NC0000272_Color Compliance Report Appendices_20060501

APPENDICIES to Color Compliance Report
Blue Ridge Paper Products Inc.
Canton Mill
May 2006
Appendix A—January 25, 2006 Due Date Extension Letter for Color Variance Report
Appendix B—Copies of Permit Required Reports:
October 2003 —Analysis of Color Performance, December 2001 —August 2003
December 2003 —Color Performance Following Highest Certainty Actions and
Evaluation of Reasonable Certainty Actions
March 2004—CRP Color Reduction Technology Assessment
December 2005 —Color Performance Following Highest and Reasonable Certainty
Actions
Appendix C —Executive Summary from 2005 Pigeon River Biological Assessment Report

Appendix A
January 25, 2006 Due Date Extension
Letter for Color Variance Report

OF W ATF
`O� 9pG Michael F.Easley
©pw/� Governor
'7 William G.Ross,Jr.,Secretary
> r NCDENR
> North Carolina Department of Environment and Natural Resources
0 Y
® �Diio o at
January25 2006
' FEB
- 6 2006
Mr.Paul Dickens,Manager
Environmental Affairs BLUE RIDGE PAPER PRODUCTS ING
Blue Ridge Paper Products,Inc. I BNS DEPARTMENT
175 Main Street,P.O.Box 4000
Canton,North Carolina 28716
Subject: Color Report/316a Report
Extension Request
Blue Ridge Paper—Canton Mill
NPDES Permit No.NC0000272
Haywood County
Dear Mr.Dickens:
The Division of Water Quality(Division)has reviewed your report entitled"Effluent Color
Performance Following Highest Certainty and Reasonable Certainty Actions".The Division commends
Blue Ridge Paper Products' efforts on reducing color in the effluent.
The Division has also reviewed your request(dated January 12,2006)for an extension of the Part I,
Condition A.(8).Paragraph 10 stipulation(Color Variance Report)of the subject NPDES permit.
According to condition A(8.)Paragraph 8 of your permit,the new effluent color limit shall be established
based on the submitted statistical analysis report via recommendation to the NPDES Committee by
February 1,2006.
Due to high flow conditions in the Pigeon River during the summer of 2005,it is our understanding
that the field work for the 316a study was delayed. This information is necessary for the completion of
the Color Variance Report.Therefore,the Division is willing to extend the due date of the subject report
and the 316a Study Report,until May 31,2006. This date coincides with the date of the NPDES Permit
Renewal Application. It should be noted that this date extension does not change any other compliance
date requirements of the Permit.
A
The Division will conduct consultations with the members of-the Technology Review Workgroup
(TRW) during renewal of the permit,to get a color limit that is acceptable to the TRW members.
If you have any questions concerning this issue,please contact Sergei Chernikov at telephone number
[phone], extension 594, or Mr.Roger Edwards, or Mr.Keith Haynes of our Asheville Regional
Office at 828-296-4500.
Sincerely,
Alan Klimek,P.E.
Cc: Central Files
NPDES Files
Asheville Regional Office,Surface Water Protection
Roosevelt Childress,EPA Region IV
t Don Anderson,US EPA, Office of Water, Office of Science and Technology(4301 T), 1200 Pennsylvania
Avenue,NW, Washington,DC 20460
N.C.Division of Water Quality 1 NPDES Unit Phone:[phone]
1617 Mail Service Center,Raleigh,NC 27699-1617 fax:[phone]
Internet:h2o.enr.state.nc.us DENR Customer Service Center..1 800 623-7748

Appendix B
Copies of Permit Required Reports

October 2003
Analysis of Color Performance,
December 2001 — August 2003

September 29, 2003
Mr. Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfm Place
Asheville, NC 28801
RE: NPDES Permit No. NC0000272,Blue Ridge Paper Products, Inc.
October 1, 2003 Required Report
Dear Mr. Westall:
z _ Attached is the October 1, 2003 Report. This report is submitted to fulfill the
requirements stated in Section A(8.), Paragraph 5 of the 2001 NPDES Permit. Blue
Ridge Paper Products is submitting this report to you in your capacity as Regional Water
Quality Supervisor for the Division of Water Quality and as a member of the Technology
Review Workgroup.
Please call me at(828) 646-2033 or Melanie Gardner at(828) 646-6749 if you have any
questions or concerns regarding this report.
Sincerely,
Bob Williams
Director-Environmental, Health and Safety
Attachment

