124576 Softwood Do-Eo-D 84.93 8.68 124582 Do-PHT-D 81.93 8.51 124579 Do-Eo -D 83.81 8.41 12424 74 572 Hardwood Do-E-D 66.26 8.15 15 Do-P -D 70.49 9.02 124818 Do-E -D 68.98 8.80 ., a I e a Nu.t_ .a Cj_. w n w.ve. ....e12�G. ""'t,0'1 AMRMTL Pulp & Paper Experimental Standard Operating Procedures Procedure Description PITC-84 100% Chlorine Dioxide Substitution PITC-B8 Chlorine Dioxide Bleaching PITC-136 Alkaline Extraction PITC-B6 Oxidative Alkaline Extraction w/ eroxide Tappi T525 om-92 Diffuse Brightness TappiT230 Capillary Viscosity TappiT248 PFI Beating of Wood Pulp TappiT236 Ka a Number NCASI TB#253 Color in Effluent ITappiT227 Canadian Standard Freeness w R1en(z.o :en, AIri191M1s Id N I I I I' dr L co=_uel II' 1Cv��a�rt--, ec . mu t tne w n mr suc c.tr q6. ' . Fa9e3 0't AMRMTL Pulp & Paper Test Results - Series 1 (2011-054), no carryover from post 02 washing or between bleach plant stages Table 1. Softwood Do-E-D Bleaching Sample Mill Post 02 Softwood Sample ID 124558 Kappa number 14.2 Viscosity, mPa s 14.3 ISO Brightness, % 35.2 Do Stage: 150°F. 40 min.. 10% cons. Sample ID 124574 Kappa Factor 0.24 CI02, % 1.29 H2SO4, % 0.35 Final pH 2.8 Consumed CIOZ, % 1.29 ISO Brightness, % 51.9 Color, C.U. 1850 Eo Stage: 1750F. 60 min..35 psi 0 psi. 10 min., 10% cons. Sample ID 124575 NaOH, % 0.9 Final pH 11.0 Kappa Number 3.2 Viscosity, mPa s 13.8 ISO Brightness, % 58.2 Color, C.U. 2390 D Stage: 165°F, 240 min., 10% cons. Sample ID 124576 CI02, % 1.0 1.2 1.4 NaOH, % 0.45 0.54 0.6 Final pH 4.2 4.1 3.6 CI02 Consumed, % 1.0 1.197 1.396 ISO Brightness, % 84.6 85.1 86.1 Color, C.U. -- -- 59 Viscosity, mPa s 11.2 (corrected) AMRMTL Pulp & Paper Table 2. Softwood Do-Eop-D Bleachng Sample Mill Post 02 Softwood Sample ID 124558 Kappa number 14.2 Viscosity, mPa s 14.3 ISO Brightness, % 35.2 Do Stage: 150°F. 40 min., 10%cons. Sample ID 124577 Kappa Factor 0.2 C1O2, % 1.08 H2SO4, % 0.49 Final pH 2.9 Consumed C1O2, % 1.08 ISO Brightness, % 49.0 Color, C.U. 2125 Eop Stage: 175°F, 60 min..35 psi. psi 0 psi. 10 min., 10% cons. Sample ID 124578 NaOH, % 1.1 H2O2, % 0.5 Final pH 11.0 Kappa Number 3.2 H2O2 Consumed, % 0.5 Viscosity, mPa s 12.9 ISO Brightness, % 64.3 Color, C.U. 2045 D Staae: 165°F, 240 min., 10% cons. Sample ID 124579 CIO2, % 1.0 1.2 1.4 NaOH, % 0.45 0.54 0.6 Final pH 4.4 3.8 4.0 C102 Consumed, % 1.0 1.2 1.4 ISO Brightness, % 84.8 85.6 86.2 Color, C.U. --- --- 58 Viscosity, mPa s --- - 10.8 AWMTL Pulp & Paper Table 3. Softwood Do-Ph,-D Bleaching Sample Mill Post 02 Softwood Sample ID 124558 Kappa number 14.2 Viscosity, mPa-s 14.3 ISO Brightness, % 35.2 Do Stage: 150°F, 40 min., 10% cons. Sample ID 124580 Kappa Factor 0.2 C1O2, % 1.08 H2SO4, % 0.49 Final pH 2.9 Consumed CIO2, % 1.08 ISO Brightness, % 48.8 Color, C.U. 2125 Pwr Stage: 200°F. 60 min.. 100 psi. 15 min. 10% cons. Sample ID 124581 NaOH, % 1.4 H2O2, % 0.6 Final pH 11.1 Kappa Number 2.8 Viscosity, mPa s 12.3 ISO Brightness, % 67.5 Color, C.U. 1640 D Stage: 165°F, 240 min., 10% cons. Sample ID 124582 C1O2, % 0.8 1.0 1.2 NaOH, % 0.30 0.40 0.50 Final pH 3.9 4.0 4.0 C1O2 Consumed, % 0.8 1.0 1.2 ISO Brightness, % 84.5 85.6 86.4 Color, C.U. -- -- 71 Viscosity, mPa s 10.7 AMRMTL Pulp & Paper Table 4. Hardwood Do-E-D Bleaching Sample Mill Post 02 Hardwood Sample ID 124655 Kappa number 6.8 Viscosity, mPa s 13.8 ISO Brightness, % 44.1 Do Stage: 150°F. 40 min., 10% cons. Sample ID 124570 Kappa Factor 0.26 CIO2, % 0.67 H2SO4, % 0.7 Final pH 2.5 Consumed CIOZ, % 0.67 ISO Brightness, % 67.4 Color, C.U. 685 E Stage: 175°F. 60 min.. 10% cons. Sample ID 124571 NaOH, % 0.9 Final pH 11 Kappa Number 2.7 Viscosity, mPa s 13.1 ISO Brightness, % 68.4 Color, C.U. 570 D Stage: 165°F. 160 min.. 10%cons. Sample ID 124572 CIO2, % 1.0 1.2 1.4 NaOH, % 0.40 0.48 0.56 Final pH CI02 Consumed, % 0.997 1.190 1.394 ISO Brightness, % 85.5 86.1 86.7 Color, C.U. -- 27 -- Viscosity, mPa s 10.7 AMRMTL Pulp & Paper Table 5. Hardwood Do-Phl-D Bleaching Sample Mill Post 02 Hardwood Sample ID 124655 Kappa number 6.8 Viscosity, mPa s 13.8 ISO Brightness, % 44.1 Do Stage: 150°F. 40 min.. 10%cons. Sample ID 124743 Kappa Factor 0.21 CIO2, % 0.54 H2SO4, % 0.7 Final pH 2.7 Consumed C1O2, % 0.54 ISO Brightness, % 64.7 Color, C.U. 373 PHT Stage: 200°F. 60 min.. 100 psi. 15 min. 10% cons. Sample ID 124744 NaOH, % 1.3 H2O2, % 0.5 MgSO4, % 0.1 H202Consumed % 0.5 Final pH 11.3 Kappa Number 2.7 Viscosity, mPa s 11.6 ISO Brightness, % 79.4 Color, C.U. 210 D Stage: 165°F, 160 min.. 10% cons. Sample ID 124745 CIOz, % 0.2 0.4 0.6 H2SO4, % 0.09 0.01 -- NaOH, % -- -- 0.05 Final pH 4.2 4.0 3.4 CIO2 Consumed, % 0.2 0.4 0.6 ISO Brightness, % 84.9 86.7 87.8 Color, C.U. -- 52 -- Viscosity, mPa s 11.3 AMRMTL Pulp & Paper Table 6. Hardwood Do-Ep-D Bleaching Sample Mill Post 02 Hardwood Sample ID 124655 Kappa number 6.8 Viscosity, mPa s 13.8 ISO Brightness, % 44.1 Do Stage: 150°F. 40 min.. 10% cons. Sample ID 124746 Kappa Factor 0.21 CIO2, % 0.54 H2SO4, % 0.7 Final pH 2.7 Consumed CIO2, % 0.54 ISO Brightness, % 65.0 Color, C.U. 345 ED Stage: 175°F. 60min., 10% cons. Sample ID 124747 NaOH, % 1.0 H202, % 0.3 Final pH 11.1 H2O2 Consumed, % 0.3 Kappa Number 2.7 Viscosity, mPa•s 12.0 ISO Brightness, % 74.8 Color, C.U. 365 D Stage: 165°F. 160 min.. 10%cons. Sample ID 124818 CIO2, % 0.6 0.8 NaOH, % 0.04 0.24 Final pH 4.4 3.8 CIO2 Consumed, % 0.6 0.8 ISO Brightness, % 85.7 86.3 Color, C.U. -- 32 Viscosity, mPa s 10.8 Conf,denflel d=. nt.AH♦i,ts reserved Vege 5 of 11 C ME OOf NM nMpNn Or N 0� O MMO W �p MtDn a0r O t0 nON ° 0) co O V N O N M 0) r t0 V to n V V M (O rn n 0) M It r O IT ItA' C E N M M (M M M th M ty CV M M m 6 (V (M M M M , N N P7 M N CV 6 M m V/ O _ a W O N N rM0 a N (qhr 07 0f — (nn N V W OOONr V O n to O V O N d _ _ O C LO mOO (O W (pMOW n MOO) to N M MO V MN t0M I W N 0 Z MMn O) LO (mIT tD m (Drao MIT �} r mMn aa {� nN O F Y M V V V In M V (O (O N � V (fI O (1') M V (O N O M V V (A N M fF V O N — N a E mN mnu� yM (p � to m m M O N � N (M '' v a! � N MONON fOM � On rNNO O (O M m ro a r co in n rn m ao to0) c0 tD fV (A a) � Oj ap t0 � Oj V M C7 O �j O O a0 r M Oi O n to tD (V � �- Q Nt0 c0 � � W H Ol d E q Ma<r OONO fmO ND M mo n o7MIn Mrao UDCO 0 Z � WWturrNm1�: ih ao om ao ao 0 O 6 w co E x am EO iIn 1 It 7 Or WCE OivtDJN .0 M M N 0 w ON (V m O WC Z N v t0 (0 OM to D D wawOOM0n0 MN r n M N t0 I� n a N N y E V M 10 In O t0 O M CoM W O V N " n 0) M It M It N M CDW 10 a MNn V NM00 7 MM rO) M NOM W N N V 7NmM (D MO V m _ a m Ul Y Co nCO COON 01N Nr W Nn WW W (p tD r N M t0 !V E Ito N V I": M (', M n (D 700 N N M M w (D a MN � (S, N th . (D m Y a pp aa pp VV a O OI N tO M M (MD (OO f� N M h MN O a M M N V V V th a 7 N M 8 w V — OO N t0 t0 tDO co fD (O OO tO t0 tO 6tflO t0t0O t0 (O to tO O t0 t0 t0O Im C ° ` W V� J ra0M0 (D OOOOON ONE t0N M V tO V o V r O E (n N N N V M N M M n M O r 01 tO t0 O O t0 tD m M N r t() E N tD V00 M N tD t0t0 N M N O tp V � � t0 (D V N m t0o O N N N M N N lD M N A � U Q° T N M N NO (O OM M O t0 ODO� Nth O N O ryO OON ON LnONnC 0 0 0 G NCi o L vo a s N ar p p O p p p $ O > d a a W W w d za w b b N 0 = U) _ = m N a W N N (O O N (0 O 61 Y a 7 LO to J u AMRMTL Pulp & Paper Miscellaneous Information All samples included in this report will be held in cold storage for three months after issuance of the report. At that time, the samples will be discarded without notice. If there is a need to retain sam- ples longer than the three-month grace period, please contact PITC. Addendum March 2012 — the attached tables (4) document the results of Series 2 laboratory bleaching tests on hardwood designed to simulate the effect of carryover from post 02 washing and between bleach plant stages Test Results—Series 2 (2012-023), hardwood laboratory trials evaluating effect of carryover from post 02 washing and between bleach plant stages • Without and with carryover Do-E-D • Without and with carryover Do-Ep-D • Without and with carryover Do-Pht-D • Final D stage physical strength properties s C.nN*I.l al tlowmanl.All righ%reserved No tlupiicat',en or OisGosure to lwd patllers perminen Whoul the written consent 0 ANDFITZ AG Page 11 of 11 ' 1 Series 2-Hardwood Bleach Trials(2012-023)without and with carryover Do-E-D Do-E-D Bleach Sample Mill Post 02 Hardwood Sample ID 128065 Kappa number 7.0 Viscosity mPa•s 12.7 ISO Brightness 43.8 Do Stage: 150°F. 40 min.,10%cons. Sample ID 128150 128450 Kappa Factor 0.28 0.28 CI02,% 0.75 0.75 H2SO4,% 0.69 1.5 Mill 02 Carryover,kgBDMT 0 12.5 Final pH 2.5 2.7 %Consumed CI02, % 0.75 0.75 ISO Brightness, % 69.0 61.6 Color,C.U. 385 1140 E Stage: 175°F.60 min., 10%cons. Sample 128152 128452 NaOH,% 0.8 0.5 Mill E Carrover, kg/BDMT 0 5.0 Final pH 11.0 10.8 Kappa Number 2.3 3.2 Viscosity mPa•s 12.4 12.1 ISO Brightness, % 70.8 65.8 Color,C.U. 520 1390 D Stage: 165°F.160 min.,10%cons. Sample ID 128160 128455 CI02, % 0.8 1.0 1.2 1.2 1.4 1.6 NaOH, % 0.25 0.38 0.45 0.45 0.52 0.59 Final pH 3.6 3.8 3.7 3.4 3.2 3.1 C102 Consumed, % 0.796 0.994 1.119 1.199 1.397 1.595 ISO Brightness, % 86.4 86.7 86.7 85.6 86.0 86.3 Color,C.U. 16 - - - 75 - Viscosity mPa•s 11.5 -- - - 10.2 -- ^\ Series 2-Hardwood Bleach Trials(2012-023)without and with carryover Do-Ep-D Do-Ep-D Bleach Sample Mill Post 02 Hardwood Sample ID 128065 Kappa number 7.0 Viscosity mPa•s 12.7 ISO Brightness 43.8 Do Stage: 150°F. 40 min..10%cons. Sample ID 128151 128451 Kappa Factor 0.26 0.20 C102,% 0.53 0.53 H2SO4,% 0.84 1.8 Mill 02 Carryover,kg/BDMT 0 12.5 Final pH 2.6 2.6 %Consumed C102, % 0.53 0.53 ISO Brightness, % 63.8 56.7 Color,C.U. 290 1120 Ep Stage: 175°F.60min.. 10%cons. Sample 128153 128453 NaOH, % 0.9 0.6 H2O2,% 0.3 0.3 Mill E Carrover, kg/BDMT 0 5.0 Final pH 11.1 10.4 H2O2 Consumed% 0.3 0.3 Kappa Number 2.9 3.6 Viscosity mPa•s 11.5 11.8 ISO Brightness,% 75.3 70.4 Color,C.U. 450 1370 D Stage: 165°F. 160 min.. 10%cons. ,Sample ID 128161 128456 C102, % 0.6 0.8 1.0 1.0 1.2 1.4 NaOH,% 0.20 0.24 0.38 0.35 0.42 0.52 Final pH 3.6 3.4 3.6 3.5 3.4 3.0 C102 Consumed,% 0.6 0.8 1.0 1.0 1.2 1.4 ISO Brightness, % 85.7 86.6 86.9 85.1 85.9 86.6 Color,C.U. - 27 - - - 74 Viscosity mpa•s -- 10.9 - + - - 9.9 r �I Series 2-Hardwood Bleach Trials(2012-023)without and with carryover Do-Pht-D Do-PHrD Bleach Sample Mill Post 02 Hardwood Sample ID 128065 Kappa number 7.0 Viscosity mPa•s 12.7 ISO Brightness 43.8 Do Stage: 1500F. 40 min..10%cons. Sample ID 128151 128451 Kappa Factor 0.20 0.20 C102,% 0.53 0.53 H2SO4,% 0.84 1.8 Mill 02 Carryover, kg/BDMT 0 12.5 Final pH 2.6 2.6 %Consumed C102, % 0.53 0.53 ISO Brightness, % 63.8 56.7 Color,C.U. 290 1120 P.,Stage: 2000F.60 min.. 100 psi. 15'min. 10%cons. Sample 128154 128454 NaOH,% 1.0 0.9 H2O2,% 0.5 0.5 MgSO4,% 0.1 0.1 H2O2 Consumed% 0.47 0.49 Mill E Carrover, kg/BDMT 0 5.0 Final pH 10.8 10.4 H2O2 Consumed% 0.5 0.494 Kappa Number 2.6 3.6 Viscosity mPa•s 11.4 11.1 ISO Brightness, % 80.4 72.8 Color,C.U. 210 1580 D Stage: 1650F. 160 min.,10%cons. Sample ID 128162 ' 128457 CI02, % 0.2 0.3 0.4 0.6 0.8 1.0 H2SO4,% 0.23 0.15 -- - - -- NaOH,% - - 0.007 0.08 0.22 0.34 Final pH 3.9 3.4 3.8 3.2 3.2 3.4 C102 Consumed, % 0.2 0.3 0.4 0.6 0.8 1.0 ISO Brightness, % 84.8 86.1 87.1 85.1 85.8 86.3 Color,C.U. - 31 - - - 119 Viscosity mPa•s - 11.3 - - - 10.2 C O CN CV 11 r,i fV M t,1 '+ lJ CV e•1 M N CV t,1 to O L� ^ y N � N Yl O Gl m Q b M N O\ G\ O m M n b Nn L1 Q .0 Q Q R y G d x M Q Q V1 Vf m Q v Vl Vl M Q Q V1 Vf M'Q Q Vl Vl M Q Q Vl Vl N Q Vl Vl V1 N j' L W _ R F u 0 E c� o � — M N hmnQ nb n a M 1 :7 nM V � bbm h — nQ -- F .p MlV ob coo ob mc� mvlb o -- Q v W Gl G. U. m . O. G. m. m. l. O. Gl W . O. . m cC l. m. L1 W W lh l. � c O v •R K � M n O O\ ^ '+ m m N V1 ^ \D O tY N lD h N b M � m M M ^ T Vl m T Cl i h Q O N m N P �+ I! N m IT: n N N W m Q N Nw b lV N M 'C Y C M Q Vt Q M Q Q Vl m Q Q Q V1 M Q Q Q Q Q Q Q Q M M m Vl M M N Q ov0 .y WE Q O Q n n M O Vl Vl Vl m O VI Vl �/1 M n Q M M Q m M N N m O Q Q N u U N N Q M N Vl Vl Q M N Vl vl Q M N Vl Q Q M N Vf Q Q M N Vl Vf Q m N en R y 65o �n0000 �n0000 v� 0000vi0000 �n0000v+ 000 Q �+ O — N M O — N m O — N M O � N m O — N M C � N M R C n aQ A o 0 0 8 S 0 q x z x N_ N V V R F Laboratory Study of Effects of Oxidatively Intensifying the Extraction Stages at Evergreen Packaging's Canton, NC Mill Final Report C Thomas J. McDonough June 11, 2012 r' � Executive Summary This report describes a study undertaken to study and document the effects of oxidatively reinforcing the Canton mill's extraction stages. The effect on effluent color and chemical consumption were of particular interest; effects on bleached pulp physical properties were also measured. Mill oxygen-delignified softwood and hardwood pulps were subjected to laboratory bleaching trials. In the case of the softwood pulp trials,existing(EO) stage conditions were compared with conditions chosen to simulate(EPO) and(PO) stages.The(EPO) stage was simulated by adding 0.5% hydrogen peroxide.The (PO) stage(sometimes referred to as a pressurized peroxide or Pm stage) was simulated by increasing the temperature, oxygen pressure and peroxide charge. In the softwood trials, the pulps were thoroughly washed after each stage; no attempt was made to simulate post-oxygen washing carryover and E-stage filtrate recycle. In the case of the hardwood pulp trials,the existing E stage conditions were compared with conditions chosen to simulate(EP) and (PO) stages. The(EP) stage was simulated by adding 0.3%peroxide.The(PO) stage was simulated by increasing the peroxide charge,pressurizing with oxygen and raising the temperature.In both cases the chlorine dioxide charge in the first D stage(the"Do stage") was decreased and the chlorine dioxide charge.in the final stage(the"Di stage")was adjusted to reach the desired target brightness. Two series of hardwood pulp bleaching trials were conducted. In the first, the pulps were thoroughly washed after each bleaching stage. When these trials gave promising results,it was decided to run a second set of trials in which post-oxygen washing carryover and E-stage filtrate recycle were simulated. In the softwood case, adding peroxide to the(EO)stage resulted in almost no decrease in total effluent color. Converting the(EO)stage to a(PO) stage decreased the total color by 11%. The hardwood bleaching trials that incorporated simulation of the washing carryover and E stage recycle levels that inevitably occur in the mill showed no beneficial effects of the extraction stage modifications on effluent color. In experiments in which post-oxygen washing carryover and E-stage filtrate recycle were not simulated, reinforcing the extraction stages decreased total chlorine dioxide consumption by as much as 10 lb/ton (0.5% on pulp)in the case of softwood pulp and by as much as 16 lb/ton (0.8%on pulp) in the case of the hardwood pulp. When bleaching hardwood pulp, inclusion of filtrate carryover and recycle increased extracted kappa numbers,resulting in increased C1O2 consumption. C1O2 consumption increased by 0.8% when the extraction stage was an E stage and by 0.6%when the extraction was an (EP) or(PO) stage. In the presence of filtrate carryover and recycle, converting the E stage to an (EP)stage decreased total chlorine dioxide consumption by 8 lb/ton(0.4% on pulp)and converting the E stage to a(PO)stage decreased total chlorine dioxide consumption by 16 lb/ton (0.80% on pulp). With a few exceptions,effects on the physical properties of both pulp types were generally small or nonexistent.The exceptions were increases in elongation and tensile energy absorption of the softwood pulps and possible increases in maximum tearing resistance strength of the hardwood pulps. The results suggest that there is little environmental benefit to be gained by implementing the extraction stage modifications studied here. Introduction The Canton mill employs the OD(EO)D and ODED bleaching sequences to produce bleached softwood and hardwood pulps. The mill commissioned a laboratory study to predict the effects of intensifying the alkali extraction stages in the bleaching sequences of both softwood and hardwood pulps. In the case of softwood, this amounted to converting the(EO) stage to either an(EPO) stage or a high-temperature pressurized peroxide stage, here denoted by(PO).In the case of hardwood the study assessed the effects of 2 converting the E stage to a peroxide reinforced extraction stage(EP) or a(PO)stage. These changes may be expected to reduce the color of the effluent generated in the bleach plant. Post-oxygen mill pulps were the starting materials for the study. After each stage,the pulps were characterized by suitable measurements (kappa number, brightness and/or viscosity, depending on the stage)and the color of the effluent from each of the last three stages was measured. In addition, fully bleached samples were subjected to laboratory refining and the physical properties of the refined pulps were measured. Two series of hardwood pulp bleaching experiments were run. In the first set, the starting pulp was thoroughly washed post-oxygen-stage pulp and the pulp was thoroughly washed after each bleaching stage. As a result,none of the effluent generated in any stage found its way into the next one. In the second series, hardwood pulp was the starting material and measured mill washer carryover was simulated by adding a realistic amount of mill post oxygen-stage effluent("carryover") to the pulp going to the first C102 stage (the"Do stage) and corresponding amount of mill E stage effluent(recycle)to the pulp going to the extraction [E, (EP) or(PO)] stage. Another difference between the two series of hardwood bleaching experiments is that the kappa factor in the second series was increased from 0.26 in the first series to a more typical 0.28 in the second. The experiments were performed at the Pruyn's Island Technical Center of Andritz Inc.The raw data and details of the experimental procedures used may be found in their reports. Results and Discussion Multistage Bleaching Tables 1 and 2 contain the results*of multistage bleaching experiments performed without stage-to-stage carryover on the softwood and hardwood pulps, respectively. Table 3 shows the effect of carryover when bleaching with an extraction stage that employs no oxygen or peroxide. Tables 4 and 5 illustrate the effects of effluent carryover in sequences incorporating(EP) and(PO)stages, respectively. Effluent Color Figures 1 and 2 illustrate the effects of reinforcing the extraction stage on the color of the bleaching stage effluents when the pulps were thoroughly washed after each stage. Figure 1 shows that,in the softwood case, under conditions of perfect interstage washing, adding peroxide to an(EO)stage to convert it to an (EPO) stage resulted in almost no decrease in total color,measured as the sum of the three individual effluent color values. Increasing the temperature, oxygen pressure and peroxide charge,i.e. converting the (EO) stage to a(PO)stage, decreased the total color from 4299 units to 3836 units (an I I%reduction). In both the(EPO)and(PO) cases, the attendant decreases in Do kappa factor(C102 charge) caused slight increases in the color of the Do effluent. In the hardwood case with perfect interstage washing there were somewhat greater effects of reinforcing the extraction stage, as Figure 2 shows. Adding peroxide decreased the total color(again measured as the sum of the individual stage effluent color values) from 1282 to 742 units (a 42%reduction). Increasing the temperature, oxygen pressure and peroxide charge, i.e. converting the(EO) stage to a(PO) stage, further decreased the total color to 635 units (a 50%reduction relative to the value obtained when the extraction stage employed neither oxygen nor peroxide). 