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Home My WebLink AboutNC0000272_TechReviewWorkgroupMeeting_20031226 Technology Review Workgroup Meeting Agenda Blue Ridge Paper Products Inc. Canton, NC Tuesday, December 16, 2003: 8:30am —2pm • Welcome/Background Bob Williams • Pigeon River Re-introduction Effort Dr. Larry Wilson • Environmental Capital Plan/Financials Bob Shanahan • 2001 Permit: Color Reduction Improvements Michael Ferguson • Color Performance Melanie Gardner and John Pryately • October 2003 Report Bob Williams • December 2003 Report Bob Williams • Questions • Lunch • Tour ��S� ,OoO or N,�sk Swr p l;v,1ia--mlR4w7*C `9;?4/2zpw1j All G'Vli e, mjinsa,--� Q 6. U Q L�2Q 6i(� 2Y�C, �lerrKe, lye( USEPA - /2egi T70 5 % Q g30g L a �c�es tJc ,J� 8a8-2& l- Owe 14 . 8 Z 8 - 6`I In-9 3.19 -Dary� i _ tom nh l U11t�A Co I - 7�t - 66�f3 IL`c�ea„Q L-?'� «Nsv�r r) �} 4o �4-z 3333 o `�E� `t�C � (2yz� 566 (OZ( epA // /, lZoz� Sto6—io4�f J x 24,tto wpP , Y6 S S 9j/ - � ll�oc Agenda • Welcome/Background. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Bob Williams • Pigeon River Re-introduction Effort. . . . . . . . . . . . . . . . . . .Dr. Larry Wilson • Environmental Capital Plan/Financials. . . . . . . . . . . . .... . . ..Bob Shanahan • 2001 Permit: Color Reduction Iinprovements.. . . . ...Michael Ferguson • Color,Performance. . . . . . . . . . . . . . . . . .Melanie Gardner and John Pryately • October 2003 Report. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..Bob Williams • December 2003 Report. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..Bob Williams • Questions • Lunch • Tour Pigeon River A Survey of Pigeon River 7 Re-introduction Efforts iw Joyce Coombs,Virginia Harrison,J,Larry Wilson ~ K Unfvers7tyof Tennessee �.a Department of Forestry,Wildlife and Fisheries Jonathon Burr Tennessee Department of Environment and Conservation,Water Pollution Control _J Knox llle,Tennessee - Pigeon River has suffered historical Management Goals degradation from Industrial discharge. • UT goal:to coilect,tag,and track • Water quality improvements have led to the return of some fish species. reintroduced fish.species • Joint re-Introduction project by TDEC-WPC, ., L�`� - TWRA,TVA,USGS,USFWS,NCWRC, BRPP,CFI and UT • Stale goal:reintroduce native species as part of efforts to restore river ecosystem health and designated usages Pigeon River Pigeon River 1983 1995 4 1 Pigeon River, Newport Annual Mean Effluent Color(Ibs/day) Including Permit Limitations(Ibs/day) February 2002 1988-2003 ®� - 777777 Native Fish Collected 1988-2001 Pigeon River: Moderniutlon What Species are Missing? bluebmastclartar gilt darter _ tangerine darter olive darter N 0Donton if _- rlverdarter wounded darter ■Tannery shlpetall dader longhead Bader blotchslde lotipeah blueslde darter Nwarpilntshlner eWped ahlner - mI.rshln., samm.ahlner stamadng minnow mink shiner bullhead minnew blotched Nub a epatfln chub mountain madtorn northern sb.alish moumalnbrooklampmy Z American brook lampmy mooneye yea s Pigeon River: Tagging Mollusk Populations ggIn g • Approximately 40 species of native mussels are believed to have thrived In the Pigeon River historically.There are no native unionid mussel species populations. r: r • several species of river snails were re-Introduced in 1996 (Lepfoxis sp,Pleurocen,sp.,Elimia sp.)and 109(In sp., campelema sp.,Lithasia spJ;Leptoxls sp.and Pieurocera sp. are reproducing well - ♦y - • Re-introduction of mussels began In 2000•Survival of some mussels has been observed but reproduction Is Indeterminate at this date. 2 Tagged to sp. Spiny Riversnail to fluvialis j� Fish Consumption Advisory Pigeon River: Trend summary and Current Status WAR�111NG CARP • IBI scares have risen from'poor'In late 80•s to CATFISH 'good'range In 2000 k�V • strong Improvements in species diversity, } Ehw v�,md c amwNnam.s abundance,and sport fishery M.aw hc(Eo7 •�l EEI�ic•^�' �,2C,�-CCrj eE er uAwn •� idm•� • Fish Consumption Advisory removed entirely. ee fish shodid n• 0t 1)6 eetel4y chi�fl'6�. • Agencies began ra-Introducllonsof native fish pregnentGrnursingwv n�?ue, e,T,�. species in March 2001 CdOSllm G W ar • A total of eight species re-Introductions Re-establishing Native Fish Initial Candidate List 2001-2002 Criteria for selecting candidate fish species to be relocated to the Pigeon Included: • Gilt Darter—Percina evides • Historic range • Bluebreast Darter—Etheostoma camurum • Available habitat • Blueside Darter—Etheostoma stigmaeum • Ease of collection and transport • Stargazing Minnow—Phenacobius uranops • Available in large numbers nearby • Mountain Madtom—Noturus eleutherus • No listed species 3 I Gilt Darter Bluebreast Darter Percina evides Etheostoma camurum Blueside Darter Stargazing Minnow Etheostoma stigmaeum Phenacobius uranops Mountain Madtom Methods Noturus eleutherus collection by seining from Little Pigeon, '+ - _ t•s Nolichucky,and French Broad Rivers • Tagging with various colors of Visible Implant Fluorescent Elastomer(VIE) • Snorkeling surveys to locate the tagged ti- fish and YOY tq 4 Collecting Fish: Field Tagging Nolichucky River VIE Tagging Injecting VIE • � a . 1111P, Transporting Fish VIE Tag Under Blue Light t j • r arA Acclimation and Release 2002 Snorkel Survey z� 2002 Snorkel Survey 2002 Snorkel Survey Results • Observed 175 fish,a density of 58.3 fish In 600 m2 or 19.4 fish1100 m2 • Primarily Gilt darters with few bluebreast darters • Representatives observed from all 4 batch re-Introductions of gllt darters Phase 1 Observations 2003 Project Activities • Re-Introduction of selected darters to the • Relocated 3 new species for 2003: adequate habitat Is Identified Pigeon River appears a where American brook lamprey,mountain brook lamprey,and stdpetalldarter • In the lab study,VIE tag retention was - Relocated additional common snails good for 100+days and did not cause mortalities • Monitored survival,movement,and • In the field study, VIE tags have been reproduction in tagged Individuals retained over 2 years 6 Collection Results Collection Results Tagged and relocated as of 10/28/2003: Relocated as of 10/28/2003: Blueside darters 766 Stargazing minnows 270 Gilt darters lots Mountain madtoms 381 Bluebreast darter 334 American brook 477 lamprey Stripetall darters 493 Mountain brook 239 lamprey American Brook Lamprey Mountain Brook Lamprey Lampetra appendix Ichthyomzon greeleyi s Stripetail Darter River Snails Etheostoma kennicotti pe Pleurocerasp. Leptoxissp. 7 Pigeon River: Snorkel Survey Results 2003 What Species are Still Missing? Ungerl aatdaeaadserved 102 Gilt darters during blu.b.a darterr out diva lonrt • Ober 9 random &e,darter wounded darter transacts of 21 habitat sites .Idpwn darter lwalwad darter —18 tagged,ed entagged blatchtlde laeperch blue.lde darts 99 mrpalnt sinner sWMd sinner • Gills were located at seven sites Including the mlrrorstdn.r .am=shloer re-Intro site stargazing mlm,ow mimic s Iotr • Three genera of river snails(to,Leptauds, buOlead minnow blotched chub Pleurocera)were located at five sites: spolnn chub rn u madlom 3•,TI"',+1"',+11',+18'(Denton"') .orth..rlca audfthookl mountain brook Lamprey Successful recruitment for Le toils and Amad.