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
i
I. Introduction
The following report details the Canton Mill's ability to attain the lowest achievable
annual average and monthly average color loading limits based on the Mill's performance
from December 2001 —August 2003. Section A (8.), Paragraph 5 of the 2001 NPDES
Permit provides in part, as follows:
"...By October 1, 2003, the permittee shall submit to the North Carolina
Division of Water Quality a report including a statistical analysis of the
permittee's monthly average color discharge, mill performance as related
to color, all available data necessary to derive the lowest achievable
}
annual average and monthly average color loading limits..."
This report is submitted to fulfill the requirements of Section A(8.),Paragraph 5. Based
on the Mill's performance from December 2001 —August 2003 and the Mill's continued
commitment to color improvement, Blue Ridge Paper Products believes an annual
average color limit of 4t000 pounds per day and a monthly average color limit of 52,000
pounds per day are feasible. .
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
H. Color Performance
Set forth below is a summary of the actions implemented and planned for further color
improvement at the Canton Mill. These actions satisfy the `Highest Certainty' items
recommended by the Division of Water Quality and the Technology Review Workgroup.
2.1 Process Optimizations Items
The sixteen Process Optimization Items recommended in the Bleach Environmental
Process Evaluation and Report prepared by Liebergott &Associates Consulting Inc. and
GL&V Pulp Group Inc. have all been evaluated and implemented where appropriate.
2.2 Improved Black Liquor Leak and Spill Collection and Control
This recommendation consists of four elements including:
1) Continuous improvement of operating practices so more leaks and spills are recovered
rather than discharged to the sewer;
2) Improvement in preparation for planned outages to maximize capture of tank clean-out
waste and routing to recovery;
3)Reduction of clean water that continuously runs into sewers to prevent dilution of
smaller spills and facilitate recovery of highly colored wastewaters; and
4) Improvement in the equipment used for the handling of knot rejects to prevent black
liquor leaks into the recovery sumps.
The following is a discussion of actions relating to each element.
2.2.1 Continuous Improvement of Operating Practices etc.
A number of Best Management Practices (BMPs) have been implemented to improve the
1,
recovery of colored discharges within the mill. These include: A) Color testing on the
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
1
Primary Influent every 2 hours; B)The use of the off-line, spare clarifier for process
losses and intentional diversions; C)Piping the Hardwood Brown Spill tank to the Pine
Blow Tower for additional spill collection capability and Hardwood Fiberline outage
management; and D) Implementation of control logic in the Pine Brownstock area to
minimize tank overflows during shutdowns.
The Mill began 24-hour color testing in 2-hour increments on the primary influent in
2001. The purpose of this increased color testing is to improve the mill's ability to
respond to process upsets on an immediate, real-time basis. If high 2-hour color results
are detected, the Wastewater Treatment Plant(WWTP) operators communicate the
information to mill operations and in-mill investigations begin. If necessary, diversion of
the primary influent to the off-line, spare clarifier is initiated. The high color material
r� that is captured in the off-line clarifier is later discharged into the system at a rate that has
a minimum impact on color and is not disruptive to the WWTP system. The off-line
spare clarifier is also used during outage situations when high color material cannot be
recovered by the in-mill spill control systems due to upset conditions, lack of recycle or
evaporator capacity or intentional diversions.
In order to increase the Hardwood Fiberline's ability to recycle recovered brownstock
material, piping was installed from the Hardwood Brown Spill tank to the Pine Blow
Tower. Prior to installation of this piping, there was no outlet for recycled hardwood
brownstock material when that system was shut down. This design allows for the
Hardwood Brown Spill tank to be recycled into the Pine Blow Tower and is especially
useful in hardwood outage situations when the recycle of additional recovered material is
required. Color savings from this 2001 project are reflected in the improvements seen
around the hardwood brownstock or 2B sewer area as well as improved color
performance.
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
During the first quarter of 2003, additional control logic was developed and implemented
on the pine brownstock system to prevent high colored filtrate tanks (0 2"d, and 3'd stage
Pre-02 filtrate tanks)from overflowing and potentially reaching the sewer. The control
logic is designed to alert the operator when the brownstock filtrate tank(s) reach 85%
with audible and visual alarms. If the tank level(s) continues to rise to 90%, the pine
brownstock operators receive a"high-high" level alarm and warning text on their
monitors. The control logic then automatically interlocks (i.e., shuts down) the washer
stock feed pump that is associated with the high-level filtrate tank. Further, additional
controls have been built into the logic for the Pine Brown Spill tank. The alarm logic for
this tank checks the tank level at various times each day. If the tank level is greater than
50% at either time period, the Pine Brownstock Operator will receive an audible alarm as
well as a text message stating that the "Pine Brown Spill tank level is high." The control
logic will then check the level three hours later and if the level is still above 50%, the
i
operator will receive another alarm stating that the "Pine Brown Spill tank level is still
too high." In addition, if the Brown Spill tank level exceeds 80%, the operator receives a
high level alarm on his/her Digital Control System(DCS) graphic. All of these control
system improvements have enhanced the operator's ability to monitor the system and
prevent spills and losses from these processes.
A
2.2.2 Improvement in Preparation for Planned Outages
Color management of planned outages has improved significantly as a result of the
following practices:
• Increasing color testing from 2 hours to one hour before outages, during outages
and upon start-up;
• Improved communication between the Wastewater Treatment Plant and mill
operations;
( O Utilization of the off-line, spare clarifier;
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
f°
• Developing tank draining schedules where only the necessary vessels are emptied
for inspection and scheduled maintenance;
• Reducing tank levels to the lowest level possible prior to shutdown.
To effectively monitor color performance during maintenance outages, the WWTP
operators begin hourly color testing on the primary influent when the Recovery operation
initiates its shutdown procedure. The hourly color data is posted on the mill's Plant
Information(PI) System where it is widely available to operations and support personnel.
If a result is greater than 300 color units, it is immediately communicated to the Recovery
and Pulp Mill foremen via the mill radio system and they institute investigative action to
pinpoint the source. The appropriate corrective action is then taken. The Pulp Mill and
Recovery foremen also communicate their investigative findings with one another to
ensure effective troubleshooting is in place.
If an hourly color result is elevated and mill operations communicates that there has been
a process loss, the WWTP operators will divert the primary influent flow to the 1 million
gallon off-line, spare clarifier for temporary storage. There have also been instances
when the WWTP operators diverted the primary influent flow without direct
communication of a spillA The WWTP operators are trained to take action and route high
colored primary influent to the off-line, spare clarifier when necessary. The high color
material is later fed into the WWTP system at a slow, non-disruptive rate. Such a slow
feed rate minimizes the material's impact on secondary effluent color and does not
disrupt the W WTP process. For very high colored material captured in the off-line
clarifier, polyamine may be added in small amounts. Small amounts of polyamine aid in
the color removal of the concentrated material captured in the clarifier without negatively
affecting the sludge quality as larger amounts of polyamine have been demonstrated to
do. During normal mill operations, full-scale application of polyamine was not proven to
be effective and it created unmanageable sludge conditions; however, polyamine has
been effective on these higher color concentration events captured in the off-line clarifier.
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
Also, if at any time high colored material is seen in the primary influent, or if mill
operations communicates a process loss/intentional diversion, the WWTP operators can
immediately divert the primary influent flow into the off-line, spare clarifier. Improved
communications between the WWTP and mill operations have allowed for optimal use of
the off-line clarifier, especially in outage situations when overall spill system capacity is
in demand.
Tank draining schedules are developed in preparation for planned maintenance outages.
Increased attention has been given to draining only the tanks and lines requiring
inspection and/or maintenance rather than draining entire sequences. Draining the entire
sequence was a routine approach in the past so that vessels would be empty and available
for maintenance if problems were detected. The schedule has been optimized so that
inspections are rotated between outages, thereby ensuring that all tanks are inspected
while reducing the frequency that individual tanks must be emptied. However, issues
may arise where more frequent maintenance is required on certain vessels and
appurtenances and in these cases, the tanks must be drained before a scheduled inspection
is due. hi preparation for all scheduled outages, it is standard practice to focus on
reducing tank levels to minimize the amount of material to be drained. This practice also
reduces potential losses in the event of an upset process condition during shutdown,
outage, or start-up periods.
These practices have measurably improved outage color performance. Specifically,
reductions in the color losses are demonstrated by the 2002 semi-annual shutdowns
(outages performed twice per year, lasting approximately one week with each outage
involving half of the mill operations). In a comparison of semi-annual outage primary
influent color data, the 2002 data showed an average 38%reduction in the maximum
daily primary influent color from historical performance(1996—2001). These
improvements are significant given that the majority of the spill recovery systems were
implemented in 1997 and 1998.
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
2.2.3 Reduction of Clean Water that Continuously Runs into Sewers
There has been a greater than 90,000 gallon per day reduction in the amount of clean
water being sewered, primarily in the mill's digester courtyard. This reduction in flow
was achieved by implementing customized Double Mechanical Seals and Water
Management Systems on the 18 digester re-circulation pumps. This project has involved
extensive trialing of different types and combinations of specially designed mechanical
seals over the past several years. The decrease in flow from the mechanical seals is at
least 3 to 4 gallons per minute per pump, which equates to a daily flow savings greater
than 90,000 gallons. The removal of non-mechanical seal pump packing water from the
digester sewers has also contributed to improved color performance for the area. Since
complete implementation of the mechanical seals, measured color in the area has been
reduced by approximately 60%. This is due in part to the removal of seal water that
could be contaminated by black liquor leaks on the non-mechanical seal packing and
from the recovery sumps operating more efficiently. With less clean water dilution in the
sewers leading to the recovery sumps, the effective conductivity of the material increases
and can be captured for re-use in the process at a greater efficiency. Customized Double
Mechanical Seals and Water Management Systems have also been installed on the
Knotter feed pumps for Both the Pine and Hardwood Fiberlines, to further reduce water
infiltration to the sewer.
2.2.4 Improvement in Equipment used for Handling Knot Rejects
Two projects have been completed to improve the equipment used for handling knot
rejects. Black liquor from the Knot Rejects Collection bins is routed to a dedicated U-
drain, which flows to a dedicated knot bin sump pump for each Fiberline. The flow from
the knot bin areas is collected and pumped to the Brown Spill tank for each respective
~ Fiberline. Recovery of this material has contributed to improved color performance, as
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
demonstrated by Figure 1 below. The Hardwood Fiberline Brownstock sewer color has
shown the most dramatic reduction in color, which results from:
• Having the flexibility to send contents from the Hardwood Brown Spill tank to
the Pine Blow Tower during shutdown and start-up from an outage;
• Reducing the amount of clean water dilution by installing the Double Mechanical
Seals and Water Management Systems;
• Capturing the black liquor from the knot rejects system and;
• Improved communication and color monitoring.
Monthly Average Hardwood Brownstock and Digester Area Color
Since Installation of Double Mechanical Seals and
Water Management Systems
12000
r
( 10000
n 8000
0
N
6000
O
U 4000
2000
0 7.
N
O O O O O O O O O O O O O O O O
� Q
'+—Hardwood Brownstock and Digester Area Color
Figure 1
1
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
III. Improvements in BFR'Reliability
Approximately$1.5 Million has been spent on Bleach Filtrate Recycle process
improvements for 2002—2003. This has resulted in improved BFRm closure rates over
the past year and operational variability is also showing improvement in the Metals
Removal Process (MRP). In August 2003, the monthly average closure rate reached
targeted levels with improved MRP uptime and equipment reliability matching Fiberline
reliability. To improve process variability, a new media filter and a new ion exchange
softener were installed in the MRP. Due to accelerated degradation of the original three
media filters over recent months, they will also be replaced by the end of 2003. With this
additional equipment, metallurgy changes and other process improvements, MRP
