NC0000272_Technology Review Workgroup docs Color Removal_20080225

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�m 'z UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
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February 25,2009 OFFICE OF
WATER
Memorandum
Subject: Additional Color Removal.Opportunities,Blue Ridge Paper Product's(BRPP)
Canton,NC Bleached Kraft Paper Mill, 2008 NPDES Permit Renewal
From: Technology Review Workgroup(TRW) ;i
Donald Anderson, Chair, EPA p� tivr tl 1
Karrie-Jo Shell,EPA Region IV
Marshall Hyatt,EPA Region IV
Paul Davis,Tennessee DEC
David McKinney, Tennessee DEC
Roger Edwards,North Carolina DNR
Sergei Chemikov,North Carolina DNR
To: North Carolina Division of Water Quality and the NC Environmental
Management Commission's NPDES Sub-Committee
Since the 1997 NPDES Permit Settlement Agreement for the Canton Mill,the Technology
Review Workgroup (TRW)has examined the progress made at the facility in relation to reducing
the color content of the Mill's effluent and the potential for additional color reduction at the Mill.
The focus of this examination includes a review of reports and data submitted by Blue Ridge
Paper Products (BRPP),information and data gathered attendant to a visit to the Mill on
February 8,2007 by EPA's Technology Team (Tech Team)and TRW members,and
consultation among the EPA Tech Team and the TRW's members.
The TRW notes that the Tech Team submitted a Memorandum,publicly released by EPA
Region 4 and dated September 5, 2007, including findings and recommendations for further
color reduction based upon its data gathering and analyses. The TRW also notes,comments
submitted from BRPP, separate from the State of North Carolina comments submitted by letter
dated September 14, 2007,which took exception to some of the findings and recommendations
in the Tech Team Memorandum. Further,a meeting of the TRW was held in Asheville,NC on
October 23,2007,to discuss and attempt to come to resolution on these comments. Also in
response,the Tech Team prepared responses to these comments and an Addendum to the Tech
Team Memorandum. All of these documents are included as attachments to this TRW
memorandum. These documents represent'an appropriate evaluation of the potential for further
color reduction at the Mill over the upcoming permit cycle (estimated to be 2008 through 2013).
The original Tech Team report,BRPP and NC DWQ comments and Tech Team Responses to
NC DWQ comments, TRW meetings and discussions, addendum to the Tech Team report,and
other public comments,form the basis for the TRW's attached,recommendations to the Division
Internet Address(URL)• httpl/www.epa.gov
RecycletllRecyclable•Printed with Vegetable Oil Based Inks on 100%Postconsumer.Process Chlorine Free Recycled Paper

2
of Water Quality and the Environmental Management Commission's NPDES Sub-Committee as
guidance for developing the effluent limitations for color and related special conditions of the
draft NPDES Permit renewal. The TRW also notes that public interest organizations separately
provided their comments to the State of North Carolina.
The TRW recognizes and concludes that not all of the options outlined in the Tech Team
Memorandum can be predicted to achieve specific color reductions with complete accuracy.
Consequently this Memorandum from the TRW provides,where appropriate,estimates of an
aggregate range of likely color reduction from the application of a group of specific technologies
that are available. In making these recommendations,the TRW relied on the following basic
tenets:
• The highest priority for additional color reduction rests with additional in-mill
improvements,particularly considering the success already achieved by continuing
improvements in leak and spill prevention and control (Best Management Practices
BMPs) and process modifications and changes.
• As in-mill technologies are exhausted, segregated waste stream pretreatment and end-of-
pipe treatment technologies,while they may reflect significant economic,technical,and
non-water quality environmental impact issues at this mill,must also be considered
carefully as supplementary options.
In presenting these attached recommendations to the Division of Water Quality and the
Environmental Management Commission's NPDES Sub-Committee,the TRW wishes to
acknowledge the excellent success achieved since the 1997 Settlement Agreement and the
continued effort of BRPP to improve on this record. Very difficult and unusual circumstances
occurred in 2004,with back-to-back historical flooding of the Pigeon River and associated
significant costs ($39 million) for repairing damage and replacing equipment at the BRPP mill
after 21 days of being out of operation. The TRW also recognizes that significant additional
expenditures have been made by BRPP over the last permit term for environmental projects
($25.9 million),the largest portion for air pollution controls (e.g.,MACT I and MACT II
compliance) and including color reduction projects($5.9 million), all building on previous
projects and expenditures. All of this has occurred during a continuing and difficult period of
industry-wide transformation, capacity shrinkage, and mill closings. Nonetheless,the BRPP mill
management has committed to surviving these challenges. These efforts and expenditures have
resulted in substantial and commendable progress made to date by BRPP through additional and
improved best management practices,process and related technologies, and incremental
improvements in treatment system performance which have reduced the long term average color
discharges. It is also noteworthy that some of these technologies and practices have been
implemented by BRPP in addition to those identified in the previous Tech Team and TRW
reviews. The TRW notes that through these efforts the long term average end-of-pipe color
discharge from the mill has been reduced from approximately 42,300 lbs/day in 2001 to
approximately 37,100 lbs/day in 2006. While the Canton Mill is among world leaders in the
pulp and paper industry as measured by the quality of its treated effluent, the commitment of
BRPP,the availability of other potential color reduction technologies, and the continued interest

3
and participation in this process by the regulatory agencies,stakeholder public and
environmental interest groups, and the general public makes additional improvement during the
upcoming permit cycle appropriate.
If there are questions concerning the attached recommendation,please feel free to contact the
TRW.
Attachments: 1) TRW Recommendations
2) Memorandum from EPA Tech Team to the TRW, entitled,Additional
Color Removal Technologies for Blue Ridge Paper Products, Canton,NC,
dated September 5, 2007
3) NC DWQ comments on draft Tech Team report,.dated September 14,
2007
4) Tech Team Responses to NC DWQ and(Indirectly)to BRPP Comments
5) Addendum to Memorandum from Tech Team to the TRW
6) Available upon request-electronic files with:
➢ Submissions from BRPP in response to Tech Team requests
➢ BRPP comments, dated June 4, 2007, on first draft Tech Team
Memorandum
➢ Telecon with EPA Tech Team on July 25,2007 (agenda and notes)
➢ BRPP comments dated July 26, 2007 on second draft Tech Team
Memorandum
➢ Data for color discharge,production,various Tech Team analyses
of data, etc.
4

4
TRW Recommendations
The options needing further study should be incorporated in the permit as an additional
increment of color reduction to be demonstrated by the Mill. BRPP should be required to
evaluate the technologies identified below and to develop an implementation plan that would
either utilize these technologies when technically, operationally,or economically feasible,or
identify other options that would result in similar increments of color reduction. The TRW
recommends that it be allowed to review and comment on the justification for any item among
the following recommendations found by BRPP to be technically, operationally,or economically
infeasible.
1. The following suite of items should be implemented,upon further expedited evaluation if
necessary to refine detailed design and operating parameters, during the upcoming permit
cycle:
A. further improvements in leak and spill prevention and control (BMP's) covering
all process lines, including probable color-generating sources (e.g., sulfide
containing) among white and green liquors in the recovery cycle
B. process optimization(enhanced extraction stages,reduced bleaching chemical
use, etc.); and
C. addition of second stage oxygen delignification on the softwood/pine fiber line
The time necessary for BRPP to implement these items in logical sequence should
realistically reflect the Mill's ability to design, fund, and install them at the earliest
possible date. For example, an updated and detailed evaluation of the addition of second
stage oxygen delignification on the softwood fiber line should identify,necessary
adjustments to upstream pulp digestion (e.g.,kappa number targets),bleaching(e.g.,
bleaching chemical usage rates,kappa factors) and downstream brightness/strength and
other relevant process control and product quality parameters, designing and costing,and
refining color reduction projections.
2. The following items also should be evaluated and implemented as appropriate during the
upcoming permit cycle:
A. increasing filtrate recycle and use of the existing BFR process for the hardwood
fiber line
B. reducing black liquor carryover by further evaluating in detail and adjusting
operating conditions in the direct contact evaporators (DCEs)
C. reducing impact of Chloride Removal Process (CRP)purge on treated effluent
color by gathering data sets over as long a period as possible,preferably at full
scale,with and without the CRP purge to better inform the treatability of this
source of color. If CRP color is found not to be removed in the treatment system,
further study should assess:

5
o securing whatever additional reductions are possible based on any
demonstrated technology that works and can be economically applied to
this waste stream, either within the mill and sewer system, or chlorine
dioxide pretreatment to reduce color in the CRP purge stream prior to
introduction to the treatment system, or through end-of-pipe activated
sludge biological wastewater treatment system
o avoiding release of the CRP purge during periods of low flow in the
receiving stream
D. better understanding and controlling the physical and chemical mechanisms
underlying"sewer generated color;"this will require a sustained effort going
forward beyond the upcoming permit term given that process changes and BMP
improvements to be made during the upcoming permit term will more than likely
further change the chemistry and mechanisms underlying"sewer generated color"
E. improving color removal by the Mill's wastewater treatment plant via
o better equalizing and further optimizing treatment by using polymers
and other chemicals to pretreat highly-colored segregated wastewaters
including streams that are diverted to the extra primary clarifier, or by
other operational and/or treatment means not yet identified
o investigating use of polymers or other chemicals upstream of the
secondary clarifiers, especially during periods of high influent color
and/or low river flow
3. Contrary to past practice for lowest certainty options, the TRW does not consider it
necessary for BRPP to study further the Ozone-Chlorine Dioxide(ZD)process change
within the upcoming permit cycle. However, the TRW does consider the ZD process an
available option beyond the upcoming permit cycle if further reductions in color
discharges are found to be necessary.
4. The permit should continue to require BRPP to report on or identify any"breakthrough"
color reduction technologies developed at the Mill or that become available within the
industry or the research community.
5. While the current permit does apply color limits at the effluent discharge point,the
permit issued for the upcoming term should clearly reflect that the color limits and
sampling point for color compliance is the Mill's end-of-pipe discharge point to the
Pigeon River.
6. The permit to be issued for the upcoming permit term should include an immediately
effective maximum day effluent limitation for color based upon current operations and
data representing recent long term performance, as it relates to capturing and better
controlling day-to-day effluent variability. Some TRW members raised short term
variability as a significant concern that should be addressed in the upcoming permit
cycle.

6
7. After implementing and putting into operation additional technologies and practices per
the above recommendations,but no later than the end of the upcoming permit term, the
permit should require an effluent target range of 32,000—37,000 lbs/day as an annual
average. Data on effluent color loadings should be statistically evaluated to develop a
revised annual average within this range, along with 30-day average and maximum day
effluent limitations for color,by the end of the upcoming permit term which capture
actual day-to-day variability at the end-of-pipe immediately prior to discharge to the
Pigeon River. The Division of Water Quality should apply those revised effluent
limitations in the permit through formal notification.
8. The permit should require a formal evaluation with periodic update reports as well as any
necessary permit reopeners regarding color reduction efforts.

ATTACHMENTS

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FINAL DRAFT-February 14, 2008
Memorandum
Subject: Additional Color Removal Opportunities, Blue Ridge Paper Product's (BRPP)
Canton, NC Bleached Kraft Paper Mill,2008 NPDES Permit Renewal
From: Technology Review Workgroup (TRW)
Donald Anderson, Chair, EPA
Karrie-Jo Shell, EPA Region IV
Marshall Hyatt, EPA Region IV
Paul Davis, Tennessee DEC
David McKinney, Tennessee DEC
Roger Edwards,North Carolina DNR
Sergei Chernikov,North Carolina DNR
To: North Carolina Division of Water Quality and the NC Environmental
Management Commission's NPDES Sub-Committee
Since the 1997 NPDES Permit Settlement Agreement for the Canton Mill, the Technology
Review Workgroup (TRW) has examined the progress made at the facility in relation to reducing
the color content of the Mill's effluent and the potential for additional color reduction at the Mill.
The focus of this examination includes a'review of reports and data submitted by Blue Ridge
Paper Products (BRPP), information and data gathered attendant to a visit to the Mill on
February 8, 2007 by EPA's Technology Team (Tech Team) and TRW members, and
consultation among the EPA Tech Team and the TRW's members.
The TRW notes that the Tech Team submitted a Memorandum, publicly released by EPA
Region 4 and dated September 5, 2007, including findings and recommendations for further
color reduction based upon its data gathering and analyses. The TRW also notes comments
submitted from BRPP, separate from the State of North Carolina comments submitted by letter
dated September 14, 2007,which took exception to some of the findings and recommendations
in the Tech Team Memorandum. Further, a meeting of the TRW was held in Asheville,NC on
October 23, 2007, to discuss and attempt to come to resolution on these comments. Also in
response,the Tech Team prepared responses to these comments and an Addendum to the Tech
Team Memorandum. All of these documents are included as attachments to this TRW
memorandum. These documents represent an appropriate evaluation of the potential for further
color reduction at the Mill over the upcoming permit cycle (estimated to be 20.08 through 2013).
The original Tech Team report, BRPP and NC DWQ comments and Tech Team Responses to
NC DWQ comments, TRW meetings and discussions, addendum to the Tech Team report, and
other public comments form the basis for the TRW's attached recommendations,to the Division
of Water Quality and the Environmental Management Commission's NPDES Sub-Committee as
guidance for developing the effluent limitations for color and related special conditions of the

ppppp�
draft NPDES Permit renewal. The TRW also notes that public interest organizations separately
provided their comments to the State of North Carolina.
The TRW recognizes and concludes that not all of the options outlined in the Tech Team
Memorandum can be predicted to achieve specific color reductions with complete accuracy.
Consequently this Memorandum from the TRW provides,where appropriate, estimates of
possible reductions and an aggregate range of likely color reduction from the application of a
likely group of specific technologies that are available. In making these recommendations, the
TRW relied on the following basic tenets:
• The highest priority for additional color reduction rests with additional in-mill
improvements,particularly considering the success already achieved by continuing
improvements in leak and spill prevention and control(Best Management Practices—
BMPs) and process modifications and changes.
• As in-mill technologies are exhausted, segregated waste stream pretreatment and end-of-
pipe treatment technologies,while they may reflect significant economic,technical, and
non-water quality environmental impact issues at this mill,must also be considered
carefully as supplementary options.
In presenting these attached recommendations to the Division of Water Quality and the
Environmental Management Commission's NPDES Sub-Committee, the TRW wishes to
acknowledge the excellent success achieved since the 1997 Settlement Agreement and the
continued effort of BRPP to improve on this record. Very difficult and unusual circumstances
occurred in 2004,with back-to-back historical flooding of the Pigeon River and associated
significant costs ($39 million) for repairing damage and replacing equipment at the BRPP mill
after 21 days of being out of operation. The TRW also recognizes that significant additional
expenditures have been made by BRPP over the last permit term for environmental projects
($25.9 million), the largest portion for air pollution controls (e.g., MACT I and MACT 11
compliance) and including color reduction projects ($5.9 million), all building on previous
projects and expenditures. All of this has occurred during a continuing and difficult period of
industry-wide transformation, capacity shrinkage, and mill closings. Nonetheless, the BRPP mill
management has committed to surviving these challenges. These efforts and expenditures have
resulted in substantial and commendable progress made to date by BRPP through additional and
improved best management practices, process and related technologies, and incremental
improvements in treatment system performance which have reduced the long term average color
discharges. It is also noteworthy that some of these technologies and practices have been
implemented by BRPP in addition to those identified in the previous Tech Team and TRW
reviews. The TRW notes that through these efforts the long term average end-of-pipe color
discharge from the mill has been reduced from approximately 42,300 lbs/day in 2001 to
approximately 37,100 lbs/day in 2006. While the Canton Mill is among world leaders in the
pulp and paper industry as measured by the quality of its treated effluent, the commitment of
BRPP, the availability of other potential color reduction technologies, and the continued interest
and participation in this process by the regulatory agencies, stakeholder public and

ppppr,
environmental interest groups, and the general public makes additional improvement during the
upcoming,permit cycle appropriate.
If there are questions concerning the attached recommendation,please feel free to contact the
TRW.
Attachments: 1) TRW Recommendations
2) Memorandum from EPA Tech Team to the TRW, entitled, Additional
Color Removal Technologies for Blue Ridge Paper Products, Canton,NC,
dated September 5, 2007
3) BRPP comments on draft(s) Tech Team Memorandum: dated June 4,
2007, Telecon with EPA Tech Team on July 25,2007 (telecon agenda and
notes); and dated July 26, 2007(electronic files with detailed comments
available separately)
4) NC DWQ comments on draft Tech Team report, dated September 14,
2007
5) Tech Team Responses to NC DWQ and (Indirectly) to BRPP Comments
6) Addendum to Memorandum from Tech Team to the TRW
7) Electronic data files from BRPP for color discharge,production, various
Tech Team analyses of data, etc,

ppppp�
TRW Recommendations
The options needing further study should be incorporated in the permit as an additional
increment of color reduction to be demonstrated by the Mill. BRPP should be required to
evaluate the technologies identified below and to develop an implementation plan that would
either utilize these technologies or identify other options that would result in similar increments
of color reduction. The TRW recommends that it be allowed to review and comment on the
justification for any item among the following recommendations found by BRPP to be
technically, operationally, or economically infeasible.
1. The following suite of items should be implemented,upon further expedited evaluation if
necessary to refine detailed design and operating parameters, during the upcoming permit
cycle:
^'�,�,, A. M further improvements in leak and spill prevention and control (BPs) covering A�
'""" " D�e�'"lda�yalso white and green liquor source's in the recovery cycle;.
B. process optimization(enhanced extraction stages,reduced bleaching chemical
use, eta); and
C. addition of second stage oxygen delignification on the softwood/pine fiber line
The time necessary for BRPP to implement these items in logical sequence should
realistically reflect the Mill's ability to design, fund, and install them at the earliest
possible date. For example, an updated and detailed evaluation of the addition of second
stage oxygen delignification on the softwood fiber line should identify necessary
adjustments to upstream pulp digestion (e.g.,kappa number targets), bleaching (e.g.,
bleaching chemical usage rates, kappa factors) and downstream brightness/strength and
other relevant process control and product quality parameters, designing and costing, and
refining color reduction projections.
2. The following items also should be evaluated and implemented as appropriate during the
upcoming permit cycle:
A. increasing filtrate recycle and use of the existing BFR process for the hardwood
fiber line
B. reducing black liquor carryover by further evaluating in detail and adjusting
operating conditions in the direct contact evaporators (DCEs)
C. reducing impact of Chloride Removal Process (CRP) purge on treated effluent
color by gathering data sets over as long a period as possible,preferably at full
scale,with and without the CRP purge to better inform the treatability of this
source of color. If CRP color is found not to be removed in the treatment system,
further study should assess:

ppppp�
o securing whatever additional reductions are possible based on any
demonstrated technology that works and can be economically applied to
this waste stream, either within the mill and sewer system, or chlorine
dioxide pretreatment to reduce color in the CRP purge stream prior to
introduction to the treatment system, or through end-of-pipe activated
sludge biological wastewater treatment system
o avoiding release of the CRP purge during periods of low flow in the
receiving stream ,
D. better understanding and controlling the physical and chemical mechanisms
underlying "sewer generated color;"this will require a sustained effort going
forward beyond the upcoming permit term given that process changes and BMP
improvements to be made during the upcoming permit term will more than likely
further change the chemistry and mechanisms underlying "sewer generated color"
E. improving color removal by the Mill's wastewater treatment plant via
o better equalizing and further optimizing treatment by using polymers
and other chemicals to pretreat highly-colored segregated wastewaters
including streams that are diverted to the extra primary clarifier, or by
other operational and/or treatment means not yet identified
o investigating use of polymers or other chemicals upstream of the
secondary clarifiers, especially during periods of high influent color
and/or low river flow
3. Contrary to past practice for lowest certainty options; the TRW does not consider it
necessary for BRPP to study further the Ozone- Chlorine Dioxide (ZD)process change
within the upcoming permit cycle. However, the TRW does consider the ZD process an
available option beyond the upcoming permit cycle if further reductions in color
discharges are found to be necessary.
4. The permit should continue to require BRPP to report on or identify any"breakthrough"
color reduction technologies developed at the Mill or that become available within the
industry or the research community.
5. While the current permit does apply color limits at the effluent discharge point, the
permit issued for the upcoming term should clearly reflect that the color limits and
sampling point for color compliance is the Mill's end-of-pipe discharge point to the
Pigeon River.
6. The permit to be issued for the upcoming permit term should include an immediately
effective maximum day effluent limitation for color based upon current operations and
data representing recent long term performance, as it relates to capturing and better
controlling day-to-day effluent variability. Some TRW members raised short term
variability as a significant concern that should be addressed in the upcoming permit
cycle.

ppppp�
7. After implementing and putting into operation additional technologies and practices per
the above recommendations,but no later than the end of the upcoming permit term, the
permit should require an effluent target range of 32,000—37,000 lbs/day as an annual
average. Data on effluent color loadings should be statistically evaluated to develop a
revised annual average within this range, along with 30-.day average and maximum day
effluent limitations for color, by the end of the upcoming permit term which capture
actual day-to-day variability at the end-of-pipe immediately prior to discharge to the
Pigeon River. The Division of Water Quality should apply those revised effluent limits
in the permit through formal notification.
8. The permit should require a formal evaluation with periodic update reports as well as any
necessary permit reopeners regarding color reduction efforts.

onse to NC's comments on draft TRW memo
Subject: Reg 4 response to NC's comments on draft TRW memo
From: [e-mail]
Date: Wed, 6 Feb 2008 15:20:09 -0500
To: [e-mail]
CC: [e-mail],[e-mail],[e-mail], Sergei
Chernikov<[e-mail]>, [e-mail]
sorry for the delay in getting these to you . . . .
Region 4 has concerns with some of NC's comments and suggested changes.
If not mentioned specifically below, Region 4 agrees with NC's proposed
changes.
Last sentence on pg. 2': changing "...makes additional improvement at
this time and in the future appropriate and possible" to "..makes
additional improvement in the future appropriate".
EPA disagrees with the proposed deletion_ This implies that no
reduction may occur "during the upcoming permit, which we view as highly
unlikely.
- Why has the NC Environmental Management Commission's NPDES
Sub-Committee been deleted as an addressee? The 1997 Settlement has
several provisions where the TRW provides recommendations or information
directly to the NPDES Sub-Committee. Also, the previous 2001 TRW letter
was addressed to the NPDES Sub-Committee.
-.pg. 4 - addition of the phrase "technically, economically and
operationally feasible" in several places
Region 4 does not agree with the use of this phrase for several reasons.
First, the previous 2001 TRW letter, stated "As the purpose of the TRW is
to provide a-review of the possible technology options available to the
Mill to further reduce the color discharge to the Pigeon River. . ."
Region 4 believes this is still the purpose of the TRW - to evaluate
possibleoptions. Assuming that NC and TN agree that that it is still
our purpose, exploring possibleoptions already implies that -some options
may not be implemented for a variety of reasons.
Second, .use of this phrase is redundant and adds a level of uncertainty
about what will actually be implemented. The very first sentence in the
recommendation section already begins with "The options needing further
study..." Use of that introductory phrase already indicates that the TRW
does not necessarily expect that all the options .will automatically be
implemented.
Third, use of this phrase is not needed because the introductory
paragraph in the recommendation section already ends with "...or identify
other options that would result in similar increments of color
reduction." This requirement is re-stated just above item 2. NC, TN,
and EPA have already agreed that BRPP will be required to achieve the
color reductions specified whether the initial suite of items is
implemented or not. Use of NC's phrase is superfluous based on this
agreed-to requirement.
- pg. 4, item '1.A - deletion of "covering also white and green liquor
1 of 2 2/7/2008 7:32 AM

nse to NC's comments on draft TRW memo
sources in the recovery cycle" from "further improvements in leak and
spill prevention and control (BMPs)"
Region 4 strongly disagrees with this deletion. The EPA Tech Team
report indicated likely improvements in addressing white and green .
liquor sources are well known and can be implemented. The EPA Tech Team
report repeated this recommendation several times.
- pg. 5, item 2.C.1 - deletion of references to chlorine dioxide
pretreatment and activated sludge
Region 4 disagrees with these deletions. We believe both areas should
be specifically evaluated.
pg. 5, item 2.D - inclusion of "possible" and "may be possible" to
sewer generated color
discussion
r
Region 4 disagrees with the need for these terms of uncertainty to be
added. Sewer generated color needs sustained attention to understand
and control and should be evaluated during the upcoming permit term.
- pg. 5 - Item 2.E - "evaluate improving color removal..." rather than
"improving color removal"
Region 4 does not support use of "evaluate". Region 4's view of the EPA
Tech Team report is that the specific bullets mentioned here can and
should be implemented by BRPP.
pg. 5 - Item 6- a daily maximum color limit in the upcoming permit
should be consideredby NC and evaluated in relation to its potential
benefits
Region 4 strongly disagrees with NC's proposed changes. Use of a daily
maximum limit is mandated by 40 CFR Part 122.45(d) (1) - the regulations
do not allow for consideration of potential benefits. Region 4 recalls
from the October Asheville meeting that NC agreed with inclusion of
daily maximum color limits at that time and acknowledged the NPDES
regulation cited ,above. Daily maximum limits should be applied at the
beginning of the upcoming permit term and then revised at the end of
that cycle to reflect the improvement(s) made in the interim.
- pg. 6 - Item 9 - NC's suggested changes in the membership of the TRW
and that TRW recommendations should be provided on a set schedule
Region 4 does not agree with NC's proposed changes to the TRW's
membership. Region 4 believes the existing TRW membership has worked
well during the previous times it was involved in this process.
Previous TRW recommendations have always been unanimous. Region 4 is
not aware of any assertion of conflict of interest or bias based 'on the
existing TRW membership. Region 4 also does not believe that it is
practical or possible to provide TRW recommendations on a set schedule,
although that should be its goal.
2 of 2 2/7/2008 7:32 AM

omments on proposed edits to the TRW Memo
Subject: Re: TDEC's comments on proposed edits to the TRW Memo
From: "Paul.Estill Davis" <[e-mail]>
Date: Wed, 06 Feb 2008 22:12:10 -0600
To: <[e-mail]>, <[e-mail]>,
<[e-mail]>, <[e-mail]>,
"[e-mail]" <[e-mail]>, "Dave McKinney
<[e-mail]>
Sergei - you're correct on that. We submitted no comments on the Tech Team report..
Don - are you still looking at this Friday for a conference call?
Thanks. Paul
Paul E. Davis, P.E.
Director, Division of Water Pollution Control
Tennessee Department of Environment and Conservation
615/532-0632
[e-mail]
I I "[e-mail]" <[e-mail]> 2/6/2008 8:23 � II
AM >>>
Paul;
Thank you for comments! Hopefully we can discuss them soon. We also
would like to request TN comments on Tech Team Report, we have never
received your comments in writing. If I remember it correctly, you were
in agreement with Tech Team Report and did not have any comments. If
this is your official position itshould not be difficult or time
consuming to put it in writing on your official letterhead and mail it
to us.
Thank you!
Sergei
1 of 1 2/7/2008 7:31 AM

Vub
ntson proposed edits to the TRW Memo
ect: TDEC's continents on proposed edits to the TRW Memo
From: "Paul.Estill Davis" <[e-mail]>
Date: Mon, 04 Feb 2008 23:57:17 -0600
To: <[e-mail]>, <[e-mail]>,
<[e-mail]>, <[e-mail]>, "Sergei Chernikov"
<[e-mail]>, "Dave McKinney" <[e-mail]>
All - this will set out TDEC's comments .on the TRW memo and changes proposed by
NCDWQ. I. have discussed these comments with Tennessee's other TRW member, David
McKinney of TWRA, and I believe we are in full agreement. But I will leave it to
David to add any further comments he might wish'to present.
I will limit my review here to the "TRW Recommendations" part of the memo. .
Generally, I find many of the proposed changes to be matters of style, not
representing substantive change. This includes edits such as changing from
"discharge color" to "color" and rewriting the "2008 - 2013 term" as the "upcoming
permit cycle." I don't see those changes as necessary, but neither do I find them
objectionable. Several of the more substantive proposed changes are at odds with
Tennessee's position that this permittee must continue to make the best possible
progress toward full protection of our waters. As set out below, 'I can't agree to
those changes.
My comments are organized by the recommendation numbers in the original document.
Introductory Paragraph and Recommendation 1 - TDEC cannot agree to these proposed
changes. NCDWQ accepted the recommended effluent color target range, and did not
propose to change the recommendation that If any recommended technologies cannot be
implemented, ". . .BRPP should be required to identify other options that would result
in similar increments of color reduction." The recommendation as drafted provides
sufficient latitude for BRPP to assert that technologies are infeasible, with such
assertion then to be reviewed by the. TRW. So there would seem to be no need to add
additional and potentially confusing conditioning phrases such as ". . .when
technically, economically and operationally feasible. . ." and ". . .provided these
items are. found to be technically, economically and operationally feasible. . .".
Recommendation 3 - TDEC objects to the proposed change regarding periods of low
stream flow. During recent low flows color in the Tennessee portion of the river has
been particularly objectionable.
Recommendation 7 - TDEC objects to the proposal that we should drop the
recommendation for a ' maximum day effluent limit for color to a recommendation that
such limitation be considered. NPDES rules require daily mass limits for this
discharge. And, since this is a very significant flow in relation to the receiving
stream, it's appropriate to protect against slug loading.
Recommendation 8 - TDEC can't agree to delete the recommendation that monthly and
daily limitations should be developed during the coming permit term.
Recommendation 10 - TDEC favors the original language in this section- We can at
some point discuss whether a different composition of the Tech Team and Workgroup
better serves the process. I don't at this point see why that should change, but
would be open to discussion. I don't object to deleting the phrase "requests the
opportunity to" in the second sentence.
I'm holding most of this Friday in case we will be doing a conference call to
discuss.
Paul E. Davis, P.E.
Director, Division of Water Pollution Control
Tennessee Department of Environment and Conservation
615/532-0632
1 of 4 2/5/2008 7:58 AM

rpaule,.ts on proposed edits to the TRW Memo
[e-mail]
i <[e-mail]> 1/30/2008 12:09 PM >>> , III
Sergei -
TN and R9 have agreed to give us comments. Then we will have a conf.
call to discuss and act on all. of them re: the content of the final TRW
memo.
Don
Sergei Chernikov
<sergei.cherniko
[e-mail]> To
DonaldF Anderson/DC/USEPA/US@EPA
01/29/2008 09:19 cc
AM
Subject
ke: TRW Memo
Don,
Why are we scheduling a conference call? We already discussed our
comments and agreed that now it's time for Tennessee and EPA to provide
comments. Then, it would make sense to have a discussion of the new ,
comments.
Sergei
[e-mail] wrote:
All -
Please let me know when you will have time within the next few days as
options for scheduling a conference call to discuss NC's comments and
the TRW's next steps. Thx,
Don
Sergei Chernikov
<sergei.cherniko
2 of 4 2/5/2008 7:58 AM

rent.,on proposed edits to the TRW Memo
[e-mail]> To
DonaldF Anderson/DC/USEPA/US@EPA I
01/23/2008 09:16 cc
AM Roger Edwards
<[e-mail]>, Ahmar I
Siddiqui/DC/USEPA/US@EPA, Betsy I
Bicknell
<[e-mail]>,
[e-mail],
[e-mail],
[e-mail]..us, Maryt
Smith/DC/USEPA/US@EPA, Richard
Reding/DC/USEPA/US@EPA, Karrie-Jo
Shell/R4/USEPA/US@EPA, Marshall I
Hyatt/R4/USEPA/US@EPA,
[e-mail],
' [e-mail],
ISusan Wilson
<[e-mail]>
Subject I
TRW Memo I
3 of 4 2/5/2008 7:58 AM

rents on proposed edits to the TRW Memo
Don,
Attached is the TRW Memo with our suggested corrections. Sorry for not
delivering it last Friday! It took a few days to get it through the
chain for command, and holiday on Monday did not help. If these
corrections are acceptable, we will proceed with the permitting.
process.
Sergei
Sergei Chernikov, Ph.D.
Environmental Engineer
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
phone: [phone] ext. 594
fax: [phone]
[attachment "DWQ comments on TRW recommendations-1.doc" deleted by
DonaldF Anderson/DC/USEPA/US]
Sergei Chernikov, Ph.D.
Environmental Engineer
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
phone: [phone] ext. 594
fax: [phone]
TRWrcmndtnBRPP2007.121907.doc Content-Type: application/msword
Content-Encoding: base64
Content-Type: application/msword
DWQ comments on TRW recommendations-l.docl
Content-Encoding: base64
4 of4 2/5/2008 7:58 AM

Subject: TRW Memo
From: Sergei Chernikov<[e-mail]>
Date: Wed, 23 Jan 2008 09:16:13 -0500
To: [e-mail]
CC: Roger Edwards <[e-mail]>, [e-mail], Betsy
Bicknell <[e-mail]>, [e-mail], [e-mail],
[e-mail], [e-mail],[e-mail],
[e-mail],[e-mail],[e-mail],
[e-mail], Susan Wilson<[e-mail]>
Don,
Attached is the TRW Memo with our suggested corrections. sorry for not delivering
it last Friday!. It took a few days to get itthrough the chain for command, and
holiday on Monday did-not help. If these corrections are acceptable, we will proceed
with the permitting process.
Sergei
Sergei Chernikov, Ph.D.
Environmental Engineer "
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
phone: [phone] ext.. 594
fax: [phone]
DWQ comments on TRW recommendations 1 doc' Content Type: application/msword
Content-Encoding: base64
I
1 of 1 1/23/2008 9:40 AM

DRAFT-December 19,2007
Memorandum
Subject: Additional Color Removal Opportunities, Blue Ridge Paper Product's(BRPP)
Canton,NC Bleached Kraft Paper Mill,2008 NPDES Permit Renewal
From: Technology Review Workgroup (TRW)
Donald Anderson, Chair,EPA
Karrie-Jo Shell,EPA Region IV
Marshall Hyatt,EPA Region IV
Paul Davis, Tennessee DEC
David McKinney, Tennessee DEC
Roger Edwards, North Carolina DNR
Sergei Chernikov,North Carolina DNR
To: North Carolina Division of Water Quality and the NC Environmental
Management Commission's NPDES Sub-Committee
Since the 1997 NPDES Permit Settlement Agreement for the Canton Mill,the Technology
Review Workgroup (TRW) has examined the progress made at the facility in relation to reducing
the color content of the Mill's effluent and the potential for additional color reduction at the Mill.
The focus of this examination includes a review of reports and data submitted by Blue Ridge
Paper Products (BRPP), information and data gathered attendant to a visit to the Mill on
February 8, 2007 by EPA's Technology Team(Tech Team) and TRW members, and
consultation among the EPA Tech Team and the TRW's members.
The TRW notes that the Tech Team submitted a Memorandum,publicly released by EPA
Region 4 and dated September 5,2007, including findings and recommendations for further
color reduction based upon its data gathering and analyses. The TRW also notes comments
submitted from BRPP, separate from aud-&&m4the State of North Carolina comments submitted
by letter dated September 14, 2007,which tooktake exception to some of the findings and
recommendations in the Tech Team Memorandum. Further, a meeting of the TRW was held in
Asheville,NC on October 23, 2007, to discuss and attempt to come to resolution on these
comments. Also in response,the Tech Team prepared responses to these comments and an
Addendum to the Tech Team Memorandum. All of these documents are included as attachments
to this TRW memorandum. These documents represent an appropriate evaluation of the
potential for further color reduction at the Mill over the next permit cycle.(estimated to be 2008
through November 2013). They original Twit Tteam report. NCDWQ comments, TRW
meetzn,s and discussions, and other addendums form the general basis for the TRW's attached
recommendations to the Division of Water Quality-and the EnvirmirAental Management
Commission's T, rDBS Sub r,..„..,:«.oe as guidance for developing the effluent limitations for
color and related special conditions of the draft NPDES Permit renewal.

2
The TRW recognizes and concludes that not all of the options outlined in the Tech Team
Memorandum can be_predicted to achieve specific color reductions with complete accuracy.
Consequently the Memorandum provides, where appropriate, estimates of possible reductions
and an aggregate range of likely color reduction from the application of a likely group of specific
technologies that are available. The TRW also notes that public interest organizations separately
provided their comments to the State of North Carolina. In making these recommendations,the
TRW relied on the following considerations:
�1.*,^ort_s� The highest priority for additional color reduction+navi rg*,oward-aehievi�#e
N i Carolina-r' ateF-ga••lamy standard C eler, a .,it h sinee the 1_ ce,lTricnwfft
Agp-eomea , rests with additional in-mill improvements,particularly considering the
success already achieved by continuing improvements,in leak and spill prevention and
control (Best Management Practices—BMPs) and,process modifications and changes.
2. As in-mill technologies are exhausted; and if additional color reduction is
appropriate, segregated waste stream pretreatment and end-of-pipe treatment
technologies, while they may reflect significant economic,technical, and non-water
quality environmental impact issues at this mill,must also be considered carefully as
supplementary options.
In presenting these attached recommendations to the Division of Water Quality and the
Enyi,e ffi-.,,.ntal Management r,..,,„,i..siei,'..rW-DES Sub Ge :+tee the TRW wishes to
acknowledge the excellent success achieved since the 1997 Settlement Agreement and the
continued effort of BRPP to improve on this record. Very difficult and unusual circumstances
occurred in 2004,with back-to-back historical flooding of the Pigeon River and associated
significant costs ($39 million) for repairing damage and replacing equipment at the BRPP mill
after 21 days of being out of operation. The TRW also recognizes that significant additional
expenditures have been made by BRPP over the last permit term for environmental projects
($25.9 million), the largest portion for air pollution controls (e.g.,MACT I and MACT II
compliance) and including color reduction projects ($5.9 million), all building on previous
projects and expenditures. All of this has occurred during a continuing and difficult period of
industry-wide transformation, capacity shrinkage, and mill closings. Nonetheless, the BRPP mill
management has committed to surviving these challenges. These efforts and expenditures have
resulted in substantial and commendable progress made to date by BRPP through additional and
improved best management practices,process and related technologies, and incremental
improvements in treatment system performance which have reduced the long term average color
discharges. It is also noteworthy that some of these technologies and practices have been
implemented by BRPP in addition to those identified in the previous Tech Team and TRW
reviews. The TRW notes that through these efforts the long term average end-of-pipe color
discharge from the mill has been reduced from approximately 42,300 lbs/day in 2001 to
approximately 37,100 lbs/day in 2006. While the Canton Millis among world leaders in the
pulp and paper industry as measured by the quality of its treated effluent, the commitment of
BRPP, the availability of other potential color reduction activities, and the continued interest and
participation in this process by the regulatory agencies, stakeholder public and environmental

3 y 1 -4, 4
interest groups, and the general public makes additional improvement in the future a kin t:—e
and appropriate. irA c€ttture-apprepriat�nd-pessikile.
ir-WnwAUWa-LCRw1•'11�
W C�
�J

4
If there are questions concerning the attached recommendation,please feel free to contact the
TRW.
Attachments: 1) TRW Recommendations
2) 2)—Memorandum from EPA Tech Team to the TRW, entitled,
Additional Color Removal Technologies for Blue Ridge Paper
Products, Canton,NC, dated September 4, 2007
3) NCDWQ comments and letter on Tech Team Report (September 14, 2007)
3-)4 Addendum to Memorandum from Tech Team to the TRW
4)5 Technology Team Responses to NC DWQ Comments

TRW Recommendatwns
The options needing further study should be incorporated in th permit as an additional
increment of color reduction to be demonstrated by the Mill.. tRPP should be required to
evaluate the technologies identified below and to develop ari implementation plan that would
either utilize these when technical) elegies, economical Rand ouerationall feasible,. or identify
other options that would result in similar increments of color reduction.
1. The following suite of items should be implemented, if necessary pon further expedited
evaluation, during the upcoming flex` (2009 20 �� permit c cle
�A. further improvements in leak and spill prevention and ontrol(BMPs)eevering
alsoAvhite iind� gao�souree�-ec-every eyele•
—'_B.process optimization(enhanced extraction stages, r, uced bleaching chemical
use, etc.); and
G. addition of second stage oxygen delignification o. he softwood/pine fiber line
< The time necessary for BRPP to implement these items in logi al sequence should realistically
reflect the Mill's ability to design, fund, and install them at the arliest possible date provided
these items are found to be fechnicall economical) and one ationally feasible. For example,
an updated and detailed evaluation of the addition of second tage oxygen delignification on the
softwood fiber line should identify necessary adjustments upstream pulp digestion (e.g., kappa
number targets),bleaching(e.g., bleaching chemical usa rates,kappa factors) and downstream
brightness/strength and other relevant process control Id product quality parameters, designing
and costing, and refining color reduction projections. e TRW recommends that it be allowed
to review and comment on justification for any above item found by BRPP not to be technically,
r , l v . .m.,.,,.aehis, RhI . If an
economically and aperationallv feasible:.' ._ ,...,..._.. __,.___.__.___„ ._____.__. _ y
above item cannot be implemented, BRPP should be required to identify other options that
would result in similar nts o#'color reduction.
., Based on implementation from the suite of items above or their equivalent, the permit
should require an effluent color target range of 32,000-37,000 lbs/day as an annual
average by the end of the next permit term.
-3-.2. The following items should be evaluated and implemented as appropriate during the
upcoming permit cycle 2008 2n,z ..e_..,:«,�
A. increasing hardwood filtrate recycle and use of the existing BFR process
=B. reducing black liquor carryover by further evaluating in detail and adjusting
operating conditions in the direct contact evaporators (DCEs)

6
uC. reducing impact of Chloride Reduction Process (CRP)purge on treated effluent
color, gathering data sets over as long a period as possible, eferably at full scale,
with and without CRP purge to better inform on the treatability and effluent color
impact of this source of color-. ilf CROP color is not removed in the treatment
system, further study should assess:
o_gatherii-&ta�nis-pveizr�leng-a parted asp r*fcrabl at full
sealev
further"t�rcm;�hould-asses
of. securing whatever additional reductions are possible based on any
demonstrated technology that works and that is found to be cai+be
technically, economically and operationally feasible applied.to this eeffipleh
plitnormenen waste stream, either within the mill and sewer system, or
ehlo n -diemde pretreatment to reduce its color prior to introduction to the
treatment system,er-thee b ,
r.a:,-..ter 4ne.atn,den+system—-water ;., -- [/V'Y8Y
o2. Evaluate methods to avoiding the release of the CRP purge during
periods of low flow in the receiving stream#lew4or-truck-it— b,ut-as-a
eoniingeney and only A&
b
.eests
, a
L, as off it liazardeus nnr treatment ail disp sal
-qD. with the acid"sewer relocation project now complete,better understanding and
possible controlling of the physical and chemical mechanisms underlying"sewer
generated color"mac be possible. 11his will require a sustained effort beyond the
next permit term given that process changes and BMP improvements to be made will
more than likely further change the chemistry and mechanisms underlying"sewer
generated color".
=E. improving colon'removal by the Mill's wastewater treatment plant via
o better equalizing and further optimizing treatment by using polymers
and other chemicals to pretreat highly-colored segregated wastewaters
including streams that are diverted to the extra primary clarifier, or by
other operational and/or treatment means not yet identified
o investigating use of polymers or other chemicals upstream of the
secondary clarifiers, especially during periods of high influent color
and/or low river flow
13. Contrary to past practice for lowest certainty options, the TRW does not consider it
necessary for BRPP to study further the Ozone - Chlorine Dioxide (ZD)process change
within the upcoming permit cycle. However, the TRW does consider the ZD process an
available option beyond the next permit cycle if further reductions in color are found to
be necessary.
-5:4__._The permit should continue to require BRPP to report on or identify any"breakthrough"
color reduction technologies developed at the Mill or that become available within the
industry or the research community.

7
0 5. While the current permit does apply color limits at he the effluent discharge point.;Tt#he
permit issued for 2008-2444 this term should clearly reflect that the color limits and
sampling point for color compliance be is the Mill's end-of-pipe discharge point to the
Pigeon River.
7:6. For Tthe permit to be issued for the upcominQ2_00 —4''013 permit term. DWQ should
consider the adoption ofifla a maximum day effluent limitation for color based upon
current operations and data representing recent long term performance (e.g., one year,
2006), as it relates to capturing and better controlling effluent color variability. Some
TRW members raised short term variability as a significant concern that should be
addressed in the next permit cycle,.-but those considerations should be evaluated in
relation to potential benefits of a maximum daily effluent limit.
8:7. After implementing and putting into operation additional technologies and practices per
the above recommendations,but no later than the end of the upcoming permit term, data
on effluent color loadings should be statistically evaluated to develop revised ira?Eittttm
trionthly (30 da)` average and mwximum aa color effluent limitations which capture
actual variability at the end-of-pipe immediately prior to discharge to the Pigeon River.
The Division of Water Quality should apply those revised effluent limits in the permit
through formal notification.
M. The permit should require a formal evaluation, with periodic update reports as well as
any necessary reopeners regarding color reduction efforts.. °*' °' "' "rts dw-ing
the pefitmt -yele (2008 20 ^) to _ __ pl; with weft rCarolina's nff tiVe Water quality
standai-d-for eol8y-.
400. The role of the TRW should continue through the next permit cycle,and beyond. The
TRW should establish a set schedule to avoid delays in the permitting process, with
1-11 recommendations developed prior to the permit expiration date.-In addition, to avoid any
P perception of bias or conflict of interest, and to ensure autonomy of the Tech Team, the
membership of the Tech Team cannot overlap with.membership of the TRW.However,
this in no way precludes the TRW from consulting members of the Tech Team(or other
outside experts) for clarification in technical matters.
The TRW requesis the should review and advise NC DWO on the results of
.,recommendations#1,#3,#5, #6, and#7 above, as necessary and appropriate. As a
"clearinghouse" for the reports and information submitted by BRPP under the next permit cycle,
the TRW should endeavors to provide an objective view that is useful to the two States and EPA
and to the interested public. This advisory role is important to fostering the cooperative
advancement of the color reduction process at the Mill.

DRAFT- December 19, 2007
Memorandum
Subject: Additional Color Removal Opportunities,Blue Ridge Paper Product's (BRPP)
Canton,NC Bleached Kraft Paper Mill, 2008 NPDES Permit Renewal
From: Technology Review Workgroup (TRW)
Donald Anderson, Chair,EPA
Karrie-Jo Shell, EPA Region IV
Marshall Hyatt,EPA Region IV
Paul Davis, Tennessee DEC
David McKinney, Tennessee DEC
Roger Edwards,North Carolina DNR
Sergei Chernikov,North Carolina DNR
To: North Carolina Division of Water Quality and the NC Environmental
Management Commission's NPDES Sub-Committee
Since the 1997 NPDES Permit Settlement Agreement for the Canton Mill, the Technology
Review Workgroup (TRW) has examined the progress made at the facility in relation to reducing
the color content of the Mill's effluent and the potential for additional color reduction at the Mill.
The focus of this examination includes a review of reports and data submitted by Blue Ridge
Paper Products (BRPP), information and data gathered attendant to a visit to the Mill on
February 8,2007 by EPA's Technology Team(Tech Team) and TRW members, and
consultation among the EPA Tech Team and the TRW's members.
The TRW notes that the Tech Team submitted a Memorandum, publicly released by EPA
Region 4 and dated September 5, 2007, including findings and recommendations for further
color reduction based upon its data gathering and analyses. The TRW also notes comments
submitted from BRPP and from the State of North Carolina by letter dated September 14,2007,
which take exception to some of the findings and recommendations in the Tech Team
Memorandum. Further, a meeting of the TRW was held in Asheville,NC on October 23, 2007,
to discuss and attempt to come to resolution on these comments. Also in response,the Tech
Team prepared responses to these comments and an Addendum to the Tech Team Memorandum.
All of these documents are included as attachments to this TRW memorandum. These
documents represent an appropriate evaluation of the potential for further color reduction at the
Mill over the next permit cycle (2008 through November 2013). They original Tech Team
report. NCDWQ comments and other addendums form the basis for the TRW's attached
recommendations to the Division of Water Quality and the Environmental Management
Commission's NPDES Sub-Committee as guidance for developing the effluent limitations for
color and related special conditions of the draft NPDES Permit renewal.

2
The TRW recognizes that not all of the options outlined in the Tech Team Memorandum can be
predicted to achieve specific color reductions with complete accuracy. Consequently the
Memorandum provides,where appropriate, estimates of possible reductions and an aggregate
range of likely color reduction from the application of a likely group of specific technologies that,
are available. The TRW also notes that public interest organizations separately provided their
comments to the State of North Carolina. In making these recommendations, the TRW relied on
the following considerations:
• The highest priority for additional color reduction moving toward achieving the North
Carolina water quality standard for color, as it has since the 1997 Settlement Agreement,
rests with additional in-mill improvements,particularly considering the success already
achieved by continuing improvements in leak and spill prevention and control (Best
Management Practices—BMPs) and process modifications and changes.
• As in-mill technologies are exhausted, aid if additional color reduction is appropriate.
segregated stream pretreatment and end-of-pipe treatment technologies,while they may
reflect significant economic, technical, and non-water quality environmental impact
issues at this mill, must also be considered carefully as supplementary options.
In presenting these attached recommendations to the Division of Water Quality and the
Environmental Management Commission's NPDES Sub-Committee, the TRW wishes to
acknowledge the excellent success achieved since the 1997 Settlement Agreement and the
continued effort of BRPP to improve on this record. Very difficult and unusual circumstances
occurred in 2004, with back-to-back historical flooding of the Pigeon River and associated
significant costs ($39 million) for repairing damage and replacing equipment at the BRPP mill
after 21 days of being out of operation. The TRW also recognizes that significant additional
expenditures have been made by BRPP over the last permit term for environmental projects
($25.9 million), the largest portion for air pollution controls (e.g.,MACT I and MACT II
compliance) and including color reduction projects ($5.9 million), all building on previous
projects and expenditures. All of this has occurred during a continuing and difficult period of
industry-wide transformation, capacity shrinkage, and mill closings. Nonetheless, the BRPP mill
management has committed to surviving these challenges. These efforts and expenditures have
resulted in substantial and commendable progress made to date by BRPP through additional and
improved best management practices,process and related technologies, and incremental
improvements in treatment system performance which have reduced the long term average color
discharges. It is also noteworthy that some of these technologies and practices have been
implemented by BRPP in addition to those identified in the previous Tech Team and TRW
reviews. The TRW notes that through these efforts the long term average end-of-pipe color
discharge from the mill has been reduced from approximately 42,300 lbs/day in 2001 to
approximately 37,100 lbs/day in 2006. While the Canton Millis among world leaders in the
pulp and paper industry as measured by the quality of its treated effluent, the commitment of
BRPP and the continued interest and participation in this process by the regulatory agencies,
stakeholder public and environmental interest groups, and the general public makes additional
improvam at this time ond-i 4he—fttuFe appropriate and possible, within the historical process
s a lished of beine technoloeical economically and operationally feasible.

i
4
If there are questions concerning the attached recommendation,please feel free to contact the
TRW.
Attachments: 1) TRW Recommendations
2) Memorandum from EPA Tech Team to the TRW, entitled,Additional
Color Removal Technologies for Blue Ridge Paper Products, Canton;NC,
dated September 4, 2007
3) Addendum to Memorandum from Tech Team to the TRW
4) Technology Team Responses to NC DWQ Comment

s
TRW Recommendations
The options needing further study should be incorporated in the permit as an additional
increment of color reduction to be demonstrated by the Mill. BRPP should be required to
evaluate the technologies identified below and to develop an implementation plan that would
either utilize these technologies or identify other options that would result in similar increments
of color reduction that are technologically, economically and operationally feasible.
1. The following suite of items should be implemented, if necessary upon further expedited
evaluation, during the next(2008—2013)permit term:
=A. further improvements in leak and spill prevention and control (BMPs)
covering also white and green liquor sources in the recovery cycle;
B. process optimization(enhanced extraction stages, reduced bleaching
chemical use, etc.); and
C. addition of second stage oxygen delignification on the softwood/pine fiber
line
EThe time necessary for BRPP to implement these items in logical sequence should realistically
reflect the Mill's ability to design, fund, and install them at the earliest possible date,provided
these items are tecluioloSically. economically and nd operationally feasible. For example, an
updated and detailed evaluation of the addition of second stage oxygen delignification on the
softwood fiber line should identify necessary adjustments to upstream pulp digestion(e.g., kappa
number targets),bleaching (e.g.,bleaching chemical usage rates, kappa factors) and downstream
brightness/strength and other relevant process control and product quality parameters, designing
and costing, and refining color reduction projections. The TRW recommends that it be allowed
to review and comment on justification for any above item found by BRPP not to be
technologically economically and operationallv feasible. teehnioai4y infeasible ,.dlor
cetin ;:eall unaelie;able. If any above item cannot be implemented,BRPP should be required
to identify other options that would result in similar increments of color reduction.
2. Based on implementation from the suite of items above or their equivalent, the permit
should require an effluent color target range of 32,000-37,000 lbs/day as an annual
average by the end of the next permit term.
3. The following items should be evaluated and implemented as appropriate during the 2008
-2013 permit term if found to be technoloeically, economically and operationally
feasible:
' A. increasing hardwood filtrate recycle and use of the existing BFR process
-B. reducing black liquor carryover by further evaluating in detail and
adjusting operating conditions in the direct contact evaporators (DCEs)

7
6. While the current permit reflects color limit at the discharge point. The permit to be
issued for 2008 —2013 tenn should clearly reflect that the color limits and sampling point
for color compliance be the Mill's end-of-pipe discharge point to the Pigeon River.
7. The permit to be issued for the 2008—2013 permit term should consider adoption of a
i•.,.elude maximum day effluent limitation for color based upon current o,per
ns and
data representing recent longterm performance (e.g., one year, 200 , rt relates t
capturing and better controlling effluent color vana i i members raised
sigm cant concern that should be addressed in the next permit
cycle.
8. After implementing and putting into operation additional technologies and practices per
the above recommendations,but no later than the end of the upcoming permit term, data
on effluent color loadings should be statistically evaluated to develop revised maximum
monthly(30-day) average and maximum day effluent limitations which capture actual
variability at the end-of-pipe immediately prior to discharge to the Pigeon River. The
Division of Water Quality should apply those revised effluent limits in the permit through
formal notification.
9. The permit should require a formal evaluation,with periodic update reports as well as
any necessary reopeners, of the Mill's efforts during this permit cycle (2008-2013) to
comply with North Carolina's narrative water quality standard for color.
10. The role of the TRW should continue through the next permit cycle and as deemed
appropriate by EPA.Tennesse Department of Environmental Control and North Carolina
En
of Water Quality beyen . The TRW requests the opportunity to review and
C DWQ on the results of recommendations#1, #3, #5, #6, #7, and#8 above, as
and appropriate. As a"clearinghouse"for the reports and information
by BRPP under the next permit, the TRW endeavors to provide an objective
is useful to the two States and EPA and to the interested public. This advisory
portant to fostering the cooperative advancement of the color reduction process
ll.

6
nC. reducing impact of Chloride Reduction Process (CRP) purge on treated
effluent color
_gathering data sets over as long a period as possible,preferably at full
scale,with and without the CRP purge to better inform the treatability of
this source of color; if CRP color is not removed in the treatment
system, further study should assess:
92)securing whatever additional reductions are possible based on any
demonstrated technology that works and can be economically amid
operationally feasibly-applied to this complex phenomenon, either
within the mill and sewer system, or chlorine dioxide pretreatment to
reduce its color prior to introduction to the treatment system, or through
the end-of-pipe activated sludge biological wastewater treatment system
o3) Evaluate,niethods to avoiding release of the CRP purge during periods
of low stream flow (or truck it offsite), but as a contingency and only
after consideration of possible offsetting revenues or costs, such as off-
site hazardous waste treatment and disposal
D. with the acid sewer relocation project now complete, a better
understanding and controlling of the physical and chemical mechanisms
underlying "sewer generated color;" may be possible. Tthis will require a
sustained effort beyond the next permit term given that process changes and BMP
improvements to be made will more than likely further change the chemistry and
mechanisms underlying"sewer generated color"
-E. e improving color removal by the Mill's wastewater treatment
plant via
better equalizing and further optimizing treatment by using polymers
and other chemicals to pretreat highly-colored segregated wastewaters
including streams that are diverted to the extra primary clarifier, or by
other operational and/or treatment means not yet identified
02 investigating use of polymers or other chemicals upstream of the
secondary clarifiers, especially during periods of high influent color
and/or low river flow
4. Contrary to past practice for lowest certainty options, the TRW does not consider it
necessary for BRPP to study further the Ozone- Chlorine Dioxide (ZD) process change
within the upcoming permit cycle. However,the TRW does consider the ZD process an
available option beyond the next permit cycle if further reductions in color discharges are
found to be necessary to comply with NCDWQ water quality standards.
5. The permit should continue to require BRPP to report on or identify any"breakthrough"
color reduction technologies developed at the Mill or that become available within the
industry or the research community.