3 Table 1.Results of Bleaching Softwood Pulps Type of Extraction Stage (EO) (EPO) (PO) Unbleached kappa number 14.2 14.2 14.2 Viscosity, mPa-s 14.3 14.3 14.3 ISO Brightness, % 35.2 35.2 35.2 Do Stage: 150°F,40 min., 10%a cons. C102,% 1.29 1.08 1.08 H2SO4, % 0.35 0.49 0.49 Final pH 2.8 2.9 2.9 Residual g/L as C12 0 0 0 ISO Brightness, % 51.9 49.0 49.0 Filtrate color,C.U. 1850 2125 2125 Extraction Stage: 60 min., 10% cons. NaOH, % 1.1 1.1 1.4 Temperature, °F 175 175 200 OZ Pressure(0/10/15160 min.), psig (35/0/0/0) (35/0/0/0) (100/100/0/0) H202, % 0 0.5 0.6 Final pH 11.0 11.0 11.1 Kappa Number 3.2 3.2 2.8 Viscosity, mPa-s 13.8 12.9 12.3 ISO Brightness, % 58.2 64.3 67.5 Filtrate color, C.U. 2390 2045 1640 D, Stage: 165°F,.240 min., 10% cons. C102, % 1.0 1.2 1.4 1.0 1.2 1.4 0.8 1.0 1.2 NaOH,% 0.45 0.54 0.6 0.45 0.54 0.6 0.3 0.4 0.5 Final pH 4.2 4.1 3.6 4.4 3.8 4.0 3.9 4.0 4.0 Residual C102, g/L 0 0.003 0.004 0 0 0 0 0 0 Total Sequence C102,% 2.29 2.49 2.69 2.08 2.28 2.48 1.88 2.08 2.28 Viscosity, mPa-s -- -- 11.2 -- -- 10.8 -- -- 10.7 ISO Brightness, % 84.6 85.1 86.1 84.8 85.6 86.2 84.5 85.6 86.4 Filtrate color, C.U. -- -- 59 -- -- 58 -- -- 71 4 Table 2. Results of Bleaching Hardwood Pulps: Series 1 (No Stage-to-Stage Carryover) Type of Extraction Stage E (EP) (PO) Unbleached kappa number 6.8 6.8 6.8 Viscosity, mPa-s 13.8 13.8 13.8 ISO Brightness, % 44.1 44.1 44.1 Do Stage: 150°F,40 min., 10% cons. C102,% 0.67 0.54 0.54 H2SO4, % 0.7 0.7 0.7 Final pH 2.5 2.7 2.7 Residual g/L as C12 0 0 0 ISO Brightness, % 67.4 65.0 64.7 Filtrate color,C.U. 685 345 373 Extraction Stage: 60 min., 10% cons. NaOH, % 0.9 1.0 1.3 Temperature,OF 175 175 200 02 Pressure(0/10/15/60 min.), psig (0/0/0/0) (0/0/0/0) (100/100/0/0) H2O2, % 0 0.3 0.5 Final pH 11.0 11.1 11.3 Kappa Number 2.7 2.7 2.7 Viscosity, mPa-s 13.1 12.0 11.6 ISO Brightness, % 68.4 74.8 79.4 Filtrate color, C.U. 570 365 210 D, Stage: 165°F,240 min., 10% cons. C102, % 1.0 1.2 1.4 0.6 0.8 0.2 0.4 0.6 NaOH/H2SO4A 0.40/0 0.48/0 0.56/0 0.04/0 0.24/0 0/0.09 0/0.01 0.0510 Final pH -- -- -- 4.4 3.8 4.2 4.0 3.4 Residual C102,g/L 0.003 0.010 0.006 0 0 0 0 0 Total Sequence C102,% 1.67 1.87 2.07 1.14 1.34 0.74 0.94 1.14 Viscosity, mPa-s -- 10.7 -- -- 10.8 -- 11.3 -- ISO Brightness, % 85.5 86.1 86.7 85.7 86.3 84.5 85.6 86.4 Filtrate color,C.U. -- 27 -- -- 32 -- 52 -- 5 Table 3.Series 2 Results: Effect of Carryover on Hardwood E-Stage Bleach Sequence Type of Extraction Stage E Unbleached kappa number 7.0 Viscosity, mPa•s 12.7 ISO Brightness, % 43.8 Do Stage: 150°F,40 min., 10% cons. Mill O-Stage Carryover, kg/BDMT 0 12.5 C1O2,% 0.75 0.75 Kappa Factor 0.28 0.28 H2SO4, % 0.69 1.5 Final pH 2.5 2.7 Residual g/L as C12 0 0 ISO Brightness, % 69.0 61.6 Filtrate color, C.U. 385 1140 E Stage: 175°F, 60 min., 10% cons. Mill E Stage Carryover, kg/BDMT 0 5.0 NaOH, % 0.8 0.5 Temperature,OF 175 175 OZ Pressure(0/10/15/60 min.),psig (0/0/0/0) (0/0/0/0) H202, % 0 0 Final pH 11.0 10.8 Kappa Number 2.3 3.2 Viscosity, mPa•s 12.4 12.1 ISO Brightness, % 70.8 65.8 Filtrate color, C.U. 520 1390 D, Stage: 165°F, 160 min., 10% cons. C1O2, % 0.8 1.0 1.2 1.2 1.4 1.6 NaOH/H2SO4,% 0.25/0 0.38/0 0.45/0 0.45/0 0.52/0 0.59/0 Final pH 3.6 3.8 3.7 3.4 3.2 3.1 C1O2 Consumed, % 0.796 0.994 1.119 1.199 1.397 1.595 Total Sequence C102,% 1.55 1.75 1.95 1.95 2.15 2.35 Viscosity, mPa•s 11.5 - -- -- 10.2 -- ISO Brightness, % 86.4 86.7 86.7 85.6 86.0 86.3 Filtrate color,C.U. 16 -- -- -- 75 -- 6 Table 4.Series 2 Results: Effect of Carryover on Hardwood(EP)-Stage Bleach Sequence Type of Extraction Stage (EP) Unbleached kappa number 7.0 Viscosity, mPa•s 12.7 ISO Brightness, % 43.8 Do Stage: 150°F,40 min., 10% cons. C1O2,% 0.53 0.53 Kappa Factor 0.199 0.199 H2SO4, % 0.84 1.8 Final pH 2.6 2.6 Residual g/I.as C12 0 0 Mill O-Stage Carryover, kg/BDMT 0 12.5 ISO Brightness, % 63.8 56.7 Filtrate color, C.U. 290 1120 (EP)Stage: 175°F,60 min., 10% cons. NaOH, % 0.9 0.6 Mill E Carrover,kg/BDMT 0 5.0 Temperature, OF 175 175 02 Pressure(0/10/15/60 min.),psig (0/0/0/0) (0/0/0/0) H2O2, % 0.3 0.3 Final pH 11.1 10.4 Kappa Number 2.9 3.6 Viscosity, mPa•s 11.5 11.8 ISO Brightness, % 75.3 70.4 Filtrate color, C.U. 450 1370 D, Stage: 165°F, 160 min., 10% cons. C1O2, % 0.6 0.8 1.0 1.0 1.2 1.4 NaOH/H2SO4,% 0.20/0 0.24/0 0.38/0 0.35 0.42 0.52 Final pH 3.6 3.4 3.6 3.5 3.4 3.0 C1O2 Consumed, % 0.6 0.8 1.0 1.0 1.2 1.4 Total Sequence C1O2,% 1.13 1.33 1.53 1.53 1.73 1.93 Viscosity, mPa•s -- 10.9 -- -- -- 9.9 ISO Brightness, % 85.7 86.6 86.9 85.1 85.9 86.6 Filtrate color,C.U. -- 27 -- -- 74 7 Table 5.Series 2 Results:Effect of Carryover on Hardwood (PO)-Stage Bleach Sequence Type of Extraction Stage (PO) Unbleached kappa number 7.0 Viscosity, mPa•s 12.7 ISO Brightness, % 43.8 Do Stage: 150°F,40 min., 10% cons. C1O2,% 0.53 0.53 Kappa Factor 0.199 0.199 H2SO4, % 0.84 1.8 Final pH 2.6 2.6 Residual g/L as C12 0 0 Mill O-Stage Carryover, kg/BDMT 0 12.5 ISO-Brightness, % 63.8 56.7 Filtrate color,C.U. 290 1120 E Stage: 175°F,60 min., 10% cons. NaOH, % 1.0 0.9 Mill E Carrover, kg/BDMT 0 5.0 Temperature,T 200 200 02 Pressure(0/10/15/60 min.), prig (100/100/0/0) (100/100/0/0) H2O2, % 0.5 0.5 Final pH 10.8 10.4 Kappa Number 2.6 3.5 Viscosity, mPa•s 11.4 11.1 ISO Brightness, % 80.4 72.8 Filtrate color, C.U. 210 1580 D, Stage: 165°F, 160 min., 10% cons. C1O2, % 0.2 0.3 0.4 0.6 0.8 1.0 NaOH/H2SO4,% 0/0.23 010.15 0.007/0 0.08/0 0.22/0 0.34/0 Final pH 3.9 3.4 3.8 3.2 3.2 3.4 C1O2 Consumed, % 0.2 0.3 0.4 0.6 0.8 1.0 Total Sequence C1O4% 0.73 0.83 0.93 1.13 1.33 1.53 Viscosity, mPa•s - 11.3 - 10.2 ISO Brightness, % 84.8 86.1 87.1 85.1 85.8 86.3 Filtrate color,C.U. 31 - 119 8 6000 5000 4299 4228 4000 3836 D1 ■E 'c 3000 ■DO 0 0 U 2000 1000 0 (EO) (EPO) (PO) Figure 1. Effects of extraction stage reinforcement on softwood bleaching effluent color 1600 1400 1282 1200 y 1000 ❑D1 c ■E 2 800 742 L 0 ■DO 0 635 U 600 400 200 0 E (EP) (PO) Figure 1. Effects of extraction stage reinforcement on hardwood bleaching effluent color when bleaching with no stage-to-stage effluent carryover 9 The results shown in Figure 1 suggest that there is little to be gained by implementing the softwood pulp extraction stage modifications studied here. On the other hand, Figure 2 shows that adding peroxide to the hardwood pulp extraction stage appeared to have the potential to substantially decrease the color of the hardwood pulp bleaching effluent. The results of the Series 2 study, shown in Figure 3,indicate similar color reduction potential for clean pulp(without carryover). On the other hand, the Series 2 experiments designed to simulate realistic levels of washer carryover and recycle showed an overall color increase from that observed when clean pulp was bleached, and showed no beneficial effect of the studied extraction stage modifications. 3500 3000 2500 �DII ■E E■DO c 2000 `o 1500 1000 soo 0 E Without (EP) (PO) E With (EP)With (PO)With Carryover Without Without Carryover Carryover Carryover Carryover Carryover Figure 3. Effects of extraction stage reinforcement on total hardwood bleaching effluent color when bleaching with and without stage-to-stage effluent carryover Chemical Consumption Figure 4 illustrates the favorable effect of reinforcing the extraction stage on total C102 consumption when bleaching softwood pulp with no stage-to-stage effluent carryover. At a final brightness level of 86.0,and under the conditions of these experiments, adding 10 lb of peroxide per ton of pulp to the(EO) stage may be expected to result in a reduction in total C102 consumption of 5.6 lh/ton(0.28% on pulp). Further intensifying the extraction stage by increasing the peroxide charge to 12 lb/ton, increasing the temperature and pressurizing with oxygen may be expected to result in a further reduction of 4.4 lb/ton (0.22% on pulp). In this case the total reduction in C102 consumption would therefore be 10 lb/ton(0.5% on pulp)relative to the(EO)case, where peroxide was not used. 10 87.0 •(Eo) 86.$ •tEPo) ■(PO) 1 I N I d I C t 85.5 I I 1 I m 85.0 I I I I I I I I I • I 84.5 1 1 I I 84.0 1.6 1.8 2.0 2.2 2.4 2.6 2.8 Total C102(DO+D1),% Figure 4.Final brightness vs. total C102 consumption; softwood pulp; no stage-to-stage effluent carryover Figure 5 shows the corresponding effects for the hardwood pulp with perfect interstage washing, as determined in the first series of hardwood bleaching experiments.Under the conditions employed, adding 6 lb of peroxide per ton of pulp to the extraction stage resulted in a reduction in total C102 consumption of 12 lb/ton of pulp (0.6% on pulp). Adding high-pressure oxygen and increasing the peroxide charge to 10 lb/ton while also increasing the temperature resulted in a further reduction of 4 lb/ton(0.2% on pulp). In this case the total reduction in C102 consumption would therefore be 16 lb/ton(0.8% on pulp)relative to the case where neither oxygen nor peroxide was used. The kappa factor used in the experiments of Figure 5 was 0.26, which turned out not to be optimal.A second series of hardwood bleaching experiments was done to assess the effects of effluent carryover. In these experiments the kappa factor was adjusted upwards to 0.28, with the result that the baseline(no carryover) experiments resulted in lower total C102 consumption figures than in the first series. The data are shown in Figure 6. Without carryover, adding 6 lb of peroxide per ton of pulp to the extraction stage reduced the total C102 requirement from 1.4 % on pulp to 1.2%,a reduction of 0.2% on pulp or 4 lb/ton. Adding high-pressure oxygen and increasing the peroxide charge to 10 lb/ton while also increasing the temperature resulted in a further reduction of 8 lb/ton(0.4% on pulp). The experiments in which washer carryover and recycle were used provide a more realistic assessment of the expected savings in C102. As shown in Figure 7, adding 6 lb of peroxide per ton of pulp to the extraction stage reduced the total C102 requirement from 2.2 % on pulp to 1.8%,a reduction of 0.4% on pulp or 8 lb/ton. Adding high-pressure oxygen and increasing the peroxide charge to 10 lb/ton while also increasing the temperature resulted in a further reduction of 8 lb/ton (0.4%on pulp). Comparison of Figures 6 and 7 shows that inclusion of filtrate carryover and recycle increased C102 consumption by 0:8% when the extraction stage was an E stage and by 0.6% when the extraction was an (EP)or(PO) stage. 11 87.0 86.5 86.0 ----------------' --- ---------- ---------- N 01 � C � t 85.5 rn , +E i 85.0 ; •(EP) 84.5 i i i , 84.0 0.4 0.6 0.8 1.0 1.2 1.4 1.6 1.8 2.0 2.2 2.4 Total C102(Do+D,),% Figure 5.Final brightness vs. total 002 consumption; hardwood pulp..Series 1: no stage-to- stage effluent carryover; kappa factor 0.26 for E, 0.21 for(EP) and(PO). 88.0 87.5 No Carryover 87.0 m 86.5 a c t86.0 ----------- 7--------- ----- ------------------------ m 01 85.5 ' ♦E,KF=0.28 85.0 84.5 i 84.0 0.4 0.6 0.8 1.0 1.2 1.4 1.6 1.8 2.0 2.2 Total C102(Do+D,),% Figure 6.Final brightness vs. total C102 consumption: hardwood pulp.Series 2: no stage-to- stage effluent carryover 12 87.0 With Carryover 86.5 h86.0 ----------- --------- ---------- ------------------ w c t rn m 85.5 +E,KF=020 i i ♦(EPA KF-020 85.0 •(PO),KF-020 84.5 1.0 1.2 1.4 1.6 1.8 2.0 2.2 2.4 2.6 2.8 Total CI02(Do+DI), Figure 7.Final brightness vs. total C102 consumption: hardwood pulp.Series 2: stage-to- stage effluent carryover included Physical Properties of Bleached Pulps Softwood Pulps Inspection of the results in Table 6 shows that the studied extraction stage modifications had, with one possible exception, virtually no effect on the physical properties of bleached softwood pulp.Figure 8 demonstrates the lack of any effects on the relationship between handsheet density and tensile strength and Figure 9 shows that the all three extraction types gave pulps with the same tear-tensile characteristic. The possible exception is an effect on elongation and its associated effect on tensile energy absorption, as shown in Figures 10 and 11. Table 6.Physical Properties of Bleached Softwood Pulps Density Tensile Burst T. Tensile Pulp BJ PH CSF Index Index Index T.B.A. (j/m Elongffioo2) SURness lnd (0 revs x 10°). (ML) (8)um) (N,m/g) (kP..21g) (mN.m'/g) (mm) (kNMg) (EO) 0.0 691 0.568 36.64 2.40 22.11 58.16 3.17 3565 05 660 0.641 60.34 425 12.96 89A9 3.23 473.6 2.5 520 0.704 81.19 5.30 9.69 108.98 3.00 576.5 5.0 350 0.719 86.49 5.83 8.26 11857 3.22 568.7 75 235 0.741 88.63 6.16 8.31 12955 3.37 587.9 (EPO) 0.0 678 0.549 34.93 2.33 20.95 49.45 2.90 344.1 0.5 632 0.637 64.61 4.38 12.07 114.04 3.77 493.9 2.5 408 0.719 83.65 5.70 8.44 13323 3.62 558.1 5.0 172 0.758 88.41 5.94 755 133.06 3.49 5795 75 88 0.787 93.91 6.32 7.14 14025 3.50 589.7 (Po) 0.0 696 0.539 33.44 2.22 23.08 44.76 2.73 3325 OS 652 0.633 62.12 4.07 13.11 95.83 3.43 463A 25 461 0.709 79.90 539 8.80 120.16 3.40 543.9 5.0 201 0.763 8856 5.91 7.58 130.04 3.39 576.0 -- 75 91 0.781 96.06 6.23 7.31 148.79 3.56 614.6 13 120 100 •(EO) •(EPO) E 80 ■(PO) i u j � 60 u N u 40 F 20 0 D.45 0.50 0.55 0.60 0.65 0.70 0.75 0.80 0.85 Density,glcm3 Figure 8.Softwood pulp tensile index vs.sheet density 30 25 •(EO) 20 • •(EPO) ■(PO) Z E d 15 v c v 10 • F ' 5 0 20 40 60 80 100 120 Tensile Index,N.mlg Figure 9.Softwood pulp tearing resistance vs. tensile index 14 r 4.00 3.80 3.60 E 3.40 E 3.20 c m 3.00 rn c 2.80 �(EO) w 2.60 ♦(EPO) 2.40 ■ PO 2.20 2.00 0 20 40 60 80 100 120 Tensile Index,.N.mlg Figure 10.Softwood pulp Elongation vs.Tensile Index 180 (� 160 140 120 E E 100 of 80 F 60 •IEC ♦(EPO) 40 0 IPo) 20 0 0 20 40 60 80 100 120 Tensile Index,N.mlg . Figure 11.Softwood pulp tensile energy absorption vs.tensile index Hardwood Pulps Series 1 (No carryover, Kappa Factor 0.26): The results in Table 7 indicate that when bleaching with no stage-to-stage effluent carryover and with a Da kappa factor of 0.26,the studied extraction stage modifications had virtually no effect on the physical properties of bleached hardwood pulp, with one ` exception. Figure 12 demonstrates the lack of any effects on the relationship between handsheet density 15 and tensile strength.The exception to the above statement is illustrated by Figure 13, which suggests that intensification of the extraction stage increases the maximum tearing resistance that can be achieved by refining and also increases the tensile strength at which the maximum tearing resistance is achieved. Table 7.Physical Properties of Bleached Hardwood Pulps. (Series 1 Experiments;No Carryover) Tensile Tensile Burst Tear PF7 T.E.A. Elonga-[ion Stiffness Pulp ID (#revs x CSF Density Index Index Index 0/m2) (nun) Index 10.3) (ML) (g/em) (N.m/g) (kPa-ml/g) (mN•m'/g) (kNn✓g) E 0.0 557 0.535 29.37 1.34 9.06 26.68 1.90 335.7 0.5 528 0.602 48.94 2.53 9.31 61.65 2.69 435.3 1.0 483 0.641 60.40 3.35 8.44 82.13 3.02 470.0 2.0 356 0.690 69.36 4.25 8.00 105.58 3.43 495.4 3.0 246 1 0.730 1 76.39 4.71 7.20 119.32 3.54 519.1 (EP) 0.0 556 0.526 30.64 1.39 854 25.90 1.79 341.7 0.5 536 0.606 51.95 2.60 9.40 66.86 2.76 445.5 1.0 484 0.654 61.04 3.31 9.18 82.53 2.97 478.8 2.0 377 0.694 71.15 4.08 8.69 110.91 3.40 522A 3.0 260 0.735 72.30 4A5 8.05 111.83 3.42 509.0 (PO) 0.0 593 0.526 29.30 1.24 1 8.12 27.57 1.93 341.7 0.5 554 0.602 49.52 2.45 957 63.72 2.76 445.5 1.0 515 0.641 59.43 3.13 9.78 79.92 2.97 478.8 2.0 384 0.694 72.03 4.24 8.91 110.08 3.38 522.4 3.0 269 0.730 76.72 1 4.62 1 8.11 1 117.641 3.47 509.0 90 80 •E ♦(EP) ■(Po) rn 70 • E z x 60 � m v c ♦ d 50 N C d ~ 40 30 �• 20 0.45 0.50 0.55 0.60 0.65 0.70 0.75 0.80 Density,glcc Figure 12. Hardwood pulp tensile index vs.sheet density.Series 1,no carryover. 