j--. downtime is expected to be reduced significantly. Having four media filters and three ion
exchange softeners will provide enough capacity for the MRP to remain online while
repairs are made to an individual media filter or softener. These projects are beginning to
demonstrate improved closure rates, reduced operational variability of the MRP, and
increased mechanical reliability of the MRP, all of which should aid in reducing both
measured and unaccounted color. As was expected, a recent statistical evaluation
demonstrated that lower Closure rates are a major contributor to elevated secondary
effluent color and unaccounted color, individually as a main effect and also combined
with other factors as an interaction effect. These effects will be discussed in a later
section.
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
a"
IV. Color Challenges in 2002—2003
As a result of many years of color reduction activities and those discussed herein, the
monthly average secondary effluent color for the period December 2001 through October
2002 was 39,833 lbs/day. However, due to unforeseen and complex issues discussed in
this report, secondary effluent color increased in late 2002.
In November 2002, secondary effluent color variability began to increase. The
contributing source(s) were not readily evident. Out of the 15 sewer and process areas
measured daily, there were no measured sources that were statistically out of control
except for the Pine Eo filtrate, and that influent contribution was less than 5,000 lbs/day
over the in-control average. Two major sewer areas, the Bleach Plant Filtrate Acid Sewer
and the Hardwood Brownstock/Digester Area Sewer were actually operating below their
` average level of performance. The unaccounted color averaged about 23,000 lbs/day for
the month(compared to a 2002 YTD average of approximately 10,0001bs/day). A
thorough review of all sewered, color-contributing sources revealed that the hardwood
screen rejects were not being quantified in the daily in-mill color analysis. Data has been
collected and the average color contribution from the hardwood screen rejects is 3,000
Ibs/day. This source has'been a small portion of the mill's unaccounted color since 1996;
therefore, it is not a significant contribution to the elevated unaccounted color seen during
this period. Further, the Wastewater Treatment Plant Color removal effect was dropping.
Elevated unaccounted color and reduced WWTP color removal are indicators that
support the presence of Sewer Generated Color(SGC), yet closure was averaging 77%
and the color contribution from the Bleach Plant Filtrates, the historical pre-cursors of
SGC, were running below average as illustrated in Figure 2 below.
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
Monthly Average Color In the Bleach Plant Acid Sewer
Jan-02 through Jan-03
16000
140M
a 12000
a
10000
`o
0
U 6000
6000
4000
Color 6A
Figure 2
1 " As the Canton Mill has reduced releases of brown colored material, a greater percentage
of the primary influent color has become unaccounted color. Color is a pH dependent
parameter and Blue Ridge is in un-charted territory with such low brown color effluents
and the BFRTm technology. The result of increasing the pH of an acidic bleach plant
filtrate in the laboratory shows a visually significant increase in color. The Sewer
Generated Color phenomenon has been duplicated on the bench in multiple studies and
a
the National Council on Air and Stream Improvement(NCASI) supports that color is a
pH dependent phenomenon. Sewer Generated Color does not disappear when the pH is
adjusted from alkaline back to neutral conditions.
Duke University graduate level internship and thesis studies performed at the Canton Mill
in 19941 and 19952 showed, on average, Sewer Generated Color for Pine Dl filtrate was
an increase of 32-47% above the original sample color and Sewer Generated Color for
Hardwood Dl filtrate was 64-88%. Regarding WWTP color removal, data suggested
I "A Laboratory Analysis of Color Removal Across a Pulp and Paper Mill Wastewater Treatment Facility"
by Aimee Winter McCord
2 "A Laboratory Analysis of the Color Removal Mechanism Occurring Across the Wastewater Treatment
Platt"by Chad Salisbury
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
some hardwood Sewer Generated Color may be removable across the WWTP (3%
reduction in color after WWTP process), but pine filtrates showed an average increase in
color of 21% in the simulated WWTP process. Data from this study show brown source
color removal up to 70% and the long-term average color removal across the WWTP
from primary influent to secondary effluent is 25%. The annual Color Pies showing the
breakdown of mill sewers compared to primary influent color support the presence of
Sewer Generated Color as unaccounted color has averaged 25% (19,081 lbs/day) since
1996. Of this 25%, the hardwood screen rejects contribute a small amount(currently
about 2,700 lbs/day). The period from November 2002 through April 2003 is evidence
that specific interactions and operational conditions can significantly intensify the Sewer
Generated Color effect. Bench scale studies are planned to better understand the various
types and magnitudes of the major interaction effects pinpointed during the period of
elevated color. It is recognized that these conditions may change and new effects may
need to be studied in the future.
Figure 3 below shows the trend of increasing unaccounted color and decreasing WWTP
color removal that began in November 2002.
t
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
Unaccounted Color and WWTP Color Removal
m 30000 Monthly Averages: Jan-02 through Feb-03 35.00%
y 25000 30.00%
a n
`o 20000 25.00%0
15000 20.00%CD
3
v
15.00%0
10000 d
10.00%e
C 5000 5.00%
0 0.00%
0 0 0 0 0 0 0 0 0 0 0 0 0 0
o v c a
ti Q "D Q rn 0 Z �m
Unaccounted Color * WWTP Color Removal
i
Figure 3
The trend of increasing unaccounted color and simultaneous decreasing WWTP color
removal continued in December and a Color Team was formed including representatives
from Operations,Envirohmental and the Technical Manufacturing Support group. This
team initially audited the color measurement system as well as monitored sewer areas and
related instrumentation for accuracy as well as potential unmeasured sources of color.
When there were no anomalies discovered, the team focused on analyzing process
parameters for shifts and deviations that could contribute to elevated color. Processes in
the Fiberlines and Recovery area were reviewed in most detail while deviations from the
Paper Machines were also considered. The Pine Eo filtrate was consistently the only
color source that was running above its upper control limit but the causes were unknown.
Multiple statistical analyses were performed including CUSUMs or Cumulative Sum
charts to identify if, in fact, statistically significant shifts were occurring. While there
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
were several process parameters that were discovered to be operating outside their normal
ranges of variability, the most notable shifts were seen in the Fiberlines. Specifically,the
Pine Fiberline Bleach Plant and the Hardwood Fiberline Pre-Bleach and D 1 (first D)
stages. Additional statistical studies were performed and targets were established for the
above parameters as well as others, based on early 2002 when the color performance was
in the 36,000—39,000 lbs/day range. As the Fiberlines began reaching the established
targets, the unaccounted color remained elevated.
During the latter part of 2002, the variability in the White Liquor strength and solids
increased. This change was believed to be negatively impacting the Fiberline operations
by causing increased carryover into the bleach plants. These issues corresponded to the
decreased color performance seen beginning in November 2002. Elevated White Liquor
solids were then identified as an interaction effect contributing to elevated secondary
effluent and unaccounted color and this parameter was added to the Daily Color
Monitoring list. Also during late 2002, the quality of purchased lime for the Causticizing
operation was compromised due to flooding and other issues with the Mill's normal lime
supplier. Negotiations with additional lime suppliers are ongoing to improve the quality
of purchased lime.
A
Upon startup from the Cold Mill Outage in April 2003, unaccounted color increased even
further to the 35,000—40,000 lbs/day range from pre-Cold Mill levels in the 20,000
lbs/day range. Pine Eo filtrate color was back below the in-control average yet
unaccounted color was still high. Detailed Analysis of Variance (ANOVA) Factorials
were performed in an effort to determine which factors and combinations of factors were
affecting secondary effluent color and unaccounted color significantly. For these
analyses, an alpha of.05 was used. The results of the ANOVAs proved that there were
multiple statistically significant main effects and interaction effects "responsible" for the
elevated secondary effluent color and unaccounted color. This means that the effect
\ impacting the dependent variables (secondary effluent and unaccounted color) was not
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
doing so by chance. The interaction effects involve relationships between certain
parameters that significantly affect color. Subtle operational changes made in late 2002
had triggered a major Sewer Generated color problem and greater than 30 effects,
including main and interaction effects, were pinpointed. The most significant main
effects were BFRTM Closure, Pulp Mill Flow and Hardwood Pre-Bleach Conductivity.
There were numerous significant interaction effects, some including up to four interacting
factors, which is evidence of the problem's complex nature. To determine if the effects
had been present during periods of"good" color performance,ANOVAs were performed
on those periods as well. The only main effect that was statistically significant in
impacting secondary effluent color from January 2002—July 2002 was Closure and there
were no main effects nor interaction effects that were statistically significant for
unaccounted color during the period of good color performance. As a result of the
ANOVA studies, a daily color monitoring information report was created which tracks
the color-impacting parameters via targets and 30-day trends. Closure was the most
significant main effect contributing to elevated secondary effluent color. Given the
increase in bleach plant filtrate that reaches the mill sewer when closure rates are low,
there is a larger volume of low pH material available to undergo the Sewer Generated
Color effect. Because it has been shown that Sewer Generated Color is not removed
across the Wastewater Treatment Plant, lower closure rates translate into a measurable
increase in secondary effluent color. In addition to being a main effect, closure was a
statistically significant color-impacting variable in 13 different interaction effects as well.
Pulp Mill flow was the second most significant main effect contributing to elevated
secondary effluent color. Similar to closure, elevated flow from the Pulp Mill is likely to
be low pH material, which is a pre-cursor for Sewer Generated Color.
Hardwood Pre-Bleach Conductivity is the measure of conductivity from a pulp filtrate
sample taken off of the Pre-Bleach washer. Elevated conductivity indicates increased
carryover into that stage. Increased carryover from the pre-bleach stage can affect the
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
first stage of bleaching (D1),potentially requiring elevated acid usage on the D1 stage.
This was observed during the period of elevated color and was also a statistically
significant main effect and interaction effect in the ANOVA analyses. Elevated acid use
in the bleach plant could intensify the Sewer Generated Color effect by further reducing
pH.
Also, it was believed that start-up of the entire mill from the Cold Mill outage required
adequate time to reach stable operation. This stable operation was not achieved until
mid-May. Challenges from the Cold Mill start-up had to be managed before the targets
from the ANOVA Factorial analyses could properly be incorporated into the daily
operation. At this point unaccounted color and secondary effluent color finally began
reaching normal ranges.
1
Incorporation of the results from the ANOVA studies into the Daily Color Monitoring
Information report has proven to be a useful tool for color management at the Canton
Mill. It is recognized that the conditions causing these effects may change in the future
and new effects may need to be studied/evaluated. Since the Daily Color Monitoring
Information report has been in use, the average secondary effluent color has dropped
from 49,024 lbs/day (average during November 2002 through April 2003 period of
elevated color) to 42,669 lbs/day. The Canton Mill is utilizing this new tool and will
continue to use and develop innovative tools for troubleshooting color in the future.
t
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
V. Statistical Analysis of Data
The average secondary effluent color from December 2001 through August 2003,
excluding the period of elevated secondary effluent and unaccounted color, is 39,833
lbs/day. Based on a statistical evaluation of the mill's monthly average color
performance, for the same period, the achievable secondary effluent color using a 95"'
percentile distribution is 43,189 lbs/day. The 2002 annual average secondary effluent
color was 41,171 lbs/day. Blue Ridge is committed to continued color performance
improvements and recommends an annual average secondary effluent limit of 42,000
lbs/day.
r
Blue Ridge recommends a monthly average effluent limit of 52,000 lbs/day based on the
color challenges encountered in the past year. Data for the December 2001 through
August 2003 period is attached to this report.
A
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Blue Ridge Paper Products Inc.
Monthly Average Secondary Effluent Color: Dec-01 through Aug-03
Attachment 1:October 1, 2003 Report
Monthly Average Ibs/day
Month Secondary Effluent.Color
Dec-01 36,821
Jan-02 39,040
Feb-02 39,870
Mar-02 37,886
Apr-02 42,477 Monthly Average Ibs/day
May-02 42,458 Secondary Effluent Color Excluding Nov-02-Apr-03
Jun-02 41,312 Dec-01 36821
Jul-02 41,686 Jan-02 39,040
Aug-02 40,750 Feb-02 39,870
Sep-02 39,480 Mar-02 37,886
Oct-02 36,382 Apr-02 42,477
Nov-02 48,014 May-02 42,458
Dec-02 44,701 Jun-02 41,312
Jan-03 51,269 Jul-02 41,686
Feb-03 48,324 Aug-02 40,750
Mar-03 50,412 Sep-02 39,480
Apr-03 51,423 Oct-02 36,382
May-03 40,955 May-03 40,955
Jun-03 42,458 Jun-03 42,458
r Jul-03 44,734 Jul-03 44,734
Aug-03 42,527 Aug-03 42,527
2002 average 41,174 95th percentile 43,189
2003 ytd average 46,513 period average 40,591
95th percentile for 2003 51,369
s
r