•^brook lamprey moo^aye P amt aao:awe Pleurocera Movement and Recruitment Tf"fig ram. Pigeon River Re-introductions t. Year Organism Genera/Sp. Individuals �T/ r 1998.2003 Snail 8 60k-80k '�i„ - :,_„'-n•• 2000.2003 Mussel 9 145 2001-2003 Darter 4 sp. 2608 (� } _ 2002-2003 Madtom 1 sp. 381 2002-2003 Minnow 1 sp. 270 .. n ,'r' ate ? 2003 Lamprey 2 zip. 716 a� 2004 Project Plans-TN Tangerine Darter Percina aurantiaca • Continue relocation of current species • Relocate additional common snails • Continue to monitor survival,movement, and reproduction In tagged Individuals • Begin propagation of the tangerine darter •"�'` ' • Analyze aquatic Insect data 8 2004 Project Plans-NC NC Candidate List • Complete habitat assessment of NC reach of • Silver shiner—Notropis photogents Pigeon River • Identify candidate species and sites for • Saffron shiner—Notropis rubricroceus reintroduction • Telescope shiner—Notropls to/escopus • Identify sources for re-Introduced species • Tangerine darter—Perolna aurantlaca • Analyze aquatic Insect data • Golden redhorse—Moxostcma erythrurum Questions? a I 9 Presentation to the Technology Review Workcgroup Tuesday, December 16, 2003 Blue Ridge Paper Products Inc. Cantor, NC N W A Ut O V O O O O O O O O O O O O O O O O O O O O O O O O O O O O O Jan-88 i Jul-88 Jan-89 I Jul-89 Jan-90 Jul-90 i Jan-91 - nil Jul-91 I Jan-92 Jul-92 UG Jan-93 Jul-93 Jan-94 700 n Jul-94 00 O Jan-95 0 Jul-95 Jan-96 Jul-96 oC Jan-97 0 Jul-97 Jan-98 I r-h I Jul-98 Q Jan-99 Q Jul-99 n Jan-00 Jul-00 Jan-01 I Jul-01 Jan-02 Jul-02 Jan-03 Jul-03 Pigeon River Color Upstream of the Mill and at the State Line Monthly Averages from Jan-88 through Nov-03 250.0 — --—— ------ — 200.0 --- 150.0 — -- C 7 o _ O 100.0 50.0 0.0 OJ C? O O O W in m O O N N ao o? m rn rn rn rn m rn rn rn rn m rn m m w 9 9 m T m 9 o 0 0 0 0 0 0 0 C j C = C C j C C C C C C j G G j C j C j C j C ♦Upstream Color o TN/NC Color Pigeon River Color at Hepco Monthly Averages from Jan-88 through Nov-03 350 300 250 - - `0 200 - --- -- - - 6 U m 2 150 f- 100 50 0 00 00 00 00 00 00 O^ 0^ 0r 0� 0� 00 Ot 0t 0� OP 00 00 O� O� 00 O� 00 00 00 00 O^ O^ O� O� O� O� 'J� �J� @� �J 0� sz� 0� ,J 3C 'J 0C t Hepco True Color Environmental Capital Plan/Financials Blue Ridge Paper Products — Canton Mill Regulatory Impact Regional Haze VISTAS TRI I w. ;L G , , ,,. �• � _owerThreshold �{ h global Chmate? ri Change.. Title V' P;M/Ozone NAAQS Hs _ a „•. NoX Controls , n Combustio MACT.,,k -- . ._ _ � � � �11 r C 4 6k t RCRA ._ Cluster Rule&: ml MACT �'1VIDL Cooling' a QS � .r: 61 6B7� Compliance Maintenance,- $14 Million o 6 eb9 2001 NPDES Permit Color Reduction Improvements Table of Color Reduction Measures Color Reduction Measure 2001 2002 zo03 2004 zoos 2006 I 2-Hour Color Testing .. .. ;; 2 Liebergott Recormandations Impletrnnted 3 Use of Off-line Clarifier 4 Hwd Brown Recovery Tank Line to Pine Blow Tower 5 1-Hour color testing before and during maintenance outages � 1 6 Installation ofMechanical Seals - --- ' 7 Improvement of equiprrent used for handling Pine and Hardwood Knot Rejects 8 $1.5MM spent on Bleach Filtrate Recycle hr{rroveurarTts 9 Installed Pine Brownstock Control Logic improvements —-- 10 Detemrined multiple contributers and interaction effects causing Sewer Generated Color , '- 11 Bench-scale sewer-generated color work --'" 12 Process Optimization/Six Sigma Team designated for -7—�- -'- --T- Hardwood Ffberline color in-proverents 13 Improverrents nade to Pine Brownstock sunps for better recovery 14 White Rot Fungus Trial-growth efforts unsuccessful,Tray re-visit in future. 15 Pine Brown Recovery Tank Line to Hwd Blow Tower —T -- -----"-- - -- 16 De-Watering/Disposal ofPine and Hwd Screen Rejects 17 Pilot Scale Plant for Ozone De-Colorization 18 Inplerrent full-scale Ozone De-colorization systemifPilot- scale study is successfulFEW r_ 9 . i �i'p 4��j `,t � "# � • � �,'• ,'yn9 y xe � qi #1:'P' :-,I, 1 ° +{ WN STOCK `StTI°LTA v x 4 a . r H10SO4 £'. 5s LLE�CTIOM TANp{�� I as�` °+.ra'Se..% +%v a. w'#.{ " & Y+ 4e; "e"tp'�°§'�.3STe `4 , • + + ea+y� raa.)�}l��+t P v wig .F `t&'4'F'. A.oxa. ,,tr `'y�"q"st`' '!'' i` �� y8P'fLL,+TFiK'.R�CTI�C-:• i e{ :_� , �#U :;,°^� tHl�� s'�B: i + �':. �,s PC0494 R + P.SIG 2 5 i .q. . } *AUTO 0. 0 '. I i✓. . � T r Yhi ,Po a' M Y +PY I '� AP •� Y '$ { a 4 , f 3 i�'eA x e' :y��p ST, a, ��s��rbck �� • , � xsso��sTCSGK I 049la • 2ND I ' AT0513 �wak 216 uMH0 ipWASHER 1 24 uMHO r . HIE k 7MR e ' e ' SPILL TANS{ LE(k�L • LC0495 :1, F, •zt P C T 1 7 Y 0 — K SPT 20.0 FC0496 - t ' GPM —1 . 0 } TANK FARM 'LOC 100.0' _ BROWN .STt{ AUTO 700.0 4 .„.. s SUMP PUMP .,' a PEND ,. s / t s ® • Y } � ;o fi fIOU v 1 Y� 1� f ow tx BFRTM Improvements • Greater than $ 1 .5 MM has been spent to improve BFR over thelast 2 years • Three phases of improvements: R� — piping 0(Ca k � ��ash �':l�ecsloss s�c.:..�ess — Media Filters ,-a( r — Ion Exchange Softeners oAK • Improvements; completed in October, 2003 — Just now beginning to see true benefits • Goal: To get. rid of the individual component liability and reach 1000X -Uptiine with the exception of planned outages. {r ? -`�i�i � '�• A RBI�-, {54 � s. 4f►� f I T +t All x <. �1u9�1 OI 1.� IMIWgL" i°7.I .+1 I I' �Lv mF i• " I— II�� Ilti, �� '� `"w '�"•� � � .IP 4 '9�• r yr � r I -rrs ^'• ek ,.,:... r. .� „ A ,'a _ IK� fir, • 4" - fl'hM �r BFRTM New North Media three Media Filters to Filter -. allows for remain online if one req-41res repairs. - 7 ti p■ .a i^ •, ^� M . ` i � BFRTm Improvements Continued • Top view of three04 original Media Filters, which have all-been11 replaced to reduce MRP downtime, and is improve throughput-. ' I af :' - r MRP Uptime 100 90 73 80 70 60 — — x 50 — r#{ 4zp Uptime 40 m - IN can 19 bcs t yI 30 20 r 10 O O� ,O✓ ,O✓ ,O� O� O� O� ,OJ P\0 C6eIR All, m a • " •AVATA I 10 M4 I I a 01 UN• 1=1 17 M 1111111 . • • ' • � x AZ C4 I , Rap ' f < v f Improved .System for. Handling Pine and Hardwood Knot BirRejects z kHardwood Knot Bin — grating prevents knots from entering U-Drain but allows filtrate to flow to dedicated sump ! k pump for recovery to the Hardwood Spill Tank. ^r y Pine Knot Bin Sum � Pum p _ , . p r t L il< "-' t m^ 4 I'•- k k � L a �� ; '�`� «T @: e R.�x ;,�,r �. ��r y g�• � y #+r j t 9Y ttif�n; Y cr �x' n �a t'i `1xm �' CV ® Ah sm WMA sr, A}< `g`\ -r ` •. �. r (., $ RL , a„�'--�-- :{fey�gJ�� '%�- �,i/.t � !` = ��s "l�i+'f , 'r r��j 9°�u '� 0.}t°,z:, rk+. I ' ." •c. 46 .` �p�'+'.,' i �'k��7ruw• �(LI li " I, f�a:3 a r. �r„ � /,l +k,{y" ,rf - -.,.Fw —1'CO:+ ) 1 =- .. x man. ".�'ES- -.-. �` '�+r�av+x ,. � �';"�P .15...a�r+_�„�-x-.-,.- F—•-•-�•-'� .�'. ..G*`_.."._=:3i"....�..1 sty."'•-�="""'r", -�/'4��•F�`.A`2,,�<�'.6a"A.sPq..A°®ra�n> +-.�..^i ��ti.i�..ti. •I ` �__ '+7: t"e ti' .. �:.. s a ++'�,aur _ .r w•'�. a .r`�"^'� SR �y]T,,,,,� - p" �' t�� ---•_s`'smr,--.-�` � � � �`IIf �1 � "W �i, � r i tIQ ��11S2-iFI • 11 �y ,�` \ � ,� �t�``"' �``�.,,,� 4J^ ✓'�4 t , P '. yl Tr 4'riTl^ a ".'-.'^�^ r k. 7xY t , + , e` � ,� how' P " •�, � x ,1 Installation of Mechanical Seals • Customized Double a Mechanical. Seals and 3f Rod Water Management k Systems have been installed on the 18s digester re=circulation pumps for clean water reductions in the - Digester Courtyard.. a a . , a . , ; .