16 10 ■ 10 ' 9 a j s E >Z 8 kA m v r 8 •E F •(EP) 7 '(PO) 7 6 20 30 40 60 60 70 80 90 Tensile Index,N.m/g Figure 13. Hardwood pulp tearing resistance vs.tensile index.Series 1,no carryover. t Series 2(Kappa Factor 0.28):The Series 2 bleaching experiments with no carryover gave bleached pulps having the properties shown in Table 8.The corresponding data for the Series 2 experiments with carryover added are shown in Table 9. Table 8.Properties of Bleached Hardwood Pulps. (Series 2 Experiments; KF 0.28,No Carryover) Tensile Burst Tear Tensile PFI T.E.A. Elonga-lio Stiffness Pulp ID (N revs xCSF Density Index Index Index (1/m2) (mm) Index 10.1) (mL)L) (g/em3) (t`1 Mg) (kPa•m'/B) (mN•m'/g) (kNm/g) E 0.0 544 0.535 28.23 1.25 8.39 20.45 1.55 342.2 0.5 504 0.610 45.77 2.24 9.20 51.26 2.36 448.5 1.0 447 0.641 52.70 2.80 9.14 62.00 2.47 499.0 2.0 373 0.694 63.39 3.42 9.01 87.79 2.99 520.9 3.0 273 0.719 70.15 3.78 8.63 101.87 3.19 539.3 (EP) 0.0 539 0.529 27.31 1.22 8.92 21.61 1.64 354.4 0.5 507 0.606 45.18 2.29 9.07 50.95 2.41 441.6 1.0 456 0.641 55.48 2.81 9.08 69.34 2.68 495.3 2.0 352 0.694 66.91 3.41 8.67 94.34 3.12 520.1 3.0 251 0.725 72.62 3.85 8.34 107.99 3.26 539.2 (Po) 0.0 537 0.546 29.45 1.23 7.97 23.57 1.68 350.9 0.5 507 0.610 46.61 2.26 9.86 51.39 2.37 443.9 1.0 455 0.649 56.36 2.89 9.57 76.78 2.91 486.0 2.0 357 0.699 66.20 3.65 8.69 94.67 3.19 507.3 3.0 255 0.735 69.44 4.01 8.03 106.80 3.35 1 525.3 17 Table 9.Properties of Bleached Hardwood Pulps. (Series 2 Experiments; KF 0.28,With Carryover) Tensile Tensile Burst Tear PFI T.E.A. Elonga-tion Stiffness Pulp ID (p revs x CSF Density Index Index Index O/m2) (nun) Index 10.1) (mL) (g/cm) (N•-1g) (kPa•tn/g) (mN-m/g) (kNnYg) E 0.0 534 0.559 31.52 1.42 9.11 23.37 1.59 369.7 0.5 476 0.625 49.66 2.60 9.45 56.88 2.44 466.6 1.0 448 0.658 58.27 3.20 8.41 72.09 2.71 492.2 2.0 331 0.694 69.72 3.82 8.27 96.96 3.07 541.9 3.0 234 0.746 74.46 4.19 7.89 106.30 3.11 563.9 (EP) 0.0 543 0.549 30.33 1.36 8.84 25.37 1.76 357.4 0.5 489 0.613 49.71 2.53 9.11 56.28 2.46 457.1 1.0 437 0.654 58.48 3.19 8.85 71.65 2.68 495.9 2.0 321 0.699 71.43 3.95 8.56 104.48 3.27 523.4 3.0 225 0.735 80.33 4.36 7.98 125.13 3.49 551.4 (Po) 0.0 537 0.441 22.91 0.94 7.57 13.70 1.28 299.4 0.5 505 0.585 46.19 2.32 8.51 47.69 2.25 434.8 1.0 448 0.654 60.15 3.23 9.17 74.43 2.73 502.1 2.0 340 0.704 69.78 4.00 8.44 93.19 3.05 518.2 3.0 226 0.741 75.29 4.40 8.01 112.45 3.27 555.8 Examination of the Series 2 physical properties data revealed no significant effects of extraction stage type, kappa factor or carryover.The Series 2 data did not confirm the existence of the extraction type effect on tear that was observed at the lower kappa factor(Series 1, Figurel3). Summary and Conclusions Mill oxygen-delignified softwood and hardwood pulps were subjected to laboratory bleaching trials to evaluate the effects of potential changes to the conditions of the alkali extraction stage. Two series of experiments were done. In the first, the pulps were thoroughly washed before bleaching and after each bleaching stage, and the first-stage kappa factor was 0.26. In the second series, hardwood pulp was bleached with a first-stage kappa factor of 0.28, which more accurately reflects mill practice, and the experiments simulated the washer carryover and recycle that characterize actual mill operation.This was accomplished by adding appropriate amounts of filtrate carryover and recycle: mill post oxygen stage effluent was added to the first bleaching stage and mill E effluent to the extraction stage. These additions reflected what happens during actual mill operation. In the case of the softwood pulp trials, existing(EO) stage conditions were compared with conditions chosen to simulate(EPO) and(PO) stages.The(EPO) stage was simulated by adding 0.5% hydrogen peroxide. The(PO) stage(sometimes referred to as a pressurized peroxide or PHT stage) was simulated by increasing the temperature, oxygen pressure and peroxide charge. In the case of the hardwood pulp trials, E stage conditions were compared with conditions chosen to simulate(EP)and(PO) stages. The(EP) stage was simulated by adding 0.3%peroxide. The PO stage was simulated by increasing the peroxide charge,pressurizing with oxygen and raising the temperature. In both cases the chlorine dioxide charge in the D0 stage was decreased and the chlorine dioxide charge in the DI stage was adjusted to reach the desired target brightness. Effects on the color of all bleaching stage effluents were monitored.Effects on bleaching chemical consumption and bleached pulp physical properties were also measured. In the softwood case(without effluent carryover or recycled filtrate), adding peroxide to an(EO) stage to convert it to an(EPO) stage resulted in almost no decrease in total color, measured as the sum of the three 18 individual effluent color values. Increasing the temperature, oxygen pressure and peroxide charge,i.e. converting the(EO)stage to a(PO) stage, decreased the total color from 4299 units to 3836 units (an I I% reduction). In both the(EPO) and(PO)cases, the attendant decreases in Do kappa factor (CIOZ charge) caused a slight increase in the color of the Do effluent. When the hardwood pulp was bleached with no washer carryover or recycle, there were somewhat greater effects on effluent color than in the softwood case. Adding peroxide decreased the total color(again measured as the sum of the individual stage effluent color values) from 1282 to 742 units (a 42% reduction). Converting the(EO) stage to a(PO)stage further decreased the total color to 635 units (a 50% reduction relative to the value obtained when the extraction stage employed neither oxygen nor peroxide). In sharp contrast to these beneficial effects on hardwood effluent color was the corresponding absence of any beneficial effect on color when mill operation was more closely simulated by incorporating washer filtrate carryover and recycle in the Do and extraction stages respectively. In the presence of carryover and recycle, the color was higher than in its absence. In experiments in which post-oxygen washing carryover and E-stage filtrate recycle were not simulated, reinforcing the extraction stages decreased total chlorine dioxide consumption by as much as 10 lb/ton (0.5% on pulp)in the case of softwood pulp and by as much as 16 lb/ton(0.8%on pulp)in the case of the hardwood pulp. When bleaching hardwood pulp, inclusion of filtrate carryover and recycle increased extracted kappa numbers, resulting in increased C102 consumption.CIOZ consumption increased by 0.8% when the extraction stage was an E stage and by 0.6% when the extraction was an(EP)or(PO)stage. In the presence of filtrate carryover and recycle, converting the E stage to an(EP)stage decreased total chlorine dioxide consumption by 8 lb/ton (0.4%on pulp) and converting the E stage to a(PO) stage decreased total chlorine dioxide consumption'by 16 lb/ton(0.80% on pulp). With a few exceptions, effects on the physical properties of both pulp types were generally small or nonexistent.The exceptions were increases in elongation and tensile energy absorption of the softwood pulps and a possibility increases in maximum tearing resistance strength and in the tensile strength at which the maximum tearing resistance is achieved.The latter increases were observed only in the absence of effluent carryover. In general, the results suggest that there is little or no environmental benefit to be gained by implementing the extraction stage modifications studied here. Reinforcing the softwood extraction stage produced only a small improvement in effluent color. Adding peroxide to the hardwood extraction stage in the presence of washer filtrate carryover and recycle has no significant beneficial effect on effluent color, despite indications of a beneficial effect in the absence of carryover and recycled filtrate. Report: No.2011-054, Pruyn's Island Technical Center, Andritz Inc. (August 3,2011). 19 Appendix C April 24,2012 Partial Settlement Agreement of Contested Cases concerning the May 2010 NPDES Permit State of North Carorina (Department oflustice ROY COOPER 42 North French Broad Avenue Western Office Attorney General -Asheville,NC 28801 Phone: (828)251-6083 Fax: (828)251-6338 24 April 2012 Ms. Kim Hausen By electronic transmission and first-class mail Chief Hearings Clerk oah.clerksna, ncmail.net. Office of Administrative Hearings 6714 Mail Service Center Raleigh,North Carolina 27699-6714 RE: Cooke County TN v.DENR, DWQ,and Blue Ridge Paper Products, Inc. OAH File No 10 ERR 4341 Cooke County TN v. EMC,NPDES Committee and Blue Ridge Paper Products,Inc. OAH File No. 10 EHR 4982 r l (Consolidated for hearing) i, Dear Ms.Hausen: I have enclosed the original and two copies of a document for filing in the above-referenced contested case. Please return a file-stamped copy to me in the enclosed self-addressed envelope. Thank you for your help in this matter. Sincerely, Sueanna P. Sumpter Assistant Attorney General /SPS Enclosures xc: The Honorable J. Randall May(via e-mail:be9y.owens(a)oah.nc.gov) Following via e-mail and first-class mail: Julia F.Youngman, Esq. Amelia Y. Burnette, Esq. Austin D. Gerken, Jr.,Esq. Becky Jaffe, Esq. William Clarke, Esq. Dick Krieg, Esq. STATE OF NORTH CAROLINA IN THE OFFICE OF COUNTY OF HAYWOOD ADMINISTRATIVE HEARINGS Cocke County, Tennessee, et al., ) Petitioners, ) V. ) North Carolina Department of Environment ) and Natural Resources—Division of Water ) Quality, ) Respondent, ) 10 EHR 4341 and ) Blue Ridge Paper Products Inc. ) Respondent-Intervenor. ) STATE OF NORTH CAROLINA IN THE OFFICE OF COUNTY OF WAKE ADMINISTRATIVE HEARINGS Cocke County,Tennessee, et-al., ) Petitioners, ) V. ) Environmental Management Commission ) acting by and through its NPDES Committee, ) and the NPDES Committee, ) 10 EHR 4982 Respondents, ) and ) Blue Ridge Paper Products Inc., ) Respondent-Intervenor. ) Partial Settlement Agreement and Joint Stipulation to Stay Respondents North Carolina Division of Water Quality (the"Division'),North Carolina Environmental Management Commission acting by and through its NPDES Committee, and the NPDES Committee (the "NPDES Committee"), and Petitioners Cocke County,Tennessee, Clean Water Expected for East Tennessee, Clean Water for North Carolina, the Tennessee Chapter of the Sierra Club, Tennessee Scenic Rivers Association, and the Western North Carolina Alliance (collectively, the"Petitioners"), and Respondent-Intervenor Blue Ridge Paper Products, Inc., hereby enter into this Partial Settlement Agreement pursuant to N.C. Gen. Stat. § 150B-31(b). This matter arose out of the Petitioners' filing of a Petition for Contested Case Hearing (10 EHR 4341)on July 23, 2010, challenging the Division's issuance of NPDES Permit No. NC0000272(the "Permit") to Respondent-Intervenor. The issues raised by Petitioners in.their contested case against the Division relate to the Permit limits on Blue Ridge Paper's discharge into the Pigeon River. Petitioners filed a second Petition for Contested Case Hearing (10 EHR 4982) against the NPDES Committee on August 13, 2010, challenging its decision to grant a variance to Respondent-Intervenor from North Carolina's water quality standard for color. Without any contested case hearing, and without any admissions of liability, the Division, the NPDES Committee, Petitioners, and Respondent-Intervenor have reached the following Partial Settlement Agreement: A. Temperature: 1. Subject to Environmental Protection Agency ("EPA") approval, DWQ will modify the Permit so that the first sentence of Condition A. (I.) footnote 11 of the Permit reads as follows: "1 I. The weekly average instream temperature measured at a point 0.4 miles downstream of the discharge location shall not exceed 32°C during the months of July, August, and September and shall not exceed 29°C during the months October through June." 2. Respondent-Intervenor will prepare an updated Balanced Indigenous Population study ("BIP study") of the Pigeon River in accordance with the requirements of Section 316(a) of the Clean Water Act. The BIP Study will, among other study requirements: (1) survey mussels/shellfish as targeted species in the mainstem of the Pigeon River; (2) include detailed studies of macro-invertebrates and shellfish; (3) conduct thermal sampling at 20 locations in the Pigeon River and 2 locations in a reference river; and (4) intensively survey for fish, macroinvertebrates/shellfish, and periphyton in accordance with standardized sampling protocols, and in some cases, sampling protocols developed in coordination with EPA and DWQ. Surveying will be done at 20 Pigeon River locations and 2 locations in a reference river. 3. Respondent-Intervenor will use its best efforts to submit a final BIP study report to the Division and to the EPA for review before January 1,2014, unless river conditions in 2012 do not allow safe access for field sampling. Respondent- Intervenor will serve the completed study report on counsel for Petitioners at the same time it submits the final study to the Division and EPA for review. Respondent- , � 2 Intervenor will notify counsel for Petitioners if delays in data collection planned for 2012 and early 2013 render submission of the study by January 1,2014 not feasible. 4. Respondent-Intervenor has submitted a proposed 316(a) study plan to the Division and to EPA and provided a copy to counsel for Petitioners. 5. In reliance on these commitments, Petitioners agree to voluntarily dismiss (in accordance with section D, below) their claims relating to the current temperature limits in the Permit. B. Color 1. Respondent-Intervenor will, in accordance with the requirements of the 2010 Color Variance, fund a site-specific study of color in the Pigeon River in North Carolina. The study protocol shall be approved by DWQ and will generally be as outlined in EPA's letter of February 22, 2010 to DWQ. Respondent-Intervenor has submitted a draft protocol for such a study to the Respondents and to the EPA for comment. Respondent-Intervenor will exercise best efforts to complete the study and submit a report to Respondents before January 1, 2013. Respondent-Intervenor will serve a copy of the final study protocol and -completed report on counsel for Petitioners at the same time it submits the report to Respondents. 2. Because the color perception study currently being developed by Respondent- Intervenor may have bearing on the positions of the parties in these consolidated contested cases, the parties jointly agree and stipulate to a stay of the hearing in these consolidated. contested cases until January 30, 2013. The parties jointly agree and stipulate to submit a joint status report to OAH on or before January 30, 2013, reporting on the status of the color perception study, whether a continued stay of this matter is required to allow Respondents and the EPA to review the study, and the appropriate scheduling of a hearing to resolve these contested cases, if necessary. C. Within three days of execution of this Partial Settlement Agreement, Respondents shall submit a draft revised NPDES permit reflecting the terms of this agreement to the EPA for approval of its terms. The parties understand and stipulate that approval of the draft revised permit does not bind EPA or any party to approval of any of the future studies, or plans or protocols for future studies contemplated by this agreement. Furthermore, the parties understand and stipulate that, by entering into this Agreement, no party is bound I 3 to approve any of the future studies, or plans or protocols for future studies contemplated by this agreement. D. Within ten days of being notified that EPA has approved a draft revised NPDES permit reflecting the terms of Partial Settlement Agreement, Petitioners shall file a Notice of Settlement and Partial Dismissal with the Office of Administrative Hearings("OAH") for dismissal of only their temperature claims against the Permit in their Contested Case, Cocke County,Tennessee et al. v.NC DENR,Division of Water Quality, 10 EHR 4341, with prejudice,with each party to bear its own costs and attorney's fees. E. If the draft revised NPDES permit is disapproved by EPA such that any provision of this agreement cannot be implemented, the agreement shall be rendered void and the parties agree to negotiate in good faith to revise this agreement. F. The Parties agree to cooperate fully in executing any and all supplementary documents and in taking all additional actions that may be necessary to give full force and effect to the terms of this Partial Settlement Agreement. G. It is understood and agreed that this Partial Settlement Agreement is not to be construed as an admission by any party to this agreement and that this agreement is a compromise of disputed claims. H. This Partial Settlement Agreement may not be modified, altered or changed except in a written document that is signed by all Parties and that makes specific reference to this Partial Settlement Agreement. I. The Parties represent that any necessary corporate and governmental formalities have been complied with for purposes of signing and entering into this Partial Settlement Agreement. The persons executing this agreement represent and warrant that they have full authority to sign this agreement on behalf of the Parties for which they are acting. J. This Partial Settlement Agreement shall be binding upon the Parties, their successors and assigns. 