AGENDA
Meeting of Technology Review Workgroup(TRW)
October 23,2007
Offices of Metropolitan Sewerage District of Buncombe County,Asheville,NC
Sullivan Conference Room
l. Introduction, discuss process for developing memorandum with recommendations
from TRW to NC DWQ
2. Review of comments from NC on Technology Team Report,dated September 5,
2007
3. Comments for which
a. consensus reached
b. issues requiring further clarification and discussion
C. issues for which no consensus was reached
4. Follow-up to reach closure on recommendations
5. Preparing TRW memorandum and concurrence
6. Action items

' ' ' - 1 .heG •/0�23�07
• I '
DRAFT'—October 19,2007 .
Responses to NC DWQ Comments, dated September 14,2007,,on
Technology Team Memorandum regarding Color Removal Strategies
for the Blue Ridge Paper Products mill, Canton,NC
Unless noted, all responses are based on the Technology Team (T7) reportito the
Technical Review Workgroup (TR 99, as publicly released by EPA Region 4 on
September 5, 2007
Comment 1) . . . Sewer generated color is-not a measurement of the mill's efforts to
reduce color. "The Tech Team's conclusion that the Canton mill can further reduce
primary effluent loads through continuing efforts to minimize unplanned spills and leaks
is incorrect. Reduction in leaks and spills is not reflected in primary effluent; it is
reflected in primary influent and secondary effluent."
Response:
• It is important to control mechanisms resulting in sewer generated color
(location of mixing acid and alkaline wastewater streams, now occurring in
primary effluent and also at least in part in the aeration basin of the
secondary activated sludge biological treatment) and further reduce sources
of leaks and spills contributing to this phenomena; the TT report noted (pg.
13) that the simple mixing of these streams forms nearly half the total untreated
color discharge from the mill to the treatment system
• -The TT acknowledged that since 2001 the mill made improvements in spill .
,u collection (BMPs, pg. 5, 13), including a project to reroute the acid sewer to
address sewer generated color; the TT report also recommended additional
improvements to BMPs and black liquor control (pg. 15, 16) to build upon
further initiatives already planned by BRPP -
1�' d • BRPP would not invest in these initiatives if they did not believe, as the TT
does, that there would be reduction in final effluent color
• Thus, the TT considered it important to note that variability in influent to
Y 11JJ secondary activated sludge biological treatment(primary effluent) and the
` color now also generated in part in the secondary treatment system (see also
J�"1 pg. 12, 13) "holds valuable indicators and clues to the sources and solutions
1 to reducing the overall performance [Long Term Average-LTA]I and
variability in effluent color discharged to the Pigeon River" (pg . 6)
Comment 2) "The comparison of the two effluents on page 14 of the report is not
relational because it does not provide equivalent conditions,and it violates the most basic
scientific principles. This comparison is also inappropriate because it corripaies a sample
from a facility that uses tertiary treatment with a facility that uses in-plant controls." The
Tech team must acknowledge that BRPP uses in-plant controls to reduce color load—a
preferred option to end-of-pipe treatment,which frequently generates pollution load in
other media.
i

r
Response: _
•. The photographic comparison (Celco,Valdivia; Chile); and another example
at P. H. Glatfelter,were offered by the TT-as evidence of potential for further
improvements at BRPP (pg. 14,15) using improvements in end-of-pipe
treatment technologies, both secondary and tertiary
The-TT also dutifully noted (pg 14, 15) both the differences in both in-plant
and end-of-pipe technologies between these mills and BRPP, BRPP's
comments concerning the comparison, and other caveats and concerns which
the TT noted may become important if similar end-of-pipe'technologies are
pursued
•- Both the current and all past TT reports have included basic tenets of its
review (TT report pg. 2; see also 2001 TT report, pgs 5-7, 12; and TRW
recommendations to NC DWQ,2001, pg 2; see also Summary Report
12/02/1997, pgs 6, 10), notably ,
➢ the importance and preference for in-plant controls and process
changes to prevent the generation of pollutants before they must be
treated at end-of-pipe, as well as
➢ the potential for pulti-media issues that may occur with end-of:pipe
treatment(e.g., generation of sludges that may be'difficult to dewater,
potential effluent toxicity possibly attributable to coagulants, etc.)
• The current TT report also includes multiple acknowledgements of BRPP's
efforts and expenditures reflecting these basic tenets (pg. 4, 5,6, 13, 14, 15,
16) C
\j Comment 3)NCDWQ disagrees with the indication that variability factors developed for
S' BOD can be used for color in developing a daily maximum value. The color
F phenomenon in pulp and paper is very-complicated and has substantial unknowns. On
e Athe one hand the Tech Team acknowledges complicated and'unpredictable color
�t'''' behavior, while on the other hand the Team suggests that color should be treated like a
conservative parameter.
Response:
• The TT appreciates the complexity of color generation in pulp and paper
effluent;and it exercised its BPJ to derive reasonable.and appropriate color
limits (see pg. 18; 19) and used the variability factors developed for the .
Bleached Papergrade Kraft (BPK) subcategory (presented in EPA's
Statistical Support Document for the Pulp and Paper Industry, Subpart.B,
EPA. 1997) for BODsto calculate suggested BRPP daily maximum and 30-
day average permit limits for color as follows:
➢ The factors were developed using monitoring data from BPK mills
with well-operated secondary` treatment; BRPP is a BPK mill with
well-operated secondary treatment
➢ Color, like BODS, is monitored at the effluent of the secondary
treatment plant
2. _

WJ ➢ Most importantly, color, like BOD , is reduced by a combination of
Jay biodegradation and absorption/adsorption to biomass
G U �➢ The TT notes that BRPP representatives have indicated their belief
that brown color is likely subject to removal processes in the
11 treatment system, e.g., adsorption /absorption and biodegradation
l.(Z' ➢ The TT has never asserted that color, from its various sources
n _ including that generated from mixing of different wastewater streams,
�✓ is a conservative pollutant
o
Comment 4)The comment to apply the color limit at the end of the pipe demonstrates a
lack of understanding of the permit, since NCDWQ already applies a color limit at the
end of the pipe.
Response:
i
1 • The TT acknowledged that the current color limits were applied at the end-
of-pipe, although ambiguously.
� Ahe TT report further notes: ". . . the current permit is not clear that this is
the point of application of effluent limits for color. See [from the 2001
z NPDES permit] Table A(1), which prescribes end-of-pipe monitoring,but no
AA�n- color limits are included(emphasis added). See also the TRW's-2001.
bsl �� Memorandum, at item no. 8."
�gopol I The TT report states, at pg, 17, "Daily maximum and maximum 30-day
�ot+J average permit limits would enhance the consistency of day-to-day in-stream
water quality, and would be consistent with limits for other parameters
controlled in the present BRPP permit (BODS, TSS,AOX, etc). The Tech
Team also believes that these effluent limitations for color should continue to
be applied unambiguously at the end-of-pipe discharge from the mill to the
river (emphasis added)."
6rrComment 5) The Tech Team recommends that BRPP spend approximately $5,000,000 to
y� install 2nd stage delignification, which might potentially result in only 1,100 pounds of
color reduction. This reduction is only an estimate, which might not be realized.
)M J�UResponse:
/ • In 2001 BRPP estimated the capital cost of adding an additional oxygen
/ delignification stage would be in the order of$2 to $3 million and the
chemical cost savings approximately$1.2 million/year, providing a
reasonable payback; mill staff has mentioned a three year pay-back,which is
consistent with this estimate
3

• BRPP has further asserted from their more recent estimates that the cost,
could be$3 to $5 million, but BRPP offered no details to substantiate this
,increase; the TT presumes this,increased cost is a rough estimate and not as .
specifically fabricated and costed for installation at BRPP (pg. 9),with only a
�o A small:partof this increase in cost possibly attributable to increases in the -
general prices of stainless steels
elf"
t , •' In 2001 the TT'report recommended that BRPP conduct a detailed study to
' J develop an engineering design leading to installing an additional oxygen"
delignification stage for the pine (softwood) pulping/bleaching line, and
/ estimated that this process change wouldr'educe effluent color by 1,100 to
9�1
1,4001bs/day (see 2001 TRW memorandum, item no. 4)
The TT noted (see pgs. 8- 10) that Liebergott, et. al., (GL&V 2006; BRPP's
consultant) estimated that implementing a second oxygen delignification
stage on the pine fiber line would reduce color discharge by 1142 lbs/day
- • In 2007 the TT noted and remained confident that
➢ this technology progressed beyond being considered "reasonable
certain in 2001 to "highest certainty" at this time,,and thus will
contribute to further,reduction of color
➢ adjustments in upstream pulp digestion would increase pulp yield and
reduce cost for bleaching chemicals (e.g., 002 and caustic,thus
increased savings will be realized compared to earlier estimates),
while also reducing chloride and color contained in the purge stream
from-the Chloride Removal Process (CRP); the only unknowns are `
the actual magnitudes of these adjustments
Therefore,the TT again recommended that priority should be given to
expedited and detailed evaluation and implementation at the earliest possible
date during the upcoming permit term
• In order to satisfy BRPP's recent concerns concerning differences in
products and processes and potentially higher costs'since 2001,
➢ the updated detailed evaluation needs to identify necessary
adjustments to upstream pulp digestion (e.g.;kappa number targets),
bleaching(e.g., bleaching chemical usage rates) and downstream {
brightness/strength parameters,-designing,and costing, and refining
color reduction projections
➢ results of this updated evaluation may need-to be shared with the
TRW, prior to being implemented
Comment 6)The Tech Team's recommendation to shut down the Chloride Removal
Process (CRP) for an extended period of time would result in major corrosion; scaling
and pluggage due to the accumulation of chlorides,and potassium in the equipment.• This
option is not operationally feasible.
r
4

Response:
• The TT has noted, from data,and facts presented by-BRPP,that CRP color is os&W/i/b F
now a significant portion of the total color discharged from the mill processes
(pg. 10)
A10*1
This mill has operated in the past for weeks ata time without the CRP
running
(" Early literature on the BFR process published by Champion indicated that
weeks are needed for significant build up of chlorides that could likely cause
operational problems (pg. 11) due to the small mass of chlorides purged daily
through CRP relative to the large inventory of chlorides in the recovery loop
�� i ,y • During August 2006 to January 2007, the mill shutdown the CRP (for parts
7� of each day)for ..nine widely dispersed pairs of days." (pg. 10, 11). The
3Z�' TT believes that the mill should extend the period of CRP shutdown (e.g.,
three weeks) in order to allow sufficient time for the treatment system to
e1 v respond to the decrease in color from the CRP purge contributed to the
71 influent and any changes in color now generated from the relocated acid _
-sewer at the influent to and within the activated-sludge system
•' BRPP offered no specific facts or details, aside from the assertion in these
comments,why there would be operational difficulties in conducting a full-
scale mill trail in which the CRP purge is excluded from the system '
• Nonetheless, the TT is open to another reasonable approach that could be
devised (pg. 11); such an approach would need to gather the data necessary
over a sufficient.period of time to better identify and quantify the underlying
color loads to the treatment system, both with and without the purge from
CRP
Comment 7) Statements in the Tech Team report in regard to the CRP contribution to the
9 AV effluent color appear to be incongruous. The CRP produces brown color, which might
explain why shutting it down did not result in any significant difference in the effluent
color.
�,,e4�*Responsc:
y7,� '�. • See response to Comment 6)"above for background regarding discharges
from the CRP,which contributes wastewater with very high color(41,000
peu)
• BRPP representatives believe that brown color is likely subject to removal
processes in the treatment system
• The TT noted,from data supplied by BRPP, that day-to-day variations in
color discharges tend to subsume and confound analysis of the impact of
changes in the CRP purge stream on effluent color
_ l
5

• Notwithstanding these data and the expected removal processes in the
treatment system, the TT also noted that color discharge, though not a major
( difference in the limited-data being considered (pg. 11);was the reverse of
what would be expected when CRP was.operating (i.e., higher color loading)
versus color discharge when CRP was not operating (i.e., lower color loading)
f. J, Comment 8) The Tech Team's assertion about the effectiveness of CIOZ treatment of .
U CRP purge is inaccurate. Although, it was about 80% effective in some cases,the report
failed to mention that it was about 0% effective in other cases. If the statement is left-in
the report "as is," it could create an impression that BRPP, for some reason, refuses to
implement an inexpensive and effective method to reduce color, which is false:NCDWQ
believes this treatment option should be studied to'determine its feasibility and will
recommend this as part of the TRW.
Response:
• The TT.acknowledges (pg. 10)variability in results, and that
• NC and BRPP support the TT's recommendation (pg..10, 16) to further
study this segregated stream pretreatment technology, and the TT
recommended implementation as appropriate during the upcoming permit
term, given that CRP color is now a significant portion of the total color
discharged from the mill processes
Comment 9) The Tech Team's recommendation to add a daily maximum color limit is
inappropriate. The DM limits are typically placed in the permit for a parameter that
exhibits acute toxicity or where there are standard effluent guidelines for a DM limit.
Response:
1,- • NPDES permit regulations (40 CFR 122.45(d)(1)) for continuous discharges
require daily maximum effluent limitations, including those necessary to
achieve water quality standards (WQBELs); it is not impracticable to
s� calculate such limits
Y'��� • The TT notes that BRPP's progress in reducing the annual average of color
l�. discharges has made increasingly apparent the importance of reducing day-
to-day effluent variability (pg. 15, 17)
'1 �� �7?� • Daily maximum permit limits would further focus efforts.on reducing day-to-
i day process and wastewater variability, and thus enhance the consistency of
day-to-day final effluent and in=stream water quality, and would be
consistent with limits for other parameters controlled in the present BRPP
permit (BODS, TSS, AOX, etc.)
• The TT notes (pg. 19) the suggested range of values for a daily maximum
effluent limitation for color was exceeded only for two days during 2006 for
which data were available; both days were attributable to unexpected and
first-time CRP tank overflows
6
r

• To address.this overflow, the TT recommended that BRPP continue to move
forward with'the planned CRP sump and containment project to eliminate
unplanned releases of this highly-colored material to the mill sewer
• Thus,it is not impracticable to achieve such a daily maximum limit
rW Comment 10) , The Tech Team's recommendation to reduce the kappa factor is not
per ' feasible, as the market currently requires paper and paperboard with higher brightness
R 1`" values, which requires a higher degree of bleaching. If the kappa factor were to be
" reduced, the mill would be forced to do more bleaching at the second [bleaching] stage in
t� order to produce marketable products. The filtrate from the secon&stage is not recycled,
.„vS�and shifting more bleaching to the second stage would result in more color production.
Response:
• In preparation for the current renewal of their NPDES permit,Liebergott&
F}+� Associates and GL&V(2006) repeated their recommendations,also made in 2001,
for BRPP to reduce the kappa factor in the D�stage and replace some of the CIO
Z -
ia', bleaching power with oxygen and/or peroxide in the extraction stages'(previously
discontinued by BRPP),for both bleach lines (see also comments 13—15 and
responses); increasing the operating temperature of the hydrogen peroxide
rIXy{p- extraction stages to reduce efflaent color also was identified as a viable option
Q during this review process
�O�u 1 l� • Recommendations by the consultant in 2006, also embraced by the TT(see figs 3,4,
and 16), recognized changes in market-driven requirements for higher brightness
C+r pulp for certain paper products produced since 2001 and the resulting need for
adjustments in both the chemicals used and their application rates in the bleaching
yeY sequence
aA" 0 • In addition to allowing for higher pulp brightness products while reducing the color
of the bleach plant effluents,use of a lower kappa factor means BRPP would '
➢ use less C102 and also caustic to bleach,thus with increased unit costs for.
chemicals cost savings have been"under-estimated from previous TT
estimates
➢ reduce the total chloride content of bleach plant filtrates, and-thus also
➢ reduce the amount of color CRP purge contributes to the mill effluent(pg.4)
i
Comment 11) The Tech Team recommends BRPP to investigate possible ways to reduce
black liquor carryover in the direct contact evaporator. The name of the equipment used
in the process is a"direct contact evaporator,"which already implies that black liquor is
in direct contact with the exhaust and it is physically impossible to reduce carryover
because of the existing direct contact. The proposed solution is to`replace the existing
[recovery] boiler, which is extremely expensive and not economically feasible.
- I
I ,
7

Response: D
�� , • The TT dutifully noted that replacement of the recoveboiler is an existing
option,in theory, but also noted it". . would probably represent a capital
rr
. cost of over$100 million. ... . Analysis of all the economics and long term life
' �ekk ��; of the mill would be necessary to evaluate such a major investment." L f".}� " "�
,y A In light of this fact, because DCE carryover typically is not an issue at most �`�*t0`
N� pV mills, the TT instead recommended "On a more modest level, it may be
feasible to reduce black liquor carry over by adjusting operating conditions
in the existing DCE's." (pg. 12)
Comment 12) The comparison to the Glatfelter Permit limit is inappropriate in the
technical report. There are several significant differences between the mills, the critical
P difference being that the Glatfelter mill purchases a substantial amount of pulp to produce
pulping an technicalPa paper. Since color is predominantly during theProcess,
y� comparison should be based on the amount of pulp production by the two mills.
ko
Response:
•° The TT considered and acknowledged the differences in processes and pulp
production between the two mills, including the amount of purchased pulp
by the Glatfelter mill
• Notwithstanding these differences, substantial differences were noted in
production normalized end of-pipe"color discharge loadings between the two ,
m���� ills (Pg. 14, 19)
Comm nt43) The Tech Team claims that the mill consultant recommended adding
oxygen and peroxide to E stages; when in fact it was recommended to evaluate such
b�y��"^` � � additions, not to implement it immediately.
`"�U,l °1`" �}s�� Response:
ot
• The consultant's report does state the recommendation to "evaluate the use
of oxygen and peroxide fortification of the extraction stage at reduced D,
factor's_." J
• The TT discusses (pg. 3, 4) and recommends the changes be implemented
(pg. 16); see also response to Comment 10, above.
Comment 14)The Tech Team claims the need to use oxygen in the extraction state on the
hardwood line. BRPP has used oxygen for an extended period of time and did not
observe any effect on the effluent color. ,
' 8

Response:
• See response to comment 10 and 13, above.
• The Tech Team continues to believe these changes are still viable for both
fiber lines and should remain as high certainty options that should be
pursued for further color reduction. (pg. 4)
Comment 15) The Tech Team claims that the consultant recommended replacement of
C102 bleaching power with oxygen and/or peroxide. This is not true, as the consultant
only recommended evaluation of this option not replacement.
Response:
• See response to comment 10, 13 and 14, above.
Comment 16) The Tech Team's insistence on the need to recycle more filtrate from the
hardwood line is unfounded. This proposal is not operationally feasible since the
hardwood line has no metal removal process, which is necessary to successfully recycle
bleach filtrate. The construction of MRP and BFR would cost about$30 million and
would not be economically feasible.
Response:
• Installation of a second stage OD system on the softwood fiber line (see
response to Comment 5) above)would reduce the load on the BFR system, �[n - I • .
and thus the TT noted (pg. 4), it may be possible to introduce a portion of 1^-
these hardwood filtrates to the existing BFRTM process, which to this point has
been dedicated solely to recovering sofbvood fiber line filtrates (emphasis
�W added), and reduce the total colored filtrates discharged to the sewer
7 • The BFR system as originally installed was adequately'sized (CRP
component; MRP was not adequately sized, plus reliability problems which
have since been over to.accommodate some hardwood ft line
filtrates (Eo) and-thus the original TT summary report included a (then)
near-term recommendation for partial BFR(using CRP) on the hardwood
fiber lin see Summary Report 12/02/1997, pgs. 4,-5-6); recenTadd n of
^ , ion exchange media could possibly reduce or eliminate the MRP bottleneck
Thus, a second separate and complete BFR process for the hardwood fiber
line, including both the Metals Removal Process (MRP) and Chloride
Removal Process (CRP),would-not be necessary and thus was not considered
w� by the TT
,R' Comment 17) The Tech Team's use of the following phrase—`BRPP believes that
secondary effluent showed improvement" is improper (page 7) and should be stated
definitively, not as a belief.
2
a�

Response:
fN a The TT's statement was based on an interpretation of the data presented by
/ BRPP in Table 4, pg 7; the report also acknowledges improvements in
performance (pgs. 2, 4, 5, 6, 13, 15, 17); this statement is,consistent with
gv BRPP's comment, but could be more explicit
Comment 18).The Tech Team's remark on page 16 of the memo regarding mills that are
required to implement end-of-pipe color removal technology fails to mention that those
mills do not have extensive in-mill process controls, which has been emphasized at
F& BRPP.
da n Response;
• The TT report (pg. 14) acknowledges more than one important caveat
regarding differences among the mills, including that ". . . neither the Valdivia
TM
mill nor the Glatfelter mill employs the BFR system as applied at BRPP."
' • `However,the TT report also notes that both of the other two mills do have in
place extensive and very effective in-plant controls (e.g.,BMPs) (pg. 14)
Comment 19) The Tech Team's selected strategy to "...ultimately eliminate discharges
��of highly colored wastewaters" is unrealistic. Continued reduction, when feasible, is
certainly NCDWQ'.s goal for colored wastewater discharges, but any reduction or
limination must be weighed along with the technically and economically feasible issues.
Response:
I,,,y • The TT recommended (pg 15, 16) strategies included continuing ". . . to
improve the performance of BMPs to further substantially reduce and
ultimately eliminate discharges of highly-colored [untreated] wastewaters
directly to the wastewater treatment system (emphasis added). . . "
It was implied, but not explicitly stated, that this recommendation for highly
colored wastewaters (e.g., CRP tankage, CRP purge) focused on both
➢--further reducing leaks and spills (e.g., moving forward with BRPP's
planned CRP sump project); and
➢ segregated stream pretreatment as necessary to ensure reduced color
loadings introduced into the wastewater treatment system
The TT did not envision complete elimination of highly colored discharges,
though this is always a worthy goal
Comment 20) The Tech Team's recommendation to avoid releasing CRP purge streams
during low flow condition is not operationally feasible. CRP is an integral part of the
BFR, which produces significant reductions in color discharges.
10

1f" Response:
q (�,�� • The TT notes that (see response to Comment 6) -
O ➢ this mill has operated in the past for weeks at a time without the CRP
running
➢ given the small daily mass of chlorides generated by'CRP operation
relative to the large inventory of chlorides in the recovery loop,weeks are
needed for significant build up of chlorides that could likely cause
operational problems
j • Alternatively, also given the modest volume of CRP purge wastewater
(approximately three tank truck loads per day) it could be feasible to avoid
discharging this wastewater during those infrequent periods of very low flow
v4 conditions in the Pigeon R.; again, this need not be among the first options
'NU / considered
{ Comment 21) The paragraph on page 17 that contains the recommendation to curtail
roduction during low flow contradicts itself. In the beginning the memo acknowledges
hat color treatment is best during long periods of steady production. Then it
�,y� recommends reducing production,which has been shown to increase color load to the
p 4 receiving stream.
Response:
• The TT only reiterated past consideration of this option, a requirement of the
original Settlement Agreement, to curtail pulp production during periods of
low stream flow
The TT also noted as it did previously, however,that ". . . this should
continue to be considered an option of last resort, given that best
performance has been noted by the mill to be during extended periods of
steady production and greater risk of elevated color during process
shutdown and startup. See Low Flow Contingency Plan-,December 1, 1998."
(pg. 17)
u'" Commenf 22) The Tech Team recommends further trials to evaluate potential of
s ozone/chloride dioxide (ZD) bleaching for the hardwood line. . . .Due to the high cost
and unlikely benefit, this technology is not economically feasible and should not be
to evaluated.
1 t j R sponse:
'`U a • As noted on pg. 89 "The Tech Team concludes that BRPP's investigation of the
Gl J
potential for hardwood pulp ozone bleaching to reduce the mill's effluent
y �J color was inadequate."
11

y • As also noted on pg. 8, "Notwithstanding the above-noted inadequacies and
upon reflection, the Tech Team believes that further laboratory trials appear
not to be necessary because this application ofZD technology may not be
appropriate for this mill at this time-(emphasis added). Therefore, ZD
technology is considered a technology option of lowest certainty for
ky f +11 application at this mill at this time:"
Comment 23) The Tech Team's statement on page 6 that`�'BRPP did not report one single .
` event or one single type of event that caused high color in the primary effluent" is
incorrect. BRPP provided information on the cause of some elevated primary effluent
color days in the March 2007 response to additional questions.
Response:
// • The TT noted (pg. 6) the following reasons the mill presented for high color
/ j days: planned mill outages, unplanned outages, a CRP slurry tank overflow,
and a release from the evaporator related to an equipment failure. However,
in the TT's opinion,ty of t these events by themselves did'not account for high color
p\ kO and variabilihe primary effluent.
rr : PIq �7-/ mil
12

of warF
� 90 Michael F. Easley
0 Governor
NCDENR William G.Ross,Jr.,Secretary
OY North Carolina Department of Environment and Natural Resources
Coleen H.Sullins, Director
Division of Water Quality
September 14,2007
James D.,Giattina,Director
Water Management Division
EPA Region IV,Atlanta Federal Center
61 Forsyth Street
Atlanta,GA 30303-8960 Subject: Response to EPA Technology Team
Memorandum on Color Removal Strategies
For Blue Ridge Paper Products,Inc.
Dear Mr. Giattina: NC NPDES Permit No. NC0000272
The North Carolina Division of Water Quality(NCDWQ)received the memorandum from the EPA Technology
Team entitled"Color Removal Strategies For Blue Ridge Paper Products, Inc". We appreciate the opportunity to
review the report and provide EPA Region IV written comments. NCDWQ has a number of serious objections
and concerns regarding the report that we would like to bring to your attention. NCDWQ also wishes to present
these comments as part of the written record to be considered by the upcoming Technology Review Workgroup
(TRW). As you are aware, the TRW will review the EPA Technology Team(Tech Team)report as part of its
decision-making process and subsequent recommendations for Blue Ridge Paper Product's NPDES renewal.
Specific concerns with the Tech Team's report are outlined in Appendix A attached to this letter. We would
appreciate you sharing these continents with members of your staff who will be involved in the NPDES renewal
for Blue Ridge Paper Products,Inc. (BRPP),as well as members of the TRW.
NCDWQ's most serious objections to the report are with respect to the Tech Team's recommendation of effluent
color limits and the Tech Team's recommendation of immediate implementation of certain perceived color
reduction technologies. It is NCDWQ's understanding that the Tech Team's responsibility was to address
technically,economically,and operationally feasible measures in the manufacturing process that may reduce
color in the effluent. The recommendation of effluent color limits was never the goal or responsibility of the Tech
Team and NCDWQ strongly objects to numeric effluent limits as part of the report. Discussion and
recommendation of any effluent color limits is part of the TRW, and NCDWQ will make its recommendation
regarding any differing effluent color limits within the scope of that workgroup, and as part of the NPDES
renewal. However, because the Tech Team has already recommended effluent color limits, it will be more
difficult for all parties that comprise the TRW to review the Tech Team report and objectively recommend any
differing color limits or possible reductions. It is likely that many members of the TRW(and members of the
general public)will view these recommendations as absolutes, when the recommendations should not have been
made at all,and have now been made based on a technically flawed report.
In addition to the recommendation of effluent color limits,NCDWQ also objects to the Tech Team's
recommendation to immediately implement certain technologies to reduce color. This also was not the goal of the
Tech Team,as NCDWQ understood it. Some of these technologies have not been carefully tested and evaluated
as to their ultimate effect on effluent color(especially in regard to the complexities of the BRPP mill). While
NCDWQ does not object to evaluation of some of these technologies, immediate implementation by BRPP may
not prove to be effective or provide significant reduction.Discussion of implementation should have been held
with members of the TRW and should not have been part of the Tech Team report.
N.C.Division of Water Quality I NPDES Unit Phone:[phone]
1617 Mail Service Center,Raleigh,NC 27699-1617 fax:[phone]
Internet:www.newaterquality.org DENR Customer Service Center.1 800 623-7748

W.Giattina
EPA Region IV
Page 2
Again, NCDWQ strongly objects to the Tech Team's report,as it strayed significantly from its goal of providing
only factual information regarding the technically, economically,and operationally feasible methods of color
reduction for pulp and paper mills. Instead,the Tech Team proceeded to make recommendations of which
technologies BRPP should implement and when,as well as what effluent color limits BRPP should receive with
renewal of the NPDES permit. We hope that EPA Region IV reviews the Tech Team report and takes this into
consideration prior to convening the TRW. Although it is too late for NCDWQ to have influence over the Tech
Team report,we respectfully request that this letter be shared with all parties of the TRW in equal measure to the
flawed Tech Team report,and that this letter with comments be considered along with that report. Should you
have further questions,please contact Charles Wakild,P.E.,Deputy Director,at(919)733—5083.ext.204,Dr.
Sergei Chemikov,ext.594,or Susan A.Wilson,P.E.,ext.510.
rSi ere
11
/r
Co een H.Sullin
w/Appendix
cc: Mr.Donald Anderson,EPA Headquarters
Mr.Marshall Hyatt,EPA Region IV
Ms.Karrie-Jo Shell,EPA Region IV
Mr.Roger Edwards,ARO/Surface Water
NPDES File .
Central Files

Mr.Giattina
EPA Region N
Page 3
Appendix A
NCDWQ has made an effort to clarify some of the inaccuracies in the Tech Team's report.Likely,due to the
short time frame between notification of the finalized report and release to the public,NCDWQ may not have
caught every flaw or misstatement. Should further issues with the report be found,NCDWQ representatives will
bring this to the attention of the TRW.
Again, NCDWQ believes the Tech Team has inappropriately made recommendations on effluent color limits and
recommendations regarding the implementation of color removal technologies. NCDWQ's representatives will
provide information on our understanding of the goal of the Tech Team and the goal of the TRW during the
meeting of that workgroup.
1) Data in the discussion of the Primary Effluent Color(Table 3)represents a phenomenon well known to
pulp and paper experts as sewer-generated color.Primary Effluent data cannot be used to evaluate the
effectiveness of color reduction efforts because it reflects sewer-generated color. The best indicators of
mill performance are primary influent color, and most importantly, secondary effluent color.Both of
these streams have shown a significant decrease in color over the term of the permit.The Tech Team's
claim that mill efforts did not result in reduced color loads to the treatment systems is incorrect and
appears to be in contradiction to the existing data. Sewer-generated color is not a measurement of the
mill's efforts to reduce color.The Tech Team's conclusion that the"Canton mill can further reduce
primary effluent loads through continuing efforts to minimize unplanned spills and leaks"is incorrect.
Reduction in leaks and spills is not reflected in primary effluent, it is reflected in primary influent and
secondary effluent.
2) Although this part of the Tech Team report may seem minor, the comparison of the two effluents on page
14 of the report is not relational because it does not provide equivalent conditions, and it violates the most
basic scientific principles.This comparison is also inappropriate because it compares a sample from a
facility that uses tertiary treatment with a facility that uses in-plant controls.The Tech Team must
acknowledge that BRPP uses in-plant controls to reduce color load—a preferred option over end-of-pipe
treatment, which frequently generates more pollution load in other media. BRPP has been a leader in the
industry with implementation of in-process color reduction.
3) NCDWQ disagrees with the indication that variability factors developed for BOD can be used for color in
developing a daily maximum value. The color phenomenon in pulp and paper is very complicated and has
substantial unknowns. One example of this is sewer-generated color, which describes creation of an
additional color due to the mixing of the two streams with different pH levels. This generated color
significantly exceeds simple summation of color in two streams;BOD does not exhibit similar behavior.
BRPP's experience with color reduction efforts clearly indicates that some measures to reduce color,that
were recommended by experts,resulted in no or very little color reductions, while others were very
successful. The same cannot be said about BOD. On one hand the Tech Team acknowledges complicated
and unpredictable color behavior, on the other hand the Team suggests that color should be treated like a
conservative parameter.
4) The comment to apply the color limit at the end of the pipe demonstrates a lack of understanding of the
permit, since NCDWQ already applies a color limit at the end of the pipe.NCDWQ has provided an
explanation about this issue to the Tech Team on several occasions and it is unclear why the Tech Team
makes a recommendation that has already been implemented.
5) The Tech Team recommends that BRPP spend approximately$5,000,000 to install 2nd stage
delignifrcation, which might potentially result in only 1,100 lbs of color reduction.This reduction is only
an estimate, which might not be realized. Removal of 1,100 lbs of color is equivalent to about 4% of the
total color output, which is well within daily variation. This removal would also translate into only 1 unit
of color at the Fiberville bridge just below the discharge.

Mr.Giattina
EPA Region IV
Page 4
Such a change is likely not distinguishable by the naked eye and is well within daily color variability.
Even under tightly controlled laboratory conditions this small difference would not be measurable
considering color variability. Therefore,a recommendation to spend$5,000,000 to receive such a small
reduction is inappropriate.NCDWQ will make this comment as part of the TRW as well.
In addition,NCDWQ believes the cost savings that might be realized are significantly overestimated. The
Liebergott report(mill consultant) estimates the cost savings to be on the order of$500,000.The Tech
Team miscalculated the savings by trying to take double credit for saving the chemicals and increasing
the yield.However, such an approach would not result in color reduction and thus cannot be
recommended as a color reduction measure.It is not possible to achieve three things at the same time:
reduce consumption of chemicals, increase yield and reduce color.
6) The Tech Team's recommendation to shut down the Chloride Removal Process (CRP)for an extended
period of time would result in major corrosion, scaling and pluggage due to the accumulation of chlorides
and potassium in the equipment.This option is not operationally feasible. NCDWQ feels that the Tech
Team may lack an understanding that CRP is an integral part of Bleach Filtrate Recycling(BFR) process
and, although CRP itself contributes to color output, the entire BFR process(including CRP) results in a
significant reduction of color on the order of 20,000—25,000 lbslday.
7) Statements in the Tech Team report in regard to the CRP contribution to the effluent color appear to be
incongruous.The report states that"day to day variations in color discharge values are frequently over 20
percent". At the same time surprise is expressed by the fact that during time when CRP was down the
average color was reduced by 7%. Since 7% reduction is far below the variation of 20%,the scientific
conclusion must be that there is no statistically significant difference between days when CRP is
operational and days when CRP is not operational.The report statement that"This defies common sense"
is puzzling at best. Studies conducted by a graduate student from Duke University demonstrated that color
removal at the treatment plant acts primarily on brown color.The CRP produces brown color,which
might explain why shutting it down did not result in any significant difference in the effluent color.
8) The Tech Team assertion about the effectiveness of CIOZ treatment of CRP purge is inaccurate. Although,
it was about 80%effective in some cases,the report failed to mention that it was about M"effective in
other cases. If the statement is left in the report"as is", it could create an impression that BRPP,for some
reason,refuses to implement an inexpensive and effective method to reduce color, which is false.
NCDWQ believes this treatment option should be studied to determine its feasibility and will recommend
this as part of the TRW. One of the successful CRP treatment studies conducted by BRPP where C102
was used for 20 days demonstrated average color removal at approximately 79%level.However,this
reduction did not manifest itself in any significant decrease of color in the effluent, which questions the
need to treat CRP color.The color phenomenon is very complicated, and there is a need to carefully study
it before making any categorical recommendations to implement some technological measure.
9) The Tech Team's recommendation to add a daily maximum color limit is inappropriate. As stated
previously, NCDWQ does not believe that recommendation of permit limits was the goal of the Tech
Team. It is also necessary to stress that the color standard is an aesthetic standard that is based on 30Q2
flow.Therefore, a monthly average limit is the most appropriate.The daily maximum limits are typically
placed in the permit for a parameter that exhibits acute toxicity or where there are standard effluent
guidelines for a daily maximum limit. Present color level in the mill's discharge is not toxic and there are
no Federal effluent guidelines for color. NCDWQ believes there is no need for color to be limited on a
daily basis and this will be emphasized during meetings with the TRW.

a '
Mr.Giattina
EPA Region IV
Page 5
10) The Tech Team's recommendation to reduce the kappa factor is not feasible,as the market currently
requires paper and paperboard with higher brightness values, which requires a higher degree of bleaching.
Therefore,there is a market driven need to maintain a higher kappa factor.
If the kappa factor were reduced, the mill would be forced to do more bleaching at the second stage in
order to produce marketable products. The filtrate from the second stage is not recycled, and shifting
more bleaching to the second stage would result in more color production.
11) The Tech Team recommends BRPP to investigate possible ways to reduce black liquor carryover in the
direct contact evaporator.The name of the equipment used in the process is a"direct contact evaporator",
which already implies that black liquor is in direct contact with the exhaust and it is physically(impossible
to reduce carryover because of the existing direct contact.The proposed solution to install a new boiler is
extremely expensive(about$100,000,000) and is not economically feasible.NCDWQ disagrees with this
recommendation and will reiterate this as part of the TRW.
12) The comparison to the Glatfelter Permit(Spring Grove,PA) limit is inappropriate in the technical report.
There are several significant differences between the mills, the critical difference being that the Glatfelter
mill purchases a substantial amount of pulp to produce paper.Therefore,any comparison based on the
amount of paper produced is inaccurate. Since color is predominantly produced during the pulping
process,any technical comparison should be based on the amount of pulp production by the two mills.
Taking into account the above stated issues, the color performance of both mills appears to be similar.
Although again, this portion of the report does not maintain NCDWQ's understanding of the Tech
Team's goal on the technically, economically, and operationally feasible measures in the manufacturing
process that will reduce the color in the effluent.
13) The Tech Team claims that the mill consultant recommended adding oxygen and peroxide to E stages,
when in fact it was recommended to evaluate such additions,not to implement it immediately.
14) The Tech Team claims the need to use oxygen in the extraction stage on the hardwood line.BRPP has
used oxygen for an extended period of time and did not observe any effect on the effluent color. After
oxygen use was discontinued,effluent color also did not change. NCDWQ will object to this
recommendation within the scope of the TRW.
15) The Tech Team claims that the consultant recommended replacement of CIOZ bleaching power with
oxygen and/or peroxide. This is not true, as the consultant only recommended evaluation of this option,
not replacement.
16) The Tech Team's insistence on the need to recycle more filtrate from the hardwood line is unfounded.
This proposal is not operationally feasible since the hardwood line has no MRP(metal removal process),
which is necessary to successfully recycle bleach filtrate.The construction of MRP and BFR for the
hardwood line would cost about$30,000,000 and is not economically feasible. NCDWQ will object to
this within the scope of the TRW.
17) The Tech Team's use of the following phrase—`BRPP believes that secondary effluent showed
improvement"is improper(page 7)and should be stated definitively,not as a belief. The existing data
clearly indicates that a decrease in effluent color from 42,676 to 37,058 was indeed realized.
18) The Tech Team's remark on page 16 of the memo regarding mills that are required to implement end-of-
pipe color removal technology fails to mention that those mills do not have extensive in-mill process
controls, which has been emphasized at BRPP.

Mr.Giattina
EPA Region N
Page 6
19) The Tech Team's selected strategy to"... ultimately eliminate discharges of highly colored wastewaters"
is unrealistic. Continued reduction,when feasible,is certainly NCDWQ's goal for colored wastewater
discharges,but any reduction or elimination must be weighed along with the technically and
economically feasible issues.
20) The Tech Team's recommendation to avoid releasing CRP purge streams during low flow condition is not
operationally feasible. CRP is an integral part of the BFR,which produces significant reductions in color
discharges. NCDWQ objects to this recorninendation and will do so as part of the TRW.
21) The paragraph on page 17 that contains the recommendation to curtail production during low flow
contradicts itself.In the beginning the memo acknowledges that color performance is best during long
periods of steady production. Then it recommends reducing production,which has been shown to increase
color load to the receiving stream. NCDWQ objects to this recommendation and believes all plants retain
better performance under steady operation.
22) The Tech Team recommends further trials to evaluate potential of ozonetchloride dioxide(ZD)bleaching
for the hardwood frberline.This recommendation contradicts Dr.Liebergott's conclusion in the report
dated July 7, 2066. It also has a'high capital cost($10,000,000)and operating cost($1,500,000—
$1,700,000). Another concern with this recommendation is its effect on pulp strength, which is of special
importance for BRPP since it produces milk and juice cartons.The Glatfelter Spring Grove mill that
employed this technology determined that there is little or no color benefit. Due to the high cost and
unlikely benefit,this technology is not economically feasible and should not be evaluated.NCDWQ will
reiterate this within the scope of the TRW.
23) The Tech Team's statement on page 6 that`BRPP did not report one single event or one single type of
event that caused high color in the primary effluent" is incorrect.BRPP provided information on the
cause of some elevated primary effluent color days in the March 2007 response to additional questions.

Technology Team Responses to NC DWQ Comments, dated September 14, 2007,
and(Indirectly)to BRPP Comments, dated June 4,2007,
from Teleconference on July 25,2007, and dated July 26,2007, on
Technology Team Memorandum Regarding Color Removal Strategies
for the Blue Ridge Paper Products Mill, Canton,NC
Unless noted, all responses are based on the Technology Team (TT) report to the
Technical Review Workgroup (TRW), as publicly released by EPA Region 4 on
September 5, 2007 and per Addendum dated December 19, 2007
Comment 1) . . . Sewer generated color is not a measurement of the mill's efforts to
reduce color. "The Tech Team's conclusion that the Canton mill can further reduce
primary effluent loads through continuing efforts to minimize unplanned spills and leaks
is incorrect. Reduction in leaks and spills is not reflected in primary effluent, it is
reflected in primary influent and secondary effluent."
Response:
• It is important to control mechanisms resulting in sewer generated color
(location of mixing acid and alkaline wastewater streams,now occurring in
primary effluent and also at least in part in the aeration basin of the
secondary activated sludge biological treatment) and further reduce sources
of leaks and spills contributing to this phenomena; the TT report noted(pg.
13)that the simple mixing of these streams forms nearly half the total untreated
color discharge from the mill to the treatment system
• The TT acknowledged that since 2001 the mill made improvements in spill
collection (BMPs,pg. 5, 13),including a project to reroute the acid sewer to
address sewer generated color; the TT report also recommended additional
improvements to BMPs and black liquor control (pg. 15, 16)to build upon
further initiatives already planned by BRPP
• BRPP would not invest in these initiatives if they did not believe, as the TT
does,that there would be reduction in final effluent color
• Thus, the TT considered it important to note that variability in influent to
secondary activated sludge biological treatment(primary effluent) and the
color now also generated in part in the secondary treatment system (see also
pg. 12, 13) "holds valuable indicators and clues to the sources and solutions
to further improving the overall performance [Long Term Average-LTA]
and reducing the variability of effluent color discharged to the Pigeon River"
(pg. 6 and the Addendum to the TT Report)
• The TT also notes that a sustained effort to further study and control this
phenomena will be required beyond the upcoming permit term given that
process changes and BMP improvements to be made during the 2008—2013
permit term will more than likely further change the mechanisms underlying
"sewer generated color"

Comment 2) "The comparison of the two effluents on page 14 of the report is not
relational because it does not provide equivalent conditions, and it violates the most basic
scientific principles. This comparison is also inappropriate because it compares a sample
from a facility that uses tertiary treatment with a facility that uses in-plant controls." The
Tech team must acknowledge that BRPP uses in-plant controls to reduce color load—a
preferred option to end-of-pipe treatment,which frequently generates pollution load in
other media.
Response:
• The photographic comparison (Celco,Valdivia, Chile), and another example
at P.H. Glatfelter,were offered by the TT as evidence of potential for further
improvements at BRPP (pg. 14,15) using improvements in.end-of-pipe
treatment technologies,both secondary and tertiary
• The TT also noted(pg 14, 15)the differences in both in-plant and end-of-pipe
technologies between these mills and BRPP,BRPP's comments concerning
the comparison, and other caveats and concerns which the TT noted may
become important if similar end-of-pipe technologies are pursued
• Both the current and all past TT reports have included basic tenets of its
review(TT report pg.2; see also 2001 TT report, pgs 5-7, 12; and TRW
recommendations to NC DWQ, 2001,pg 2; see also Summary Report
12/02/1997,pgs 6, 10),notably
➢ the importance and preference for in-plant controls and process
changes to prevent the generation of pollutants before they must be
treated at end-of-pipe, as well as
➢ the potential for multi-media issues that may occur with end-of-pipe
treatment(e.g., generation of sludges that may be difficult to dewater,
potential effluent toxicity possibly attributable to coagulants, etc.)
• The current TT report also includes multiple acknowledgements of BRPP's
efforts and expenditures reflecting these basic tenets (pg.4,5, 6, 13, 14, 15,
16)
Comment3)NCDWQ disagrees with the indication that variability factors developed for
BOD can be used for color in developing a daily maximum value. The color
phenomenon in pulp and paper is very complicated and has substantial unknowns. On
the one hand the Tech Team acknowledges complicated and unpredictable color
behavior,while on the other hand the Team suggests that color should be treated like a
conservative parameter.
Response:
• The TT has appreciated the complexity of color generation in pulp and paper
effluent particularly at this mill since 1997, and it exercised its best
professional judgment(BP.l)to derive reasonable and appropriate suggested
color limits (see pg. 18, 19) and used the variability factors developed for the
Bleached Papergrade Kraft(BPK) subcategory (presented in EPA's
2

Statistical Support Document for the Pulp and Paper Industry, Subpart B,
EPA. 1997) for BODsto calculate suggested BRPP daily maximum and 30-
day average permit limits for color as follows:
➢ The factors were developed using monitoring data from BPK mills
with well-operated secondary treatment; BRPP is a BPK mill with
well-operated secondary treatment
➢ Color,like BODS,is monitored at the effluent of the secondary
treatment plant
➢ Most importantly, color,like BOD5'is reduced by a combination of
biodegradation and absorptionladsorption to biomass
➢ The TT notes that BRPP representatives have indicated their belief
that brown color is likely subject to removal processes in the
treatment system,e.g.,adsorption/absorption and biodegradation
➢ The TT has never asserted that color, from its various sources
including that generated from mixing of different wastewater streams,
is a conservative pollutant
• An acceptable alternative would be gathering effluent color monitoring data,
after technologies actually implemented by BRPP are installed and
operating, and a statistical analysis to develop variability factors to calculate
maximum day and maximum month WQBELs for color to be applied at the
end of pipe (see response to comment#4); results of this should be shared
with the TRW
Comment 4)The comment to apply the color limit at the end of the pipe demonstrates a
lack of understanding of the permit, since NCDWQ already applies a color limit at the
end of the pipe.
Response:
• The TT acknowledged that the current color limits were applied at the end-
of-pipe, although ambiguously.
• The TT report further notes: ". . .the current permit is not clear that this is
the point of application of effluent limits for color. See [from the 2001
NPDES permit] Table A(1),which prescribes end-of-pipe monitoring,bat no
color limits are included(emphasis added). See also the TRW's 2001
Memorandum, at item no. 8."
• The IT report states,at pg, 17, "Daily maximum and maximum 30-day
average permit limits would enhance the consistency of day-to-day in-stream
water quality, and would be consistent with limits for other parameters
controlled in the present BRPP permit(SODS,TSS,AOX, etc). The Tech
Team also believes that these effluent limitations for color should continue to
be applied unambiguously at the end-of-pipe discharge from the mill to the
river (emphasis added)"
3

Comment 5)The Tech Team recommends that BRPP spend approximately$5,000,000 to
install 2"d stage delignification,which might potentially result in only 1,100 pounds of
color reduction. This reduction is only an estimate,which might not be realized.
Response:
• In 2001 BRPP estimated the capital cost of adding an additional oxygen
delignification stage would be in the order of$2 to $3 million and the
chemical cost savings approximately$1.2 million/year,providing a
reasonable payback; mill staff has mentioned a three year pay-back,which is
consistent with this estimate
• BRPP has further asserted from their more recent estimates that the cost
could be$3 to $5 million,but BRPP offered no details to substantiate this
increase; the TT presumes this increased cost is a rough estimate and not as
specifically fabricated and costed for installation at BRPP (pg.9),with only a
small part of this increase in cost possibly attributable to increases in the
general prices of stainless steels
• In 2001 the TT report recommended that BRPP conduct a detailed study to
develop an engineering design leading to installing an additional oxygen
delignification stage for the pine(softwood) pulping/bleaching line, and
estimated that this process change would reduce effluent color by 1,100 to
1,4001bs/day(see 2001 TRW memorandum, item no.4)
• The TT noted (seepgs. 8—10)that Liebergott, et. al.,(GL&V 2006; BRPP's
consultant) estimated that implementing a second oxygen delignification
stage on the pine fiber line would reduce color discharge by 1142 lbs/day
• In 2007 the TT noted and remained confident that
➢ this technology progressed beyond being considered"reasonable
certainty"in 2001 to "highest certainty" at this time, and thus will
contribute to further reduction of color
➢ adjustments in upstream pulp digestion would increase pulp yield and
reduce cost for bleaching chemicals (e.g., C1O2 and caustic, thus
increased savings will be realized compared to earlier estimates by the
TT),while also reducing chloride and color contained in the purge
stream from the Chloride Removal Process (CRP); the only
unknowns are the actual magnitudes of these adjustments
• Therefore,the TT again recommended that priority should be given to
expedited and detailed evaluation and implementation at the earliest possible
date during the upcoming.permit term
• In order to satisfy BRPP's recent concerns concerning differences in
products and processes and potentially higher costs since 2001,
➢ the updated detailed evaluation needs to identify necessary
adjustments to upstream pulp digestion (e.g., kappa number targets),
bleaching(e.g., reducing bleaching chemical usage rates (kappa
factor; see response to comment#10), enhanced extraction stages (see
responses to comment#13,#14,#15), etc.) and downstream
4

brightness/strength parameters, designing and costing,and refining
color reduction projections
➢ results of this updated evaluation should be shared with the TRW,
with provision that any or all of the technologies implemented be
conditioned upon the results of this updated and expedited evaluation
Comment 6) The Tech Team's recommendation to shut down the Chloride Removal
Process(CRP) for an extended period of time would result in major corrosion, scaling
and pluggage due to the accumulation of chlorides and potassium in the equipment. This
option is not operationally feasible.
Response:
• The TT has noted, from data and facts presented by BRPP,that CRP color is
now a significant portion of the total color discharged from the mill processes
(pg. 10)
• This mill has operated in the past for weeks at a time without the CRP
running
• Early literature on the BFR process published by Champion indicated that
weeks are needed for significant build up of chlorides that could likely cause
operational problems(pg. 11) due to the small mass of chlorides purged daily
through CRP relative to the large inventory of chlorides in the recovery loop
• During August 2006 to January 2007,the mill shutdown the CRP (for parts
of each day) for". . .nine widely dispersed pairs of days." (pg. 10, 11). The
TT believes that the mill should extend the period of CRP shutdown (e.g.,
three weeks)in order to allow sufficient time for the treatment system to
respond to the decrease in color from the CRP purge contributed to the
influent and any changes in color now generated from the relocated acid
sewer at the influent to and within the activated sludge system
• BRPP offered no specific facts or details, aside from the assertion in these
comments,why there would be operational difficulties in conducting a full-
scale mill trail in which the CRP purge is excluded from the system
• Nonetheless,the TT is open to another reasonable approach that could be
devised (pg. 1'1); such an approach would need to gather the data necessary,
preferably at full scale, and over a sufficient period of time to better identify
and quantify the underlying color loads to the treatment system,both with
and without the purge from CRP
Comment 7) Statements in the Tech Team report in regard to the CRP contribution to the
effluent color appear to be incongruous. The CRP produces brown color,which might
explain why shutting it down did not result in any significant difference in the effluent
color.
5

Response:
• See response to Comment 6) above for background regarding discharges
from the CRP,which contributes wastewater with very high color(--41,000
pcu)
• BRPP representatives believe that brown color is likely subject to removal
processes in the treatment system
• The TT noted, from data supplied by BRPP,that day-to-day variations in
color discharges tend to subsume and confound analysis of the impact of
changes in the CRP purge stream on effluent color
• Notwithstanding these data and the expected removal processes in the
treatment system,the TT also noted that color loads,though not a major
difference in the limited data being considered (pg. 11),was the reverse of
what would be expected when CRP was operating(i.e., higher color loading)
versus color discharge when CRP was not operating(i.e., lower color
loading); see the Addendum to the TT Report
Comment 8)The Tech Team's assertion about the effectiveness of C1O2 treatment of
CRP purge is inaccurate. Although,it was about 80%effective in some cases,the report
failed to mention that it was about 0%effective in other cases. If the statement is left in
the report"as is,"it could create an impression that BRPP, for some reason, refuses to
implement an inexpensive and effective method to reduce color,which is false.NCDWQ
believes this treatment option should be studied to determine its feasibility and will
recommend this as part of the TRW.
Response:
• The TT acknowledges (pg. 10)variability in results (from as low as 0 percent
to as much as 80 percent)(see also the Addendum to the TT report), and that
• NC and BRPP support the TT's recommendation(pg. 10, 16) to further
study this segregated stream pretreatment technology, and the TT
recommended implementation as appropriate during the upcoming permit
term, given that CRP color is now a significant portion of the total color
discharged from the mill processes
Comment 9)The Tech Team's recommendation to add a daily maximum color limit is
inappropriate. The DM limits are typically placed in the permit for a parameter that
exhibits acute toxicity or where there are standard effluent guidelines for a DM limit.
Response:
• NPDES permit regulations (40 CFR 122.45(d)(1)) for continuous discharges
require daily maximum effluent limitations,including those necessary to
achieve water quality standards (WQBELs); it is not impracticable to
calculate such limits
6

• The TT notes that BRPP's progress in reducing the annual average of color
discharges has made increasingly apparent the importance of reducing day-
to-day effluent variability(pg. 15, 17)
• Daily maximum permit limits would further focus efforts on reducing day-to-.
day process and wastewater variability, and thus enhance the consistency of
day-to-day final effluent and in-stream water quality, and would be
consistent with limits for other parameters controlled in the present BRPP
permit(BODS,TSS,AOX, etc.)
• The TT notes (pg. 19)the suggested range of values for a daily maximum
effluent limitation for color was exceeded only for two days during 2006 for
which data were available; both days were attributable to unexpected and
first-time CRP tank overflows
• To address this overflow, the TT recommended that BRPP continue to move
forward with the already planned CRP sump and containment project to eliminate
unplanned releases of this highly-colored material to the mill sewer
• Thus,it is not impracticable to achieve such a daily maximum limit(see
responses to comments#3 and#4)
Comment 10) The Tech Team's recommendation to reduce the kappa factor is not
feasible, as the market currently requires paper and paperboard with higher brightness
values,which requires a higher degree of bleaching. If the kappa factor were to be
reduced,the mill would be forced to do more bleaching at the second [bleaching] stage in
order to produce marketable products. The filtrate from the second stage is not recycled,
and shifting more bleaching to the second stage would result in more color production.
Response:
• In preparation for the current renewal of their NPDES permit,Liebergott&
Associates and GL&V(2006) repeated their recommendations,also made in 2001,
for BRPP to reduce the kappa factor in the D,stage and replace some of the CIO
bleaching power with oxygen and/or peroxide in the extraction stages(previously
discontinued by BRPP),for both bleach lines(see also comments 13—15 and
responses); increasing the operating temperature of the hydrogen peroxide
extraction stages to reduce effluent color also was identified as a viable option
during this review process
• Recommendations by the consultant in 2006,also embraced by the TT(see pgs 3,4,
and 16),recognized changes in market-driven requirements for higher brightness
pulp for certain paper products produced since 2001 and the resulting need for
adjustments in both the chemicals used and their application rates in the bleaching
sequence
• In addition to allowing for higher pulp brightness products while reducing the color
of the bleach plant effluents,use of a lower kappa factor with the above process
changes and optimizations means BRPP would
➢ use less CIOZ and also caustic to bleach,thus with increased unit costs for
chemicals cost savings have been under-estimated from previous TT
estimates
➢ reduce the total chloride content of bleach plant filtrates,and thus also
7

➢ reduce the amount of color CRP purge contributes to the mill effluent(pg.4)
• All of the above considerations are contingent upon further evaluating and,if
feasible,implementing on an expedited basis second stage OD on the pine line,
enhanced extraction stages,and other process;see response to comment#5
Comment 11) The Tech Team recommends BRPP to investigate possible ways to reduce
black liquor carryover in the direct contact evaporator. The name of the equipment used
in the process is a"direct contact evaporator,"which already implies that black liquor is
in direct contact with the exhaust and it is physically impossible to reduce carryover
because of the existing direct contact. The proposed solution is to replace the existing
[recovery] boiler,which is extremely expensive and not economically feasible.
Response:
• The TT noted that replacement of the recovery boiler is an existing option,in
theory,but also noted it". . .would probably represent a capital cost of over
$100 million. . . .Analysis of all the economics and long term life of the mill
would be necessary to evaluate such a major investment."
• In light of this fact,because DCE carryover typically is not an issue at most
mills,the TT instead recommended "On a more modest level,it may be
feasible to reduce black liquor carry over by further evaluating in detail and
adjusting operating conditions in the existing DCE's." (pg. 12) The Tech
Team will provide suggestions if requested by BRPP.
Comment 12)The comparison to the Glatfelter Permit limit is inappropriate in the
technical report. There are several significant differences between the mills,the critical
difference being that the Glatfelter mill purchases a substantial amount of pulp to produce
paper. Since color is predominantly produced during the pulping process, any technical
comparison should be based on the amount of pulp production by the two mills.
Response:
• The TT considered and acknowledged the differences in processes and pulp
production between the two mills,including the amount of purchased pulp
employed at the Glatfelter mill
• Notwithstanding these differences,substantial differences were noted in
production normalized end-of-pipe color discharge loadings between the two
mills (pg. 14, 19)(see also the Addendum to the TT report)
Comment 13)The Tech Team claims that the mill consultant recommended adding
oxygen and peroxide to E stages,when in fact it was recommended to evaluate such
additions, not to implement it immediately.
8

Response:
• The consultant's report does state the recommendation to "evaluate the use
of oxygen and peroxide fortification of the extraction stage at reduced DI
factors."
• The TT discusses (pg.3,4) and also recommends the changes be
implemented(pg. 16); see also response to Comment 10,above.
Comment 14)The Tech Team claims the need to use oxygen in the extraction state on the
hardwood line. BRPP has used oxygen for an extended period of time and did not
observe any effect on the effluent color.
Response:
• See response to comment 10 and 13, above.
• The Tech Team continues to believe these changes are still viable for both
fiber lines and should remain as high certainty options that should be
implemented during this permit cycle for further color reduction. (pg. 4)
Comment 15) The Tech Team claims that the consultant recommended replacement of
C102 bleaching power with oxygen and/or peroxide. This is not true, as the consultant
only recommended evaluation of this option not replacement.
Response:
• See response to comment 10, 13 and 14, above.
Comment 16)The Tech Team's insistence on the need to recycle more filtrate from the
hardwood line is unfounded. This proposal is not operationally feasible since the
hardwood line has no metal removal process,which is necessary to successfully recycle
bleach filtrate. The construction of MRP and BFR would cost about$30 million and
would not be economically feasible.
Response:
• Installing a second stage OD system on the softwood fiber line (see response
to Comment#5 and#10 regarding again evaluating this technology,
enhanced extraction, and other process improvements, and reaffirming it is
appropriate to be implemented)would reduce the load on the BFR system,
and thus the TT noted (pg.4),it may be possible to process an increased
portion of these hardwood filtrates through the existing BFRTD1 process
(notably CRP) and reduce the total color load discharged to the sewer
• The BFR system as originally installed was adequately sized (CRP
component; MRP was not adequately sized,plus reliability problems which
have since been overcome)to accommodate some hardwood fiber line
filtrates (Fo) and thus the original TT summary report included a (then)
near-term recommendation for partial BFR(using CRP) on the hardwood
9

fiber line(see Summary Report 12/02/1997,pgs. 4, 5-6); recent addition of
ion exchange media could possibly reduce or eliminate the MRP bottleneck
• Thus, notwithstanding further recent comment from BRPP and NC to the
contrary, a second separate and complete BFR process for the hardwood
fiber line,including both the Metals Removal Process (MRP) and Chloride
Removal Process(CRP),would not be necessary and thus was not considered
by the TT
Comment 17)The Tech Team's use of the following phrase—`BRPP believes that
secondary effluent showed improvement"is improper(page 7) and should be stated
definitively,not as a belief.
Response:
• The TT's statement was based on an interpretation of the data presented by
BRPP in Table 4,pg 7; the report also acknowledges improvements in
performance (pgs. 2,4, 5, 6, 13, 15, 17); this statement is consistent with
BRPP's comment,but could be more explicit; see Addendum to TT report
Comment 18)The Tech Team's remark on page 16 of the memo regarding mills that are
required to implement end-of-pipe color removal technology fails to mention that those
mills do not have extensive in-mill process controls,which has been emphasized at
BRPP.
Response:
• The TT report(pg. 14) acknowledges more than one important caveat
regarding differences among the mills,including that". . . neither the Valdivia
TM
mill nor the Glatfelter mill employs the BFR system as applied at BRPP."
• However,the TT report also notes that both of the other two mills do have in
place extensive and very effective in-plant controls (e.g.,BMPs) (pg. 14)
Comment 19) The Tech Team's selected strategy to"...ultimately eliminate discharges
of highly colored wastewaters"is unrealistic. Continued reduction,when feasible, is
certainly NCDWQ's goal for colored wastewater discharges,but any reduction or
elimination must be weighed along with the technically and economically feasible issues.
Response:
• The TT recommended (pg 15, 16) strategies included continuing ". . . to
improve the performance of BMPs to further substantially reduce and
ultimately eliminate discharges of highly-colored [untreated] wastewaters
directly to the wastewater treatment system (emphasis added). . . "
• It was implied,but not explicitly stated, that this recommendation for highly
colored wastewaters focused on both
10

➢ further reducing leaks and spills (e.g., moving forward with BRPP's
planned CRP sump project), and
➢ segregated stream pretreatment as necessary to ensure reduced color
loadings introduced into the wastewater treatment system
• The TT
➢ did not envision completely eliminating highly colored untreated
wastewaters to the treatment system,though this is always a worthy goal
➢ notes that all projects are evaluated for technical and economic feasibility
Comment 20) The Tech Team's recommendation to avoid releasing CRP purge streams
during low flow condition is not operationally feasible. CRP is an integral part of the
BFR,which produces significant reductions in color discharges.
Response:
• The TT notes that(see response to Comment 6)-
➢ this mill has operated in the past for weeks at a time without the CRP
running
➢ given the small daily mass of chlorides generated by CRP operation
relative to the large inventory of chlorides in the recovery loop,weeks are
needed for significant build up of chlorides that could likely cause
operational problems
• Alternatively, also given the modest volume of CRP purge wastewater
(approximately three tank truck loads per day) it could be feasible to avoid
discharging this wastewater during those infrequent periods of very low flow
conditions in the Pigeon R.
• The TT notes
➢ this is an option for contingency only, and need not be among the first
options considered
➢ it will be important to evaluate offsetting revenues (or costs) for use of the
black liquor solids at another off-site facility, or the cost of disposal at an
off-site hazardous waste treatment and disposal facility
Comment 21) The paragraph on page 17 that contains the recommendation to curtail
production during low flow contradicts itself. In the beginning the memo acknowledges
that color treatment is best during long periods of steady production. Then it
recommends reducing production,which has been shown to increase color load to the
receiving stream.
Response:
• The TT only reiterated past consideration of this option, a requirement of the
original Settlement Agreement,to curtail pulp production during periods of
low stream flow
• The TT also noted as it did previously, however,that". . .this should
continue to be considered an option of last resort, given that best
11

performance has been noted by the mill to be during extended periods of
steady production and greater risk of elevated color during process
shutdown and startup. See Low Flow Contingency Plan,December 1, 1998."
(pg. 17)
Comment 22)The Tech Team recommends further trials to evaluate potential of
ozone/chloride dioxide(ZD)bleaching for the hardwood line. . . .Due to the high cost
and unlikely benefit, this technology is not economically feasible and should not be
evaluated.
Response:
• As noted on pg. 8, "The Tech Team concludes that BRPP's investigation of the
potential for hardwood pulp ozone bleaching to reduce the mill's effluent
color was inadequate."
• As also noted on pg. 8, "Notwithstanding the above-noted inadequacies and
upon reflection,the Tech Team believes that further laboratory trials appear
not to be necessary because this application ofZD tecbnolo"may not be
appropriate for this mill at this dine (emphasis added).Therefore,ZD
technology is considered a technology option of lowest certainty for
application at this mill at this time."
• Contrary to past practice by BRPP for lowest certainty options,the Tech
Team agrees this technology need not be studied within the 2008-2013
permit term; however,the Tech Team does consider the ZD process an
available option for in-process changes and modifications in subsequent
permit cycle(s) if further reductions in color discharges are found to be
necessary in the future ,
Comment 23)The Tech Team's statement on page 6 that'BRPP did not report one single
event or one single type of event that caused high color in the primary effluent" is
incorrect. BRPP provided information on the cause of some elevated primary effluent
color days in the March 2007 response to additional questions.
Response:
• The TT noted (pg. 6) the following reasons the mill presented for high color
days: planned mill outages, unplanned outages, a CRP slurry tank overflow,
and a release from the evaporator related to an equipment failure. However,
in the TT's opinion,these events by themselves did not account for high color
and variability of the primary effluent. See the Addendum to the TT report
12

ADDENDUM to Tech Team Report,released September 5,2007 by EPA Region 4
December 19,2007
1. The first sentence,last paragraph on pg 6, is being amended to read as follows:
"The Tech Team continues to believe that the information presented in Table 3,
among other available process and wastewater treatment systems performance data,
holds valuable indicators and clues to the sources and solutions.to further improving
the overall performance and reducing the variability of effluent color discharged to
the Pigeon River."
2. On pg. 11, second paragraph,the third and fourth sentences are being amended to
replace them as follows:
"The Tech Team notes that the difference in treated effluent color loads,though not
major based upon the limited data considered,was the reverse of what would be
expected when the CRP was operating(i.e.,higher color loading) compared to
when the CRP was not operating(i.e., lower color loading)."
3. On pg. 10,the second paragraph under the heading Treatment of CRP Purge
Stream for Color Removal,the third sentence is amended to read as follows:
"BRPP found that C1O2 bleaching could remove 75 to 90 percent of the color in the
CRP stream,-but with variability noted to range on occasion to as low as 0 percent
removal."
4. On pg. 19,under Comparison to Glatfelter Permit Limits,the end of this
paragraph is amended by replacing the last sentence with the following:
"The annual average color discharge,expressed in kg/Metric Ton(kg/MT),for the
Glatfelter mill is approximately 10.4 kg/MT pulp produced on site,while at BRPP
the long term average color discharge is 13.1 kg/MT pulp produced on site. The
Glatfelter 30-day(monthly) average and maximum day effluent limitations
(included in its NPDES permit) are substantially more stringent than those
suggested by the Tech Team for BRPP. However, the Tech Team believes,
consistent with similar efforts by BRPP in the past, it is appropriate for BRPP to
undertake data gathering and develop statistically derived effluent limitations as an
alternative to the effluent limitations suggested by the Tech Team. Such an effort
would follow implementation by BRPP of those technologies found to be
technically feasible and economically achievable during the 2008—2013 permit
term.The following table presents a comparison of actual long term performance
and suggested BRPP and actual PH Glatfelter end-of-pipe effluent limitations for
color.

Effluent Limitations and Performance
P H Glatfelter and Blue Ridge Pa eir Products
BRPP PH Glatfelter
Parameter Low High Winter Summer Winter 5 Summer
Kg/MT'2 I Kg/MT2 Kg(MT Kg/MT PCU PCU
Long 13.14 10.44 NA
Term Ave.
Ann.Ave. 22.7 26.2 NA NA NA NA
Max. 31.8 36.7 11.6 ' 13.2 123 140
Monthly
(30-day)
Ave.
Max.Day 59.0 68.7 23.3 26.5 246 280
NA Not Applicable
1 Source:Memorandum from EPA Technology Team to Technology Review Workgroup,"Color Removal Strategies for Blue Ridge
Paper Products,Inc,"released by EPA Region 4 on September 5,2007,and as amended by this Addendum December 19,2007
2 Range of end-of--pipe effluent limitations for color suggested by EPA Technology Team;
3 Source:"Water Quality Protection Report Amendment,"P.H.Glatfelter Company,Spring Grove Borough and Jackson Township,
York County,for the Renewal of NPDES Permit No.PA 0008869,Pennsylvania Department of Environmental Protection,
Southcentral Regional Office,June 1,2007.
4 Actual long term performance;for PHG,the above values in kg1MT were calculated from wastewater flow,effluent limitations in
PCU,and on-site pulp production(excluding purchased pulp)for comparison with BRPP
5 Effluent limitations in NPDES permit;units:PCU
5. On pg. 15,the bullet at the bottom of the page is amended to read as follows:
"Continue to improve the performance of BMPs to further substantially reduce, or
eliminate, if technically feasible and economically achievable, discharges of
untreated wastewaters directly to the wastewater treatment system through further
improvements in—".
6. The next to last bullet on pg. 16 is amended to read as follows:
"If the CRP purge color is found not to be removed in secondary treatment,avoid
releasing the CRP purge during periods of low stream flow(or truck it offsite); this
should be considered as a contingency after consideration of possible offsetting
revenues or costs, such as off-site use of black liquor solids or hazardous waste
treatment and disposal facility costs."
7. On pg. 6,in the second complete paragraph below Table 3,the third sentence is
amended to read as follows:
"BRPP did not report any one single event or types of events that by themselves
account for high color in the primary effluent."

1
8. At the bottom of pg. 13,prior to the start of the next section entitled Improving
W WTP Performance Using Chemicals,the last paragraph is being amended by
adding the following sentence"
"The Tech Team also notes that a sustained effort to further study and control this
phenomena will be required beyond the upcoming permit term given that process
changes and BMP improvements to be made during the 2008—2013 permit term
will more than likely further change the mechanisms underlying `sewer generated
color."'
9. The first sentence at the top of pg. 7 is amended to read as follows:
`BRPP stated that the color reduction projects completed since 2001 and ongoing
management of mill processes and wastewater treatment systems have resulted in
secondary effluent improvement, as shown by data provided by BRPP,presented in
Table 4 (below).
10. The List of References is amended by adding an additional items as follows:
"Water Quality Protection Report,"P. H. Glatfelter Company, Spring Grove
Borough and Jackson Township,York County, for the Renewal ofNPDES Permit
No. PA 0008869,Pennsylvania Department of Environmental Protection,
Southcentral Regional Office, October 23, 2006.
"Water Quality Protection Report Amendment,"P. H. Glatfelter Company, Spring
Grove Borough and Jackson Township, York County, for the Renewal of NPDES
Permit No. PA 0008869,Pennsylvania Department of Environmental Protection,
Southcentral Regional Office,June 1,2007.

MEMORANDUM
DATE: September 5,2007
SUBJECT: Color Removal Strategies For Blue Ridge Paper Products,Inc
FROM: EPA Technology Teamt
TO: Technology Review Workgroup
Purpose of this Review
Blue Ridge Paper Products Inc.(BRPP)has requested renewal of their National Pollution
Discharge Elimination(NPDES)discharge permit NC0000272. This permit allows discharge to the
Pigeon River of industrial and other wastewaters from the pulp and paper mill BRPP operates in
Canton,NC. In their May 2006 Color Compliance Report(Blue Ridge,2006a),BRPP requested
that North Carolina reissue the NPDES permit for the Canton Mill with an annual average effluent
color limit of 39,000 lbs per day. This is a reduction from the current 42,000 lb per day annual
average limit which became effective January 2004. BRPP's requested limit was based on the
mill's 2005 annual average effluent color,39,000 lbs per day. EPA Region 4 requested that the
EPA Technology,Team("Tech Team")support EPA's review of the color limits included in the
draft permit renewal developed by North Carolina Department of Environment and Natural
Resources. The Tech Team last evaluated color discharges of the mill in 2001 (EPA Tech Team
2001).
Members of the Tech Team visited the Canton mill on February 8,2007 with members of the
Technology Review Workgroup(TRW)to observe and collect information and data on the status of
technologies implemented and color discharges at the mill. This memorandum incorporates
analysis of data provided by BRPP prior to and from that visit,and other data subsequently
provided by BRPP at the request of the Tech Team.
This memorandum reviews the process improvements previously analyzed by the Tech Team,the
status of their implementation at BRPP,and identifies additional color reduction activities that
BRPP could implement during its next permit term. This memorandum also reviews the variability
of the mill effluent color discharges and suggests final effluent color limits for incorporation in the
revised permit.
Background and History
BRPP operates a bleached papergrade kraft pulp and paper mill in Canton,NC,which it purchased
from Champion International Corporation in May 1999. BRPP is owned 55 percent by KPS
Special Situations Fund, L.P. and 45 percent by the employees through an employee stock
ownership plan.' BRPP announced on June 14,2007 that it is being acquired by The Rank Group.
The New Zealand-based Rank Group has considerable holdings in the paper industry. Rank Group
recently bought Evergreen Packaging,the former North American beverage packaging division of
International Paper. Operations at the mill began in 1908,but the mill has been extensively
EPA Tech Team members are Ahmar Siddiqui, EPA/EAD;Karrie-Jo Shell,EPA Region 4;Donald
Anderson,EPA/EAD;Betsy Bicknell,ERG,contractor;Neil McCubbin,subcontractor to ERG;Dan Bodien,
subcontractor to ERG.
'BRPP announced on June 14,2007 that it is being acquired by The Rank Group. The New Zealand-based
Rank Group has considerable holdings in the paper industry. Rank Group recently bought Evergreen
Packaging,the former North American beverage packaging division of International Paper.