December 2003
Color Performance Following Highest
Certainty Actions and Evaluation of
Reasonable Certainty Actions

December 2003 Report
Blue Ridge Paper Products Inc. —Canton, NC
Contains Confidential Business Information
I. Introduction
The following report details the Canton Mill's ability to attain the targeted 3,000— 8,000
pounds per day annual average color reduction from the reduction achieved by
implementation of the `Highest Certainty' actions. Section A(8.), Paragraph 7 of the
2001 NPDES Permit provides as follows:
"The permittee shall submit to the Division of Water Quality, the Technology Review
Workgroup and the NPDES Committee by December 1, 2003, a report on the feasibility
of achieving a target annual average color reduction within the range of 3,000 and 8,000
pounds per day from the reduction achieved by implementation of the Highest Certainty'
actions. This report shall include an evaluation of the use of the Reasonable Certainty'
actions identified in the EPA Tech Team Report and any other actions that would result
in additional color reductions, actions taken by the permittee to reduce color loading
r (since permit issuance), and the technical, economic, and operational feasibility of
1
implementing the Reasonable Certainty'actions on a continuous or intermittent basis, in
order to achieve a target annual average color reduction within the range of 3,000 and
8,000 pounds per day. As identified in the EPA Tech Team Report, the 'Reasonable
Certainty'actions are the technologies of Ozone/Chlorine Dioxide stage for the
hardwood bleach line and second stage oxygen delignification for the pine line. The
report shall identify specific economic and implementation issues associated with the
proposed improvements. The report shall also project expected additional color
reduction for each technology evaluated and maximum color reduction possible using the
identified technologies. The report shall also include a proposed schedule for
implementation of process improvements or installation of technologies required to
achieve an additional an effluent color reduction of 3,000-8,000 pounds per day. The
permittee shall provide this evaluation/report, together with an updated report on the
results of ongoing and additional planned color reduction activities, to the Division of
Water Quality, the Technology Review Workgroup and the NPDES Committee. By
February 1, 2004, DWQ(in consultation with the Technology Review Workgroup)shall
approve or modify the permittee's recommended plan for achieving an additional 3,000-
8,000 pounds per day reduction to the target annual average. "
Blue Ridge has conducted extensive analysis of the"Reasonable Certainty" actions since
the issuance of the NPDES Permit in November, 2001. Based on the results of that
i^ analysis, Blue Ridge does not believe implementation of the Reasonable Certainty actions
' will result in a reduction of color within the range of 3,000 to 8,000 pounds per day. Even
NPDES Permit 0000272
1

December 2003 Report
Blue Ridge Paper Products Inc. —Canton, NC
Contains Confidential Business Information
i
if the Reasonable Certainty actions were projected to result in the targeted color
reduction, Blue Ridge does not believe implementation at the Canton Mill would be
feasible given economic, technical and operational considerations.
The Blue Ridge technology analysis indicates the most feasible approach to reducing
color at the Canton Mill within the targeted range of 3,000 to 8,000 pounds per day,
considering technical, economic and operational factors, is to: 1) contain color associated
with the de-watering/disposal of the Pine and Hardwood Quaternary Screen Rejects 2)
provide additional capacity and outlet for color associated with the Pine Brown Recovery
tank and 3) improve process control around Hardwood washing through process
optimization efforts.
r^. Further, Blue Ridge proposes to pilot test Ozone destruction of color associated with CRP
and Hardwood Eo filtrate streams. If successful, this technology, coupled with the 3
identified steps,provides the best opportunity for the ultimate elimination of the color
variance.
d
NPDES Permit 0000272
2

December 2003 Report
Blue Ridge Paper Products Inc. —Canton, NC
Contains Confidential Business Information
II. Proposed Schedule for Implementation of Process Improvements/Technologies to
Achieve 3,000— 8,000 pounds per day additional Secondary Effluent Reduction
2.1 De-watering/Disposal of Pine and Hardwood Quaternary Screen Rejects
The Canton Mill has developed a project to pipe the quaternary screen rejects from both
fiberlines to the Pine Rejects Press and recover the filtrate for reuse in the process. The
current configuration of this system sends the quaternary screen rejects from both
fiberlines to the sewer.
The capital cost for these color reduction process improvements is approximately
$250,000. This Screen Room modification is scheduled for completion in 2005. Color
savings from this project are estimated to range between 1,500 - 3000 lbs/day from the
secondary effluent.
2.2 Pine Brown Recovery Tank Line to Hardwood Blow Tower
a
There is currently a project underway to pipe the Pine Brown Recovery tank to the
Hardwood Blow Tower for additional process collection reclaim capability and Pine
Fiberline outage management. This project is scheduled for completion by March 1,
2004. It is expected that this will reduce color by less than 5001bs/day from an annual
average. This design allows for the Pine Brown Recovery tank to be recycled into the
Hardwood Blow Tower and is especially useful in pine outage situations when the
recycle of additional process material is required.
� k
NPDES Permit 0000272
3

December 2003 Report
Blue Ridge Paper Products Inc. —Canton, NC
Contains Confidential Business Information
2.3 Process Optimization
Since the issuance of the NPDES Permit in December 2001,many steps have been
implemented to further reduce color(see Attachment A). The mill is still optimizing the
benefit of all these activities. Hardwood Fiberline washing parameters were pinpointed
as statistically significant contributors to unaccounted color in May 2003. While the
variability of these parameters has been reduced since they were pinpointed as being
related to color, the Canton Mill is committed to further improvements associated with
sewer generated and unaccounted color. Blue Ridge has recently undertaken an initiative
for process evaluation and improvement within the company. As part of that initiative, a
project was selected to evaluate Hardwood Brownstock washing and it's impact on
unaccounted color.
b
1
NPDES Permit 0000272
4

December 2003 Report
Blue Ridge Paper Products Inc.—Canton, NC
Contains Confidential Business Information
III. Evaluation of Ozone/Chlorine Dioxide stage for Hardwood Bleach Line
The Pulp and Paper Research Institute of Canada (PAPRICAN)performed an
ozone/chlorine dioxide bleaching sequence ((ZD)EoD) study using washed Pre-Bleach
stage pulp from the Canton Mill. A ZD stage was one of the two `Reasonable Certainty'
actions recommended by the Tech Team. Based on PAPRICAN's study of Canton mill
pulp, overall Hardwood Bleach Plant color from the (ZD)EoD bleaching sequence
increased 7% when compared to PAPRICAN's baseline DEoD bleaching sequence.
Canton Mill management also visited the Domtar mill at Espanola, Ontario, Canada in
August 2003, toured that facility and reviewed a presentation on Domtar's color
reductions. Domtar's Espanola mill utilizes a ZD bleaching stage on their Hardwood
line. Because Domtar did not measure color from individual filtrate streams, it was
impossible to quantify the actual color reductions seen from the ZD bleaching stage. It is
important to note, however, that Domtar's final effluent color after the reductions was
300 color units greater than the Canton Mill's current color level (i.e. 500c.u. vs 200c.0 at
Canton). Further, Domt ar's objective in implementing the ZD bleaching was to improve
pulp brightness, not to reduce color.
Technology Operating Costs Capital Costs Color Reduction I Quality Concerns
ZD Bleaching Increase of$1.5- $9MM 7% Increase Decrease in
2MM per year T_ Freeness
The operating cost projections from the PAPRICAN study revealed an increase in
chemical costs by the ZD stage. The DEoD baseline cost of$12.52 per ton increased to
$16.85 per ton for the ZD stage and, while the reduction in chlorine dioxide needed
NPDES Permit 0000272
5