4 This the��A.— ofj, 2012. Austin D. Gerken Jr.,N.C. State Bar No. 32689 Amelia Y. Bumette,N.C. State Bar No. 33845 Rebecca Jaffe, N.C. State Bar No. 40726- - Southem Environmental Law Center 22 S. Pack Square, Suite 700 Asheville, NC 28801 828-258-2023 Julia F. Youngman,N.C. State Bar No. 21320 Southern Environmental Law Center 601 W. Rosemary Street, Suite 220 Chapel Hill, NC 27516 919-967-1450 On behalf ofCocke County, Tennessee, Clean Water Expected for East Tennessee, Clean Water for North Carolina, the Tennessee Chapter of the Sierra Club, Tennessee Scenic Rivers Association, and the Western North Carolina Alliance Sueanna Sumpter, Esq. Assistant Attorney General N.C. Department of Justice 42 N. French Broad Ave. Asheville, NC 28801 828-251-6083 on behalf of North Carolina Division of Water Quality #arcasse, Esq. eputy Attorney General North Carolina Department of Justice P.O. Box 629 Raleigh,NC 27602 919-716-6962 On behaljoJNorth Carolina Environmental Management Commission acting by and through its NPDES Committee 5 William Clarke Roberts & Stevens,P.A. PO Box 7647 Asheville,NC 28802 828-252-6600 Richard W. Krieg, Esq. Lewis, King, Krieg& Waldrop, PC One Centre Square 620 Market Street, 5th Floor Knoxville,Tennessee 37902 865-546-4646 On behalf of Blue Ridge Paper Products, Inc. 6 r Appendix D April 2012 Color Perception Study Plan approved by NC D WQ on June 1,2012 Paul Dickens From: Belnick,Tom <tom.belnick@ncdenr.gov> Sent: Friday, June 01,2012 2:40 PM To: Paul Dickens Cc: Poupart,Jeff; Reid, Dianne; Chernikov, Sergei; Cranford, Chuck; Fritz Wegener Subject: BRPP/Color Perception Study Plan Blue Ridge Paper NPDES Permit NC0000272 Color Perception Study Plan Paul-by this email, DWQ is approving the proposed 2012 color perception study in the North Carolina portion of the Pigeon River. In their review of the study plan/revisions, EPA raised comments about ultimate data interpretation. DWQ concurs that the primary goal of this study is to establish an aesthetically acceptable color level in the Pigeon River based on unbiased observers. Given this goal, it is hopeful that a broad range of instream color levels are encountered over the study duration. After an acceptable color level is determined,the NPDES permit will be revisited to ensure consistency with study results. Since the color perception study will focus on a site-specific evaluation of our narrative color standard,Dianne Reid with our Water Quality Standards Unit will take the DWQ lead through the study process. Tom Belnick Supervisor,Complex NPDES Permitting Unit NC DENR/Division of Water Quality 1617 Mail Service Center, Raleigh, NC 27699-1617 (919)807-6390;fax (919)807-6495 E-mail correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation. T . 1 evergreen-la Canton Office packaging I TS Mo;n Sweet. Canton, NC 28716 17 April 2012 PSD 30-12 Tom Belnick CERTIFIED MAIL Supervisor, Complex NPDES Permitting Unit RETURN RECEIPT REQUESTED Division of Water Quality 7008 3230 0002 2591 1663 North Carolina Department of Environment and Natural Resources 1617 Mail Service Center Raleigh,North Carolina 27699-1617 Subject: Response to EPA Comments dated 28 March 2012 March 2012 Revised Color Perception Study NPDES Permit NC0000272 Blue Ridge Paper Products Inc. Canton Mill Dear Mr. Belnick— Attached is our response to EPA comments received by the DWQ on 28 March 2012 and forwarded to Blue Ridge Paper Products Inc. for evaluation. The EPA comments concern the revised Color Perception Study Plan submitted on 16 March 2012. Evergreen has consulted with Drs. Prestrude and Cherry about the comments. The response to comments is an addendum to the study plan and is the result of a collaborative effort between the company and Drs. Prestrude and Cherry. We understand EPA's interest in clarifying how the perception study data will be analyzed and used. Evergreen shares this interest. EPA also had specific questions about discrepancies in the study plan appendices, several of which were submitted as examples. Those discrepancies have been corrected in a revised version of the study plan enclosed with this letter. Please let us know if you have questions, or if you need additional information. Very truly yours, BLUE RIDGE PAPER PRODUCTS INC. DOING BUSINESS AS EVERGREEN PACKAGING Paul Dickens Nick McCracken Manager—Environmental Affairs Water Compliance Coordinator 828-646-6141 828-646-2874 ` naul.dickensAevemack.com nick.mccrackphjq Tpck.com /f Dang Easiness h Camcrnw.Evergreen Beverag= Tom Belnick, NC DWQ 17 Apr 2012 Page 2 Attachment: Response to EPA comments dated 28 March 2012 concerning the March 2012 Revision to the Color Perception Study Plan Enclosure: Proposal for Site Specific Study of Color in the Pigeon River—April 2012 cc(w/attachment & enclosure): DWQ ARO Color Team, Internal Distribution I evergreen. Office packaging 175 Main Street•Canton, NC 28716 Attachment Blue Ridge Paper Products Inc. dba Evergreen Packaging(BRPP) Response to EPA Comments dated 28 March 2012 concerning the March 2012 Revised Color Perception Study Plan 17 April 2012 Comments on Revised Color Perception Study dated 28 Mar 2012 received from EPA via DWQ were in two parts. EPA Comments- Part 1 of 2: EPA COMMENTS ON REVISED PIGEON RIVER COLOR PERCEPTION STUDY The EPA appreciates the revisions that were made to the original study plan based on our March 6 comments and the inclusion of more detail regarding how the study will be conducted. We do have the following comments based on the revised study plan. If the color study is conducted and used to support a future removal of the existing color variance, our goal is that the study be as credible and scientifically supportable as possible. I. EPA Comment- Dr. Cherry's response#I to EPA's previous comments alludes to a statistical analysis of observer ratings, but provides no details regarding that analysis. We request additional details regarding how observer ratings for the three days of observation will be analyzed and assessment of aesthetic quality will be conducted, especially in light of comments#4 and#5 below. We request this so there is up front agreement and less need to question the basis behind any study conclusions. Response Our response is in two parts — how data may be analyzed and presented and what specific perception data will be collected in the field. Data Analysis - Perception study data on the aesthetic aspects of the water will be organized by descriptive statistics into a group mean, range, and standard deviation of observation ratings for all categories and individual aspects for each observation site. Correlations between ratings and color will be determined for each site and across sites. The statistical evaluation of data including ANOVA, simple t-test and correlation will determine if there are significant differences and relationships between and among ratings at each site. r fresh by destgn. Doing Business in Cofbrnia as Evergreen 3everoge Packaging Response to EPA Comments, Page 2 Examples of how the perception study data on a specific observation day and on all observation days may be statistically evaluated and summarized are illustrated in the following table and graph. Other examples appear in the published color perception studies cited in the revised study plan. Example Statistical Comparisons for Color Perception Study(illustration only) RM RM RM RM RM RM RM RM 24.7 42.6 48.3 52.8 61.2 62.9 62.5 67.5 Perception Study Brown's HEPCO Ferguson Clyde Thickety Fiber- Canton Wells Rd Data Bridge Bridge Bridge Bridge 02 Ville Park Aesthetic Aspects • Scenic Beauty ANOVA,t-tests and correlations on individual aesthetic aspects at each • Color observation site and across all observation sites to test relationships and • Clarity trends. Purpose is to determine how individual aspects are related and • Wading how individual aspects affect overall aesthetic rating scores.Additional • Swimming purpose is to determine any statistical difference or similarity between • Fishing observation sites on each observation day and on all observation days. • Rafting, canoeing, boating River Quality Data ANOVA,t-tests and correlations of individual aesthetic aspects and overall rating scores against color and turbidity data across all observation sites. Apparent Color Purpose is to determine statistical differences between sites, relationships • True Color between color and turbidity,and if aesthetic ratings are statistically • Turbidity correlated with color and turbidity data. ANOVA,t-tests and correlations of individual aesthetic aspects, overall River Flow rating scores,and color and turbidity data against river flow and mill color discharge data across all observation sites. Purpose is to determine Canton Mill Color statistical differences between sites,relationships between color,turbidity, Discharge river flow and mill color discharge,and if aesthetic ratings are statistically correlated with river flow and mill color discharge. Environmental ANOVA on environmental attitude survey elements to compare to control Attitudes Survey group norms and then across rating scores to test for bias. Purpose is Elements validation of the erce tion studydata. Response to EPA Comments, Page 3 Example Presentation of Aesthetic Rating Data (illustration only) Range and Mean of Aesthetic Quality Rating by Pigeon River Mile on DATE 0o 7 -- c z 6 5 — - 7i CY 4 u m 3 t w 2 40 Q 1 26 9�p83 i 1 6f 6`'.9 9�OV 6 S EXAMPLE 4'se,. C°49^ �G�o e Pe"O not actual data Q'P 4 Perception Data — In its letter dated February 22, 2010 regarding the NPDES permit ultimately issued in May 2010 and effective June 1, 2010, the EPA suggested a study such as the Color Perception Study proposed by Evergreen Packaging to assess ambient color levels in the Pigeon River in North Carolina. The purpose of the Perception Study is to assess, in a quantitative fashion, the aesthetic component of the North Carolina narrative standard for color. The proposed study will obtain data on how independent observers perceive ambient color levels in the river, at different locations, in different seasons, under different flow conditions, and how these perceptions affect the observers' opinions about use of the water. Drs. Prestrude and Cherry designed the Color Perception Study to obtain data on seven (7) "aspects of the water" in three (3) general categories that put the evaluation of ambient color into context of appearance and appropriateness for use. These aspects are: Response to EPA Comments, Page 4 • Scenic beauty o Upstream and downstream • Appearance of the water o Color o Clarity • Activities o Wading o Swimming o Fishing o Rafting, canoeing, boating Scenic beauty is an important anchor to determine how the environmental setting may boost or take away from other ratings specific to appearance of the water and appropriateness for use. [See response to EPA comment 2]. 2. EPA Comment-The revised study plan and written instructions in Appendix G indicate that scenic beauty will be evaluated at each site, along with water color and water clarity. Our interpretation is that"scenic beauty" includes both the River and the land surrounding the River. Because"scenic beauty" includes a land component that is not a direct measure of the aesthetic quality of the Pigeon River and that land component is likely to be the factor that will be focused on the most(rather than the River color), how will observers' scenic beauty ratings be used vs. ratings for combined water clarity+ color? Without further clarification,we strongly recommend that"scenic beauty"not be assessed and that the revised study plan not include it. Response Because no observer can look at a river in a vacuum, the observer cannot help but notice the surrounding topography, vegetation and land use when approaching an observation site. Rating of scenic beauty is an important anchor and will be included in the data collected for the Perception Study. The data can be analyzed with scores for scenic beauty included or not included. A combined score, including scenic beauty, may or may not be more predictive than one without, but that cannot be determined if the observers do not rate sites for impression of scenic beauty. Observer comments recorded on field rating sheets are valuable in this determination. Response to EPA Comments, Page 5 3. EPA Comment-The revised study plan states that observer ratings will be collected after each site assessment. Because observers will view upstream reference"clean" sites last, if they then realize they want to change previous ratings for any downstream site, will they be allowed to do that? Response Observers will not be allowed to change ratings for any prior rated sites. It is standard practice to collect the completed ratings sheet upon conclusion of the observation at each site. It is also standard practice in rating scale procedures to instruct observers not to look at other observers' ratings or discuss their ratings. Similarly, raters are asked for their first response. Observers will be instructed not to use their mobile phones or other electronic devices for any purpose. The study procedure would not be valid if observers were allowed to change their ratings after seeing the mill or sites above the mill. The example Field Instructions to Observers and the Site Observation sheets in Appendices G & H have been revised and reformatted to comport with our response to EPA comments 1., 2 U. 4. EPA Comment-The environmental attitudes questionnaire/environmental response inventory in Appendix D was not a part of the original study plan. The majority of its questions do not directly assess one's environmental views (e.g., #62—"I would enjoy entertaining famous people"; 9106—"I like to ride on roller coasters";#113 - Birth control practices should be accepted by everyone.) It is difficult to understand the basis of further excluding observers based on the responses to this questionnaire. Because observers have already been screened regarding current or past affiliation with several environmental groups, it seems the inventory is being used to further exclude observer ratings that might be considered as "extreme." If available,we request additional details regarding the basis of the questions and how responses are judged to determine environmental attitudes that reflect a central tendency and the basis for excluding those outside one standard deviation from the mean from providing relevant observations during the survey. Response In discussion with Drs. Prestrude and Cherry, we understand that the Environmental Attitudes Questionnaire / Environmental Response Inventory is an important control to add credibility to the Color Perception Study. We defer to their expertise that this recognized standard environmental attitude tool and control should be part of the Color Perception Study of the Pigeon River. Dr. Prestrude provides more detail below to explain how the questionnaire is used. Response to EPA Comments, Page 6 Prestrude - Neither the Environmental Attitudes Questionnaire nor the vision tests are used to exclude observers. We have used these procedures in three other river color studies and have not excluded an observer yet. They are included as a set of controls. All observers' ratings will be included in the data set, but if an observer or observers do not match the norms, we can look at the data set with and without their ratings. Actually, by my count, at least 110 of the items in the ERI [Environmental Response Inventory] are clearly environmental. All of the items derive from an initial base of over 300 self-report statements. Over 3000 people responded to these items. These responses were analyzed by determining the correlation of each item with every other item. Then, by factor analysis, the items were grouped into "factors" or scales defined by significant inter-correlations among all the items that make up a scale. This process is described in the ERI manual. Even items that don't seem to refer to the environment can be valid because of their relationship to environmental attitudes. 