Memorandum
September 5,2007
Page 2
modernized,with the most recent major project completed in 1993. The mill currently operates an
810 tpd hardwood pulping line and a 600 tpd softwood(pine)pulping line. After cooking,pulp
from each line is further.delignified in single-stage oxygen delignification(OD)systems,both
installed in 1993. Hardwood pulp is subsequently bleached with a DED sequence(BRPP stopped
adding oxygen to the hardwood E stage after 2001). Pine pulp is bleached with a DEoD sequence
(BRPP stopped adding peroxide to the pine E stage after 2001). Target brightness is 86 ISO,an
increase by one point from the target brightness in 2001. Up to 80 percent of the filtrate flow from
the pine bleach line is returned to the recovery cycle using the unique Bleach Filtrate Recycle
(BFR"")process,developed by Champion. This 80 percent closure rate is an improvement from
2001,when the pine line closure averaged 73.7 percent. Up to 25 percent of the hardwood line
bleach plant E-stage filtrate flow is also recovered. BRPP produces 300,000 tons per year of
uncoated paper including offset,tablet,and envelope grades.The mill also produces 275,000 tons
per year of bleached paperboard used for liquid packaging and paper cups,including FDA-
approved grades for milk and juice cartons.
Basic tenets of this review,which are consistent with the Tech Team's approach beginning with the
original Settlement Agreement(with Champion International)and the 2001 TRW review with
BRPP,are:
• The first and highest priority again is focused on available in plant process changes and
best management practices(BMPs)as the most cost-effective approach to color
reduction in order to maximize the likelihood of success
Process changes deemed to be of highest and reasonable certainty,thereafter
lowest certainty technologies
BMPs that hold promise to further reduce generation and discharge of color
• After it is clear that in plant process changes and BMPs alone are not be sufficient,in
plant segregated stream pretreatment and end-of-pipe treatment options are carefully
considered
The Tech Team recognizes that very difficult and unusual circumstances occurred in 2004,with
back-to-back historical flooding of the Pigeon River and associated significant costs($39 million)
for repairing damage and replacing equipment at the BRPP mill after 21 days of being out of
operation. The Tech Team also recognizes that significant additional expenditures have been made
over the last permit term for environmental projects($25.9 million),the largest portion for air
pollution controls(e.g.,MACT I and MACT II compliance)and including color reduction projects
($5.9 million), all building on previous projects and expenditures. All of this has occurred during a
continuing period of industry-wide transformation,capacity shrinkage,and mill closings.
Nonetheless,the BRPP mill management has committed to surviving these challenges. The Tech
Team notes that these efforts and expenditures have resulted in substantial and commendable
progress made to date by BRPP through expenditures for additional and improved best management
practices,process and related technologies,and treatment technologies which have reduced the long
term average color discharges. It is also noteworthy that some of these technologies and practices
have been in addition to those identified in the previous Tech Team/TRW reviews.
Process Improvements Previously Analyzed by Tech Team
As a result of its 2001 analysis of the BRPP mill discharges and operations,the Tech Team
identified five mill improvements that itjudged capable of reducing the discharge of color in the
mill effluent. BRPP and its consultant also identified several process optimization projects that
would reduce color discharges.The status of BRPP's implementation or evaluation of each of these
improvements is summarized in Table 1,discussed below.

Memorandum
September 5,2007
Page 3
Table 1. Review of Process Improvements Identified in 2001
'Predicted Color
Reduction(Final .Color -
Effluent,.lbs/day t Reduction
Improvement arm.avg) Implementation Status Achieved Comments
Process 1,400 Predicted reduction in Consultant recommends reduced CIO,
optimization C102 use(27%on HW, use and adding oxygen and peroxide to
projects 17%on SW)not made. E stages to reduce color generation
CIO,use increased on
SW,decreased 5%on
HW Total
BFR reliability 1,000—1,200 Pine line filtrate recycle reduction Further improvements to BFR
improvement increased from 74 to from 2001: reliability may not be feasible
80%. 6,000 lb/day,
Improved black >5,000 Spill collection =uot Additional improvement to black
liquor leak and improvements made; average liquor control possible: further
spill collection untreated color(influent eliminate overflows and pretreat
control(BMPs) to treatment)variability diverted high-color wastewater.Also
unchanged improve control of losses of white and
green liquors to reduce or eliminate
sulfide-based color
Ozone/CIO, 3,000—6,400 Inadequate evaluation BRPP concems for this technology are
stage for (lab studies);not installed noted.Notwithstanding inadequacies
hardwood line of lab studies,this technology
None considered low certainty in this case
and further detailed study not
warranted at this time.
2°d Stage OD for 1,100—1,400 Incomplete evaluation Detailed engineering evaluation needed
pine line (lab studies);not installed for costing and design and color
None reduction,followed by
implementation.BRPP concerns for
additional study are noted,but still
considered high certainty.
Color treatment <2,750 Evaluated(lab studies); CRP purge stream now averages 8,745
of CRP purge not installed lb/day.. Detailed testing needed for
stream extended period to determine what
fraction of this color is removed in the
None W WTP and strategies for reducing
color released in the purge. Any color
that is not removed in W WTP could be
reduced with segregated stream
pretreatment or other options.
,
Process Optimization Projects
In 2001,Liebergott&Associates and GL&V Pulp Group prepared an extensive analysis of the mill
fiberlines that included identification of options for effluent color reduction. Dr. Liebergott was
retained for this work by a coalition of environmental groups. This report,Bleach Environmental
Process Evaluation and Report(BEPER)(GL&V 2001)presented I recommendations for
incremental improvement to ftberline operations. These included suggestions for improving
process control,OD performance,reducing the amount of CIOZ used on both bleach lines, and
enhancing the extraction stages on both bleach lines with oxygen and/or hydrogen peroxide. The
BEPER recommendations were evaluated,and BRPP implemented those deemed to be technically,
economically,and operationally feasible.

Memorandum
September 5,2007
Page 4 -
Process control and OD performance have been improved. However,on the hardwood line,the D,
stage kappa factor has not been decreased as previously recommended and use of oxygen in the
extraction stage was discontinued. As a result,the total C1O2 charge on the hardwood line as of
May 2006 was only 5 percent less(not the predicted 27 percent less)than the C102 charge in 2000.
Similarly,on the softwood line,the D, stage kappa factor was not decreased as previously
recommended and the use of peroxide in the extraction stage was discontinued. As a result,the
total C102 charge on the softwood line as of May 2006 was 11 percent more(not the predicted 17
percent less)than the charge in 2000. While BRPP has noted the increased portion of higher
brightness pulps since 2001 as a reason for these changes,among other trade-offs cited the Tech
Team continues to believe these changes are still viable and should remain as high certainty options
that should be pursued for further color reduction.
In preparation for renewal of their NPDES permit,BRPP retained Liebergott&Associates and
GL&V Pulp Group to analyze their fiber lines,review the implementation of the 2001
recommendations,and identify further options for color reduction. In the 2006 update to the
BEPER(GL&V 2006),the consultants repeated their recommendations for BRPP to reduce the
kappa factor in the D, stage of each bleach line and replace the C102 bleaching power with oxygen
and/or peroxide in the extraction stages. Increasing the operating temperature of the hydrogen
peroxide extraction stage to reduce effluent color also has been identified as a viable option during
this process.
In addition to reducing the color of the bleach plant effluents,use of a lower kappa factor means
BRPP would use less C1O2 to bleach,which will reduce the total chloride content of bleach plant
filtrates. Lower chloride content can also be expected to make it possible for the mill to reduce the
CRP purge flow and the color it contributes to the mill effluent. The Tech Team also believes that
lower chloride content will make it possible for the mill to recycle more filtrates within the
hardwood fiber line,notwithstanding BRPP concerns(e.g., adverse effects to washing,carryover to
D stage,possible increased chemical usage and color). Further,it also may be possible to introduce
a portion of these hardwood filtrates to the BFRT process,which to this point has been dedicated
solely to recovering softwood fiber line filtrates,and reduce the total colored filtrates discharged to
the sewer.
BFR Reliability Improvement
As reported during the Tech Team'sFebruary 2007 site visit,BRPP spent$1.5 million over the last
five years to improve the reliability of the BFRTA4 system. These expenditures included replacing
tank liners for the three existing sand filters(now high grade stainless steel),replacing and/or
upgrading existing process piping with piping with improved metallurgy, installing a fourth(new)
multimedia filter, and installing a third ion exchange softener. With these improvements in more
reliable metallurgy and unit process redundancy,BRPP has increased the BFRTm closure rate from
73.7 percent in 2001 to 79.2 percent in 2006. Mill representatives stated that the present closure
rate of approximately 80 percent of the pine line bleach plant effluent represents the maximum
amount attainable without incurring unmanageable corrosion and scaling problems. Further
increases in closure and increased recycle rates above 80 percent may be possible but are likely to
be a difficult challenge because of the corrosion and scaling problems associated with current mill
bleaching filtrate chemistry. Scaling from hardness minerals accelerates above closure rates of 80
percent(Bodien,2007).

Memorandum
September 5,2007
Page 5
Improved Black Liquor Leak and Spill Control(BMPs)
BRPP continued efforts intended to improve its management of leaks,spills,and intentional
diversions of black liquor over the last six years. These efforts include:
• Interconnecting the pine line and hardwood line spill collection sumps so that
tankage in either line can be used interchangeably for spills;
• Repositioning sewer conductivity probes from sumps to in-line to more accurately
and reliably identify high conductivity wastewaters;
• Diverting up to one hour of total mill flow to off--line 1-million-gallon clarifier,
during high color releases,thus providing some equalizing of color discharge to
wastewater treatment plant;
• Prior to process line outages, improved prior planning for and capture of high-color
process liquors and black liquors and better managing their timed release to
treatment system;
• Continued operator training;and
• Implementing two hour testing for color at the W WTP with one hour testing during
outages or semi-annual shutdowns.
BRPP has stated that these improvements in BMPs have resulted in reduced color variability in
influent to the Primary treatment unit,which BRPP asserts is the best measure of color reduction
through in plant changes and BMPs. Data provided by BRPP are presented in Table 2 and depict
Primary(total)Influent Statistics by year.
Table 2. Primary(Total)Influent Statistics,by year
Mean Relative Percent Decrease
True Color 'Standard Standard Deviation from Baseline
(lbs/day) Deviation(SD) (SD/mean%) (2001).
2001 57,725 20,619 35.7% 0.00%
2002 54,780 17,195 31.4% 5.10%
2003 55,550 19,424 35.0% 3.77%
2004 49,466 18,786 1 38.0% 14.30
2005 1 45,175 22,297 49.4% 21.7%
2006 1 .38,454 14,015 36.4% 33.4%
Primary effluent,which is the total load to secondary treatment, is directly measured with a
composite sampler. Data provided by BRPP and compiled by the Tech Team are presented in
Table 3 (below)showing the mean,standard deviation,and relative standard deviation(standard
deviation as a percent of the mean)by year, for the years 2001 to 2006. Prior to 2006,the acid
sewer mixed with other mill wastewater prior to the treatment system,resulting in"sewer generated
color." As of January 1,2006,the acid sewer was separated from the other mill sewers and now
enters the treatment plant after the primary clarifier("primary effluent"). The primary effluent
sampler is located downstream of the mixing point of the primary clarifier overflow and acid sewer.
Thus,the statistics for 2006 presented in Table 3, represent the mixture of primary effluent and

Memorandum
September 5,2007
Page 6
newly rerouted acid sewer, including any color generated from the mixing of the two streams.
Some portion of the color generation is immediately measurable in primary effluent samples taken
from the channel leading to the aeration basin. It is also likely that additional color generation from
this mixing occurs,after the primary effluent sampling location within the aeration basin of the
secondary treatment system,with additional time for any chemical reactions to proceed to
completion.
Table 3. Primary Effluent(Influent to Secondary Treatment)Statistics,by year
Mean Relative
True Color Standard Standard Deviation Number of days
(Ibs/day) Deviation(SD) -.(SD/mean%) , >100,000 lb/day
2001 62,008 19,561 31.5% 13
2002 59,956 18,680 31.2% 16
2003 59,646 18,468 31.0% 10
2004 65,206 26,674 40.9% 40
2005 63,838 24,158 37.8% 28
2006 65,512 25,427 38.8% 36
Table 3 presents the number of days for which the primary effluent color exceeded 100,000 Ibs/day.
Comments received from BRPP assert that primary effluent is not the most appropriate measure of
progress. BRPP further stated that color loads to the treatment system have been reduced. In spite
of improvements made over the last permit term,including the acid sewer relocation,all clearly
made in good faith by BRPP,the Tech Team respectfully disagrees with these assertions. As
shown in Table 3,evaluation of available data does not appear to support BRPP's assertion that
there has been progress in reducing the frequency at which it experiences high color loads into the
secondary treatment system.
BRPP provided the Tech Team with notes describing mill events that were related to high primary
influent color in 2006 (Blue Ridge 2007a). These events included,among others,planned mill
outages,unplanned outages, a CRP slurry tank overflow,and a release from the evaporator related
to an equipment failure. BRPP did not report one single event or one single type of event that
caused high color in the primary effluent. Further,not all high primary effluent color resulted in a
high final effluent discharge(e.g.,BRPP reports that color associated with high turbidity is
effectively removed in the secondary treatment system). However,from analysis of the data,the
Tech Team concludes that the Canton mill can further reduce primary effluent loads through
continuing efforts to minimize unplanned spills and leaks and planned discharges of high-color
streams during fiber line disruptions. BRPP has reported some success through recent efforts in
detailed scheduling of planned outages, contingency planning for unplanned outages,and
continuing efforts to minimize process operation variability. The Tech Team wishes to
acknowledge these efforts and their importance. While clearly challenging,these efforts must be
further developed and consistently implemented to minimize high color discharge risks all agree are
associated with these fiber line disruptions,both planned and unplanned.
The Tech team continues to believe that the information presented in Table 3,among other
available performance data,holds valuable indicators and clues to the sources and solutions to
reducing the overall performance and variability in effluent color discharged to the Pigeon River.
On the other hand,BRPP has asserted that primary effluent information and other data collected
within the Mill's biological treatment system are not indicative of the facility's true performance.

Memorandum
September 5,2007
Page 7
BRPP believes that secondary effluent showed improvement, and data provided by BRPP are
presented in Table 4(below).
Table 4 Secondary Effluent Statistics,by year
Mean Relative:'
True Color Standard Standard Deviation Number of days
(lbs/day) Deviation(SD) (SD/mean.%) >100,000jb/day
2001 42,676 10,925 25.6% 3
2002 41,166 9,928 24.1% 0
2003 44,627 IQ,043 24.7% 1
2004- 41,463 32,568 76.6% 4
2005 39,092 10,092 25.8% 0
2006 37,058 8;959 24.2% 2
* -2004 data were affected by historic floods in September 2004
Ozone/Chlorine Dioxide Stage for the Hardwood Bleach Line
BRPP engaged the Pulp and Paper Research Institute of Canada(PAPRICAN)to investigate
potential modifications to the hardwood pulp bleaching process and determine effluent color
reduction that would result from these modifications. The PAPRICAN report entitled"Bleaching
Evaluation for Effluent Color Reduction"(Audet et at,2003)was provided to the Tech Team in
early 2007.
PAPRICAN stated that their objective was to evaluate whether modifications to the hardwood
bleaching sequence at Canton specified by Mr.Johnnie Pearson(BRPP process engineer)could
"generate effluents with a color reduction target of 25 percent."
BRPP provided PAPRICAN with oxygen delignified hardwood pulp. PAPRICAN bleached this
pulp in their laboratory,investigating various combinations of chlorine dioxide, ozone and
hydrogen peroxide.
The report concluded that ozone could replace some of the chlorine dioxide used in bleaching
(known as a"W"'stage),while producing pulp of equal or slightly better quality than the control
sequence. This is consistent with the open literature on ozone/chlorine dioxide combinations.
PAPRICAN also concluded that replacing some of the chlorine dioxide in bleaching with ozone
increased the color in the bleach plant effluents. This contradicts the experience reported by
Domtar(formerly E.B.Eddy)at their Espanola mill,where a dramatic reduction in effluent color
was observed when that mill installed an ozone pulp bleaching system(Munro and Griffiths,2000).
The Tech Team notes that the Espanola mill has no color discharge limits and it installed ozone to
reduce its bleaching costs.
The Tech Team found significant deficiencies in PAPRICAN's analysis of the laboratory results.
The 2006 Liebergott/GLV report agrees with this finding. The concentration of color in the
effluent for each stage was added to obtain the total concentration for each tested bleach sequence.
This approach neglects two points:
1) Mixing effluents produces reactions that may increase or decrease the
concentration of color in the combined effluent.

Memorandum
September 5,2007
Page 8
2) Filtrate volume affects the measured concentration(e.g.,lower volume will
concentrate the filtrate to a higher color). PAPRICAN's report does not present the
filtrate volumes,so a comparison of concentrations may be misleading.
Liebergott,et. al.,reviewed the PAPRICAN report and identified the same deficiency with regard
to effluent mixing. They also noted that the quantity of chlorine dioxide added to the ZD stage was
too high,which would result in higher effluent color(GL&V 2006,p 18).
In response to EPA's question about how the PAPRICAN results were used to estimate impacts on
final effluent color,BRPP responded:
The pilot study reactors were batch and not continuous and did not include
filtrate recycle. The pilot studies included' bleach stage filtrate color
concentrations, but there was no filtrateJlow rate data from which to calculate a
production-normalized filtrate color mass. For these reasons, we did not attempt
to calculate secondary effluent color impacts rising pilot study data for individual
bleach plant color streams.
In the PAPRICAN study, the individual bleach stage colors were compared
directly and in total. By both means, the color of the ZD stage was higher than
the baseline DEoD. It is also well known that when individual bleach stage
filtrates are mixed the resultant effluent color is very difficult to predict. (Blue
Ridge,2007a)
The Tech Team concludes that BRPP's investigation of the potential for hardwood pulp ozone
bleaching to reduce the mill's effluent color was inadequate. Notwithstanding the above-noted
inadequacies and upon reflection,the Tech Team believes that further laboratory trials appear not to
be necessary because this application of ZD technology may not be appropriate for this mill at this
time. Therefore,ZD technology is considered a technology option of lowest certainty for
application at this mill at this time.
Second Stage Oxygen Delignification for the Pine Bleach Line
BRPP contracted with Andritz/Ahlstrom("Andritz")to study,among other things,the addition of
an additional stage of oxygen delignification in the pine(softwood)bleach line at Canton. Andritz,
a well established supplier of pulping and bleaching technology and equipment,maintains the
Pruyn's Island Technical Center,which conducted the tests. The Andritz report,entitled,
"Laboratory CK and Lo-Solids Cooking with O-Do-Eop-D Bleaching Sequences on Softwood
Furnish from Blue Ridge Paper,Blue Ridge,NC"(Andritz Ahlstrom Sales 2001)was provided to
the Tech Team in early 2007.
The text of the Andritz report states that`BRPP requested the sales department of Andritz-
Ahlstrom to investigate alternative methods of pulping and bleaching that would reduce their waste
products and improve the quality of their hardwood and softwood paper products." As indicated by
this statement of work,testing of second-stage oxygen delignification was a minor part of the work
Andritz did for BRPP. Further, very few of the data in the report are usef il.for analysis of effluent
color improvement.

Memorandum
September 5,2007
Page 9
Specifically,Andritz compared single stage and two stage oxygen delignification of samples of
pulp provided by the BRPP mill.The tests showed that a second stage of oxygen delignification
could reduce the kappa number of the unbleached pine pulp by 22 percent.
Andritz did not bleach the pulp after the two stage oxygen delignification, so the report provides no
information on the impact of the additional oxygen delignification stage on effluent characteristics,
including color.
In response to EPA's question about how the Andritz results were used to estimate impacts on final
effluent color,BRPP responded:
The AndrtiZ Ahlstrom study of second stage 02 for pine shoved delignification
ranging from 42.7 percent for the single stage, 48.6 percent for the 0-0 and 55
percent for the 00 stage. With improvements that BRPP made on the existing
single stage pine 02, the deliginification increased from 40 percent to 45 percent.
With BFR in place on the pine fiberline, the effluent color reduction from this
improvement in 02 deliginification has been very difficult to identify. The
inability to quantify the effect on effluent color of improved 02 deliginification
made the capital cost to install a second stage 02 on pine not economically
feasible. (Blue Ridge,2007a)
BRPP's analysis of the benefits of adding a second oxygen delignification stage to the pine line is
incomplete. BRPP's consultants note that even with the percent delignification currently achieved
on the pine line,a second stage could achieve an additional 20 to 25 percent delignification(see
GL&V 2006,p 118).
By making a 20 to 25 percent reduction in the kappa number of the pine pulp before bleaching,20
to 25 percent of the colored material currently discharged from bleaching to the BFRTM would be
recovered and burned in the mill's recovery boiler. In addition,the quantity of chlorine dioxide and
caustic required in bleaching would be reduced by approximately 20 to 25 percent,reducing the
load on the BFRTM system. This would allow an increased proportion of the bleach filtrates to be
recycled through the BFRTM system. BRPP believes that a kappa number decrease or
delignification efficiency increase would not equate to a similar decrease in color. Although with
the information available it is not possible to rigorously calculate the benefit of this change,the
Tech Team would expect on the order of 1000 lbs/day reduction in bleach plant color discharge.
In 2001,the Tech Team recommended that BRPP conduct a detailed study to develop an
engineering design leading to installing an additional oxygen delignification stage for the pine
(softwood)pulping/bleaching line.The Tech Team estimated that this process change would reduce
effluent color by 1,100 to 1,400 lbs/day. Liebergott,et.al.,(GL&V 2006)estimated that
implementing a second oxygen delignification stage on the pine fiber line would reduce color
discharge by 1142 Ibs/day.They estimated the capital cost of adding an additional oxygen
delignification stage would be in the order of$2 to$3 million and the chemical cost savings
approximately$1.2 million/year,providing a reasonable payback. Mill staff has mentioned a three
year pay-back,which is consistent with this estimate. However,the mill has further asserted from
their more recent estimates that the cost could be$3 to 5 million owing,presumably at least in part,
to increases in the general prices of stainless steels(not as specifically fabricated and estimated For
this technology). The BRPP oxygen delignification systems were installed in 1993. Since that
time,the use of two-stage oxygen delignification rather than the traditional single-stage systems has
become well established in the industry because it normally further reduces mill operating costs.
BRPP believes that the previous evaluation of adding a second stage oxygen delignification stage

Memorandum
September 5,2007
Page 10
should be repeated in part because of differences cited in delignification efficiencies,and concerns
for possibly lower-than-estimated color reductions. Notwithstanding these concerns,the Tech
Team continues to believe this technology has progressed beyond being considered"reasonable
certainty"in 2001 to"highest certainty"at this time. Therefore,the Tech Team again recommends
that priority should be given to a detailed evaluation for identifying necessary adjustments to
upstream pulp digestion(e.g.,kappa number targets),downstream bleaching(e.g.,bleaching
chemical usage rates)and brightness/strength parameters,designing and costing,and refining color
reduction projections. In order to satisfy BRPP's recent concerns,an update from the results of this
work may need to be shared with the TRW,prior to being implemented at the earliest possible date.
Andritz also evaluated modifications to the mill cooking process. These would require complete
replacement of the digester systems at Canton,which would cost(at least)several tens of millions
of dollars,if they are feasible at all within the mill's space constraints. The Tech Team concluded
that while theoretically possible,modifications to the mill cooking process do not merit further
analysis at this time.
Treatment of CRP Purge Stream for Color Removal
The Chloride Removal Process(CRP)purge is a low flow, highly concentrated stream. Color is
typically 41,000 platinum cobalt units(pcu)in a stream that discharges at 10 gpm(15,000 gal/day
or 3 tank trucks/day).BRPP reported that in 2006 the CRP purge contributed approximately 8,745
lb/day(23 percent)of the total mill color loading to the treatment system but only 0.05 percent of
the discharge flow. By comparison,in 2001 the CRP contributed approximately 5,000 lb/day(13
percent)to the treatment system loading(EPA Tech Team,2001). Thus, in the last five years there
has been a significant increase in color contributed by the CRP,both in lb/day and in percent of
total mill load. BRPP reported on its investigations into technologies for reducing CRP purge color
in its March 2005 report,"Chloride Removal Process(CRP)Color Reduction Technology
Assessment" (Blue Ridge 2005). In this report,BRPP points out that the CRP purge is a very
concentrated material(360,000 mg/L or 36 percent total dissolved solids)that is discharged to
sewer at 165°F. Handling the material is difficult because it will crystallize as it cools. Also,it is
quite corrosive due to the high chloride content.
As described in their 2005 report,BRPP assessed more than nine alternatives for disposal or
treatment of the CRP purge and concluded that none was technically feasible. Although consistent
performance was not demonstrated, C1O2 bleaching was a low cost,potentially effective means of
reducing the CRP purge color prior to introduction to the treatment system. BRPP found that CIOZ
bleaching could remove 75 to 90 percent of the color in the CRP purge stream,with some concern
about consistency. This is a significant reduction in a now prominent source of color.
Although CRP purge is a relatively low flow stream,BRPP estimated that off-site solidification and
land disposal would cost more than$3.6 million/year,which does not include the additional cost of
loading facility infrastructure.
During the Tech Team's 2007 mill visit,BRPP stated that there was no apparent decrease in
secondary effluent color when CRP wastewater was not flowing into the treatment system. In
response to a Tech Team request,BRPP presented data correlating the days on which the CRP
process was shut down with secondary effluent discharge color,for August 2006 to January 2007
(Blue Ridge 2007a). During this period,there were nine widely dispersed pairs of days when the
CRP process was down for part of the day. BRPP believes that CRP color is removed in the
secondary treatment system,based on their analysis of variance(ANOVA)comparing"down"days
with CRP operating days and"general observations."

Memorandum
September 5,2007
Page 1 I
In response to a Tech Team follow-up request for clarification,BRPP later asserted that these data
allowed no definitive conclusion,and that there is no relationship of presence or absence of CRP
purge to secondary effluent color based upon general observations. The Tech Team does not agree
with this belief or rationale for the following reasons. First,with one exception,the periods of CRP
shutdown are only a day or so each,which is insufficient time for the W WTP to stabilize with the
change in raw effluent characteristics. Second,the times of shutdown and startup of the CRP do
not correspond with the effluent sampling times in the mill system,so that there is no direct
correlation in time with the effluent sample.Further,the fact that all CRP"off'days are in pairs
suggests that CRP was down for a period that spanned parts of two mill sampling days.
The simple mathematical average of treated effluent color discharge during"CRP off"days days for
August to December 2006 is 39,995 Ibs/day. The average when the CRP process was operating is
36,958 lbs/day. This suggests that the presence of the CRP purge stream in the wastewater
treatment system causes a reduction in effluent color. This defies common sense. Also,the
difference in effluent color between the"CRP on"and"CRP off'days is 7 percent,while day to
day variations in color discharge values are frequently over 20 percent,tending to subsume and
confound any analysis of the impact of changes in the CRP purge stream. BRPP asserted that color
performance data from this period likely varied due only to normal day-to-day performance
variation.
In short,because there are so few consecutive days without a CRP purge,the data from the period
August to December 2006 are not sufficient for establishing the extent to which the CRP purge
contributes to final effluent color. In order to explore this further,BRPP could conduct a full-scale
mill trial in which the CRP purge is excluded from the wastewater treatment plant for a period of at
least three weeks. This can be achieved in two alternative ways,or perhaps a combination of both.
The first is to shut off the CRP purge for at least three weeks,and allow the chloride concentration
to slowly build up in the recovery system. Early literature published by Champion on the BFRT"'
process showed that the response of the chloride and potassium content in the mill's white liquor to
operation of the CRP was very slow,requiring a month or more to show significant changes. This
is consistent with experience in other mills,and is due to the fact that the quantity of chlorides and
potassium removed by CRP is small relative to the inventory in the mill's black,green and white
liquor system. The second approach would be to store the CRP purge stream,either in the spare
clarifier or off site for a period of at least three weeks. The impact of excluding the CRP purge
from the wastewater treatment plant would be observed by routine analysis of effluent color. If the
effluent color without the CRP purge is unchanged,BRPP could conclude that the CRP purge
contributes little to the final effluent color. In this case, further research into reducing CRP color
would be a low priority. On the other hand,if the effluent color without the CRP purge decreased,
BRPP could conclude that the CRP purge contributes to the final effluent color and further research
into reducing CRP color should be undertaken.
BRPP mill staff asserted that a full-scale shut off of CRP purge to the treatment system for such a
period of time(e.g., at least three weeks)would not be operationally feasible,but offered no
specific facts or reasons why this would be the case. Nonetheless, given BRPP's concerns for
operational feasibility at full scale,the Tech Team is open to another reasonable approach that
could be devised. Such an approach would need to gather the data necessary over a sufficient
period of time to better identify and quantify the underlying color loads to the treatment system,
both with and without the purge from CRP. Moreover, it would be important to identify and
quantify to the extent possible any changes in the downstream color generation and removal
processes that are occurring with the current acid sewer introduction point just upstream of the
aeration basin in the secondary activated sludge wastewater treatment system.

Memorandum
September 5,2007
Page 12
BRPP also could investigate approaches to prevent color from accumulating in the CRP. The
source of the color in the CRP purge stream is carryover of black liquor particles in the direct
contact evaporators(DCE)in the recovery boiler systems. This carryover could be eliminated if the
two traditionally designed recovery boilers(which are 34 and 42 years old)were replaced by one
modern boiler. This would probably represent a capital cost of over$100 million,and would very
substantially reduce the energy costs at the mill,since today's recovery boilers are much more
efficient than the DCE/recovery boiler systems of the vintage installed at Canton. Analysis of all
the economics and long term life of the mill would be necessary to evaluate such a major
investment.
On a more modest level, it may be feasible to reduce black liquor carry over by adjusting operating
conditions in the existing DCE's. The Tech Team is not aware of any experience with this in other
mills,or research,but the situation at Canton strongly suggests that at least some investigation and
trials of modifications to the operations is warranted. Any of the measures discussed previously in
this document to reduce C1O2 use could reduce the quantity of chloride to be removed in the CRP
purge stream. If this is reduced,the color discharge also would be reduced.
BRPP should also further investigate CIOZ treatment and other treatment of color in the segregated
CRP purge stream and other approaches for excluding the CRP purge stream from the mill
discharge.
Additional Color Reduction Strategies
The Tech Team has identified the following color reduction activities that should be for improving
the color removed by the Canton Mill wastewater treatment plant:
• Investigate in further depth color formation when acid wastewater is mixed with
mill wastewater in the current configuration,with and without the CRP purge,and
identify techniques to reduce this effect;
• Maintain addition of polymer and/or other treatment chemicals to the high-color
wastewater diverted to the extra primary clarifier,and investigate improving
equalization and pretreatment performance;and
• Further investigate adding polymer and/or other treatment chemicals to aeration
basin mixed liquor prior to introduction to the secondary clarifiers.
These strategies are discussed below.
Color Formation When Acid Wastewater Is Mixed With Mill Wastewater
BRPP provided the Tech Team with daily color data for the"Low Lift"(mill sewer),acid sewer,
and primary effluent sampled after the acid sewer is added in the discharge channel of the primary
clarifier leading to the aeration basin of the secondary activated sludge biological treatment system.
Figure 1 (below)presents the total mill color calculated by adding the mill sewer lb/day to the acid
sewer lb/day(the lower(blue line)on the figure). For comparison,the primary effluent sampled
after the acid sewer is introduced is also shown on the figure(the upper red line on the figure).
Thus,the figure depicts the impact of mixing the acid sewer with the rest of the mill effluent'.
3 The color of the mill sewer wastewater may be reduced somewhat by treatment in the primary clarifier. This color
reduction is neglected in the calculated untreated color,so Figure 1 is probably a slight underestimate of the impact of
mixing the acid sewer with the rest of the mill effluent.

Memorandum
September 5,2007
Page 13
1sD,o6D
Total untreated color,before and after m(zin0,2006 (Ibslday)
125,000
100,00D
75,00o A
YY 1
50,000 1
25,000
IJan 31Jan 14Aar 314ar 304pr 30Atay 29Jue 294ul 28-Aug 27Sep 27.0d 2"ov 2"ec
Figure 1: Impact of Mixing Acid Sewer and Mill
The Tech Team observed:
• The quantity of color formed on mixing the acid sewer and mill sewer is striking.
On average,the quantity of color formed is 78 percent of the total color in the two
streams. In other words,the simple mixing of these streams forms nearly half the
total color discharge from the mill.
• The variation in quantity of color formed by mixing the effluent streams from day-
to-day is dramatic,as is evident in the graphs. When expressed as a percentage of
primary input color,the value ranges from essentially zero on some days to a
maximum of 480 percent.
• There is no obvious correlation between the values on any one day, or series of
days close to one another;however,statistical analysis has not been attempted.
Notwithstanding these observations,the Tech Team understands and appreciates BRPP's efforts
during the last permit tern to reduce color formation through the acid sewer relocation project. The
Tech Team suggests that BRPP build on this project and the above color reduction strategies to
better understand the mechanisms of and the follow-up strategies for reducing color formation in
the current sewer configuration. BRPP could investigate,among other things,how sulfides
introduced by leaks,spills,and unplanned discharges from white and green liquor systems into the
mill wastewater contribute to effluent color: In particular,BRPP could investigate whether sulfides
in the mill wastewater contribute to color formation when acid sewer is added to mill effluent prior
to biological treatment. Approaches to this investigation should include:
• Laboratory experiments on effluent with varying degrees of sodium sulfide
addition; and
• Daily measurement of the sulfide content of the effluent from the primary clarifier
influent at the low lift pump sampling station for a period of at last three months to
determine correlation of sulfide concentration with color formation.
In most mills,losses of sulfides can be reduced. Well known sources include imbalance in the
weak wash system,as well as spills of white,black, and green liquor. BRPP should further
investigate losses from the green and white liquor systems and technologies that can reduce these
losses.

Memorandum
September 5,2007
Page 14
Improving W WTP Performance Using Chemicals
Several bleached kraft mills around the world have successfully reduced color to well below 5
lb/ton pulp by installing tertiary treatment systems. These systems use polymers and other
chemicals to precipitate color bodies,then remove the precipitate in tertiary clarifiers. One of the
newest of these mills is Celco in Valdivia,Chile. This mill has excellent in-plant effluent control,a
conventional secondary wastewater treatment plant,followed by a small tertiary system.Effluent
from this mill is depicted in Figure 2(below)beside the effluent from BRPP.
x
Figure 2: Comparison of BRPP Canton Mill Effluent(February 2007)and Valdivia Mill
Effluent(November 2005)
The Tech Team notes that treatment systems like the one operated at Valdivia have a capital cost in
the tens of millions of dollars,and can create issues with solid waste disposal. BRPP also
expressed the opinion that this comparison was not appropriate. However,some more modest
control measures using variations of this technology also exist. For example, since March 2004,
Glatfelter Inc., Spring Grove,PA has supplemented its in-plant color control strategies by using a
commercially available polyaluminum chloride polymer to enhance color removal in the
wastewater treatment plant. The polymer is added in the discharge flume from the aeration basin,
just upstream of the mixing box feeding the four secondary clarifiers. The polymer reduces pH and
complexes with organic compounds that produce color. Colored material settles out with the
secondary sludge which is held in the former stabilization basin before dewatering. Glatfelter has
not reported sludge dewatering problems.Polymer used for additional color removal reportedly
costs on the order of$2,000 to$3,000/day. Moreover,neither the Valdivia mill nor the Glatfelter
mill employs the BFR77N system as applied at BRPP.
As further in-plant process changes and improved BMPs are implemented and color loads are
reduced in magnitude(long term average and variability)and change chemical composition,BRPP
could conduct further laboratory trials of commercially available polymers and other wastewater
treatment chemicals. In some cases this may entail repeats of previous tests, for example for
polyamine,but under potentially different circumstances and wastewater chemistry than previously
tested. In addition to those previously evaluated, it could be helpful to assess adding one or more of
these chemicals upstream of the secondary clarifiers. During these trials BRPP would determine
the potential for reducing color discharge and estimate the costs. Such analysis would consider

Memorandum
September 5,2007
Page 15
seasonal use of the additive chemicals (i.e.,adding the chemicals during periods when river flow is
low and the mill discharge has the greatest impact on the river color). The Tech Team
acknowledges BRPP concerns regarding significant issues that may occur,such as possible effluent
toxicity,difficulty in sludge dewatering,and cost.
If the laboratory trials are successful,BRPP could institute a full-scale trial for one month, and
report results to the TRW.
Pretreatment of Diverted High-Color Wastewater
BRPP currently diverts up to one hour of total mill flow at current flow rates to their off-line 1-
million-gallon clarifier,during high color releases. The purpose of this flow diversion is to equalize
color contributions to the wastewater treatment plant. Diverted high color wastewater is batch
pretreated by polyamine and returned to the wastewater treatment system. The Tech Team believes
that BRPP should further investigate options for increasing the performance of equalization and
pretreatment capacity beyond that which currently exists. This would probably be an important
contribution to both further reducing color variability,an increasingly higher priority endeavor as
long term averages are reduced,and to removing color before being introduced into the secondary
activated sludge biological treatment system.
Summary: Additional Identified Color Load and Variability Reducing Activities.that BRPP
can Pursue in the Next Five Years
Since installing the BFR process and other improvements(OD,BMPs,etc.),BRPP is to be
commended for the important progress in reducing their annual average color discharges,which
needs to be continued. However,high color discharges continue to be experienced for short periods
(e.g.,daily) and these discharges become more evident as the annual average discharge is reduced.
When these discharges coincide with periods of low river flow(typically in the late summer),they
can contribute to an elevation in river color that could be noticeable to the citizens who use the
river. Thus,reducing the impacts of the peaks in color discharged from the mill requires not just
reducing the annual average color discharged but also reducing variability measured by the daily
color discharges. Mill process changes that reduce wastewater color are generally preferred to end-
of-pipe treatment because they may have lower capital costs and may benefit the mill by reducing
operating costs and improving process efficiencies. However,mills in environmental regulatory
jurisdictions with severe restrictions on their color discharges have been required to implement end-
of-pipe color removal technologies since the 1970's. Although the Tech Team continues to
maintain the highest priority for in-mill improvements such as process changes and optimization,
increased black liquor recovery and further improvements in BMPs, external color removal
technologies should continue to be considered carefully in the mix of options for further controlling
the color of BRPP's discharges. These color removal technologies include,with first priority,
treatment of segregated low-volume concentrated wastestreams(e.g.,the CRP purge)and thereafter
end-of-pipe wastewater treatment.
The Tech Team identified strategies focused primarily on in-mill process improvements but also
including color treatment that BRPP can use to further reduce its effluent color discharges. These
strategies are summarized below.
• Continue to improve the performance of BMPs to further substantially reduce and
ultimately eliminate discharges of highly-colored wastewaters directly to the
wastewater treatment system through further improvements in-

Memorandum
September 5,2007
Page 16
o managing and controlling planned and unplanned releases of highly
colored process liquors through regular mill staff meetings
o interconnected collection sump capacity within the mill available to both
fiber lines for capture and recovery of leaks,spills,and planned diversions
of black liquor and other highly-colored wastewater
o increasing use of short-term testing to supplement advanced real-time
process monitoring,rapid communication among mill staff,identifying and
immediately repairing failed equipment/parts,regular operator training,
and
o moving forward with the planned CRP sump and containment project to
eliminate unplanned releases of this highly-colored material to the mill
sewer.
• On the pine bleaching line, implement the use of peroxide fortification of the Eo
stage and decrease the target kappa factor as recommended in BEPER 2001 and by
Liebergott/GL&V 2006. Evaluate the use of high temperature for the peroxide-
fortified extraction stage.
• On the hardwood bleaching line,implement the use of oxygen and peroxide
fortification of the E stage and decrease the target kappa factor as recommended in
BEPER 2001 and 2006. Evaluate the use of high temperature for the peroxide-
fortified extraction stage.
• Complete an expedited and detailed evaluation of and install an additional oxygen
delignification(OD)stage for the pine pulping/bleaching line.
• As C102 use is reduced through second stage OD on the pine line and other options
on both fiber lines, further investigate increasing the amount of hardwood filtrates.
recycled and investigate introducing for the first time some of these hardwood
filtrates to the BFRTm system,and thus potentially further reduce the purge rate
from the CRP,now a significant portion of the total color discharged from the mill
processes.
• Continue to evaluate the impact of the CRP purge on treated effluent color to
determine if the CRP color,now a significant portion of the total color discharged
from the mill processes,is removed by the treatment system. Such an effort may
take special efforts to accomplish and for a meaningful period of time. If CRP
color is not removed in the treatment system, investigate approaches to prevent
color from accumulating in the CRP,such as reducing black liquor carryover by
further adjusting operating conditions in the direct contact evaporators. Also, if
CRP color is not removed in the treatment system, further investigate C102
pretreatment of the CRP purge to reduce its color prior to being introduced into the
mill wastewater treatment system.
• If the CRP purge color is found not to be removed in secondary treatment, avoid
releasing the CRP purge during periods of low stream flow(or truck it off site);
• Continue to investigate and implement strategies for improving color removed by
the Canton Mill wastewater treatment plant:

Memorandum
September 5,2007
Page 17
— Further analyze color formation when acid wastewater is mixed with mill
wastewater in the current configuration,particularly in the activated sludge
aeration basin,and identify other techniques,such as minimizing sulfide
releases to the mill sewer from white and green liquor leaks,spills,and/or
diversions,to reduce this effect
— Maintain or further increase the performance for pretreating highly-colored
wastewaters prior to introducing them to the wastewater treatment system,
including further optimizing adding polymer and other pretreatment
chemicals to the highly-colored wastewater diverted to the extra primary
clarifier and/or any additional facilities that may be provided;
Further investigate treating total mill biological system effluent prior to
discharge using polymers or other wastewater treatment chemicals
upstream of the secondary clarifiers, particularly during periods of high
influent color and/or low river flow;and
• Curtail pulp production during periods of low stream flow;this should continue to
be considered an option of last resort,given that best performance has been noted
by the mill to be during extended periods of steady production and greater risk of
elevated color during process shutdown and startup.See Low Flow Contingency
Plan,December 1, 1998.
Suggested Final Effluent Color Limits for Blue Ridge Pulp and Paper
Substantial and commendable progress has been made to date by BRPP through expenditures for
additional and improved process and related management practices and treatment technologies
which have reduced the long term average color discharges. Some of these technologies and
practices have been in addition to those identified in the previous Tech Team/TRW reviews. This
progress in reducing the annual average of color discharges has made increasingly important and
apparent the importance of reducing day-to-day effluent variability along with the other
recommendations of the Tech Team going forward from this critical point in time. Therefore,the
Tech Team recommends to the TRW and the North Carolina Department of Environment and
Natural Resources that the existing permit limits be expanded to include a maximum day discharge
limit,and not rely solely on the annual average and maximum 30-day average limits to protect the
quality of the Pigeon River. Daily maximum and maximum 30-day average permit limits would
enhance the consistency of day-to-day in-stream water quality,and would be consistent with limits
for other parameters controlled in the present BRPP permit(BOD5,TSS,AOX,etc.). The Tech
Team also believes that these effluent limitations for color should continue to be applied
unambiguously at the end-of-pipe discharge of the mill to the river. However,the current permit is
not clear that this is the point of application of effluent limits for color. See Table A(1),which
prescribes end-of-pipe monitoring,but no color limits are included. See the TRW's 2001
Memorandum,at item no. 8. BRPP has commented that inclusion of a daily maximum end-of-pipe
effluent limitation for color would lead to administrative efforts focusing on any violations of such
a daily maximum limit that may occur,and thus diverting limited mill staff and resources away
from executing process controls and BMPs and wastewater treatment measures. The Tech Team's
recommended range of end-of-pipe permit limits and the derivation of these limits are presented in
Table 5,and discussed,below.

Memorandum
September 5,2007
Page 18
Table 5. Tech Team Recommended Range of End-of-Pipe Color Permit Limits
Limit Range.of Recommended Limits(lb/day)
Annual Average 32,000 to 37,000
30-day(Monthly)Average 44,800 to 51,800
Daily Maximum 83,840 to 96,940
Basis for Recommended Annual Average for Color
BRPP provided daily measurements secondary effluent color(lb/day)for every day in 2006.
Examination of the daily measurements for 2006 identified two days(July 7 and 8)with measured
discharge greater than 100,000 lb/day. BRPP reported that this elevated color discharge resulted
from"CRP slurry tank overflow for approximately 20 minutes,the first time the mill experienced
this type of event." Because these discharges were so high and from a unique source,they were
omitted from the calculation of the annual average. The annual average for 2006,without July 7
and July 8,is 36,695 lb/day,which rounds to 37,000 lb/day.
• This annual average load is less than the 39,0001b/day suggested by BRPP.
However,it is based on the mill's 2006 performance and does not include any
reductions that may be achieved by the process changes outlined in this
memorandum. As a result of analysis of the BRPP mill discharges by the Tech
Team and others in support of the 2001 permit,the permit's interim color goal was
32,000 lb/day with a range up to 39,000 lb/day.
• As described earlier in this memorandum,the Tech Team recommends that BRPP
implement several key process improvements and investigate others in order to
reduce the annual average toward the interim goal of 32,000 lb/day,which the Tech
Team recommends be carried forward from the 2001 permit as the goal for this
permit term.
Basis for Suggested Daily Maximum and 30-Day Average Limits for Color
The statistical analysis used for the development of EPA's Cluster Rules is documented in
Statistical Support Document for the Pulp and Paper Industry: Subpart B(EPA, 1997).This
document describes EPA's development of, among other things,the variability factors that were
used to calculate NSPS for BOD5 for the Bleached Papergrade Kraft and Soda(BPK)subcategory.
These variability factors are reproduced in Table 6.
Table 6. Bleached Papergrade Kraft NSPS Variability Factors
Variability'Factors
Analyte 1-Day 30-Day(Monthly)
BOD, 2.62 1.4
Source: U.S.EPA 1997. Table 24.
The BOD5 variability factors shown above were developed using daily monitoring data for the best
performing(in terms of production normalized BOD5 load)BPK mills. The monitoring data
represent the effluent from well-operated wastewater treatment systems. The calculated variability
factors account for the autocorrelation of the daily loads and the log-normal distribution of the
measurements.

Memorandum
September 5,2007
Page 19
Notwithstanding BRPP's comments to the contrary,the Tech Team believes that it is reasonable
and appropriate to use the variability factors developed for the BPK NSPS for BOD5 to calculate
BRPP daily maximum and 30-day average permit limits for color because:
• The factors were developed using monitoring data from BPK mills with well-
operated secondary treatment and BRPP is a BPK mill with well-operated
secondary treatment;
• Color, like BOD5, is monitored at the effluent of the secondary treatment plant;and
• Color, like BOD5, is removed from effluent by a combination of biodegradation
and absorption/adsorption to biomass.
Applying the BODS variability factors to the 2006 annual average daily color discharge results in
the following daily maximum and 30-day average limits:
Daily Maximum: 37,000 lb/day x 2.62=96,940 lb/day
30=Day(Monthly)Average: 37,000 lb/day x 1.40=51,800 lb/day
The Daily Maximum and 30-day(Monthly)average limits for the long term average goal of 32,000
lb/day are derived in the same manner.
Comparing the 2006 effluent monitoring data to these limits finds that two days exceeded the daily
maximum,July 7(104,504 lb), and July 8 (101,223 lb),during the unexpected CRP tank overflow.
Further,the 30-day(Monthly)average(51,800 lb/day),as calculated for compliance purposes in the
current permit,was not exceeded for 2006.
Comparison to Glatfelter Permit Limits
The Glatfelter,Inc. mill in Spring Grove,PA(NDPES permit number PA0008869), like BRPP,is
an older bleached kra8 mill that discharges to a small,color-limited stream. As noted previously,
however, Glatfelter does not use the BFRTm process that is unique to BRPP. As described in PA
DEP's Water Quality Protection Report(Fudanic,2007),during the summer,the Glatfelter mill is
permitted to discharge 140 mg/L color(average monthly)and 280 mg/L(daily maximum). Winter
discharge limits are more stringent. The Glatfelter mill's average daily discharge is 11.9 MGD and
it produces an average of 1268 U.S.tons of paper per day. BRPP produces approximately 1640 US
tons per day,with a greater proportion of softwood to hardwood processed than at the Glatfelter
mill,and with a daily total wastewater flow of approximately 26 MGD. Therefore,the Tech Team
calculates that the recommended range of end-of-pipe permit limits for BRPP(32,000 to 37,000
lb/day annual average;44,800 to 51,800 lb/day 30-day average; 83,840 to 96,940 lb/day daily
maximum) are less stringent than the Glatfelter permit limits expressed on the same production
normalized basis (either lbs/metric ton pulp or finished paper).

Memorandum
September 5,2007
Page 20
References
Andritz Ahlstrom Sales. 2001. Pruyn's Island Technical Center Report 2001-068 Part 1.
Laboratory and Lo-Solids Cooking with O-Do-Eop-D Bleaching Sequences on Softwood Furnish
from Blue Ridge Paper,Blue Ridge,NC. Part 1 Softwood Results. Part 2. Hardwood Results.
(December 6).
Audet,Andre,Michel Faubert,Zhi-Hua Jiang and Barbara van Lierop,PAPRICAN. 2003.
Technical Service Contract Report TSC-7447. Bleaching Evaluation for Effluent Colour
Reduction. Prepared for Blue Ridge Paper Products,Inc.,Canton,NC. October.
Blue Ridge Paper Products,Inc. 2005. Chloride Removal Process (CRP) Color Reduction
Technology Assessment. (March).
Blue Ridge Paper Products,Inc. 2006a. Color Compliance Report: Canton Mill.(May).
Blue Ridge Paper Products,Inc. 2006b. Blue Ridge Paper response to questions from the
Technology Review Workgroup(TRW) that were e-mailed on 28 Nov 2006. (December 19).
Blue Ridge Paper Products,Inc.2007a.Response to additional questions for BRPP about data
provided to TRWDon Anderson e-mail dated 5 March 2007(March 15)
Blue Ridge Paper Products, Inc. 2007b. March 19, 2007 Additional Data Required from BRPP
(March 28).
Bodien,Danforth G. 2007. Site Visit Report,Blue Ridge Paper Products, Canton,North Carolina.
(April 2007)
EPA Tech Team. 2001. Memorandum to Technology Review Workgroup. "Additional Color
Removal Technologies and Their Economic Impacts on Blue Ridge Paper Products, Canton,NC.
(July 25,2001).
Furjanic,Sean M. 2007. Water Quality Protection Report,P. H. Glatfelter Company, Spring
Grove Borough and Jackson Township,York County, for the Renewal of NPDES Permit No.PA
0008869.
PADEP Southcentral Regional Office(draft,February 2007).
GL&V Pulp Group, Inc.and Liebergott&Associates Consulting. 2001. Bleach Environmental
Process Evaluation and Report. Prepared for Blue Ridge Paper Products,Inc. and Clean Water
Fund of North Carolina. (June 8)
GL&V Pulp Group,Inc.,Liebergott&Associates Consulting. 2006. 2006 Update: Bleach
Envir0nmental Process Evaluation and Report. Version containing manufacturer's proprietary
information. Prepared for Blue Ridge Paper Products,Inc.(July 7,2006)
Munro,Fred and John Griffiths. 2000. Operating Experience with an Ozone-based ECF Bleaching
Sequence,Proc.International Bleaching Conference, Halifax, Canada,2000. TAPPI Press.
Technology Review Workgroup,2001.Memorandum to North Carolina Division of Water
Quality and the NC Environmental Management Commission's NPDES Sub-Committee.

Memorandum
September 5,2007
Page 21
"Additional Color Removal Opportunities, Blue Ridge Paper's (BRP) Canton,NC
Bleached Kraft Paper Mill, 2001 NPDES Permit Renewal." (August 3, 2001).
U.S.EPA, 1997. Statistical Support Document far the Pulp and Paper Industry: Subpart B.
(November)

PFV
Agenda
EPA Tech Team Final Report—Discussion with DWQ
Blue Ridge Paper Products Inc.
August 24,2007
I. Introduction
H. Areas of Agreement with Tech Team Report:
• CRP color studies
• Leaks and spills
• Outage planning GqC e e" w v
• Acid sewer color studies
• Color treatment
• Spill capacity
III. Unresolved Issues in Tech Team Report:
• Second-stage oxygen deliginification on the pine fiberline
Do not agree this is highest certainty. The requirement to install second stage oxygen
delignification is not appropriate at this time. Laboratory studies and engineering analysis to
evaluate the color reduction benefit and cost of 2-stage OD on pine against the criteria of
technical,economic and operational feasibility are appropriate.
o Install cost$3-$=(preliminary)
o Predicted color effluent reduction — 1000 lbs/day
o Pulp strength is a commercial concern when driving Kappa number to this range(11-13),
the#19 PM machine and product line are very sensitive to pulp strength
dV, o Operating cost reduction of$1.2 MM is overstated, $500 to 600k max (Liebergott 2006
�" tir' predicts 0.2% reduction on C102 and NaOH)
o Cannot take ie d credit and color reduction credit both v00
%'Q ex fv�oC'l y
• Peroxide fortification on the pine and hardwood fiberlines extraction stages and hardwood
extraction stage oxygen fortification
Do not agree these are highest certainty. The requirement to implement these is not appropriate
at this time. The 2006 Liebergott report recommends evaluation of peroxide fortification of the
pine Eo stage and evaluation of oxygen and peroxide fortification of the hardwood E stage.
Consistent with the 2006 Liebergott report, full-scale trails to evaluate the color reduction
benefit of EoP on bleach plant filtrate and final effluent color are appropriate.
o Install cost$150 to 200k, all equipment was flooded in 2004
o Operating cost increase of$1.3 MM per year
o Predicted color reduction is in Eo stage effluent only, does not show up in SE color
o Do full scale trials to evaluate

Op Blue Ridge Paper Comments on 8-14-2007 EPA Tech Team Final Report
Page 2
• Daily color limit
Daily color performance is important,and we continue to work hard to minimize color variability.
However, a daily color limit is not appropriate.Also, under both EPA and North Carolina water
quality procedures for applying aesthetic water quality standards, a 30-day average is listed as the
appropriate time period.Therefore,a monthly average limit is appropriate.
IV. Other Issues and Concerns with Tech Team Report
• CRP studies
o Don't believe idea to turn off CRP for extended period to determine effect is feasible
o CRP is an important part of BFR process, which avoids 15,000 to 20,000 lbs per day of
effluent color
o Studies are appropriate
• Primary effluent(PE)color
o Complex and confusing issue
o Primary influent(PI)color and secondary effluent(SE)color have significantly improved
o PI and SE color are the correct measure of effectiveness of mill BM[Ps —
o Agree that further study of sewer generated color within the wastewater plant may yield 1
useful information for additional improvement
Primary Influent(PI), Primary Effluent(PE), and Secondary Effluent(SE) G G�0. Sew
Blue Ridge Paper Canton Mill
70,000
65,206 65,512
63,838
62,008
59,956 59,64
60,000
T 57,72
a�~N0d-
540 555 5 ,
50,000
9,466
c
as,ns
U 44,627
42,676 1 492
40,000 67
38,454
39,092 37,0581
30,000 - - - _-
2001 2002 2003 2004 2008 2006
t PI Color tPE Color -*-BE Color

Blue Ridge Paper Comments on 8-14-2007 EPA Tech Team Final Report
Page 3
• Comparison with Glatfelter
o Comparison of Blue Ridge Paper Canton Mill to Glatfelter Spring Grove omits several
important differences between the two mills
o Each mill's situation is unique, and the comparison of effluent limits is not on an
equivalent basis
o When all the differences between the mills are properly considered, the color control
performance of the two mills are similar n
V. Next Steps /v1
• TRW meeting and recommendations based on Tech Team Report
• Changes to monitoring parameters and frequencies
• Preliminary draft permit

MEMORANDUM
DATE: August 14,2007
SUBJECT: Color Removal Strategies For Blue Ridge Paper Products, Inc
FROM: EPA Technology Team'
TO: Technology Review Workgroup
Purpose of this Review
Blue Ridge Paper Products Inc.(BRPP)has requested renewal'of their National Pollution
Discharge Elimination(NPDES)discharge permit NC0000272. This permit allows discharge to the
Pigeon River of industrial and other wastewaters from the pulp and paper mill BRPP operates in
Canton,NC. In their May 2006 Color Compliance Report(Blue Ridge,2006a),BRPP requested
that North Carolina reissue the NPDES permit for the Canton Mill with an annual average effluent
color limit of 39,000 lbs per day. This is a reduction from the current 42,000 lb per day annual
average limit which became effective January 2004. BRPP's requested limit was based on the
mill's 2005 annual average effluent color,39,000 lbs per day. EPA Region 4 requested that the
EPA Technology Team("Tech Team")support EPA's review of the color limits included in the
draft permit renewal developed by North Carolina Department of Environment and Natural
Resources. The Tech Team last evaluated color discharges at the mill in 2001 (EPA Tech Team
2001).
Members of the Tech Team visited the Canton mill on February 8,2007 with members of the
Technology Review Workgroup(TRW)to observe and collect information and data on the status of
technologies implemented and color discharges at the mill. This memorandum incorporates
analysis of data provided by BRPP prior to and from that visit,and other data subsequently
provided by BRPP at the request of the Tech Team.
This memorandum reviews the process improvements previously analyzed by the Tech Team,the
status of their implementation at BRPP,and identifies additional color reduction activities that
BRPP could implement during its next permit term. This memorandum also reviews the variability
of the mill effluent color discharges and suggests final effluent color limits for incorporation in the
revised permit.
Background and lUstory
BRPP operates a bleached papergrade kraft pulp and paper mill in Canton,NC,which it purchased
from Champion International Corporation in May 1.999. BRPP is owned 55 percent by KPS
Special Situations Fund,L.P. and 45 percent by the employees through an employee stock
ownership plan.2 BRPP announced on June 14,2007 that it is being acquired by The Rank Group.
The New Zealand-based Rank Group has considerable holdings in the paper industry. Rank Group
recently bought Evergreen Packaging,the former North American beverage packaging division of
International Paper. Operations at the mill began in 1908,but the mill has been extensively
' EPA Tech Team members are Ahmar Siddiqui, EPA/EAD;Karie-Jo Shell,EPA Region 4;Donald
Anderson,EPA/EAD;Betsy Bicknell,ERG,contractor;Neil McCubbin,subcontractor to ERG;Dan Bodien,
subcontractor to ERG.
2 BRPP announced on June 14,2007 that it is being acquired by The Rank Group. The New Zealand-based
Rank Group has considerable holdings in the paper industry. Rank Group recently bought Evergreen
Packaging,the former North American beverage packaging division of International Paper.

Memorandum
August 14,2007
Page 2
modernized,with the most recent major project completed in 1993. The mill currently operates an
810 tpd hardwood pulping line and a 600 tpd softwood(pine)pulping line. After cooking,pulp
from each line is further delignified in single-stage oxygen delignification(OD)systems,both
installed in 1993. Hardwood pulp is subsequently bleached with a DED sequence(BRPP stopped
adding oxygen to the hardwood E stage after 2001). Pine pulp is bleached with a DEoD sequence
(BRPP stopped adding peroxide to the pine E stage after 2001). Target brightness is 86 ISO,an
increase by one point from the target brightness in 2001. Up to 80 percent of the filtrate flow from
the pine bleach line is returned to the recovery cycle using the unique Bleach Filtrate Recycle
(1317e)process,developed by Champion. This 80 percent closure rate is an improvement from
2001,when the pine line closure averaged 73.7 percent. Up to 25 percent of the hardwood line
bleach plant E-stage filtrate flow is also recovered. BRPP produces 300,000 tons per year of
uncoated paper including offset,tablet,and envelope grades.The mill also produces 275,000 tons
per year of bleached paperboard used for liquid packaging and paper cups, including FDA-
approved grades for milk and juice cartons.
Basic tenets of this review,which are consistent with the Tech Team's approach beginning with the
original Settlement Agreement(with Champion International)and the 2001 TRW review with
BRPP, are:
• The first and highest priority again is focused on available in plant process changes and
best management practices(BMPs)as the most cost-effective approach to color
reduction in order to maximize the likelihood of success
Process changes deemed to be of highest and reasonable certainty,thereafter
lowest certainty technologies
BMPs that hold promise to further reduce generation and discharge of color
• After it is clear that in plant process changes and BMPs alone are not be sufficient,in
plant segregated stream pretreatment and end-of-pipe treatment options are carefully
considered
The Tech Team recognizes that very difficult and unusual circumstances occurred in 2004,with
back-to-back historical flooding of the Pigeon River and associated significant costs($39 million)
for repairing damage and replacing equipment at the BRPP mill after 21 days of being out of
operation. The Tech Team also recognizes that significant additional expenditures have been made
over the last permit term for environmental projects($25.9 million),the largest portion for air
pollution controls(e.g.,MACT I and MACT II compliance)and including color reduction projects
($5.9 million),all building on previous projects and expenditures. All of this has occurred during a
continuing period of industry-wide transformation,capacity shrinkage,and mill closings.
Nonetheless,the BRPP mill management has committed to surviving these challenges. The Tech
Team notes that these efforts and expenditures have resulted in substantial and commendable
progress made to date by BRPP through expenditures for additional and improved best management
practices,process and related technologies,and treatment technologies which have reduced the long
term average color discharges. It is also noteworthy that some of these technologies and practices
have been in addition to those identified in the previous Tech Team/TRW reviews.
Process Improvements Previously Analyzed by Tech Team
As a result of its 2001 analysis of the BRPP mill discharges and operations,the Tech Team
identified five mill improvements that it judged capable of reducing the discharge of color in the
mill effluent. BRPP and its consultant also identified several process optimization projects that
would reduce color discharges.The status of BRPP's implementation or evaluation of each of these
improvements is summarized in Table 1,discussed below.

Memorandum
August 14,2007
Page 3
Table 1. Review of Process Improvements Identified in 2001
Predicted Color „
.Reduction Moat „ ' "Color
Effluent,lbs/day - .Reduction
Improvement arm.avg) Implementation Status Achieved Comments
Process 1,400 Predicted reduction in Consultant recommends reduced CIO,
optimization CIO,use(27%on HW, use and adding oxygen and peroxide to
projects 17%on SW)not made. E stages to reduce color generation
CIO,use increased on
SW,decreased 5%on
HW Total
BFR reliability 1,000—1,200 Pine line filtrate recycle reduction Further improvements to BFR
improvement increased from 74 to from 2001: reliability may not be feasible
80%. 6,000 lb/day,
Improved black >5,000 Spill collection Dual Additional improvement to black
liquor leak and improvements made; average liquor control possible: further
spill collection untreated color(influent eliminate overflows and pretreat
control(BWs) to treatment)variability diverted high-color wastewater.Also
unchanged improve control of losses of white and
green liquors to reduce or eliminate
sulfide-based color
Ozone/C102 3,000—6,400 Inadequate evaluation BRPP concerns for this technology are -
stage for (lab..studies);not installed noted.Notwithstanding inadequacies
hardwood line None of lab studies,this technology
considered low certainty in this case
and further detailed study not
warranted at this time.
2nd Stage OD.for 1,100—1,400 Incomplete evaluation Detailed engineering evaluation needed
pine line (lab studies);not installed for costing and design and color
None reduction,followed by
implementation.BRPP concerns for
additional study are noted,but still
considered high certainty.
Color treatment <2,750 Evaluated(lab studies); CRP purge stream now averages 8,745
of CRP purge not installed lb/day. Detailed testing needed for
stream extended period to determine what
fraction of this color is removed in the
None W WTP and strategies for reducing
color released in the purge.. Any color
that is not removed in W WTP could be
reduced with segregated stream
pretreatment or other options.
Process Optimization Projects
In 2001,Liebergott&Associates and GL&V Pulp Group prepared an extensive analysis of the mill
fiberlines that included identification of options for effluent color reduction. Dr.Liebergott was
retained for this work by a coalition of environmental groups. This report,Bleach Environmental
Process Evaluation and Report(BEPER)(GL&V 2001)presented 16 recommendations for
incremental improvement to fiberline operations. These included suggestions for improving
process control,OD performance,reducing the amount of CIOz used on both bleach lines,and
enhancing the extraction stages on both bleach lines with oxygen and/or hydrogen peroxide. The
BEPER recommendations were evaluated,and BRPP implemented those deemed to be technically,
economically,and operationally feasible.