December 2003 Report
Blue Ridge Paper Products Inc.—Canton, NC
Contains Confidential Business Information
i
corresponds to an annual energy savings of$40,000, the annual energy demands of an
ozone generator are greater than $500,000. Therefore, the result is a net increase in
operating costs for a ZD bleaching stage, based on the mill-specific PAPRICAN study.
The Canton Mill estimates a capital cost (+/-30% estimate) requirement of$9 Million for
a ZD bleaching stage. Information supporting this estimate marked "Confidential
Business Information" (CBI) is attached to and included in this report in Attachment B.
Please treat this attachment under the appropriate CBI requirements.
The PAPRICAN study showed most parameters were unaffected by the ZD bleaching
stage. The one parameter that demonstrated a measurable decrease was freeness. Such a
drop in freeness (See Figure 1) could potentially cause production and cost issues,
T especially for the paperboard machine.
Paprican Bleaching Evaluation PFI Strength Evaluation
Freeness Drop
500 AN
450OW
ti
a
400 i. a 43
y 350
w 10 ..._ t
300
'
250 �x
0 1,000 3,000 5,000
PFI Revolutions
�-DEoD�(ZD)Eop
Figure 1
NPDES Permit 0000272
6

December 2003 Report
Blue Ridge Paper Products Inc. —Canton, NC
Contains Confidential Business Information
t
Based on a thorough review of the PAPRICAN study results, the implementation of a ZD
bleaching stage does not achieve color reduction and is not economically, operationally
nor technically feasible.
A
NPDES Permit 0000272
7

December 2003 Report
Blue Ridge Paper Products Inc. —Canton, NC
Contains Confidential Business Information
IV. Evaluation of Second Stage Oxygen Delignification on the Pine Fiberline
Andritz-Ahlstrom's Pruyn's Island Technical Center performed a second stage oxygen
delignification laboratory study with Brownstock pulp from the Canton Mill. The
purpose of this study was to evaluate both qualitative and quantitative effects of a second
oxygen delignification stage on pulp from the Pine Fiberline.
Technology Operating Costs Capital Costs Color Reduction Quality Concerns
Vd Stage 02 $340,000 savings $2MM Insignificant due Decrease in
Delignification to BFR' Viscosity
ram,
Operationally, there was a 22% Kappa reduction seen from the second oxygen
delignification stage. This reduction in Kappa would likely.correspond to an
approximate reduction of 1,2001bs/day in color from the bleach plant filtrates. However,
the Canton Mill's Bleach Filtrate RecycleTM process reuses the majority of the Pine
Fiberline's bleach plant filtrate, and, as BFRTM Closure rates continue to improve, the
potential 1,2001bs/day reduction in color becomes nominal.[
i
There was a 12% drop in viscosity resulting from the benchscale second oxygen
delignification stage on the CantonMill's pulp. Such a decrease in viscosity could
contribute to problematic deteriorations in pulp strength. A benefit of this system could
be an increase in brightness but the corresponding decrease in strength would likely result
in off-quality pulp, paper and paperboard.
Please refer to the October 1,2003 Report for specific details around improvements made to the Bleach
Filtrate Recycle'"'Process that are contributing to improved closure.
NPDES Permit 0000272
8

December 2003 Report
Blue Ridge Paper Products Inc. —Canton, NC
Contains Confidential Business Information
While an annual wood cost savings would be seen from a 2-stage oxygen delignification
system, Blue Ridge estimates these savings to be in the range of$340,000, which equates
to a 1% yield increase on the Pine Fiberline.
Blue Ridge believes a second Oxygen Delignification Stage would not result in
significant color reduction and could result in deteriorations in pulp strength.
Accordingly, implementation of a second oxygen delignification stage at the Canton Mill
does not result in significant and color reduction and is not feasible for technical and
operational reasons.
a
NPDES Permit 0000272
9

December 2003 Report
Blue Ridge Paper Products Inc. —Canton, NC
Contains Confidential Business Information
V. Additional Color Reduction Technologies
5.1 Ozone Color Reduction System
The Canton Mill is currently evaluating the feasibility of an Ozone Color Reduction
System for treatment of CRP and Hardwood Eo filtrate streams. Based on extensive
laboratory testing, Blue Ridge believes the application of Ozone to these waste streams
should result in reduction of color in these waste streams by 70 percent. A pilot scale
plant is currently under an engineering study to evaluate the potential real-time effects of
such a system. This pilot scale system will be installed in early 2004. It is estimated that
design, construction, implementation and analysis will encompass a 12 to 18 month
timeframe. A bench scale wastewater treatment plant simulation to gage the effects of
the ozonated filtrate on the biological system will be included in the overall analysis.
Based on a detailed assessment of the pilot plant's performance, which will include
economic, technical and operational considerations, a full-scale system will be evaluated.
Pending favorable results from the pilot study assessment, the full-scale system would be
installed in 2006.
Technology Operating Costs Capital Costs Color Reduction Quality Concerns
Ozone Color $0.5 -1 MM $ 3-5mm > 5,000 lbs/day None known
Reduction
Annual operating costs of an Ozone Color Reduction System would range between
$0.5MM -$1MM due to the large energy and oxygen requirements. The capital costs for
this system,based on a+/- 30% estimate, would be approximately$3.8MM. While this
capital expenditure is large, the potential color reductions are substantial and could likely
allow the Canton Mill to operate without a color variance.
1
NPDES Permit 0000272
10

December 2003 Report
Blue Ridge Paper Products Inc. —Canton, NC
Contains Confidential Business Information
�I
5.2 White Rot Fungus Trial
In early 2003, Blue Ridge Paper Products Inc. began investigating the potential for color
reduction across the Wastewater Treatment Plant(WWTP) using White Rot Fungus.
Studies had been performed since the early 1980's by various universities and de-
colorization of pulp mill wastewater was seen in the laboratory. Canton Mill personnel
visited a textile mill Wastewater Treatment Plant using White Rot Fungus in its aeration
basins and polishing with ozone. The color reduction achieved from the fungus alone
was greater than 90%.
The Canton Mill has worked with 2 potential vendors with experience in fungal
wastewater treatment applications. Neither vendor was able to demonstrate the technical
or operational capability to support an on-site demonstration project. Beginning in
August, 2003 an on-site "fungal farm" was installed at the waste treatment aeration basin.
However the project was discontinued in November when the supplier was unable to
deliver on the production of any white rot fungus. The Mill continues to be interested in
this decolorization technology and will monitor further progress in this field.
For additional actions taken to reduce color loading since permit issuance, please refer to
Appendix C, the October 1, 2003 Report.
NPDES Permit 0000272
11

December 2003 Report
Blue Ridge Paper Products Inc. —Canton, NC
Contains Confidential Business Information
VI. Schedule for Implementation of Technologies to Achieve 3,000— 8,000 pounds Per
day Additional Secondary Effluent Color Reduction
The Pine Brown Recovery Tank project will be completed,in 2004. The De-
watering/Disposal system for the Quaternary Screen Rejects will be completed in 2005.
The formation of a process optimization team that will evaluate and make improvements
in Hardwood washing, coupled with the optimization of all improvements identified in
Attachment A will drive further color reductions in 2004. This entire effort, combined
with the items discussed in the October 1, 2003 report, is expected to result in secondary
effluent color reductions within the targeted 3,000—8,000 lbs/day range.
The Canton Mill plans to begin a pilot-scale Ozone Color Reduction System in the first
quarter of 2004. A 12 to 18 month trial will be conducted to monitor the real-time effects
of the ozone treatment on the selected waste streams. If consistent de-colorization of
70% of the CRP and Hardwood Eo filtrate color is achieved during the trial, the
economic, operational and technical feasibility of a full-scale system will be re-evaluated
based on specific trial results (i.e., ozone application rate, energy demands, consistent
color reduction out of the reactor and treated waste stream impact). Pending a favorable
assessment of this pilot study, a full-scale system would be installed in 2006. Color
reductions from this system are anticipated to be significant. If this project is successful,
the Canton Mill's goal is removal of the color variance.
The Canton Mill is committed to continuous improvements in color management and
believes disposal of the Quaternary Screen Rejects, the Pine Brown Recovery Tank
expansion and the Hardwood Fiberline washing improvements will reduce the Canton
Mill's secondary effluent annual average color within the range of 3,000— 8,000 lbs/day.
NPDES Permit 0000272
12