5. EPA Comment-If observers will be disqualified based on both the visual screening and the environmental inventory, it appears that evaluations will not be based on 25 observers, but a substantially smaller subset that may not be a credible minimum. What is the minimum number of observers needed for a given day of observation? What happens if that minimum number is not achieved? Based on the concerns in comment#4 and here, it is difficult for EPA to support use of the environmental response inventory. t � Response A sufficient number of observers will be selected and screened to ensure that there are a sufficient number of observers on each observation day. Discussion with Drs. Prestrude and Cherry indicates that a target of 25 observers will provide sufficient statistical power for a valid study, even if there are a few absences. Concerning the environmental response inventory (EPA comment 4), it is an important study control and will be included. The questionnaire is completed at the end of the day after all sites have been rated. Based on Dr. Prestrude's experience with prior color perception studies, the number of observers excluded by screening is minimal, and there are no problems mobilizing sufficient numbers on observation days. 6. EPA Comment-Dr. Cherry's response#14 states that non-registered voters will not be excluded as participants. However, question 6 of the Appendix C sample screening sheet indicates that a non-registered voter will be excluded. We recommend that question 6 be deleted. 7. EPA Comment- Dr. Cherry's response#12 states that the participant selection screen will ask potential observers whether or not they have visual acuity or color perception problems. However, question 8 of the Appendix C screening sample addresses vision Response to EPA Comments, Page 7 only in the context of riding in a van or walking. We recommend that question 8 be revised to "Do you have any unaddressed physical or vision restrictions such as color blindness or nearsightedness?" 8. EPA Comment- Dr. Cherry's response#16 states that canoers and rafters will be allowed to participate,but question 13 of the Appendix C screening sample still specifically excludes them. Question 13 should be revised so that canoers/rafters are not excluded. 9. EPA Comment-Dr. Cherry's response 417 states that members of various environmental groups that have challenged the most recent mill permit will be excluded, but question 14 has not been revised to include the names of those groups. Response to EPA Comments 6-9 All of the Appendix examples have been revised to comport with the text of the study plan and previous response to comments. 10. EPA Comment- EPA's original comment#8 related to the color levels occurring in the river during the surveys. Our concern is that the ambient color levels should be in the range of 50 to 120 pcu during the surveys. If the ambient color levels are not in this range, it is not clear that the study will achieve its intended purpose. For example, if instream color levels are not greater than 50 pcu during the site visits, and the observers' opinions support the conclusion that the aesthetic criterion is being met,that scenario leaves open the question as to whether higher ambient color levels also meet the aesthetic criterion. NC water quality standards require that the narrative color criterion be met at flows at or above the 30Q5 instream flow. From EPA's perspective, it would not be sufficient, based on the scenario that observers' ratings during all of the site visits support an outcome that the color narrative is met,to conclude that continuation of the color effluent limits at levels in the current permit is consistent with the color narrative—unless the highest ambient color levels during the site visits were consistent with the projected ambient color levels that would occur at the current color effluent limits and the 30Q5 flow. EPA has estimated that the current permit color limits, when discharged at the 30Q5 flow,results in ambient color levels in the middle of the 50 to 120 pcu range. Therefore, we suggest that the study include a contingency plan if ambient color levels in the upper part of this range do not occur during the site visits. Response Observations from independent observers under normal mill operating conditions, on different dates and under different river flow conditions will provide a statistically accurate analysis to support the interpretation and application of North Carolina's narrative color standard to the Pigeon River near Canton. The governing flow for the NC Narrative Standard is 30Q2, not 30Q5. The 30Q2 I at Canton is 58 mgd. We understand that EPA recommended an assessment of ambient color levels in the range of 50 to 120 platinum cobalt units. Because we Response to EPA Comments, Page 8 cannot control or ensure color levels in a specific range in the Pigeon River, three observations in different seasons and river flow conditions are necessary for an accurate Perception Study that accounts for the river's natural variability. It would be inappropriate for the Canton Mill to increase color discharge or throttle river flow as was suggested in some preliminary discussions on the Study Plan. Those actions are generally not feasible, and/or are contrary to the NPDES permit. Color discharge on river observation days will reflect normal Canton Mill operation. The low flow period on the Pigeon River typically occurs between August and October of each year. We will monitor how river base flow is trending this summer and adjust plans for the 3rd Quarter observation to correspond with the period of normal annual river low flow. Delay in the date of the 3` observation trip may push back the date by which the study data can be analyzed and the final study report prepared. EPA Comments -Part 2 of 2 Based on Dr. Cherry's numbered responses to our first round of comments: EPA Comment No. 4 -The statement that there is a psychological bias that comes from seeing the upstream water is not intuitively obvious just by providing this statement. If it is not scientifically explained using references, it will be questioned by outside parties. Please provide the references that explain the psychological bias for this bias. This is the same comment as original EPA Comment No. 4b. Response The purpose of this study is not to assess differences in color of the Pigeon River above and below the mill, but rather the appearance of the water and appropriateness for use at each observation site. The planned order in which sites are observed forces a site by site independent assessment that is separate from point and non-point contributions of color, turbidity and other factors influencing aesthetic quality. The mill is large and cannot be avoided when viewing the upstream sites, which creates a bias that all downstream conditions observed are related to the mill. The study design removes the observers' awareness of the mill to the greatest extent possible so that observations are neutral evaluations of the water. The observation sites at Fiberville and at the Recreation Park have the mill as part of the background environmental setting, the effect of which will be evaluated with the scenic beauty rating. Dr. Prestrude has provided references on bias that are included in the revised plan. A key reference is the Masters Thesis by Laws [Laws, E. L. (1990). THE EFFECT OF INSTRUCTIONS ON SCENIC BEAUTY RATINGS OF RIVERSCAPES AND THE PREDICTION OF THOSE RATINGS BY ENVIRONMENTAL QUESTIONNAIRES. MS Thesis. Virginia Polytechnic Institute and State University.] I Response to EPA Comments, Page 9 EPA Comment No. 14 -This is a new selection method not previously mentioned.The statement that residents from the local geographic area only should be used should be explained. What will be the extent of the geographic area and what value will that add? Response The standard being evaluated is the North Carolina narrative standard for color. Information on county and state of residence will be used by the opinion research agency that recruits and-screens observers to obtain a mix of independent observers from the Western North Carolina region. There is also the practical matter of travel distance. The observers need to live within a reasonable commuting distance of Waynesville, NC where the observers will gather at the start of each observation day. EPA Comment No. 16 -The statement is made to avoid rafters from Tennessee. Why?No explanation is given. Response The screening tool to recruit observers has been clarified to exclude rafting guides working on the Pigeon River in Tennessee. These guides as a group participated in the February 2010 public meeting on the Canton Mill NPDES permit in Cocke County and were active in Clean Water Expected in East Tennessee (CWEET). r EPA Comment Page 5 -Rating Scales. Clarity and color scores will be combined for one score on water quality? Why will the values for color and clarity be combined? Why not keep those scores separate?Many people may not understand the definition of clarity, so those scores may not provide a sound basis for evaluation vs. color which is the main object of the study. Clarity is also not the basis for the variance. Calling the combined scores'water quality' gives the impression that it is rating more than color and clarity but is somehow rating the quality of the water. If they are combined (which we do not suggest) the combined score should be called the 'combined score for color/clarity'. Response See response to Part 1 EPA comments 1& 2 above. Color and clarity are separate aspects of the aesthetic component. Separate rating of clarity is necessary to separate the turbidity element of apparent color from true color which is dissolved. Color is tint. Clarity is how far into the water you can see. For example, are the rocks in the river bottom visible? Drs. Prestrude and Cherry have determined, based on prior color perception studies, that the average independent observer intuitively understands the difference between color and clarity without explanation. These are important aspects of the appearance of the water to evaluate and relate to the Mill color discharge as well as to non-point and tributary sources that affect the appearance of the main stem of the I Pigeon River. Response to EPA Comments, Page 10 The NC narrative standard for color includes the qualitative element of acceptable (not objectionable) aesthetic quality. The interpretation and application of the standard to the Pigeon River near Canton should be based on the ratings of independent and neutral observers who, at a minimum, are not water quality experts, not associated with the mill and not associated with legal challenges to the wastewater permit. Blue Ridge Paper expressly asked the experts — Drs. Prestrude and Cherry—to design a Color Perception Study that is independent so the results are credible to all parties involved in continued protection and improvement of the Pigeon River. 1 Proposal for Site Specific Study of Color in the Pigeon River Albert M. Prestrude, Ph.D. and Donald S. Cherry, Ph.D. April2012 Introduction and Background The 2010 Color Variance issued by the NPDES Committee of the North Carolina Environmental Management Commission ("EMC") includes the following language in paragraph 12.1). on page 14. Compliance with the North Carolina color standard in the Pigeon River shall be established by results from a site-specific study of color in the Pigeon River. The study protocol shall be approved by DWQ and will generally be as outlined in EPA's letter of February 22, 2010 to DWQ. Results of this study shall be evaluated by the EMC's NPDES Committee as part of any new request to remove the variance. The language, beginning on page 5 of the EPA letter of February 22, 2010, reads as follows: Recommendation For Site-Specific Study In order to create a better record for any future effort to reinterpret the narrative color standard, and ensure that authorized discharges are protective of the narrative standard, EPA recommends the addition of a condition in the draft permit requiring the permittee to provide funding for an independent study of color levels in the North Carolina segment of the Pigeon River, or a segment of a watershed that is reasonably similar to the physical characteristics of the. Pigeon River downstream of the mill. Vie study should focus on the aspects of the State's narrative color standard that are relevant to conditions and limits on the permit, and should address assessment of color levels in ambient waters of the Pigeon River (or other watershed(s), as specified above) when those levels are in the range of 50 to 120 PCU. The permit could also include a reopener clause to implement the conclusions of the study if warranted. EPA believes that an independent, unbiased site-specific study would be useful to determine how the State's narrative color standard should be interpreted or applied to the Pigeon River near R&S 928021-1 Color Perception Study Plan—April 2012, Page 2 Canton. Such a study would be valuable in addressing uncertainties relating to the narrative standard for color because many site-speck factors influence the overall perception of an individual stream setting and the level of protection needed for a stream or watershed. Evaluation of the Pigeon River downstream of the Blue Ridge »till is even more critical for setting regulatory targets, given the color levels in the river, and the public interest in the present permitting process for the Blue Ridge facility. The study would be conducted with unbiased observers. For example, college students were used in some of the studies performed by Prestrude. The results of the study could be used by the State to address other issues related to the application of the North Carolina narrative color standard, such as whether it would be more appropriate to establish a regulatory requirement for the river solely based on a specific color concentration, or as an increment over "background" color levels. We also suggest that EPA be involved in the review and approval of the framework of the plan for conducting the study prior to initiation. i North Carolina Water Ouality Standard for Color The North Carolina water quality standard for color is set forth at 15A N.C.A.C. 2B.0211 (f) and reads as follows: (n Oils, deleterious substances, colored or other wastes: only such amounts as shall not render the waters injurious to public health, secondary recreation or to aquatic life and wildlife or adversely affect the palatability of fish, aesthetic quality, or impair the waters for any designated uses. Proposed Study Blue Ridge Paper Products Inc. d/b/a Evergreen Packaging ("BRPP")proposes to fund a study of color levels in the Pigeon River in North Carolina focusing on the aesthetic component of North Carolina's narrative color standard relevant to conditions and limits in the NPDES permit issued to the Canton Mill. The study will be done, generally in accordance with the protocol described in the EPA letter of February 22, 2010, to the North Carolina Division of Water Quality. The study will be conducted by Albert M. Prestrude,Ph.D. of Alcyon Consulting Color Perception Study Plan—April 2012, Page 3 and Donald S. Cherry, Ph.D. Dr. Prestrude is an expert in environmental psychology and has performed similar color perception studies on rivers in the United States. Dr. Cherry, an expert in aquatic ecotoxicology, has worked on similar color perception studies in the past, and is the author of numerous articles in peer reviewed journals and publications. Curriculum Vitae for Drs. Prestrude and Cherry are attached (see Appendix A). Both Dr. Prestrude and Dr. Cherry are retired from the faculty at Virginia Tech. Graduate students at Virginia Tech assisted in past studies. The study will focus on the aesthetic component of the North Carolina Water Quality Standard for Color by measuring independent observers' perceptions of the aesthetic quality of the Pigeon River in North Carolina above and below the Canton Mill. The observers will be i taken to a number of different locations along the river and asked to answer a series of questions designed to assist them in evaluating the sites. Study Procedures • Observation Sites — Eight sites on the Pigeon River, all in North Carolina, have been selected for observation. Drs. Prestrude and Cherry have visited and inspected all the sites. The sites were selected to be approximately equidistant (between sites), to be accessible, to accommodate vans and passengers and to limit traffic hazards. The site locations are shown on the map in Appendix B. The observations will begin at the North Carolina / Tennessee line and work upstream so as not to bias the observers. The observation sites include the end of the mixing zone (Fiberville Bridge) and two locations above the Canton Mill discharge. • Independent Observers - Twenty-five (25) independent observers will be recruited and selected from the western North Carolina area by an independent consulting firm. Observers will be screened for biasing factors and ability to carry out the requirements of the study (Appendix C). For example, individuals Color Perception Study Plan—April 2012,Page 4 who work, have worked, or are related to current or past employees of the Canton Mill, will be excluded. Individuals with uncorrected vision problems, with conditions limiting or precluding spending several hours in a van, getting into and out of a van, and walking short distances on uneven terrain, will not be recruited. Individuals who are or have been members of entities