Memorandum
August 14,2007
Page 4
Process control and OD performance have been improved. However,on the hardwood line,the D,
stage kappa factor has not been decreased as previously recommended and use of oxygen in the
extraction stage was discontinued. As a result,.the total C1O2 charge on the hardwood line as of
May 2006 was only 5 percent less(not the predicted 27 percent less)than the C1O2 charge in 2000.
Similarly,on the softwood line,the Di stage kappa factor was not decreased as previously
recommended and the use of peroxide in the extraction stage was discontinued. As a result,the
total C1OZ charge on the softwood line as of May 2006 was 11 percent more(not the predicted 17
percent less)than the charge in 2000. While BRPP has noted the increased portion of higher
brightness pulps since 2001 as a reason for these changes,among other trade-offs cited,the Tech
Team continues to believe these changes are still viable and should remain as high certainty options
that should be pursued for further color reduction.
In preparation for renewal of their NPDES permit,BRPP retained Liebergott&Associates and
GL&V Pulp Group to analyze their fiber lines,review the implementation of the 2001
recommendations,and identify further options for color reduction. In the 2006 update to the
BEPER(GL&V 2006),the consultants repeated their recommendations for BRPP to reduce the
kappa factor in the D,stage of each bleach line and replace the C1O2 bleaching power with oxygen
and/or peroxide in the extraction stages. Increasing the operating temperature of the hydrogen
peroxide extraction stage to reduce effluent color also has been identified as a viable option during
this process.
In addition to reducing the color of the bleach plant effluents,use of a lower kappa factor means
BRPP would use less CI02 to bleach,which will reduce the total chloride content of bleach plant
filtrates. Lower chloride content can also be expected to make it possible for the mill to reduce the
CRP purge flow and the color it contributes to the mill effluent. The Tech Team also believes that
lower chloride content will make it possible for the mill to recycle more filtrates within the
hardwood fiber line,notwithstanding BRPP concerns(e.g.,adverse effects to washing,carryover to
D stage,possible increased chemical usage and color). Further,it also may be possible to introduce
a portion of these hardwood filtrates to the BFRTm process,which to this point has been dedicated
solely to recovering softwood fiber line filtrates,and reduce the total colored filtrates discharged to
the sewer.
BFR Reliability Improvement
As reported during the Tech Team's February 2007 site visit,BRPP spent$1.5 million over the last
five years to improve the reliability of the BFRT system. These expenditures included replacing
.tank liners for the three existing sand filters (now high grade stainless steel),replacing and/or
upgrading existing process piping with piping with improved metallurgy, installing a fourth(new)
multimedia filter,and installing a third ion exchange softener. With these improvements in more
reliable metallurgy and unit process redundancy,BRPP has increased the BFRTM closure rate from
73.7 percent in 2001 to 79.2 percent in 2006. Mill representatives stated that the present closure
rate of approximately 80 percent of the pine line bleach plant effluent represents the maximum
amount attainable without incurring unmanageable corrosion and scaling problems. Further
increases in closure and increased recycle rates above 80 percent may be possible but are likely to
be a difficult challenge because of the corrosion and scaling problems associated with current mill
bleaching filtrate chemistry. Scaling from hardness minerals accelerates above closure rates of 80
percent(Bodien,2007).

Memorandum
August 14,2007
Page 5
Improved Black Liquor Leak and Spill Control(BWs)
BRPP continued efforts intended to improve its management of leaks,spills,and intentional
diversions of black liquor over the last six years. These efforts include:
• Interconnecting the pine line and hardwood line spill collection sumps so that
tankage in either line can be used interchangeably for spills;
• Repositioning sewer conductivity probes from sumps to in-line to more accurately
and reliably identify high conductivity wastewaters;
• Diverting up to one hour of total mill flow to off-line 1-million-gallon clarifier,
during high color releases,thus providing some equalizing of color discharge to
wastewater treatment plant;
• Prior to process line outages,improved prior planning for and capture of high-color
process liquors and black liquors and better managing their timed release to
treatment system;
• Continued operator training; and
• Implementing two hour testing for color at the W WTP with one hour testing during
outages or semi-annual shutdowns.
BRPP has stated that these improvements in BMPs have resulted in reduced color variability in
influent to the primary treatment unit,which BRPP asserts is the best measure of color reduction
through in plant changes and BMPs. Data provided by BRPP are presented in Table 2 and depict
Primary(total)Influent Statistics by year.
Table 2. Primary(Total)Influent Statistics,by year
Mean - Relative Percent Decrease '
True Color Standard Standard Deviation dram Baseline
,. Obs/day) Deviation(SD) (SD/mean%) " (2001)
2001 57,725 20,619 35.7% 0.00%
2002 54,780 17,195 31.4% 5.10%
2003 55,550 19,424 35.0% 3.77%
2004 49,466 18,786 1 38.0% 14.3°/
2005 45,175 22,297 49.4% 21.7%
2006 38,454 14,015 36.4% 33.4%
Primary effluent,which is the total load to secondary treatment,is directly measured with a
composite sampler. Data provided by BRPP and compiled by the Tech Team are presented in
Table 3 (below)showing the mean, standard deviation,and relative standard deviation(standard
deviation as a percent of the mean)by year,for the years 2001 to 2006. Prior to 2006,the acid
sewer mixed with other mill wastewater prior to the treatment system,resulting in"sewer generated
color." As of January 1,2006,the acid sewer was separated from the other mill sewers and now
enters the treatment plant after the primary clarifier("primary effluent'). The primary effluent
sampler is located downstream of the mixing point of the primary clarifier overflow and acid sewer.
Thus,the statistics for 2006 presented in Table 3,represent the mixture of primary effluent and

Memorandum
August 14,2007
Page 6
newly rerouted acid sewer, including any color generated from the mixing of the two streams.
Some portion of the color generation is immediately measurable in primary effluent samples taken
from the channel leading to the aeration basin. It is also likely that additional color generation from
this mixing occurs,after the primary effluent sampling location within the aeration basin of the
secondary treatment system,with additional time for any chemical reactions to proceed to
completion.
Table 3. Primary Effluent(Influent to Secondary Treatment)Statistics,by year
Mean - Relative
True Color Standard Standard Deviation Number of days
(lbs/day)- Deviation(SD) (SD/mean%) >100,000 lb/day
2001 62,008 19,561 31.5% 13
2002 59,956 18,680 31.2% 16
2003 59,646 18,468 31.0% 10
2004 65,206 1 26,674 40.9% 40
2005 63,838 24,158 37.8% 28
2006 65,512 25,427 38.8% 36
Table 3 presents the number of days for.which the primary effluent color exceeded 100,000 lbs/day.
Comments received from BRPP assert that primary effluent is not the most appropriate measure of
progress. BRPP further stated that color loads to the treatment system have been reduced. In spite
of improvements made over the last permit term,including the acid sewer relocation, all clearly
made in good faith by BRPP,the Tech Team respectfully disagrees with these assertions. As
shown in Table 3, evaluation of available data does not appear to support BRPP's assertion that
there has been progress in reducing the frequency at which it experiences high color loads into the
secondary treatment system.
BRPP provided the Tech Team with notes describing mill events that were related to high primary
influent color in 2006 (Blue Ridge 2007a). These events included,among others,planned mill
outages,unplanned outages,a CRP slurry tank overflow,and a release from the evaporator related
to an equipment failure. BRPP did not report one single event or one single type of event that
caused high color in the primary effluent. Further,not all high primary effluent color resulted in a
high final effluent discharge(e.g.,BRPP reports that color associated with high turbidity is
effectively removed in the secondary treatment system). However, from analysis of the data,the
Tech Team concludes that the Canton mill can further reduce primary effluent loads through
continuing efforts to minimize unplanned spills and leaks and planned discharges of high-color
streams during fiber line disruptions. BRPP has reported some success through recent efforts in
detailed scheduling of planned outages,contingency planning for unplanned outages,and
continuing efforts to minimize process operation variability. The Tech Team wishes to
acknowledge these efforts and their importance. While clearly challenging,these efforts must be
further developed and consistently implemented to minimize high color discharge risks all agree are
associated with these fiber line disruptions,both planned and unplanned.
The Tech team continues to believe that the information presented in Table 3,among other
available performance data,holds valuable indicators and clues to the sources and solutions to
reducing the overall performance and variability in effluent color discharged to the Pigeon River.
On the other hand,BRPP has asserted that primary effluent information and other data collected
within the Mill's biological treatment system are not indicative of the facility's true performance.

Memorandum
August 14,2007
Page 7
BRPP believes that secondary effluent showed improvement,and data provided by BRPP are
presented in Table 4(below).
Table 4 Secondary Effluent Statistics,by year
Mean - Relative '
True Color Standard Standard Deviation .Number or days.
abs/day) Deviation(SD) (SD/mean.%) >100,000 lb/day
2001- 42,676 10,925 25.6% 3
2002 41,166 9,928 24.1% 0
2003 44,627 11,043 24.7% 1
2004- 41,463 32,568 76.6% 4
2005 39,092 10,092 25.8% 0
2006 37,058 8,959 24.2% 2
2004 data were affected by historic floods in September 2004
Ozone/Chlorine Dioxide Stage for the Hardwood Bleach Line
BRPP engaged the Pulp and Paper Research Institute of Canada(PAPRICAN)to investigate
potential modifications to the hardwood pulp bleaching process and determine effluent color
reduction that would result from these modifications. The PAPRICAN report entitled"Bleaching
Evaluation for Effluent Color Reduction"(Audet et al,2003)was provided to the Tech Team in
early 2007.
PAPRICAN stated that their objective was to evaluate whether modifications to the hardwood
bleaching,sequence at Canton specified by Mr. Johnnie Pearson(BRPP process engineer)could
"generate effluents with a color reduction target of 25 percent."
BRPP provided PAPRICAN with oxygen delignified hardwood pulp. PAPRICAN bleached this
pulp in their laboratory,investigating various combinations of chlorine dioxide,ozone and
hydrogen peroxide.
The report concluded that ozone could replace some of the chlorine dioxide used in bleaching
(known as a"W"stage),while producing pulp of equal or slightly better quality than the control
sequence. This is consistent with the open literature on ozone/chlorine dioxide combinations.
PAPRICAN also concluded that replacing some of the chlorine dioxide in bleaching with ozone
increased the color in the bleach plant effluents. This contradicts the experience reported by
Domtar(formerly E.B.Eddy)at their Espanola mill,where a dramatic reduction in effluent color
was observed when that mill installed an ozone pulp bleaching system(Munro and Griffiths,2000).
-The Tech Team notes that the Espanola mill has no color discharge limits and it installed ozone to
reduce its bleaching costs.
The Tech Team found significant deficiencies in PAPRICAN's analysis of the laboratory results.
The 2006 Liebergott/GLV report agrees with this finding. The concentration of color in the
effluent for each stage was added to obtain the total concentration for each tested bleach sequence.
This approach neglects two points:
1) Mixing effluents produces reactions that may increase or decrease the
concentration of color in the combined effluent.

Memorandum
August 14,2007
Page 8
2) Filtrate volume affects the measured concentration(e.g.,lower volume will
concentrate the filtrate to a higher color). PAPRICAN's report does not present the
filtrate volumes,so a comparison of concentrations may be misleading.
Liebergott,et,al.,reviewed the PAPRICAN report and identified the same deficiency with regard
to effluent mixing. They also noted that the quantity of chlorine dioxide added to the ZD stage was
too high,which would result in higher effluent color(GL&V 2006,p 18).
In response to EPA's question about how the PAPRICAN results were used to estimate impacts on
final effluent color,BRPP responded:
The pilot study reactors were batch and not continuous and did not include
filtrate recycle. The pilot studies included bleach stage filtrate color
concentrations, but there was no filtrate flow rate data from which to calculate a
production-normalized filtrate color mass. For these reasons,we did not attempt
to calculate secondary effluent color impacts using pilot study data for individual
bleach plant color streams.
In the PAPRICAN study, the individual bleach stage colors were compared
directly and in total. By bath means, the color of the ZD stage was higher than
the baseline DEoD. It is also well known that when individual bleach stage
filtrates are mixed the resultant effluent color'is very difficult to predict (Blue
Ridge,2007a)
The Tech Team concludes that BRPP's investigation of the potential for hardwood pulp ozone
bleaching to reduce the mill's effluent color was inadequate. Notwithstanding the above-noted
inadequacies and upon reflection,the Tech Team believes that further laboratory trials appear not to
be necessary because this application of ZD technology may not be appropriate for this mill at this
time. Therefore,ZD technology is considered a technology option of lowest certainty for
application at this mill at this time.
Second Stage Oxygen Delignscation for the Pine Bleach Line
BRPP contracted with AndritziAhIstrom("Andritz")to study,among other things,the addition of
an additional stage of oxygen deligniftcation in the pine(softwood)bleach line at Canton. Andritz,
a well established supplier of pulping and bleaching technology and equipment,maintains the
Pruyn's Island Technical Center,which conducted the tests. The Andritz report, entitled,
"Laboratory CK and Lo-Solids Cooking with O-Do-Eop-D Bleaching Sequences on Softwood
Furnish from Blue Ridge Paper,Blue Ridge,NC"(Andritz Ahlstrom Sales 2001)was provided to
the Tech Team in early 2007.
The text of the Andritz report states that`BRPP requested the sales department of Andritz-
Ahlstrom to investigate alternative methods of pulping and bleaching that would reduce their waste
products and improve the quality of their hardwood and softwood paper products." As indicated by
this statement of work,testing of second-stage oxygen deligniftcation was a minor part of the work
Andritz did for BRPP. Further,very few of the data in the report are useful for analysis of effluent
color improvement.

Memorandum
August 14,2007
Page 9
Specifically,Andritz compared single stage and two stage oxygen delignification of samples of
pulp provided by the BRPP mill.The tests showed that a second stage of oxygen delignification
r could reduce the kappa number of the unbleached pine pulp by 22 percent.
Andritz did not bleach the pulp after the two stage oxygen delignification,so the report provides no
information on the impact of the additional oxygen delignification stage on effluent characteristics,
including color.
In response to EPA's question about how the Andritz results were used to estimate impacts on final
effluent color,BRPP responded:
The Andrtz Ahlstrom study of second stage 02 for pine showed delignification
ranging from 42.7 percent for the single stage, 48.6 percent for the 0-0 and 55
percent for the 00 stage. With improvements that BRPP made on the existing
single stage pine 02,the deliginification increased from 40 percent to 45 percent.
With BFR in place on the pine frberline, the effluent color reduction from this
improvement in 02 deliginification has been very difficult to identify. The
inability to quantify the effect on effluent color of improved 02 deliginifrcation
made the capital cost to install a second stage 02 on pine not economically
feasible. (Blue Ridge,2007a)
BRPP's analysis of the benefits of adding a second oxygen delignification stage to the pine line is
incomplete. BRPP's consultants note that even with the percent delignification currently achieved
on the pine line,a second stage could achieve an additional 20 to 25 percent delignification(see
GL&V 2006,p 118).
By making a 20 to 25 percent reduction in the kappa number of the pine pulp before bleaching,20
to 25 percent of the colored material currently discharged from bleaching to the BFRTM would be
recovered and burned in the mill's recovery boiler. In addition,the quantity of chlorine dioxide and
caustic required in bleaching would be reduced by approximately 20 to 25 percent,reducing the
load on the BFRTM system. This would allow an increased proportion of the bleach filtrates to be
recycled through the BFRTm system. BRPP believes that a kappa number decrease or
delignification efficiency increase would not equate to a similar decrease in color. Although with
the information available it is not possible to rigorously calculate the benefit of this change,the
Tech Team would expect on the order of 1000 lbs/day reduction in bleach plant color discharge.
In 2001,the Tech Team recommended that BRPP conduct.a detailed study to develop an
engineering design leading to installing an additional oxygen delignification stage for the pine
(softwood)pulping/bleaching line.The Tech Team estimated that this process change would reduce
effluent color by 1,100 to 1,400 lbs/day: Liebergott,et.al.,(GL&V 2006)estimated that
implementing a second oxygen delignification stage on the pine fiber line would reduce color
discharge by 1142 Ibs/day.They estimated the capital cost of adding an additional oxygen
delignification stage would be in the order of$2 to$3 million and the chemical cost savings
approximately$1.2 million/year,providing a reasonable payback. Mill staff has mentioned a three
year pay-back,which is consistent with this estimate. However,the mill has further asserted from
their more recent estimates that the cost could be$3 to 5 million owing,presumably at least in part,
to increases in the general prices of stainless steels(not as specifically fabricated and estimated for
this technology). The BRPP oxygen delignification systems were installed in 1993. Since that
time,the use of two-stage oxygen delignification rather than the traditional single-stage systems has
become well established in the industry because it normally further reduces mill operating costs.
BRPP believes that the previous evaluation of adding a second stage oxygen delignification stage

FPP
Memorandum
' August 14,2007
Page 10
should be repeated in part because of differences cited in delignification efficiencies,and concerns
for possibly lower-than-estimated color reductions. Notwithstanding these concerns,the Tech
Team continues to believe this technology has progressed beyond being considered"reasonable
certainty"in 2001 to"highest certainty"at this time. Therefore,the Tech Team again recommends
that priority should be given to a detailed evaluation for identifying necessary adjustments to
upstream pulp digestion(e.g,kappa number targets),downstream bleaching(e.g., bleaching
chemical usage rates)and brightness/strength parameters,designing and costing,and refining color
reduction projections. In order to satisfy BRPP's recent concerns, an update from the results of this
work may need to be shared with the TRW,prior to being implemented at the earliest possible date.
Andritz also evaluated modifications to the mill cooking process. These would require complete
replacement of the digester systems at Canton,which would cost(at least)several tens of millions
of dollars,if they are feasible at all within the mill's space constraints. The Tech Team concluded
that while theoretically possible,modifications to the mill cooking process do not merit further
analysis at this time.
Treatment of CRP Purge Stream for Color Removal
The Chloride Removal Process(CRP)purge is a low flow,highly concentrated stream. Color is
typically 41,000 platinum cobalt units(pcu) in a stream that discharges at 10 gpm(15,000 gal/day
or 3 tank trucks/day).BRPP reported that in 2006 the CRP purge contributed approximately 8,745
lb/day(23 percent)of the total mill color loading to the treatment system but only 0.05 percent of
the discharge flow. By comparison,in 2001 the CRP contributed approximately 5,000 lb/day(13
percent)to the treatment system loading(EPA Tech Team,2001). Thus,in the last five years there
has been a significant increase in color contributed by the CRP,both in lb/day and in percent of
total mill load. BRPP reported on its investigations into technologies for reducing CRP purge color
in its March 2005 report,"Chloride Removal Process(CRP)Color Reduction Technology
Assessment" (Blue Ridge 2005). In this report,BRPP points out that the CRP purge is a very
concentrated material(360,000 mg/L or 36 percent total dissolved solids)that is discharged to
sewer at 165'F. Handling the material is difficult because it will crystallize as it cools. Also,it is
quite corrosive due to the high chloride content.
As described in their 2005 report,BRPP assessed more than nine alternatives for disposal or
treatment of the CRP purge and concluded that none was technically feasible. Although consistent
performance was not demonstrated, C1O2 bleaching was a low cost,potentially effective means of
reducing the CRP purge color prior to introduction to the treatment system. BRPP found that CIO,
bleaching could remove 75 to 90 percent of the color in the CRP purge stream,with some concern
about consistency. This is a significant reduction in a now prominent source of color.
Although CRP purge is a relatively low flow stream,BRPP estimated that off-site solidification and
land disposal would cost more than$3.6 million/year,which does not include the additional cost of
loading facility infrastructure.
During the Tech Team's 2007 mill visit,BRPP stated that there was no apparent decrease in
secondary effluent color when CRP wastewater was not flowing into the treatment system. In
response to a Tech Team request,BRPP presented data correlating the days on which the CRP
process was shut down with secondary effluent discharge color,for August 2006 to January 2007
(Blue Ridge 2007a). During this period,there were nine widely dispersed pairs of days when the
CRP process was down for part of the day. BRPP believes that CRP color is removed in the
secondary treatment system, based on their analysis of variance(ANOVA)comparing"down"days
with CRP operating days and"general observations."

FF
Memorandum
August 14,2007
Page 11
In response to a Tech Team follow-up request for clarification,BRPP later asserted that these data
allowed no definitive conclusion,and that there is no relationship of presence or absence of CRP
purge to secondary effluent color based upon general observations. The Tech Team does not agree
with this belief or rationale for the following reasons. First,with one exception,the periods of CRP
shutdown are only a day or so each,which is insufficient time for the W WTP to stabilize with the
change in raw effluent characteristics. Second,the times of shutdown and startup of the CRP do
not correspond with the effluent sampling times in the mill system,so that there is no direct
correlation in time with the effluent sample.Further,the fact that all CRP"off'days are in pairs
suggests that CRP was down for a period that spanned parts of two mill sampling days.
The simple mathematical average of treated effluent color discharge during"CRP off'days for
August to December 2006 is 39,995 lbs/day. The average when the CRP process was operating is
36,958 lbs/day. This suggests that the presence of the CRP purge stream in the wastewater
treatment system causes a reduction in effluent color. This defies common sense. Also,the
difference in effluent color between the"CRP on"and"CRP off'days is 7 percent,while day to
day variations in color discharge values are frequently over 20 percent,tending to subsume and
confound any analysis of the impact of changes in the CRP purge stream. BRPP asserted that color
performance data from this period likely varied due only to normal day-to-day performance
variation.
In short,because there are so few consecutive days without a CRP purge,the data from the period
August to December 2006 are not sufficient for establishing the extent to which the CRP purge
contributes to final effluent color. In order to explore this further,BRPP could conduct a full-scale
mill trial in which the CRP purge is excluded from the wastewater treatment plant for a period of at
least three weeks. This can be achieved in two alternative ways,or perhaps a combination of both.
The first is to shut off the CRP purge for at least three weeks, and allow the chloride concentration
to slowly build up in the recovery system. Early literature published by Champion on the BFRTM
process showed that the response of the chloride and potassium content in the mill's white liquor to
operation of the CRP was very slow,requiring a month or more to show significant changes. This
is consistent with experience in other mills,and is due to the fact that the quantity of chlorides and
potassium removed by CRP is small relative to the inventory in the mill's black,green and white
liquor system. The.second approach would be to store the CRP purge stream,either in the spare
clarifier or off site fora period of at least three weeks. The impact of excluding the CRP purge
from the wastewater treatment plant would be observed by routine analysis of effluent color. If the
effluent color without the CRP purge is unchanged,BRPP could conclude that the CRP purge
contributes little to the final effluent color. In this case, further research into reducing CRP color
would be a low priority. On the other hand, if the effluent color without the CRP purge decreased,
BRPP could conclude that the CRP purge contributes to the final effluent color and further research
into reducing CRP color should be undertaken.
BRPP mill staff asserted that a full-scale shut off of CRP purge to the treatment system for such a
period of time(e.g.,at least three weeks)would not be operationally feasible,but offered no
specific facts or reasons why this would be the case. Nonetheless,given BRPP's.concems for
operational feasibility at full scale,the Tech Team is open to another reasonable approach that
could be devised. Such an approach would need to gather the data necessary over a sufficient
period of time to better identify and quantify the underlying color loads to the treatment system,
both with and without the purge from CRP. Moreover, it would be important to identify and
quantify to the extent possible any changes in the downstream color generation and removal
processes that are occurring with the current acid sewer introduction point just upstream of the
aeration basin in the secondary activated sludge wastewater treatment system.

PPP
Memorandum
August 14,2007
Page 12
BRPP also could investigate approaches.to prevent color from accumulating in the CRP. The
source of the color in the CRP purge stream is carryover of black liquor particles in the direct
contact evaporators(DCE)in the recovery boiler systems. This carryover could be eliminated if the
two traditionally designed recovery boilers(which are 34 and 42 years old)were replaced by one
modern boiler. This would probably represent a capital cost of over$100 million,and would very
substantially reduce the energy costs at the mill,since today's recovery boilers are much more
efficient than the DCE/recovery boiler systems of the vintage installed at Canton. Analysis of all
the economics and long term life of the mill would be necessary to evaluate such a major
investment.
On a more modest level,it may be feasible to reduce black liquor carry over by adjusting operating
conditions in the existing DCE's. The Tech Team is not aware of any experience with this in other
mills,or research,but the situation at Canton strongly suggests that at least some investigation and
trials of modifications to the operations is warranted. Any of the measures discussed previously in
this document to reduce C1O2 use could reduce the quantity of chloride to be removed in the CRP
purge stream. If this is reduced,the color discharge also would be reduced.
BRPP should also further investigate C102 treatment and other treatment of color in the segregated
CRP purge stream and;other approaches for excluding the CRP purge stream from the mill
discharge.
Additional Color Reduction Strategies
The Tech Team has identified the following color reduction activities that should be for improving
the color removed by the Canton Mill wastewater treatment plant:
• Investigate in further depth color formation when acid wastewater is mixed with
mill wastewater in the current configuration,with and without the CRP purge,and
identify techniques to reduce this effect;
• Maintain addition of polymer and/or other treatment chemicals to the high-color
wastewater diverted to the extra primary clarifier,and investigate improving
equalization and pretreatment performance; and
• Further investigate adding polymer and/or other treatment chemicals to aeration
basin mixed liquor prior to introduction to the secondary clarifiers.
These strategies are discussed below.
Color Formation When Acid Wastewater Is Mixed With Mill Wastewater
BRPP provided the Tech Team with daily color data for the"Low Lift"(mill sewer),acid sewer,
and primary effluent sampled after the acid sewer is added in the discharge channel of the primary
clarifier leading to the.aeration basin of the secondary activated sludge biological treatment system.
Figure 1 (below)presents the total mill color calculated by adding the mill sewer lb/day to the acid
sewer lb/day(the lower(blue line)on the figure). For comparison,the primary effluent sampled
after the acid sewer is introduced is also shown on the figure(the upper red line on the figure).
Thus,the figure depicts the impact of mixing the acid sewer with the rest of the mill effluent'.
3 The color of the mill sewer wastewater may be reduced somewhat by treatment in the primary clarifier. This color
reduction is neglected in the calculated untreated color,so Figure 1 is probably a slight underestimate of the impact of
mixing the acid sewer with the rest of the mill effluent.

PPF
Memorandum
August 14,2007
Page 13
160,000
Total untreated color,before and after mixing,2006 (lbstday)
125,000
100,000
75,000 Al it
50,000
25,000
14an 314an lWar 314ar 30-Apr atuaay 29Jun 29Jul 28Aug 2Mep 27Oct 2"w 26-0ec
Figure 1: Impact of Mixing Acid Sewer and Mill
The Tech Team observed:
• The quantity of color formed on mixing the acid sewer and mill sewer is striking.
On average,the quantity of color formed is 78 percent of the total color in the two
streams. In other words,the simple mixing of these streams forms nearly half the
total color discharge from the mill.
• The variation in quantity of color formed by mixing the effluent streams from day-
to-day is dramatic,as is evident in the graphs. When expressed as a percentage of
primary input color,the value ranges from essentially zero on some days to a
maximum of 480 percent.
• There is no obvious correlation between the values on any one day,or series of
days close to one another;however,statistical analysis has not been attempted.
Notwithstanding these observations,the Tech Team understands and appreciates BRPP's efforts
during the last permit term to reduce color formation through the acid sewer relocation project. The
Tech Team suggests that BRPP build on this project and the above color reduction strategies to
better understand the mechanisms of and the follow-up strategies for reducing color formation in
the current sewer configuration. BRPP could investigate,among other things,how sulfides
introduced by leaks,spills,and unplanned discharges from white and green liquor systems into the
mill wastewater contribute to effluent color. In particular,BRPP could investigate whether sulfides
in the mill wastewater contribute to color formation when acid sewer is added to mill effluent prior
to biological'treatmeht. Approaches to this investigation should include:
• Laboratory experiments on effluent with varying degrees of sodium sulfide
addition; and
• Daily measurement of the sulfide content of the effluent from the primary clarifier
influent at the low lift pump sampling station for a period of at last three months to
determine correlation of sulfide concentration with color formation.
In most mills,losses of sulfides can be reduced. Well known sources include imbalance in the
weak wash system,as well as spills of white,black,and green liquor. BRPP should further
investigate losses from the green and white liquor systems and technologies that can reduce these
losses.

PPPPF
Memorandum
August 14,2007
Page 14
Improving W WTP Performance Using Chemicals
Several bleached ktaft mills around the world have successfully reduced color to well below 5
lb/ton pulp by installing tertiary treatment systems. These systems use polymers and other
chemicals to precipitate color bodies,then remove the precipitate in tertiary clarifiers. One of the
newest of these mills is Celco in Valdivia, Chile. This mill has excellent in-plant effluent control,a
conventional secondary wastewater treatment plant, followed by a small tertiary system.Effluent
from this mill is depicted in Figure 2(below)beside the effluent from BRPP.
u ,
l �
'4
i
Figure 2: Comparison of BRPP Canton Mill Effluent(February 2007)and Valdivia Mill
Effluent(November 2005)
The Tech Team notes that treatment systems like the one operated at Valdivia have a capital cost in
the tens of millions of dollars,and can create issues with solid waste disposal. BRPP also
expressed the opinion that this comparison was not appropriate. However,some more modest
control measures using variations of this technology also exist. For example,since March 2004,
Glatfelter Inc., Spring Grove,PA has supplemented its in-plant color control strategies by using a
commercially available polyaluminum chloride polymer to enhance color removal in the
wastewater treatment plant. The polymer is added in the discharge flume from the aeration basin,
just upstream of the mixing box feeding the four secondary clarifiers. The polymer reduces pH and
complexes with organic compounds that produce color. Colored material settles out with the
secondary sludge which is held in the former stabilization basin before dewatering. Glatfelter has
not reported sludge dewatering problems.Polymer used for additional color removal reportedly
costs on the order of$2,000 to$3,000/day. Moreover,neither the Valdivia mill nor the Glatfelter
mill employs the BFRn"system as applied at BRPP.
As further in-plant process changes and improved BMPs are implemented and color loads are
reduced in magnitude(long term average and variability)and change chemical composition,BRPP
could conduct further laboratory trials of commercially available polymers and other wastewater
treatment chemicals. In some cases this may entail repeats of previous tests,for example for
polyamine,but under potentially different circumstances and wastewater chemistry than previously
tested. In addition to those previously evaluated, it could be helpful to assess adding one or more of
these chemicals upstream of the secondary clarifiers. During these trials BRPP would determine
the potential for reducing color discharge and estimate the costs. Such analysis would consider

Memorandum
PFAugust '
Page 15
seasonal use of the additive chemicals(i.e.,adding the chemicals during periods when river flow is
low and the mill discharge has the greatest impact on the river color). The Tech Team
acknowledges BRPP concerns regarding significant issues that may occur,such as possible effluent
toxicity,difficulty in sludge dewatering,and cost.
If the laboratory trials are successful,BRPP could institute a full-scale trial for one month, and
report results to the TRW.
Pretreatment of Diverted High-Color Wastewater
BRPP currently diverts up to one hour of total mill flow at current flow rates to their off-line 1-
million-gallon clarifier,during high color releases. The purpose of this flow diversion is to equalize
color contributions to the wastewater treatment plant. Diverted high color wastewater is batch
pretreated by polyamine and returned to the wastewater treatment system. The Tech Team believes
that BRPP should further investigate options for increasing the performance of equalization and
pretreatment capacity beyond that which currently exists. This would probably be an important
contribution to both further reducing color variability,an increasingly higher priority endeavor as
long term averages are reduced,and to removing color before being introduced into the secondary
activated sludge biological treatment system.
Summary: Additional Identified Color Load and Variability Reducing Activities that BRPP
can Pursue in the Next Five Years
Since installing the BFR process and other improvements(OD,BMPs,etc.),BRPP is to be
commended for the important progress in reducing their annual average color discharges,which
needs to be continued. However,high color discharges continue to be experienced for short periods
(e.g.,daily)and these discharges become more evident as the annual average discharge is reduced.
When these discharges coincide with periods of low river flow(typically in the late summer),they
can contribute to an elevation in river color that could be noticeable to the citizens who use the
river. Thus,reducing the impacts of the peaks in color discharged from the mill requires not just
reducing the annual average color discharged but also reducing variability measured by the daily
color discharges. Mill process changes that reduce wastewater color are generally preferred to end-
of-pipe treatment because they may have lower capital costs and may benefrt.the mill by reducing
operating costs and improving process efficiencies. However,mills in environmental regulatory
jurisdictions with severe restrictions on their color discharges have been required to implement end-
of-pipe color removal technologies since the 1970's. Although the Tech Team continues to
maintain the highest priority for in-mill improvements such as process changes and optimization,
increased black liquor recovery and further improvements in BMPs,external color removal
technologies should continue to be considered carefully in the mix of options for further controlling
the color of BRPP's discharges. These color removal technologies include,with first priority,
treatment of segregated low-volume concentrated wastestreams(e.g.,the CRP purge)and thereafter
end-of-pipe wastewater treatment.
The Tech Team identified strategies focused primarily on in-mill process improvements but also
including color treatment that BRPP can use to further reduce its effluent color discharges. These
strategies are summarized below.
• '' Continue to improve the performance of BMPs to further substantially reduce and
ultimately eliminate discharges of highly-colored wastewaters directly to the
wastewater treatment system through further improvements in-

PF
Memorandum
August 14,2007 '
Page 14
Improving W WTP Performance Using Chemicals
Several bleached kraft mills around the world have successfully reduced color to well below 5
lb/ton pulp by installing tertiary treatment systems. These systems use polymers and other
chemicals to precipitate color bodies,then remove the precipitate in tertiary clarifiers. One of the
newest of these mills is Celco in Valdivia,Chile. This mill has excellent in-plant effluent control,a
conventional secondary wastewater treatment plant,followed by a small tertiary system.Effluent
from this mill is depicted in Figure 2(below)beside the effluent from BRPP.
14,
r.A ?
•yc.jf ,� �3 YS �' �„I ,
.....a-t..=..yam.,. ..:. ,,. _ .
Figure 2: Comparison of BRPP Canton Mill Effluent(February 2007) and Valdivia Mill
Effluent(November 2005)
The Tech Team notes that treatment systems like the one operated at Valdivia have a capital cost in
the tens of millions of dollars,and can create issues with solid waste disposal. BRPP also
expressed the opinion that this comparison was not appropriate. However,some more modest
control measures using variations of this technology also exist. For example,since March 2004,
Glatfelter Inc., Spring Grove,PA has supplemented its in-plant color control strategies by using a
commercially available polyaluminum chloride polymer to enhance color removal in the
wastewater treatment plant. The polymer is added in the discharge flume from the aeration basin,
just upstream of the mixing box feeding the four secondary clarifiers. The polymer reduces pH and
complexes with organic compounds that produce color. Colored material settles out with the
secondary sludge which is held in the former stabilization basin before dewatering. Glatfelter has
not reported sludge dewatering problems.Polymer used for additional color removal reportedly
costs on the order of$2,000 to$3,000/day. Moreover,neither the Valdivia mill nor the Glatfelter
mill employs the BFRTm system as applied at BRPP.
As further in-plant process changes and improved BMPs are implemented and color loads are
reduced in magnitude(long term average and variability)and change chemical composition,BRPP
could conduct further laboratory trials of commercially available polymers and other wastewater
treatment chemicals. In some cases this may entail repeats of previous tests,for example for
polyamine,but under potentially different circumstances and wastewater chemistry than previously
tested. In addition to those previously evaluated, it could be helpful to assess adding one or more of
these chemicals upstream of the secondary clarifiers. During these trials BRPP would determine
the potential for reducing color discharge and estimate the costs. Such analysis would consider

Ppp
Memorandum
August 14,2007
Page 15
seasonal use of the additive chemicals(i.e.,adding the chemicals during periods when river flow is
low and the mill discharge has the greatest impact on the river color). The Tech Team
acknowledges BRPP concerns regarding significant issues that may occur,such as possible effluent
toxicity,difficulty in sludge dewatering,and cost.
If the laboratory trials are successful,BRPP could institute a full-scale trial for one month,and
report results to the TRW.
Pretreatment of Diverted High-Color Wastewater
BRPP currently diverts up to one hour of total mill flow at current flow rates to their off-line I-
million-gallon clarifier,during high color releases. The purpose of this flow diversion is to equalize
color contributions to the wastewater treatment plant. Diverted high color wastewater is batch
pretreated by polyamine and returned to the wastewater treatment system. The Tech Team believes
that BRPP should further investigate options for increasing the performance of equalization and
pretreatment capacity beyond that which currently exists. This would probably be an important
contribution to both further reducing color variability,an increasingly higher priority endeavor as
long term averages are reduced,and to removing color before being introduced into the secondary
activated sludge biological treatment system.
Summary: Additional Identified Color Load and Variability Reducing Activities that BRPP
can Pursue in the Next Five Years
Since installing the-BFR process and other improvements(OD,BMPs,etc.),BRPP is to be
commended for the important progress in reducing their annual average color discharges,which
needs to be continued. However,high color discharges continue to be experienced for short periods
(e.g.,daily)and these discharges become more evident as the annual average discharge is reduced.
When these discharges coincide with periods of low river flow(typically in the late summer),they
can contribute to an elevation in river color that could be noticeable to the citizens who use the
river. Thus,reducing the impacts of the peaks in color discharged from the mill requires not just
reducing the annual average color discharged but also reducing variability measured by the daily
color discharges. Mill process changes that reduce wastewater color are generally preferred to end-
of-pipe treatment because they may have lower capital costs and may benefit the mill by reducing
operating costs and improving process efficiencies. However,mills in environmental regulatory
jurisdictions with severe restrictions on their color discharges have been required to implement end-
of-pipe color removal technologies since the 1970's. Although the Tech Team continues to
maintain the highest priority for in-mill improvements such as process changes and optimization,
increased black liquor recovery and further improvements in BMPs,external color removal
technologies should continue to be considered carefully in the mix of options for further controlling
the color of BRPP's discharges. These color removal technologies include,with first priority,
treatment of segregated low-volume concentrated wastestreams(e.g.,the CRP purge)and thereafter
end-of-pipe wastewater treatment.
The Tech Team identified strategies focused primarily on in-mill process improvements but also
including color treatment that BRPP can use to further reduce its effluent color discharges. These
strategies are summarized below.
• Continue to improve the performance of BMPs to further substantially reduce and
ultimately eliminate discharges of highly-colored wastewaters directly to the
wastewater treatment system through further improvements in-

P
Memorandum
August 14,2007
Page 16
o managing and controlling planned and unplanned releases of highly
colored process liquors through regular mill staff meetings
o interconnected collection sump capacity within the mill available to both
fiber lines for capture and recovery of leaks,spills,and planned diversions
of black liquor and other highly-colored wastewater
o increasing use of short-terns testing to supplement advanced real-time
process monitoring,rapid communication among mill staff,identifying and
immediately repairing failed equipment/parts,regular operator training,
and
o moving forward with the planned CRP sump and containment project to
eliminate unplanned releases of this highly-colored material to the mill
sewer.
• On the pine bleaching line,implement the use of peroxide fortification of the Eo
stage and decrease the target kappa factor as recommended in BEPER 2001 and by
Liebergott/GL&V 2006. Evaluate the use of high temperature for the peroxide-
fortified extraction stage.
• On the hardwood bleaching line,implement the use of oxygen and peroxide
fortification of the E stage and decrease the target kappa factor as recommended in
BEPER 2001 and 2006. Evaluate the use of high temperature for the peroxide-
fortified extraction stage.
• Complete an expedited and detailed evaluation of and install an additional oxygen
delignification(OD)stage for the pine pulping/bleaching line.
• As CI02 use is reduced through second stage OD on the pine line and other options
on both fiber lines, further investigate increasing the amount of hardwood filtrates
recycled and investigate introducing for the first time some of these hardwood
filtrates to the BFRm system,and thus potentially further reduce the purge rate
from the CRP,now a significant portion of the total color discharged from the mill
processes.
• Continue to evaluate the impact of the CRP purge on treated effluent color to
determine if the CRP color,now a significant portion of the total color discharged
from the mill processes,is removed by the treatment system. Such an effort may
take special efforts to accomplish and for a meaningful period of time. If CRP
color is not removed in the treatment system,investigate approaches to prevent
color from accumulating in the CRP,such as reducing black liquor carryover by
further adjusting operating conditions in the direct contact evaporators. Also,if
CRP color is not removed in the treatment system, further investigate CIOZ
pretreatment of the CRP purge to reduce its color prior to being introduced into the
mill wastewater treatment system.
• If the CRP purge color is found not to be removed in secondary treatment,avoid
releasing the CRP purge during periods of low stream flow(or truck it off site);
• Continue to investigate and implement strategies for improving color removed by
the Canton Mill wastewater treatment plant:

Memorandum
August 14,2007 �
Page 17
— Further analyze color formation when acid wastewater is mixed with mill
wastewater in the current configuration,particularly in the activated sludge
aeration basin, and identify other techniques,such as minimizing sulfide
releases to the mill sewer from white and green liquor leaks,spills,and/or
diversions,to reduce this effect
Maintain or further increase the performance for pretreating highly-colored
wastewaters prior to introducing them to the wastewater treatment system,
including further optimizing adding polymer and other pretreatment
chemicals to the highly-colored wastewater diverted to the extra primary
clarifier and/or any additional facilities that may be provided;
Further investigate treating total mill biological system effluent prior to
discharge using polymers or other wastewater treatment chemicals
upstream of the secondary clarifiers,particularly during periods of high
influent color and/or low river flow;and
• Curtail pulp production during periods of low stream flow;this should continue to
be considered an option of last resort,given that best performance has been noted
by the mill to be during extended periods of steady production and greater risk of
elevated color during process shutdown and startup.See Low Flow Contingency
Plan,December 1, 1998.
Suggested Final Effluent Color Limits for Blue Ridge Pulp and Paper
Substantial and commendable progress has been made to date by BRPP through expenditures for
additional and improved process and related management practices and treatment technologies
which have reduced the long term average color discharges. Some of these technologies and
practices have been in addition to those identified in the previous Tech Team/TRW reviews. This
progress in reducing the annual average of color discharges has made increasingly important and
apparent the importance of reducing day-to-day effluent variability along with the other
recommendations of the Tech Team going forward from this critical point in time. Therefore,the
Tech Team recommends to the TRW and the North Carolina Department of Environment and
Natural Resources that the existing permit limits be expanded to include a maximum day discharge
limit,and not rely solely on the annual average and maximum 30-day average limits to protect the
quality of the Pigeon River. Daily maximum and maximum 30-day average permit limits would
enhance the consistency of day-to-day in-stream water quality,and would be consistent with limits
for other parameters controlled in the present BRPP permit(BOD5,TSS,AOX,etc.). The Tech
Team also believes that these effluent limitations for color should continue to be applied
unambiguously at the end-of-pipe discharge of the mill to the river. However,the current permit is
not clear that this is the point of application of effluent limits for color. See Table A(1),which
prescribes end-of-pipe monitoring,but no color limits are included. See the TRW's 2001
Memorandum,at item no. 8. BRPP has commented that inclusion of a daily maximum end-of-pipe
effluent limitation for color would lead to administrative efforts focusing on any violations of such
a daily maximum limit that may occur, and thus diverting limited mill staff and resources away
from executing process controls and BMPs and wastewater treatment measures. The Tech Team's
recommended range of end-of-pipe permit limits and the derivation of these limits are presented in
Table 5,and discussed,below.

Memorandum
August 14,2007
Page 18
Table 5. Tech Team Recommended Range of End-of-Pipe Color Permit Limits
_Limit _ Range of Recommended.Limits(Ib/day). i
Annual Average 32,000 to 37,000
30-day(Monthly)Average 44,800 to 51,800
Daily Maximum 83,840 to 96,940
Basis for Recommended Annual Average for Color
BRPP provided daily measurements secondary effluent color(lb/day)for every day in 2006.
Examination of the daily measurements for 2006 identified two days(July 7 and 8)with measured.
discharge greater than 100,000 lb/day. BRPP reported that this elevated color discharge resulted
from"CRP slurry tank overflow for approximately 20 minutes,the first time the mill experienced
this type of event." Because these discharges were so high and from a unique source,they were
omitted from the calculation of the annual average. The annual average for 2006,without July 7
and July 8,is 36,695 lb/day,which rounds to 37,000 lb/day.
• This annual average load is less than the 39,000 lb/day suggested by BRPP.
However, it is based on the mill's 2006 performance and does not include any
reductions that may be achieved by the process changes outlined in this
memorandum. As a result of analysis of the BRPP mill discharges by the Tech
Team and others in support of the 2001 permit,the permit's interim color goal was
32,000 lb/day with a range up to 39,000 lb/day.
• As described earlier in this memorandum,the Tech Team recommends that BRPP
implement several key process improvements and investigate others in order to
reduce the annual average toward the interim goal of 32,000 lb/day,which the Tech
Team recommends be carried forward from the 2001 permit as the goal for this
permit term.
Basis for Suggested Daily Maximum and 30-Day Average Limits for Color
The statistical analysis used for the development of EPA's Cluster Rules is documented in
Statistical Support Document for the Pulp and Paper Industry: Subpart B(EPA, 1997).This
document describes EPA's development of,among other things,the variability factors that were
used to calculate NSPS for BOD5 for the Bleached Papergrade Kraft and Soda(BPK)subcategory.
These variability factors are reproduced in Table 6.
Table 6. Bleached Papergrade Kraft NSPS Variability Factors
. . - Variability Factors
Analyte I-Day 30-Day(111onthlyj
BOD, 2.62 1.4
Source: U.S.EPA 1997. Table 2-4.
The BOD5 variability factors shown above were developed using daily monitoring data for the best
performing(in terms of production normalized BOD5 load)BPK mills. The monitoring data
represent the effluent from well-operated wastewater treatment systems. The calculated variability
factors account for the autocorrelation of the daily loads and the log-normal distribution of the
measurements.

PPFP
Memorandum
August 14,2007
Page 19
Notwithstanding BRPP's comments to the contrary,the Tech Team believes that it is reasonable
and appropriate to use the variability factors developed for the BPK NSPS for BOD5 to calculate
BRPP daily maximum and 30-day average permit limits for color because:
• The factors were developed using monitoring data from BPK mills with well-
operated secondary treatment and BRPP is a BPK mill with well-operated
secondary treatment;
• Color,like BOD5, is monitored at the effluent of the secondary treatment plant;and
• Color, like BOD5, is removed from effluent by,a combination of biodegradation
and absorption/adsorption to biomass.
Applying the BOD5 variability factors to the 2006 annual average daily color discharge results in
the following daily maximum and 30-day average limits:
Daily Maximum: 37,000 lb/day x 2.62=96,940 lb/day
30-Day(Monthly)Average: 37,000 lb/day x 1.40=51,800 lb/day
The Daily Maximum and 30-day(Monthly)average limits for the long term average goal of 32,000
lb/day are derived in the same manner.
Comparing the 2006 effluent monitoring data to these limits finds that two days exceeded the daily
maximum,July 7(104,504 lb),and July 8(101,223 lb), during the unexpected CRP tank overflow.
Further,the 30-day(Monthly)average(51,800 lb/day),as calculated for compliance purposes in the
current permit,was not exceeded for 2006.
Comparison to Glatfelter Permit Limits
The Glatfelter,Inc.mill in Spring Grove,PA(NDPES permit number PA0008869), like BRPP, is
an older bleached kraft mill that discharges to a small,color-limited stream. As noted previously,
however,Glatfelter does not use the BFRTM process that is unique to BRPP. As described in PA
DEP's Water Quality Protection Report(Furjanic,2007),during the summer,the Glatfelter mill is
permitted to discharge 140 mg/L color(average monthly)and 280 mg/L(daily maximum). Winter
discharge limits are"more stringent. The Glatfelter mill's average daily discharge is 11.9 MGD and
it produces an average of 1268 U.S.tons of paper per day. BRPP produces approximately 1640 US
tons per day,with a greater proportion of softwood to hardwood processed than at the Glatfelter
mill,and with a daily total wastewater flow of approximately 26 MGD. Therefore,the Tech Team
calculates that the recommended range of end-of-pipe permit limits for BRPP(32,000 to 37,000
lb/day annual average;44,800 to 51,800 lb/day 30-day average; 83,840 to 96,940 lb/day daily
maximum)are less stringent than the Glatfelter permit limits expressed on the same production
normalized basis(either lbs/metric ton pulp or finished paper).

PPPPFP
Memorandum
August 14,2007 '
Page 20
References
Andri[z Ahlstrom Sales. 2001. Pruyn's Island Technical Center Report 2001-068 Part 1.
Laboratory and Lo-Solids Cooking with O-Do-Eop-D Bleaching Sequences on Softwood Furnish
from Blue Ridge Paper,Blue Ridge,NC. Part 1 Softwood Results. Part 2. Hardwood Results.
(December 6).
Audet,Andre,Michel Faubert,Zhi-Hua Jiang and Barbara van Lierop,PAPRICAN. 2003.
Technical Service Contract Report TSC-7447. Bleaching Evaluation for Effluent Colour
Reduction. Prepared for Blue Ridge PapeF Products,Inc., Canton,NC. October.
Blue Ridge Paper Products,Inc. 2005. Chloride Removal Process(CRP) Color Reduction
Technology Assessment. (March).
Blue Ridge Paper Products,Inc. 2006a. Color Compliance Report: Canton Mill.(May).
Blue Ridge Paper Products,Inc. 2006b. Blue Ridge Paper response to questions from the
Technology Review Workgroup(TRW) that were e-mailed on 28 Nov 2006.(December 19).
Blue Ridge Paper Products,Inc.2007a.Response to additional questions for BRPP about data
provided to TRW Don Anderson e-mail dated 5 March 2007(March 15)
Blue Ridge Paper Products, Inc. 2007b. March 19, 2007Additional Data Required from BRPP
(March 28).
Bodien,Danforth G. 2007. Site Visit Report,Blue Ridge Paper Products, Canton,North Carolina.
(April 2007)
EPA Tech Team. 2001. Memorandum to Technology Review Workgroup. "Additional Color
Removal Technologies and Their Economic Impacts on Blue Ridge Paper Products, Canton,NC."
(July 25,2001).
Furjanic, Sean M. 2007. Water Quality Protection Report,P. H.Glatfelter Company, Spring
Grove Borough and Jackson Township,York County,for the Renewal of NPDES Permit No.PA
0008869.
PADEP Southcentral Regional Office(draft,February 2007).
GL&V Pulp Group,Inc.and Liebergott&Associates Consulting. 2001. Bleach Environmental
Process Evaluation and Report. Prepared for Blue Ridge Paper Products,Inc. and Clean Water
Fund of North Carolina. (June 8)
GL&V Pulp Group,Inc.,Liebergott&Associates Consulting. 2006. 2006 Update: Bleach
Environmental Process Evaluation and Report. Version containing manufacturer's proprietary
information.Prepared for Blue Ridge Paper Products,Inc.(July 7,2006)
Munro,Fred and John Griffiths. 2000. Operating Experience.with an Ozone-based ECF Bleaching
Sequence,Proc.International Bleaching Conference,Halifax, Canada,2000. TAPPI Press.
Technology Review Workgroup,2001.Memorandum to North Carolina Division of Water
Quality and the NC Environmental Management Commission's NPDES Sub-Committee.

Ppp
Memorandum
August 14,2007
Page 21
"Additional Color Removal Opportunities, Blue Ridge Paper's (BRP) Canton,NC
Bleached Kraft Paper Mill, 2001 NPDES Permit Renewal."(August 3,2001).
U.S.EPA, 1997. Statistical Support Docwnent for the Pulp and Paper Industry: Subpart B.
(November)

Additional questions for BRPP about data provided to TRW
1. BRPP provided the following monitoring data to the TRW:
TRWRequested WTPData.xls, "TRWData"worksheet
Secondary Effluent
Influent to Treatment
PE Color 2001-2006.xls
Primary Effluent
Please identify the monitoring locations that correspond to the data provided by BRPP.
Indicate the locations on:
- a flow diagram for the current configuration for the wastewater treatment plant;
- a flow diagram for its configuration prior to the segregation of the acid sewer; and
- indicate for what dates each configuration applies.
If the values for Primary Effluent reported in PE Color 2001-2006.xls
were calculated by summing loads for the acid sewer and primary clarifier overflow,
please provide the daily values for individual streams.
2. Figure 2 of the February 23, 2007 letter from Glenn Rogers and Paul Dickens shows
the trend in WWTP removal % (PI [Primary Influent] —SE fSecondary Effluentl). For
the period after the acid sewers were segregated from the rest of the mill flow, how is the
acid sewer color contribution calculated for in Primary Influent?
3. During the mill visit,BRPP stated that there was no apparent decrease in SE color
when CRP wastewater was not flowing into the treatment system. For the SE data
provided to the TRW(1/l/2002 to 11/30/2006),please identify the dates during which the
CRP wastewater was not flowing to the WWTP.
4. For 2006,please identify mill process operations,maintenance events, and any other
unusual events that occurred immediately preceding!coinciding with each measured
color discharge (e.g., pulp mill/bleach plant/BFR/treatment system upsets, etc.,based
on daily sewer/treatment system data sheets, etc.) for which:
Secondary effluent>50,000 lb/day
Primary effluent>100,000 lb/day
Influent to treatment>65,000 lb/day
1

5. During the TRW visit to the mill,BRPP identified potential projects that may improve
color discharges to the river. Among these projects was a recovery area project described
as, "dregs filter feed improvements, underflow pump upgrade." Please explain the
possible scope of this project,how much and how often green liquor dregs are currently
sewered(including any events in 2006, per item#4 above),where they are known to
occur(or may be occurring) in the sewer system, and how BRPP believes the green
liquor dregs releases,affect color. What improvements in color discharges are expected
from this project?
6. Utilizing the results of evaluations performed by PAPRICAN and Andritz-Ahlstrom,
please explain how BRPP calculated (and any underlying assumptions)the impact on
final effluent color of:
- ozone and C1O2 bleaching stage on the hardwood line; and
- second stage OD on the pine line.
2

BRPP Monitoring Data Provided to the TRW
Work - Location Time Period of
File name. Sheet Identification . Data Data Provided
TRW Requested TRW data Secondary Effluent 1/1/2002 BOD (Ibs/day)
WTP Data.xls 11/30/2006
COD Ibs/da
True Color Ibs/da
Temp de C
Flow MGD
Influent to Treatment 1/1/2002- BOD (Ibs/day)
11/30/2006
True Color Ibs/da
Temp de C
PE Color'2001'- PE Color PrimarylEffluent 1/1/2001 True Color(Ibs/day)
2006.x1s Data 12/31/2006
TRW Prod and WTP Annual NA 2001-2006 ytd Pulp Production,ADBTP
Data.xls Data /cal day
Paper Production,ADT/
cal day
BFR Annual Average
Closure Rate, %
Secondary effluent 2002-2006 ytd Avg.Annual.SE Flow,
m d
1997-2006 ytd Avg.Annual SE True
Color, Ibs per day
2002-2006 ytd Avg.Annual SE BOD,
Ibs/da
2002-2006 ytd Avg.Annual SE COD,
Ibs/da
3

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Agenda
EPA Tech Team Report Discussion
Blue Ridge Paper Products Inc.
July 25,2007
I. Introduction
II.Areas of Agreement:
• CRP color studies
• Leaks and spills
• Outage planning
• Acid sewer color studies
• Color treatment
• Spill capacity
III.Unresolved Issues:
• Second-stage oxygen deliginification on the pine fiberline
The requirement to install second stage oxygen delignification is not appropriate at this time.
Laboratory studies and engineering analysis to evaluate the color reduction benefit and cost of
2-stage OD on pine against the criteria of technical,economic and operational feasibility are
appropriate.
• Peroxide fortification on the pine and hardwood fiberlines extraction stages and hardwood
extraction stage oxygen fortification
The 2006 Liebergott report recommends evaluation of peroxide fortification of the pine Eo stage
and evaluation of oxygen and peroxide fortification of the hardwood E stage. Consistent with
the 2006 Liebergott report,full-scale trails to evaluate the color reduction benefit of EoP on
bleach plant filtrate and final effluent color are appropriate.
• Further trials to evaluate potential of ozone/chlorine dioxide(ZD)bleaching for the
hardwood fiberline
We do not agree with the Tech Team recommendations on ZD. Dr.Liebergott does not
recommend ZD for the Canton Mill. We believe that further evaluation of ZD bleaching is not
warranted at this time.
• Daily color limit
Daily color performance is important and we continue to work hard to minimize color variability.
However,a daily color limit is not appropriate.Also,under both EPA and North Carolina water
quality procedures for applying aesthetic water quality standards a 30-day average is listed as the
appropriate time period.Therefore,a monthly average limit is appropriate.
IV. Other issues and concerns
V.Follow-up communications

Blue Ridge Paper Comments Julv 25.2007
MEMORANDUM
DATE: June 29,2007 (2nd Draft Final,DO NOT DISTRIBUTE until this header is
deleted)
SUBJECT: Color Removal Strategies For Blue Ridge Paper Products,Inc.
FROM: EPA Tech Team'
TO: Technology Review Workgroup
Purpose of this Review
Blue Ridge Paper Products Inc.(BRPP)has requested renewal of their National Pollution Discharge
Elimination(NPDES)discharge permit NC0000272. This permit allows discharge to the Pigeon River of
industrial and other wastewaters from the pulp and paper mill BRPP operates in Canton,NC. In their
May 2006 Color Compliance Report(Blue Ridge,2006a),BRPP requested that North Carolina reissue
the NPDES permit for the Canton Mill with an annual average effluent color limit of 39,000 Ibs per day.
This is a reduction from the current 42,000 lb per day annual average limit which became effective
January 2004. BRPP's requested limit was based on the mill's 2005 annual average effluent color,
39,000 lbs per day.The Technology Review Workgroup requested that the EPA Tech Team support
EPA's review of the color limits included in the draft permit renewal developed by North Carolina
Department of Environment and Natural Resources. The Tech Team last evaluated color discharges at
the mill in 2001 (EPA Tech Team 2001).
Members of the Tech Team visited the Canton mill on February 8,2007 to observe and collect
information and data on the status of technologies implemented and color discharges at the mill. This
draft memorandum incorporates analysis of data from that visit and other data provided by BRPP.
This memorandum reviews the process improvements previously analyzed by the Tech Team,the status
of their implementation at BRPP,and identifies additional color reduction activities that BRPP could
implement during its next permit term. The memorandum also reviews the variability of the mill effluent
color discharges and suggests final effluent color limits for incorporation in the revised permit.
Background and History
BRPP operates a bleached papergrade kraft pulp and paper mill in Canton,NC,which it purchased from
Champion International Corporation in May 1999.BRPP is owned 55 %by KPS Special Situations Fund,
L.P.and 45 %by the employees through an employee stock ownership plan. BRPP announced on June
14,2007 that it is being acquired by The Rank Group. The New Zealand-based Rank Group has
considerable holdings in the paper industry. Rank Group recently bought Evergreen Packaging,the
former North American beverage packaging division of International Paper. Operations at the mill began
in 1908, but the mill has been extensively modernized,with the most recent major project completed in
1993. The mill currently operates a 810 tpd hardwood pulping line and a 600 tpd softwood(pine)pulping
EPA Tech Team members are Ahmar Siddiqui, EPA/EAD;Karrie-Jo Shell,EPA Region 4;Donald Anderson,
EPA/EAD;Betsy Bicknell ERG,contractor;Neil McCubbin,subcontractor to ERG;Dan Bodien,subcontractor to
ERG.
2 BRPP announced on June 14,2007 that it is being acquired by The Rank Group. The New Zealand-based Rank
Group has considerable holdings in the paper industry. Rank Group recently bought Evergreen Packaging,the
former North American beverage packaging division of International Paper.

Memorandum
May 10,2007
Page 2
line. After cooking,pulp from each line is further delignified in single-stage oxygen delignification(OD)
systems,both installed in 1993.Hardwood pulp is subsequently bleached with a DED sequence(BRPP
stopped adding oxygen to the hardwood E stage after 200.1).Pine pulp is bleached with a DEoD sequence
(BRPP stopped adding peroxide to the pine E stage after 2001). Target brightness is 86 ISO,an increase
by one point from the target brightness in 2001. Up to 80%of the filtrate flow from the pine bleach line
is returned to the recovery cycle using the unique bleach filtrate recovery(BFRrm)process,developed by
Champion.This 80%closure rate is an improvement from 2001,when the pine line closure averaged
73.7%.Up to 25%of the hardwood line bleach plant E-stage filtrate flow is also recovered. BRPP
produces 300,000 tons per year of uncoated paper including offset,tablet,and envelope grades.The mill
also produces 275,000 tons per year of bleached paperboard used for liquid packaging and paper cups,
including FDA-approved grades for milk and juice cartons.
Basic tenets of this review,which are consistent with the Tech Team's approach beginning with the
original Settlement Agreement(with Champion International)and the 2001 TRW review with BRPP,are:
• The first and highest priority again is focused on available in plant process changes and best
management practices(BMPs)as the most cost-effective approach to color reduction in order to
maximize the likelihood of success
•• Process changes deemed to be of highest and reasonable certainty,thereafter lowest
certainty technologies
•• BMPs that hold promise to further reduce generation and discharge of color
• After it is clear that in plant process changes and BMPs alone may-are not be sufficient, in plant
segregated stream pretreatment and end-of-pipe treatment options will be are carefully considered
The Tech Team recognizes that very difficult and unusual circumstances occurred in 2004,with back-to-
back historical flooding of the Pigeon River and associated significant costs($39 million)for repairing
damage and replacing equipment at the BRPP mill after 21 days of being out of operation. The Tech
Team also recognizes that significant additional expenditures have been made over the last permit term
for environmental projects($25.9 million),the largest portion for air pollution controls(e.g.,MACT I and
II compliance)and including color reduction projects($5.9 million),all building on previous projects and
expenditures. All of this has occurred during a continuing period of industry-wide transformation,
capacity shrinkage,and mill closings. Nonetheless,the BRPP mill management has committed to
surviving these challenges. The Tech Team notes that these efforts and expenditures have resulted in
substantial and commendable progress made to date by BRPP through expenditures for additional and
improved process and related technologies,treatment technologies,and management practices which
have reduced the long term average color discharges. It is also noteworthy that some of these
technologies and practices have been in addition to those identified in the previous Tech Team/TRW
reviews.
Process Improvements Previously Analyzed by Tech Team
As a result of its 2001 analysis of the BRPP mill discharges and operations,the Tech Team identified five
mill improvements that it judged capable of reducing the discharge of color in the mill effluent. BRPP
and its consultant also identified several process optimization projects that would reduce color discharges.
The status of BRPP's implementation or evaluation of each of these improvements is summarized in
Table 1,discussed below.

Memorandum
May 10,2007 '
Page 3
Table 1. Review of Process Improvements Identified in 2001
Predicted Color
Reduction(Final Color
Effluent,lbs/day Reduction -
,Improvement ann.avg). Implementation Status Achieved Comments
Process 1,400 Predicted reduction in BRPP consultant recommends
optimization C102 use(27%on HW, reduced C1O2 use and evaluate adding
projects 17%on SW)not made. oxygen and peroxide to E stages to
C102 use increased on reduce color generation(GL&V 2006,
SW,decreased 5%on HW pp52-53)
BFR reliability I,000—.1,200 Pine line filtrate recycle Total Further improvements to BFR
improvement increased from 74 to 80% reduction from reliability may not be feasible
2001: 6,000
Improved black >5,000 Spill collection lb/day,annual Additional improvement to black
liquor leak and improvements made; average liquor control possible: further
spill collection untreated color(influent to eliminate overflows and pretreat
control(Blv1Ps) treatment)variability diverted high-color wastewater.Also
unchanged improve control of losses of white and
green liquors to reduce or eliminate
sulfide-based color
Ozone/CI02 3,000-6,400 Incmnpletelnadegttate BfiPFiltou7d-cempteia-ae-tody
stage for evaluation(lab studies); te
hardwood line not installed None eralaatu-r�zeae�lr.tchin"
No ftulherstudy warranted.
2"d Stage OD for 1,100—1,400 Incomplete evaluation(lab TFtisaltentat+ isteebnically-arttl
pine line studies);not installed
eoncertts-fer�dditiona!✓;tudvare
noted.Engineering:
None
Wla ...,o„9..cav,-,.,•.:mplRnentation.
Laboratory studies and engineering
analysis for cost and color reduction
benefit are required.
Color treatment 52,750 Evaluated(lab studies); CRP purge stream now averages
of CRP purge not installed 8,745 lb/day.Additional Foil sea!
stream testing fore. ided-per-ied to
determine what fraction of this color
is removed in the W WTP should be
None undertaken. Any of this color that is
not removed in W WTP should Paull
be-continued to be evaluated for
reduction Ilvough-reduced- ,th
pretreatment. Need further study of
strategies for reducing color released
in the purge.