AttactJ,(�;nt A
2001 NPDES Color Reduction Initiatives
Color Reduction Measure 2002 2004 0 751MI 2006
1 2-Hour Color Testing
2 Lieber ott Recommendations Implemented
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 outgges
6 Installation of Mechanical Seals
Improvement of equipment used for handling Pine and
7 Hardwood Knot Rejects
8 $1.5MM spent on Bleach Filtrate Recycle Improvements
9 Installed Pine Brownstock Control Logic improvements
10 Determined multiple contributers and interaction effects causing
Sewer Generated Color
11 I Bench-scale sewer-generated color work
12 Process Optimization/Six Sigma Team designated for
Hardwood Fiberline color improvements
13 Improvements made to Pine Brownstock sumps for better
recover
14 rite Rot Fungus Trial-growth efforts unsuccessful,may re-
visit in future.
15 Pine Brown Recovery Tank Line to Hwd Blow Tower -
16 De-Watering/Disposal of Pine and Hwd Screen Rejects
17 Pilot Scale Plant for Ozone De-Colorization
18 Implement full-scale Ozone De-colorization system if Pilot-
scale study is successful
- Past Process Change Implementation
Continued Performance Improvement
- Future Process Change Implementation
Expected Performance Improvement

AttacliuJmt A
2001 NPDES Color Reduction Initiatives

ATTACHMENT B-Confidential Business Information
Hardwood Fiberline Ozone Bleaching
( Equipment Design List
1 New MC Z Stage
System Equipment Specs of Note Cost Estimate Source
Bleaching
Z Stage Chute 254 SMO Inc Andritz
Z Stage MC Pump 254 SMO Inc Andritz
Ozone Mixer 254 SMO Inc Andritz
Z Stg Retention Pipe 254 SMO Inc Andritz
Z Stg Discharger 254 SMO Inc Andritz
Relief Gas Scrubber 317 SS Inc Andritz
Post Z MC Feed Chute 254 SMO $1,025,000 Andritz
D1 Stage MC Pump 254 SMO $450,000 Sulzer
600 HP VSD Mixer $116,000 Ogles
500 HP Direct Drive Z MC Pump $102,000 Ogles
450 HP Direct Drive Do MC Pump $40,000 Ogles
Piping $200,000 BRPP
Power Supply and Transformation 250 KVA/CP&L 10 $185,000 Ogles
Electrical $125,000 BRPP
Instrumentation and Valving $251,000 BRPP
Civil &Structural New Mezz Floor Ext $75,000 BRPP
Misc $40,000 BRPP
Installation Estimate $750,000 BRPP
Gas Treatment
755 ACFM @ 155 Included with Z
Ozone Destructor Units deg F Generation Ozonia
4 Units
Piping $45,000 BRPP
Electrical $35,000 BRPP
Instrumentation $75,000 BRPP
Civil &Structural Located on BP Roof $25,000 BRPP
Misc ; $20,000 BRPP
Installation Estimate $85,000 BRPPI
Recompression of Waste Gas Optional Air Liquide
Condenser for Saturated Gas• Optional (Not Enough Info at this Time)
Electrical and Instrumentation Optional (Not Enough Info at this Time)
Installation Estimate Optional (Not Enough Info at this Time)
Optional
Total $3,644,000
Ozone Generator Estimate $3,650,000
Building and Civil $250,000
Utilities Cost $175,000
Power Connection Cost $250,000
Total Installation Estimate $1,100,000
Total Estimated Installed Cost $9,069,000
Estimate quality is+/-30%
Blue Ridge Paper Products
December 2003 Report
NPDES #0000272

r_�
BLUE RIDGE
�-� PAPER PRODUCTS INC.
May 18, 2004
Mr. Forrest Westall
Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Hwy 70
Swannanoa, North Carolina 28778
Subject: Supplement to December 2003 Color Report & Schedule Revision
NPDES No. NC0000272
Blue Ridge Paper Products Inc.
Canton, North Carolina
Dear Mr. Westall:
`y This letter is a supplement to the December 2003 report on"Reasonable Certainty" actions for
color reduction as specified in the November 2001 NPDES permit for Blue Ridge Paper
Products, Inc. The letter outlines current ongoing and additional color reduction activities in
preparation for the CRP color reduction report due in December 2004 [Permit Condition A.(8.)9]
and the statistical evaluation report for second tier color reductions due in December 2005
[Permit Condition A.(8.)81.
The Blue Ridge technology analysis documented in the December 2003 report identified three
most feasible areas for additional color reduction:
1. Contain color associated with the de-watering/disposal of Pine and Hardwood
Quaternary Screen Rejects.
2. Provide an additional capacity and outlet for color associated with the Pine Brown
Recovery tank.
3. Improve process control around Hardwood washing through process optimization efforts.
Blue Ridge also proposed a pilot test of ozone destruction of color associated with CRP and
Hardwood Eo filtrate streams.
This supplement communicates Blue Ridge's intent to update and revise the schedule around
`7 certain color reduction initiatives. Blue Ridge will be accelerating and adding certain initiatives
Environmental Group
175 Main Street a PO Box 4000
Canton, North Carolina 28716 o 828-646-2000
Raising Your Expectations

Mr. Forest Westall, NC DENR DWQ
May 18, 2004, Page 2
that are expected to benefit overall reductions. While evaluating these initiatives Blue Ridge
intends to modify the timeline for any ozone pilot test pending this evaluation. Significant
engineering work has already been completed for the ozone pilot test.
The status of these color reduction activities follows. Our first priority for color reductions
continues to be pollution prevention; color minimization through even tighter process operations
as opposed to end-of-pipe color treatment.
Current Color Reduction Activities
A. Hardwood and nine quaternary screen rejects—implementation accelerated
This project was defined in the December 2003 report and will pipe the quaternary screen
rejects from both pine and hardwood fiber lines to the Pine Rejects Press and recover the
filtrate for reuse in the process. For process operability reasons related to purging "dirt" and
other pulp contaminates, the quaternary screen reject flows are currently sewered
contributing an estimated 1500 to 20001bs per day to secondary effluent color.
Preliminary engineering for rejects transfer piping is underway. Evaluation of alternative
equipment for rejects dewatering is also underway.
B. Pine brown recovery spill line to hardwood blow tower—complete 2°d Otr. 2004
This is the project defined in December 2003 to provide additional process collection and 1
reclaim capability for black liquor and colored filtrates by connecting the pine brown
recovery tank to the hardwood blow tower. The piping work for the project was completed
during I"Quarter 2004. The final phase of piping system changes will become active and
available at the end the May 2004 scheduled fiber line outage for annual maintenance.
The reduction in annual average secondary effluent color from the pine brown recovery spill
line is less than 500 lbs/day. However; this additional process collection and reclaim
capability can potentially avoid 1500 to 30001bs/day of monthly average color related to
outages and unplanned maintenance events.
C. Green liquor sump in Recovery Furnace area—additional initiative
Green liquor spills, leaks and maintenance diversions in the recovery furnace area are
sewered. Black liquor spills or leaks in the recovery furnace area that are contaminated with
green liquor are also sewered. This sewering of highly color materials is due to operational
problems that occur when green liquor is recovered and mixed with black liquor in recovery
furnace sumps. The recovery furnace spill sumps reclaim liquor materials by returning them
to the black liquor evaporator system. Green liquor causes corrosion and fouling of the
evaporators and is therefore segregated from black liquor whenever possible.
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

j
Mr. Forest Westall, NC DENR DWQ
May 18, 2004, Page 3
Preliminary engineering for a separate green liquor spill sump system at the recovery
furnaces is underway. The sump will segregate green liquor and black liquor handling areas
at the recovery furnaces. It will allow recovery of green liquor chemicals from process leaks,
operational purges and maintenance diversions and should improve color performance by
reducing sewering of green liquor materials and black liquor that is contaminated with green
liquor. These colored process loses will be recovered.
The reduction in annual average secondary effluent color from the green liquor sump is less
than 500 lbs/day. The additional process collection and reclaim capability provided by the
sump can potentially avoid 1500 to 30001bs/day of monthly average color related to outages
and unplanned maintenance events.
D. Chlorine dioxide treatment of the CRP waste stream—additional initiative
Blue Ridge will substitute a trial of chloride dioxide(002)treatment of the chloride
removal process (CRP)waste stream in place of the ozone treatment pilot test described in
the December 2003 report. We are prepared to proceed with the ozone pilot test if the C102
trial is not successful. However,based on bench and pilot scale work for combined C102
and ozone treatment of CRP completed during 2003, we believe that C102 treatment alone is
viable and worth further study. The advantage over ozone treatment is that Blue Ridge has
an existing C102 generation system with associated safety and air emission controls. These
existing facilities make C102 treatment potentially much more cost effective.
Preliminary engineering is underway for transfer piping and supporting utilities to treat CRP
along with pine D2 filtrate with C102 in a surplus process bleach tank. The D2 filtrate
contains residual C102 from the pulp bleaching process and will dilute the CRP color stream
to prevent salt precipitation during color treatment. Blue Ridge will retain an outside
chlorine dioxide expert to conduct additional CRP color treatment trials to verify the sizing
of equipment and C102 dose rates for a full-scale system.
The potential reduction in annual average secondary effluent color from CRP treatment with
chlorine dioxide is estimated to be 20001bs/day.
E. Milk of lime to sewer—additional initiative
Blue Ridge is conducting a trial on the color reduction effect of adding continuous slurry of
hydrated lime to the mill sewer system prior to wastewater treatment. This "milk of lime"
slurry provides calcium, which in bench scale studies was effective in reducing brown color
from bleaching filtrates. As Blue Ridge has tightened controls on black liquor-related dark
color,brown color has become a large portion of the mill's remaining color discharge.
The milk of lime trial will conclude in May. Blue Ridge will prepare a statistical analysis of
primary influent and secondary effluent color data to determine if the"milk of lime" effect
on color is significant. We will also evaluate the potential color reduction benefit, the effect
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