• . ... =' Increased Color Testing and Improved Communications y� k tM k t'""Ft ,f r' Around-the-clock 2-hr '" tt . r A color testing on the rho ��4i iSk Primary Influent pF Color testing every g w'� +: hour before during �. and upon start-up of T P" outages if E ° ' At°' • WWTP Crew leader communicates Y r . * elevated color results to Pulp Mill and Recovery Foremen Color (lbs/day) N W A CT m O O O O O O O O O O O O O Jan-01 I I Feb-01 Ml I Mar-01 I Apr-01 I I I I May-01 I Jun-01 I I Jul-01 Aug-01 I Sep-01 O 0 ct-01 Nov-01 Dec-01 I `C Jan-02 I I �D Feb-02 Mar-02 CD CD Apr-02 rt cn CD M ay-02 C O Jun-02 Jul-02 O Aug-02 Im O Sep-02CD w 0 ct-02 rt Nov-02 O Dec-02 p Jan-03 Feb-03 I I I Mar-03 Apr-03 I I M ay-03 I Jun-03 Jul-03 Aug-03 I I I Sep-03 I 0 ct-03 I I I Nov-03 Average Sewer Area Color by Year 1997 - 2003 (through November) 35000 30000 Note:for 2002, 5,000 Ibs/day was included for contribution from Quaternary Screen rejects. For 2003, 3,000 Ibs/day contribution was 25000 included. II 20000 0 t15000 ._ U 10000me _ s to 5000 ` r, 0 ` 1 "All 1&2 FL's D1 + 56- Recovery, 3A- No. 1/2 Eo, 213 - Digesters, Unaccounted Phis- 11 & 12 Contaminated Combined Pine D2: BLO,CRP No.2FL BSW, No. 1 FL Condensate Condensate 02 Delig p 1997 ®1998 ❑1999 p 2000 E 2001 u 2002 (E 2003 1997 Average Measured Color in Mill Sewer Areas as a Percentage of Primary Influent Color Annual Average PI Color = 87,485 Ibs/day Annual Average SE Color = 62,318 Ibs/day 0% 12% E 2B - Digesters, No. 1 FL: 10,342 ppd h i( ■ 3A- No. 1/2 Eo, No.2FL BSW, 02 Delig: ` 14,122 ppd o 39/0 X 16% r' ❑ PM's- 11 & 12: 5,120 ppd t eK M 513- Recovery, BLO,CRP: 10,871 ppd IN 6% 1&2 FL's D1 + Pine D2: 13,407 ppd 12% ❑ Unaccounted: 33,601 ppd 15% 2003 Average Measured Color (Ibs/day) in Mill Sewers as a Percentage of Primary Influent Color PI Color = 56,568 Ibs/day SE Color = 45,192 Ibs/day 7% 1% 15% 3% s ❑ 1&2 FL's D1 + Pine D2: 8,196 Ibs/day 5B- Recovery, BLO,CRP: 12,074 Ibs/day xK p 3A - No. 1/2 Eo, No.2FL BSW, 02 Delig: 10,196 Ibs/day 27% ❑2B - Digesters, No. 1 FL: 2,593 Ibs/day 23% ® Unaccounted: 14,270 Ibs/day " p PM's- 11 & 12: 1,824 lbs/day Contaminated Condensate: 3,956 Ibs/da ❑ Combined Condensate: 459 Ibs/day 5% 19% Historical Sewer Generated Color Studies. • 1995 Study was performed to determine if sewer generated: color is removed across the WWTP — Average SGC for Pine Dlwas 32-47% — Average SGC for Hardwood D l was 6.4- 8 8% — Pine filtrates increased in color an average of 21 % across the WWTP — Brown source color removal ranged up to 70% across the WWTP, in this study Historical SGC Studies Cont. hd • 1994 Study was performed to determine what type of color-the WWTP is removing and what factors are significant. in that process . — Brown color sources were removed across the reactors by an average of 62% — Bleach plant color inereased across the reactors by an average: of 3% Recent Benchscale Sewer Generated Color Work Col a Pine D1 Filtrate V6 Simulation of In-mill Sewer Mixing and Resulting Sewer Generated Color Samples taken 11/30/03 - 1218/03 3500 pH was increased to 11, then brought back to 7.6. 3000 Color measurements were made at each incremental pH. 2500 — 0 2000 F 1500 �.,., Original Sample 500 0 2.75 5 7.15 9 11 9 7 7.6 pH Benchscale Study Continued. . . Pine DI at ph 9 111 11 111 CL 15 11 py�v�..�-��s-v.�..a��r °t v ° . a°' �� ^`1 w ✓"^ 1..+�"e' � v °v n . �`^.T'^mn.a+4V„ ��n a T� ° v #e°N� ° � • w �.'sd o fig. e � e 4 ft S•�v y 'r@ a +.. y !� & '§8� 4e� � 1 1 11 11 11 11 11 11 11 11 11 11 Date Sampled . pH Decreasing pH Increasing Pine D 1 sample at different pH ' s � ,xi X j1 xt v •ze. ;.. M hING 10 . [ �- kf � ,fit-• �� x � � �" ... .—,�,a� �x$� � "T�. �,/ui Original Pine D l-filtrate, pH = 2.7 Pine D 1 filtrate at pH = 10.9, filtered 4 times October 2003 Report • BRPP recommends an annual average Secondary Effluent color limitation of 42,0OO lbs/day • BRPP recommends a monthly average Secondary Effluent color limitation of 52,O00 lbs/day December -2003' . Report • Current strategy , to remove additional 3 ,000 — 8 ,000 lbs/day- is to: = — De-water/Dispose -of Quaternary Screen rejects — Pipe Pine- Brown Spill to Hardwood Blow Tower for additional capacity' , — Process Qptimization • Hardwodd washing • Sewer Generated Color;'_ _ e ~ ProposedO, , z,, ,on. , e. ? Color Reduction Treatment • Lab study showed 70 % color reduction offHardwood Eo/CRP Purge mixture is possible. Pilot scale study must be conducted to `determine overall feasibility and true effects on mill effluent color. - r +.a �4 a Questions ? Lunch Tour i evergreemo Canton Office 175 Main Street• Canton, NC 28716 packaging August 26,2011 Hand Delivery Keith Haynes Acting Regional Supervisor Division of Water Quality,Surface Water Protection North Carolina Department of Environment and Natural Resources Asheville Regional Office 2090 U.S. Highway 70 Swannanoa,North Carolina 28778 Re: Color Reduction Implementation Plan—Report on TRW Recommendations in May 2010 NPDES Permit NPDES Permit No. NC0000272 Blue Ridge Paper Products Inc.dba Evergreen Packaging Canton Mill Dear Mr. Haynes— The enclosed report documents Canton Mill work during the first year of the May 2010 NPDES permit related to February 2008 recommendations of the EPA Technology Review Workgroup(TRW)that were incorporated into Part I A.(8.) item 10 of the permit. The report is required by the permit. It is a supplement to the Annual Progress Report on Color submitted on July 1,2011. Very truly yours, BLUE RIDGE PAPER PRODUCTS INC. DOING BUSINESS AS EVERGREEN PACKAGING By: I Nick McCracken Paul Dickens Water Compliance Coordinator Manager Environmental Affairs Canton Mill Canton Mill—Waynesville Plant nick.mccracken@everpack.com paul.dickens@everpack.com 828-646-2874 828-646-6141 Enclosure: September 1,2011 Color Reduction Implementation Plan cc: Billy Clarke,Roberts and Stevens Internal distribution j fresh by design. / l n,if,q B _ur._olth, ,o�.E c)rgrtvir &ver,,Pof kc�i,n September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 I. Introduction The May 2010 NPDES Permit (the 'Permit") [NC DWQ 2010] requires Blue Ridge Paper Products (BRPP) to submit a Color Reduction Implemention Plan.. The specific permit condition is: Part I AM) Item 11. The facility shall submit the color reduction implementation plan within the first year of permit issuance. The permit will be reopened and modified to include interim requirements and dates for their achievement based on the submitted implementation plan. The revised color variance issued to BRPP in July 2010 (the "Color Variance") [NC EMC 2010], includes an identical requirement for a Color Reduction Implementation Plan . This report is being submitted to satisfy the Color Reduction Implementation Plan in the Permit and in the Color Variance. The color limits in the Permit and the Color Variance and the specific processes and technologies identified in the Permit and Color Variance to achieve the specified color reductions are being challenged in two contested cases filed in the North Carolina Office