Memorandum
May 10,2007
Page 4
Process Optimization Projects
In 2001,Liebergott&Associates and GL&V Pulp Group prepared an extensive analysis of the mill
fiberlines that included identification of options for effluent color reduction. Dr. Liebergott was retained
for this work by a coalition of environmental groups. This report,Bleach Environmental Process
Evaluation and Report(BEPER)(GL&V 2001)presented 16 recommendations for incremental
improvement to fiberline operations. These included suggestions for improving process control, OD
performance,reducing the amount of CIOZ used on both bleach lines,and enhancing the extraction stages
on both bleach lines with oxygen and/or hydrogen peroxide. The BEPER recommendations were
evaluated, and BRPP implemented those deemed to be technically,economically,and operationally
feasible.
Process control and OD performance have been improved. However,on the hardwood line,the Di stage
kappa factor has not been decreased as previously recommended and use of oxygen in the extraction stage
was discontinued. As a result,the total CI02 charge on the hardwood line as of May 2006 was only 5%
less(not the predicted 27%less)than the charge in 2000. Similarly,on the softwood line,the Di stage
kappa factor was not decreased as previously recommended and the use of peroxide in the extraction
stage was discontinued. As a result,the total CIOZ charge on the softwood line as of May 2006 was 11%
more(not the predicted 17%less)than the charge in 2000. While BRPP has noted the increased portion
of higher brightness pulps since 2001 as a reason for these changes,among other trade-offs cited,the
Tech Team believes these changes may-are still be viable and should remain as options for additional
color reduction high-ewtaimy options.These process modifications should continue to be evaluated and
considered items of reasonable certainty.
In preparation for renewal of their NPDES permit,BRPP retained Liebergott&Associates and GL&V
Pulp Group to analyze their fiberlines,review the implementation of the 2001 recommendations,and
identify further options for color reduction. In the 2006 update to the BEPER(GL&V 2006),the
consultants repeated their recommendations for BRPP to reduce the kappa factor in the D, stage of each
bleach line and evaluate the replacement of the CIO2 bleaching power with oxygen and/or peroxide in the
extraction stages. Increasing the operating temperature of the hydrogen peroxide extraction stage to
reduce effluent color also has been identified as a viable option to evaluate during this process.
In addition to reducing the color of the bleach plant effluents,use of a lower kappa factor means BRPP
would use less CIO2 to bleach,which will reduce the total chloride content of bleach plant filtrates.
Lower chloride content can also be expected to make it possible for the mill to reduce the CRP purge flow
and the color it contributes to the mill effluent. The Tech Team also believes that lower chloride content
could+vill make it possible for the mill to recycle more filtrates within the hardwood fiber line,
notwithstanding BRPP concerns(e.g.,adverse effects to washing,carryover to D stage,possible increased
chemical usage and color). Further,it also may be possible to introduce a portion of these these
hardwood filtrates to the BFRTM process,which to this point has been dedicated solely to recovering
softwood fiber line filtrates,and reduce the total colored filtrates discharged to the sewer.
BFR Reliability Improvement
As reported during the Tech Team's February 2007 site visit,BRPP spent$1.5 million over the last five
years to improve the reliability of the BFRTm system. These expenditures included replacing tank liners
for the three existing sand filters(now high grade stainless steel),replacing and/or upgrading existing
process piping with piping with improved metallurgy,installing a fourth(new)multimedia filter,and
installing a third ion exchange softener. With these improvements in more reliable metallurgy and unit
process redundancy,BRPP has increased the BFRTm closure rate from 73.7%in 2001 to 79.2%in 2006.
Mill representatives stated that the present closure rate of approximately 80%of the pine line bleach plant

Memorandum
May 10,2007
Page 5
effluent represents the maximum amount attainable without incurring unmanageable corrosion and
scaling problems. Further increases in closure and increased recycle rates above 80%may be possible but
are likely to be a significant and very difficult challenge with the corrosion and scaling problems
associated with current mill bleaching filtrate chemistry. This is because scaling from hardness minerals
accelerates above closure rates of 80%(Bodien,2007):
Improved Black Liquor Leak and Spill Control(BMPs)
BRPP continued efforts intended to improve its management of leaks,spills,and intentional diversions of
black liquor over the last six years. These efforts include:
• Interconnecting the pine line and hardwood line spill collection sumps so that tankage in
either line can be used interchangeably for spills;
• Repositioning sewer conductivity probes from sumps to in-line to more accurately and
reliably identify high conductivity wastewaters;
• Diverting up to one hour of total mill flow to off-line 1-million-gallon clarifier,during
high color releases,thus providing some equalizing of color discharge to wastewater
treatment plant;
• Prior to process line outages, improved prior planning for capturing high-color process
liquors and black liquors and better managing their timed release to treatment system;
• Continued operator training; and
• Implementing two hour testing for color at the W WTP with one hour testing during
outages or semi-annual shutdowns.
BRPP has stated that these improvements in BMPs have resulted in reduced color variability in in neat
to the primary treatment unit,which BRPP asserts is the best measure of color reduction through in
plant changes and BMPs. Data provided by BRPP are presented in Table 2 and depict Primary(total)
Influent Statistics by year.
Table 2. Primary(Total)Influent Statistics,by year
Mean Relative
True Color Standard Standard Deviation Percent Decrease
(lbs/day) Deviation(SD) (SD/mean%) from Baseline(2001)
2001 57,725 20,619 35.7% 0.00%
2002 54,780 17,195 31.4% 5.10%
2003 55,550 19,424 35.0% 3.77%
2004 491466 18,786 38.0 0 14.3 0
2005 45,175 22,297 49.4% 21.7%
2006 38,454 14,015 36.4% 33.4%
Primary effluent,which is the total load to secondary treatment,is directly measured with a composite
sampler. Data provided by BRPP and compiled by the Tech Team are presented in Table 3 showing the
mean,standard deviation,and relative standard deviation(standard deviation as a percent of the mean)by
year, for the years 2001 to 2006. Prior to 2006,the acid sewer mixed with other mill wastewater prior to

Memorandum
May 10,2007
Page 6
the treatment system,resulting in"sewer generated color." As of January 1,2006,the acid sewer was
separated from the other mill sewers and now enters the treatment plant after the primary clarifier. The
primary effluent sampler is located downstream of the mixing point of the primary clarifier overflow and
acid sewer.Thus,the statistics for 2006 presented in Table 3,represent the mixture of primary effluent
and acid sewer, including any color generated from the immediate mixing of the two streams. It is
possible that additional color generation from this mixing occurs after sampling within the secondary
treatment system with additional time for any chemical reactions to proceed to completion.

Memorandum
May 10,2007
Page 7
Table 3. Primary Effluent(Influent to Secondary Treatment)Statistics,by year
_ Mean Relative
True Color Standard Standard Deviation Number of days
Obs/day) Deviation(SD) (SD/mean%) >100,000 lb/day
2001 62,008 19,561 31.5% 13
2002 59,956 18,680 31.2% 16
2003 59,646 18,468 31.0% 10
2004 65,206 26,674 40.9% 40
2005 F 63,838 24,158 37.8% 28
2006 65,512 25,427 38.8°% 36
Table 3 presents the number of days for which the primary effluent color exceeded 100,000 lbs/day.
Comments received from BRPP assert that primary effluent is not the most appropriate measure of
progress. BRPP further stated that color loads to the primary treatment system have been reduced. 411
spite of-impF64EtHe-nt5-in de Ewer he last'pe nit iofiii ...lulling the acid sewer.^l..eation, .,—ull,clearl'jmade iii gog d faith by BRPP.the Teeh Team respectffilly disagrees Ah thesc .
assertions.
As shown in
^ ^ ^ ^ta-dee5 net app of to steppe ' that there re tas heon pregre5 rin reElueino hey
BRPP provided the Tech Team with notes describing mill events that were related to high primary
influent eMuettt color in 2006 (Blue Ridge 2007a). These events included,among others,planned mill
outages,unplanned outages,a CRP slurry tank overflow,and a release from the evaporator related to an
equipment failure. BRPP does not track and did not report one single event or one single type of event
that caused high color in the primary effluent. Further,not all high primary effluent color resulted in a
high final effluent discharge(e.g.,BRPP reports that color associated with high turbidity is effectively
removed in the secondary treatment system). However, from analysis of the data,the Tech Team
concludes that the Canton mill can further reduce primary effluent loads through continuing efforts to
minimize unplanned spills and leaks and intentional discharges of high-color streams during fiber line
disruptions. BRPP has reported some success through recent efforts in detailed scheduling of planned
outages and contingency planning for unplanned outages and continuing efforts to minimize process
operation variability. The Tech Team notes that these efforts,though challenging,must be further
developed and consistently implemented wherever possible to minimize high color discharge risks all
agree are associated with these fiber line disruptions,both planned intgnt and unplanned
tttt4rltentiotlal.
BRPP believes that-seooltda:-effluent she...-'r.-provement.and d Data provided by BRPP,which
shows that secondary effluent has improved significantly over the past five years,are presented in Table
4.This shows that reliance on primary effluent information and other data collected within the Mill's
biological treatment system is not indicative of the true facility performance.
Table 4 Secondary Effluent Statistics,by year
Mean Relative
True Color Standard Standard Deviation Number of days
Obs/day) Deviation(SD) (SD/mean'%) >100,000 lb/Jay
2001 42,676 10,925 25.60/. 3

J
Memorandum
May 10,2007
Page 8
2002 41,166 9,928 24.1%. 0
2003 44;627 11,043 24.7% 1
2004.* 41,463 32,568 76.6% 4
2005 39,092 10,092 25.8% 0
2006 37,058 8,959 24.2% 2
*.-2004 data were affected by historic floods in September 2004
Ozone/Chlorine Dioxide Stage for the Hardwood Bleach Line
BRPP engaged the Pulp and Paper Research Institute of Canada(PAPRICAN)to investigate potential
modifications to the hardwood pulp bleaching process and determine effluent color reduction that would
result from these modifications.The PAPRICAN report entitled"Bleaching Evaluation for Effluent Color
Reduction"(Audet et al,2003)was provided to the Tech Team in early 2007.
PAPRICAN stated that their objective was to evaluate whether modifications to the hardwood bleaching
sequence at Canton specified by Mr.Johnnie Pearson(BRPP process engineer)could"generate effluents
with a color reduction target of 25%."
BRPP provided PAPRICAN with oxygen delignified hardwood pulp.PAPRICAN bleached this pulp in
their laboratory,investigating various combinations of chlorine dioxide,ozone and hydrogen peroxide.
The report concluded that ozone could replace some of the chlorine dioxide used in bleaching(known as
a"DZ"stage),while producing pulp of equal or slightly better quality than the control sequence. This is
consistent with the open literature on ozone/chlorine dioxide combinations.
PAPRICAN also concluded that replacing some of the chlorine dioxide in bleaching with ozone increased
the color in the bleach plant effluents. This contradicts the experience reported by Domtar(formerly E.
B.Eddy)at their Espanola mill,where a dramatic reduction in effluent color was observed when that mill
installed an ozone pulp bleaching system(Munro and Griffiths,2000). The Tech Team notes that the
Espanola mill has no color discharge limits and it installed ozone to reduce its bleaching costs.
The Tech Team found significant deficiencies in PAPRICAN's analysis of the laboratory results. The
2006 Liebergott/GLV report agrees with this finding. The concentration of color in the effluent for each
stage was added to obtain the total concentration for each tested bleach sequence. This approach neglects
two points:
1) Mixing effluents produces reactions that may increase or decrease the concentration of
color in the combined effluent.
2) Filtrate volume affects the measured concentration(e.g.,lower volume will concentrate
the filtrate to a higher color). PAPRICAN's report does not present the filtrate volumes,
so a comparison of concentrations may be misleading.
Liebergott,et.al.,reviewed the PAPRICAN report and identified the same deficiency with regard to
effluent mixing. They also noted that the quantity of chlorine dioxide added to the ZD stage was too
high,which would result in higher effluent color(GL&V 2006,p 18).
In response to EPA's question about how the PAPRICAN results were used to estimate impacts on final
effluent color,BRPP responded:

Memorandum
May 10,2007
Page 9
The pilot study reactors were batch and not continuous and did not include filtrate
recycle. The pilot studies included bleach stage filtrate color concentrations, but there
was no frltrate,llow,rate data from which to calculate a production-normalized filtrate
color mass. For these reasons, we did not attempt to calculate secondary effluent color
impacts using pilot study data for individual bleach plant color streams.
Li the PAPRICAN study, the individual bleach stage colors were compared directly
and in total. By both means, the color of the ZD stage was higher than the baseline
DEoD. It is also well known that when individual bleach stage filtrates are mixed the
resultant effluent color is very difficult to predict. (Blue Ridge,2007a)
The Tech Team concludes that BRPP's investigation of the potential for hardwood pulp ozone bleaching
to reduce the mill's effluent color was iucomplcte4fw4equa4e. The Tech Team believes that further
laboratory trials,designed and implemented to provide reliable information on the production normalized
color generated by each stage and by the effluents as combined at the BRPP mill,are not needed to
", ea e-1histeelinele .
Second Stage Oxygen Delignification for the Pine Bleach Line
BRPP contracted with Andritz/Ahlstrom("Andritz")to study,among other things,the addition of an
additional stage of oxygen delignification in the softwood bleach line at Canton. Andritz,a well
established supplier of pulping and bleaching technology and equipment,maintains the Pruyn's Island
Technical Center,which conducted the tests. The Andritz report, entitled,"Laboratory CK and Lo-Solids
Cooking with O-Do-Eop-D Bleaching Sequences on Softwood Furnish from Blue Ridge Paper,Blue
Ridge,NC"(Andritz Ahlstrom Sales 2001)was provided to the Tech Team in early 2007.
The text of the Andritz report states that"BRPP requested the sales department of Andritz-Ahlstrom to
investigate alternative methods of pulping and bleaching that would reduce their waste products and
improve the quality of their hardwood and softwood paper products." As indicated by this statement of
work,testing of second-stage oxygen delignification was a minor part of the work Andritz did for BRPP.
Further,very few of the data in the report are useful for analysis of effluent color improvement.
Specifically,Andritz compared single stage and two stage oxygen delignification of samples of pulp
provided by the BRPP mill.The tests showed that second stage of oxygen delignification could reduce
the kappa number of the unbleached pine pulp by 22%.
Andritz did not bleach the pulp after the two stage oxygen delignification,so the report provides no
information on the impact of the additional oxygen delignification stage on effluent characteristics,
including color.
In response to EPA's question about how the Andritz results were used to estimate impacts on final
effluent color,BRPP responded:
The Andrtiz Ahlstrom study of second stage 02 for pine showed delignification
ranging from 42.7%for the single stage, 48.6%for the 0-0 and 55%for the 00 stage.
With improvements that BRPP made on the existing single stage pine 02, the
deliginification: increased from 40% to 45%. With BFR in place on the pine fiberline,
the effluent color reduction from this improvement in 02 deligiuification has been very
difficult to identify. The inability to quantify the effect on effluent color of improved
02 de[iginification made the capital cost to install a second stage 02 on pine not
economically feasible. (Blue Ridge,2007a)

Memorandum
May 10,2007
Page 10
BRPP's analysis of the benefits of adding a second oxygen delignification stage to the pine line is
incomplete. BRPP's consultants note that even with the percent delignification currently achieved on the
pine line, a second stage could achieve an additional 20 to 25%delignification(see GL&V 2006,p 118).
By making a 20 to 25%reduction in the kappa number of the pine pulp before bleaching,20 to 25%of
the colored material currently discharged from bleaching to the BFRTM could potentially would be
recovered and burned in the mill's recovery boiler. In addition,the quantity of chlorine dioxide and
caustic required in bleaching would be reduced by approximately 20 to 25%,reducing the load on the
BFRTM system. If actually effective tThis may weuld allow an increased proportion of the bleach filtrates
to be recycled through the BFRTM system. BRPP believes that a kappa number decrease or
delignification efficiency increase would not necessarily equate to a similar decrease in color. Although
with the information available it is not possible to rigorously calculate the benefit of this change,the Tech
Team would expect in the order of 1000 lbs/day reduction in bleach plant color discharge.
Liebergott,et.al.,(GL&V 2006)estimated that implementing a second oxygen delignification stage on
the pine line would reduce color discharge by 1142 lbs/day.They estimated the capital cost of adding an
additional oxygen delignification stage would be in the order of$2 to$3 million and the chemical cost
savings approximately$1.2 million/year,providing a reasonable payback. Mill staff has mentioned a
three year pay-back,which is consistent with this estimate,but have further asserted from their more
recent estimates that the cost could be$3 to 5 million owing,presumably at least in part,to increases in
the general prices of stainless steels(not as specifically fabricated and estimated for this technology). The
BRPP oxygen delignification systems were installed in 1993. Since that time,the use of two-stage
oxygen delignification rather than the traditional single-stage systems has become well established in the
industry because it normally further reduces mill operating costs. BRPP believes that the previous
evaluation of adding a second stage oxygen delignification stage should be repeated in part because of
differences cited in delignification efficiencies.Nonetheless,the Tech Team believes this technology has
potential to move progressed beyond being considered"reasonable certainty"in 2001 to"highest
certainty„at this time: ..,ram•" '• -1- A d at the eaFliest ., gibl.,date
The Tech Team identified the following color reduction activity for BRPP: conduct laboratory studies to
evaluate the color reduction benefit and engineering analysis to determine the cost of op-an
engit ee=^ deb rtding to the installation of an additional oxygen delignification stage for the pine
(softwood)pulping/bleaching line. In 2001,the Tech Team estimated that this process change would
reduce effluent color by 1,100 to 1,400 lbs/day. As noted above,even after the recent improvements to
pine line delignification efficiency,GL&V estimated that this change would reduce discharge by the
order of 1000 lbs/day.
Andritz also evaluated modifications to the mill cooking process. These would require complete
replacement of the digester systems at Canton,which would cost(at least)several tens of millions of
dollars,if they are feasible at all within the mill's space constraints. The Tech Team concluded that
modifications to the mill cooking process do not merit further analysis.
Treatment of CRP Purge Stream for Color Removal
The Chloride Removal Process(CRP)purge is a low flow,highly concentrated stream. Color is typically
41,000 platinum cobalt units(peu)in a stream that discharges at 10 gpm(15,000 gal/day of 3 tank
trucks;tlay). BRPP reported that in 2006 the CRP purge contributed approximately 8,745 lb/day(23%)of
the total mill color loading to the treatment system but only 0.05%o£the discharge flow. By comparison,
in 2001 the CRP contributed approximately 5,000 lb/day(13%)to the treatment system loading(EPA
Tech Team,2001). Thus, in the last five years there has been a significant increase in color contributed

Memorandum
May 10,2007
Page 11
by the CRP,both in lb/day and in percent of total mill load. BRPP reported on its investigations into
technologies for reducing CRP purge color in'its March 2005 report,"Chloride Removal Process(CRP)
Color Reduction Technology Assessment" (Blue Ridge 2005).In this report,BRPP points out that the
CRP purge is a very concentrated material(360,000 mg/L or 36%total dissolved solids)that is
discharged to sewer at 165'F. Handling the material is difficult because it will crystallize as it cools.
Also,it is quite corrosive due to the high chloride content.
As described in their 2005 report,BRPP assessed more than nine alternatives for disposal or treatment of
the CRP purge and concluded that none was technically feasible. Although consistent performance was
not demonstrated,CI02 bleaching was a low cost,potentially effective means of reducing the CRP purge
color prior to discharge to the treatment system.BRPP found that CIOZ bleaching could inconsistently
remove up to 75 to 90%of the color in the CRP purge stream. }hia3i_+tiisanHedust en i+3 a new
prominent scarce-0ta efor:
Although CRP purge is a relatively low flow stream,BRPP estimated that off-site solidification and land
'disposal would cost more than$3.6 million/year excluding loading facility infrastructure.
During the Tech Team's 2007 mill visit,BRPP stated that there was no apparent decrease in secondary
effluent color when CRP wastewater was not flowing into the treatment system. In response to a Tech
Team request,BRPP presented data correlating the days on which the CRP process was shut down with
secondary effluent discharge color,for August 2006 to January 2007(Blue Ridge 2007a). During this
period,there were nine widely dispersed pairs of days when the CRP process was down for part of the
day. BRPP believes conekided that CRP color is removed in the secondary treatment system,based on an
ANOVA analysis comparing"down"days with CRP operating days and general observations. However,
in response to a Tech Team follow-up request for clarification BRPP later indieate confirmed these data
allowed no definitive conclusion,and that there is no relationship of presence or absence of CRP purge to
secondary effluent color based upon general observations.
The Tech Team does not agree with BRPP's belief this oenelrtsdeu or rationale for the following reasons.
First,with one exception,the periods of CRP shutdown are only a day or so each',which is insufficient
time for the W WTP to stabilize with the change in raw effluent characteristics. Second,the times of
shutdown and startup of the CRP do not correspond with the effluent sampling times in the mill system,
so that there is no direct correlation in time with the effluent sample.Further,the fact that all CRP"off
days are in pairs,suggests that CRP was down for a period that spanned parts of two mill sampling days.
The simple mathematical average of treated effluent color discharge during"CRP off'days for August to
December 2006 is 39,995`lbs/day. The average when the CRP process was operating is 36,958 Ibs/day.
This suggests that CRP purge stream causes a reduction in effluent color,which defies common sense.
Also,the difference in effluent color between the"CRP on"and"CRP off'days is 7%,while day to day
variations in color discharge values are frequently over 20%,tending to subsume and confound any
analysis of the impact of changes in the CRP purge stream. The resultant statistical color performance
data from this period likely varied just due to the normal variation in day to day color performance.
In short,because there are so few consecutive days without a CRP purge,the data from the period August
to December 2006 are not sufficient for establishing the extent to which the CRP purge contributes to
final effluent color. In order to explore this further,BRPP should conduct additional evaluation of die
effect ol'CRP purge on final effluent color levels.These evaluations could include a trials
to determine the impact of CRP on effluent color in-which-the-CRI'-par-ge+s exshtded-feorn-t}}e
WaSt %tmvF tFea�4ruent-plant f;31 lethree ,i- TI,' L., .,6:....�.i :,t... 1�......,i;..a
a. ,a
T°i'3��'rP�"�T'aP5-a'69mbM3atF9e ,£I•rm-vcth—The. iPsti to shut flie cnn r-ge { ' least three
mad ..ice„ ..+ ihll o o. _ _ - -1 published

Memorandum
May 10,2007
Page 12
by-C=hampion An the BFdST^ sSss shewect th"Rr,;;e expanse e£the ch4eri�o and o6as.to rsentent in
the tHill s�v'"nlique toAperatinnof flee EP{'��a s o requ r'^b Ar-tnAr to chew
siglritisant-shangc�-�fktis-;SR,,;^���nE-witl+-e?Ypsrienec:ta-ethc3r-nz}Ils,-a+ta :�tAi:�:-faet-that-the
n,.,..tit,. ,,f ehl@FideS and Potassiu.. feFA0Ve 1 M.CR D :. ..,.. ll ..,I.at',.,. the 1141R.,blaei,
green an•1...ii����`:.e I k�HA(31= t%in. Teal preachouidoi'ae—tEi-it'<�i r-`��x��ii!`DD .. ..�.. am.eiihe..'^
thee sp r^ I� m, e:er-aff site €amp aR' i st h: rethol€s5—B1CPP-tni4 taf-f assert-that
utdAwn feF saAh a-peElAd^f mould nOt beep^ n ,$1>1 , ' �A-specs l n.e�F
rtaSHi}St�}IS w�HlE1 bC t�3ti£a lS
Follow the evaluation,Tihe impact of excluding the CRP purge from the....,....,..ateF tpeat em-pla^R
stream could be related to final would-Fie-observ€d4y-retain analys effluent color. If the effluent
color without the CRP purge is unchanged,BRPP could conclude that the CRP purge contributes little to
the final effluent color. In this case,further research into reducing CRP color would be a low priority.
On the other hand,if the effluent color without the CRP purge decreased,BRPP could conclude that the
CRP purge contributes to the final effluent color and further research into reducing CRP color should be
undertaken.
BRPP could investigate approaches to prevent color from accumulating in the CRP. The source of the
color in the CRP purge stream is carryover of black liquor particles in the direct contact evaporators
(DCE)in the recovery boiler systems. This carry over could be eliminated if the two traditionally
designed recovery boilers(which are 34 and 42 years old)were replaced by one modern boiler. This
would probably represent a capital cost of over$100 million,and would very substantially reduce the
energy costs at the mill;since today's recovery boilers are much more efficient than the DCE/recovery
boiler systems of the vintage installed at Canton. Analysis of all the economics and long term life of the
mill would be necessary to evaluate such a major investment.
On a more modest level,it may be feasible to reduce black liquor carry over by adjusting operating
conditions in the existing DCE's. The Tech Team is not aware of any experience with this in other mills,
or research, but the situation at Canton strongly suggests that at leasi some investigation and trials of
modifications to the operations is warranted. Any of the measures discussed previously in this document'
to reduce C102 use could reduce the quantity of chloride to be removed in the CRP purge stream. If this
is reduced,the color discharge of the CRP also would be reduced.
BRPP could also further investigate C1O2 treatment and other treatment of the CRP color and other
approaches for excluding the CRP purge from the mill discharge.
Additional Color Reduction Strategies
The Tech Team has identified the following color reduction activities that should be for improving the
color removed by the Canton Mill wastewater treatment plant:
1) Investigate in further depth color formation when acid wastewater is mixed with mill
wastewater in the current configuration,and identify techniques to reduce this effect;
2) Further investigate adding,polymer and/or other treatment chemicals upstream of the
secondary clarifiers; and
3) Maintain addition of polymer and/or other treatment chemicals to the high-color
wastewater diverted to the extra primary clarifier,and investigate adding additional
equalization/treatment tankage.

Memorandum
May 10,2007
Page 13
These strategies are discussed below.

Memorandum
May 10,2007
Page 14
Color Formation When Acid Wastewater Is Mixed With Mill Wastewater
BRPP provided the Tech Team with daily color data for the"Low Lift"(mill sewer),acid sewer,and
primary effluent sampled after the acid sewer is added in the discharge channel of the primary clarifier
leading to secondary activated sludge biological treatment sysiem. Figure I (below)presents the total
mill color calculated by adding the mill sewer lb/day to the acid sewer lb/day(the lower(blue line)on the
figure). For comparison,the primary effluent sampled after the acid sewer is added is also shown on the
figure(the upper(red line)on the figure).Thus,the figure depicts the impact of mixing the acid sewer
with the rest of the mill effluent".
150,000
Total untreated color,before and after mixing,2006 (lbsiday)
125,000
100,000
75,000 M1
t YY t
50,000 ^ 1 I
25,000 —
1J2n 31Jan LMar 31�r 304pr 304ay 29Jun 294ul 28-Aug 275ap 27-0ct 2"w 2643ec
Figure 1: Impact of Mixing Acid Server and Mill
The Tech Team observed:
• The quantity of color formed on mixing the acid sewer and mill sewer is striking. On
average,the quantity of color formed is 78%of the total color in the two streams. In
other words,the simple mixing of these streams forms nearly half the total color
discharge from the mill.
• The variation in quantity of color formed by mixing the effluent streams from day-to-day
is dramatic,as is evident in the graphs. When expressed as a percentage of primary input
color,the value ranges from essentially zero on some days to a maximum of 480%.
• There is no obvious correlation between the values on any one day,or series of days
close to one another.
Notwithstanding these observations,the Tech Team understands and appreciates BRPP's efforts during
the last permit term to reduce color formation through the acid sewer relocation project. The Tech Team
suggests that BRPP build on this project to better understand the mechanisms of and the follow-up
strategies for reducing color formation in the current sewer configuration. BRPP could investigate,
among other things,how sulfides introduced by leaks,spills,and unplanned discharges from white and
green liquor systems into the mill wastewater contribute to effluent color. In particular,BRPP could
3 The color of the mill sewer wastewater may be reduced somewhat by treatment in the primary clarifier. This color reduction is
neglected in the calculated untreated color,so Figure I is probably a slight underestimate of the impact of mixing the acid sewer
with the rest of the mill effluent.

c
Memorandum
May 10,2007
Page 15
investigate whether sulfides in the mill wastewater contribute to color formation when acid sewer is
added to mill effluent prior to biological treatment. Approaches to this investigation should include:
• Laboratory experiments on effluent with varying degrees of sodium sulfide addition; and
• Daily measurement of the sulfide content of the effluent from the primary clarifier
influent at the low lift pump sampling station for a period of at last three months to
determine correlation of sulfide concentration with color formation.
In most mills, losses of sulfides can be reduced. Well known sources include imbalance in the weak wash
system,as well as spills of white,black,and green liquor. BRPP should further investigate losses from
the green and white liquor systems and technologies that can reduce these losses.
Improving W WTP Performance Using Polymers
Several bleached kraft mills around the world have successfully reduced color to well below 5 lb/ton pulp
by installing tertiary treatment systems. These systems use polymers and other chemicals to precipitate
color bodies,then remove the precipitate in tertiary clarifiers. One of the newest of these mills is Celco in
Valdivia,Chile. This mill has excellent in-plant effluent control,a conventional secondary wastewater
treatment plant, followed by a small tertiary system. [This comparison isn't useful or appropriate.]
x = v •
liigurt�—�";�,aFisan tit=IIT2I'-P-�axknrA-fi16-L�4fluent-EFebrttar��2007}-and-V-ald+vin-tlLN1-U+-ftktent
[This whole section should be removed or signrHcautiy edited.]
Treatment systems like the one operated at Valdivia have a capital cost in the tens of millions of dollars,
and ein create issues with solid waste disposal. BR4 Rasec#tit min nay"�iseon}parisetl
was-not-appropriate.. However, some more modest control measures using variations of this technology
also exist. Forexample,since March 2004,Glatfelter Inc.,Spring Grove,PA has supplemented its in-
plant color control strategies by using a commercially available polyaluminum chloride polymer to
enhance color removal in the wastewater treatment plant. The polymer is added in the discharge flume
from the aeration basin,just upstream of the mixing box feeding the four secondary clarifiers. The
polymer reduces pH and complexes with organic compounds that produce color. Colored material settles
out with the secondary sludge which is held in the former stabilization basin before dewatering.

Memorandum
May 10,2007
Page 16
Glatfelter have not reported sludge dewatering problems.Polymer used for additional color removal
reportedly costs on the order of$2,000 to$3,000/day. It is noted that neither of these mills have installed
the pollution prevention BFR system such as has been done at BRPP.
BRPP could conduct further laboratory trials of commercially available polymers and other wastewater
treatment chemicals in addition to those already evaluated,adding them upstream of the secondary
clarifiers. During these trials BRPP would determine the potential for reducing color discharge and
estimate the costs. Such analysis would consider seasonal use of the additive chemicals(i.e.,adding the
chemicals during periods when river flow is low and the mill discharge has the greatest impact on the
river color). The Tech Team acknowledges BRPP concern regarding issues that may occur,such as
possible effluent toxicity,difficulty in sludge dewatering,and cost.
If the laboratory trials are successful,BRPP could institute a full-scale trial for one month,and report
results to the TRW.
Pretreatment of Diverted High-Color Wastewater
BRPP currently diverts up to one hour of total mill flow to their off-line 1-million-gallon clarifier,during
high color releases. The purpose of this flow diversion is to equalize color contributions to the
wastewater treatment plant. Diverted high color wastewater is batch treated by polyamine and returned to
the wastewater treatment system. The Tech Team believes that BRPP should further investigate options
for providing additional tankage that would be important in increasing the equalization and treatment
capacity beyond that which currently exists;now limited to about one hour of wastewater volume at
current flow rates. This would probably be an important contribution to both further reducing color
variability,an increasingly higher priority endeavor as long term averages are reduced,and to removing
color before being introduced into the secondary activated sludge biological treatment system.
Summary: Additional Identified Color Reduction Activities that BRPP can Pursue in the Next Five
Years
Mill process changes that reduce wastewater color are generally preferred to end-of-pipe treatment
because they may have lower capital costs and may benefit the mill by reducing operating costs:;
however,some mills have chosen to use end-of-}pipe technologies to achieve color reductions. It is noted
than throughout this color reduction process the Mill has continued to evaluate other color reduction
technologies. including end-of-pipe. These technologies have never been demonstrated to be
operationally,technically or economically feasible.1l mills in envii-Emmemal regula•e13'
',6 .nr,etiensat:-their color discharges have bee Od t implement-end of
pipe ,a,.-removal « olegies sinee the 197 Nonetheless,Aalthough the Tech Team continues to
maintain the highest priority for in-mill improvements such as process changes and optimization and
increased black liquor recovery,external color removal technologies should also Fise to a higher priority
n continue to be considered carefully in the mix of options for further controlling the
color of BRPP's discharges. These color removal technologies include both end-,of-pipe wastewater
treatment and treatment of segregated wastestreams(i.e.,the CRP purge).
The Tech Team identified strategies,focused primarily on in-mill process improvements,which that
BRPP can use to further reduce its effluent color discharges. These strategies are summarized below.
1) On the pine bleaching line,conduct full scale trials with imps iiw •" —ef peroxide
fortification of the Eo stage and decreased the target kappa factor as recommended in
BEPER 2001 and by Liebergott/GL&V 2006 to determine the impact to effluent color.
Also.£evaluate the use of high temperature for the peroxide-fortified extraction stage.

Memorandum
May 10,2007
Page 17
2) On the hardwood bleaching line, conduct full scale trials with it»p1ntH ttt�use of
oxygen and peroxide fortification of the E stage and decreased the target kappa factor as
recommended in BEPER 2001 and 2006. Also,k evaluate the use of high temperature for
the peroxide-fortified extraction stage.
3) Continue to improve the control of leaks,spills,and intentional diversions of black liquor
and other highly-colored wastewater:
— Move forward with the planned CRP sump and containment project to eliminate
unplanned releases of this highly-colored material to the mill sewer.
— Further substantially reduce and ultimately eliminate discharges of highly-
colored wastewaters directly to the wastewater treatment system. These
wastewaters are generated during planned mill outages or diverted to the off-line
clarifier during mill upsets.Increase interconnected tankage available to both
fiber lines in order to maximize recovery of these wastewaters and treat the
wastewaters that cannot be recovered to reduce color prior to metering them to
the treatment system.Regular training and advanced realtime coordination
among mill staff(identifying and correcting problems, failed equipment/parts)is
critical to the success of these efforts and is ever more important in reducing day-
to-day variability which is becoming more apparent as long term averages are
decreased.
a F "a`
re}iable in€or atforrenihe prrodd=stio;rrt8 Taal eEl ee le Generate#breve d by
Fhc cstt}u� -eer»bimE1-at-thc3u3ifl—
5) ]rista&an Evaluate an additional oxygen delignification(OD)stage for the pine
pulping/bleaching line by conducting laborator; studies and engineering analysis to
evaluate the color reduction benefit and cost of 2-stage OD on pine.
both-}13 t r w a n E}
petentialle reduce-tlte purge rate from tk e-GF�P nes siretiftsattt-}sorEion of4he
fatal ccil�-a:- <rfroean--•�"e-R.i'„=�rese�s<;s:
7) Continue to evaluate the impact of the CRP purge on treated effluent color to determine if
the CRP color,now a significant portion of the total color discharged from the mill
processes, is completely removed in the secondary treatment system. If CRP color is not
removed in the treatment plant,investigate approaches to prevent color from
accumulating in the CRP,such as reducing black liquor carry over by adjusting operating
conditions in the direct contact evaporators.Also, if CRP color is not removed in the
treatment plant,further investigate C102 treatment of the CRP purge to reduce its color
prior to the mill wastewater treatment system. Such an effort may take special efforts to
accomplish.
8) Continue to investigate and implement strategies for improving color removed by the
Canton Mill wastewater treatment plant:

Memorandum
May 10,2007
Page 18
Further analyze color formation when acid wastewater is mixed with mill
wastewater in the current configuration,and identify other techniques,such as
minimizing sulfide releases to the mill sewer from white and green liquor leaks,
spills, and/or diversions,to reduce this effect;
— Further analyze addition of polymer(s)and other treatment chemicals upstream
of the secondary clarifiers;and
— Maintain or further increase the hydraulic capacity for capturing and treating
highly-colored wastewaters prior to introducing them to the wastewater treatment
system,including the further optimization of adding polymer and other treatment
chemicals to the highly-colored wastewater diverted to the extra primary clarifier
and/or any additional facilities that may be provided.

Memorandum
May 10,2007
Page 19
Effluent Color Variability
Since installing the BFR process and other improvements(BMPs, etc.),BRPP is to be commended for the
continuing and important progress in reducing their annual average color discharges. However,the Tech
Team believes there are additional areas where further color reduction strategies can contribute to reduced
effluent variability.klewev aft>er y °v th o^ 'c a�aso ^..,._,�. e9jit:n n e to e-;;:pe::ensed and
then d'scharges are be-otttirig t err deiA-as-Nze-anmhik% err. dissliarga-is-reduced—NV4w.4bese
disoha, �^ th per eds e€lewr#Io P rthe{a s a e�}tleatrsc a+x let atien
in rivef color that is ii4eeabW to the aitigOVS Who UW the FiVeF. Thus, FedtiOti011 Of the impacts of the
P .
discharge' �a ';^., Of Nral4abillIVITlea ur­d l y the daily� T x;an�.;ar-diseharae�The
Tech Team identified several strategies for reducing merit color variability dischaigesand4heir
intpa w. These strategies are listed below:
• Segregate and reuse highly colored waste streams during normal operations and pretreat
the remaining acid sewer flow to minimize and reduce the variability of the generation of
"sewer generated color,"now occurring in the secondary activated sludge biological
treatment system;
• Continue and improve treating highly colored non-reusable wastewater diverted to the
off-line primary clarifier,including increasing the wastewater volume which can be
treated;
• Segregate highly-colored wastewaters released during planned and unplanned diversions
/mill outages and recover/reuse those for which it is feasible and treat the remaining
wastewaters prior to metering into the mill wastewater treatment system;
• Increase the tank volume available for equalizing highly-colored wastewater prior to
pretreatment and introduction into the wastewater treatment system;
• Further investigate treating total mill biological system effluent prior to discharge using
polymers or other wastewater treatment chemicals, particularly during periods of high
influent color and/or low river flow;
• If the CRP purge color is found not to be removed in secondary treatment,avoid
releasing the CRP purge during periods of low stream flow(or truck it off site);and
• Curtail pulp production during periods of low stream flow; this should continue to be
considered an option of last resort,given that best performance has been noted by the mill
to be during extended periods of steady production and greater risk of elevated color
during process shutdown and startup. See Low Flow Contingency Plan,December 1,
1998.

Memorandum
May 10,2007
Page 20
Suggested Final Effluent Color Limits for Blue Ridge Pulp and Paper
Substantial and commendable progress has been made to date by BRPP through expenditures for
additional and improved process and related technologies,treatment technologies,and management
practices which have reduced the long term average color discharges. Some of these technologies and
practices have been in addition to those identified in the previous Tech Team/TRW reviews. This
prop zSs-:�it theannual average of eeleF dice arges has ..ade-ittcreasin gly important andapparelx
the impertaneo-ef-r dueitt�a Paa tfllaer.� �01 s;eug--ti�=ith the�t#te+r sotrmaendatiens a the
Teoh Team going t;Bi-A-afd f+gm this eFitical point in tifne. ThffefiBFO,the Teelt Team F@Painmends to the
TRW that the NoFth Catalina DepaAffient of Environment and Natural Resources expand the existin
- annual average an
Piggeon River. Daily Friaximani an
��tr[[>��h/(irr�num 30 daay a - gee-p otrld-cnh tncstbc-,or , t€+ie-r-eIday-te�lar+n-strt�tm-++ator
The T eh Team Fitse 1..,1:.,yes 4hat thps..`e effluent limitations shouid be applied
t a the ..-m�rt¢-wipe dis f the mill to the rive T�it2G
would-sitaplifv-and-fay,.,iate compliance-Rmn:tou;ient pe::r..tr.r. s..ea an.,.o.i..gPee,>z,
Go}}ditiewA-4)- wvi4cs41) olop-{w4hau�4�t-ihu twd of pipe—anE}dowttsGr tm-o dhc
6
is ineiuded and dependent upon Pigeon Rivef flow. This reconifnefidation was ineluded in Ae T-R VV�
2001 \,,enio_..nd m, at it.,m nA o• The Tech Team's recommended range of end-of pipe permit effluent
limits and the derivation of these limits are presented in Table 5,and discussed below.
Table 5. Tech Team Recommended Range of Effluent End-of-Pipe Color Permit Limits
- Limit Range.of Recommended Limits Ob/day).
Annual Average 32,000 to 37,000
30-day Average 44,800 to 51,800
Daily NIati1 1- oa o and.ns n Inns n 1
Basis for Recommended Annual Average
BRPP provided daily measurements secondary effluent color(lb/day)for every day in 2006.
Examination of the daily measurements for 2006 identified two days(July 7 and 8)with measured
discharge greater than 100,000 lb/day. BRPP reported that this elevated color discharge resulted from
"CRP slurry tank overflow for-20 min,first time the mill experienced this type of event." Because
these discharges were so high and from a unique source,they were omitted from the calculation of the
annual average.
Annual average for 2006,without July 6 and July 7:
36,695 lb/day,rounds to 37,000 lb/day
• This annual average load is less than the 39,000 lb/day suggested by BRPP. However,it
is based on the mill's 2006 performance and does not include any reductions that may be
achieved by the process changes outlined in this memorandum. As a result of analysis of
the BRPP mill discharges by the Tech Team and others in support of the 2001 permit,the
permit's interim color goal was 32,000 lb/day with a range up to 39,000 lb/day.
• As described earlier in this memorandum,the Tech Team recommends that BRPP
implement several key process improvements and investigate others in order to reduce

Memorandum
May 10,2007
Page 21
the annual average color performance toward the overall permit interim goal of 32,000-
37,000lb/day. Tee1a=1 xneerdsb ea^; air "ua Freu}t4ur�0a1
pear+it-as4hc gear-f�tis-pc 4o4
Basis for Suggested Daily-Alatxinwm mid 30-Day Average Limits
The statistical analysis used for the development of EPA's Cluster Rules is documented in Statistical
Support Document for the Pulp and Paper Industry: Subpart B(EPA, 1997).This document describes
EPA's development of,among other things,the variability factors that were used to calculate NSPS for
BOD5 for the Bleached Papergrade Kraft and Soda(BPK)subcategory. These variability factors are
reproduced in Table 6.
Table 6. Bleached Papergrade Paper grade Kraft NSPS Variability Factors
Variability Factors.
Analyte - i-Dxe 30-Day. ..
BOD, 2,42- 1.4
Source: U.S.EPA 1997. Table 2-4.
The BOD5 variability factors shown above were developed using daily monitoring data for the best
performing(in terms of production normalized BOD5 load)BPK mills. The monitoring data represent the
effluent from well-operated wastewater treatment systems. The calculated variability factors account for
the autocorrelation of the daily loads and the log-normal distribution of the measurements.
', «The Tech Team believes that it is reasonable and
appropriate to use the variability factors developed for the BPK NSPS for BOD5 to calculate BRPP daily
maximuin-arid 30-day average permit limits for color,beeaus'ei
® •ram, ^-^""e developed using FA0114OFin-g '"a kom nnv mills .,:a, , .all operated
seefln€tm-y-traattrrerx-arid-B2PIrT ., nns„z, ',�.nill�riih-Snell-c�per�,t�•`d-�e�r�l�rr-t-ttc�atan
is-ma'nm"cb'Frar!he-oxixaent-ez-mv—.^``a'cvnc�rcavi f�rzvr'�"sz"�a
r- like onn,-_+s-iemoved fi-orn effluen� t.aria aofaa�'�a;,nao n'na
' absorptier,r'.�serp'�":.-`.�.-bicrrnass:
Applying the BOD5 variability factors to the 2006 recommended annual average daily color discharge
results in the following daily maiiiinum and 30-day average limits:
Aa:lry M 37�00E lbldayy�i 2.62='nr n—R 0 lb'da,.
30-Day Average: 37,000 lb/day x 1.40=51,8001b/day
(- ;t�rtr:i +n day averago limit, r the io .;, o �..a : nnn a 1
'r.CZ;..:- lie sari=11?anHif�)
C<xrrr tatir l " BF efkluent+n.,,; ^ :^ atat tllesc I: Ttl attwo- 4a epee <lett-tlxtai4y
�I,^ n�, b
axa>iirrrurrr-
duly 9 ioi.Qe ib

Memorandum
May 10,2007
Page 22
Further-, the '-o a is 1.800 Iti'a^a eded�e rehi{nat�{y e'tgM 330 day
daY-avgRg�oo--.�*'Ra.y-v.`as-e�ce raP13 ��.; averaging
{�BrieC�c:Tk��'i(jdS-arc. l:^•—�.,�"-•ern%1316 7:
TaMe-- Suggested 30 day AveFage-��
Redioei-F.aiW 3(Htny-averiwe{tktitlay)
ltpri!-� 34;SG6
ltdi� 6�3
du" "i-X34
+'Uu9ese9 6&,664
".Boast= -0;6§8
f�a}gu5t-Fi 3?yA�}
SeNelnFler-}N 521)8t
Nnveelbe 26 s',334
Co mrmr°-,poi to Gl tie te".-z'-E::m:.t--T�*its
dischargesTile GlaffelteF. !Be, mill in Spfing Gfeve, PA(IsIOR98 permil number RA0008969). like4NU41,49-an
Report(C. r .. 2007) during time summer.the Gla#blteF mill : ...:et.,.l�„ A:�,.6......., 1 40 .m,—! cale�
- a a'.-rnsrti�m-i-hrn-fSE"'" r c.
ftaverar tiux;*M nd3S0 "' ail is*irrat{;m` ,,�t.� ,teTo+sehaeg3-lira its are mf�r6 stri�gen. The
o'dailydiGGhaFgOd it t.
papef per Elay. BRPP produces appi-eximately 16,10 619 tons peF day,with a gveatei-propef4ion
softmood to hardwood processed than at the Glat fi ls_,_...:1 l
approximately 26 M}6D " her,e..., on a 1,.^,.:.. the=r•eeh Tea ^..fie
reso monde-d-range-oteHcl-of-{�i�< t + liniitste,'�°mom ! SBll- S48-41�1t1ay-tnE>tt}r}} av€rage
.eFmit-limits

Memorandum
May 10,2007
Page 23
References
Andritz Ahlstrom Sales. 2001. Pruyn's Island Technical Center Report 2001-068 Part 1. Laboratory and
Lo-Solids Cooking with O-Do-Eop-D Bleaching Sequences on Softwood Furnish from Blue Ridge Paper,
Blue Ridge,NC. Part 1 Softwood Results. Part 2. Hardwood Results. (December 6).
Audet,Andre,Michel Faubert,Zhi-Hua Jiang and Barbara van Lierop,PAPRICAN. 2003. Technical
Service Contract Report TSC-7447. Bleaching Evaluation for Effluent Colour Reduction. Prepared for
Blue Ridge Paper Products,Inc.,Canton,NC. October.
Blue Ridge Paper Products,Inc. 2005. Chloride Removal Process(CRP) Color Reduction Technology
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Blue Ridge Paper Products, Inc. 2006a. Color Compliance Report: Canton Mill. (May).
Blue Ridge Paper Products,Inc. 2006b. Blue Ridge Paper response to questions from the Technology
Review Workgroup(TRW)that were e-mailed on 28 Nov 2006.(December 19).
Blue Ridge Paper Products,Inc.2007a.Response to additional questions for BRPP about data provided
to TRW Don Anderson e-mail dated 5 March 2007(March 15)
Blue Ridge Paper Products,Inc. 2007b. March 19, 2007 Additional Data Required from BRPP(March
28).
Bodien, Danforth G. 2007. Site Visit Report, Blue Ridge Paper Products, Canton,North Carolina.
(April 2007)
EPA Tech Team. 2001. Memorandum to Technology Review Workgroup. "Additional Color Removal
Technologies and Their Economic Impacts on Blue Ridge Paper Products,Canton,NC."(July 25,2001).
Furjanic, Sean M. 2007. Water Quality Protection Report,P. H.Glatfelter Company,Spring Grove
Borough and Jackson Township,York County, for the Renewal of NPDES Permit No.PA 0008869.
PADEP Southcentral Regional Office(draft,February 2007).
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Evaluation and Report. Prepared for Blue Ridge Paper Products,Inc. and Clean Water Fund of North
Carolina. (June 8)
GL&V Pulp Group,Inc.,Liebergott&Associates Consulting. 2006. 2006 Update: Bleach
Environmental Process Evaluation and Report. Version containing manufacturer's proprietary
information. Prepared for Blue Ridge Paper Products,Inc. (July 7,2006)
Munro, Fred and John Griffiths. 2000. Operating Experience with an Ozone-based ECF Bleaching
Sequence,Proc.International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press.
Technology Review Workgroup,2001.Memorandum to North Carolina Division of Water Quality
and the NC Environmental Management Commission's NPDES Sub-Committee. "Additional
Color Removal Opportunities, Blue Ridge Paper's(BRP) Canton,NC Bleached Kraft Paper
Mill, 2001 NPDES Permit Renewal." (August 3, 2001).
U.S. EPA, 1997. Statistical Support Document for the Pulp and Paper Indusny: Subpart B. (November)

Re:Fw:progress on Tech Team report,TRW comments?
Subject: Re: Fw: progress on Tech Team report , TRW comments?
From: [e-mail]
Date: Thu, 24 May 2007 14:26:12 -0400
To: Sergei Chemikov<[e-mail]>
CC: Roger Edwards<[e-mail]>, Susan Wilson<[e-mail]>,
[e-mail], [e-mail], [e-mail],
[e-mail]
Sergei -
Thanks for your input and very important concern. As noted in another
message we are now separately engaged with BRPP in a careful review of
the facts contained in our draft final report from the Tech Team to the
TRW. The process we are following for our charge is the same as we used
in 2001 wherein we consulted carefully with BRPP before releasing our
Tech Team lfinalreport to the TRW. Please remember that this report is
the product of only the Tech Team, not the larger TRW. We are being
relied upon by all stakeholders as an independent resource of technical
expertise and thus our product must remain so. Thus, we take our
responsibilities very seriously to ensure the highest possible degree of
objectivity and care for the information and data we gather, review, and
present to the TRW. Should our representations of technical fact be
colored with opinions of one side or another among the stakeholders, we
would no longer be an independent resource. The Tech Team report of
2001 was released to the environmentalists approximately currently with
preparation of the TRW memorandum to NC DWQ. The environmentalists were
involved earlier than and separately from the Tech Team with BRPP in
2001 in a cooperative process (BEPER, Liebergott, et al, 2001) . While
that BEPER report was prepared separately from the Tech Team, we did
have access to it and it was a critical component of the information and
data resources we used for preparing our report to the TRW. Thus, all
stakeholders and the Tech Team had concurrent access to much of the same.
raw information. However, the process with the environmentalists is not
the same this time. Nonetheless, the point at which your rightful
concerns become ripe is in the preparation by the TRW members of the
memorandum from the TRW to you folks in the NC DWQ. We do expect the
TRW memorandum to NC DWQ will again be drafted and reviewed by the TRW
members before it is released in final form to NC DWQ (and other
stakeholders) for use in preparing the next draft of the BRPP permit.°
Regarding your continuing concerns for further delay in this process,
the 2001 Tech Team final report was released to the TRW on Jul 25, 2001,
and the final memorandum from the TRW to NC DWQ, with review and input
from all TRW members, was dated August 8, 2001. I hope all of this
helps, thanks for your message, and I will continue to keep you apprised
of our progress,
Don
Sergei
Chernikov
<sergei.chernik To
[e-mail]> DonaldF Anderson/DC/USEPA/US@EPA
CC
05/24/2007 Susan Wilson
09:33 <[e-mail]>, Roger
Edwards <Roger.Edwards@ncmail..net>
Subject
Re: Fw: progress on Tech Team
report , TRW comments?
1 of 5 5/24/2007 3:00 PM

Re:Fw:progress on Tech Team report,TRW comments?
I
Hope -
I must offer my sincere apology for this reply being so late in coming
to you. However, we have been working diligently toward completing our
Draft Final Report from the Tech Team to the members of the TRW (TN,
NC,
EPA Reg 4) . First, as we did last time (2001) , I have just sent the
Draft Final report to BRPP for factual review. Upon receiving input
>from BRPP on our presentation of the facts, hopefully by the week of
June 4 (already booked calendars of key BRPP staff) , we will complete
our final report and release it to the TRW. At that point in our
informal process it is my intention that We also will make it available
to you folks. I cannot speak for BRPP but I would expect that since
you
folks received production information during the earlier permit cycle,
it seems reasonable to me that you should again expect such data during
this cycle. With any comments we receive from the TRW members, we will
go through a hopefully short process to prepare the memorandum from the
TRW to the NC DWQ for use in preparing a new draft of the next permit.
>From there forward we do not expect to actively participate in the
formal part of the process. If there is any change in this process, I
will let you know. Thanks again for your patience,
Don
Donald F. Anderson
Senior Environmental Engineer
Engineering and Analysis Division (4303T)
Environmental Protection Agency '
For regular mail, balance of address is:
EPA West - Connecting Wing; Rm 6233V
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Email: [e-mail]
Ph: (202) 566-1021
FAX: (202) 566-1053
Express / Hand Delivery, balance of address is:
1301 Constitution Avenue, NW
Washington, DC 20004
'Hope
3 of 5 5/24/2007 3:00 PM

about:blank
I have concerns about Don Anderson-EPA latest e-mail to Sergei. Sergei has made it clear regarding
the release of information of the TRW prior to a final report document being generated is
unacceptable. The TRW must review, edit and make correcting to any report generated prior to any
information release. The release of information from the tech team to stakeholder is inappropriate.
As I understand, there are no stakeholders involved at the TRW level for report review.
Stakeholders/public are involved during the public notice of the permit renewal. As we all know, the
issuing agency,weather it be NC or EPA must public notice the permit renewal. I do not understand
way Mr. Anderson feels the need to pull in stakeholder at this time. I have my opinions but this
process must not take those into consideration. What is important is process follow the correct
procedure for the purpose of the TRW. The process not be manipulated making the permitting
process more difficult than necessary for permit issuing agency and to move the process in a timely
manner. Mr. Anderson is jaet doing this and must be confronted and reminder that EPA are members
of the TRW to prepare a report and nothing else. The permit is to be issued by NC-DWQ, unless
EPA wants to issue the permit. DWQ and EPA should be partners in the protection of the
environment and his actions are not in any way fostering that relationship. This permit may be a
small issue for EPA but is a very large issue for NC and must not be manipulated by EPA. If Mr.
Anderson's report is written in the same manner as the recent e-mail's who knows how long before we
get to permit issuance.
Respectfully,
R. Edwards
Roger Edwards - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
I of 1 5/25/2007 9:27 AM

Re:Fw:progress on Tech Team report,TRW comments?
Don,
Thank you for forwarding this e-mail to me. We don't have any objections
against releasing any FINAL reports to the public. However, we would
like to have a chance to review your report and comment on it before it
is finalized and released. We would strongly object to the release of
your report before it has been reviewed by TRW members. The report might
contain factual errors or interpretations that are outside of Tech Team
jurisdiction. Therefore, it should be reviewed and approved by TRW
members before being released to the public.
Sergei
[e-mail] wrote:
FYI
----- Forwarded by DonaldF Anderson/DC/USEPA/US on 05/23/2007 10:31
DonaldF
Anderson/DC/USEP
A/US To
"Hope Taylor-Guevara"
05/23/2007 10:29 <[e-mail]>
cc
Subject
Re: progress on Tech Team report
TRW comments?(Document link:
DonaldF Anderson)
I
2 of 5 5/24/2007 3:00 PM

Re:Fw:progress on Tech Team report,TRW comments?
Taylor-Guevara"
I <htaylor@gloryro To
ad.net> Don aldF Anderson/DC/USEPA/US@EPA
cc
05/03/2007 14:40
Subject
progress on Tech Team report
TRW comments?
Dear Mr. Anderson:
I'm just checking on progress on the Tech Team's report and
TRW review, hoping that we'll be able to get a copy of it soon, and
also
trying to project the timing for the public process.
Since the Tech Team' s visit, we've received several
documents from DWQ, .including Dr. Leibergott' s more recent report for
Blue -Ridge, the UT fish study, etc, and are reviewing them carefully.
One point of interest is that Dr. Leibergott indicates that BRPP
achieved about a 30% reduction in color/ton for hardwood and softwood
lines, but pretty closely agrees with our analysis that the overall
discharged color decreased less than 10% during the permit period. He
states that he expects only "marginal" further improvements, which
seems
like preparation to resist further required reductions, but it seems to
us possible that this apparent discrepancy in color reductions could be
explained by a coincident increase in production. Will we have access
to I
, production information in this permit cycle, as we did for the previous
one?
Best wishes, hope you are doing well, and we look forward
to
4 of 5 5/24/2007 3:00 PM

Re:Fw:progress on Tech Team report,TRW comments?
hearing from you,
Hope Taylor-Guevara
Clean Water for North Carolina
2009 Chapel Hill Rd.
Durham, NC 27707
919-401-9600
www.cwfnc.org
Sergei Chernikov, Ph.D.
Environmental Engineer
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
phone: [phone] ext. 594
fax: [phone]
5 of 5 5/24/2007 3:00 PM

Vo n Tech Team report,TRW comments?
Subject:Fw: progress on Tech Team report,TRW comments?
From: [e-mail]
Date: Wed, 23 May 2007 10:34:52 -0400
To: [e-mail],[e-mail],[e-mail],
[e-mail],[e-mail], [e-mail],
[e-mail],[e-mail], [e-mail]
FYI
----- Forwarded by DonaldF Anderson/DC/USEPA/US on 05/23/2007 10:3
DonaldF
Anderson/DC/USEP To
A/U3
"Hope Taylor-Guevara"
05/23/2007 10:29 <[e-mail]>
cc
Subject
Re: progress on Tech Team report
, TRW comments?(Document link:
DonaldF Anderson)
Hope -
I must offer my sincere apology for this reply being so late in coming
to you. However, we have been working diligently toward completing our
Draft Final Report from the Tech Team to the members of the TRW (TN, NC,
EPA Reg 4) . First, as we did last time (2001) , I have just sent the
Draft Final report to BRPP for factual review. Upon receiving input
from BRPP on our presentation of the facts, hopefully by the week of
June 4 (already booked calendars of key BRPP staff) , we will complete
our final report and release it to the TRW. At that point in our
informal process it is my intention that we also will make it available
to you folks. I cannot speak for BRPP but I would expect that since you
folks received production information during the earlier permit cycle,
it seems reasonable to me that you should again expect such data during
this cycle. With any comments we receive-from the TRW members, we will
go through a hopefully short process, to prepare the memorandum from the
TRW to the NC DWQ for use in preparing a new draft of the next permit:
From there forward we do not expect to actively participate in the
formal part of the process. If there is any change in this process, I
will let you know. Thanks again for your patience,
Don
Donald F. Anderson
Senior Environmental Engineer
Engineering and Analysis Division (4303T)
Environmental Protection Agency
For regular mail, balance of address is:
EPA West - Connecting Wing; Rm 6233V
1200 Pennsylvania Avenue, NW ,
5/24/2007 10:59 A
_rl

V
nTech Team report,TRW comments?
hington, DC 20460
il: [e-mail]
Ph: (202) 566-1021
FAX: (202) 566-1053
Express / Hand Delivery, balance of address is:
1301 Constitution Avenue, NW
Washington, DC 20004
"Hope
Taylor-Guevara"
<htaylor@gloryro To
ad.net> DonaldF Anderson/DC/USEPA/US@EPA
cc
05/03/2007 14:40
Subject
progress on Tech Team report ,
TRW comments?
Dear Mr. Anderson:
I'm just checking on progress on the Tech Team's report and
TRW review, hoping that we'll be able to get a copy of it soon, and also .
trying to project the timing for the public process.
Since the Tech Team's visit, we've received several
documents from DWQ, including Dr. Leibergott's more recent report for
Blue Ridge, the UT fish study, etc, and are reviewing them carefully.
One point of interest is that Dr. Leibergott indicates that BRPP
achieved about a 30% reduction in color/ton for hardwood and softwood
lines, but pretty closely agrees with our analysis that the overall
discharged color decreased less than 10% during the permit period. He
states that he expects only "marginal" further improvements, which seems
like preparation to resist further required reductions, but it seems to
us possible that this apparent discrepancy in color reductions could be
explained by a coincident increase in production. Will we have access to
production information in this permit cycle, as we did for the previous
one?
Best wishes, hope you are doing well, and we look forward to
hearing from you,
Hope Taylor-Guevara
Clean Water for North Carolina
2009 Chapel Hill Rd.
Durham, NC 27707
919-401-9600
www.cwfnc.org
2 of 2 5/24/2007 10:59 AM

Ridge
Subject: latest on Blue Ridge
From: Sergei Chemikov<[e-mail]>
Date: Wed, 23 May 2007 10:38:04 -0400
To: Roger Edwards <[e-mail]>, Susan Wilson<[e-mail]>
-------- Original Message --------
Subject:Re: DRAFT Site Visit Report
Date:Wed, 23 May 2007 10:04:48 -0400
From:Anderson.Donaldf()epamail.epa.gov
To:Sergei Chernikov<sergei.chernikov(cr),ncmail.net>
Sergei -
Thanks for the inquiry - good to hear from you. In fact, the Tech Team
has just sent a draft of our report (using info in the site visit
report) to BRPP for a factual review. Our intention is to be as sure
that our presentation of facts is as correct as possible. Derric Brown
and I have been talking regularly. Based on his voice message late
yesterday and my reply this morning it appears that together we will
complete that review sometime during the week of June 4. Shortly
thereafter (no more than a week) we will send our final report to the
TRW. With that as the basis, we will,.work with the TRW members toward a
memorandum from the TRW to NC DWQ as the input for proceeding toward the
next draft of the permit for BRPP. We are following the same process as
last time (2001) . I hope this helps.
Don
Donald F. Anderson
Senior Environmental Engineer
Engineering and Analysis Division (4303T)
Environmental Protection Agency
For regular mail, balance of address is:
EPA West - Connecting Wing; Rm 6233V '
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Email: [e-mail]
Ph: (202) 566-1021
FAX: (202) 566-1053
Express / Hand Delivery, balance of address is:
1301 Constitution Avenue, NW
Washington, DC 20004
Sergei Chernikov
To
DonaldF Anderson/DC/USEPA/US@EPA
05/22/2007 14:52 cc
Subject
Re: DRAFT Site Visit Report
1 of 3 5/24/2007 10:59 AM

Ridge
Don,
Please let me know the status of the TRW report. It has been more than 3
months since the site visit and we really need to move forward with the
permit renewal.
Thank you!
Sergei
Sergei Chernikov, Ph.D.
Environmental Engineer
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
phone: [phone] ext. 594
fax: [phone]
[e-mail] wrote:
>Derric, Bob,
>Sergei,
>Paul, Dave,
>et. al.,
>
>I have attached a file with a draft of our Site Visit Report (SVR) or
>the mill visit of Feb. 8, 2007. I would appreciate receiving any
>comments you feel are appropriate. Thanks, and more to come,
>Don
>Donald F. Anderson
>Senior Environmental Engineer
>Engineering and Analysis Division (4303T)
>Environmental Protection Agency
>For regular mail, balance of address is:
>EPA West - Connecting Wing; Rm 6233V
>1200 Pennsylvania Avenue, NW
>Washington, DC 20460
>Email: [e-mail]
>Ph: (202) 566-1021
>FAX: (202) 566-1053
>For Express / Hand Delivery, balance of address is: :
>1301 Constitution Avenue, NW
>Washington, DC 20004 _
>
>(See attached file: BRPPSiteVisitRept d4.doc)
5/24/2007 10:59 A
� ..f1

Ve
ss on Tech Team report,TRW comments?
Subject: Re: Fw: progress on Tech Team report , TRW comments?
From: Sergei Chernikov<[e-mail]>
Date: Thu, 24 May 2007 09:33:06 -0400
To: Anderson.Donald£@epamail.epa.gov
CC: Susan Wilson<[e-mail]>, Roger Edwards <[e-mail]>
Don,
Thank you for forwarding this e-mail to me. We don't have any objections against
releasing any FINAL reports to the public. However, we would like to have a chance
to review your report and comment on it before it is finalized and released. We
would strongly object to the release of your report before it has been reviewed by
TRW members. The report might contain factual errors or interpretations that are
outside of Tech Team jurisdiction. Therefore, it should be reviewed and approved by
TRW members before being released to the public.
Sergei
[e-mail] wrote:
FYI
----- Forwarded by DonaldF Anderson/DC/USEPA/US on 05/23/2007 10:31
DonaldF
Anderson/DC/USEP
A/US To
"Hope Taylor-Guevara"
05/23/2007 10:29 <[e-mail]>
CC
Subject
Re: progress on Tech Team report
, TRW comments?(Document link:
DonaldF Anderson)
Hope -
I must offer my sincere apology for this reply being so late in coming
to you. However, we have been working diligently toward completing our
Draft Final Report from the Tech Team to the members of the TRW (TN, NC,
EPA Reg 4) . First, as we did last time (2001) , I have just sent the
Draft Final report to BRPP for factual review. Upon receiving input
from BRPP on our presentation of the facts, hopefully by the week of
June 4 (already booked calendars of key BRPP staff) , we will complete
our final report and release it to the TRW. At that point in our
informal process it is my intention that we also will make it available
to you folks. I cannot speak for BRPP but I would expect that since you
folks received production information during the earlier permit cycle,
it seems reasonable to me that you should again expect such data during
this cycle. With any comments we receive from the TRW members, we will
go through a hopefully short process to prepare the memorandum from the
TRW to the NC DWQ for use in preparing a new draft of the next permit.
From there forward we do not expect to actively participate in the
formal part of the process. If there is any change in this process, I
1 of 3 5/24/2007 10:59 AM

ress on Tech Team report,TRW comments?
ill let you know. Thanks again for your patience,
Don
Donald F. Anderson
Senior Environmental Engineer
Engineering and Analysis Division (4303T)
Environmental Protection Agency
For regular mail, balance of address is:
EPA West - Connecting Wing; Rm 6233V
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Email: [e-mail]'
Ph: (202) 566-1021
FAX: (202) 566-1053
Express / Hand Delivery, balance of address is:
1301 Constitution Avenue, NW
Washington, DC 20004
"Hope
Taylor-Guevara"
<htaylor@gloryro To
ad.net> DonaldF Anderson/DC/USEPA/US@EPA
cc
05/03/2007 14:40
Subject
., progress on Tech Team report ,
TRW comments?
Dear Mr. Anderson:
I'm just checking on progress on the Tech Team's report and
TRW review, hoping that we'll be able to get a copy of it soon, and also
trying to project the timing for the public process.
Since the Tech Team's visit, we've received several
documents from DWQ, including Dr. Leibergott's more recent report for
Blue Ridge, the UT fish study, etc, and are reviewing them carefully.
One point of interest is that Dr. Leibergott indicates that BRPP
achieved about a 30% reduction in color/ton for hardwood and softwood
lines, but pretty closely agrees with our analysis that the overall
discharged color decreased less than 10% during the permit period. He
states that he expects only "marginal" further improvements, which seems
like preparation to resist further required reductions, but it seems to
us possible that this apparent discrepancy in color reductions could be
explained by a coincident increase in production. Will we have access to
production information in this permit .cycle, as we did for the previous
one?
Best wishes, hope you are doing well, and we look forward to
hearing from you,
2 of 3 5/24/2007 10:59 AM

ress on Tech Team report,TRW comments?
Hope Taylor-Guevara
Clean Water for North Carolina
2009 Chapel Hill Rd.
Durham, NC 27707
919-401-9600
www.cwfnc.org
Sergei Chernikov, Ph.D.
Environmental Engineer
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
phone: [phone] ext. 594
fax: [phone]
3 of 3 5/24/2007 10:59 AM

BRPP Comments on Draft EPA"Draft Team"Report, 10 May 2007,Page I
BRPP Continents are in blue italic text Requested edits are in blaek-s#keeut and blue text.
MEMORANDUM
DATE: May 21,2007 (Draft Final,DO NOT DISTRIBUTE until this header is
deleted)
SUBJECT: Color Removal Strategies For Blue Ridge Paper Products,Inc.
FROM: EPA Tech Teamr
TO: Technology Review Workgroup
BRPP Comments—Purpose and Overall Report. {Ge disagree ivith stated purpose ctc intconsisteru nzth
the scope of the Technologl,Review Workgroup(TR if):order the 2001 XPDES permit. The purpose of
the draft report is defined in Parr 1, Section A. (8),Paragraph 8 ofrlte 2001 WDES permit.
"By Februar7,1, 2006, the Division of Mater Qualin?(in consultation with the Technology
Review 1T•orkgr•oup)shall recommend to the NPDES Committee, considering the statistical
anal vsis report submitted by dye pernniuee and the demonsn•ated performance of the mill, the
lowest achievable annual average and monthly average color loading effluent limitations. 1f the
limits determined to he achievable are nithin or below the target range of 32.000-39,000
pounds per day as an<rnutral average, the linnits shall become efterive ou,A•farch 1. 2006, by
written rhotltcation fi•onh the Director. If the limits determined to be'achievable by the Division
of Water Quality(in consultation with rite Technology Revew Work-group)are above the target
range, the Permit shall be modifted in accordance with North Carolina's permitting process to
rellect those limits.'
Bhte Ridge Paperrsubmitted the statistical unalvsis report re%rented in this permit condition in
December 2005. In Januaty 2006, the Division of Water Quality deferred changing the Cannon Mill
color limits until completion ofthe permit renewal process.
We disagree strongly with the negative tone for the majority gl'the draft report. The b4av 2007 dr•gft
reportfocuses almost exclusively on 2001 TRfV n-,cotnmendatior s that did not work, overlooks the rnill's
actual effluent color•performance and the key positive statements in the 2006 Liebergott Report
concerning implementation of rite 2001 TRW recommendations, and contains liurdarrental technical
errors. The draft report overlooks the fact that the Canon Afill achieved the second net,range of
gjIluent color perftnmance in the December 2001 NPDES pennit. Tire 2006 secondary ejjhient color
performance was 37,058 lbs per dqv equivalent to 26.2 lbs per air-dried ton of bleached pulp
(lbs./dDTBP). The.mill:s current performance is annnng the best, if not the best. of Kraft pulp and paper
mills in the world that use in-rnh`l color prevention technology to achieve effluent color goals.
As elocunzented in the.A,1a},2006 Color Compliance Report Blue Ridge Paper aggressiveli-purstncd the
2001 reconrntendationsofthe TRI1'. In addition to the TRi1'reconunendotions,Blue Ridge Paper
implemented alternative techniques for achieving the color reduction goals in the NPDES pernnit. H`e-
achieved the second tier effluent perjorntance goal for true color in the range of 32,000 to 39,000lbs per
dqv.
Specifics•follow.-
Purpose of this Review

BRPP Comments on Draft EPA "Draft Team"Report, 10 May 2007, Page 2
Blue Ridge Paper Products Inc. (BRPP)has requested renewal of their National Pollution Discharge Elimination
(NPDES)discharge permit NC0000272. This permit allows discharge to the Pigeon River of industrial and other
wastewaters from the pulp and paper mill BRPP operates in Canton,NC. The permit expired November 30
406 In their May 2006 Color Compliance Report(Blue Ridge,2006a), BRPP requested that North Carolina
reissue the NPDES permit for the Canton Mill with an annual average effluent color limit of 39,000 His per day.
This is a reduction from the current 42,000 lb per day annual average limit,which became effective January
2004. BRPP's requested limit was based on the mill's 2005 annual average effluent color,39,000 lbs per day.
The Technology Review Workgroup requested that the EPA Tech Team support EPA's review of the color limits
included in the draft permit renewal developed by North Carolina Department of Environment and Natural
Resources. The Tech Team last evaluated color discharges at the mill in 2001 (EPA Tech Team 2001).
BRPP Comment— The 2001 ArPDES permit did not expire. Blue Ridge Paper submitted a complete
permit application ISO dues prior to the permit espirtttiort date. Tlie permit continues in g((ect as•
outlined in the Standard Conditions for NPDESPermits,Part 11, Sec•rion B. 10.
Members of the Tech Team rRW visited the Canton mill on February 8,2007 to observe and collect
information and data on the status of technologies implemented and color discharges at the mill. This draft
memorandum incorporates analysis of data from that visit and other data provided by BRPP.
This memorandum reviews the process improvements previously analyzed by the Tech Team,the status of their
implementation at BRPP,and identifies additional color reduction activities that BRPP could implement during
its next permit term. The memorandum also reviews the variability of the mill effluent color discharges and
suggests final effluent color limits for incorporation in the revised permit.
Background and History
BRPP operates a bleached papergrade kraft pulp and paper mill in Canton,NC,which it purchased from Champion
Intemational Corporation in May 1999. BRPP is owned 55%by KPS Special Situations Fund,
L.P. and 45 %by the employees through an employee stock ownership plan. Operations at the mill began in 1908,
but the mill has been extensively modernized. ,most reeently in 1993. The mill currently operates a 810 tpd
hardwood pulping line and a 600 tpd softwood(pine)pulping line. After cooking,pulp from each line is further
delignified in single-stage oxygen delignification(OD)systems,both installed in 1993.Hardwood pulp is
subsequently bleached with a DED sequence(BRPP stopped adding oxygen to the hardwood E stage in 2005)
Pine pulp is bleached with a DEoD sequence tnnnn stopped adding POFOXideto the pine❑ stage in 2005 s Target
brightness is 86 ISO,an increase by one point from the target brightness in 2001. Up to 80%of the filtrate flow
from the pine bleach line is returned to the
---------------------
EPA Tech Team members are Ahmar Siddiqui, EPA/EAD;Karrie-Jo Shell,EPA Region 4;Don Anderson,EPA/EAD;
Betsy Bicknell,ERG,contractor;Neil McCubbin,subcontractor to ERG;Dan Bodien,subcontractor to ERG.1 BRPP
announced on March 26,2007 that it is engaged in preliminary discussions with The Rank Group concerning the sale of Blue
Ridge. The New Zealand-based Rank Group has considerable holdings in the paper industry. Rank Group recently bought
Evergreen Packaging,the former North American beverage packaging division of Intemational Paper.
--------------------
TM
recovery cycle using the unique bleach filtrate recovery(BFR )process,developed by Champion.This 80%
closure rate is an improvement from 2001,when the pine line closure averaged 73.7%. Up to 25%of the hardwood
line bleach plant E-stage filtrate flow is also recovered. BRPP produces 300,000 tons per year of uncoated paper
including offset,tablet,and envelope grades.The mill also produces 275,000 tons per year of bleached paperboard
used for liquid packaging and paper cups, including FDA-approved grades for milk and juice cartons.
BRPP Comment- The strike through test are editorial comments and are not pertinent to the description
of the current will process.Also, not all of the rears listed are correct.