involved in prior or pending litigation against the Canton Mill will not be recruited. On the dates of the observations, observers will be screened for visual acuity, color vision and contrast sensitivity. The observers will be asked to report to a central location in Haywood County, North Carolina where they will be provided a light breakfast and receive instructions. After the observations, the observers will be provided lunch and will complete an environmental attitudes questionnaire consisting of 184 statements regarding the environment and its use. The respondents indicate their degree of agreement or disagreement with each statement (Appendix D). All observers will also be given visual acuity and color vision tests (Appendices E and F). The number of observers will be limited to twenty-five (25) to ensure observer safety, to allow all observers to view a site at the same time, and to allow all observers to observe all sites on the same day. Based on prior experience, screening observers for visual acuity, color vision and environmental attitudes will not result in an insufficient number of observers. • Personnel — Research Supervisor (A.M. Prestrude), three assistants, professional photographer, van drivers and security personnel to direct traffic. The assistants are Virginia Tech graduates with previous experience in this type of environmental study. • Procedures — Dr. Prestrude will introduce himself, the assistants, and the photographer and describe the procedures. Each observer will be given a clipboard and pencil. Each clipboard will have a written copy of the instructions (Appendix G) with the observer's number and multiple copies of the ratings scale. There will be a brief practice session in which the observers will look at slides of Color Perception Study Plan—April 2012, Page 5 river scenes and rate them. These ratings will be collected and filed. The observers will then be sent to the waiting vans. Two of the assistants will act as van leaders to organize and direct the activities of the observers in their vans and at each site. The third assistant will be responsible for collecting the rating scales at each site. Observers will be instructed to turn off their mobile phones. No incoming or outgoing calls or internet searching will be allowed. Observers will be asked to remove sunglasses. Water, soft drinks and snacks will be available in the vans. There will be bathroom stops along the way. Uniformed security personnel will direct traffic at each site. • Site Evaluations — The sites will be evaluated on three different dates. Exact dates have not been identified, but it is anticipated that the observations would be done during spring and summer of 2012 representing river conditions in May, June/July and August/September. Water samples will be collected at each site by an independent environmental consulting firm and will be analyzed for conductivity, total dissolved solids, and true and apparent color. The analysis for true and apparent color will be done by an independent laboratory and by the Canton Mill laboratory. Analysis for all other parameters will be done by an independent laboratory. Observation events will not be done within three days of a measurable rain event. Individual observers will be contacted via e-mail or phone on the day prior to the event to remind them to be there, or in the case of bad weather, that there will not be an event. Multiple light levels will determined and noted at each site and a computerized photographic record will be maintained of water appearance, sky conditions, upriver and downriver views and the location of the observers when they made their ratings. • Materials—Observers will be provided with 7—Point Likert(Likert, 1932) scales with anchors at 1 (unacceptable), 4 (acceptable), and 7 (very attractive) (see Appendix A). This rating procedure, called magnitude estimation, has been used by psychologists and psychophysicists for 200 years to quantify human perceptual experience. The rating procedure has also been adopted in other venues. For Color Perception Study Plan—April 2012, Page 6 example, in gymnastics and figure skating, contestants are judged and scored on a numeric scale, of I to 7 or I to 10. In recent years,numeric scales have been used to evaluate fire and insect damage to national forests (see e.g. Buyhoff, Wellman and Daniel, 1982) and studies of the impact of treated industrial effluent on receiving waters (Laws, 1990); (Prestrude, 1996, COLOR: Misperceptions About the Aesthetics of River Color); (Prestrude & Laws, 1988 [study on the Hiwassee River for BowateJ) (Prestrude, Lmvs and McMurry, D.K. — Hiwassee River Color Perception Study, Proceedings, 1991 Environmental Conference, Technical Association of the Pulp and Paper Indushy, pages 599-614). These procedures typically result in at least interval scales of measurement from which the numbers can be summarized and subjected to statistical analysis(Stevens 1950; 1975). • Rating Scales-There will be seven rating scales on each sheet. The first scale will refer to the scenic beauty/aesthetic quality of the site looking up river and down river. The second scale will refer to the color of the water. The third scale will refer to the clarity of the water.The last four scales will refer to the acceptability of each site for recreational activities including wading, swimming, fishing, and rafting, canoeing, boating. There will be a space for comments on each rating sheet, and observers will be encouraged to write comments..A sample rating scale is included in Appendix H. • Environmental Response Inventory — Upon completion of the rankings, observers will be asked to complete an environmental attitudes questionnaire (Environmental Response Inventory-McKechnie, 1974, 1977, Appendix D). The results of this test will be used to identify observers with extreme environmental attitudes (defined as one standard deviation above or below the population mean). A copy of the scoring scales for Environmental Response Inventory is attached as Appendix I. • Visual Acuity — Brief visual acuity, contrast sensitivity and color vision testing procedures will be used to determine whether observers have visual problems not Color Perception Study Plan—April 2012,Page 7 identified or reported during the selection screening process. Observers will be thanked for their participation, paid $200 and dismissed. The process should be complete by 3:00 P.M. • Renortin¢ - A report of the study will be prepared and submitted to the North Carolina Division of Water 'Quality and the United States Environmental Protection Agency on or before January 1, 2013. References 1. Buyhoff, G.J., Wellman, J.D. &Daniel, T.C. (1982). Predicting Scenic Quality For Mountain Pine Beetle and Western Spruce Budworm Damaged Forest Vistas. Forest Science,28, 827-838. 2. Laws, E.L. (1990). The Effect of Instructions on Scenic Beauty Ratings of Riverscapes and the Prediction of Those Ratings by Environmental Questionnaires. MS Thesis. Virginia Polytechnic Institute and State University. 3. Likert, R. (1932). A Technique for the Measurement of Attitudes. Archives of Psychology, 140, 1-55. 4. McKechnie, G.E. (1974). Environmental Response Inventory. Palo Alto, CA: Consulting Psychologist's Press. 5. McKechnie, G.E. (1977). The Environmental Response Inventory in Application. Environment and Behavior, 9,255-276. 6. Prestrude,A.M. &Laws, E.L. (1988). Hiwassee River Study. II. Color perception. Unpublished. 7. Prestude, A.M., Laws, E.L., McMurry,D.K.—Hiwassee River Color Perception Study, TAPPI Proceedings, 1991 Environmental Conference,Technical Association of the Pulp and Paper Industry,pages 599-614. 8. Prestrude,A.M.,Misperceptions About the Aesthetics of River Color, 1996. Color Perception Study Plan—April 2012, Page 8 List of Appendices Appendix A Curriculum Vitae of Albert M. Prestrude,Ph.D. and Donald S. Cherry, Ph.D. Appendix B Pigeon River Site Locations Appendix C Sample Screening Sheet Appendix D Environmental Attitudes Questionnaire Appendix E Visual Acuity Test Appendix F Color Vision Test Appendix G Field Instructions to Observers Appendix H Likert Rating Scale Appendix I Environmental Response Inventory Appendix A Curriculum Vitae of Albert M. Prestrude, Ph.D. and Donald S. Cherry, Ph.D. RESUME Albert M. Prestrude December 9, 2011 Born: May 26, 1934, Eastedge, ND Education: BA, Concordia College, Moorhead, MN. Major- psychology, minor- chemistry. MS and Ph.D., Florida State University, Tallahassee, FL. Major— experimental psychology, minor- psychobiology. Employment: I held my first job at age 14 washing dishes in a restaurant within a year becoming a grill cook. Through my high school and college years, I worked as a bellhop, cemetery groundskeeper, furniture warehouseman, truck driver, wheat harvester, sheet metal worker, iron worker, and Forest Service fire fighter. 1958-1960 - Public School Teacher, Lolo, MT. 1960-1962 - Psychometrist, Univ. of Montana Counseling Center. 1962-1966 - Instructor, Grays Harbor, College, Aberdeen, WA. 1966-1969 - National Science Foundation Trainee, Florida State University. 1969-2000 - Assistant and Associate Professor, Virginia Polytechnic and State University, Blacksburg, VA. Retired as Emeritus Associate Professor. 1995-present- Self employed as Alcyon Consulting. Professional activities at Virginia Tech: Assistant and Associate Department Head, coauthored the application for a graduate program to the Virginia Council of Higher Education, began and chaired the graduate program in Applied-Experimental Psychology, served on numerous departmental, college, and university committees. Consulting: Spent one year at the Naval Aerospace Medical Research Labs as a Visiting Scientist developing vision tests for the selection and evaluation of carrier based tactical jet pilots. US Army Medical Service - served on a committee evaluating their Vision Research Program. Later advised on their program to evaluate and prevent ocular damage from laser range finders. Science Applications International Corp. Classified. Federal Aviation Administration - Develop "non-detonable" training aids for bomb detecting dogs. Five year contract. Environmental impact of treated papermill effluent on receiving waters. Four studies: Bowater Southern Corp., Paper Industry Information Office, Champion Paper, and Blue Ridge Paper. North Carolina Dept. of Water Quality - effect of textile mills on the Catawba River. Expert witness in environmental and hunting accident court proceedings. Numerous research reports published in national and international journals and papers presented at regional, national, and international scientific meetings. Directed the graduate research at the MSc and PhD levels of psychology, engineering, and architecture students Donald S.Cherry, Ph.D.—Three-Page Resume-November 2011 Rank: Professor Discipline:Ecotoxicologv Highest Degree: Ph.D. Institution: Clemson University 1973 EDUCATION 1965 Furman University,Greenville,S.C.,B.Sc.Degree,Biology,Secondary Education. 1967 University of Arizona,Tucson,Summer Sessions,Chemistry. 1968 Wofford College,Spartanburg,S.C.,Summer Sessions,Chemistry. 1970 Clemson University,Clemson,S.C.,M.Cs.Degree,("Comparative Radiosensitivity in the Class Insecta"), Zoology,Radioecology. 1972 Duke Univ.,Marine Institute,Beaufort,N.C.,Summer Program in Marine Ecology. 1973 Clemson University,Clemson,S.C.,Ph.D.Degree,("Dynamics of a Piscine Community in a Reservoir Ecosystem"), Zoology,Aquatic Ecology,Environmental Health. PROFESSIONAL EXPERIENCE 1986 Professor—Biology Department and University Centerfor Environmental and Hazardous Materials Studies,VATech 1981-86 Associate Professor—Biology Department and University Centerfor Environmental Studies,VATech 1976-81 Assistant Professor-Biology Department and University Centerfor Environmental Studies,VA Tech 1974-76 Visiting Assistant Professor—University Center for Environmental Studies and Biology Department,VA Tech 1973-74 Postdoctoral Appointment with John Cairns,Jr.,University Center for Environmental Studies.Thermal Effects Upon Fish Populations in the New River at a Site-Specific Field Laboratory and Coal Ash Impact Upon Aquatic Food Chains 1972-74 Instructor,Human Ecology,Man and The Environment,General Biology at Clemson University MAJOR AWARDS AND RECOGNITIONS 1990-95 Senior Associate Director—University Center for Environmental and Hazardous Materials Studies TEACHING Description of Teaching Activities: Taught graduate/undergraduate level in Aquatic Ecotoxicology,Hazard Evaluation of Toxic Chemicals,Environmental Toxicology,Umnology,and Principles of Ecology. Student Advising Past Ten Years: Master Candidates:Travis Schmidt,Jessica Yeager,Matthew Hull,Alan Kennedy,Chad Merricks,Theodore Valenti, Branden Locke,Matthew Simon,Brandi Echols,Michael Chanov. Doctoral Candidates:David Soucek,Branch Echols Major Professor:12 completed.Past 35 years:49 MS/Ph.D.s,14 Post-dots. RESEARCH Description of Research Activities Developing and carrying out eight specific areas of research.(1)Power Plant Ecology and Effects Upon Aquatic Food Chains.Documenting preference and avoidance behavior of fish from lethal exposures to heated,chlorinated discharges and acidic-alkaline PH excursions;studying potential control of Asian clams and zebra mussels that disrupt cooling systems; predicting safe concentrations of fly ash effluent,pH and ash particulate interactions upon aquatic receiving systems.(2) Correlation of Physiological-Biochemical Mechanisms with Toxicological Responses of Fish and Invertebrate Populations from Power Plant Effluents Stressed by Fly Ash and Heavy Metal Effluents.(3)Hazard Evaluation of Toxic Substances in Aquatic Ecosystems-Industry Versus State or Federal Regulatory Agencies.Investigating hazard evaluation of using field,field laboratory,field artificial stream microcosms,laboratory artificial stream systems,and accepted laboratory static and flow- through bioassay techniques;understanding the cost-effectiveness of these protocols to industry;providing the optimal and most applicable results of hazard evaluation studies in accessing environmental Impact;developing new or revised protocols to optimize the current and future toxicity testing methodologies to access this area of hazard evaluation between industry and state or federal regulatory agencies.(4)Comprehensive Evaluation of Pulp and Paper Mill Effluents—Ecotoxicology,Color Perception and Dioxin Issues.Investigating the potential toxicity of effluents using US EPA approved test organisms and endemic species;carrying out in-river surveys of periphyton,benthic macroinvertebrates,and fish;evaluating scenic river beauty and color perception of darkened effluents;negotiating NPDES permitting between the paper industry and regulatory agencies and being an expert witness in litigious situations.(5)Waste Water Treatment Plant Revisions with Toxicity Reduction Evaluations.(6)Recovery/Restoration Ecology of Damaged Stream/River Ecosystems.Investigating the effects of non-point inputs from abandoned mined land(AML),sedimentation from agricultural runoff,and influences of rural town runoff upon ecosystem integrity.The overall strategy is to develop a watershed-level approach to restoration ecology.(7)Field Surveys for Native Unionids and Their Competitive Interaction with Asian Clams.Emphasis was to determine the most sensitive part of the life cycle of mussels in the laboratory as well as how Asian clam invasion contributes to their demise.(8)Biofouling and Control Strategies for Asian Clams and Zebra Mussels.Evaluating the efficacy and fate/effects of selected molluscicides upon pest organisms and endemic creatures residing in the water column and sediment. More Recent Pertinent Research Activities Conducted research in the recovery/restoration ecology of damaged stream/river ecosystems.Developed the first ecological improvement plan in watershed management prioritizing restoration activities between AML,agriculture and other nonpoint source discharges for the US Department of Justice.Conducted whole effluent toxicity testing for regulatory agencies, and am developing benthic impairment indices for streams adversely influenced by a bank erasion and sedimentation from poor land and use practices.Conducting watershed evaluations(N.Fork Holston River&Clinch River,VA)of point/non-point impacts upon native mussels and developing an improved field/laboratory ecotoxicological testing protocol for ASTM&US EPA standards.Developing an environmentally safe standard of Total Dissolved Solids for the coal mining industry as well as studying hollow fill impacts in headwater streams from mountain top-surface mining activities. RELEVANT RESEARCH PROJECTS Principal Investigator: Evaluation of Coal Mining Discharges for Toxicity in Clinch/Powell River Watersheds,VA. Sponsor: Virginia Coal Association,2007-2011. Principal Investigator: Watershed Evaluations(N.Fork Holston River&Clinch River,VA)of Point/Non-point Impacts upon Native Mussels to Develop an Improved Field/Laboratory Ecotoxicological Testing Protocol for ASTM&US EPA Standards. Sponsor: U.S.Fish&Wildlife Service,2002-2007. Principal Investigator: Development of Ecological Restoration Activities for Ten Watersheds Confluencing with the Powell River Drainage System in Lee and Wise.Counties,VA. Sponsor:Virginia Department of Mined Land Reclamation and the U.S.Army Corps of Engineers.1995-2007. Principal Investigator: Development of Leading Creek Improvement Plan in Meigs County,CH.This was a 7-year project Identifying all major point and non-point source impacts in a 90,000 acre watershed,then prioritizing the 17 major tributaries for restoration purposes,and implementing a best management practice for agricultural uses. Sponsor:American Electric Power Company.1995-2002. Principal Investigator: Ecotoxicological Analysis of Point and Non-Paint Source Discharges in the Clinch River Watershed,VA. Sponsor:American Electric Power Company.1984-1995. TOTAL GRANT DOLLARS GENERATED PI and CO-PI investigator: $4,500,000 past 10 years;$12,000,000 past 35 years. PUBLICATION TOTAL:224(Book Chapters,Invited Paper,Journal Articles),236(Published Abstracts,Proceedings)and—330 Industrial Reports of Limited Distribution=790 for Career. RESPRESENTATIVE PUBLISHED ARTICLES,2002 to Present Soucek,D.J.,D.S.Cherry and C.E.Zipper.2002.Aluminum Dominated Toxicity in Neutral Waters Below an Acid Mine Drainage Discharge.Can.J.Aquatic.Sci.58:2396-2404. Cherry,D.5.,J.H.Van Hassel,J.L.Farris,D.J.Soucek and R.J.Neves.2002.Site-Specific Derivation of the Acute Copper Criteria for the Clinch River,Virginia.Human&Evol.Risk Assess.8:591-601. Schmidt,T.S.,D.J.Soucek and D.S.Cherry.2002.Modification of an Ecotoxicological Rating to Bioassay Small Acid Mine Drainage Impacted Watersheds Exclusive of Benthic Macroinvertebrate Analysis.Environ.Tox.Chem.21:1091-1097. Soucek,D.J.,B.C.Denson,T.S.Schmidt,D.S.Cherry and C.E.Zipper.2002.Impaired Acroneurio sp.