of Administrative Hearings (OAH) — 10 EHR 4341 and 10 EHR 4982. Because the contested cases have not yet been resolved (and may not be resolved until sometime in 2012), and because the Petitioners have alleged that the North Carolina Division of Water Quality (DWQ) should have included a requirement to evaluate and implement other technologies and processes in the Permit and the Color Variance, BRPP has not yet R&S 865344-1 September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations,in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton, North Carolina NPDES Permit No. NC0000272 identified the specific technologies and processes to reduce color. Evaluation of the specific technologies identified in the Permit and Color Variance is ongoing. BRPP has, since 2006 and before, implemented and continues to utilize a number of best management practices (BMPs) related to the prevention of effluent color. This report discussses the ongoing evaluation and implementation of BMPs. H. Contested Cases In July 2010, Cocke County, Tennessee and a coalition of environmental groups, represented by the Southern Environmental Law Center, filed a Petition for Contested Case in the NC OAH — 10 EHR 4341, challenging color and temperature limits in the May 2010 NPDES permit. The Petitioners also filed a second Petition for Contested Case challenging the revised Color Variance for the Canton Mill — 10 EHR 4982. The two cases were consolidated in October 2010. The Petitioners in the Contested Cases allege, among other things, that the NC DWQ and the NPDES Committee of the NC Environmental Management Commission (EMC) failed to require the Canton Mill to evaluate and implement technologies and processes to reduce color that were reasonable and economical. Because Part I A.(8.) item 10 of the Permit (and identical related sections of the Color Variance) identifies specific technologies and processes for the Canton Mill to evalute and implement; and because R&S 865344-1 September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 Petitioners allege that DWQ should have required other technologies and processes, BRPP moved for an extension of time to submit the color reduction implementation plan. The date for the plan was extended to September 1, 2011 by Order of Adminstrative Law Judge (ALJ) Randall May in January 2011. Discovery in the Contested Cases was conducted from October 2010 through June 2011. Dispositive motions were filed in July 2011. A hearing on dispositive motions is scheduled for September 30, 2011. BRPP personnel have'devoted time and resources in responding to discovery requests and in assisting the DWQ and EMC with defense of the Permit and Color Variance. . Because the outcome of these cases may affect the technologies and/or processes that the Canton Mill may use to reduce color, the company has not yet determined the technical approach and associated time frames and capital investment, if any, it will employ to achieve additional reductions in color. III. TRW Recommendations in the May 2010 NPDES Permit Part I A.(8.) item 10 of the May 2010 NPDES Permit incorporates February 2008 recommendations of the EPA Technology Review Workgroup (TRW). These recommendations are in two lists (A.& B.), the first of which is targeted for expedited evaluation in anticipation of the Color Reduction Implementation Plan. R&S 865344-1 September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Pennit No. NC0000272 Part I A.(8.) item 10 A. The following suite of items will be implemented by the permittee, upon further expedited evaluation if necessary to refine detailed design and operating parameters, during this permit tern: • further improvements in leak and spill prevention and control (BMPs) covering all process lines, including probable color-generating sources (e.g. sulfide containing) among white and green liquors in the recovery cycle • process optimization (enhanced extraction stages, reduced bleach chemical use, etc); and • addition of second stage oxygen delignification on the softwood/pine fiber line. The time necessary for Blue Ridge Paper to implement these items or alternatives in logical sequence should realistically reflect the Mill's ability to design, fund, and install or implement 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 or other relevant process control and product quality parameters, designing and costing, and refining color projections. The balance of this report outlines work done by the Canton Mill related to TRW recommendations during the first year of the May 2010 NPDES Permit. R&S 865344-1 September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 IV. Background on Color Levels of color in the wastewater effluent from the Canton Mill are among the best of Kraft pulp and paper mills in the world [EKONO August 2005, NCASI August 2006]. This high level of color performance is achieved by in-process controls and best management practices. The mill will continue to operate the controls and practices proven successful for color prevention. These controls and practices go well beyond the requirements of the EPA Cluster Rule for Pulp and Paper (40 CFR 430, Subpart B). Many, such as the Bleach Filtrate Recycling (BFR) ProceSSTM, are unique to the Canton Mill. The BFR process includes two technologies — the Minerals Removal Process (MRP) with D1 stage filtrate recycling on the pine fiberline and the Chloride Removal Process (CRP) on the black liquor chemical recovery cycle. The May 2010 NPDES Permit includes a daily maximum effluent true color limit of 105,250 lbs per day. The permit also specifies a monthly average true color limit of 52,000.lbs per day and an annual average (calendar year) true color limit of 38,020 lbs per day. Compliance with these effluent limits requires significant management of mill operations related to color. Prevention of wastewater effluent color is a priority for mill operations every day. The Canton Mill is in compliance with these effluent limits for color. R&S 865344-1 September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 V. Best Management Practices On July 1, 2011 the Canton Mill submitted the Annual Progress Report on Color [Evergreen July 2011] required by Part I A.(8.) item 8 of the May 2010 NPDES Permit. That report documented 34 color-related capital and maintenance projects completed between May 2006 and May 2011. During this period the mill also completed 14 color- related BMP refinements, trials and process improvements. Several of the projects and process improvements documented in the July 2011 Progress Report are related to 2006 Liebergott recommendations for existing process optimization [GL&V 2006]. These include projects for brown stock washing improvement and target pulp bleach kappa factor. Other projects and improvements are related to sewer-generated color and polymer use optimization, which are TRW evaluation recommendations in Part I A.(8.) item 10 B. of the Permit. The complete application to renew the NPDES permit was submitted by the Canton Mill in May 2006. The Permit renewal process, including review by the TRW, public comment and public hearings was completed in May 2010. Between May 2006 and May 2010, the Canton Mill implemented further improvement in leak and spill prevention and control (BMPs) as required in Part I A.