BRPP Comments on Draft EPA "Dmit Team"Report, 10 May 2007, Page 3
Process Improvements Previously Analyzed by Tech Team
As a result of its 2001 analysis of the BRPP mill discharges and operations,the Tech Team identified five mill
improvements that it judged capable of reducing the discharge of color in the mill effluent. BRPP and its
consultant also identified several process optimization projects that would reduce color discharges.The status of
BRPP's implementation or evaluation of each of these improvements is summarized in Table 1,then discussed
below.
BRPP Conrrnents—Revisions to table are marked below including several continents.
This table is an over simplification of a very complex process and decisions related to process
optimization during the current permit terns. D overlooks conclusions from the 2006 Liebergott i GLc2 V
report. The trade-offs betiveen bleaching chemical rates and other pulp mill color control techniques
related to kappa.filtrate recvele, and hrownstock washing g1ficienev are not reflected in this table or in the
TRW's reviety. Also Arming the 2001 XPDES perndt ferin, the market specification for some grcrcles offrne
Kraft paper changed from 87 bright to 92 bright. This market specification change required a change to
Carton tifill laippa and bleaching strategies. The current pulp bleach operation is very oil -rentthan the
operation in 2001. Sign fcan progress°was made during fhe permit term in reducing bleach plant effluent
color.
ZD(ozone.chlorine dioxide) is not a viable technologv fcn-the Canton Mill(reference page 18 of the 2006
Liebergott;GLR V Report). Recent eaperience of the pulp and paper industry is that ZD bleaching has
not given the color reduction benefits promised. Ifs application is will and wood species specific. The ZD
process at Spring Grove has been shutdown.
shore details regarding our edits to Table 1 cure in comments that f Xow drgft repot discussions out the
table items.
Table 1.Review of Process Improvements Identified in 2001
Predicted Color
Reduction(Final Color
Effluent;lbs/day Reduction
Improvement ant.avg) Ira Iementatidit Status Achieved' - Comments -
Process 1,400 Predicted reduction in BRPP consultant recommends
optimization CIOz use(27%on HW, reduced CIOz use and adding oxygen
projects 17%on SW)not made. and peroxide to E stages to reduce
CIOz use increased on color generation(GL&V 2006,pp52-
SW,decreased 5%on 53)
HW
BFR reliability 1,000—1,200 Pine line filtrate recycle Total Further improvements to BFR
improvement increased from 74 to reduction reliability may not be feasible
80%. from 2001:
6,000
Improved black >5,000 Some Significant spill lb/day,annual Additional improvement to black
liquor leak and collection improvements average liquor control possible: further
spill collection made:untreated eel-- eliminate overflows,and continue to
control(BMPs) (influent to treatment) pretreat diverted high-color
vatiability meharged, wastewater.Also improve control of
total influent color losses of white and green liquors to
variability was reduced reduce or eliminate sulfide-based
color.
Ozone/CIO: 3,000-6,400 - inadequate evaluation None BBnn..hould,.....plete...,...a..
stage for (lab studies);not installed ^^••-^"OR--'----dUGfi--`---'
hardwood line to valuate e7gne b eash4 g, This

BRPP Comtnents on Draft EPA "Draft Team'Report, 10 May 2007,Page 4
technology is not recommended by
Dr.Liebergotl(see page 18 of 2006
Lieberrotti GL$V Report). ZD
process at Spring Grove is shutdown;
no color reduction benefits were seen
during operation.
2m Stage OD for 1,100—1,400 Ifleemplete evaluation None This alternative is technically and
pine line Evaluated(lab studies); eeeuenxeally feasible but may not be
not installed a viable retrofit for the Canton Mill.
Complete additional studies.
Following 2001 recommendations.
BRIIII optimized existing single stage
OD system on pine and achieved
most of benefit of a 2-stage OD
system based on average industry
experience.;gig neeFing des g;,
imp _e".�ya.. d,followed-bi
lementatien. Additionally,with
Bleach Filtrate Recvcie(BFRf.
benefit of l d stage 02 will be
a,, aid(su:page 60 of 2006
Lio eir ott GLRV Re art).
Color treatment 52,750 Evaluated(lab studies); None CRP purge stream now averages
of CRP purge not installed 8,745 lb/day.Full---'.a„�.e-test''--
stream extended peFied to determine wha
a.._.:,,..OfthGi..__i,..:.._...........a:_
.M in nrvIT-12 Saida a be
be
.,�..,,.T:.ti at-. Need
further study of strategies for
reducing color released in the purge.
Process Optimization Projects
BRPP Comments-
Bete Ridge Paper evaluated all gfthe 2001 TINV recommendations. All the "Highest Certainty-items
were evaluated and implemented as fec:hnicallj,, economically and operationalli,feasible. These and other
color reduction initiatives identified bp.Blue Ridge Paper achieved thefirst tier,color reduction to 42,000
Ibs per day. 77?e Daft report should include these facts as documented in the several color progress
reports submitted under the 2001 NTDESpermit.
BRPP absolutely disagrees with the statements in this section that the Canton Mill was slow in pursuing
BiVP controls and other TRW recommendations. As documented in the May 2006 Color Compliance
Report. Blue Ridge Paper aggressively pursued the 2001 recommendations of the EPA TRi3: Me
implemented those. TRIfreconimendations that werefeasible. in conirmction with additional improvements
to achieve the second tier effluent perlarrnunce goal r f hue color in the range of3_',000 to 39,000 lbs per
dap.
The 2006 Liebergott review,of Craton;hill color pet%r7nance was vetp worthwhile. Overall,Dr.
Liebergott understood and agreed ttzth our decisions concerning process changes that were made and not
made relative to the 2001 TRW reconunendadons. In the executive.sttrnmmr to the 2006 report. Dr.
Liebergott states:
"The report concludes that Blue Ridge Paper Products has date a ver),good job implementing the

BRPP Comments on Draft EPA "Draft Team"Report, 10 May 2007,Page 5
2001 recommendations and has made additional environmental improveunerni as a result. An
updated comparison of the Canton Mill to other Krgft mills in the USA. Canada and Finland
indicated that there are still no COD,BOD or color values lower than those achieved by the
Canton mill. Given the current state of adaptable technology and the mills already high level of
environmental performance,jilture improvements are capected only to be narginally
incremental."
This A•ey statement and the positive evaluations of Blue Ridge Paper color work during the terns ofthe
current NPDFSperrnit need to be rrflected on the draft report. The report also should consider important
benchmar•king information provided in the 2006 NCASI Color Studv report which was submitted to the
TRW with the.2006 Liebergott Report.
Dr.Liebergott has identified areas of investigation%rjurther improvement. Blue Ridge Paper supports
these recommendations. It is not accurate to characterise the 2006 Liebergott/GL&V report as critical of
the Canton rtfill operations. The benchrnarking(lain that Dr. Liebergott provided during the February
2007 TR1V review meeting clearly demonstrate that the Blue Ridge Paper Canton:Will is operating at all
in-mill color performance level where fens. if any mills in the svar•ld, have atnv experience. This is also
supported by the 2006 NCASI Color Study. which nvmv provided to the TRiF.. The Bleach Filtrate
Recvcling(BFR)process makes the Canton:Will situation unique. Process changes for color that may
work of non-BFR, higher color level mills•: don't necessarily make sense for the Blue Ridge Paper Canton
Mill. Dr.Liebergott has made this point repeatedh,and has advised that BRPP needs to carejidly evaluate
ate
further process changes. He was vety supportive of the Cantor,blill's findings related to the effect of
brownstock washing efcierncv on kappa factor, chemical consumption, and overall blench plant effluent
color. tin important area of out-t-approach.
Specific edits and continents on this section follow:
In 2001, Liebergott&Associates and GL&V Pulp Group prepared an extensive analysis of
the mill fiberlines that included identification of options for effluent color reduction. Dr. Liebergott was retained
for this work by a coalition of environmental groups. This report,Bleach Environmental Process Evaluation and
Report(BEPER)(GL&V 2001)presented 16 recommendations for incremental improvement to fiberline
operations. These included suggestions for improving process control,OD performance,reducing the amount of
CI02 used on both bleach lines,and enhancing the extraction stages on both bleach lines with oxygen and/or
hydrogen peroxide. The Liebergott recommendations were included in the 2001 NPDES permit and were
evaluated. Those that were technically.economically and operational feasible were implemented.
BRPP Comments—Dr. Liebergott was identified and retained by a coalition gfensironnuental groups in
2001. Blue Ridge Paper agreed to allow Dr. Liebergott and these groups frdl access to the mill for
technical revicrsr gfour•process outcolor reduction opporfurtities. However, the Canton Mill was not the
clienifir the 2001 Liebergott report. The mill evaluated all of the 2001 Liebergott report
recommendations. and the majority of these recommendations were implemented. Where not
innylemented. the mill learned hifbimation that in.several cases led to other im rovements.
as edginally Gast in the 1998 Settlement Agreement, and has implemented sOFRO but HOt all Of the prOGOss
Optimization and ifflPFevements identified by the TRW in 2001 (:Peehnology Review Wer4gfeup 2001, GL&N
2006,and Blue Ridge 2006a)as among the"highest BRPP Gquld have been mere aggFessive in implementing inere elementq of the hest me agement pf;aotiGes (BN4Ps)items. They have implemented fnaft),of the RMPq
wastewater and trented effluent AR14 netOd ON'OF FOGOBt years(paFtiGulaFj5,-2004 2006),as discussed latefin this
memorandum.

BRPP Comments on Draft EPA "Draft Team'•Report, 10 D7ay 2007, Page 6
Process control and OD performance have been improved. However,on the hardwood line,they did not decrease
the DI stage kappa factor as recommended and they discontinued use of oxygen in the extraction stage.As a result,
the total C102 charge on the hardwood line as of May 2006 was only 5%less(not the predicted 27%less)than the
charge in 2000. Similarly,on the softwood line,they did not decrease the DI stage kappa factor as recommended
and they discontinued use of peroxide in the extraction stage. As a result,the total C1O2 charge on the softwood
line as of May 2006 was 11%more(not the predicted 17% less)than the charge in 2000.
13RPP Comments-
Discontinuation of 02 in hardwood E stage -Iteni 7,page: 14 in the 2001 Liebergott report recommended
a reduction is 02 in hardwood E stage. BRPP iniplentented this change and continuer)optimization
resulted in the elimination of 02 front hardwood E stage. During all this process work, BRPP smv no
change in E stage kappa or to effluent color.
C1O2 charge-Bleaching strategy changed in response to ntcirket conditions as discussed above. This hair
t;ffected overall bleach plant chemical use and lmppa factor, cis discussed at lire Feb 2007 TRW nieering,
Blue Ridge Paper has identrf ed pulp washing efficiency as a primary factor influencing kappa factor and
bleach plant chemical demand. This is the current focus ofIcolor and chemical use efforts. Ai the April
2007 outage, the pre-bleach washer&runt was changed as BRPP advised the TRfk at the Feb 2007
meeting. As a result. Pine DI stave kappa factor is now at rargets recommended by Dr. Liebergott(27
Before, .24,4fter).
In preparation for renewal of their NPDES permit,BRPP again hired retained Leibergott&Associates and GL&V
Pulp Group to analyze their fiberlines, review the implementation of the.2001 recommendations and identify
further options for color reduction. In the 2006 update to the BEPER(GL&V 2006),the consultants repeated their
recommendations for BRPP to reduce the kappa factor in the DI stage of each bleach line and replace the C1O2
bleaching power with oxygen and/or peroxide in the extraction stages.
BRPP investigate inereasing the operating tempaFature of the 1154FOgOR Peroxide extraetien stage to Feduee effluen
se}ef
BRPP Comment- The Liebergort recommendation is to investigate perosi&e for tifcation of the E stage.
High temperature peroxide(PH7) is not recommendation in Table I of the 2006 Licheigot(I GL&V
Report.
In addition to reducing the color of the bleach plant effluents, use of a lower kappa factor means BRPP would use
less C102 to bleach,which will reduce the total chloride content of bleach plant filtrates. Lower chloride content
Will Make it possible fef the mill to FeenvOY MQFO haFdWOod filtrates with the BFPJm pmeess and reduoe the
colored filtrates disehagedto the sewer. Lwver AhIsFide eAntent ean also be expeeted to make it possible ferthe
:II to Feduee the nnn purge iqe and the ....lot it eontfibutes tR the mill effluent
BRPP Content BFR is not on the hardwood line. Statements above are technically incorrect. A
portion of hardwood E stage filtrate;is recveted. ;hill experience shown increasing in hardwood E stage
recycle adversely affects pulp washing and causes carryover to the D stage, increased chemical
a.•onsuniption and results in increased color. 77rese offset any poieruial color•bertefr't,fi-onr increased E
stage reevcic.
BFR Reliability Improvement
As reported during the Tech Team's February 2007 site visit,BRPP spent$1.5 million over the last five years to
improve the reliability of the BFRTm system.These expenditures included replacing tank liners for the three
existing sand filters(now high grade stainless steel),replacing and/or upgrading existing process piping with

13UP Comments on Dmft.EPA "Draft Team"Report, 10 May 2007, Page 7
piping with improved metallurgy, installing a fourth(new)multimedia filter,and installing a third ion exchange
softener. With these improvements,BRPP has increased the BFRTM closure rate from 73.7%in 2001 to 79.2%in
2006. Mill representatives stated that the present closure rate of approximately 80%of the pine line bleach plant
effluent represents the maximum amount attainable without incurring unmanageable corrosion and scaling
problems.. This is because scaling from hardness minerals accelerates above closure rates of 80%(Bodien,2007).
BRPP Comment—This discussion accurately reflects our experience.
Improved Black Liquor Leak and Spill Control(BMPs)
BRPP Continents-
Blue Ridge Paper strongly disagrees with the technical analysis, conclusions and tone of this discussion.
We have a number of comments and request that rite Draft Team properly consider all of our wastewater
data before making conclusions about lack of demonstrated improvement in Black liquor management an
spill control.
The Canton Mills Best Management Practices(BAIP)program and action levels•fbr black liquor leak and
spill control are hase.d.on!oral influenr color to the wastewater treatment system. Primary influent color
is the most representative parameter to track in-still eolorperfornance. This has always been the focus of
previous TRW review sessions.
Prinmry effluent color is monitored for process contr of ptaposes, but it is not air accurate indicator of
black liquor losses o•other color material losses to the mill sewers)>.stern. Primary effluent color is
skewed byfine turbidity and also reflects Lire sewergenerated colorphenomena andpossibly other effects.
Its apparent removal efficiency in biological treatment is better than total influent color—suggesting that
the fine turbidity component is signrficaut or that the treatability ofcolo•is transformed in the primary
treatment process.
The TRW requested infi»•ruation on color to-ents determined front our BMP monitoring program during
2006. The monitoring of influent color identifies these events. The TRR'did not request data fr)r high
primary effluent color data. and Blue Ridge Paper dial not provide such irrforrnation.
Blue Ridge Paper requests that the DraflReport Team present toad influent and secondary ejfhrent color
in air)-discussion of black liquor leak and spill control. The appropriate data tables are below. Between
2001 and 2006. average influent color was reduced Uv 19,271 lbs,'duv or 33.3 percent. Secondary effluent
color was reduced by 5,616 lbsAdav or 13.2 percent:
In summary,ptinuny influent color—the correct measure of black liquor loss and spill control—showed
defnirive improvement during the term ofdre 2001 NPDES pennit. Secondary•effluent color also showed
dcfinitme improvement. In 2006 following implementation of the acid sewer project, the contribution to
color fi om all mill sevvers balanced with measured influcwt color to wastewater treatment. This was a
major topic of discussion at the Februai),2007 TRW meeting at rite Canton Mill. The balance ofmill
seiner color loadings with measured influent color is 2006 supports influent color as the accurate uneasure
e f BA1P effectiveness. This injbimation•indicates that reduced injhrem color does not translate into
reduced effluent color. The Primary effluent table should be retnowcd from this analysis. The lowest
primary effhten[year was the kiglrest ser;nnrluny efflueru year. 11ore importantly, the highest primary
eflluenr year was the lowest secondary effluent year. Therefore. this is not an appropriate comparison of
nrill color perfor•rnance.
Table 2.1—Prirnary Influent(Totallnfluent)Statistics be Year

BRPP Comments on Draft CPA`Draft Team"Report, 10 h4ay 2007,Page 8
Mean True IRelative < ` -Percent
Color Standard Number of Decrease `
(lbs/day) Standard Deviation days>100,000 From Baseline
Deviation (SD) SD/mean % lb/day (2001
2001 57,725 20,619 35.7% 4 0.0045
2002 54,780 17.195 31.4% 7 5.10%
2003 55,550 19,424 35.0% 9 3.77%
2004 49.466 18,786 38.0% 8 14.31%
2005 45,175 22297 49.4°%0 7 21.7140
2006 38,454 14,015 36.4"0 2 3_3.38°0
Table 2.2—Primatj,Effluent Statistics by Year(Should not be included in Report)"
Mean True Relative Standard
Color(lbs/day) Standard Deviation(SD/mean Number of days> .
Deviation SD %) 100,000lb/da
2001 62.008 19,561 31.500 13
2002 59,956 18,680 31.2% 16
2003 59,646 18,468 31.0% 10
2004 Ci5,206 26,674 40.9% 40
2005 93.33S 24,158 37.8% 28
2006 65,512 25.427 38.8% 36
`Percentages not given due to lack ofsignificast statistical change.
Table 3.3—Secondat3,Effluent Statistics by Year
Mean True Relative Percent
Color Standard Number of Decrease
(lbs/day) Standard Deviation days> 100,000 From Baseline
Deviation SD SD/mean % lb/day 2001)
2001 42,676 10,925 25.6% 3 0.00'.'%°
2002 41;166 9928 24.190 0 3.54%
2003 44,627 1 L043 24.7% 1 -4.57%u
2004 e 4L463+ 32,569 76.6% 4 0.43%
2005 39,092 10,092 25.8% 0 8.40°0
2006 37.058 8959 24.2% 2 13.17°,%
"2004 data were affected by histmde footle in Sep 2004
Specific edits follow:
BRPP continued efforts intended to improve its management of leaks, spills, and intentional diversions of black
liquor over the last six years. These efforts include:
• Interconnecting the pine line and hardwood line spill collection sumps so that tankage in either line can be
used interchangeably for spills;
• Repositioning sewer conductivity probes from sumps to in-line to more accurately and reliably identify
high conductivity wastewaters;
• Diversion of up to one hour of total mill flow to off-line 1-million-gallon clarifier, during high color

BRPP Comments on Draft EPA `Draft Team"Report, 10 May 2007, Page 9
releases,to equalize color discharge to wastewater treatment plant;
• Prior to process line outages, improved prior planning for capture of high-color process liquors and black
liquors and better managing their timed release to treatment system;
• Continued operator training;and
• Implementing two hour testing for color at the W WTP with one hour testing during outages or semi-annual
shutdowns.
However-,these impfevements did not reduee the variability of the eeleF diseharged to the seeandaFy tFealme
system. Table 2 shews the Fnean,standard devimien,and relative staffidaM deviation (standafd deviation as a
BRPP Comments-
The primary effluent table should be r•einoved firont this analysis. The lowest primary etlhtent rear was the
highest secondmv effluent year. Afore importaraly, the highest primaryr:Effluent year was the lowest
secondmy effluent rear. Thereyore, this is not an appropriate comparison of•ntill colorperfirrmance.
In 2006, the contribution to color•from all mill servers halonced with ineasured influent color to
wastewater treatment. This)i rther supports that influent color is the accurate measure gf'B:1fP
effectiveness.
Table 2-Primary Effluent Statisties,by 3'eaF
A4earrTnre CnleF Relative Standard
Obs/flay) Stendar+t-Deviation100,000
2OU 62,008 19;36-4 3-i.51% +3
2M 39;836 +8,680 343"4 46
2003 39,646 19,468 3-i.00 40
ZM 65,206 26,674 40.9106 40
2003 1 63,838 24,158 37." 29
„ '
PAOF tO 2006,the aeid seweF mixed with other mill wastewater prior to the treatment systern,resulting in
Sewe
the treatment plant afteF the p6mai=),elafifien However-,the primary effluent sampleF iq Ineated d.Rvffi­qtFeaFn 9fth
mixing point of the primary clarifier averflev.,and apid swven Thus,t . ­ .. I esenied in Table 2,
Fepr-eseat the FfibitUFO of pfifnaFy effluent and acid sewer-, ineluding any oaleF geneFated fFem the immediate mixing
of thn twe stFmT
Table 2 pFesents the number of days feFwhieh the pFifnaE3,effluent eeleF exGeeded 100,000 lbs/day.As shawF,
system.2006(Blue Ridge 2907a).These events ineluded, ameng others,planned mill BRPP provided the Teeh Team with notes deseFibing Fail! events that weFe Felated to high primaFy effluent ealAF in
outages, outages,lanned
singlesluFfy tank oveFflaw,and a release &am the evaperatOF Felated tO an equipment failure. BRPP did not Fepoft one
single event oF one type of event that eaused high color in the pFimafy effluent. FuFlheF,not all b
h pFimaF5,
bh final effluent b
throughe (e.g.,BRPP FePBAS that CGIGF aSSOGiated with hig
turbidity is effeetivelY Femoved in the seeandaFy treatment system). However, ffern analysis of the data,ihe Teph

BRPP Comments on Draft EPA `Draft Team"Report, 10 May 2007, Page 10
Fninifnize unplanned spills alld leaks and intentional diseharges of high eeleF stmams anq eiiiitinuing effbits-te
The Tesh Team notes that paragFaph 19 efthe 1998 Settlement AgFeement ineluded the following liFovisimp
eontrolling fneasuFable Week liqueF leaks and spills . . and capturing and FeGyeling liqueFs duFipg fibeF NHO
»
outages
This was again noted in the 2001 T-eeh Team fepof4. Despite;his eammitmeni,the inill haq not degFeaqed t
disGharge of grLater than 100,000 pounds,the mill variability inereased between 2001 and 2006 (see Table 2*
Ozone/Chlorine Dioxide Stage for the Hardwood Bleach Line
BRPP Comments-
ZD(ozoneiehlorine dioxide) is not an appropriate technologv for the Canton Mill(see page 13 of the
2006 Liebergott!GL&['Report). The ZD process at Spring Grove was shut down gJier it failed to
demonstrate color benefit.
Dr. Leibegott discussed the perforrnanc•e of the Dontar Espanola mill during the Febrttcny 2007 TRH'
meeting at the Canton hfill. The Espanola mill is cited as a successlid application of ZD that is
applicable to otherpulp and paps?-mill. TTie Dorntar Espanola Colo•petfonnance is 3 to 4 times higher
than the currem!color perfornttntc•e of the Bhte Ridge Paper Catntotr A,Iill(Recent Ernviromaental
Improvements at the Espanola Afill, 2002). Additionally, the Dorntar mill uses a ven3,different good
species than the Cannon 1Lfill. The Dorntar mill does not have bleach filtrate recveling(BFR).
Dr. Liebergor identified issues with the PAPRICAN work Blue Ridge paper reported these to the TRIG"
its part of color project documentation.
Edits and comments for this section follow:
BRPP engaged the Pulp and Paper Research Institute of Canada(PAPRICAN)to investigate potential
modifications to the hardwood pulp bleaching process and determine effluent color reduction that would result
from these modifications.The PAPRICAN report entitled"Bleaching Evaluation for Effluent Color Reduction"
(Audet et al,2003)was provided to the Tech Team in early 2007.
PAPRICAN stated that their objective was to evaluate whether modifications to the hardwood bleaching
sequence at Canton specified by Mr.Johnnie Pearson(presumably a BRPP representative)could"generate
effluents with a color reduction target of25%."
BRPP Comment-11r.Pearson was the BRPP process engineer who oversaw this work._
BRPP provided PAPRICAN with oxygen delignified hardwood pulp.PAPRICAN bleached this pulp in their
laboratory, investigating various combinations of chlorine dioxide,ozone and hydrogen peroxide.
The report concluded that ozone could replace some of the chlorine dioxide used in bleaching(known as a
"DZ"stage),while producing pulp of equal or slightly better quality than the control sequence. This is
consistent with the open literature on ozone/chlorine dioxide combinations.
PAPRICAN also concluded that replacing some of the chlorine dioxide in bleaching with ozone increased the
color in the bleach plant effluents.This contradicts the experience reported by Domtar(formerly E.

BRPP Comments on Draft EPA "Draft Team"Report, 10 May 2007, Page I 1
B.Eddy)at their Espanola mill,where a dramatic reduction in effluent color was observed when than mill
installed an ozone pulp bleaching system(Munro and Griffiths,2000). The Tech Team notes that the Espanola
mill has no color discharge limits and it installed ozone to reduce its bleaching costs.
The Tech Team found ni€eant agrees with findings in the 2006 Leibergott/GLV report that there were
deficiencies in PAPRICAN's analysis of the laboratory results. The concentration of color in the effluent for
each stage was added to obtain the total concentration for each tested bleach sequence. This approach neglects
two points:
1) Mixing effluents produces reactions that may increase or decrease the concentration of color
in the combined effluent.
2) Filtrate volume affects the measured concentration(e.g.,lower volume will concentrate
the filtrate to a higher color).PAPRICAN's report does not present the filtrate volumes,
so a comparison of concentrations may be misleading.
Liebergott et.al.reviewed the PAPRICAN report and identified the sane deficiency with regard to effluent
mixing. They also noted that the quantity of chlorine dioxide added to the ZD stage was too high,which would
result in higher effluent color(GL&V 2006,p 18).
In response to EPA's question about how the PAPRICAN results were used to estimate impacts on final effluent
color,BRPP responded:
The pilot study reactors were batch and not continuous and did not include filtrate recycle. The pilot
studies included bleach stage filtrate color concentrations, but there was no filtrate flow rate data
from which to calculate a production-normalized filtrate color mass.For these reasons,we did not
attempt to calculate secondary effluent color impacts using pilot study data for individual bleach plant
color streams.
In the PAPRICAN study, the individual bleach stage colors were compared directly and in total.By
both means, the color of the ZD stage was higher than the baseline DEaD.It is also well known that
when individual bleach stage filtrates are mixed the resultant effluent color is very difficult to predict.
(Blue Ridge,2007a)
The Teph Team Agneludes!hat BRPP's investigation of the potential fbF haFdwood pulp ozone bleaehing to
fedull"i�ls li�uent Golorwas inadequate. Further labarataiy tFials,designed and implemented to pfavide
reliable infennation .1 . 1 1. nalized color generated by eaek stage and by the effluents as
..tined at the BDDB Mill aFe needed to evaluate this♦e,final......
BRPP Comment- While there here issues with the PAPRICAN work. Dr.Liebergott floes not
recommend ZD technologyfor the Canton Afill(page 18 ofthe 2006 Liebergott!GL&V report).
Second Stage Oxygen Delignitication for the Pine Bleach Line
BRPP Comments-.Following Dr. Liebergott's 2001 suggestions,Blue Ridge Paper made significant
process improvements in our existing, single stage 02 delig systetn on pine We don't agree that 2
stage 02 is now a "highest certainty"color reduction teclhnolow. Blue Ridge Paper does agree to
conduct another lab scale studs for this potential process modification.
GI the 200E report, Dr.Leibergott warns that it is proven difficult to accurately.1brecast the benefit to
secondar)-effluent color of individual in-mill process changes. Two stage 02 deliginification on pine
stay not be the most cost effective use of limited capital for additional color reduction. 7]ivical
performance far 00 is 40 to 50%deligniJicationciencv fT 2PPI Bleach Plant Operations 2007J. The

BRPP Comments on Draft EPA "Draft Team"Report, 10 May 2007,Page 12
current single-.stage 02 delig achieves 45%. [TAPPI Bleach.Plant Operations 2007]. The 63%
gficienoy for 00 slated in the 2006 Liebergott report is a single eaarnple for a mill with a different 1+,00d
species and higher inconting kappa than.the Canton Alill.
.Specific edits and commentsfollow:
BRPP contracted with Andritz/Ahlstrom("Andritz")to study,among other things,the addition of an additional
stage of oxygen delignification in the softwood bleach line at Canton.Andritz,a well established supplier of
pulping and bleaching technology and equipment,maintains the Pruyn's Island Technical Center,which
conducted the tests. The Andritz report,entitled,"Laboratory CK and Lo-Solids Cooking with O-Do-Eop-D
Bleaching Sequences on Softwood Furnish from Blue Ridge Paper,Blue Ridge,NC"(Andritz Ahlstrom Sales
2001)was provided to the Tech Team in early 2007.
The twit of the AndFitz Fepoi4 states that"BRPP requested the sales depaftfneiA of AndFitz AhIstrom to
investigate altemative Fnethods of pulping and bleaohing that would reduee theirwaste p�eduets and iffipFeve-tL�
quality ofthek hardweed and saftwood paper pmduets." As indieated by this statement efwerk,testing e
data in the Fepei4 are useful fbF analysis ef effluent ealeF inipfavemen .
Specifically,Andritz compared single stage and two stage oxygen delignification of samples of pulp provided by
the BRPP mill.The tests showed that a second stage of oxygen delignification could reduce the kappa number of
the unbleached pine pulp by 22%.
Andritz did not bleach the pulp after the two stage oxygen delignification,so the report provides no information
on the impact of the additional oxygen delignification stage on effluent characteristics, including color.
In response to EPA's question about how the Andritz results were used to estimate impacts on final
effluent color,BRPP responded:
The Andrtiz-AhIstrom study ofsecond stage 02 for pine showed delignification ranging from
42.7%for the single stage, 48.6%for the 0-0 and 55%for the 00 stage. Willa improvements
that BRPP made on the existing single stage pine 02, the deliginifrcation increased from 40%
to 45%. With BFR in place on the pine frberline,the effluent color reduction from this
improvement in 02 deliginification has been very difficult to identify. The inability to quantify
the effect on effluent color of improved 02 deliginifrcation made the capital cost to install a
second stage 02 on pine not economically feasible. (Blue Ridge,2007a)
BRPP's analysis evaluation of the benefits of adding a second oxygen delignification stage to the pine line is
ineemplete should be conducted again. BRPP's consultants note that even with the percent delignification
currently achieved on the pine line,a second stage could achieve an additional 20%to 25,%delignification(see
GL&V 2006,p 118). Page 117 of the Liebergott Report predicts an 8%improvement in delignification
efficiency at the Canton Mill.
By making a 20 to o oFeng, n
Go!E)Fed material currently disehaFged from b
FeGeveFy beilen in addition,the quantity of ehlerine diex�ido and oaustie required in bleaching would be Feduped
by appFoximately 20 to to the BIZR;LmA,E)uld be reeovefed and humpd in the mill's
reducing the lead on the BFPJm system.
of H "A hleaeh filt�tes to be reel led thFeugh the BF-RTm systern. A kappa number decrease or
delignification efficiency increase would not equate into a similar color reduction. Although with the
information available it is not possible to rigorously calculate the benefit of this change,the Tech Team would
expect in the order of 1000 Ibs/day reduction in bleach plant color discharge.

BRPP Comments on Draft EPA "Draft Team"Report, 10 May 2007, Page 1
BRPP Comment-BFR is not on the hardivood line. Statements above are technically incorrect. A
portion ofharzhvood F:stage filtrate is recycled. Afill experience shows increases in hordwood E stage
ren,cle adversely gtlects pulp washing and causes cai7yover to the D stage, increased chemical
consumption aril results in increased color. 77iese offset any potential color bens f t f•onn increased E
stage recycle.
Liebergott et al(GL&V 2006)estimated that implementing a second oxygen delignification stage on the pine
line would reduce bleach plant(Note 4.Page 6)color discharge by 1142 lbs/day.They estimated the capital cost
of adding an additional oxygen delignification stage would be in the order of$2 to$3 million"and the
chemical cost savings approximately$1.2 million/year,providing a reasonable payback. Mill staff has
mentioned a three year pay-back,which is consistent with this estimate. The BRPP oxygen delignification
systems were installed in 1993. Since that time,the use of two-stage oxygen delignification rather than the
traditional single-stage systems has become well established in the industry because it normally reduces mill
operating costs. ThMf _a the Teeh Team hereve&q thig te,.r..,,.regy has ....,..._,,..Sed bey and being,.,.nsideFed
4ea ..Hie eFtainty"in 2001 to"highest„eftaint. , at this tifne
BRPP Comment- *Based on steep steel price increases since the 2006 Liebergott report, the capital
cost estimate is now on the order of S3 to 5 million. Potential pgvback is overstated. Blue Ridge Paper
agrees that second stage 02 delig on pine warrants further evaluation.
The Tech Team identified the following color reduction activity for BRPP: develop an engineering design
leading to installation of an additional oxygen delignification stage for the nine(softwood)pulping/bleaching
line. In 2001,the Tech Team estimated that this process change would reduce effluent color by 1,100 to 1,400
lbs/day. As noted above,even after the recent improvements to pine line delignification efficiency,GL&V
estimated that this change would reduce discharge by From the bleach plant on the order of 1000 lbs/day.
Andritz also evaluated modifications to the mill cooking process. These would require complete
replacement of the digester systems at Canton,which would cost(at least)several tens of millions of dollars,
if they are feasible at all within the mill's space constraints. The Tech Team concluded that modifications to
the mill cooking process do not merit further analysis.
Treatment of CRP Purge Stream for Color Removal
BRPP Comments—The suggested esperimenl to shut down CRP for an extended period is operationally
infeasible. The CRP process is cm essentietl pa•t of BFR and must at:hieve high upiinue to sustain a high
BFR closure rate. Without BFR, the Canton.Mill secondary effluent color will be at a minimum of
15,000 to 20,000 lbs per day higher than the current level gfperfortnance.. JEe.will continue to look at
options for ultennative handling nfthe CRP purge.streann.
Specific edits and eorrrntents follow:
The Chloride Removal Process(CRP)purge is a low flow,highly concentrated stream. Color is typically 41,000
platinum cobalt units (pcu)in a stream that discharges at 10 gpm(15,000 gal/day or 3 tank trucks/day).BRPP
reported that in 2006 the CRP purge contributed approximately 8,745 lb/day(23%)of the total mill color loading
to the treatment system but only 0.05%of the discharge flow. By comparison,in 2001 the CRP contributed
approximately 5,000 lb/day(13%)to the treatment system loading(EPA Tech Team,2001). 'Thus, in the last
five years there has been a significant increase in color contributed by the CRP,both in lb/day and in percent of
total mill load. BRPP reported on its investigations into technologies for reducing CRP purge color in its March
2005 report,"Chloride Removal Process(CRP)Color Reduction Technology Assessment" (Blue Ridge 2005).
In this report,BRPP points out that the CRP purge is a very concentrated material(360,000 mg/L or 36%total
dissolved solids)that is discharged to sewer at 165'F. Handling the material is difficult because it will

BRPP Comments on Draft EPA `(Draft Team"Report, 10 May 2007,Page 14
crystallize as it cools. Also, it is quite corrosive due to the high chloride content.
BRPP Comment-The increase in CRP purge contribution to total mill color loading is related to other
color improvements including increased BFR closure rate.
As described in their 2005 report,BRPP assessed more than nine alternatives for disposal or treatment of the
CRP purge and concluded that none was technically feasible. Although consistent performance was not
demonstrated,C102 bleaching was a low cost,potentially effective means of reducing the CRP purge color prior
to discharge to the treatment system.BRPP found that C102 bleaching could remove 75 to 90%of the color in
the CRP purge stream.
BRPP Comment- Color removal horn C102 bleaching of CRP daring pilot scale trials ranged,%rorn cero
l0 90 percertt imd rwas very inconsistent. Foaming was ectr•erne. Process control ivas very cl(Uieull.
Based on the extended pilot scale testing. C102 bleaching of'CRP is not considered operationally
feasible.
Although CRP purge is a relatively low flow stream,BRPP estimated that off-site solidification and land
disposal would cost more than$3.6 million/year.
During the Tech Team's 2007 mill visit,BRPP stated that there was no apparent decrease in secondary effluent
color when CRP wastewater was not flowing into the treatment system. In response to a Tech Team request,
BRPP presented data correlating the days on which the CRP process was shut down with secondary effluent
discharge color, for August 2006 to January 2007(Blue Ridge 2007a). During this period,there were nine
widely dispersed pairs of days when the CRP process was down for part of the day. RR RR,.„„,.lulled that C-R R
PF)IAF iiq Fem-oved in the seeendary tFeatment system,based en an ANONLA analysis eemparing"down"days
with GRR „„erating days, The data analysis conducted did not indicate a difference in secondary effluent color
between days when CRP purge was being sewered and days when the CRP process was down. `these data
were not conclusive.
Thp,T-Psh Team Haps not agFee with this oonGlusien for the fellewing Feasens. Firstly,with one exeeptionolle
GarFespendwith the effluent sampling times in the mill system, go that th.pFe ig Be diFeet AAFFelatign an time'.
the effluent sample. FuFtheF,the faet that all GRP"eg' days aFe in pairs,suggests that GRP A-aq dwvn for
P@Fi@d that spapmed paFts of twa mill sampling days.
BRPP Continent-77rere,was no definitive conclusion. BRPP has reported the general observation
supported by limited statistics that CRP purge on and off sloes not appear to influence secondary effluent
color.
averageThe simple mathematieal
suggests that GR12 puFge stream eauses a Hduetian.in-effluent Polar-, which defies cernmon sense. Also,th
O
,tending to subsume and oonfound any analysis of the impaet o
ohanges in the GRR pufge stream
ealer. in eFdOF tO explefe this furtheF,BRPP should Gondud a fi.111 quale mill tfial in whiek the GRP in shot4,because theFe. afess fe,,,,eAnwet itive dayswithout a CRP purge,the data from the paFiod August to

BRPP Comments on Draft EPA `Draft Team" Report, 10 May 2007,Page 1;
thfee weeks, and allew the ehlefide eeneentratien to build up in the reeevefy system. Early liteiattiFe publis
This is eansistent with experienee in etheF Enills, and is due to the fact that thO quaRtit), Of Ohlefid0s afld
The seeend appFeash would he to qtefe the GRP pufge stream,either in the spafe slaFifier eF off site.feF a period
The impmt of exeluding the CRP purge ff em the wastewater tf eatntent plant would be absen,ed by Foutine
analysis ef effluent Golan if the effluent ee!E)F witheta the G"purge is unshanged,BRPP would eenelud
the GRP puFge eenifibutes little to the final effluent eeler. In this ease,f4ther research into redueing CRP e-1—
On the etheF hand,Wt�e. Affluent AslaF wk,4eut the GRP pufge deefeased,BRPP would sanglude.that the CRP
feoeveFy beileF systems. This eaM,av@F Gould.he eliminated ifthe two tFaditignally designed reeeveFy beilm
(whiek are 34 and 42 years old)weFe FeplaGed by one madem boiler. ThisweHld probably represent a eapi
cost of ever$100 million,and would veFy substantialb,Feduee the energy easts at the mill,sinGe today's bei
afe mueh mefe offiGiont than these of.the vintage installed at Canten.Analysis of all 4he eGaneFflies and 18HE
tp,rm life of the«.nl . eula be neeessafy to evaluate such a estme..t
in the existing DGE'q. The Teeh Team iq not awaFe Of aft)'WkpffieHGO With thiS in OtheF milk, OF FOSeamh,but
the situation at Canton stFangly suggests that at least some investigation and tFials of tn th
}-use-could
reduce the quantity ef AfilgFid-e to he femAi,ed in the GRP purge Ftrearn. if this iS FeduGed,the e9loF discharge
BRPP Comment- Clunnpion did an ecrtensive investigation of'DCE can rover ofsolids into CRP and did
not identify atn viable solutions.
BRPP could also further investigate C1O2 treatment and other treatment of the CRP color and other
approaches for excluding the CRP purge from the mill discharge.
Additional Color Reduction Strategies Not Previgusl• Analyzed by Teek Tea
BRPP Coninzent-2I11 of the items helii}v were,discussed in the past Go-the TRIV: See page 3 ofJuly 25,
2001 TRW report
Thp,T-Rph T-Ram itipstified the following color reduGtion activities for ifflPFOViRg thO GGIGF Fenio-ed by the Canto
Mill wastewater tFeatment plant:
The following color reduction activities have been previously identified and evaluated for the Canton Mill. They
should continue to be evaluated.
1) Investigate color formation when acid wastewater is mixed with mill wastewater, and
identify techniques to reduce this effect;

BRPP Comments on Draft EPA"Draft Team'Report, 10 May 2007, Page 16
BRPP Comment-The Canton dull has been a leader in the pulp and paper industry oil the phenomena
ofservergenerated color. The mills extensive sewer color balance data first ideniilfed selver•-generated
color-as•an issue. The acid server project completed in January 2006($1.5 million capital cost)was a
specific measure to reduce the sewergenerated color elect. Secondary effluent color has been reduced
as a result.
2) Add polymer and/or other treatment chemicals upstream of the secondary clarifiers;and
BRPP Continent- The Canton[hill hav evaluated end-of-pipe treatment of this type in detail. Yhere are
many problems with this 11pe oj'rreatment approach.
3) Add polymer and/or other treatment chemicals to the high-color wastewater diverted to the
extra primary clarifier.
BRPP Comment The Carton dill has been doing,this for years and null continue to do so:
These strategies are discussed below.
Color Formation When Acid Wastewater Is Mixed With Mill Wastewater
BRPP Continent Blue Ridge Paper will continue to study and evaluate opportunities to continue to
reduce sewer-generated color.
efflu"sampled afiff thA Agid qW.A.'AF iq added.iq akA qhAv.,11 An the f4gUFe(the Uppef(Fed BRPP provided the Teeh Teamwith daily eeler data for the"Lew Lift"(mill se'Wer), *4
Thus,the figure depiets the impaet of mixing the Kid SeWeFlfflith the Fest ef the fail!effluen
l ell the figui:e�
The Te..h T-Pam a4gPF,Pd.
The quantity of eal....f.coed- .. filiming the aoid seweF and mill sewer is stAking On a e the
quantity of ealer famied is 0 of the total ealer in the twe stieafils- In atheF ,
mixing the simple Faixing
is evident in the gFaphs. When expressed as a percentagebFpFirriaF5,input GOlOF,the value FangeS fiefn
-. The..e:.. ng Ah-inug sarFpletisn hew,pen the values an any are day,eF..eFies of days elese w ene
afieflieF.
The Teeh Team suggests that BRPP investigate strategies f9F Fedueing the color fefmed whom the aeid seweF is
inixed with the rest of the fail! effluent. BRP12,eould invesfigate,among athef:things,how sulfides iatreduGed*
leaks,spills,and unplanned disehaFges frem wh . — .. . I #Rmq into the m-ill wAstewater eantFibute
to effluent enign In pai4ieular,BRPP eould investigate whether sulfides in the Fail!wastewater contribute to
eeler fermation when aoid sewer is added to mill efiluent prioF to biological tFeatmem. AppFeaelies to this
investigation ifioludd8:
T aberatgF .expeFiments an effluent with..e....:ng degFees of,....J:..m sulfide addition; an

BRPP Comments on Draft EPA "Draft Team"Report, 10 May 2007, Page 17
inmost mills,lasses of sulfides eanbe redueed Well linAwn qn-iree;include imbsignee in!be weak was
system,aswell as spills afwhite,blaek,and green liquor. BRPP ShOUld fUFth@F investigate losses fFom the gFee
: 150,000
'Total'uritrealed color,.tefore and after mixing,2006 VWday) ,
125,000
100,000
. . i r )-
75,000
50,000
PI
25,000
14" 314xn 14,1er 31N.r WApr 30- ay 294un 29Jul WAup 27Sep 27-0ct 26 ov 26-0ee
mill effluent. .
Improving W WTP Performance Using Polymers
BRPP Continents—
Blue Ridge Paper currently uses polvanine to batch treat color-material diverted to the spare clarifier.
This is the otl L use gfpolvamine that the have found effective. Polyamine is of ective for•treatment of
brolrn color—color from black liquor solids—but is not effective for treating hleach filtraie color-. It is
also not effective for dilute brown color. The majority gfcolor in the Canton Mill wastervater•effluent is
related to bleach plant filtrates.
The rise ofpolyarnine in the secondary treabnent system is operationally infeasible. at this time,for a
number of reasons:
• Thepolycrntine adversely affects sludge dewa(ering.
• The polyamine can result in chronic tonicity in the treated wastew•q(e•e%fluent
• The polyamine builds rip in activated sludge causing probhuns with settling and overall
treatment effectiveness
• High cost treatment
In 2005, the Canton Hill dirt an ertended pilot scale trial oftertia v color tr•eatrnentusing polymer
coagulation and ntic•rofilfratiat(Pall Filtration studv in Figure 1 gf the May 2006 Color Compliance
Repoq). d nurnber of different polvnrers Here rested including polvandne and potynhaninrun chloiide..
There was no significant reduction in secondary effluent true color front polymer-added filtration. The
reason for this result is the absence of brown color in the Canton Afill effluent. Pollaner coagulation is
not of crive on bleach plant ftlrrate color, the majority gf the color in the Canton Mill treated seconday
effluent.

BRPP Comments on Draft EPA"Draft Team"Report, 10 May 2007, Page 18
bodies,then femove the fiFeeillitate in WF4iaFy slarifiefs. One of the newest ef these mills is Gelee in Waldh,iaT
Ghile.Thig mill hp-q exeellefit in plant effluent eeniFiil, a eanventional seeefidaq wastewatef tFeatment plant,
fellewed by a small tel4iatty system.Effluent ffem this mill is depleted in FiguFe 2,se)(4 te effluent ftem B
installing teFtiaiy tfeatnien4 systems. These systems use pelymers and other ehentioals to preeiiii4ate eale
r
L ' r
Figure 2: Comparison of BRPP Canton Mill Effluent(February 2007)and Valdivia dill Effluent
(November 2005)
BRPP Comment- This is an inappropriate comparison ivith different size containers and different
contrasting backgrounds. This is not an appropriate comparison and not appropriate in a technical
report on color reduction technology.
usingTreatment systems like the one epeffited at Valdivia have a eapital eest in the tens of millions of dollms,alld
earl create issues with solid waste disposal. HeweveF-,same mefe mad-eqt egntfAl inpasures
vafiations of
this technology also exist. FaFe�Eafnple,sifleeD!aFoh2Qg4,Glatfelter'...-.,
sludgewhich is held in the fe�er stabilization basin before dewatering. Glatfelter have not reported sludge
dewaterin
b.
a .
BRPP Comment-Representatives from the Valdivia, Chile Mill visited the Canton Mill in sunmter of
2000 to review our success with in-mill color prevention,specifically bleach filtrate recycling. The
motirntion for their visit was to identi,alternatives to their vet),expensive and sludge intensive tail-
pipe color treatment system.
BRPP could conduct laboratory trials of commercially available polymers and other wastewater treatment
chemicals,adding them upstream of the secondary clarifiers. During these trials BRPP would determine the
potential for reducing color discharge and estimate the costs. Such analysis would consider seasonal use of the
additive chemicals(i.e.,adding the chemicals during periods when river flow is low and the mill discharge has
the greatest impact on the river color).

BRPP Comments on Draft EPA"Draft Team"Report, 10 May 2007, Page 19
If the laboratory trials are successful,BRPP could institute a full-scale trial fer one month,and report results
to the Technical Review Workgroup.
Pretreatment of Diverted High-Color Wastewater
BRPP currently diverts up to one hour of total mill flow to their off-line I-million-gallon clarifier,during high
color releases. The purpose of this flow diversion is to equalize color discharge to wastewater treatment plant.
Diverted high color wastewater is batch treated by polyamine.then drained back into the wastewater treatment
system.
However-, examination of the pFimaFy elaFifie.F effitlent data indinntg that the mill Pen iflues to experienee 3
40 days per year of high ealor leads(>109,009 May)late the Feeendmy tFeatment system. BRPPeouldk-eat
Summary: Additional Identified Color Reduction Activities that BRPP can pursue in the Next Five Years
BRPP Comments-BRPP disagrees with the assertion that we have not adequately implemented the
strategies identified by the TRIP"
As required by the ArPDESperntii, Blue Ridge Paper evaluated all of the 2001 TRIFreconunendations.
implemented those that werefeasible, and developed alternative technical approaches to achieve the
color reduction goals in the permit. Upon detailed examination, the 'Reasonable Certainty"items in
the 2001 tVPDESperntit were not technically, economically or gperationallv,feasiblef n-the reduction
oj'effluent color•. .9ddilionahhv, while the mill achieved significant influent color reduction, the actual
elfhrem color reductions from the Highest Certainty items were less than forecast by the TRI3: The
projects implemented by Bhte Ridge Paper-that achieved the greatest effluent color reductions-the
hardwood brownstock cashing improvements, and the acid seover project—were not envisioned by the
TRji'. The Canton Mill ntet the color reduction goads in the 2001 NPDESpermit using a combination of
projects identified by the 7RN and additional projects identified by the mill. The many color reduction
initiatives pursued by Blue Ridge Paper that went "above and beyond permit requirements"should be
recognized for both the effort involved and for the success of those initiatives that worked.
Edits and specific contnterzts follow. Details for edits arc in ova•c•onunents for specific sections o.f the
draft report above:.
Mill process changes that reduce wastewater color are generally preferred to end-of-pipe treatment because they
may have lower capital costs and may benefit the mill by reducing operating costs. However,mills in
environmental regulatory jurisdictions with severe restrictions on their color discharges have been required to
implement end-of-pipe color removal technologies since the 1970's. Although the Tech Team continues to
maintain the highest priority for in-mill improvements such as process changes and optimization and increased
black liquor recovery,external color removal technologies must now also rise to a higher priority than
previously and be considered carefully in the mix of options for further controlling the color of BRPP's
discharges. These color removal technologies include both end-of-pipe wastewater treatment and treatment of
segregated wastestreams(i.e.,the CRP purge).
The Tech Team identified numerens the following strategies, focused primarily on in-mill process
improvements,that BRPP ean use to further reduce its effluent color discharges. "lost of these strategies wet
identified
not adequately implpmentpd them. These strategies are summarized below.

BRPP Comments on Draft EPA "Draft Team"Report, 10 May 2007, Page 20
1)On the pine bleaching line,implement evaluate the use of peroxide fortification of the Eo stage
and decrease the target kappa factor as recommended in BEPER 2001 and 2006.
Evaluate the use e f high t.,....efatwe F .,r the .,foxide feFtified ext...etiO.. .a..ge
2) On the hardwood bleaching line,implement evaluate the use of oxygen and peroxide fortification
of the E stage and decrease the target kappa factor as recommended in BEPER 2001 and
2006. Evaluate the u of high te.....o_etum r_the. ,,:de f..t:aed extFastion stage
3) As Q02
ree8vered in ODD a I ....t.,.." II.......1......the purge Fate fief.the GRP
BRPP Comment- This is not technically possible. D stage hardwood is not recovered
in BFR.
4) Continue to improve the control of leaks, spills, and intentional diVeFSiGHS capture of black
liquor and other highly-colored wastewater:
• Move forward with the planned CRP sump and containment project to eliminate unplanned
releases of this highly-colored material to the mill sewer.
• Eliminate discharges of highly-colored wastewaters directly to the wastewater treatment
system. These wastewaters are generated during planned mill outages or diverted to the off-
line clarifier during mill upsets.Maximize recovery of these wastewaters and treat the
wastewaters that cannot be recovered to reduce color prior to metering them to the treatment
system.
5) Full), hwestigate the potential for haFdwead pulp ozone bleaehing te Feduee the mill's effluent
P.nlo CAnduet Q..wheF l.b aFateFy tFiale designed and implemented to provide Fellable
as .,,bined at the fn4l
BRPP Comment-Dr. Liebergott does not recommend ZD technology,for the Canton
AIM (page 18 o/'the 2006 Liebergott i GL&V repoir).
6) install Evaluate an additional oxygen delignification stage for the pine pulping/bleaching line.
As Cl9a-use on the pine r:..e is educed hIeFease the amounta.heal..a, d D alt.ete
stage
FePA—A
..ed :., DDD an ...ae..t:vu....ed..,.e the.....,.e.ate from the rDD
BRPP Connuent—IncreasingDl stage f ltrate:ecovery is not technically possible. D
stage hardwood is not recovered in BFR.
7) Continue to evaluate the impact of the CRP purge on treated effluent color. if GRP GoloF is not
investigateremoved in the treatment plant,
adjusting
Gofi!aGt evaperatons.Also, if GRP eeleF is n—st Fernaved in the.treatment plant, f4ther investigate
Q ,t­et...e..t..Fthe M2P purge to red..,.e its ..,vl.v prior to discharge to the mill , aste.....te.
item.
8) Continue to investigate strategies for improving the color removed by the Canton Mill
wastewater treatment plant:

BRPP Comments on Draft EPA "Draft Team"Report, 10 May 2007, Page 21
teehniques,suGh as minifnizing sulfide releases te the Fnill sewer ffem white and gFeeH lique
leek,. spills. e..are..diver-si..... to Fe.i..,.e this effect;
Of PE)15'MOF and 9theF treatment ehefnieals to the highly GeleFedwastewater diverted to
Effluent Color Variability
BRPP Comments—Several of the strategies listed are already used by Blue Ridge Paper and are areas
of continued evaluation and improvement. Other recoPntendations are impractical. Additionally,
severed ofthe recommendations have been evaluated before and determined to be lechnically,
economically or operationally inleasible. The section should be deleted.
Blue Ridge Paper agrees that reducing the frequency and magnitude of high color events is an
important focus. BRPP also believes that we have deniortstrated significant progress'in this area. Our
pi imaty color control strareo-is to capture highly-colored materials in the process. During the current
permit tern, we increased storage volume.for black liquor materials by inter-connecting the pine and
hardwood spill systems. We made strategic improvements to spill sumps. conductivity meters and other
sysrerns bused on investigation ofcolov events. t3 itli carefl planning ofonfuge.s. ire niininrize losses of
highly colored materials to the Pill sewer.
The Canton riiill does treat highly colored material that is diverted to the spare priniary clarfer. This
diversion has been a perntit requirement since 1997(ref Low Flory Contingency Plait dated December
1, 1998). BRPP adds polyontine to treat this material in batch and them slowly feeds the chemically
treated ntatcrial back into the ii,astewater•treaanent s,stem. tVc also have action levels ffn-adding
polyandne to priman-treabnent to treat highly-colored materials that are not(liveried. These
recommended strategies are al early in place and are effective.
Variability in daily color during the perntit ter In has improved as outlined in the tables,for primary
influent and seconrlan,effluent color listed below. The two days greater than 100,0001b/day in 2006
were related to a single process problem that hers not occurred since CRP startup in the mid-1990s. All
engineering control for t/tis problem is plartnerl for'installation in 3007.
The best effluent color perfor narrce occurs when the pulp mill is running steady al'noramal production
rates. Elevated color tends to occur when file pulp mill is slowed back or when bleached pulp
production rate is tip and Clown due to egiiipirteru or other•process problems. The,greatest risk c f black
liquor color losses and spills occurs during process shutdowns and startup, and is the reason we do not
take outages during lose flon,'recreation periods as detailed in the Low Flom Contingency Plat
required 1n the perntit. Tlie idea of curtailing prodactirmt dmimg periods of low str'eani flow;votdd likely
have the opposite afject desired.

BRPP Comments on Draft EPA'`Draft Team"Report, 10 May 2007, Page 22
Table 2.1—Primary Influent(Total Influent)Statistics by Year
Mean True Relative, Percent
Color Standard Number of ! Decrease
(Ibs/day) Standard Deviation days>100,000 From Baseline
Deviation SD SD/mean % lb/day 2001
2001 57,725 20,619 35.7% 4 0.00%
2002 54,790 17,195 31.4% 7 5.10%
2003 55,550 19,424 35.0% 9 3.77%
2004 49,466 1S,786 38.0% 8 14.31%
2005 45,175 22,297 49.4% 7 21.74%
2006 38A54 14,015 36.4% 2 33.38%
Table 2.2—Secondary Effluent Statistics by Year
Mean True Relative Percent
Color Standard Number of Decrease
(Ibs/day) Standard Deviation days>100,000 From Baseline
Deviation SD SD/mean % lb/day 2001
2001 42.676 10,925 25.6% 3 0.00°0
2002 41,166 9928 24.1% 0 3.54%
2003 44,627 11.043 24.7% 1 4.57%
2004 41,463 * 1 32,568 'k 76.6%* 4 0.43%
2005 39,092 10,092 25.8% 0 8.40%
2006 37,058 8959 24.2% 2 13.17%
"2004 dara were gffected by historic floods in Sep 2004
Since BRPP installed the BFR process the),have made gradual progress in reducing their annual average r;
disohaFges.Howeven,they eantinue ta expeFienoe many days peF yeaF of high soleF dis6haFges. When these
diSGhaFgOS GGifiGidO'A'ith PeFiGEIS Of 18M,FiveF f4ow(typieally in the late swntneF),the),cause an elevation in
riveF eelef that is notioeable to the eifizens who use the fiven Thus,reduetion ofthe imparts of the color
daily mwEimuEn color
These
dischafges and their impaet on the river. strategies
btlftlY�
T-Fet. 'ts.r diye.aed to the..FF line primai=yelar:Qer.
Segregate
pFierte metering:t inte the.,,:11 ste,.vier 1..eatrnent.. stem.
0 Pmvide additional equalization (increasing the tank volume available tn divewt and tFeat high!), sGIGrOd
"s'vc"mc'Ti..\.
- TFeat tetal mill effluent using polyrners of otheF wastewater tFeatment ehemicals,partietflady during
- if the CRP purge gs'qF k found�nAt to he Femaved qegAndary treatment,avoid releasing the CRP
.rb
Gui4ail pulp pr...i....ti..., A..r:.a..,.,r:,..l,. ..F h,....tr......, Fl,,...