Mr. Forest Westall, NC DENR DWQ
May 18, 2004, Page 4
r�
on wastewater treatment operations and operating cost. Preliminary data suggest that milk of
line addition can potentially reduce 500 to 20001bs/day of secondary effluent color.
Summary
Implementation of `Highest Certainty' actions identified in the NPDES permit fully met the
expectations for first tier color reductions. Blue Ridge Paper Products believes that projects
identified in the December 2003 report and in this letter will meet the second tier color
reductions. This mix of initiatives will be evaluated to achieve compliance with the next color
reduction range of 39,000 to 32,000 lbs/day. We will also evaluate whether these initiatives
might achieve reductions that will allow the color variance to be lifted.
Blue Ridge is internally preparing full project descriptions with cost and color benefit analysis to
determine technical, economic and operational feasibility.
Sincerely,
Paul S. Dickens Robert V. Williams
Manager, Environmental Affairs Director,Regulatory Affairs
dickei)@blueridget)al)er.co willib@blueridgepai)er.com
828-646-6141 828-646-2033
b
PSD/s
Attachment I: Updated Color Reduction Initiatives Schedule
cc: EPA TRW
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000

March 2004
CRP Color Reduction Technology
Assessment

Color Removal Technology Assessment for Chloride Removal Process(CRP) Purge Stream - March 2005
Blue Ridge Paper Products
! � NPDES Permit No. NC0000272
Permit-Specified Technologies Other Technologies
Commercial Coagulation/ Solidification for Land Bleaching-Clozone Bleaching-Chlorine CRP on Lime Precast
Technology Land Application Incineration Precipitation Disposal (CI02&03) Dioxide(C102) Filter Other
EVALUATION Literature review and Commercial quote for off Bench scale tractability Commercial quotes for Engineering estimate for Bench scale&field trials Series of field trials Short duration field trails Third party evaluations
METHODS engineering calculations site incineration study of lime,aluminum off-site solidification and on-site evaporation and quotes for
salts,iron salts and land disposal equipment to solidify the proprietary treatment
polyamine CRP purge stream technologies including
wet air oxidation,
activated carbon,filter
paper solids separation,
catalyzed oxidation and
ultra filtration.
TECHNICAL& Not an appropriate Not an appropriate Infeasible technology- Infeasible technology Infeasible technology Infeasible technology- Infeasible technology- Unproven technology- Proprietary technologies
OPERATIONAL technology due to high technology due to high low to moderate color due to large operating due to high operating consistent bleaching consistent bleaching wide variation in color evaluated were not
FEASIBILITY chlorides in CRP purge chlorides and dissolved removal with large expense associated with and capital cost. performance difficult to performance difficult to removal. Needs more effective or not
stream. salts in CRP purge sludge generation. off-site hauling and maintain. CI02 alone is maintain. Operating work to confirm commercially viable for
stream. Potential for effluent treatment. equally effective problems with off- feasibility. color removal from the
toxicity. bleaching agent for CRP gassing and foam. CRP purge stream.
pur astream.
ESTIMATED ANNUAL NA >$25 million >$370 k >$3.6 million >$2.1 million >$615 k >$145k Undetermined NA
OPERATING COST
l ESTIMATED CAPITAL NA >$150 k for tank truck >$1.7 million >$150 k for tank truck > 11.1 million >$1.8 million >$1.2 million Undetermined NA
COST loading facility loading facility
POTENTIAL FOR
SECONDARY The contribution of CRP color to secondary effluent color is small and less than the normal variation in day today secondary color measurements. There Is no certainty that color removal in the CRP purge stream will result In an equivalent
EFFLUENT COLOR secondary effluent color reduction.
opmIrTints
EVALUATION NOTES NA Potential to remove all High chloride content of Potential to remove all Ruled out as option in Inconsistent color Inconsistent color High chlorides in CRP NA
CRP color from mill. CRP purge stream may CRP color from mill. 2001 Color Removal removal performance removal performance purge stream may
CRP purge stream require special materials CRP purge stream Technology Assessment during trial. Operating during trial. Process corrode mud filters and
handling without and higher equipment handling without Report. problems with off- control strategy for full other equipment.
crystallization and cost. No indication that crystallization and gassing and foam. scale system is not Special materials of
plugging during truck color removal in CRP plugging during truck Process control strategy defined. Operating cost construction may be
loading and purge stream will result loading and for full scale system Is assumes on-site bulk required. Need to
transportation will be in equivalent secondary transportation will be not defined. Operating CI02 supply. No evaluate effect of CRP
difficult. May require effluent color reduction. difficult. May require cost is power and indication that color filtrate recycling back
dilution and add to cost. Polyamine can adversely dilution and add to cost, chemical reagents. No removal in CRP purge into process. Precoat
Requires at least 3 effect secondary effluent Requires at least 3 indication that color stream resulted in filter does not operate
tanker trucks per day. toxicity. tanker trucks per day. removal in CRP purge equivalent secondary continuously. Impacts
Requires heated storage Requires heated storage stream resulted in effluent color reduction. on landfill Ieachate and
tank and truck loading tank and truck loading equivalent secondary potential for color return
facility. facility. effluent color reduction. to mill not known.
CONCLUSION '..
TECHNICALLY,
ECONOMICALLY AND OPERATIONALLY NO NO NO NO NO NO NO Undetermined NO
FEASIBLE?
2005 CRP Report Summary Final, Report Summary 11 xi 7, Rev 4-Final Page t of 1 Printed 5/12/2006

BLUE RIDGE
PAPER PRODUCTS INC.
Certified Mail
Return Receipt Requested
7099 3220 0007 1919
31 March 2005
Mr. Alan W. Klimek, P.E.
Director
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Chloride Removal Process - Color Reduction Technology Assessment
NPDES Permit No. NC0000272
Blue Ridge Paper Products Inc.
Canton, North Carolina
Dear Mr. Klimek:
Enclosed are two (2) copies of the subject report in accordance with Part I, Condition A.8.1 of
-- the NPDES permit. The original submittal date for the report was December 1, 2004. The
Division of Water Quality extended the due date to April 1, 2005 due to the floods of September
2004 that impacted the Blue Ridge Paper Canton Mill. A copy of the extension letter is attached.
The report documents evaluation of technologies for removal of color from the Chloride
Removal Process (CRP) purge stream. The report includes specific technologies identified in
the NPDES permit as well as other technologies identified by Blue Ridge Paper.
A
At this time, Blue Ridge Paper has not identified any technologies that are technically,
economically or operationally feasible for color reduction in the CRP purge stream.
Please contact us if you have any questions.
Sincerely,
Paul S. Dickens Robert V. Williams
Manager, Environmental Affairs Director, Regulatory Affairs
828-646-6141 828-646-2033
[e-mail] willib@blueridggg ep r.com
-= Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Alan W. Klimek, NCDENR DWQ
31 March 2005, Page 2
Attachment: 10 Nov 2004 Letter from Alan Klimek, NC DENR DWQ
Enclosure: CRP Color Reduction Technology Assessment Report(2 copies)
cc: (w/encl): Dave A. Goodrich
Environmental Supervisor
Point Source Branch
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
D. Keith Haynes
Environmental Specialist
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778
Don Anderson
US Environmental Protection Agency
Office of Water
Office of Science and Technology (4301 T)
1200 Pennsylvania Avenue, NW
Washington,DC 20460
Internal Distribution: a
C. File Water
Engr File—CRP Color Studies
B. Shanahan
S. Single
M. Ferguson
K. Hennessy
D. Brown
P. Geoghegan
R. Medford
C. Dowdle
D. Brown
J. Pryately
L. Cooper
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

1
BLUE RIDGE
PAPER PRODUCTS INC.
Blue Ridge Paper Products Inc.
Canton Mill, Canton, North Carolina
Chloride Removal Process (CRP)
Color Reduction Technology Assessment
A
J
March 2005