(8.) item 10 A. of the May 2010 NPDES Permit. R&S 865344-1 September '1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 Vl. Enhanced Extraction Stages The Canton Mill evaluated enhancement of the hardwood bleach plant extraction stage with hydrogen peroxide by full-scale trial during 2002 [Adams 2002a]. For the target pulp brightness and other process conditions at that time, hydrogen peroxide was ineffective in off-setting bleach plant chemical use. There was no statistically significant effect on secondary effluent color. Hydrogen peroxide enhancement of the pine bleach plant extraction stage ended in August 2001 as part of TRW process optimization recommendations for pine D1 stage kappa factor that were incorporated into the December 2001 NPDES Permit[Adams 2002b,NC DWQ 2001]. The TRW recommendations incorporated in Part I A.(8.) item 10 A. of the May 2010 NPDES Permit include enhanced extraction as a process optimization for expedited evaluation. In late 2010, the Canton Mill solicited quotes and sourced equipment for a new trial of extraction stage fortification with hydrogen peroxide. The process trial plan was prepared and approved in March 2011. The trial is designed to address TRW comments concerning previous enhanced extraction work as well as update economics and potential color reduction. Specifically, the fiberline pH and temperatures will be adjusted to optimize hydrogen peroxide addition towards delignification in the D 1 and Eo stages, and not D2 brightening. This is the most advantageous fortification process application to off-set bleaching chemical use. Pulp brightness development, pulp R&S 865344-1 September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 viscosity and bleach plant effluent color will be monitored during the enhanced extraction trial. Three (3) months of bleach plant and secondary effluent color data before and after the full-scale trial period will be used to evaluate potential color reduction. A temporary hydrogen peroxide storage tank, chemical metering pumps and associated piping were installed at the mill adjacent to the pine fiberline during May 2011. Safety reviews, equipment checks and employee training were then completed. At the end of June 2011, the mill began a 90-day full-scale trial of extraction stage fortification with hydrogen peroxide on both the hardwood and pine fiberlines. The trial start date for the pine fiberline was June 22. The trial start date for the hardwood fiberline was June 25. The process trial work will continue through the end of September 2011. Data analysis should be complete in early 2012. VII. Second Stage Oxygen Delignification on Pine The Canton Mill evaluated addition of second stage oxygen delignification to the pine fiberline during 2001 as part of a series of laboratory pulp cooking and bleaching trials conducted by the Pruyn's Island Technical Center (PITC) [PITC 2001]. For the target pulp brightness and other process conditions at that time, the PITC results showed a small potential effluent color reduction with a significant commercial risk of adverse effect on pulp strength. R&S 865344-1 September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 The TRW recommendations incorporated in Part I A.(8.) item 10 A. of the May 2010 NPDES Permit include expedited evaluation of second stage oxygen delignification on the pine fiberline. During 4th Quarter of 2010, the Canton Mill shipped samples of wood chips and pulp to, PITC for a new series of laboratory cooking and bleaching trials to evaluate the effects of single-stage (0) 45-50% delignification and two-stage (00) 60% delignification on the D1-Eo-D2 bleach sequence color development and final pulp strength characteristics. These trials were designed to address TRW comments concerning previous PITC oxygen delignification work as well as update economics and potential color reduction. Specifically, pulp cooking prior to oxygen delignification was adjusted to match both current process`conditions and to overcome adverse effects on pulp strength. Overall results of the 2010 PITC laboratory trials are consistent with the 2001 evaluation [PITC 2011, McDonough 2011]. To overcome adverse pulp strength effects, pulp cooking must be adjusted to a higher kappa number prior to two-stage oxygen delignification which offsets potential bleach plant chemical savings and color reduction from the two-stage process if no changes were made to current cooking practice. The projected secondary effluent color reduction from two-stage oxygen delignification with adjusted pulp cooking to preserve pulp strength properties and accounting for current R&S 865344-1 September 1, 2011 Color Reduction Implementation Plan— Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton, North Carolina NPDES Permit No. NC0000272 filtrate recycling and closure practices with the MRP process on the pine fiberline is less than 1000 lbs per day. Economic evaluation of the 2010 PITC laboratory trial technical results is not complete. VIII. Summary The Canton Mill will continue to utilize the processes and practices proven technically, operationally and economically feasible for effluent color prevention. Prevention of effluent color is a priority for mill operations every day. During the first year of the May 2010 NPDES Permit, the mill continued work related to February 2008 TRW. recommendations incorporated into Part I A.(8.) items 10 A & B of the Permit. Specifically: a. further improvement in leak and spill prevention and control (BMPs) b. sewer-generated color C. polymer use optimization d. full-scale trial of enhanced extraction stages e. laboratory trials of second stage oxygen delignification on pine. The Contested Cases filed by Cocke County and others in July 2010 challenging the May 2010 NPDES Permit create uncertainty about final permit limits and requirements. The Contested Cases may not be decided until sometime in 2012. Because the outcome of the R&S 865344-1 September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 cases may affect the technologies and/or processes that the Canton Mill may use to reduce color, the company has not yet determined the technical approach and associated time frames and capital investment, if any, it will employ to achieve additional reductions in color. References NC DWQ 2010 — Final National Pollutant Discharge Elimination System (NPDES) Permit for the Canton Mill, No. NC0000272, North Carolina Department of Environment and Natural Resources, Division of Water Quality, issued 26 May 2010, effective July 1, 2010. NC EMC 2010 — Color Variance — Request for Variance from Water Quality Standard- Based Effluent Limitations by Blue Ridge Paper Products, Inc. Canton, North Carolina, heard and decided by NC Environmental Management Commission, July 14, 2010. EKONO 2005 — Environmental Performance, Regulations and Technologies in the Pulp and Paper Industry, EKONO Inc, August 2005. NCASI 2006 —Technical Bulletin No. 919 —Review of Color Control Technologies and Their Applicability to Modern Kraft Pulp and Paper Mill, National Council for Air and Stream Improvement, August 2006. GL&V 2006 — Bleach Environmental Process Evaluation and Report prepared for Blue Ridge Paper Products Inc., Canton Mill, Norman Liebergott and Lewis Shackford, GL&V, July 2006. Evergreen 2011 — Annual Progress Report on Color, submitted to NC DWQ to meet requirements of Part I A.