BRPP Comments on Draft EPA"Draft Team"Report, 10 May 2007, Page 23
Suggested Final Effluent Color Limits for Blue Ridge Pulp and Paper
BRPP Contents— The 2001 NPDES permit inchides annual average and monthly average color limits.
The compliance period is even-calenttar year aad ei,ery calend(ir ntonih. The reporting period is
monthly based on(tail),composite samples. t(irste load f actors used for BOD and other eotiventional
waterpollulants are not approprialefor color liinils. In addition. the Tech Team has no responsibility
or mandate to determine water quality stumlards based oar effluent limits for the still;that activity will
be done by the state as part of the permit development process.
In the December 2005 report required by the NPDES and submitted to Alan Klimek o(the NC Division
o1'1Tater Qualinr, Blue Ridge Paper stared its cotnnitnrenl to continued color pe{forinance improvement
and recoinniended an anal average.secondary effluent trite color limit of 39,000 Ibs per dqv and a
monthly average true color effluent limit of 52,000 Ills per day. 114:continue to suliport mt atntual
average effluent color goal in the range of 3_',000 to 39.000lbs per day.
The Teeh Team Feeernmends s1fongly to the TRAI that the,Nnith Carolina Depawneat nf EnviFAtunent and
Natural Resewees expand the existing pemiit limitq to include.maximufn daily and FnEoEirnwn 30 day avefage
disehaFges,and not Fely selely on the annual aA,eFage lifflit tO PFOte6t the quality of the Pigeon River.Daily a
Fnenthly pefmit limits would be eensistentwith limits for-etheF parameter-s lifnited in the presefft peFinit as-
as with limitations for other pulp and paper mills nationwide.-
BRPP Comment—The preceding and following pmngraphs are not only incorrect(i.e. the effluent
limits for the mill have ahreys been at the end-of-dte pipe), the'v also include nun-technical hyperbole
such as "consistent with---limitationsfin'otherpulp and paps<r mills natiotnvide", "critical point in
tine"and wrongly implies that there has been a problem demonstrating conipliance with permit limits
and that somehow adding additional purnmetcrs "will siniplrf&and facilitate compliance monitoring".
MoFeover-,the Teeh Team al-go helieveg qti:ongly that these effluent Rhauld be applied at the end &f-
progressdilution). Given the substantial and sommendable BUP beeler disehaFges
and the b
goingT-eeh Team
permit limits will simpjif�,and faeilitate eornplianGe menitoFing. End efpipe peFinit litnits also will be
Table 3.Tech Team Recommended Range of End of Pipe GOIOF Permit Limits
Limit Rengref-Reeerttnmmkd-Uimits{ lay)
nMeFage 32 nnn.,,37,09
30 yeffige 44,898-(9-3-1-,,89
Baily Mffl imam 93,949te 96,94daily measurements fOF 2006 identified two days(july 7 and 9) vith m-emi-Fed Basis for Recommended Annual Average
b b
!Wday. BRPP FepeFted that this elevated eelof disehafge resulted ffem"GRP sluM,tgnk aveFflnv,for 20 e
first time the mill expefieneed this type of pwpnt ReeAuqe thes

BRPP Corrunents on Draft EPA "Draft Team"Report, 10 May 2007, Page 24
G and T Annual average F 7OML ..1.. ..1..Z
r ,without T
at cne lb/day,Founds to 37,000 lb/day This annual ayeFage lead is less the.,the an nnn lhrday
sqggested by BR:PP. However, it is based on the mill's 2006 peFfBmafiee and does flat inelude
aH5'FOdHGtiOBS that may be aehieved by the PFOGess shaHges eutlined in this MAMA. Aq A.Fe-quit
analysis of the BDDD..sill dis6b ages by the Teeh Teem and other. ; support o fthe 2
pe7...:t the peFFnitt7 intefim vale.. A goal ..sass vo nnn lh/de with a Fange tip to an, hr nnn lde.. s
..
leaks,deseFibed eaF!ieF iH this meme,BRPP has yet te implement sevml ef these key pFeeess
implementing the use of peremide and exygen feftifleation of the Ee stage and d0ffeasing the taF
kappa faotm on both the pine and!he hardweed bleaehing lilies;
spills,
and intentional diversiens (not simply metering
disehaFges to the tmatment pla.A. and
n6-
T....tell:....O
Tnstgllin r
--------
filtrates.
,.,.......,. DDDD L..e..Ot141-...Ie...em— 'tese..............].......,...e...,...ts the Tee/. Te..mreee......ends that the eod
for this v . fop the lono term ... ../..../:...b eonidimime ito
BRPP Comment—The following discussion, which sugge_rts that color at the Canton Afill should bare
daily limits Flared on BOD statistics f n-the pulp and paper industry, should be eliminated. There is no
need for daily color limits as discussed above. The annual and monthly color limits are protective Of
the Atorth Carolina [Pater Qualiry Standard.
Basis for Suggested Daily Maximum and 30 Day A-verage Limits
The statistieal analysis used for the development of EPA's Gluster Rules is documented in Stafisfical Support
development of-,ameng ethaF things,the vaFiability faGtOFS that were used to ealeulate NSPS f6F s fbF the
TAM. A Bleeehed Dope.-gFaJe V..eft NQDQ Ve.de6:lit..Factefs
a r
L�..� aAabitl�'-rfll'(Of5
�"'JT
BBB3 2,62 4,4
SOUFee. U.S.Q EPA 1997. Table 2 A
The OD5 vmiability faeters shown abeve were developed using daily menitering data for the best peFfeFming
(in terms of production normalized BOD�load)BUV mills. The monitoring dat.. represent the effluent frarn well
daily loads. and the lee normal distribution ofthe measuFernents•
The Teeh Team believes that it is reasenah1p.to 'Isp thp A'afighilit),faeters developed fef the RpK NSPS; fOF
e calculate BDDD de:L.maximum ^n de.. eb..e ..,a. I:...a.. F 7,.e1,.7 hee......
&t e,
Th@ faPtAFS WON developed using monitoring
treatment and BDDD :v a BDV ..sill y4th ..ell operated seoondwy tmatfnant.
Color,
like BOO; is monitored at the effluent of the seeendary treatment plant. e..d
/`..L.7 l:l.e B/lTl. ed C...., efFl..e..♦by.. e,..„h:..eti.... of h:..d.....e .. ....det:ed
b

BRPP Comments on Draft EPA"Draft Team"Report, 10 May 2007, Page 25
absaFpIien/adseFpfion to biomass.
Applying OD3 %wiability faefefs to the 2006 annual avepage daily eelor discharge results in the felkAykig
Deily Maximum: 37,900 lb/day x 2.62—96,940-lb/day
(The Daily MmEinium and 30 day aveFage limits fer the long teFm aveFage goal of 32,000 lbiday aFe deFiN
the same manner)
CompaFing the 2006 effluent menitefing data to these limits finds that twe days exeeeded the daily fsw4mufm
my 7 104,504 lb
1..1..Q 101,223
•
These peFieds aFe listed in Table S.
Table G 0006 C.-ceed....ces of Suggested 30 day A-vet ge Effluent Limit
��
'`pff
�1.
'
August-7 70,6158
August-4 33489
1-2mvw 36
Comparison to Glatfelter Permit Limits .
BRPP Conrnrents— There are several mistakes in the evahtalion of Spring Grove effluent color and
comparison to the Canton.Hill. The Table 6 comparison is not correct artd should be removed from the
report. Our actual effluent color perfor prance, using pollution prevention approaches, is similar to the
Spring Grove Hill.
Bleached pulp production, not paper production, is the appropriate normalising factor fin•comparison
between ntills. Other factors that must be considered are the wood species and the ntiy of hardwood and
sgftivood pulp that is produced by a mill. Ile ratio of pulp production to paper production at the
Glatfelter Spring Grove is loner than for the Blue Ridge Paper Canton Mill. On art air-dried lon gf
pulp basis. the Spring Grove summer 30-dt{v average L fluent limit is egrtivuleni to—22 lbs IADTBP,
which is close to the Canton rlfill color performance. On an iJfheeut color concennnliorr brtezc,
perf n-mance gfSpr•ing Grove and the Carton Mill are.similm.

BRPP Comments on Draft EPA"Draft Team"Report, 10 May 2007, Page 26
.diseharge limits am levee. The mill's a a daily disehaFge is 11.9
BRPP pFeduees appFoximately 1640 US tons per day. Applying the Glatfeltei,limitl;to BR12Pwould Fesult in
helol.-Ahe Tech T-Am Feeemmended range of end of pipe p@Fmit limits for BRPP (4 4,800 to 5 1,800 lb"day
83,8 10 to 96,940 lb,lday inaiEiinum daily disebaFge). Table 6 eempaFeS the Glatfelter permit
lifnits to the BRPP recommended limits,presented en a pmduotiAn nai:maliFed hasig.
Table 6.Comparison of BRPP Reeemmended Range of PeMit I—iM-*tg Gfld GlutfeltPF Pffmit I
Refer-enees
e.
Annual Average 19.51022.
>n da3,Avefage .44 :17-1e-33
Da&t Maxixaml 22 3-1-te-39
Andritz Ahlstrom Sales. 2001. Pruyn's Island Technical Center Report 2001-068 Part 1. Laboratory and Lo-
Solids Cooking with O-Do-Eop-D Bleaching Sequences on Softwood Furnish from Blue Ridge Paper,Blue
Ridge,NC. Part 1 Softwood Results.Part 2. Hardwood Results.(December 6).
Audet,Andre,Michel Faubert,Zhi-Hua Jiang and Barbara van Lierop,PAPRICAN. 2003. Technical Service
Contract Report TSC-7447. Bleaching Evaluation for Effluent Colour Reduction. Prepared for Blue Ridge
Paper Products, Inc.,Canton,NC. October.
Blue Ridge Paper Products, Inc.2005. Chloride Removal Process(CRP) Color Reduction Technology
Assessment. (March).
Blue Ridge Paper Products, Inc.2006a. Color Compliance Report: Canton Mill.(May).
Blue Ridge Paper Products,Inc. 2006b.Blue Ridge Paper response to questions from the Technology Review
Workgroup(TRW) that were e-mailed on 28 Nov 2006. (December 19).
Blue Ridge Paper Products,Inc.2007a.Response to additional questions for BRPP about data provided io
TRW Don Anderson e-mail dated 5 March 2007(March 15)
Blue Ridge Paper Products, Inc.2007b.March 19, 2007 Additional Data Required from BRPP(March 28).
Bodien,Danforth G.2007. Site Visit Report,Blue Ridge Paper Products, Canton, North Carolina. (April
2007)
EPA Tech Team. 2001. Memorandum to Technology Review Workgroup. "Additional Color Removal
Technologies and Their Economic Impacts on Blue Ridge Paper Products, Canton,NC."(July 25,2001).
Furianic, Sean M.2007.Water Quality Protection Report,P.H.Glatfelter Company, Spring Grove

BRPP Comments on Draft EPA"Draft Team"Report, 10 May 2007,Page 27
Borough and Jackson Township,York County,for the Renewal of NPDES Permit No.PA 0008869.
PADEP Southcentral Regional Office(draft, February 2007).
GL&V Pulp Group,Inc.and Liebergott&Associates Consulting. 2001.Bleach Environmental Process
Evaluation and Report.Prepared for Blue Ridge Paper Products, Inc. and Clean Water Fund of North Carolina.
(June 8)
GL&V Pulp Group, Inc.,Liebergott&Associates Consulting. 2006.2006 Update: Bleach
Environmental Process Evaluation and Report.Version containing manufacturer's proprietary
information.Prepared for Blue Ridge Paper Products,Inc. (July 7,2006)
Munro,Fred and John Griffiths. 2000.Operating Experience with an Ozone-based ECF Bleaching
Sequence,Proc.International Bleaching Conference,Halifax, Canada,2000.TAPPI Press.
Technology Review Workgroup,2001.Memorandum to North Carolina Division of Water Quality and
the NC Environmental Management Commission's NPDES Sub-Committee. "Additional Color
Removal Opportunities, Blue Ridge Paper's(BRP) Canton,NC Bleached Kraft Paper Mill, 2001
NPDES Permit Renewal." (August 3,2001).
U.S. EPA, 1997.Statistical Support Document for the Pulp and Paper Industry: Subpart B. (November)

SITE VISIT REPORT
BLUE RIDGE PAPER PRODUCTS, INC.
CANTON,,NORTH CAROLINA
2nd Draft Report
Prepared by
Danforth G. Bodien
15 March 2007
Blue Ridge Paper Products comments%Edits 20 March 2007

BLUE RIDGE PAPER PRODUCTS INC.—CANTON, NC
1.0 SUMMARY..........................................................................................................................................1
2.0 INTRODUCTION.................................................................................................................................1
2.1 Mill Visited................................................................................................................................ 1
2.2 Date of Site Visit...................................................................................................................... 1
2.3 Visitation Participants
2.3.1 BRPP Representatives &Consultants:.......................................................................1
2.3.2 EPA/Contractor Representatives.................................................................................2
2.3.3 State of North Carolina Representatives....................................................................2
2.3.4 State of Tennessee Representatives.......................................................................... 2
3.0 MILL STATUS UPDATE AND PHOTO TOUR...................................................................................3
4.0 MILLTOUR.........................................................................................................................................3
4.1 BFRw........................................................................................................................................3
4.2 Pine Line OD & Brown Stock Washing.................................................................................3
4.3 Control Room...........................................................................................................................3
4.4 Screening &Sumps ................................................................................................................4
4.5 Knot Rejects and Acid Sewer Reroute..................................................................................4
4.6 Other.........................................................................................................................................4
5.0 BUSINESS REVIEW...........................................................................................................................5
6.0 MAJOR ENVIRONMENT PROJECTS...............................................................................................5
6.1 Pigeon River Recovery Project..............................................................................................5'
6.2 Air Pollution Control Projects................................................................................................5
6.3 Post Flood Wastewater Treatment Projects.........................................................................5
6.4 Color Improvement Projects..................................................................................................5
7.0 COLOR PERFORMANCE REVIEW...................................................................................................6
8.0 BRPP PROPOSAL FOR POTENTIAL PROJECTS DURING NEXT PERMIT TERM ......................6
8.1 Pulp Mill....................................................................................................................................6
8.2 Recovery..................................................................................................................................6
8.3 Color Monitoring......................................................................................................................7
ATTACHMENT A- List of Attendees
ATTACHMENT B - BRPP PowerPoint Presentation of Meeting Discussion Items (44 pages)
ATTACHMENT C - North Carolina Department of Health & Human Services - Notice of
Removal of Last Fish Consumption Advisory for Pigeon River Below
Canton Mill
ATTACHMENT D - Simplified Wastewater Flow Diagram
ATTACHMENT E - Color Loading to Mil Sewer Areas
ATTACHMENT F - Canton Mill Sewers Color, Conductivity, Flow and Fiber Loss
ATTACHMENT G - Effluent Photos

PPFPP'
SITE VISIT REPORT
BLUE RIDGE PAPER PRODUCTS INC.—CANTON, NC
1.0 SUMMARY
This report describes a mill visit by the Technical Review Workgroup (TRW) including EPA staff
and contractor to the Blue Ridge Paper Products, Inc. (BRPP) mill at Canton, NC. The purpose
of the visit was to review BRPP's evaluation and installation of projects undertaken during the
past National Pollutant Discharge Elimination System (NPDES) permit term directed toward the
reduction of color discharged and to discuss color performance and the TRW information request.
2.0 INTRODUCTION
2.1 Mill Visited
Blue Ridge Paper Products, Inc.
Canton Mill
175 Main Street
Canton, NC
2.2 Date of Site Visit
8 February 2007
2.3 Visitation Participants
A sign up list of visitation participants is provided as Attachment A.
2.3.1 BRPP Representatives &Consultants
Robert V.Williams, Director Derric R. Brown, Director
Regulatory Affairs Environmental Health &Safety
BRPP BRPP
Canton, NC Canton, NC
828-454rPSDi i-0687 828-646-2318
646-2033 browndb(@blueridgepaper.com
willib()blueridgepaper.com
Paul S. Dickens, Manager
Michael P. Ferguson Environmental Affairs
Pulp Manufacturing Superintendent BRPP
BRPP Canton, NC
Canton, NC 828-646-6141
828-646-2461 dickepCa)blueridgepaper.com
ferguma(a),blueridgepaper.com
Mike McGhee
Glenn Rogers BRPP Consultant
Water Compliance Coordinator Lawrenceville, GA
BRPP 770-962-4417
Canton, NC 828 9462874
828rrso2i-646-2874 rmcghee2na bellsouth.net
77"62 4447
rogerg(a)blueridgepapers.com Forrest R. Westall, Sr., Project Manager
McGill Associates
Dr. Norman Liebergott, Ph.D. Asheville, NC
Liebergott&Associates Consulting Inc. 828-252-0575
Cote St. Luc, Quebec, Canada forrest(d)mcgillengineers.com
514-369-5575
liebergott(ailsvmpatico.ca

ppppp�
2.3.2 EPA/Contractor Representatives
Donald F.Anderson M.Ahmar Siddiqui
Senior Environmental Engineer Chemical Engineer
Engineering and Analysis Division Engineering and Analysis Division
U.S. Environmental Protection Agency U.S. Environmental Protection Agency
Washington, DC Washington, DC
202-566-1021 202-566-1044
anderson.donaldfno epa.gov siddigui.ahmar(a)epa.gov
Karrie-Jo Robinson-Shell, P.E. Danforth G. Bodien, P.E.
Environmental Engineer Consultant
US EPA Region 4 ERG Inc.
Atlanta, GA Kirkland,WA
404-562-9308 425-828-0170
shell.karrie-io(@epa.gov danna bodien.org
2.3.3 State of North Carolina Representatives
Sergei Chernikov, Ph.D. Roger Edwards
Environmental Engineer II Surface Water Protection Supervisor
NC Dept. of Envir. & Natural Resources NC Dept. of Envir. & Natural Resources
Division of Water Quality Division of Water Quality
Raleigh, NC Asheville Regional Office
919-733-5083 ext. 594 Swannanoa, NC
sergei.chernikov(cDncmail.net 828-296-4500
roger.edwards(d ncmail.net
23.4 State of Tennessee Representatives
Paul E. Davis, Director dea lbsidVoKifam than Burr
Tenn. Dept. of Environment& Conservation Tenn. Dept. of Environment& Conservation
Division of Water Pollution Control Division of Water Pollution Control
Nashville, TN Knoxville, TN
615-532-0625 423-594-5520
paul.estil.davis(a)state.tn.us lonathon:burr(r)state.tn.us
David McKinney
Tennessee Wildlife Resource Agency
Environmental Services Division
Nashville, TN
615-781-6643
dave.mckinney(a state.tn.us
3.0 MILL STATUS UPDATE AND PHOTO TOUR
BRPP provided everyone with a 44 page packet containing copies of a PowerPoint presentation
for their portion of the days discussion, see Attachment B. This report will supplement or
expand on the material provided.
Bob Williams stated that the industry and the market have changed over the course of the last
permit and that the Canton mill is a"world class performer,' in terms of effluent color discharges.
He explained that the mill has reached this status because they employ Bleached Filtrate
Recovery(BFRTM), elemental chlorine free bleaching, oxygen delignification (OD)on both
fiberlines and the most intensive monitoring system in the world. The mill has also incorporated
the use of a one million gallon (MG)off-line clarifier to contain and treat off-spec discharges to the
wastewater treatment system (WWTS). At the present average primary influent wastewater flow
of approximately 2926 MGDIPSD41, the detention time of this clarifier is about one hour.

ppppp�
Mr.Williams also provided a copy of a 9 January 2007 News Release issued by the North
Carolina Department of Health and Human Services entitled "State Removes Last Fish
Consumption Advisory Below Canton Paper Mill", see Attachment C.
4.0 MILL TOUR
4.1 BFRTM Facility
The first stop on the tour was the BFRT" area where we were shown the new sand filtration tanks
for the Metals Removal Process (MRP). These are the third generation for these tanks that were
originally epoxy coated carbon steel. The sand in the filters eroded away the epoxy coating
subjecting the carbon steel to the corrosive liquid causing failure. The second generation
involved cladding of the carbon steel tanks with stainless steel (SS).The SS cladding proved to
be resistant to the corrosive waste, however, the large temperature swings in the process
resulted in cracking of the cladding exposing the carbon steel. The new tanks are made entirely
of 2205 SS and according to mill officials are working well. In addition to this change, an
additional filter body was added so that one filter body can be taken off-line for maintenance
without impairing recovery efficiency. The throughput of this process is about 800 gal/min. The
resin life for the FeG argGion exchangerrsDst units is running about three months which has net
changed declined slightly over the past five year period.
PAII Felpresen atives state •ham R -�ps iR the Ghleride Removal PF G ^ G 4_ eFe MplaG^ed
in-or�e�tapce4eng-pump-4i#e:
4.2 Pine Line OD and Brown Stock Washing
The mill replaced its positive displacement stock pumps on the pine and hardwood (HWD)OD
feed with centrifugal medium consistency pumps. These replacements resulted in higher
pressures in the OD reactors and concomitant higher degrees of delignification.
Interlocks have been installed on filtrate tanks so that when they reach a level which will cause an
overflow they shut done-down psm the process. These filtrates which contain color has thus
been removed from entering the WWTP.
The mill has installed a screen rejects press to extract more of the liquor prior to discharge of the
solids to the WWTP. The idea for this came from a visit to the P. F. Glatfelter mill at Spring
Grove, PA.
4.3 Control Room
Bleach plant operators manage BFRT . By increasing the reliability of BFRT , though changes
discussed previously in section 4.1, BRPP has increased the BFRTPd closure rate from 73.7
percent in 2001 to 79.2 percent in 2006. Mill representatives stated that the present closure rate
of approximately 80 percent represents the maximum amount attainable without incurring
unmanageable corrosion and scalingrrsmi problems.
The mill operates with a Distributive Control System (DCS) plus PI (Plant Information)system. In
addition,working with Metsa-MetsoLpsD91 the mill has installed in-line Kappa analyzers throughout
the pulping and bleaching process and has optimized these processes using a modified Kappa
factor control method.The mill can take samples every 20 minutes and can now track problems
to individual digesters to find and correct problems.
The mill operators have gone to two hour testing for color at the WWTP.The monitoring data are
entered into the mill data system as well as reported to the control room by t^'^^�^^e pulp and
recovery shift managers by mill radiOlvsDtol. If a high color is detected, generally a grab sample
is taken to verify the result prior to diversion of the wastewater flow to the spare clarifier. Prior to
and during an outage or semi annual shutdown, the mill goes to one hour testing for color and
only goes back to two hour testing after the completion of the outage or shutdown and the mill
has stabilized. Mill representative stated that they believe that two hour testing is more effective

PPFPF_
than conductivity probes in controlling color. They-alse new believe ttaa eyaew-in 2006, they
have a good handle on where all color is coming from in the mill. '
BRPP analyzed the process when color discharges are low. BRPP found that sewering Eo
filtrates results in lower secondary effluent color than sewering Di color to maintain BFRTM
closure. This is because Eo color is removed in the secondary treatment process. This filtrate
sewering strategy has resulted in an increase in Eo color input to treatment but lower color in the
secondary effluent.
BRPP has lowered conductivity set points from 2500 micrormhos to 2000 micromhos at many of
the in-line monitoring sites.
4.4 Screening and Sumps
Spill systems for the pine and HWD lines are now inter linked and plumbed so that tankage in
either line can be used interchangeably for spills.
After reviewing spill collection and control at the Glatfelter mill, BRPP has repositioned.
conductivity probes from their sumps to in-line. They also installed these probes at a downstream
angle to minimize hang up of fiber and to reduce damage from large solids that may be pumped
from the sumps. In addition, they now pump all collected spills to treatment rather than allowing
them to flow by gravity. Using this approach, they know exactly the quality and quantity of the
liquid being sent to treatment.
BRPP has where possible replaced packed seals with mechanical seals to minimize the amount
of tramp (minimally contaminated)water getting into the sumps.
4.5 Knot Rejects and Acid Sewer Reroute
Liquor draining from'the knot bins on both fiber lines is now directed to dedicated sumps where it
is pumped back to the process. If either of these sumps were to overflow,there is a secondary
backup sump for each.
Piping of acid sewer directly to the WWTP was completed in December 2005 and started up 1
January 2006. Mill representatives stated that the sewers were rerouted when other repairs were
being made at the WWTP. These repairs at the WWTP were necessitated by flood damage
caused by the two back-to-back hurricanes, Francis and Ivan, in September 2004.
4.6 Other
Evaporators are now monitored more closely for leaks and carry over. Clean outs are done on a
ten to twelye[PSD]21 week rotational basis and in-line conductivity meters are used for all
condensate lines. Fiber StFa^,eFS W8 a added to theovaperater-feed lines iR GFder-There are
fiber strainers on the evaporator feed lines[PSD131 to reduce fiber carryover. At the present time,
approximately 3000 pounds of color come from all condensates. Issues related to the
evaporators are due mainly to soap and some fiber. Mill representatives stated that the volume
of liquids sent to the evaporators has not changed over the last five years, perhaps, at most, eight
to 10 percent more.
BRPP discovered that recycling of bleach plant wash water plugged the decking of downstream
washers. As a result of this discovery, BRPP now changes out the media-decking on the pine
line D1 and Eo washers-en a sn^oa.ed r^utlnebasistrSD141. The cycle can vary from three to
five years, and BRPP is still learning what the optimum change out cycle will be: Cost per washer
e`er ?}1-s[r_sDi5j about$400,000.
The mill can now divert spills, etc to an off-line 1 MG clarifier. However, because of the mill
sewer configuration, BRPP cannot isolate spills from one mill area. They can only divert entire
mill flow. The clarifier volume can store about one hour of flow(when the discharge is at the
average flow rate). Because of this fact, they try to capture only the spill. The mill can add
polymer to the clarifier and have, on occasion, done so. BRPP prefers not to do this, however,

PPFFP,
because it results in sludge which is hard to handle and color reductions have not been
noticeable. Generally, BRPP will bleed the diverted wastewater to the WWTS over a two to three
day period.They will also bleed sludge to the sludge dewatering system (Andritz belt presses)
along with primary and waste activated sludge. Polymer is normally added to the sludge for
dewatering.
BRPP uses the term "brown color'to describe color that consists of larger color bodies with
longer chains. This material is colloidal in nature and is generally believed to be removed in the
WWTP. They believe that the CRP purge stream is brown color. They use the term bleached
color for color discharged after bleaching. This material is almost dissolved in nature and BRPP
does not believe that it is removed in the WWTP.
Training of operators with regard to spill prevention and control has been intensified over the past
five years.
Prior to the mill tour, we were informed by mill representatives that housekeeping was not up to
normal standards due to fact it was the first day the temperature had been above freezing in
about a week. In spite of this, all areas toured were free of stock spills and liquids running across
floors. In addition, liquids flowing in floor drains were very low with respect to both volume and
color.
5.0 BUSINESS REVIEW
John Wadsworth, Chief Financial Officer for BRPP, presented information on the health of the
industry and BRPP. He presented information showing that for BRPP's main market, uncoated
free sheet(UCFS), the drop in capacity for the past five year period was equal to the growth of
the previous ten years. This he opined was due mainly to the Internet's impact on printing paper.
Next he showed that U.S. paper mill shutdowns have accelerated with 98 mills closing during the
period 1997-2006. During that same period the employment has declined by 70,000 workers or
about 32% of the workforce. BRPP has operated in the red since 2001 and in 2006 they will also
take a loss. The year 2004 was a goad year for business and they would have shown a profit
had it not been the floods from hurricanes Francis and Ivan which cost the Company
approximately$40MM. Wadsworth said that the only reason BRPP has stayed in business
though this down period in the industry was through the sale of bonds. These bonds will come
due in 2008 and 2009.
Bob Williams stated that the good news is that for those still in the business, the price of the
product has increased, noting, however, the price of chips and fuel have also increased. Bob
believes that the Canton mill will be"the last man standing".
6.0 MAJOR ENVIRONMENT PROJECTS
6.1 Pigeon River Recovery Project
See Attachment B, pp. 17-18
6.2 Air Pollution Control Projects
One project remains to be completed. This relates to compliance with MACT I—Phase 2 and
involves the installation of a Regenerative Thermal Oxidizer(RTO) unit. For costs and other
projects, see Attachment B, p. 18
6.3 Post-Flood Wastewater Treatment Projects
See Attachment B, p, 14-15, 18.
6.4 Color Improvement Projects
Color improvement projects accounted for$5.9 million (23%) of the $25.9 million spent on major
environmental projects during the last permit term. These were categorized into three major

ppppp�
groupings, Highest Certainty, Reasonable Certainty and Lowest Certainty projects. The Highest
Certainty Projects were further subdivided into Process Optimization, Improve Spill Collection and
Improve BFRTM Reliability. Details of these can be seen in the handout provided, see
Attachment B.
The CRP purge stream averages only 15,000 gpd but contains about 23 percent of the color in
the primary influent. However, BRPP does not believe that treatment of the CRP purge stream is
the answer to further color reduction because they are convinced that this color is essentially
removed by the WWTP. Mill representatives stated that they have made runs up to 18 days
where CRP was not discharged to the WWTP and the color discharged in the final effluent was
actually higher than when CRP was sent to treatment[PSD171.
Piping of the acid sewer line directly to treatment(after primary clarification and prior to
secondary activated sludge)was completed in December 2005 and started up 1 January 2006.
This change has eliminated the sewer generated color from the influent to treatment,and in 2006
BRPP Row believes that they have a good handle on all color sources from the mill complex.
This change has, however, resulted in an increase in color when comparing the primary influent
and effluent. It should be pointed out here that the acid sewer line is added after primary
treatment but prior to sampling of the primary effluent(see Attachment D). BRPP
representatives stated that they believe that the color generated from the mixing of the acid sewer
line and the primary effluent is less than the sewer generated color of the past because the pH
swing is not as great.
7.0 COLOR PERFORMANCE REVIEW
Comparison of the present color balance to that of 2001 shows a number of shifts in sources of
color. The first is the elimination of the"unaccounted for"color which mill representatives believe
was primarily sewer generated color. The second is the increase in the pine Eo color, however,
HWD Eo color has decreased. The CRP discharge continues to be the largest single source of
color, however, as discussed previously in the report, mill representative believe that this color is
effectively removed in the WWTP.
Removal of color across the entire treatment plant now appears to be essentially zerolrSDi91.
Attachment E is a daily color loading sheet which is routinely prepared at the mill. For the day
shown, 18 January 2007, a color reduction of two percent is shown for the WWTP. Looking into
this further and comparing the influent to secondary treatment to the secondary treated effluent
shows that there is a 44 percent reduction of color which is more consistent with removals seen
at other facilities employing similar treatment systems.
8.0 BRPP PROPOSAL FOR POTENTIAL PROJECTS DURING NEXT PERMIT TERM
8.1 Pulp Mill
BRPP proposes the following items related to the pulp mill:
• Continue the replacement of the HWD BSW showers on the east and west deckers.
• Conduct lab scale peroxide trials for the Eo stage on both fiberlines
• Perform lab scale high temperature peroxide trials for the Eo stages on both fiberlines.
• Perform trials to eliminate the by-pass of HWD Eo filtrate to decker filtrate tank. Move to
decker showers or another washer.
8.2 Recovery
After nearly 10 years of operation of BFRTM, the mill recently experienced a large overflow of
CRP wastewater to the sewer. This discharge has resulted in a proposal to provide a dedicated
sump and containment project for the CRP.

PPPPP�
A second project in the recovery area would entail piping to collect Sarco Strainer wash water
directly to the Wash Water Tank instead of sending this water to the sump. This project would
also include the installation of flow meters on the lines to wash water tank to monitor the flow.
On occasion, the mill discharges green liquor dregs to the WWTP. BRPP has learned that
Glatfelter found that the sulfides in these liquors react with components in other mill wastewaters
to produce additional color not previously identified. To resolve this problem, BRPP proposes to
make improvements to the green liquor dregs filter feed and to upgrade the underflow pumps.
8.3 Color Monitoring
BRPP proposes to add second, independentrrsozol an the level of overflow protection on
recovery furnace cyclones and mix tanks. This would include temperature monitoring on such
overflows which would be tied to the process and Gause the process to shutdown would alarm so
operators can take appropriate corrective action.

ppppp�
Effluent from Blue Ridge Paper Products bleached kraft mill at Canton, NC
Bleach acid filtrate
--- Influent to-primary clarifier Treated efflluent from AST
Lao
I
3Z$ 131
�c fAlor +rut calif 13
� colyr

ppppp-
SITE VISIT REPORT
BLUE RIDGE PAPER PRODUCTS, INC.
CANTON, NORTH CAROLINA
2ntl Draft Report
Prepared by
Danforth G. Bodien
15 March 2007

ppppp�
BLUE RIDGE PAPER PRODUCTS INC.—CANTON, NC
1.0 SUMMARY..........................................................................................................................................1
2.0 INTRODUCTION.................................................................................................................................1
2.1 Mill Visited................................................................................................................................1
2.2 Date of Site Visit......................................................................................................................1
2.3 Visitation Participants
2.3.1 BRPP Representatives& Consultants........................................................................1
2.3.2 EPA/Contractor Representatives.................................................................................2
2.3.3 State of North Carolina Representatives....................................................................2
2.3.4 State of Tennessee Representatives.......................................................................... 2
3.0 MILL STATUS UPDATE AND PHOTO TOUR...................................................................................3
4.0 MILLTOUR.........................................................................................................................................3
4.1 BFRw........................................................................................................................................3
4.2 Pine Line OD & Brown Stock Washing.................................................................................3
4.3 Control Room...........................................................................................................................3
4.4 Screening &Sumps ................................................................................................................4
4.5 Knot Rejects and Acid Sewer Reroute..................................................................................4
4.6 Other.........................................................................................................................................4
5.0 BUSINESS REVIEW...........................................................................................................................5
6.0 MAJOR ENVIRONMENT PROJECTS...............................................................................................5
6.1 Pigeon River Recovery Project..............................................................................................5
6.2 Air Pollution Control Projects................................................................................................5
6.3 Post Flood Wastewater Treatment Projects..:.......................................................................5
6.4 Color Improvement Projects..................................................................................................5
7.0 COLOR PERFORMANCE REVIEW...................................................................................................6
8.0 BRPP PROPOSAL FOR POTENTIAL PROJECTS DURING NEXT PERMIT TERM ......................6
8.1 Pulp Mill....................................................................................................................................6
8.2 Recovery..................................................................................................................................6
8.3 Color Monitoring......................................................................................................................7
ATTACHMENT A- List of Attendees
ATTACHMENT B - BRPP PowerPoint Presentation of Meeting Discussion Items(44 pages)
ATTACHMENT C - North Carolina Department of Health & Human Services - Notice of
Removal of Last Fish Consumption Advisory for Pigeon River Below
Canton Mill
ATTACHMENT D - Simplified Wastewater Flow Diagram
ATTACHMENT E - Color Loading to Mil Sewer Areas
ATTACHMENT F - Canton Mill Sewers Color, Conductivity, Flow and Fiber Loss
ATTACHMENT G - Effluent Photos

ppppp-
SITE VISIT REPORT
BLUE RIDGE PAPER PRODUCTS INC.—CANTON, NC
1.0 SUMMARY
This report describes a mill visit by the Technical Review Workgroup (TRW) including EPA staff
and contractor to the Blue Ridge Paper Products, Inc. (BRPP) mill at Canton, NC. The purpose
of the visit was to review BRPP's evaluation and installation of projects undertaken during the
past National Pollutant Discharge Elimination System (NPDES) permit term directed toward the
reduction of color discharged and to discuss color performance and the TRW information request.
2.0 INTRODUCTION
2.1 Mill Visited
Blue Ridge Paper Products, Inc.
Canton Mill
175 Main Street
Canton, NC
2.2 Date of Site Visit
8 February 2007
2.3 Visitation Participants
A sign up list of visitation participants is provided as Attachment A.
2.3.1 BRPP Representatives &Consultants
Robert V.Williams, Director Derric R. Brown, Director
Regulatory Affairs Environmental Health &Safety
BRPP BRPP
Canton, NC Canton, NC
828-646-2033 828-646-2318
willib(a)blueridgepaper.com browndb(@blueridgepaper.com
Michael P. Ferguson Paul S. Dickens, Manager
Pulp Manufacturing Superintendent Environmental Affairs
BRPP BRPP
Canton, NC Canton, NC
828-646-2461 828-646-6141
ferguma dblueridgepaper.com dickep(g)blueridgepaper.com
Glenn Rogers Mike McGhee
Water Compliance Coordinator BRPP Consultant
BRPP Lawrenceville, GA
Canton, NC 828-646-2874
770-962-4417 rmcghee2(g)bellsouth.net
rogerg(d.)blueridgepapers.com
Forrest R.Westall, Sr., Project Manager
Dr. Norman Liebergott, Ph.D. McGill Associates
Liebergott&Associates Consulting Inc. Asheville, NC
Cote St. Luc, Quebec, Canada 828-252-0575
514-369-5575 forrest(g)mcgillengineers.com
l i e b e rg ott(a)s ym p at i s o.c a

ppppp�
2.3.2 EPA/Contractor Representatives
Donald F. Anderson M.Ahmar Siddiqui
Senior Environmental Engineer Chemical Engineer
Engineering and Analysis Division Engineering and Analysis Division
U.S. Environmental Protection Agency U.S. Environmental Protection Agency
Washington, DC Washington, DC
202-566-1021 202-566-1044
anderson.donaldf(alepa.gov siddigui.ahmar(a)epa.gov
Karrie-Jo Robinson-Shell, P.E. Danforth G. Bodien, P.E.
Environmental Engineer Consultant
US EPA Region 4 ERG Inc.
Atlanta, GA Kirkland, WA
404-562-9308 425-828-0170
shell.karrie-io(c epa.gov danno bodien.org
2.3.3 State of North Carolina Representatives
Sergei Chernikov, Ph.D. Roger Edwards
Environmental Engineer II Surface Water Protection Supervisor
NC Dept. of Envir. & Natural Resources NC Dept. of Envir. & Natural Resources
Division of Water Quality Division of Water Quality
Raleigh, NC Asheville Regional Office
919-733-5083 ext. 594 Swannanoa, NC
sergei.chernikov(a)ncmail.net 828-296-4500
roger.edward s(cD ncm a il.n et
2.3.4 State of Tennessee Representatives
Paul E. Davis, Director Jon0laoidRkKinney
Tenn. Dept. of Environment&Conservation Tenn. Dept. of Environment& Conservation
Division of Water Pollution Control Division of Water Pollution Control
Nashville, TN Knoxville, TN
615-532-0625 423-594-5520
paul.estil.davis(astate.tn.us ionathon.burr(astate.tn.us
David McKinney
Tennessee Wildlife Resource Agency
Environmental Services Division
Nashville, TN
615-781-6643
dave.mckinney(i7o stote.tn.us
3.0 MILL STATUS UPDATE AND PHOTO TOUR
BRPP provided everyone with a 44 page packet containing copies of a PowerPoint presentation
for their portion of the days discussion, see Attachment B. This report will supplement or
expand on the material provided.
Bob Williams stated that the industry and the market have changed over the course of the last
permit and that the Canton mill is a"world class performer,'in terms of effluent color discharges.
He explained that the mill has reached this status because they employ Bleached Filtrate
Recovery(BFRTM), elemental chlorine free bleaching, oxygen delignification (OD)on both
fiberlines and the most intensive monitoring system in the world. The mill has also incorporated
-the use of a one million gallon (MG) off-line clarifier to contain and treat off-spec discharges to the
wastewater treatment system (W WTS). At the present average primary influent wastewater flow
of approximately 22 MGD, the detention time of this clarifier is about one hour.

Mr.Williams also provided a copy of a 9 January 2007 News Release issued by the North
Carolina Department of Health and Human Services entitled "State Removes Last Fish
Consumption Advisory Below Canton Paper Mill", see Attachment C.
4.0 MILL TOUR
4.1 BFRTM Facility
The first stop on the tour was the BFRT area where we were shown the new sand filtration tanks
for the Metals Removal Process (MRP). These are the third generation for these tanks that were
originally epoxy coated carbon steel. The sand in the filters eroded away the epoxy coating
subjecting the carbon steel to the corrosive liquid causing failure. The second generation
involved cladding of the carbon steel tanks with stainless steel (SS).The SS cladding proved to
be resistant to the corrosive waste, however, the large temperature swings in the process
resulted in cracking of the cladding exposing the carbon steel. The new tanks are made entirely
of 2205 SS and according to mill officials are working well. In addition to this change, an
additional filter body was added so that one filter body can be taken off-line for maintenance
without impairing recovery efficiency. The throughput of this process is about 800 gal/min. The
resin life for the recharge units is running about three months which has not changed over the
past five year period.
Mill representatives stated that the pumps in the Chloride Removal Process (CRP)were replaced
in order to prolong pump life.
4.2 Pine Line OD and Brown Stock Washing
The mill replaced its positive displacement stock pumps on the pine and hardwood (HWD) OD
feed with centrifugal medium consistency pumps. These replacements resulted in higher
pressures in the OD reactors and concomitant higher degrees of delignification.
Interlocks have been installed on filtrate tanks so that when they reach a level which will cause an
overflow they shut done the process. These filtrates which contain color has thus been removed
from entering the WWTP.
The mill has installed a screen rejects press to extract more of the liquor prior to discharge of the
solids to the WWTP. The idea for this came from a visit to the P. F. Glatfelter mill at Spring
Grove, PA.
4.3 Control Room
Bleach plant operators manage BFRTOA. By increasing the reliability of BFRTM, though changes
discussed previously in section 4.1, BRPP has increased the BFRTM closure rate from 73.7
percent in 2001 to 79.2 percent in 2006. Mill representatives stated that the present closure rate
of approximately 80 percent represents the maximum amount attainable without incurring
unmanageable corrosion problems.
The mill operates with a Distributive Control System (DCS)plus PI (Plant Information)system. In
addition,working with Metsa the mill has installed in-line Kappa analyzers throughout the pulping
and bleaching process and has optimized these processes using a modified Kappa factor control
method.The mill can take samples every 20 minutes and can now track problems to individual
digesters to find and correct problems.
The mill operators have gone to two hour testing for color at the WWTP.The monitoring data are
entered into the mill data system as well as reported to the control room by telephone. If a high
color is detected, generally a grab sample is taken to verify the result prior to diversion of the
wastewater flow to the spare clarifier. Prior to and during an outage or semi annual shutdown,
the mill goes to one hour testing for color and only goes back to two hour testing after the
completion of the outage or shutdown and the mill has stabilized. Mill representative stated that
they believe that two hour testing is more effective than conductivity probes in controlling color.

PPPPP"
They also now believe that they now have a good handle on where all color is coming from in the
mill.
BRPP analyzed the process when color discharges are low. BRPP found that sewering Eo
filtrates results in lower secondary effluent color than sewering D1 color to maintain BFRTM
closure. This is because Eo color is removed in the secondary treatment process. This filtrate
sewering strategy has resulted in an increase in Eo color input to treatment but lower color in the
secondary effluent.
BRPP has lowered conductivity set points from 2500 micrormhos to 2000 micromhos at many of
the in-line monitoring sites.
4.4 Screening and Sumps
Spill systems for the pine and HWD lines are now inter linked and plumbed so that tankage in
either line can be used interchangeably for spills.
After reviewing spill collection and control at the Glatfelter mill, BRPP has repositioned
conductivity probes from their sumps to in-line. They also installed these probes at a downstream
angle to minimize hang up of fiber and to reduce damage from large solids that may be pumped
from the sumps. In addition, they now pump all collected spills to treatment rather than allowing
them to flow by gravity. Using this approach, they know exactly the quality and quantity of the
liquid being sent to treatment.
BRPP has where possible replaced packed seals with mechanical seals to minimize the amount
of tramp (minimally contaminated)water getting into the sumps.
4.5 Knot Rejects and Acid Sewer Reroute
Liquor draining from the knot bins on both fiber lines is now directed to dedicated sumps where it
is pumped back to the process. If either of these sumps were to overflow, there is a secondary
backup sump for each.
Piping of acid sewer directly to the WWTP was completed in December 2005 and started up 1
January 2006. Mill representatives stated that the sewers were rerouted when other repairs were
being made at the W.WTP. These repairs at the WWTP were necessitated by flood damage
caused by the two back-to-back hurricanes, Francis and Ivan, in September 2004.
4.6 Other
Evaporators are now monitored more closely for leaks and carry over. Clean outs are done on a
ten week rotational basis and in-line conductivity meters are used for all condensate lines. Fiber
strainers were added to the evaporator feed lines in order to reduce carryover. At the present
time, approximately 3000 pounds of color come from all condensates. Issues related to the
evaporators are due mainly to soap and some fiber. Mill representatives stated that the volume
of liquids sent to the evaporators has not changed over the last five years, perhaps, at most, eight
to 10 percent more.
BRPP discovered that recycling of bleach plant wash water plugged the decking of downstream
washers. As a result of this discovery, BRPP now changes out the media on the pine line D1 and
Eo washers on a scheduled routine basis. The cycle can vary from three to five years. Cost per
washer(or set of-washers?) is about$400,000.
The mill can now divert spills, etc to an off-line 1 MG clarifier. However, because of the mill
sewer configuration, BRPP cannot isolate spills from one mill area. They can only divert entire
mill flow. The clarifier volume can store about one hour of flow(when the discharge is at the
average flow rate). Because of this fact, they try to capture only the spill. The mill can add
polymer to the clarifier and have, on occasion, done so. BRPP prefers not to do this, however,
because it results in sludge which is hard to handle and color reductions have not been
noticeable. Generally, BRPP will bleed the diverted wastewater to the WWTS over a two to three

ppppp�
day period.They will also bleed sludge to the sludge dewatering system (Andritz belt presses)
along with primary and waste activated sludge. Polymer is normally added to the sludge for
dewatering.
BRPP uses the term "brown color'to describe color that consists of larger color bodies with
longer chains. This material is colloidal in nature and is generally believed to be removed in the
WWTP. They believe that the CRP purge stream is brown color. They use the term bleached
color for color discharged after bleaching. This material is almost dissolved in nature and BRPP
does not believe that it is removed in the WWTP.
Training of operators with regard to spill prevention and control has been intensified over the past
five years.
Prior to the mill tour, we were informed by mill representatives that housekeeping was not up to
normal standards due to fact it was the first day the temperature had been above freezing in
about a week. In spite of this, all areas toured were free of stock spills and liquids running across
floors. In addition, liquids flowing in floor drains were very low with respect to both volume and
color.
5.0 BUSINESS REVIEW
John Wadsworth, Chief Financial Officer for BRPP, presented information on the health of the
industry and BRPP. He presented information showing that for BRPP's main market, uncoated
free sheet (UCFS), the drop in capacity for the past five year period was equal to the growth of
the previous ten years. This he opined was due mainly to the Internet's impact on printing paper.
Next he showed that U.S. paper mill shutdowns have accelerated with 98 mills closing during the
period 1997-2006. During that same period the employment has declined by 70,000 workers or
about 32%of the workforce. BRPP has operated in the red since 2001 and in 2006 they will also
take a loss. The year 2004 was a good year for business and they would have shown a profit
had it not been the floods from hurricanes Francis and Ivan which cost the Company
approximately$40MM. Wadsworth said that the only reason BRPP has stayed in business
though this down period in the industry was through the sale of bonds. These bonds will come
due in 2008 and 2009.
Bob Williams stated that the good news is that for those still in the business, the price of the
product has increased, noting, however, the price of chips and fuel have also increased. Bob
believes that the Canton mill will be"the last man standing".
6.0 MAJOR ENVIRONMENT PROJECTS
6.1 Pigeon River Recovery Project
See Attachment B, pp. 17-18
6.2 Air Pollution Control Projects
One project remains to be completed. This relates to compliance with MACT I—Phase 2 and
involves the installation of a Regenerative Thermal Oxidizer(RTO) unit. For costs and other
projects, see Attachment B, p. 18
6.3 Post-Flood Wastewater Treatment Projects
See Attachment B, p, 14-15, 18.
6.4 Color Improvement Projects
Color improvement projects accounted for$5.9 million (23%) of the$25.9 million spent on major
environmental projects during the last permit term. These were categorized into three major
groupings, Highest Certainty, Reasonable Certainty and Lowest Certainty projects. The Highest
Certainty Projects were further subdivided into Process Optimization, Improve Spill Collection and

ppppppp
Improve BFRT Reliability. Details of these can be seen in the handout provided, see
Attachment B.
The CRP purge stream averages only 15,000 gpd but contains about 23 percent of the color in
the primary influent. However, BRPP does not believe that treatment of the CRP purge stream is
the answer to further color reduction because they are convinced that this color is essentially
removed by the WWTP. Mill representatives stated that they have made runs up to 18 days
where CRP was not discharged to the WWTP and the color discharged in the final effluent was
actually higher than when CRP was sent to treatment.
Piping of the acid sewer line directly to treatment(after primary clarification and prior to
secondary activated sludge)was completed in December 2005 and started up 1 January 2006.
This change has eliminated the sewer generated color from the influent to treatment and BRPP
now believes that they have a good handle on all color sources from the mill complex. This
change has, however, resulted in an increase in color when comparing the primary influent and
effluent. It should be pointed out here that the acid sewer line is added after primary treatment
but prior to sampling of the primary effluent(see Attachment D). BRPP representatives stated
that they believe that the color generated from the mixing of the acid sewer line and the primary
effluent is less than the sewer generated color of the past because the pH swing is not as great.
7.0 COLOR PERFORMANCE REVIEW
Comparison of the present color balance to that of 2001 shows a number of shifts in sources of
color. The first is the elimination of the"unaccounted for"color which mill representatives believe
was primarily sewer generated color. The second is the increase in the pine Eo color, however,
HWD Eo color has decreased. The CRP discharge continues to be the largest single source of
color, however, as discussed previously in the report, mill representative believe that this color is
effectively removed in the WWTP.
Removal of color across the entire treatment plant now appears to be essentially zero.
Attachment E is a daily color loading sheet which is routinely prepared at the mill. For the day
shown, 18 January 2007, a color reduction of two percent is shown for the WWTP. Looking into
this further and comparing the influent to secondary treatment to the secondary treated effluent
shows that there is a 44 percent reduction of color which is more consistent with removals seen
at other facilities employing similar treatment systems.
8.0 BRPP PROPOSAL FOR POTENTIAL PROJECTS DURING NEXT PERMIT TERM
8.1 Pulp Mill
BRPP proposes the following items related to the pulp mill:
• Continue the replacement of the HWD BSW showers on the east and west deckers.
• Conduct lab scale peroxide trials for the Eo stage on both fiberlines
• Perform lab scale high temperature peroxide trials for the Eo stages on both fiberlines.
• Perform trials to eliminate the by-pass of HWD Eo filtrate to decker filtrate tank. Move to
decker showers or another washer.
8.2 Recovery
After nearly 10 years of operation of BFRTM, the mill recently experienced a large overflow of
CRP wastewater to the sewer. This discharge has resulted in a proposal to provide a dedicated
sump and containment project for the CRP.

PPPPP�
A second project in the recovery area would entail piping to collect Sarco Strainer wash water
directly to the Wash Water Tank instead of sending this water to.the sump. This project would
also include the installation of flow meters on the lines to wash water tank to monitor the flow.
On occasion, the mill discharges green liquor dregs to the WWTP. BRPP has learned that
Glatfelter found that the sulfides in these liquors react with components in other mill wastewaters
to produce additional color not previously identified. To resolve this problem, BRPP proposes to
make improvements to the green liquor dregs filter feed and to upgrade the underflow pumps.
8.3 Color Monitoring
BRPP proposes to add another level of overflow protection on cyclones and mix tanks. This
would include temperature monitoring on such overflows which would be tied to the process and
cause the process to shutdown.

ppppp�
Effluent from Blue Ridge Paper Products bleached kraft mill at Canton, NC
Bleach acid filtrate
Influent to=piimafy clarifier Treated effiluent from AST
34$ 131 13
-J-
' f _ J

z� 0V07
Agenda
Technology Review Workgr� out
February 8, 2007
• Welcome and Introductions
• Opening Remarks
• Mill Status Update and Photo Tour (2 hr. 30 min.)
• Mill Tour
• Break and Questions
• Lunch
• Business Review
• Mill Performance and TRW Information Request (3 hrs)
• Wrap-Up
Opening Remarks
Don Anderson
1

Canton Mill - Tour
Canton Mill
• 200 acre site surrounded by Town of Canton
• Fully integrated paper mill with exception of wood yard
• Process flow
— Chip Pile& Screening
— Batch Digesters
— Hardwood&Pine Fiberlines
— Paper and board machines
— Warehouse and distribution
— Chemical recovery cycle
— Utilities—water plant, coal yard,power boilers,
generators,wastewater treatment and landfill
2

World Class Color Performance
• Bleach Filtrate Recycling (BFRTM)
• Elemental Chlorine Free bleaching (ECF)
• Oxygen Delignification (OD) on both fiberlines
• Extensive color monitoring and collection systems
• Process Optimization
The best-loolarlb Paper
tlac Caiatoiz Mill employees
have ever produceel.:
F,i n
.5 ml„wacert>ailPWr[LT as C'
ntcoovvE
Glue Bldg Paper Pcuduccsr lnwrpnratr d 4t
w+w+o Yl Y.<w+l•.Ermwurwr+[w� I
o.nraw rse.nr
BLUEo RIDGE
S
3

Canton Mill Tour - Pulp Production
Hardwood Fiberline—OD with ECF
Pine Fiberline—OD with ECF, plus Bleach Filtrate
Recycling (BFRTM)
R'
Canton Mill Tour - Pulp Production
Pine 02
Delig and
Bleach
Towers
�,• Pine
Brown HD
Storage
r
Recycle and color prevention
Filtrate collection sumps and storage
4

Wastewater Treatment — Activated Sludge
Blue Ridge Paper Canton Mill
> Effluent quality is among the
best of Kraft pulp and paper
mills in the world(EKONO
2005)
> Color performance is excellent
> Chlorophenols and Dioxin in
bleach plant effluents are all
non-detect
Effluent Color Management
Pollution Prevention Approach
• Elemental Chlorine Free bleaching
• Oxygen Delignification
• Bleach Filtrate Recycling TM
• Process water recycle
• Spill collection and recovery facilities
5

Mill Tour — Safety Information
• Personal Protective Equipment Needed
— Hardhat
— Safety glasses
— Hearing protection
— Escape respirator
• Evacuation procedure
Questions from Mill Tour
6

Afternoon Agenda
• Business Review
• Major environmental projects
• Color Performance
• TRW Information Request
• TRW Closing Remarks, Next Steps
and Schedule
Business Review
7

Industry in Transformation
North American UCFS Capacity
10,000
17,000
16,000
15,000
14,000
13,000
12,000
11,000
19,000
9A00
8,000
egg egg�9g�9g�9g�9g�9g egg �9g�g egg�9g egg�9g egg 20g`Og 20g�Og�O 2gg�Og
9 0
—105CapacOy—ToWNACepaciry—Base 4e
v
F ele9 Aewelly
Seurte: =, ,2M T.Greplii PapAWU 3p,.lpats
2W2,2004,2003 TeNa 2 paga38 aM TaEle 3 page 39
8

Uncoatetl Freesheeb Capaclry Change Uncoated Freasheel Lapac(ty Change
20g0.2G05 Announced Future Closures
Company Capaclry Nef PM's Company Capacity Net pM's
Industry Trends
Change(Tons) Shutdown Change(Tons) Shutdown
International Paper fl,267,000) 8 International Paper (350,000) 1
®®© Announced ®©
®®© Source:RlA NonhAme@an G:aPF/c Paper Forecast
Smaller ®® •Anmm�cMClmvrea wlll ahtlnkugcllY DYanalhc].5X
Total Net Capacity ® 48
Change
Source:R151 North pmetl[an GnPDI[PaglFwaca[I.Tact¢8
Industry Trends
•mdaaDYeagdry has aDmna bYfa.ax Uncoated Freesheet capacityroshripk
a total of 19.9%
Bleached Paperboard Capaclry Change B/¢ached Paperboartl Capacry Change
2gg0.2gg5 Announced Future Closures
Company Capaclry Nef PM's Company Capacity Nef PM's
CM1ange(Tons) Shutdown Change(Tons) Shutdown
®® 1 ®® 1
®® 1 Saurte:RlSl Nonh Amed[an Grsphlc PegiForeozl
®® I •Announcetl dosures wlll shilnk 2agdlY bYanallry l.9X'
®_®_�_
Change
(690,000)
Bleached Board capacity to shrink a
Sourtv:R15/Norlh Ametican Gnphk Paper Fwecas(Teblefi total of 13.5%
•Intlusby cagc/ry hasshmnk by 11.aX

U.S. Paper Mill Shutdowns Accelerate Since 1991
17
1s
12 13 12
10 9
7
5 5 4 4
2 3 2 1
fo fo m m ro io fo m m o 0 0 0 0 0 0
m m m m m m m m m o 0 0 0 0 0 0
N u A m m V m m o N Y A m m
98 paper mills have closed 1997-2006
Source:A sdcan Forest 6 PaperAcsmla6on Sfanleyb coy,D4 &rEcanomlc Servlees email=6
2666 mman<emanb lrem RISI
Employment At Pula & Paaer Mills
Thousands Of Workers '
24U
22U
20U
180
160
Paper mill employment has declined by more
140 than 70,000 since early 1997,or 32%of its
workforce.
120
1997 1998 1999 2000 2001 2002 2003 2004
s.a.�eaaaanace smuwo
10

Company Overview
Locations
®Cai¢n MY(Paper6 BomERamxYm)
Cwpmab W+iW+N+ 4y�
�w=rma.mase�mF.an � � f
Q�aYTA Feuliry
s
❑ PNN N
1�

�G:,��_,�_ � -- Waynesville-Coating Facility
Canton- Pulp,Paperand Board Mill "'-1r'1•� '' - �y
� ER5'GA^Gat alp a
Ofherp ants: r
Blue Ridge Paper Products
Blue Ridge Hi Brite
Richmond,VA
Olmstetl Falls,OH !
ConveriSent,
No Mess,No Leakl
r
�,'tl Pll4'l 1 12
Neart�s
u

Blue Ridge Paper Products - Overview
•4C a @P
Carveding Pleats cum
•Poymercaaled Nm P.. eeverages(Oai y&
6Maoled •SNaNgicloaMerin •Jugs)
6oaro icy •(Fabric SoConsumer Pmduol
Oener)
® •Dry Goods,Food,
Nan Food
•QIP 610C{'/FCW SBMW
• uerablehmun Meals
C
® • NaraNtldFooO Sarviw
L /
•Naronuod Pulp Ma �
Sofia Pulp Mg •Food Packaging Packaging Segment:
•Mpe,Marffias Conveders -2006 Un-Audited Revenue
•Paperboard of$335.5 million
MadOe Pagersegment:
•Wastewater -2006 Un-Audited •2006 Tons sold 215,984
Treabnend Faonly •Emebpe Grade Revenue of$236.2
LaM69
•Sts.&Pawa �� �packag g6 million
GenaaWn Wdungl -2006 Tons sold
Faglilies on""
Pringig 300,036
PaPar
Net Operating Losses - Thousands
tieo
$0 (SS,424) ($4,077) ($27,33a) ($3t.3+g) $20,680) 2006
results
-$5,000 not yet
public
-$10,000
-$15,000
-$20,000
-$25,000
-$30,000
-$35,000
13

9h ADS
Significant Financial Impacts +�ti5` 01 ticoot
Dec 2001 thru 2006 &Lp daG
• Completed#19 PM rebuild and restart d0-1
• NOx SIP call, MACT I and MACT II
• 2004 floods, $39 million damage
a
• NPDES permit - Color Reduction Projects °I
• Survived in a very difficult economic environment
September 2004 Floods
r
milli
14

Flood Impacts and Recovery
September 2004 Floods
• Back-to-back historic floods - Frances 9/8/04 &
Ivan 9/17/04
• Mill down for 21 days, $39 million total damage
• Restored secondary wastewater treatment within 4
days of Frances and within 5 days of Ivan
Flood Protection Projects
• Elevated critical electrical systems
• Emergency generator
• Flood wall for low lift pumps.
• Close coordination with NC and TN state and county
governmental agencies and interested citizen groups
15

Questions
Major Environmental Projects
16

Pigeon River Recovery Project
�i BLUE RIDGE
PAPER PRODUCTS INC.
yar
cons,
ation
Rp nfb1:#LbY�
Progress Energy
a pPWAipq
O
f 1 1
Pigeon River 6ou Rix
uLtlR
Non-game species J Fsb"A
# r yM.
re-introductions
TN—began 2001
NC—began 2004
P.
— geien
G
Managed by University of Tennessee Dept °
of Wildlife, Forestry and Fisheries
Steering committee includes water quality
and wildlife representatives from TN,NC
and Federal agencies plus interested NGOs
17

Pigeon River Reintroduction Project -
Re-Introduced Species thru 2006
_ Shiners Release Site.-TN
Mirror Saffron 517ver Telescope T[ rmmml:land
Totals 1 40481 4031 15141 2358 WD Up D®lon,RM 16.5
- ' Release Sltes-NCI`
Darters FBR Fe gu on Br,R verside
Gift IBbiebrmtlBhicside Stripetail cc GolfCaurse RM 52.5
Totals 1 20061 3881 10101 983
FStargazing _
Minnow River.Chub Mt.Madtom
Totals 849 66 1108
`La ey
Am Brook Mt Brook
Totals I
Major Environmental Projects
Pr.ect Capital Cast Dates and slows
No.SIP Call-Poxes bola Nos covwb S5.6 mM.. 2003 tluu 2005,complete
mdmo.it...9
h1ACr I-Phue l-blmchpl tmd foul No capital requited, 12002.complete
covdeuates c.mphmce 11 $200000 expeate for
compliaroc dcm.ruutr d.v
d rel ted plena I
MACTn-recovery somas S1.4 milli.. I 2004 lau 2005,complete
_ .MAT I_.p .. e _ —o � E83 Million
o. i2006,mde construcconstruct..—.v
(Fquisalrcy by Permit-BOXRM) eomPlimr,date ofApd2W_-
7
Post-Flood Wastewater Tsmtment S4.6 milli.. 2005 N.2006,complete
ImP mveme.b-flood wall, located
switch6ea,DCS c..nole,emc:Pcvcy
geoeater
_l
Color Improvement Proleets- S5.9ollor 20016m2006,mmplete
stt Figure I of May 2006 Calm
C.mplimce Repon
Total S 25.9 m'I0m
18

Maior Environmental Proiects
Canton Mill 2001 thru 2006
Project Capital Cost Dates and status
NOx SIP CaU - Power boiler NOx controls and $ 5.6 million 2003 thru 2005, complete
monitoring
MACT I—Phase 1 -bleach plant and foul No capital required, 2002, complete
condensates compliance $200,000 expense for
compliance
demonstration and
related plans _
MACT II—recovery sources $ 1.4 million 2004 thru 2005, complete
MACT I - Phase 2 —HVLC compliance $ 8.2 million 2006, under construction with compliance
(Equivalency by Permit—BLOX RTO) date of April 2007
Post-Flood Wastewater Treatment $ 4.6 million 2005 thru 2006, complete
Improvements— flood wall, relocated switchgear,
DCS controls, emergency generator
Color Improvement Projects — see Figure 1 of $ 5.9 million 2001 thru 2006, complete
May 2006 Color Compliance Report
Total $ 25.9 million

TRW Recommended Actions
December 2001 Permit
• Highest Certainty
• Reasonable Certainty
• Lowest Certainty
l41YI�s ��a5;
Permit Milestones Achieved
✓ December 1, 1998 60,000 lbs/day
✓ December 1, 2001 48,000 lbs/day
✓ January 1, 2004 42,000 lbs/day
✓ March 1, 2006 39,000 lbs/day
19

Highest Certainty Action Items
✓ Process Optimization
✓ Improve black liquor leaks and spills
collection and control
✓ Improve BFR reliability
Process Optimization
�A�wood- zow��
1. Monitor hardwood digester k#and post-02 k#s hourly
2. Investigate methods to reduce k#variability
3. Upgrade hardwood 02 reactor feed pump
4. Monitor 02 operation for performance improvement
5. Calibrate/upgrade No.1 Dl and D2 control instrumentation n �Ic� 1 y
6. Reduce No.I Dl kappa factor to 0.20 - 0.24 e5" 1�' b
7. Reduce 02 charge to No.l Eo stage to 0.3% �, uo4 wkt
8. Propose H2O2 trial on Eo stage after kappa factor
reduction
V*VIA KRt�OR�
o eR, 6cL4 PILO
P"a
Y,O,i- no ¢ej.- 4t.,.d to PRnc2sS - 20