(Plecoptera,Perlidae) Populations Associated with Aluminum Contaminated in Natural pH Surface Waters.Arch.Environ.Contam.Toxic. 42:416A22. Hull,M.S.,D.S.Cherry,D.S.Soucek,R.J.Currie and R.J.Neves.2002.Comparison of Asian Clam Field Bioassays and Benthic Community Surveys in Quantifying Effects of a Coal-Fired Power Plant Effluent on Clinch River Biota.J.Aquatic Ecosyst.Stress&Recovery.9:271-283. Schmidt,T.S.,D.J.Soucek and D.S.Cherry.2002.Integrative Bioassessment of Small Acid Mine Drainage Mine Drainage Impacted Watersheds in the Powell River Watershed.Environ.Toxic.Chem.21:2233-2241. Bidwell,J.R.,D.S.Cherry and C.E.Zipper.2003.Toxicity Evaluation of a Commercial Bioremediation Agent Mixed with Oil. Environ.Tox Chem.22:84-91. Soucek,D.1.,D.S.Cherry and C.E.Zipper.2003.Impacts of Mine Drainage and Other Non-Point Source Pollutants on Aquatic Biota in the Upper Powell River System,Virginia.Human&Ecol.Risk Assess.9:1059-1073. Currie,RJ.,W.A.Bennett,T.L.Bellinger and D.S.Cherry.2004.Upper and Lower Temperature Tolerances of Three Freshwater Game Fish Species Exposed to 32 Days of Cycling Temperatures.Hydrobiologia.532:127-136. Mummert,A.,T.D.Newcomb,R.J.Neves and D.S.Cherry.2003.Sensitivity of Juvenile Freshwater Mussels to Total and Ionized Ammonia.Environ.Toxic.Chem.22:2554-2560. Kennedy,AJ.,D.S.Cherry and R.J.Currie.2004.Evaluation of Ecologically Relevant Bioassays for a Lotic System Impacted by a Coal-mining Effluent using/sonychia bicolor.Environ.Monit.Assess.95:37-55. Hull,M.S.,D.S.Cherry,and T.C.Merricks.2004.Effect of Cage Design on Growth of Transplanted Asian Clams:Implications for Assessing Bivalve Responses in Streams.J.Environ.Monit.Assess.96:1-14. Kennedy,A.J.,D.S.Cherry and C.E.Zipper.2005.Evaluation of the Ionic Contribution of a Coal Mine Effluent to Biotic Impairment.Arch.Environ.Contam.Tox.49:155-162. Valenti,T.W.,D.S.Cherry,R.J.Neves and J.Schmerfeld.2005.Acute and Chronic Toxicity of Mercury to Early Life Stages of the Rainbow Mussel,VdIosa iris(Bivalvia:Unionidae).Environ.Tox.Chem.24:1242-1246. Brown,M.E.,M.Kowalewski,R.I.Neves,D.S.Cherry and M.E.Schreiber.2005.Freshwater Mussel Shells as Environmental Chronicles/Geochemistry Signatures of Mercury-related Extirpations in the North Fork Holston River,Virginia.Envir. Sci.Tech.39:1455-1562. Cherry,D.S.,J.R.Sheller,N.L.Cooper and J.R.Bidwell.2005.Potential Effects of Asian Clam(Corbicula fluminea)Dieoffs on Native Freshwater Mussels(Unionidae)I.Water-column Ammonia Levels and Ammonia Toxicity J.N.Am.Benthol. Soc.24:369-380. Cooper,N.L,J.R.Bidwell and D.S.Cherry.2005.Potential Effects of Asian Clam(Cobicula fluminea)Dieoffs on Native Freshwater Mussels(Unionidae)II.Pore-water Ammonia.J.N.Am.Benthol.Soc.24:381-394. Valenti,T.W.,J.L Chaffin,D.S.Cherry,M.E.Schreiber,H.Maurice Valett and M.Charles.2005.Bioassessment of an Appalachian Headwater Stream Influenced by an Abandoned Arsenic Mine.Arch.Environ.Contam.Tox.49:488-496. Cherry,D.S.and D.J.Soucek.2006.Site-specific Impact Assessment Using In-situ Asian Clam(Corbicula fluminea)Testing Compared to Traditional Measures,with a Chronological Review of Asian Clam Biomonitcring.In,Freshwater Bivalve Ecotoxicology.J.L.Farris and J.H.Van Hassel eds.Ch.11 SETAC Press,Pensacola,FL.pp.285-305. Valenti,T.W.,D.S.Cherry,R.J.Neves,B.A.Locke and J.J.Schmerfeld.2006.Sensitivity of Mussel Glochidea and Regulatory Test Organisms to Mercury and a Reference Toxicant.In,Freshwater Bivalve Ecotoxicology,J.L.Farris and J.H.Van Hassel eds.Ch.14.SEFAC Press,Pensacola,FL.pp.351-365. Hull,M.S.,D.S.Cherry,and R.J.Neves.2006.Use of Bivalve Metrics to Quantify Influences of Coal-related Activities in the Clinch River Watershed,Virginia.Hydrobiologia 556:341-355. Locke,B.A.,D.S.Cherry,C.E.Zipper and R.J.Currie.2006.Land-Use Influences and Ecotoxicological Ratings for Upper Clinch River Tributaries in Virginia.Arch.Enviro.Contam.Toxic.51:197-205. Valenti,T.W.,D.S. Cherry,R.J.Currie,1.Jones,R.Mair,R.J.Neves and C.M.Kane.2006.Acute and Chronic Exposure of Early Life Stages of Freshwater Mussels to Chlorine.Environ.Toxic.Contam.25:2512-2518. Simon,M.L,D.S.Cherry,R.J.Currie and C.E.Zipper.2006.The Ecotoxicological Recovery of Ely Creek and Tributaries(Lee County,VA)after Remediation of Acid Mine Drainage.Environ.Monit.Assess.123:109-124. Merricks,T.C.,D.S.Cherry,C.E.Zipper,R.J.Currie and T.W.Valenti.2007.Coal Mine Hollow Fill and Settling Pond Influences on Headwater Streams in Southwestern Virginia,USA.Environ.Monit.Assess.129:359-379. Echols,B.S.,R.J.Currie and D.S.Cherry.2009.Influence of Conductivity upon Benthic Macroinvertebrates in the North Fork Holston River,Virginia,Downstream of a Point Source Brine Discharge during Severe Low-Flow Conditions.Hum.Ecol. Risk Assess.15:170-184. Echols,B.S.,R.J.Currie and D.S.Cherry.2009.An Investigation of Total Mercury in the North Fork Holston River,Saltville,VA. Hum.Ecol.Risk Assess.15:968-984. Echols,B.S.,R.J.Currie and D.S.Cherry.2010. Preliminary Results of Laboratory Toxicity Tests with the Mayfly,Isonychia bicolor,for Development as a Standard Test Organism for Evaluating Streams in the Appalachian Coal Fields of Virginia and West Virginia.Environ.Monitor.Assess.169:487-500. Echols,B.S.,R.J.Currie T.W.Valenti and D.S.Cherry.2011.An Evaluation of a Point Source Discharge into a Riverine System and Implications for TDS Limitations.Hum.Ecol.Risk Assess.In Press. Echols,B.S.,R.J.Currie and D.S.Cherry.2011.Seasonal Availability and Sensitivity of Two Field Collected Mayflies(Isonychiidae and Heptageniidae)for the Development of a Standardized Toxicity Test:A One-Year Feasibility Study.In Review. Appendix B Pigeon River Site Locations Pigeon River Perception Study Map MAX op Observational Sites Order of Observation River Mile Deu oc Lohc i �' J -o ® � Wells Rd. 8 RM 67.5 6� Canton Recreation 7 RM 64.5 Park Canton Mill Mixing 6 RM 62.9 "Lone 2 Thickety 02 Station 5 RM 61.2 3 10 \1 o CIIA Q E Clyde Bridge 4 RM 58.0 !1� 5 z° 4 vt 6 • U *Canton o Ferguson Bridge 3 RM 48.3 l 7 m 8 c Hepco Bridge 2 RM 42.6 Brown's Bridge 1 RM 24.7 (Stateline) Appendix C Sample Screening Sheet APPENDIX C EXAMPLE - River Perception Study PARTICIPANT SCREENER - Revised April 2012 Hi, my name is with We're conducting opinion research with individuals who would like to participate in a project about current regional topics which will be held in the spring and summer of 2012. May I ask a few quick questions? I am not selling anything and if you qualify to participate in the research, we would compensate you $200 per study event for your participation. Again, I would like to stress that this is a research study ONLY, and you will not be asked to make any purchases. Everything I ask is solely for research purposes and everything you say is completely confidential. Record but do not ask: 1. Gender? 1.1. Male Recruit 15 1.2. Female Recruit 15 2. Do you or does anyone in your immediate family work for... 2.1. A market research company Discontinue 2.2. An advertising or public relations firm company Discontinue 2.3. A radio station, TV station or Newspaper Discontinue 2.4. Manufacturing company such as: 2.4.1. Paper, pulp or Wood Mill Discontinue 2.4.2. Textile mill 2.4.3. Steel fabrication 2.4.4. Mining 2.4.5. Oil refinery 2.4.6. None of those mentioned 3. Which of the following categories includes your age? (must have a good mix) 3.1. Under 21 Discontinue 3.2. 21-24 3.3. 25-34 3.4. 35-44 3.5. 45-54 3.6. 55-64 3.7. Over64 4. Have you ever participated in an opinion research study before? 4.1. Yes 4.2. No Skip to Q6 4.3. Don't recall Skip to Q6 R&S 926041-1 Screening Tool-Page 2 5. What were the date, location and topic of the most recent past opinion research study in which you participated? 5.1. If anything to do with water quality or Evergreen Packaging, Discontinue 6. In what county and state do you live ? (want representative mix from region) 6.1 7. Do you have any restrictions that would prevent you from spending a weekend day - Saturday or Sunday - on this project? 7.1. Yes Discontinue 7.2. No 7.3. 1 don't think so 8. Do you have any physical or vision restrictions that would prevent you from walking on uneven terrain or riding for some time in a van? (Safety and comfort consideration) 8.1. Yes Discontinue 8.2. No 8.3. 1 don't think so 9. Do you have problems with vision such as color blindness, cataracts or nearsightedness that prevent you from seeing well when outside in open spaces? (Visual acuity consideration) 9.1. Yes Discontinue 9.2. No 9.3. I must wear glasses when driving 9.4. I see well when I wear glasses or contact lenses 10. What is the highest grade or year of school you have completed? 10.1. Grade school 10.2. Some high school 10.3. High school graduate/GED 10.4. Some college/Technical School 10.5. College graduate 10.6. Completed an advanced or graduate level degree R&S 926041-1 Screening Tool—Page 3 11. What was your 2010 total household income before taxes? Read list circle until NO. 11.1. More than $10,000 11.2. More than $20,000 11.3. More than $30,000 11.4. More than $40,000 11.5. More than $60,000 11.6. More than $80,00 11.7. More than $100,000 11.8. Rather not say/Refused 12. Are you currently... 12.1. Employed full time 12.2. Employed part time 12.3. Retired 12.4. Student 12.5. Unemployed 12.6. Rather not say/Refused 13. What is your occupation If rafting guide working on Pigeon River in Tennessee, Discontinue 14. What are your hobbies or interests 15. Which of the following are you a member, contributor or participate with in any way? 15.1. Dead Pigeon River Council 15.2. Tennessee Chapter of the Sierra Club 15.3. Isaac Walton League 15.4. American Canoeing Association 15.5. Tennessee Environmental Council 15.6. Clean Water Expected in East Tennessee 15.7. Tennessee Conservation Voters 15.8. Tennessee Scenic Rivers Association 15.9. Clean Water for North Carolina 15.10. Western North Carolina Alliance 15.11. Southern Environmental Law Center 15.12. Blue Ridge Environmental Defense League 15.13. None of them If they say yes to any of these organizations, Discontinue R&S 926041.1 Screening Tool—Page 4 16. Do you have any restrictions that would prevent you from being in Waynesville, NC on _dates? 16.1. Yes Discontinue 16.2. No 16.3. I don't think so We are interested in your thoughts and opinions on current topics in our area. We are conducting a group opinion research study in spring and summer of 2012. You qualify to participate in this opinion research study, and we would like to invite you to take part. Your participation in the study will last several hours on a weekend day starting about 9 am and ending about 3 pm and will include lunch. You will receive $200 dollars for your participation at the end of the session. Will you be able to attend? Yes No Discontinue Great! We would like to send you a confirmation letter. May I have your full name, address, zip code and e-mail? Name Address City State Zip e-mail And I dialed phone number Is that correct? We look forward to seeing you and one of our representatives will meet you at 8:00 a.m. Thank you again for agreeing to attend, we are counting on you to be there. If you find that you can't attend for some reason, please call us @ as soon as possible because we will need to replace you in order to be sure that we have a full group. Thanks, Good Bye! R&S 926041-1 Appendix D Environmental Attitudes Questionnaire r-� i ERI BOOKLET ENVIRONMENTAL t RESPONSE i i INVENTORY George E. McKechnie DIRECTIONS This questionnaire is designed to study attitudes toward the environment, It contains a series of statements on various subjects. Read each statement and decide whether you agree or disagree with it. Use the following five categories to describe your response: 5= strongly agree / 4 = agree / 3= neutral / 2— disagree / t = strongly disagree Follow the instructions on the special answer sheet provided, and mark all of your answers on it. Please do not write in this booklet. Make sure that the number on the answer sheet is the same as the number of the question you are answering in the booklet. Try to answer each question, even if you must guess. ©Copyright, 1971, by George E. McKechnle. All rights reserved. No portion of this material may be reproduced by, any process without written permission from the Publisher. Published by CONSULTING PSYCHOLOGISTS PRESS 577 Coltege Avenue Palo Alto. Celltomia 5=strongly agree / 4 =agree / 3 neutral / 2=disagree / I =strongly disagree 1. 1 like amusement parks. 34. 1 would enjoy working with precision 2. 1 would enjoy the work of an architect. power tools. 3. Machines increase man's freedom. 35. !have difficulty concentrating when things are noisy. 4. 1 prefer to live in an area where neighbors 36. 1 would rather remodel an old house than keep to themselves. build a new one. 5. 1 would enjoy driving a racing car. i 6. The idea of walking into the forest and 37. We must move ahead and not worry about . -living of(the land"for a week appeals to me. past failures. f 7. Life in the city is more interesting than 38. Cities are too noisy and crowded for sac. life,on a farm. 39. 1 often feel uneasy in a large crowd of people. 8. I would enjoy building a radio, 40. 1 can repair just about anything around the house. I 9. Traveling isn't really worth the effort. f 41. 1 often have trouble getting the privacy I want. 10. 1 have my best thoughts when f am alone. 42. There should be n law against anyone owning it. 1 enjoy browsing.in bookstores. more than a thousand acres of land. t 12. It would be fun to move around;sad live in 43. 1 feel most secure when I am working different parts of the country, around the house. 13. It is boring to spend all day working 44. It is hopeless to try,to save our cities. I with your hands. i 14. It is exciting to go shopping in a large city. 45. It would be fun own some old-fashioned costst umes. 15. There should be a law against skyscrapers, 46. Motorcycles should be kept out of 16. 1 like to be by myself much of the time. recreation areas, 17. 1 enjoy browsing in antique shops. 47_ I like modern furniture better than the 18. I sometimes daydream of being stranded more traditional styles. on a tropical island. 48. 1 would like a job that involved a lot of traveling. 19. 1 like places that have the feeling of being old: 49. It is important for me to own 26. 1 shudder at the thought or finding a spider top quality equipment. in my bed. 50. As a child, 1 often watched when someone 21. 1 would enjoy traveling around the world repaired things around the house. on a sailing ship. 51. 1 like the sounds of a city street, 22. Alleys are interesting places to explore. 52. Old sections of the city are more interesting 23, I prefer a stick-shift car to one with an than the now areas. automatic transmission. 53. 1 often feel lonely when I am by myself, 24. 1 like crystal chandeliers. 54, As a child,I was taught respect for 25. 1 like homes with stone floors. all living things. 26, I like the variety of stimulation one finds 55. It is good for man to submit to the in the city forces of nature, 27. 1 usually save spare nuts and bolts. 56. I prefer friends who are reliable and 29. 1 get annoyed when my neighbors are noisy. even-tempered. 29. When buying clothes,l usally look more 57, 1 often think of settling down on a farm some day. for comfort than for style; 58. I don't like being completely elope. 30. 1 am quite skillful with my hands. 31. it's annoying to have to share an office or 59. 1 would like to live in a modern, work space with someone. planned community. 32. 