(8) item 8 of the May 2010 NPDES Permit, Evergreen Packaging Canton Mill, July 1, 2011. Adams 2002a — Blue Ridge Paper Products - Canton Mill — Trial Report — Hydrogen Peroxide (112O2) on Hardwood Eo Stage, Bill Adams Process Engineer, Blue Ridge Paper Products Inc. Canton Mill, July 2, 2002. R&8 865344-1 September 1, 2011 Color Reduction Ilnplementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 NC DWQ 2001 — Final National Pollutant Discharge Elimination System (NPDES) Permit for the Canton Mill, No. NC0000272, North Carolina Department of Environment and Natural Resources, Division of Water Quality, issued November 15, 2001, effective December 1, 2001. Adams 2002b — Blue Ridge Paper Products - Canton Mill — Process History Report — D-100 Kappa Factors Performance / Monitoring, Bill Adams Process Engineer, Blue Ridge Paper Products Inc. Canton Mill, July 10, 2002. PITC 2001 — Report 2001-068, Part 1 — Laboratory CK and Lo-Solids Cooking with O- Do-Eop-D Bleaching Sequences on Softwood Furnish from Blue Ridge Paper, Part 1 — Softwood Results, Pruyn's Island Technical Center, December 6, 2001. PITC 2011 — Report 2010-081 — Laboratory Cooking and Bleaching for Evergreen Packaging Canton,NC, Pruyn's Island Technical Center, January 31, 2011. McDonough 2011 —Laboratory Study of Likely Effects of Installing Two-Stage Oxygen Delignification at Evergreen Packaging's Canton, NC Mill, Thomas J. McDonough, consultant to Evergreen Packaging, June 29, 2011. R&S 865344-1 evergreen.w Canton Office O (�M packaging Main Sheet. Cancan, NC 2371! �J U August 26, 2011 Hand Delivery Keith Haynes Acting Regional Supervisor Division of Water Quality, Surface Water Protection North Carolina Department of Environment and Natural Resources Asheville Regional Office 2090 U.S.Highway 70 Swannanoa,North Carolina 28778 Re: Color Reduction Implementation Plan—Report on TRW Recommendations in May 2010 NPDES Permit NPDES Permit No. NC0000272 Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton Mill Dear Mr.Haynes— The enclosed report documents Canton Mill work during the first year of the May 2010 NPDES permit related to February 2008 recommendations of the EPA Technology Review Workgroup(TRW)that were incorporated into Part I A.(8.) item 10 of the permit. The report is required by the permit. It is a supplement to the Annual Progress Report on Color submitted on July 1, 2011. Very truly yours, BLUE RIDGE PAPER PRODUCTS INC. DOING BUSINESS AS EVERGREEN PACKAGING By: `rJ4�1c�t� 1a�v 7PCS t Nick McCracken Paul Dickens Water Compliance Coordinator Manager Environmental Affairs Canton Mill Canton Mill—Waynesville Plant nick.mccracken@everpack.com paul.dickens@everpack.com 828-646-2874 828-646-6141 Enclosure: September 1, 2011 Color Reduction Implementation Plan cc: Billy Clarke,Roberts and Stevens Internal distribution September 1, 2011 Color Reduction Implementation Plan - Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 I. Introduction The May 2010 NPDES Permit (the "Permit") [NC DWQ 2010] requires Blue Ridge Paper Products (BRPP) to submit a Color Reduction Itmplemention Plan.. The specific permit condition is: Part I A.B.) Item 11. The facility shall submit the color reduction implementation: plan within the first year of permit issuance. The permit will be reopened and modified to include interim requirements and dates for their achievement based on the submitted implementation plan. The revised color variance issued to BRPP in July 2010 (the "Color Variance") [NC EMC 2010], includes an identical requirement for a Color Reduction Implementation _•, Plan . This report is being submitted to satisfy the Color Reduction Implementation Plan in the Permit and in the Color Variance. The color limits in the Permit and the Color Variance and the specific processes and technologies identified in the Permit and Color Variance to achieve the specified color reductions are being challenged in two contested cases filed in the North Carolina Office of Administrative Hearings (OAH) — 10 EHR.4341 and 10 EHR 4982. Because the contested cases have not yet been resolved (and may not be resolved until sometime in 2012), and because the Petitioners have alleged that the North Carolina Division of Water Quality (DWQ) should have included a requirement to evaluate and implement other technologies and processes in the Permit and the Color Variance, BRPP has not yet R&S 865344-1 September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton, North Carolina NPDES Permit No. NC0000272 identified the specific technologies and processes to reduce color. Evaluation of the specific technologies identified in the Permit and Color Variance is ongoing. BRPP has, since 2006 and before, implemented and continues to utilize a number of best management practices (BMPs) related to the prevention of effluent color. This report discussses the ongoing evaluation and implementation of BMPs. II. Contested Cases In July 2010, Cocke County, Tennessee and a coalition of environmental groups, represented by the Southern Environmental Law Center, filed a Petition for Contested Case in the NC OAH — 10 EHR 4341, challenging color and temperature limits in the May 2010 NPDES permit. The Petitioners also filed a second Petition for Contested Case challenging the revised Color Variance for the Canton Mill — 10 EHR 4982. The two cases were consolidated in October 2010. The Petitioners in the Contested Cases allege, among other things, that the NC DWQ and the NPDES Committee of the NC Environmental Management Commission (EMC) failed to require the Canton Mill to evaluate and implement technologies and processes to reduce color that were reasonable and economical. Because Part I A.(8.) item 10 of the Permit (and identical related sections of the Color Variance) identifies specific technologies and processes for the Canton Mill to evalute and implement, and because R&S 865344-1 September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 Petitioners allege that DWQ should have required other technologies and processes, BRPP moved for an extension of time to submit the color reduction implementation plan. The date for the plan was extended to September 1, 2011 by Order of Adminstrative Law Judge (ALJ) Randall May in January 2011. Discovery in the Contested Cases was conducted from October 2010 through June 2011. Dispositive motions were filed in July 2011. A hearing on dispositive motions is scheduled for September 30, 2011. BRPP personnel have"devoted time and resources in responding to discovery requests and in assisting the DWQ and EMC with defense of the Permit and Color Variance. . Because the outcome of these cases may affect the technologies and/or processes that the Canton Mill may use to reduce color, the company has not yet determined the technical approach and associated time frames and capital investment, if any, it will employ to achieve additional reductions in color. III. TRW Recommendations in the May 2010 NPDES Permit Part I A.