T 3 LL wrrr
4&A
Process Optimization
9. Optimize pine brownstock operation (a -As G�v a 5 K8
10. Upgrade pine 02 reactor feed pump 99
�.r7�Ib�fL/Flt (21(e
11. Calibrate/upgrade pine Dl and D2 control instrumentation
12. Optimize pine DI and Eo washer operation
13. Reduce pine D 1 kappa factor to 0.20—0.22 Ter Fe-wxsden
14. Run MgSO4 trial on pine Eo stage "may dwtio1c aFplxeEd
15. Optimize D2 stage operation and reduce C102 addition EA cL t"r 0 j "gCVk
16. Conduct training course for washer and bleach plant .M95oy—fdrxl i"i k
operators Ng—Mor &Ailg-
ea�aQ 4aAZWrmS IIr51
�tr�l To EPUL{bHMtM�RI
p MP�"Cmnu5 AUNGAI
Improve Spill Collection
I. Continuous improvement of operating practices
✓ 2-hour color monitoring. 2d I /3G S
✓ Use of off-line spare clarifier for extra recovery capacity
✓ Piping hardwood brown recovery tank to pine blow tower I
✓ Control logic in pine brownstock to minimize tank overflows
during shutdown _ brtowus✓b�l< e, f'/,<, (µu4
le tnsa�{ sPr!(r
2. Further improvement in preparation of planned outages
✓ 1-hour color testing frequency during maintenance outages
✓ Improved communication between treatment plant and
operations personnel
✓ Development of tank draining schedules
✓ Inventory management prior to shutdown
✓ Assigned personnel for color watch during shutdown and startup ��`A9s µWoo e
�lbws </uzrug cv}q5<'S.
21

Improve Spill Collection
3. Further reducing clean water that runs into sewers
to prevent dilution of smaller spills
✓ Installation of mechanical seals
4. Further improvement in the equipment used to boo% J a-K(o F�
handle knots rejects &,i& 45
✓ Dedicated u-drain and knot bin sump pit/pumps for
each fiberline
Improve BFR Reliability 3 N f'r/leA INSFhI�d
54A-W lM5
1. Replaced three existing sand filters
2. Replace/upgrade existing process piping with -Wtplgcod 1/1e5 s/Arulo-ss
improved metallurgy
3. Installed a fourth new multimedia filter and third 7'/--S-411VW �ysYaati
ion exchange softener niAr a�ArN��aA{
-04z/E AISo MArll7tiuA F
&OV4 -60°o.—e.G�sneca�r
c654,P/ao61Fr. eq �Pf
20o4 NanoiwooJ
LOloC- 7600 1lr HAaawaoc� �o a&cye Ns�xK
�y=
rl/01,L-C E
22

Reasonable Certainty Action Items
Evaluated
-VA IPA 5�
✓ Ozone/002 stage for hardwood
✓ 2nd stage Oxygen Delignification for pine
Hardwood - Ozone/002 Stage
• No effective color reduction (7% increase)
0 • PAPRICAN lab study
• Domtar visit
• Increase in operating costs
• High capital costs
• Decrease in freeness
"...this technology is not recommended for the
Canton mill... " (p.18, 2006 BEPER)
23

Pine — 2nd Stage Oygen Delignification
• Andritz-Ahlstrom study
• Color reduction insignificant due to BFR /
• Drop in viscosity (strength) F{{r�..u�4ec�ge is�a�rt
y-aFS Kg ale
"...the implementation of two stage oxygen delignification on
softwood pulp can result in a reduction of the kappa to the
bleach plant by about 1.5 units, the capital investment will
be very high compared to the reduction in chlorine dioxide
that will likely be achieved. Further, since a major portion
of the pine alkaline effluent is recycled to the BFR process,
any benefit will be diminished."(p.60, 2006 BEPER)
-J3A4B'1y c11.10azie
tzcwouW�
Lowest Certainty Action Items
c KV-I1"o (b,
APPrA0.s Jo bE'&6Mov�
Evaluated action items related to the CRPAO
{ww�- ioa �ia�6
color stream
✓ Land application
✓ Commercial incineration
✓ Coagulation/Precipitation
✓ Solidification for land disposal
✓ Application to lime pre-coat filter
24

Above and Beyond
Color Reduction Actions
• Color treatment
u spa E
✓ Ozone treatment of.
• Final effluent
• Hardwood Eo
• CRP
✓ CRP on Lime Pre-coat filter
✓ C102 treatment of CRP
✓ C102/Ozone treatment of CRP
Above and Beyond
Color Reduction Actions
• Color treatment (cont.) II
✓ Peroxide treatment of Hwd Eo and Pine Eo of �i20o f 1 b1—Ndf[oµwt.,
AVt1Y�(}d�t.,
✓ TAML treatment of Hardwood Eo
✓ White Rot Fungus
✓ Lime trials on mill sewers—
✓ Pall filtration on effluent
25

Above and Beyond
Color Reduction Actions
• Process Improvement
✓ Quaternary screen reject presses
✓ Green liquor segregation in recovery area
✓ Acid sewer re-routing
✓ Process improvement teams
• Color Material Management
✓ Reliability improvements to pine fiberline nKJo�4.vAy
sumps 4ft.9'�R
Improved color monitoring tools
Above and Beyond
Color Reduction Actions
2006 Color Optimization Projects
✓ Improvements in Hwd brownstock washing
✓ Replace showers on pine decker
✓ Pre-bleach internal recycle pump
✓ N4RP Sand cyclone
✓ Conductivity meter on digester hog line
26

cub.Peaum.n Initivtiveu eLde.xo.I Noes V.m,
eb.¢me•e.p:re�.nm sa.-e.mu.vm
dnullnn lnl m e e =2001= soon IM2003=1 Seer IM20MM xoos cutls
W-7,
buee
ue,w
.. m.I�.e.mi..m-,wmb•�mmT�4 4l e.v
..�rsmb.�n.•
�aww.wr w wmcu.,.mm.�..m
m aoP
mmism 4M•
of - "�wm.I�naaxe....bbw.rcee...,I.wen.m �
..xw.de
®umP�..Pm
ISls,tic
If W •m+u5k5pm Rm u.uYngwiry.wu+num.J
xteuycgn -mu�+..mm+vq beei.auwvebormm
Y ctri'Jf. NQ.nR�uiuyM�wlm � fmw•IPcfvmnmpea.® � ieW S;el6,lo0
•9m.bub.m®uWfaY! 6fmuiy.46vlm � ^�
Isufm•bAam� �
17
M+nw4I®Ifo4 Yn1.am0® � Csanlb6mm<I�mma
Color Performance Review
27

Color Reduction Initiatives Under 2001 NPDES Permit
Blue Ridge Paper Products Inc. - Canton Mill
Color • ion Initiative/Prolect 2001 2002 F7W 1 2004 - 5 2006 Cost$
I 2 Hour color testing fie uenc 1
2 Licbergott Recommendations Implemented (20)1 BEPER Report) incl in#8
3 11u of Off-line Clarifict for Spol Diversion
4 Hwd Brown Recovery Tank Lie to Pine Blooli I I I 1 i�.nn0
5 I How'urlot nc shop truµxixy dtemg ntun0.n,ini maecs
6 ImYalkuon of Mechanical Seats(clean water sego n°eunr
—_
7 Improvement of equipment used fnrtwdlmg Piix .iud I Imtl eoouJ knot Rrjccis I i i I'_s.5(lll
8 Bleach Filtrate Recycle I rovenretxs
9 lustalkd Fiberline wrarol logic improvements 1 oso 000
12 Hard10 male seweo-contributors
ntrib t color interaction cltccb Cuadn w rGCnera d Color
I1 Bench- _ 3 u(r�l
Wood Fiberlie Six S Teamfoi rnee8s opttmtvnlx,n mt -o ur inyr � 'nx'"I" s�lt♦L: I1A)llnl
13 I rovements made to Fine Brownstock sumps for beaer rccow,3
14 White Rot F 'Thal(See rote below)*
15 C1O2/Ozone Bleaching of CRP wastestream(See rote below)*
16 Ozone/C1O2(7�)Sta for Hardwood bleach lie -lab stud (See rote below)- t0 00�
17 2nd Stage 02 del atlon on Pine- lab study(See rote below)* � nx I m# I5
18 Ozone Bleaching ofeHluents-lab pilot stodies(See note below)* 35,(1W
19 Pine Brown Recovery Tank Lire to Hwd Blow Tower _ - "Id. m#13
0 Milk of Line Trial(See note below)* � 35.000
iLaid Application of CRP wastestream(See torte helow)*
22 Commercial Incineration of CRP wastestream(See tote below)*
23 Coagulation/Precipitation ot'CRP wastestream(See tote below)*
24 Solidification for Land Disposal ofCRP wastestream(See note below)*
25 Poe and Hardwood Quaternary Screen Rejects Press
26 Catalytic pemIxide treatment of Eo smeam(Sm rote below)* 15.000
27 Trial to confirm and size system for C1O2 de-colorization of CRP/evahmte full-scale _ _
application(trials completed after Sep 04 floods,see note below)* __ _ __ 60,000
28 Peroxide Trials on Hardwood Bo(See rote below)* _ _ _ 30,000
29 1Ooeen L' uer Surrip at recovery ftmtaces I IH),opo
30 CRP on Litre Precoat Filter(See rote below)* _
31 Peroxide Trials on Pre Eo(See rote below)* 15.000
32 TAML treatment of Hardwood Eo _ _ -
33 Acid Sewer Rerentaing 1,535,000
34 Pall Filtration(See ro[e below)* 15,000
35 Color Process Irprovement Six Sigma Team i to examine operatng conditions associated
with End color rfore nnce
36 Color Reliabl'ay Projects- process and monitoring focnrs to seduce varablry of color
1performimce 384,000
*Initiative determined not to be technically, Highest Certainty Action Items Conti nned Performanrce Improvement a— Total $5,836,300
operationally,or economically feasible Reasonable Certainty Acton Items
Lowest Certainly Action Items
Above and Beyond Color Reduction Items Contrnned Performance Improvement nnnnnnnnntn�

Annual Average Effluent Color(1000lbslday)
Blue Ridge Paper Canton Mill, 1988 thru 2006
R
9
a 400 38
333
301 107
300 1-241
`0 200 - —
0
120
�a 78 83
100 - - - -I I I I I 43
11 11 1 43 41 I' 11 11 3' 3i
w 0
W
Annual Average Effluent Color(1000 Ibs/day)
Blue Ridge Paper Canton Will, 1997 thru 2006
m 70
v 62
a60 ----------------- --- -------
0
50 --48--------------- 46 -`------------
� 41 43 43 41 40
0 40 __ __ _ __ __ ___ __ ___39 ___3T_
U
° 30 -- --- -- --- --- -- -- --
w 20
1997 1998 1999 2000 2001 2002 2003 2004 2005 2006
28

Production-Normalized Effluent Color(lb/ADBTP)
Blue Ridge Paper Canton Mill, 1997 thru 2006
60
a
m 50 46.7
40 35.6 33.9
a 31.2 32.5 30.8 33.2 28.6 28.3
o 30 - --- - — -26.2-
u
a 20 -
10
1997 1998 1999 2000 2001 2002 2003 2004 2005 2006
Production-Normalized Effluent Color(kgltonne)
Blue Ridge Paper Canton Mill,1997 thru 2006
30
25 _23.4--- -- -- - - -- -- --
d
20 - —17.8— 17.0 -_ - - - ---
162 16:6
C 15.6 15.4 14.3 14.1 13.1 ..
O 15 - -- --
..
CD 10
Y
5
0
1997 1998 1999 2000 2001 2002 2003 2004 2005 2006
29

Permit Language
NPDES Permit
Section A.(8.) Paragraph 8
"By December 1,2005, the pennittee shall submit, as related to
implementation ofthe process improvements evaluated according to
Paragraph 7, a statistical analysis of Blue Ridge Paper's effluent
quality performance. This report shall include a statistical analysis of
the Blue Ridge Paper's monthly average and annual average color
discharge,mill performance as related to color, and all available data
necessary to derive the lowest achievable annual average and monthly
average color loading limits."
• In compliance with this condition,Blue Ridge
recommended 39,000 lbs/day as an annual average
I�R PRG'W�M�`NLE
30

NPDES Permit
Section A.(8.) Paragraph 8
'By February 1, 2006, the Division of Water Quality (in
consultation with the Technology Review Workgroup)shall
recommend to the NPDES Committee, considering the
statistical analysis report submitted by the permittee and the
demonstrated performance of the mill, the lowest achievable
average and monthly average color loading effluent
limitations. If the limits determined to be achievable are
within or below the range of 32,000 to 39,000 lbs per day as
an annual average, the limits shall become effective March 1,
2006, by written notification from the Director."
NPDES Permit
Section A.(8.) Para raph 8
Color limit decision was postponed until permit
renewal by letter dated January 25, 2006
31

TRW Information Request
TRW Information Request
#1 — Trends in Pulp and Paper Production
Figure 1 Annual Pulp Production
Blue Ridge Paper Canton MI11,2002 thru 2006
MITI Flooded Sep 2004
1400 - - -- - -
T
'e 1200 — -- - -- -
'e 1000
Boo
400
600
0
zoo — - — —
0
zooz zoo3 20oa zoos 2006
OPul production 1336 7344 1311 1383 1415
32

TRW Information Request
#1 — Trends in Pulp and Paper Production
Figure 2-Annual Paper Production
Blue Ridge Paper Canton MITI,2002 thru 2006
M9 Flooded Sep 2004
2000
T
'v 1500 --- - - - -
1000500
-- --- 9 u -
ap
0
2002 2000 2004 2005 20M
nPaperProduction 1562 1561 1520 1617 1 1662
TRW Information Request
#2 — Current and Expected Production Rates
• Current trends to continue
• Mix
— 40 to 45% Pine
— 55 to 60% Hardwood
6 �fZ 0 t)63ZATror1 l g q G
33

TRW Information Request
#3 —Chemical Usage
2002-2006
• C102 —Pine averaged 57.7 lb/ADBTP
• C102 —Hardwood averaged 33.61b/ADBTP
Cheriaalwam R-EO(:stic RmEOQ"m Rre@Cadic(r3'AO
(Ibffon)
Mot to2005 38.8 119 0.07
2706(YfD) 355 10.32 1.23
Rwd+.00d OI Md Had+.00d ED Q.Ic Hadnood 02 C.1d HMd+cod eleeded
rocasbc
2101 to2005 10.92 14.95 3.56 1.48
2ffm) 7.16 lam Z07 0.98
TRW Information Request
#4—BFR data Stream Ave.Flow(GPM)*
D 1 887
Eo 880 *2006 data
Bleach Filtrate Recycling(BFR)Closure
Blue Ridge Paper Canton Mill,2001 thru 2006
82•0 79A
79.0
77.5
aU`ma0i
-
77.0 737
72.0
67.0
62.0 2001 2002 2003 200442005
2006
5 1N,0
34

TRW Information Request
#5 — Wastewater Treatment Plant Data
Data from Jan 2002—Nov 2006 provided for review
Effluent
Flow, BOD, Temp, COD, True Color
Influent
BOD, True Color, Temp
2001 Average Measured Color(lbs/day) in Mill Sewers as a
Percentage of Primary Influent Color
PI Color=57,725 lbs/day
SE Color=42,676 lbs/day
7% 1%
28% 4% ■28-Digesters,No.1 FL:4,286 lbs/day (7%)
6% 03A-No.2FL BSW,02 Delig: 507 lbs/day (1%)
❑PM's-11&12:2,249 lbs/day (4%)
■SB-Recovery,BLO: 3,658 lbs/day (6%)
■5B-CRP: 7,6521bs/day (13%)
■#2-Evaporators:668 lbs/day (1%)
14% ❑Contaminated Condensate: 1,1561bs/day (2%)
_ O Combined Condensate:360 lbs/day (1%)
OPine Ea: 3,540lbs/day (6%)
.yzk ■Hardwood Ea: 7,000 lbs/day (12%)
1% ■Pinem and D2: 3,620lbs/day (6%)
120/t 0Hardwood D1:7,190 lbs/day(12%)
4; 2% OUnacoounted:15,8421bs/day (27%)
1%
6% 12% 6%
35

2006 Average Measured Color(Ibs/day) in Mill Sewers
as a Percentage of Primary Influent Color
PI Color =38,454 Ibs/day
SE Color=37,058 Ibs/day
10% 6i°
0/ ;& 12% ■2B-Digesters,No.1 FL: 2,4411bs/day (6%)
E3A-No.2FL BSW,02 Defig: 4.816 lbs/day (13%)
❑PM's-11 812: 2,517 lbs/day (7%)
O5B-Recovery,BLO: Z3021barday (6%)
10% 6% ■SB-CRP:8,7451bs/day (23%)
■#2-Evaporators:766 lbs/day (2%)
❑Contaminated Condensate: 2,136 lbs/day (6%)
6% O Combined Condensate:458 lbs/day (1%)
■Pine Eo: 5,200 lbs/day(14%)
13 ■Hardwood Eo: 3.780 lbs/day (10%)
III Pine D7 and 02: 2,2091bs/day' (6%)
OHardwood D7: 3,7791bs/day' (10%)
23%
2%
Hardwood D1 and Pine D1 and D2 color is represeted by the fraction of
individual fiberrine colors to total acid sewer color
Unaccounted Color and the
Acid Sewer Effect
2002-2005 2006
Unaccounted 22% -2%
Color
WWTP Removal 19% 3%
36

2001 Average Measured Color (Ibs/day) in Mill Sewers as a
Percentage of Primary Influent Color
XO*R's o ; LQ/,R PI Color = 57,725 Ibs/day
Re001.4 76 o RAu4E SE Color = 42,676 Ibs/day
7% 1 %
4%
28% ■2B - Digesters, No. 1 FL: 4,286 Ibs/day (7%)
6% ■3A - No.2FL BSW, 02 Delig: 507 Ibs/day (1%)
❑ PM's- 11 & 12: 2,249 Ibs/day (4%)
■5B - Recovery, BLO: 3,658 Ibs/day (6%)
■5B - CRP: 7,652 Ibs/day (13%)
■#2 - Evaporators: 668 Ibs/day (1%)
I 14% ❑Contaminated Condensate: 1 ,156 Ibs/day (2%)
Combined Condensate: 360 Ibs/day (1%)
❑ Pine Eo: 3,540 Ibs/day (6%)
■ Hardwood Eo: 7,000 Ibs/day (12%)
1 % ■ Pine D1 and D2: 3,620 Ibs/day (6%)
12% ■ Hardwood D1 : 7,190 Ibs/day (12%)
2% El Unaccounted: 15,842 Ibs/day (27%)
1 %
6% 12% 6%

2006 Average Measured Color (Ibs/day) in Mill Sewers
as a Percentage of Primary Influent Color
PI Color = 38,454 Ibs/day
SE Color = 37,058 Ibs/day
10% 6%
111111213 - Digesters, No. 1 FL: 2,441 Ibs/day (6%)
■3A - No.2FL BSW, 02 Delig: 4,816 Ibs/day (13%)
❑ PM's- 11 & 12: 2,517 Ibs/day (7%)
■513- Recovery, BLO: 2,302 Ibs/day (6%)
10%
6% ■513- CRP: 8,745 Ibs/day (23%)
■#2 - Evaporators: 766 Ibs/day (2%)
❑ Contaminated Condensate: 2,136 Ibs/day (6%)
6% ❑Combined Condensate: 458 Ibs/day (1%)
■ Pine Eo: 5,200 Ibs/day (14%)
13% ■ Hardwood Eo: 3,780 Ibs/day (10%)
■ Pine D1 and D2: 2,209 Ibs/day" (6%)
■ Hardwood D1 : 3,779 Ibs/day ' (10%)
1%
5% 23%
2%
" Hardwood D1 and Pine D1 and D2 color is represeted by the fraction of
invdividual fiberline colors to total acid sewer color

TRW Information Request
#6 —River Color Monitoring Data
True Color
1. Fiberville
2. Hepco
3. NC/TN State Line
Monthly Average True Color in the Pigeon River at Fiberville
2002 through 2006
155
r 125
Ox
ODrL ��kbw�' s ,ao
` n 75
W
1pE�`a 2 so
2s
[ V� A
e & ff a 8 ff & q 8 $ 8
37

Monthly Average True Color In the Pigeon River at Hepco
2002 through 2006
60.00
g 45.00 /
30.00
Avg - �y ;
0
s
m
2
� 1566
0.00
Monthly Average True Color In the Pigeon River
at the North Carolina/Tennessee Line
2002 through 2006
35.00
30.00
0
u
6
y 0.00
c
_
`o
U Mae
JVI
15.00
10.00
g 9 4 9 9 9 4 $ 4 9 9 9 g 4 4 4
38

Pigeon River Color Upstream of the Canton Mill
and at Brown's Bridge(—NCrrN State Line): 1988.2006
225 —
200
V il5
a
`0 150
0
a 125
rn
A
m 100
Q
a 35
c
c
� 50
25
0
R R on an9 4 9 9 9 9 9 ry J
7� O C�/2 QrCef�lf
—Stara Line Color —Color apabeam of Canton Mill(Background)
TRW Information Request
#8 — Air Pollution Control Projects
Pro ect Cardtnl Cost Data and status
NOx SIP uv2005,ce CvB-P.xabo0erNOx SS.fi mdtiav 2003 t1mplem
controls and monitoring_ _
Merl-Phan 1-bleachpUm 52pg,0p0 expev¢ 2002,complete
and foul candemma compliant.
51ACT II-remverysomro SIA milli.. 2004 don 2005,complete
NUCT I-Phase 2-HVLC S8.2 milli.. W06,ondermnsnuctionwlh
compliance nomplianx date of April 203
Poo-Flood Watewater S4.6 milli.. 2005 tlau 2006,complete
Treatment Improxemevts
Color Ine,.veate.t Pmjeeh-see S5.9 milli.. I 20010in 2006,complete
Figure 1 of May 2W6 Repot -T
- - ---_ —�Totai S 35.9 million --
39

TRW Information Request
#9 — Discount Rate
8.5% - Real
TRW Information Request
#10—Balance Sheet
vrwm)'mu„nm otcaran
2001 20M 2003 tow 2005
CazM1 S 1.016 S 332 3 2,123 $ 2,460 S 2,110
di.Mka(net a aOawano N 4wbth4 eufa n
alemanv) s 38,20 s u,319 $ 42.64s $ 45,e14 a se,on
Imenlay E 53,183 S MAN $ 59,063 $ 41,006 S 0,988
Taal nl M.eb E 95,721 S IM,IM S1M.4O8 $111b $117.91O
Me,m as $ 400 S 1A S 62 $ 55 S 193
lm Twm Ae4eb(PPBE net) $ 199.309 $ 198.989 $192,671 $187.336 S 190.6
OonS bn4rvPm9re55 $ 7,828 S It= $ 4,314 $ 5.90E S 12.819
6Lnenllleb.. $ 100,85E $ 106389 S 70.80 $ 80,560 5 85.415
Pwea PIK Seam SutmrdmawlNae $ 37,OO1 S 4OAO6 $ 37.124 S 40.681 S 44.425
Tula Senlor OeeF $ 124.3" $ 114,692 $136.760 S 136,901 $161"
Other WNW.. S 3.659 $ 2.53E $ 2,824 $ 1,271 $ 730
Ta31l1aoJ%ea $ 239NI S 248p34 $21O.6W 529., $318.424
pelaneU Eamin'.(AvumWaletl pefw'1) $ (2,010) S (6,987) $(34,125) $(65,374) S(89,054)
Other Owner E4uftj(Tolal Ml WfEer E9uty) $ 35,1" $ 29,304 S 4.001 $(25,160) $(34.089)
Data in 0 are losses
40

TRW Information Request
#10—Income Statement
m...d,nfDW.
2001 2M 2003 20U 2005
Net Sale. $ 458,020 S 467,281 $468,636 S424.229 5101.913
Nei Saks-Padaft S 224XO S MOM $2&,500 $2&,800 5301,200
Net 6ales-Peer $ 163,500 S 1w.1iD0 $184,100 S189A00 S200.1F00
Win,General$AEmirvsireOre Expensee(SG$A) $ 26]14 S 22,509 S 22,222 $ 26,023 $ 22,i5a
Gemda0nn$AmaSmlkn S 17.472 S 18,286 S 23.062 S 19.4 S 10.124
IMma.l PiienSe-asq.enin8niknal 0ek11N
fimincin9 is $ (14,220) $ (12,550) $(14.148) $(15,904) $(17.465)
I..t Gmk ln.0 S 14,490 5 13AW S 14,996 $ 16,205 S 19,019
Imsne Tex Expe se(0ere19lnega8re vahie) S (3,498) $ - $ - S - S -
Net lnwme (S8A24) (59,P2) (527,338) ($31349) (520,660)
Dow in 0 are losses
Questions
41

2006 Liebergott Report
Table 1—Process Improvement Recommendations ,
Hardwood Pine
W.W.y Neshine
Impnwe performance ofwcuum washers through:
Reduction In feed conslstenoy Impmve performance of decker shavers through:
Ralse the vat load at Postal, ReduNon m feed co tote ency
Ckean and correctly align a0 showers Rah.the vat level set palm
Comma replacement of slewer bars Wtliaue replacement of ch ee,tasWoo the
Calculate drop leg velocities of eactt washer as a performance cored alignment
matrlc Calculate drop leg velocities as a performance metric
Mpove operation of Me deticen b bnprova the
$OCWµ�[ 'll dadwge ioreistarsr(If additional charges are
` 7 needed after completion of#1 above)
9E doix T-w W115�lE2 Evaluate the ellminallon of wasenter bypass on the
11 �' fastdeckershow.r(liqucr Wmgaddeddirectkytotbevat
'1f �r 1 F 0 "1 wD reduw dlu0on factor.,r,.d W Me washer)
bar C�-1rh* ,sG1 (-R by Evaluate dre elhnlnadon of bypas of Ea filtrate I-
decker//'' decker filtrate tank-more Me application to Me decker
6A1,.,a Grb-/lCA {�g� stmweeor another washer
RkuhT. R
Evaluate Ne use of oxygen anal peraude fordo coach of the ee dCOn Evaluate Me use of peroxide falfflicegon of the emactinn
stage at reduced 01 kappa factors stage to reduce Eo color
Decrease target kappa factor to 024 air My(OM even dry) D...target kappa factor to 0.24 air dry(0.22 oven dry)
42

Potential Future Actions
Potential Projects
Pulp Mill ql,
1.) Continue hwd BSW shower replacement on the east and west deckers(BEPER Reccomendation) 6,4460 k
2.) Peroxide trials[lab scale]for Eo stage on both libertines (BEPER Reccomendation)
3.) Trials to elimate by-pass of Hwd Eo filtrate to decker filtrate tank,move to decker showers or
another washer (BEPER Reccomendation)
4.) High temp peroxide trials[lab scale]for Eo stage on both fiberines (BEPER Reccomendation)
Recovery 1.) CRP sump and containment project— WoM1k--,eH s y;4�//"a4ed
2.) Piping to collect Same Stminerwashes directly to Wash Water Tank Instead ofthm sump area.
Install flow meters on lines to wash water tank to monitor this flow
3.) Dregs filter feed improvements,underflow pump upgrade
Color Monitoring Improvement
1.) Additional level of inerflow protectlon(redundant detection and alam)on cyclones and
mix tanks
43

Questions and Next Steps
44

Technology Review Workgroup Meeting
8 Feb 2007
Blue Ridge Paper Products, Canton Mill
Name (print) filiation E-Mail
M. EPh %a YL.
R06zgad Iwo- AAA
►� L «� �� wI Ile ebloe Vial .ct
SQ>z q eA' Cl '�jv
0
CLkl es+; aids Q
cam,,) 1civ�s
�ULa NVA�fnfto-y W` A u,�e .tv a►�ti�y �s �� ti.�,
e�.r U VI?
�2 f
eirel'O-- JO PA-22 ian-+ She11 ketv-rle-jo oV
R1e1�1�/E•c/ AA f��iz 11
rrie. � ��✓C12;�1 broAn Po 2,6 lve rj

Michael F. Easley ,.. Carmen Hooker Odom
Governor ~ ' Secretary
North Carolina
Department of Health and
Human Services
For Release: IMMEDIATE Contact: Debbie Crane
Date: January 9, 2007
State Removes Last Fish Consumption
Advisory Below Canton Paper Mill
RALEIGH—State Health Director Leah Devlin today announced the removal of the last remaining
fish consumption advisory below the Blue Ridge paper mill in Haywood County. Today's
announcement is the final chapter in a situation that first came to light in the late 1980s, when
byproducts of the paper production process led to fish consumption advisories in the Pigeon River
and the Walters Lake Reservoir.
"This is both a public health and an environmental success story," said Devlin. "It is a good example
of an industry addressing a potential public health problem by changing its processes. I'm pleased
we can close the book on this one."
The original advisory was issued by the State Health director in 1988. It warned against
consumption of any fish from below the then Champion International paper mill. In 1994, that
advisory was reduced to cover only carp and catfish. In 2001, it was reduced still further to just a
limited advisory on carp in Walters Lake, which is also known as the Waterville reservoir.
The advisory was originally issued because of high levels of dioxin found in fish taken below the
paper mill. Dioxin is a byproduct of chlorine bleaching. Studies have shown that exposure to dioxin
increases the risk of several types of cancer in animals and humans. The most common health effect
in people exposed to large amounts of dioxins is chloracne, which is a severe skin disease,
characterized by large, deep acne-like lesions. Some other effects include liver damage and changes
in hormonal levels.

Improved pollution controls at the Canton paper mill were enacted during the late 1980s. The
Canton mill, formerly owned by Champion International, was purchased by mill employees and
renamed Blue Ridge Paper Products Inc. in 1999.
More information on fish consumption advisories in North Carolina can be found at
http://www.epi.state.nc.us/epi/fish/.
Iflt#
Public Affairs Office Debbie Crane
101 Blair Drive,Raleigh, NC 27603 Director
[phone]
FAX[phone]

COLOR LOADINGS TO MILL SEWER AREAS _
January 18,2007
Data for previous day-mill sewers ending at 7 PM and influent and effluent ending at 11 PM
'Good Color' Upper Control
Sewer Area Daily Color Units Average Limit
Total Influent 30,755 Lba/day 37,959 67,413
Total lnfl.New,NCASI' 36,794 Lbs/day,
Total.Inf.Turbidity 17
2-day TI BMP LAL 55,093" Lbs/day
2-day TI BMP UAL 63,803" Lbs/day
1-day TI BMP Out of Control 72.514"'
Low Lift 25,333 Lbs/day 32,078 60,679
Acid Sewer 5,422 Lbs/day 6,179 9,963
Low Lift-2hr Average 30,018 Lbs/day
Primary Effluent 54,015 Lbs/day 60,028 99,266
Secondary Effluent 30,110 Lbs/day 36,271 50,789
#1 Sewer 120 Lbs/day 1,426 3,745
#2 Sewer 56 PPM 654 834
2B Sewer 510 Lbs/day 3,416 9,879
638 PPM 182 513
3A Sewer 14,870 Lbs/day 11,545 17,476
3A Calculated Sewer 4,820 Lbs/day, �
#4 Sewer 291 PPM 202 340
Contaminated Condensate Sewer Values
Concentration 198 PPM
Flow 790 GPM
Color 1,878 Lbs/day 2,673 4,923
Combined Condensate Sewer Values
Concentration 82 PPM
Flow 342 GPM
Color 760 Lbs/day 495 1,266
5B Sewer 8,150 Lbs/day 9,756 20,182
CRP Color 7,084 Lbs/day 1,847 3,602
Pine Bleach 6,710 Lbs/day, 8,887 20,334
Pine D1 5,000 Lbs/day 1,824 3,811
Pine Eo 880 Lbs/day, 6,026 14,660
Pine D2 830 Lbs/day 1,037 1,863
Hardwood Bleach 9,490 Lbs/day 8,535 15,314
Hardwood D1 5,550 Lbs/day 4,856 10,002
Hardwood Eo 3,940 Lbs/day 3,679 5,312
BFR Closure 87 % >85% <75%
Unaccounted Color -955 Lbs/day
Sewer Total 26,288 Lbs/day
New NCASI color test method which accounts for turbidity.
The Primary Influent Lower Action Level(LAL)and Upper Action Level(UAL)
must be exceeded for two consecutive days before investigative or corrective action is mandatory.
Immediate corrective action is required if 1-day out of control limit is exceeded.
Rev.5-7/25/2006 1/18/2007 4:55 AM

Canton Mill Sewers
Color, Conductivity, Flow and Fiber Loss
Overview - Mill Sewers Hil Fitter Plant Erco Flows - Color - Fiber
rzzfChemical Storage 0 2l2/20073:23:06 PM
0.32 MGD
3.41 MGD #19 PM
D g1oy F/L 4.08 M Lbs Color ED 6.44 Tons Fiber
Fill Riley Bark leach 468 Mlbs Color D-1 F4
Chg Boller Broke Plant 0.43 MGD #31PM
0.73 Tons Fiber
#2 Fiberline D
0.07 I 3.5 Delta
Tons Fiber 3.67 MGD AGI r. E 5.4 River Temperature
Acid Sewer 8.35 MLbs Colo S #1 "L
MLbs Color E Brown
1.16 Tons Fiber R Stock #14 PM Neer
S W ashing
335
tr MGD WBL #12 PM
#11 RB 4 Eva pa Power Power Boilers
Boiler 0.10
MGD jr
#10 R B
0.31 MLbs Color #11 PM
Kilns i s1st s0# 0.00 Tons Fiber 3.27 Tons Fiber
1.44 MLbsC or 3.70 MGD
22.91 Color 0 TN
Re- 0.01
i G HW 12.13 14.80 D.O. F'vl
Caust q Screen ® Tons Fiber f 1
Room \,_/ 19.38Tons Fiber
1.96 MGD 24.97e
10.25 MLbs Color 40923 #Color I 27.5
26.16 MGD Mill Yesterda 42593 W TP
9 Turbidly #Color �.J 4363
24.98 MGD
138.31 MGD River Flow Acid Sewer #pay 7SS —

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON,D.C.20460
F
Fx MEMORANDUM
DATE: July 25, 2001
SUBJECT: Additional Color Removal Technologies and Their Economic Impacts on Blue
Ridge Paper Products, Canton,NC
FROM: EPA Tech Team'
TO: Technology Review Workgroup
Purpose of this Analysis
As required by the 1997 Settlement Agreement,this memorandum presents a summary of an
analysis of available technologies that may be employed to further reduce color discharges from
the Blue Ridge Paper Products,Inc. (Blue Ridge) mill in Canton,NC. The analysis also includes
a summary of the economic impact("gross margin test") of the cost of implementing identified
color reduction technologies.
Members of the Tech Team visited the Canton mill on March 14,2001 to observe and gather
information and data on the status of technologies implemented and color discharges at the mill
since the 1997 evaluation. This final memorandum incorporates analyses of the data gathered
from that visit, and Blue Ridge's response to EPA's follow-up request for additional technical
and financial data. This final memorandum is based on the May 4,2001 preliminary draft
memorandum, and revisions to the July 10, 2001 draft final memorandum,based on a review of
Blue Ridge's comments, the June 8, 2001 Bleach Environmental Process Evaluation and Report
(BEPER) and subsequent comments by Liebergott and Associates and GL&V Pulp Group,Inc,
and additional comments from the Clean Water Fund of North Carolina, and the States of
EPA Tech Team is comprised of—Mark Perez,EPA/EAD;Karrie-Jo Shell,EPA Region 4;Don Anderson,
EPABAD;Betsy Bicknell,ERG,contractor;Neil McCubbin,subcontractor to ERG;Dan B dien 'subcontractor to
ERG.

Tennessee and North Carolina. This memorandum presents to the Technology Review
Workgroup (TRW)process improvements evaluated by the Tech Team and considered to.be
available technologies and briefly addresses relevant technologies evaluated in the BEPER.
Background and History
Blue Ridge operates a bleached papergrade kraft pulp and paper mill in Canton,NC, which it
purchased from Champion International Corporation in May 1999. Operations at the mill began
in 1908,but the mill has been extensively modernized, most recently in 1993. The mill currently
operates an 800 tpd hardwood pulping line and a 600 tpd softwood pulping line. After cooking,
pulp from each line is further delignified in single-stage oxygen delignification systems installed
in 1993. Hardwood pulp is subsequently bleached with a DEoD sequence; pine pulp is bleached
with a DEopD sequence. Target brightness is 85 ISO. Up to 80 percent of the filtrate flow from
the pine bleach line is returned to the recovery cycle using the unique bleach filtrate recovery
(BFRm)process, developed by Champion. A portion of the hardwood line bleach plant Eo-
stage filtrate flow is also recovered. Blue Ridge produces 250,000 tons per year of uncoated
paper including offset, tablet and envelope grades. The mill also produces 281,000 tons per year
of bleached paperboard used for liquid packaging and paper cups,including FDA approved
grades for milk and juice cartons. Since November 2000,pulp production has been reduced by
approximately 30 percent as the result of a major project to upgrade the No. 19 bleached
paperboard machine.
Continued Color Reduction Opportunities Since the 1997 NPDES Permit
The Canton Mill's 1997 NPDES permit included a schedule requiring continued study,
evaluation, and pursuit of effluent color reduction opportunities. Champion and Blue Ridge
submitted a series of reports to the NC Department of Environment and Natural Resources,
Division of Water Quality, evaluating the performance of the BFRTm process, end-of-pipe color
reduction technologies, and practices for minimizing color losses from manufacturing processes.
Since 1997 Blue Ridge has:
• continued full-scale operation of BFR for the pine line;
• concluded that full-scale BFR is not feasible for the hardwood line, but
implemented partial reuse of a portion of the Eo-stage filtrate as an effective
color-reduction approach;
• identified and implemented several practices for reducing losses of highly-colored
black liquor from manufacturing processes; and

Page 3
• evaluated 16 end-of-pipe color removal technologies and determined that they
were presently economically and/or technically infeasible for the Canton mill.
Process Improvements Analyzed by the Tech Team
The Tech Team identified five mill improvements capable of further reducing the discharge of
color in the mill effluent. For each of these improvements, technical feasibility, capital and
operating costs, and potential color reduction were reviewed. Each improvement can be
implemented independently of the others or in any combination. The costs incurred to
implement the improvements are additive,however separate evaluations are necessary to
accurately estimate the associated color reduction achieved by implementing any combination of
improvements. End-of-pipe color treatment technologies (e.g„ chemically assisted clarification
with sludge dewatering and disposal)typically require initial capital investment and ongoing
operating expenses,not savings, and are likely to incur non-water quality environmental impacts.
For this reason, the Tech Team focused on pollution prevention approaches that offer the
potential to be more cost-effective: color reduction in low flow,highly color-concentrated
wastestreams, through manufacturing process changes or in-process treatment.
The first two process improvements, discussed below (improvements in BFR reliability and leak
and spill prevention and control -Best Management Practices (BMPs)), are improvements which
the Tech Team concludes offer the highest certainty for technical feasibility and color reduction.
Blue Ridge also identified these technologies as feasible color reduction opportunities that will
be implemented,but differed from the color reduction estimates included in this memorandum.
The next two process improvements (ozone addition to an existing chlorine dioxide bleaching
stage on the hardwood fiber line; adding a second stage to the current oxygen deligni€cation
system on the softwood fiber line) also were evaluated by Liebergott,et. al., as feasible color
reduction opportunities. Additional technical evaluation and/or laboratory testing would be
appropriate to reliably determine the technical details of how to incorporate these processes into
the existing fiber lines and to more accurately predict their achievable color reduction, and the
relationship of these technologies to BFR. Additional analyses would be appropriate to
determine the most cost-effective design and the most economically feasible schedule for
implementing one or both of these improvements.
The fifth process improvement, color treatment for the chloride removal process (CRP)purge
stream (one of the two key components of the BFR process), has the potential for additional

Page 4
color reduction. However, based upon initial bench-scale treatability studies by Blue Ridge,
further study of additional color treatment technologies is necessary. Process optimization on
both the hardwood and softwood fiber lines, as recommended in the BEPER, is anticipated to
provide additional color reduction and is identified as the sixth process improvement. It was
concluded that the process optimization option was among those with the highest certainty for
technical feasibility and color reduction.
All color reductions resulting from the mill improvements are estimates based solely on available
data and information. While the Tech Team has concluded that these technologies would reduce
the color discharge from the Canton mill, there is a lack of directly comparable operating
experience with these technologies in other bleached papergrade kraft mills that can be used to
develop precise predictions of the extent of the color reduction benefits.
The BEPER evaluated additional in-process technology options for color discharge reduction
potential, including the implementation of a hot pressurized peroxide-enhanced extraction stage
in both fiber line bleach plants. At this time,the Tech Team does not have sufficient information
to confirm the applicability of this technology at the Canton mill nor relevant data to predict its
potential color discharge reduction capabilities. Therefore, while this memorandum does not
address this technology option, it may be feasible for implementation by Blue Ridge and
contribute to reducing color. In addition, the Tech Team did not analyze nor did the BEPER
recommend a Totally Chlorine-Free (TCF)bleaching option because of the high cost of this
technology and the lack of experience in producing and successfully marketing products made
by Blue Ridge at the Canton mill.
1. BFR reliability improvement. One of the two key elements in BFR is the Metals Removal
Process (MRP). Blue Ridge has found that this process element has been more challenging and,
expensive to.maintain than originally planned. The target BFR recycle rate (percent closure)for
the pine line is 80 percent. Due to unforeseen equipment failures (e.g., ion exchange media) and
metallurgy problems (e.g., erosion of multi-media filtration tank lining) in the NW, however,
the pine line closure has averaged only 74 percent from October 1998 to the present. Blue Ridge
has undertaken improvements to the MRP system in order to maintain the process closure rate
and increase operating time. Improvements include rebuilding piping and valves, and changing
construction materials and metallurgy to better withstand the chemical and physical stress
experienced in the BFR system. Blue Ridge estimates that if BFR closure is maintained at 80
percent, annual average final effluent color discharge will be reduced by 1,000 to 1,200 lbs/day.

Page 5
At this time, the Tech Team has no means of making an alternative quantitative prediction of
final effluent color reduction to compare to the Blue Ridge estimate.
2. Improved black liquor leak &spill collection and control (BMPs). The Canton mill has an
extensive spill recovery system. Sumps in this system,including one sump added in the court
yard adjacent to the digester house as required by the 1997 Settlement Agreement, are equipped
with pumps that are activated automatically when sensors detect wastewaters with high
conductivity and color. High conductivity material is routed to the recovery system. Further
improvements to the black liquor collection system include:
• continuous improvement of operating practices so more leaks and spills are
recovered rather than discharged to sewer;
• further improvement in preparation for planned outages to maximize capture of
tank clean-out waste and routing to recovery;,
• further reducing clean water that continuously runs into sewers to prevent dilution
of smaller spills and facilitate recovery of highly colored wastewaters; and
• further improvement in the equipment used for handling of knots rejects to
prevent black liquor leaks into the recovery sumps.
The plot below shows the color of wastewater treatment influent at the Canton mill. The
variability of influent color discharge to wastewater treatment is attributed to color discharge
peaks that represent,in part, unplanned spills or leaks discharged to sewers or intentional
diversions of highly-colored black liquor or other color sources routed to sewers during mill
equipment shutdowns.
100
kg/t Figure 1
75 Daily color at influent to W WTP for Canton
so
25
0 30 60 90 120 150 180

Page 6
Due to the nature of the manufacturing processes and practical equipment operation and
reliability, all spills and color losses to sewers cannot be fully anticipated,predicted, and
completely contained. However, a comparison of the variability of the Canton mill influent color
data to available primary influent color data at another bleached papergrade kraft mill indicate
that a detailed review of the spill prevention and recovery system at the Canton mill (by mill
staff or external consultants),including involvement by the mill operators,can further uncover
the causes of and better quantify black liquor losses and other color sources that can be avoided
or recovered. This will result in an overall reduction in color discharge, both in long-term
average and variability. Through improved planning of mill equipment shutdowns, continuing
efforts to minimize process operation variability, and increased recovery of highly-colored leaks
and spills, discharges of highly colored material to the wastewater treatment system can be
reduced more consistently below existing levels.
Further reducing peaks in color discharges within the mill and preventing highly colored flows
from reaching the wastewater treatment system will further reduce the variability of color
discharges from the wastewater treatment system to the Pigeon River. For example,limiting the
color of the primary clarifier influent to less than 70,000 lb/day through continuing efforts to
improve the mill's BMP system and process operations would reduce the color loadings from
mill processes to the end-of-pipe wastewater treatment system by more than 8,000 lb/day. The
Canton mill operated under this primary clarifier influent color threshold approximately 74
percent of 2000, excluding November through December 2000. This time period was considered
not to be representative of steady-state operations because of the reduced pulp production
resulting from upgrading the No. 19 bleached paperboard machine. Assuming the average
reduction of 45 percent across this wastewater treatment system for"brown" color derived from
black liquor,this would result in a minimum decrease of 4,400 lb/day in the average final
effluent color load.
Clean water, such as packing gland water,presently flows in several sewers with recovery
sumps. These colorless streams dilute other colored wastestreams, such as small black liquor
leaks and spills, to the point where the in-stream conductivity is too low to trigger recovery. By
eliminating clean water streams or diverting them away from sewers that collect black liquor
leaks and spills, wastewater streams with elevated color can be recovered more readily, resulting
in a reduction in color discharge to the end-of-pipe wastewater treatment system. Also, the
unintentional but intermittent discharge to the sewer of filtrate from knots and screen rejects can
be recovered.

Page 7
At this time, the Tech Team has no basis for determining an accurate correlation between
unaccounted color and sewer generated color, as reported in Section 2 of the Canton Mill
Environmental Performance Update presented by Blue Ridge during the March 14, 2001 Tech
Team Canton mill visit. During the March 14 visit,Blue Ridge staff indicated that results of
studies of sewer generated color showed a relationship between bleach plant filtrate pH and
temperature and unaccounted color generated in mill sewers. By operating within the range of
pH and temperatures identified during the studies the Canton mill has had some success in
controlling this source of unaccounted color. Based on this information,the Tech Team
concludes that by further reducing process operation variability, including operating within the
pH and temperature range identified during the studies, the mill can continue to also minimize
sewer generated color, thereby reducing one source of unaccounted color. Reducing overall
color discharges through BMPs and other management practices will likely further reduce
remaining unaccounted color. However, additional studies are necessary to further develop any
relationship between accounted and unaccounted color sources.
As noted above,analysis of primary clarifier influent color loading data demonstrates that color
loading to the wastewater treatment system of lower than 70,000 lbs/day is possible during
steady-state operations. Through continuing efforts to minimize unplanned spills and leaks and
intentional discharges of colored streams and continuing efforts to minimize process operation
variability,the Canton mill can achieve further reduced primary clarifier influent color loads and
subsequent final effluent color discharge within this range on a more consistent basis than
demonstrated in 2000 (i.e., more than 74 percent of the time). On this basis,the Tech Team
concluded it is feasible to reduce final effluent color by more than 5,000 lbs/day through
improved black liquor leak and spill collection and control.
3. Ozone/Chlorine dioxide stator hardwood bleach line. Ozone is used in more than ten kraft
mills around the world to bleach pulp,including two in the US and one in Canada. There are
several process configurations,but the most common is to operate an ozone(Z)mixer and
reactor immediately upstream of a chlorine dioxide reactor, without any washing between the
application of the two chemicals. This is known as a "ZD"stage. A system of this type was
retrofitted in the Domtar mill at Espanola, Ontario, Canada in 1999.2 Bleaching with ozone on
the hardwood line, one of the Domtar mill's two pulp lines, resulted in a 27 percent reduction in
the discharge of color in the combined mill treated effluent' The conversion to a ZD stage
z Munro.Fred and John Griffiths,Operating Experience with an Ozone-based ECF Bleaching Sequence,Tappi,2000.
3 Ibid.

Page 8
would reduce the use of chlorine dioxide and caustic chemicals for bleaching in exchange for
ozone. The energy requirements for ozone production would be offset by the energy savings
from less chlorine dioxide and caustic production, resulting in a net reduction in energy
consumption with the ZD stage.
As of September 2000, the long-term average color discharge from Canton's hardwood bleach
line was 12,800 pounds/day .The Espanola experience suggests that implementation of a ZD
stage in the hardwood bleach plant at the Canton mill could reduce the filtrate color discharge by
3,000 to 6,400 lbs/day. Based on comments received,the Tech Team acknowledges that
operating parameters, such as wood species processed and technology supplier performance
guarantees, may influence the practical color reduction achievable through implementation of a
ZD stage at the Canton mill, in comparison to the Espanola experience. These estimates are
based solely on the demonstrated performance and the Tech Team's assumption of color sources
at the Espanola mill, confirmed at the recent Pulp and Paper Technical Association of Canada
(PAPTAC) meeting in Thunder Bay, Ontario. Laboratory bleaching trials and possible
communication between Blue Ridge and Domtar staff would be necessary to reliably predict the
achievable color reduction possible with this option for the Canton mill.
The technical evaluation of this process improvement included in the BEPER yielded a
hardwood filtrate color discharge reduction within the range of Tech Team estimates.
4. 2ad stage OD for pine line. Oxygen delignification (OD) on the Canton Mill pine line is a
single stage system installed in 1993. It has been concluded that retrofitting a second OD stage
for the pine line could contribute to reduced color discharges in two ways. The first would be a
reduction in color for those filtrates presently not captured and reused in the BFR process. The,
second would be a color reduction in the Chloride Removal Process (CRP)purge stream as a
result of less chloride from chlorine dioxide used for bleaching.
Costs were estimated for a reactor with oxygen mixer and chemical charge equipment installed
upstream of the existing reactor. Previously, the Tech Team anticipated increasing the kappa
number(lignin content) of the cooked pulp from 24 to 32 and utilizing a two-stage OD system to
reduce kappa number from 32 to 11, an approximate 65 percent kappa reduction across the two-
stage system. Based upon comments from BRP and further technical analysis, and review of the
BEPER, it was concluded that it is technically feasible for a two-stage OD system at the Canton
4 Jacobs Engineering Croup,2001 Color Removal Technology Assessment,February 2001.

Page 9
mill to achieve an overall reduction of 50 percent in kappa number, rather than 65 percent as
previously anticipated. Therefore, with the Canton mill continuing to pulp to a kappa number of
24, the new two-stage OD system would reduce pulp kappa number into the bleach plant from
the current output of 16 to about 12,corresponding to a 50 percent kappa number reduction from
the current digester output of 24. The quantity of color released from the bleach plant will be
reduced in proportion to the reduction of the input kappa number.
By decreasing the kappa number of the pulp fed to the bleach plant from kappa 16 to 12 with a
two-stage OD system,the quantity of chemicals required in the first two stages of the bleach
plant can be reduced, because there is less lignin present in the incoming pulp to remove by
bleaching. The reduction in chlorine dioxide used for bleaching would result in a proportional
reduction in chloride load to the CRP and reduce color discharged from the purge stream in
proportion to the reduction in chloride being treated.
In response to comments received,it has been concluded that implementing a two-stage OD
system without increasing the kappa number of the cooked pulp from 24 to 32 would not achieve
a 1.5 percent pulp yield gain as anticipated with increasing digester kappa number and achieving
greater delignification with the proposed two-stage OD system. However, operating a two-stage
OD system with a higher than 50 percent delignification rate and a digester kappa number higher
than currently employed at the Canton mill is commonly seen at comparable bleached
papergrade kraft mills. Therefore,the Tech Team anticipates that additional process engineering
will maximize the benefits of a two-stage OD system at the Canton mill and enable the mill to
capture the increased delignifcation and yield gain potential of this technology and achieve
annual wood cost savings of up to approximate$950,000 from up to a 1.5 percent yield increase
across the proposed two-stage OD system.
Based on additional information supplied by Blue Ridge regarding operational limitations of the
BFR system,the Tech Team concludes that a two-stage OD system would not have a significant
impact at this time on the Canton mill's ability to increase BFR closure rate above 80 percent on
a day-to-day basis.
For this analysis, it was estimated preliminarily that a second OD stage could reduce total
influent color discharge to the wastewater treatment system by 1,500 to 2,000 lb/day from
reductions in pine line bleach plant filtrate color and CRP purge stream color.

Page 10
The technical evaluation of two-stage OD included in the BEPER yielded reduction in color
discharge influent to the wastewater treatment system within the range of the Tech Team
estimates.
5. Color Treatment of CRP purge stream. The Chloride Removal Process (CRP)purge is a low
flow,highly concentrated waste stream. Color is typically 50,000 pcu,in a 10 gpm(0.01 MGD)
flow. The CRP purge contributes up to approximately 5,000 lbs/day(13 percent)to the total mill
loading to the wastewater treatment system influent,but only 0.06 percent of the discharge flow.
It was originally speculated that it may be feasible to reduce the color in this stream by
precipitating the colored organic material with lime at a dosage of 20 g/I 5, and burning the
resulting sludge with the main lime mud stream fed to the mill's lime kiln. Laboratory trials
would be necessary to test the feasibility of color removal from the CRP purge stream by lime
treatment.
Blue Ridge subsequently conducted laboratory trials of color precipitation using four calcium
compounds, including lime mud, fresh lime, calcium chloride, and milk of lime. The
preliminary results of these trials show that at a dosage of 20 g/L,none of the compounds tested
reduced color in the CRP purge stream. Although color removal was demonstrated at higher
dosage rates, increased chemical usage would result in substantially higher operating costs,
require larger sized equipment at higher capital cost, and also result in a higher production rate of
sludge to be burned in the mill's lime kiln. Excess sludge produced from this process that is not
burned must be landfilled at additional cost.
Based on preliminary laboratory trials, Blue Ridge concluded that lime treatment of the CRP
purge is not a feasible color reduction option for the Canton mill. However,the Tech Team
recommends additional review of other innovative technologies for treatment of color in the CRP
purge stream, such as the application of the X-Filter process recently implemented at a totally
chlorine free (TCF)mi116. By minimizing color contributions from this stream,the potential
exists to achieve a significant reduction in primary influent color discharge of up to 5,000
lbs/day.
5 NCASI Technical Bulleting No.239,The Mechanisms of Color Removal in the Treatment of Pulping and Bleaching
Effluents with Lime.1. Treatment of Caustic Extraction Stage Bleaching Effluent July, 1970.
6 Comments on the Draft Report on Additional Color Removal Technologies and Economic Impacts for BRPP,Hope
Taylor,Clean Water Fund of North Carolina,July 18,2001

Page 11
6. Process Optimization. The BEPER identified sixteen recommendations for optimizing the
hardwood and softwood fiber lines, focusing mainly on the current OD systems and bleaching
operations. It was estimated that a reduction could be achieved in chlorine dioxide use in the
first bleaching stage of up to 27 percent for the hardwood line and 18 percent for the softwood
line. The reduction in chlorine dioxide use would result in a bleach plant filtrate color reduction
of up to 700 lbs/day from the hardwood line and up to 400 lbs/day from the softwood line. The
Tech Team estimated an additional color reduction from the CRP purge stream of 6001bs/day
resulting from the decreased chlorine dioxide usage. At this time,the Tech Team has no means
of making an alternative quantitative prediction of bleach filtrate color reduction to compare to
estimates presented in the BEPER. Therefore,it is estimated that through efforts by mill staff to
maximize the color reduction benefits from the process optimization opportunities identified by
Liebergott,et;al.,the Canton mill would achieve a total color reduction of 1,700 lbs/day in
wastewater treatment system influent.
Color Reduction Summary
The Tech Team estimates that by improving BFR reliability and black liquor leak and spill
collection and control,the Canton mill final effluent will be reduced by more than 5,000 lbs/day.
Process optimization, as outlined in the BEPER, would result in a further final effluent color
reduction of approximately 1,400 lbs/day. This assumes the average color reduction of 45
percent across the existing wastewater treatment for the CRP purge stream and other"brown"
color sources derived from black liquor and no reduction in color from bleach plant filtrates.
Table 1 presents a summary of the estimated reductions in final effluent color attainable with the
highest certainty by implementing improved BFR reliability, improved BMPs, and process
optimization.

Page 12
Table 1: Summary of Process Improvements and Associated Color Reductions
(Highest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/da ) (lbs/da )
1 BFR reliability improvement --- 1000-1200
2 Improved black liquor leak &spill collection and --- >5,000
control
6 Process Optimization 1700 1400
TOTAL FINAL EFFLUENT COLOR REDUCTION >7400
Additional potential mill improvements to reduce color discharge at the Canton mill were also
identified. These process improvements require further study to more accurately determine
achievable color reduction and thus are'not recommended at this time for immediate
implementation. These improvements include a 2D stage in the hardwood bleach plant, with a
preliminary estimate of a 3,000 to 6,400 lbs/day color load reduction in influent to the
wastewater treatment system, and a second OD stage for the pine line, with a preliminary
estimate of a 1,500 to 2,000 lb/day color load reduction in influent to the wastewater treatment
system. Table 2 presents a summary of preliminary estimates of color reductions for these two
additional process improvements that need further study. Reductions presented in Table 2 are
preliminary estimates with reduced certainty compared to those presented in Table 1,but are
based upon identified technology options available for the Canton mill.

Page 13
Table 2: Summary of Process Improvements and Associated Additional Color Reductions
Needing Further Study (Reasonable Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/da ) (lbs/da )
3 Ozone/Chlorine Dioxide stage for hardwood bleach 3,000-6,400 3,000-6,400
line
4 2nd stage OD for pine line 1,500-2,000 1,100-1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION 4,100 -7,800
Table 3 presents a preliminary estimate of color reduction potential for the removal of color from
the CRP purge stream. The Tech Team recommends this stream for additional review of
potential color reduction technologies but cannot identify, a particular technology option at this
time. Potential for additional color load reduction up to 2,750 lbs/day in final effluent to the
Pigeon River. Table 3 presents potential color reduction estimates with the lowest certainty.
Table 3: Summary of Additional Potential Color Reductions Needing Further Study
(Lowest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/da ) (lbs/da )
5 1 Color Treatment of CRP Purge Stream #5 000 #2 750
TOTAL ADDITIONAL POTENTIAL FINAL EFFLUENT COLOR #2,750
REDUCTION

Page 14
Economic Analysis
The estimated capital and operating costs for the process improvements one through four were
estimated and are summarized below. Costs could not be developed at this time for process
optimization or CRP treatment and thus are not presented. However, costs for these
improvements should be modest.
Table 3: Estimated Costs
Process Improvement Capital Cost Annual O&M
($) ($/ ear)
1 BFR reliability improvement $1,300,000 $85'0006
2 Improved black liquor leak& spill collection and $100,000 $50,000
control
3 Ozone/Chlorine Dioxide stage for hardwood bleach $1,500,000 ($350,000)
line savings
4 Ind stage OD for pine line $2,000,000 ($2,100,000)
savin s
Blue Ridge Paper Products Inc. was formed in May 1999 with the purchase of seven
plants (including the Canton Mill)from Champion International Corporation. Blue Ridge Paper
Products is owned 55 percent by KPS Special Situations Fund, L.P. and 45 percent by the
employees of Blue Ridge Paper through an employee stock ownership plan. At the time of the
1997 report EPA documented substantial losses over five years for the Canton Mill and
Champion had just announced its intention to sell or close the mill. However,because of the sale
of the mill to the Blue Ridge, the previous data are not comparable to the more recent data.
Further,the data submitted by Blue Ridge is still confidential, so this report cannot present as
much detail as the 1997 report.
The current analysis is based on information submitted by Blue Ridge covering part of
1999 (May-December) and all of 2000 (all of the existing financial data for the company). The
results may be relatively uncertain because of the lack of data and the company may be too
young for the current data to reflect its ultimate financial health. EPA used three measures of
financial health (gross profit test, discounted cash flow, and Altman's Z)7 to assess the impact of
See Interim Economic Guidance for Water Ouality Standards:Workbook,EPA 823-B-95-002,March 1995,and
Economic Analysis for the National Emission Standards for Hazardous Air Pollutants for Source Category:Pulp and
Paper Production-Effluent Limitations Guidelines,Pretreatment Standards.and New Source Performance
Standards:Pulp.Paper.and Paperboard Category—Phase 1.

Page 15
air emissions control technologies and devices (not addressed in this memorandum, such as
MACT II and regional NOX control) and wastewater compliance costs (separate and combined)
on the mill and company. The costs for the wastewater control options presented in Table 3 do
not change the financial status of the mill or company. However,the costs for some of the air
emissions control options do impact the health of one or both entities. When the wastewater
costs are added to costs for air emissions control, the impacts of the water costs do not change
the financial status of either the mill or company when compared to the impact of the air costs
alone.
References
Blue Ridge Paper Products,Inc. Canton Mill Canton Mill Environmental Performance Update,
Prepared for U.S.EPA Technology Review Workgroup. March 14, 2001.
Blue Ridge Paper Products, Comments on and Transmittal of Financial Data for Economic
Analysis of Blue Ridge Paper Products,from Bob Williams,May 18, 2001 (CBITS 00003911-
01)
Comments on Preliminary Draft Final Tech Team Report, email from Derric Brown,Blue Ridge,.
to Don Anderson,EPA,May 18, 2001
Comment Clarification of May 18, 2001 Blue Ridge Responses to EPA Questions,from Derric
Brown, Blue Ridge,June 4,2001
Comments on Draft Final Tech Team Report, from Bob Williams,Blue Ridge,to Don Anderson,
EPA,July 13, 2001
Comments on Draft Final Tech Team Report, from Derric Brown, Blue Ridge,to Don Anderson,
EPA, July 17, 2001
Comments on Draft Final Report,email from Forrest Westall,North Carolina DENR,to Don
Anderson,EPA,July 17, 2001
Comments on Draft Final Report on Additional Color Removal Technologies and Economic
Impacts for BRPP,Hope Taylor, Clean Water Fund of North Carolina, July 18,2001

pppppp,
Comment on Draft Final Tech Team Report, email from Paul Davis;State of Tennessee, to Don
Anderson,July18,2001
Comment on Draft Final Tech Team Report, email from Lew Shackford and Norm Liebegott,to
Don Anderson,EPA,July 19, 2001
Jacobs Engineering Group,2001 Color Removal Technology Assessment,Blue Ridge Paper
Products Inc. Prepared for The North Carolina Division of Water Quality. February 2001.
Liebergott,Norm, and Lew Shackford,Bleach Environmental Process Evaluation and Report,
June 8, 2001
McCord,Aimee,A Laboratory Analysis of Color removal Across a Pulp and Paper Mill
Wastewater Treatment Facility, Canton, North Carolina,Duke University, School of the
Environment, 1995
Munro,Fred and John Griffiths, Operating Experience with an Ozone-based ECF Bleaching
Sequence, Proc. International Bleaching Conference,Halifax, Canada, 2000. TAPPI Press.
NCASI Technical Bulletin No. 239, The Mechanisms of Color Removal in the Treatment of
Pulping and Bleaching Effluents with Lime. L Treatment of Caustic Extraction Stage Bleaching
Effluent. July, 1970.
Salisbury, Chad A Laboratory Analysis of Color Removal Mechanism Across the Wastewater
Treatment Facility of a Pulp and Paper Mill, Canton, North Carolina,Duke University, School
of the Environment, 1996
Springer, Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry. Page 182
Wiley Interscience, 1986.
Springer, Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry,3`d edition.
Page 286. TAPPI Press, 2000.

Appendix 1: Color Balance(9/1/00 to 12/31/00)
Figure 2.6,Presented by Blue Ridge on March 14,2001
Sewer Description Color Load
ID (lbs/da )
213 Digester area sewer:Digesters, HW 4,323
line,knot rejects
3A Alkaline sewer: Pine and HW Eo, 12,954
Pine line BSW,02 Deli
1 PMs11 & 12,HW weak liquor tank 1,991
5B Recovery,BLOx, CRP* 7,852
6A Acid sewer: Pine and HW Dl 17,345
filtrate+Pine D2 filtrate
Contaminated Condensate 1,591
Combined Condensate 260
Total 46,316
Primary Influent(PI) 49,284**
Unaccounted Color Z968
(PI minus Total)
Secondary E uent 37,696
Percent Removal in Treatment 23 %
* CRP contributes 5,000 to 6,000 ibs/day to 513 sewer
** Measured using test method in NCASI Tech. Bull. 803,An Update of Procedures for the
Measurement of Color in Pulp Mill Wastewaters,May 2000.

Appendix 2: Table of Effluent Color Limits, 1997 to Present
Color Limit True Color(1k*
Monthly Average Annual(Long-term)
Average
1997 Permit 125,434 98,168
Settlement Agreement,February 1998 69,000 60,000
(starting December 1, 1998)
Settlement Agreement,February 1998 --- 48,000 to 52,000
(Ultimate Target)
Interim Limits,May 2001* 1 55,000 48,000**
* As recommended by Technology Review Workgroup (TRW) and incorporated by NC in
BRP's NPDES permit.
** Reduced end-of-pipe color discharges since November 2000 reflect, in part,reduced pulp
production (approximately 30 percent) during this period because of the ongoing project to
upgrade the No. 19 paper machine used to produce bleached paperboard.

Appendix 3: Ozone Bleaching
Munro,Fred and John Griffiths, Operating Experience with an Ozone-based ECF Bleaching
Sequence,Proc. International Bleaching Conference,Halifax, Canada,2000. TAPPI Press.

prrlw�__
Appendix 4: Two-Stage Oxygen Delignification
Comparison of one-and two-stage oxygen delignification systems
Item Current Sin Ze-Sta e System Proposed Two-Sta e S stem
Oxygen Reactors One two
Input Kappa Number 24 24
Output Kappa Number 16 12
Total C102 Used 28 k ton* 22 k ton*
Oxygen Used 23.4 k ton* 28.3 k ton*
Total NaOH Used 45 k ton* 37 k ton*
* air-dried metric ton of bleached pulp