1 like to visit historic places. 60. Zoning laws and other building controls are 33, Suburbs should replace the city as the center necessary to protect the rights of the public. of cultural life. 61. 1 like things that have precision moving parts. I 5=strongly agree / 4=agree / 3=neutral / 2=disagree / I=strongly disagree 62, 1 would enjoy entertaining famous peoples 92. 1 enjoy owning a good piece of equipment, ' 63. 1 often feel that f am a part of the space ` even if I don't get to use it much. around me. 93. 1 pride myself on having a home which 64, 1 can identify many of the local flowers and trees. is always open to friends, 65. 1 would like to work with computers. 94. Fences make good neighbors. 66. 1 have vivid memories of where I lived 95. 1'd rather live in the suburbs than in the city. as a child. 96. A complex technological society cannot 67. Our national forests should be preserved in their tolerate individuality., natural state, with roads and buildings prohibited. 97. I enjoy a change in the weather,even when 68. Flying in a small airplane would it turns bad. make me nervous, 98. It is unsafe to ride on buses these days. 69. As a child,I was afraid of being outside 99,. Country people are more honest than city people by myself. 100. Hiking is boring. 70. It is better if people live out their lives 101. 1'd be afraid to live in a place where in one place. there were no people nearby. 71. 1 would enjoy owning u fancy watch. 102. 1 find street noise very distracting. 72. 1 would enjoy riding it motorcycle. 103. 1 have always been somewhat of a daredevil. 73, Making rain by artificially"seeding"clouds 104, 1 would enjoy riding in a crowded subway. is a great technological advance. 74. 1 enjoy staying up all night. 105. 1 am build sensitive to the"character" of a building. 75. 1 am happiest when 1 am alone. 106. 1 like to ride on roller coasters. 76. No child should have to grow up in a rural area. , 107. 1 enjoy tinkering with mechanical'things. 77. 1 get annoyed when people drop by my house 108. 1 do not like to loan things to neighbors, without warning, 109. 1 would enjoy living in a historic house. . � 78. A fireplace adds a special feeling of coziness to a room. 110. Sometimes I wish I had power over the forces of nature, 79. It's interesting to learn about the history of the place where you live. I 1 1. I have no interest in ballet. 80. It is fun to make scale models of things. 112. 1 like to read about the history of places. 81. 1 would enjoy living the rest of my life 113. Birth control practices should be accepted in a large city. by everyone. 82. Electricity fascinates me, 114, Jet air travel is one of the great advances 83. 1 like social gatherings where I can enjoy of our society. myself without worrying about other people. 115. f have vivid memories of the neighborhood 94. 1 don't think that 1 would ever want where 1 grew,up. to be hypnotized. 116. 1 would enjoy going to the opera. 83. Small-town life is too boring for me. 117. Today people are too isolated from the 86, Fertilizers improve the quality of food. forces of nature. 87. 1 often get the feeling that I just must bto alone. 118, It is easy for me to work undistracted 88. A person has a right to modify the in most situations. environment to suit his needs. 119. 1 like to dress in the latest fashions. 89. Sometimes I'm afraid of too much stimulation- 120, 1 seldom pay attention to what I eat. from sounds,colors. odors,etc. 121. 11 is dangerous to work around heavy machinery. 90. 1 understand the architectural idea that 122. The wilderness is cruel and harsh. form follows function. 123. Modern buildings are seldom as attractive 91. 1 would enjoy working in a Rower garden. as older ones. 5 =strongly agree / 4=agree / 3 =neutral / 2=disagree / 1 =strongly disagree 124. 1 like experimental art. 154. I like to say hello to my neighbors. 125. 1 often wish for the seclusion of a 155. 1 enjoy collecting things that most people weekend retreat. would consider junk. 126. 1 would like to own an expensive camera. 156. There are often times when I need 127. Building projects which disrupt the ecology complete silence. should be abandoned and the land returned 157. 1 worry a lot about the rising crime rate. to its natural state. 159. The cultural life of a big city is 128. The problems of the cities will never be solved, very important to me. 129. 1 am easily distracted by people moving about. 159. 1 like to go to shopping centers where 130. 1 often have trouble finding my way everything is in one place. around a new :area. 160. 1 am fond of oriental rugs. 131. In spite of all the talk about pollution, 161. I am afraid of heights. the earth is still a safe place to live. 162. People who try to repair appliances themselves 132. 1 need more variety in my life than other usually end up breaking them. people seem to need. 163. 1 would like to live in a palace or a castle. 133. 1 usually avoid public rest rooms. 164. Sight-seeing is tedious and boring, 134. I often have trouble figuring out how to use household appliances. 165. The cities contain the best aspects of 135. 1 usually enjoy having lots of people around. modem life. 136. 1 would enjoy watching movies made 166. It's nice to buy a new car every year or-so. 15 or 20 years ago. 167. Bathtubs have become obsolete. �- 137. Natural resources must be preserved even if 168. Places often play an important role in my dreams.a people must do without, 169. I would like to build a cabin in the woods. 138. 1 like to get up early to see the sun rise. 170. 1 enjoy being in dangerous places. 139. I am afraid of driving in the city. 171. Everyone should have the opportunity to live 140. Trespassing laws should be more in a great city. carefully enforced. 172. It's fun to walk in the rain even if you get wet. 141. 1 am an adventurous person. 173. Old buildings are usually depressing. 142. 1 often have strong emotional reactions 174. 1 would enjoy living on a houseboat. to buildings. 143. There is too little emphasis on privacy 175. Computers may someday take over the world. in our society. 176. 1 like to be on the move,not tied down 144. It is dangerous nowadays to live in a large city. to any one place. ' 177. Mental problems are more common in the city 145, 1 seldom vary the route 1 take to than in the country. everyday destinations. 146. It is important for me to feel that I am in 178. Odors often bring back distant memories. harmony with the forces of nature. 179, 1 like to care for animals. 147. When it comes to fixing things, I am hopeless. 180. A man should spend his leisure time at home 148. Modern communities are plastic and ugly. with his family. 181. if I had the money, I would enjoy owning 149. Science does as much harm as good. an expensive stereo set. 150. 1 get upset if 1 must do too many things at once. 182. 1 feel a great'attraction to the sea. 1.51. 1 would feel safer on the highway if 183. I would rather sleep on the open ground speed limits were reduced. . than in a tent. 152. 1 would like to take flying lessons. 184, Given enough-time,science will solve 153. Most jewelry is a waste of money. most human problems. Environmental Response lnvenittry by George E. McKechnic, ph.). Name, Agc Sn1._ Ym of Scunulinr. Matitat Siaw.,. of Chddtcn. Occupaaoo" _^____ Date,..— . Pace or Mt Ing---01hu_ Read the daeea6tt.4 on the rove: a%Ure ERI Booklet. 7hco filr in yuut name,and tither infutmaw.m requested above. Record your rrspome to caeh item in the hmrklet tit Cite squaw with the matching real tlar the five tesponse cefegorms' x 5 means strongly agree 114 means agree 13 means neutral 12 means disagree j I means strongly disagree. 1 1 24 47 10 9` 116 t3o i I IQ y 48 71 94 It? 140 16.1 I 26 44 72 95 [ IIN 141 UA 1 ' 4 so 13 14_vn� i ^ I I14' i 145 28 51 74 97 . 120 143 Ibi, 29 5' 75 96 121 1 14a 167 . 7 30 511 7t' 1 94 122 ISS I . 16g N 31 54 I 77t IUU 11: 146 I61, 4 3' 55 78 I 101 I 124 147 i 170 10 j} S6 ?9 102 ; 125 4N 17; IV 34 S' Rn 103 l2o 149 'm 150 173 .' 13 36 ( 59 k'- 10? :2N nil 1 174 14 3' I 6(i . Na ! Hkr I 121) SR � fit I [ h4 f 1U'1 I6 jo 6: H r5 j i IUg L 13!4(t [ I- 63 :u 1—� I091 132 i 1sS I'1h IN 41 IIn 133 t56 ;711 l I4 42 65 aN Ili 1.34 II------11 157 IRU 'tt 44 66 N9 1 II. i35 ISh INl i 21 44 67 qU 113"• 13b I:i2 1 114 [ 13' j [[ I6U 46 69 I 1 q_ Li 115 ! I 13N U 161 —__ __.— OU;CI AJil RIj1AM THIS LINI' PA t1R' to ss El AN NP M() CO 12 54 36 •12 120 1 134 24 I yN "i r oPri4:nt.19r.,ny{'onwlun}htycM1umynh hm�..lti,hn r gru4urlluu u<lat.tuna n Mr�i x•LLpuu(r�tnrr•lennh•wf. PROFILE SHEET FOR THE ENVIRONMENTAL RESPONSE INVENTORY : FEMALES Name Age Sex Dale Other Information PA UR EA SS ET AN NP Tad CO NOTES: IDO- -100 -110 _ _ 100 -90 _ioo 90 -110 -90 - _ 90 -90 _ -90 - -too BO - -- -..- _____....... ._..- . ...___._-�_. 80 90_ - _ w _ 90 50 90 _ - - - g0 _ - 90 -70 -7O - 0 60- ID To - -..._ 60 N 60 _ - -60 _ 70 _ _ m P SO 70_ 50 G w - _DO . _ 60 - .._------ 40 _ 60 - _ _ - 50 - - s0 —40 l0_ 30 -40 - 30 40 _ 40 - 40 - - - - - 30 - 60 _30 10 .t0 .. 30 30 -20 - - 30 - 20 D 0 PA UR EA SS ET AN NIP hf0 CO Reproduced from the hltmonl for the F.miranmctual Response Inventory. S'C opyrigln 1974.by CDn5VJlin$Psyclwl0siau Pray.Inc. tr � r PROFILE SHEET FOR THE ENVIROINNIL-NIAI- RESPONSE INVENTORY : MALES N FAnIt Agc Sex bate 01her Information I'A UR EA SS Fr AN NI' MO CO NOTES. ILA tOp • _na - 90 —tra _� _ — w Wo -•LLY.) .• so — 90 — 90 -70 so 90 ea — 60 70 er, 50 — en 50to c ._ so _ 00 _ c 6o ry 40 to - - - 5^ —s0 _ ro _ oe _ _ — _ S0 — 40 _ - - 20- lo. — 20 — 30 — 30 - - —20 P,\ LIR EA SS ET AN NI' 1110 Co r-. Appendix E Visual Acuity Test (Standard Eye.Chart) �I print full-size on 8.5x11 inch paper 200 Ft. 20 61 M 200 20 100 FT. T 100 30.5 M 37 1? !o 70 Fr. 10 21.3M 20 50D , FT. 152 M 20 FD12.2MPEC 20 "� D C Z p 9.14 M 30 'S F E L 0 P Z D 725 FT. 62M 20 D E F P Q T E 'C 20 FT. 20 6.10 M Appendix F Color Vision Test n n s Color Vision Test Dolor redness brier On Chadt � r-nter Cheek Tact kh�ps �KnAOK box for Test knapa aum!»r box for you sss rwns rau ssr oars r!• ,. . ;,,;, Nanber None • ,'' N+mber Notts r:• • + Tz Ntwnbsr Nam , ^ .Scf '� Nuff"t None f •i,� t`L y a "•' Nm W pkwa Notts Aj k l• %y,,,f . r Number fbns °'4 '° Nunber Nona r Y•` f"'r �•r i .Y 4 <1 Yr � 'T 1 i •�Y � tea x' •W �i�/!,�rt+ Nmber NON! • + �j `rS + Nu nbet Av- p ry iw s ' � •�� •� ! p Appendix G Field Instructions to Observers Appendix G — EXAMPLE Field instructions to study participants You are observer # You are participating in a study of the scenic beauty of rivers. We will visit eight (8) sites where you will be asked to give your opinion in the form of numerical ratings. At each site we visit today, you will use a rating sheet to record your observations. On the rating sheet, you will find a list of seven (7) aspects* of the water. Each aspect will have a rating scale numbered from 1 to 7. The number scale is: I = "unacceptable" 4 = "acceptable" 7 = "very attractive" or"very appropriate" Aspect I - - - 2 - - - 3 - - - 4 - - - 5 - - - 6 - - - 7 Circle the rating number or dash between numbers that corresponds to your opinion. Please give us your first impression. If your impression rating is between numbers, the dashes represent quarter points. For example, if your rating is 4.5, circle the middle dash between 4 and 5. Feel free to write comments in the spaces provided on any aspect of the rating and site. Please do not discuss or compare your ratings with the other observers during or after your site visit. Please do not use your cell phone, smart phone or wireless device until today's trip to observe river sites is concluded. Your Van Leader will collect your rating sheets as they are completed at each site. * Aspect of the water refers to its appearance or appropriateness for use. Appendix H Likert Rating,Scale c T'` Appendix H - EXAMPLE Site Observation Sheet Site # Observer # Look in the direction indicated by your Van Leader and rate the scenic beauty of that view. Circle the rating number or dash between numbers that corresponds to your opinion. The number scale is: 1 = unacceptable 4 = acceptable 7 = very attractive Upriver 1 - - - 2 - - - 3 - - - 4 - - - 5 - - - 6 - - - 7 Downriver 1 - - - 2 - - - 3 - - - 4 - - - 5 - - - 6 - - - 7 Comments: Now rate the appearance of the eater: Color 1 - - - 2 - - - 3 - - - 4 - - - 5 - - - 6 - - - 7 Clarity 1 - - - 2 - - - 3 - - - 4 - - - 5 - - - 6 - - - 7 Comments: Rate the site for its appropriateness for each of the following activities (disregard accessibility and water depth). Circle the rating number or dash between numbers that corresponds to your opinion. The number scale is: 1 = unacceptable 4 = acceptable 7 = very appropriate Wading 1 - - - 2 - - - 3 - - - 4 - - - 5 - - - 6 - - - 7 Swimming 1 - - - 2 - - - 3 - - - 4 - - - 5 - - - 6 - - - 7 Fishing 1 - - - 2 - - - 3 - - - 4 - - - 5 - - - 6 - - - 7 Rafting, canoeing, 1 - - - 2 - - - 3 - - - 4 - - - 5 - - - 6 - - - 7 boating Comments: Van Leader- record date and time the observation sheet was collected Appendix I Environmental Response Inventory Table 1: Environmental Response Inventory Scales HIGH SCORERS ARE OFTEN LOW SCORERS ARE OFTEN DESCRIBED AS: SCALE AND MAJOR THEMES: DESCRIBED AS: Aesthatic,affectionate.complicated,dis- PA(Paatmaiism).Opposition to land develop Apathetic, comcieotious, eomervadve. tracdble. outspoken, prosmulve, rebel- wont;concern about population glovith;omser. conventional. deliberate, dependable,. [loue, unconventional, unpredictable, vation of austral resomcm, including open friendly,honest,practical,self-controlled. selfish. - apace:acceptance of natural forces as shapers of human life;sensitivity to pure environmental experiences: self-sufBaieoey in the naturs] emviroamemt. Critical, skeptical. responsive to urban UA (Urbanism). Eyoymaot of high density Conscientious, conventional, friendly, aesthetics, highbrow, eoaeeraed with living. appreciation of unusual and varied Sorwous, nonverbal, opportumuic, to. philosophical problems in line,valuing ten- stimulus pattems of the city;interest in cultural bust,simple.unselfish. teliecwal nativity.managerial.interests, We; erJoymem of intervenors] rielmess and diversity. Autocratic,eondesoegdlinii,conservative. BA(Environmental Adaptation). Modification• ANstia.awkward.compassionate.canons, efficient.enterprising, extroverted, bard- oftbe environmeatto sandy needs and desires, distractible. idealistic, introspective, headed.mannerly,methodical,power and and to provide eoedom and kisoe:opposition moody, nonconforming. sensitive, son- money oriented.judgemental.aesthetically to governmental cannot over private lard use: snow,vrotymg,forthright. unresponsive. pretersove for highly designed or adapted on. vbenmenu:on oftechoology,to solveenvuon. mantel probiears; prclamce.for eylimd'en- vimnmental details. Adventurous, disorderly, distraenble. SS (Stimulus Seeking). Interest In travef and Conscientious, conservative, fastidious, dreamy.easy-going,immature.impulsive, exploration-of unusual places; enjoyment of practical,responsible,rigid,severe,stingy. progressive, unconventional, undepend- complex and intense physical sensations; able. breadth ofinlererte. Capable, competent, diligent, efficient, Et (Eavlmnmcoul Trutt). General environ. Bitter,cold.wane,dissatisfied,distrruh . halpful. ingenious, msoaroelul, stable, mental opbrums. responsiveness. and trust. ful intolerant, moody,prgludiced,spead- thorough,tolerant,web-adjusted. eompstwoe-in gndiog oui tray about she thrift.unkind. environment vs. fear of poteatiilly davgesws environments:security of home;fear of being . alone and unprotected, , Af ectiomate. animic, changeable, de- AN (Antiquarianism). Fajoyment of antiques Coarse, cool, conservative, deliberate, pendent, dreamy, emotional, forgiving„ and historical places;preference for traditional mischievous. moralistic, practical; sly, idealistic. Imrospec(ivC, aesthetically vs. modem design. eathtdc sensitivity to stolid.unemotional. reactive,warm. man-made environments and to landscape: . j appreciation of cultural anifec s of cull r eras; tendency to collect objects for their emodonal ' slgnifieance. Aloof, anviomt, autocratic, bittar, cold, NP (Need for Privacy). Need for physical Appreciative, cooperative, easy-going, format. hard-hearted, sulky, polished. itokdon from stimuli: enjoyment or solitude; friendly;seeking reauuraate,warm,seeks resentful,stubborn, dislike of neighboring; teed for freedom from acceptance,lacks confidence,introverted. distraction Amspm, conceited, egotistical, hard- MO (Metbankatl Orientation). Interest in Affectionate,feminine,generous,sincere. boomed.maseulint:.seU-suking.iniknbk. mechanics in its various fortes:enjoyment in understanding. submissive, sympathetic. . sociable,maoipuletive, working with ones hands;interest in tecbno- warm. logical prnteseaand basicprineiplesofsekace: appreciation of the functional properties of- Calm. civilized, initiatory, mannerly, pa. CO (Communality). A validity scale. Lopping. HW-headed,flistatiout.good looking.im- tint.tactful,trusting,mie-tollowing. honest, attentive, and careful tost-taking end- mature, opportunistic, "natik. witty. tude: response to hems in statistically modal independemt-minded, psychologically tanner. complex, .. �� . 2 r