(8.) item 10 of the May 2010 NPDES Permit incorporates February 2008 recommendations of the EPA Technology Review Workgroup (TRW). These recommendations are in two lists (A.& B.), the first of which is targeted for expedited evaluation in anticipation of the Color Reduction Implementation Plan. R&S 865344-1 September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 Part 1 A.M.) item 10 A. The following suite of items will be implemented by the permittee, upon further expedited evaluation if necessary to refine detailed design and operating parameters, during this permit term: o further improvements in leak and spill prevention and control (BMPs) covering all process lines, including probable color-generating sources (e.g. sulfide containing) among white and green liquors in the recovery cycle • process optimization (enhanced extraction stages, reduced bleach chemical use, etc); and Y addition of second stage oxygen delignification on the softwood/pine fiber line. The time necessary for Blue Ridge Paper to implement these items or alternatives in logical sequence should realistically reflect the Mill's ability to design, fund, and install or implement 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 or other relevant process control and product quality parameters, designing and costing, and refining color projections. The balance of this report outlines work done by the Canton Mill related to TRW recommendations during the first year of the May 2010 NPDES Permit. R&S 865344-1 September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Pen-nit No. NC0000272 IV. Background on Color Levels of color in the wastewater effluent from the Canton Mill are among the best of Kraft pulp and paper mills in the world [EKONO August 2005, NCASI August 2006]. This high level of color performance is achieved by in-process controls and best management practices. The mill will continue to operate the controls and practices proven successful for color prevention. These controls and practices go well beyond the requirements of the EPA Cluster Rule for Pulp and Paper (40 CFR 430, Subpart B). Many, such as the Bleach Filtrate Recycling (BFR) ProcessTm, are unique to the Canton Mill. The BFR process includes two technologies — the Minerals Removal Process (MRP) with D1 stage filtrate recycling on the pine fiberline and the Chloride Removal Process (CRP) on the black liquor chemical recovery cycle. The May 2010 NPDES Permit includes a daily maximum effluent true color limit of 105,250 lbs per day. The permit also specifies a monthly average true color limit of 52,000.lbs per day and an annual average (calendar year) true color limit of 38,020 lbs per day. Compliance with these effluent limits requires significant management of mill operations related to color. Prevention of wastewater effluent color is a priority for mill operations every day. The Canton Mill is in compliance with these effluent limits for color. R&S 865344-1 September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton, North Carolina NPDES Permit No. NC0000272 V. Best Management Practices On July 1, 2011 the Canton Mill submitted the Annual Progress Report on Color [Evergreen July 2011] required by Part I A.(8.) item 8 of the May 2010 NPDES Permit. That report documented 34 color-related capital and maintenance projects completed between May 2006 and May 2011. During this period the mill also completed 14 color- related BMP refinements, trials and process improvements. Several of the projects and process improvements documented in the July 2011 Progress Report are related to 2006 Liebergott recommendations for existing process optimization [GL&V 2006]. These include projects for brown stock washing improvement and target pulp bleach kappa factor. Other projects and improvements are related to sewer-generated color and polymer use optimization, which are TRW evaluation recommendations in Part I A.(8.) item 10 B. of the Permit. The complete application to renew the NPDES permit was submitted by the Canton Mill in May 2006. The Permit renewal process, including review by the TRW, public comment and public hearings was completed in May 2010. Between May 2006 and May 2010, the Canton Mill implemented further improvement in leak and spill prevention and control (BMPs) as required in Part I A.(8.) item 10 A. of the May 2010 NPDES Permit. R&S 865344-1 PPV September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton, North Carolina NPDES Permit No. NC0000272 VI. Enhanced Extraction Stages The Canton Mill evaluated enhancement of the hardwood bleach plant extraction stage with hydrogen peroxide by full-scale trial during 2002 [Adams 2002a]. For the target pulp brightness and other process conditions at that time, hydrogen peroxide was ineffective in off-setting bleach plant chemical use. There was no statistically significant effect on secondary effluent color. Hydrogen peroxide enhancement of the pine bleach plant extraction stage ended in August 2001 as part of TRW process optimization recommendations for pine DI stage kappa factor that were incorporated into the December 2001 NPDES Permit [Adams 2002b,NC DWQ 2001]. The TRW recommendations incorporated in Part I A.(8.) item 10 A. of the May 2010 NPDES Permit include enhanced extraction as a process optimization for expedited evaluation. In late 2010, the Canton Mill solicited quotes and sourced equipment for a new trial of extraction stage fortification with hydrogen peroxide. The process trial plan was prepared and approved in March 2011. The trial is designed to address TRW comments concerning previous enhanced extraction work as well as update economics and potential color reduction. Specifically, the fiberline pH and temperatures will be adjusted to optimize hydrogen peroxide addition towards delignification in the D1 and Eo stages, and not D2 brightening. This is the most advantageous fortification process application to off-set bleaching chemical use. Pulp brightness development, pulp R&S 865344-1 PPV September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 viscosity and bleach plant effluent color will be monitored during the enhanced extraction trial. Three (3) months of bleach plant and secondary effluent color data before and after the full-scale trial period will be used to evaluate potential color reduction. A temporary hydrogen peroxide storage tank, chemical metering pumps and associated piping were installed at the mill adjacent to the pine fiberline during May 2011. Safety reviews, equipment checks and employee training were then completed. At the end of June 2011, the mill began a 90-day full-scale trial of extraction stage fortification with hydrogen peroxide on both the hardwood and pine frberlines. The trial start date for the pine fiberline was June 22. The trial start date for the hardwood fiberline was June 25. The process trial work will continue through the end of September 2011. Data analysis should be complete in early 2012. VII. Second Stage Oxygen Delignification on Pine The Canton Mill evaluated addition of second stage oxygen delignification to the pine fiberline during 2001 as part of a series of laboratory pulp cooking and bleaching trials conducted by the Pruyn's Island Technical Center (PITC) [PITC 2001]. For the target pulp brightness and other process conditions at that time, the PITC results showed a small potential effluent color reduction with a significant commercial risk of adverse effect on pulp strength. R&S 865344-1 September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 The TRW recommendations incorporated in Part I A.(8.) item 10 A. of the May 2010 NPDES Permit include expedited evaluation of second stage oxygen delignification on the pine fiberline. During 41h Quarter of 2010, the Canton Mill shipped samples of wood chips and pulp to PITC for a new series of laboratory cooking and bleaching trials to evaluate the effects of single-stage (0) 45-50% delignification and two-stage (00) 60% delignification on the Dl-Eo-D2 bleach sequence color development and final pulp strength characteristics. These trials were designed to address TRW comments concerning previous PITC oxygen delignification work as well as update economics and potential color reduction. Specifically, pulp cooking prior to oxygen delignification was adjusted to match both current process conditions and to overcome adverse effects on pulp strength. Overall results of the 2010 PITC laboratory trials are consistent with the 2001 evaluation [PITC 2011, McDonough 2011]. To overcome adverse pulp strength effects, pulp cooking must be adjusted to a higher kappa number prior to two-stage oxygen delignification which offsets potential bleach plant chemical savings and color reduction from the two-stage process if no changes were made to current cooking practice. The projected secondary effluent color reduction from two-stage oxygen delignification with adjusted pulp cooking to preserve pulp strength properties and accounting for current R&S 865344-1 - September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 filtrate recycling and closure practices with the MRP process on the pine fiberline is less than 1000 lbs per day. Economic evaluation of the 2010 PITC laboratory trial technical results is not complete. VIII. Summary The Canton Mill will continue to utilize the processes and practices proven technically, operationally and economically feasible for effluent color prevention. Prevention of effluent color is a priority for mill operations every day. During the first year of the May 2010 NPDES Permit, the mill continued work related to February 2008 TRW. recommendations incorporated into Part I A.(8.) items 10 A & B of the Permit. Specifically: a. further improvement in leak and spill prevention and control (BMPs) b. sewer-generated color c. polymer use optimization d. full-scale trial of enhanced extraction stages e. laboratory trials of second stage oxygen delignifrcation on pine. The Contested Cases filed by Cocke County and others in July 2010 challenging the May 2010 NPDES Permit create uncertainty about final permit limits and requirements. The Contested Cases may not be decided until sometime in 2012. Because the outcome of the R&S 865344-1 ppppp� September 1, 2011 Color Reduction Implementation Plan Report on TRW Recommendations in the May 20101VPDES Permit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton, North Carolina NPDES Permit No. NC0000272 cases may affect the technologies and/or processes that the Canton Mill may use to reduce color, the company has not yet determined the technical approach and associated time frames and capital investment, if any, it will employ to achieve additional reductions in color. References NC DWQ 2010 — Final National Pollutant Discharge Elimination System (NPDES) Permit for the Canton Mill, No. NC0000272, North Carolina Department of Environment and Natural Resources, Division of Water Quality, issued 26 May 2010, effective July 1, 2010. NC EMC 2010 — Color Variance — Request for Variance from Water Quality Standard- Based Effluent Limitations by Blue Ridge Paper Products, Inc. Canton, North Carolina, heard and decided by NC Environmental Management Commission, July 14, 2010. EKONO 2005 — Environmental Performance, Regulations and Technologies in the Pulp and Paper Industry, EKONO Inc, August 2005. NCASI 2006 —Technical Bulletin No. 919 —Review of Color Control Technologies and Their Applicability to Modern Kraft Pulp and Paper Mill, National Council for Air and Stream Improvement, August 2006. GL&V 2006 — Bleach Environmental Process Evaluation and Report prepared for Blue Ridge Paper Products Inc., Canton Mill, Norman Liebergott and Lewis Shacldord, GL&V, July 2006. Evergreen 2011 — Annual Progress Report on Color, submitted to NC DWQ to meet requirements of Part I A.(8) item 8 of the May 2010 NPDES Permit, Evergreen Packaging Canton Mill, July 1, 2011. Adams 2002a — Blue Ridge Paper Products - Canton Mill — Trial Report — Hydrogen Peroxide (112O2) on Hardwood Eo Stage, Bill Adams Process Engineer, Blue Ridge Paper Products Inc. Canton Mill, July 2, 2002. R&8 865344-1 September 1, 2011 Color Reduction Implementation Plan — Report on TRW Recommendations in the May 2010 NPDES Pen-nit Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 NC DWQ 2001 — Final National Pollutant Discharge Elimination System (NPDES) Permit for the Canton Mill, No. NC0000272, North Carolina Department of Environment and Natural Resources, Division of Water Quality, issued November 15, 2001, effective December 1, 2001. Adams 2002b — Blue Ridge Paper Products - Canton Mill — Process History Report — D-100 Kappa Factors Performance / Monitoring, Bill Adams Process Engineer, Blue Ridge Paper Products Inc. Canton Mill, July 10, 2002. PITC 2001 — Report 2001-068, Part 1 — Laboratory CK and Lo-Solids Cooking with O- Do-Eop-D Bleaching Sequences on Softwood Furnish from Blue Ridge Paper, Part 1 — Softwood Results, Pruyn's Island Technical Center, December 6, 2001. PITC 2011 — Report 2010-081 — Laboratory Cooking and Bleaching for Evergreen Packaging Canton,NC, Pruyn's Island Technical Center, January 31, 2011. McDonough 2011 — Laboratory Study of Likely Effects of Installing Two-Stage Oxygen Delignification at Evergreen Packaging's Canton, NC Mill, Thomas J. McDonough, consultant to Evergreen Packaging, June 29, 2011. R&S 865344-1 pprr, 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 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 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 2 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 37,1001bs/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 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 continents 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 Continents 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. 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 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. PPPFP' 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.