March 2005 CRP Color Reduction Technology Report
Page ii
�a
Executive Summary
This report outlines investigations on Chloride Removal Process (CRP) color reduction
technologies that Blue Ridge Paper Products Inc. has conducted to meet the requirements of the
2001 NPDES Permit. Specifically, the report reviews extensive efforts by Blue Ridge Paper to
evaluate and identify a viable color reduction technology for the CRP purge stream. The
investigations included literature reviews, vendor contacts, bench scale tests and field trials. In
addition to the four specific technologies identified in the permit, Blue Ridge Paper looked at
several additional technologies for removing color in the CRP purge stream. The table following
this summary outlines the technologies reviewed and the results.
It is essential in understanding the difficulty of treating the CRP wastewater to recognize that the
CRP purge is a resultant waste flow from a complex system that treats what is, in a typical pulp
mill, a"sewered"wastewater(that is, a discharge to the mill's wastewater treatment system).
The CRP along with the Minerals Removal Process (MRP) at the Blue Ridge Paper Canton Mill
forms the BFRm or"Bleached Filtrate Recovery"process. The BFR process allows the mill to
recycle a large portion of its "pine line"pulp bleaching wastewaters. In a typical pulp mill these
wash waters, which contain"color" from the processed wood pulp, are sent directly to the
wastewater treatment system. Much of the color in the wash waters from a typical pulp mill ends
up in the mill's treated discharge. At Blue Ridge Paper, BFR allows the mill to "reuse"these
wash waters and reduce the total color going to the treatment system. The CRP purge stream by
its very nature is a very concentrated, high chlorides material. A summary of CRP purge stream
characteristics is as follows:
Average CRP purge stream characteristics
Average flow 10 gpm (15,000 gpd)
Total inorganic carbon(TIC, as carbonate) 30,500 mg/L
Total organic carbon(TOC) 6260 mg/L
Absorbable organic halides (AOX) 17.4 mg/L
Sodium,(Na) 110,000 mg/L
Potassium(K) 22,200 mg/L
Conductivity 133,000 mmhos/cm
Chemical Oxygen Demand (COD) 19,100 mg/L
Sulfate (SO4-) 203,000 mg/L
Chloride (Cl-) 26,800 mg/L
Color(true filtered) 41,000 mg/L at 465 nm
pH 10.1
Total suspended solids 4020 mg/L
Total solids 33.5 percent
Total dissolved salts 360,000 mg/L
Temperature at discharge to mill sewer 165 degs F
This is clearly a very"difficult to treat" wastewater. In fact, as noted in many of the trials
documented in this report,just physically handling the CRP purge stream (pumping and placing
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Page iii
{� the wastewater in tanks for treatment) proved challenging. Often the purge stream would "plug"
lines or crystallize as the temperature of the liquid dropped. These characteristics, and the
overall "treatability" issues associated with this wastewater, resulted in the EPA Technology
Review Workgroup (TRW) concluding that CRP treatment had a reduced potential for further
color reduction. The many trials, tests and evaluations outlined in this report confirm that
conclusion.
Investigations of technologies for CRP purge stream color reduction have failed to identify any
viable technology or combination of technologies that meet the NPDES Permit's test of
"technical, economic and operational feasibility." Blue Ridge Paper takes very seriously the
need to further reduce color in the Canton Mill's wastewater discharge and is fully prepared to
continue those efforts. The company took a very comprehensive look at treating the CRP purge
stream and evaluated not only the technologies identified in the permit condition, but many
more. At this juncture, Blue Ridge Paper cannot recommend implementation of any of the tested
technologies. The search for an effective CRP management strategy should continue, and the
company is committed to doing that in conjunction with mill-wide color reduction efforts.
Summary Table
The following table is a summary of the color removal technology assessment for the CRP purge
stream. The table lists both permit-specified and other technologies evaluated.
s
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Page v
Table of Contents
ExecutiveSummary..................................................................................................:.....................ii
..
Summary Table..............................................................................................................................to
Introduction..................................................................................................................................... 1
Purpose........................................................................................................................................ 1
PermitRequirement.................................................................................................................... 1
CRPProcess Overview................................................................................................................... 2
Average CRP purge stream characteristics................................................................................. 5
Permit Specified Technologies ....................................................................................................... 6
LandApplication ........................................................................................................................ 6
Conclusion on Land Application............................................................................................ 7
Commercial Incineration............................................................................................................7
Conclusion on Commercial Incineration................................................................................ 8
Coagulation/Precipitation........................................................................................................... 8
RMTStudy.............................................................................................................................. 9
Conclusion on Coagulation/Precipitation........................................................................... 10
Solidification for Land Disposal............................................................................................... 10
VOPAK................................................................................................................................. 10
OnyxEnvironmental............................................................................................................. 11
Evaporation........................................................................................................................... 11
Conclusion on Solidification................................................................................................. 12
Other Technologies—Bleaching/Oxidation.................................................................................. 12
Ozonation.............................................................................................................................. 12
Clozone(Ozone and Chlorine Dioxide)—2002/2003 ........................................................ 12
C1O2 Bleaching Trial - 2004................................................................................................. 14
Blue Ridge CRP Bleaching Trial—2004/2005....................................................................14
Conclusion on CRP Bleaching Technology......................................................................... 15
Other Technologies - CRP on Lime Precoat Filter....................................................................... 16
Conclusion............................................................................................................................ 16
Other Technologies—Proprietary Third Party.............................................................................. 16
Wet Air Oxidation and PACT- 2002................................................................................... 17
High Temperature Peroxide Oxidation- 2002...................................................................... 17
FilterPapers - 2002............................................................................................................... 17
Proprietary Oxidation Technology- 2002............................................................................ 18
Ultra/Nano Filtration—2002............................................................................................... 18
Summary/Conclusions................................................................................................................ 18
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March 2005 CRP Color Reduction Technology Report
Page I
Introduction
F Purpose
This report outlines investigations on CRP color reduction technologies that Blue Ridge Paper
Products Inc.has conducted to meet the requirements of the 2001 NPDES Permit. The original
due date for the report was December 1, 2004. However, Blue Ridge Paper and the Town of
Canton, North Carolina experienced back-to-back historic floods during September 2004. The
floods disrupted completion of CRP color investigation work. The Blue Ridge Paper Canton
Mill was down for 3 weeks during September 2004 because of the flooding. Work to fully
restore wastewater treatment operations and wastewater laboratory capability took the balance of
2004 to complete. In October 2004, Blue Ridge Paper requested an extension of the due date for
the CRP color reduction technologies report until April 1, 2005. The Division of Water Quality
(DWQ) of the North Carolina Department of Environment and Natural Resources (DENR)
approved the extension request on November 10, 2004.
Permit Requirement
The requirement of the 2001 NPDES permit for this study is specified in Section A.(8.),
Paragraph 9:
"By December 1, 2004*, the permittee shall evaluate color reduction technologies
associated with the Chloride Removal Process (CRP) wastestream. The CRP analysis
shall concentrate on the technical, economic and operational feasibility of implementing
the applicable technologies on all or a portion of the purge stream. The report shall
identify specific economic and implementation issues associated with the improvements.
The report shall also project the expected additional color reduction for each technology
evaluated and maximum color reduction possible using the identified technologies.
Though not limited to the following, the report shall include an analysis of the land
application of the high chloride wastewater, commercial incineration,
coagulant/precipitation technologies, and solidification for land disposal. The Division
of Water Quality (in consultation with the Technology Review Workgroup)shall evaluate
the feasibility of implementing identified technologies forfurther color reduction and
shall submit to the NDPES committee by February 1, 2005**the DWQ's
recommendations regarding color reductions associated with the treatment of the CRP
wastestream.
If during the course of this evaluation, Blue Ridge Paper identifies a technical, economic,
and operationally feasible color reduction technology that can be implemented for
treatment of the CRP wastestream, the permitte may request that the Technology Review
Workgroup review this technology for implementation at the Canton mill. If the
Technology Review Workgroup concurs that the identified technology is suitable for the
Canton mill and that the color reductions achievable are adequate, the mill's obligation
to research additional technologies will be waived after formal notification from Blue
Ridge Paper that the identified technology will be installed and placed into operation.
.` This notification shall include language indicating the permittee's commitment to the
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March 2005 CRP Color Reduction Technology Report
Page 2
implementation of the technology, along with a schedule for implementation. The
Division of Water Quality will notify the permittee in writing that the proposed
implementation schedule is acceptable."
Due date was extended to April 1,2005 due to September 2004 floods; see
10 Nov 2004 letter from Alan Klimek,NC DENR DWQ
** Since the submission date was extended by four months, the DWQ's submission
to the NPDES committee extends by four months to June 1,2005.
CRP Process Overview
The Bleach Filtrate Recycling(BFRT°"t)process is a pollution prevention technology unique to
Blue Ridge Paper Products' Canton Mill. It was originally implemented as a full-scale trial
demonstration project in 1995. Today, it has been converted to an integral part of the operations
at the Canton Mill. The BFR process is an important element of Blue Ridge Paper's
management of wastewater effluent color.
Recycling the bleaching filtrates has not been successful in the past at other mills because some
of the waste minerals, such as sodium,potassium, calcium, manganese, and magnesium, as well
as chlorides, interfere with the operation of the pulping, bleaching, and recovery operations.
Wherever these materials accumulate in the processes, they can impair process operation and
cause excessive corrosion damage to the process equipment. Another difficulty in recycling
bleaching wastes is that the dissolved lignin component can consume additional amounts of
bleaching chemicals, increasing bleaching cost and causing quality problems with final bleached
pulp and paper products.
The basic concept of BFRTM is to recycle the bleaching filtrates through the pulp-washing system
in the same manner that pulping and oxygen delignification filtrates are recycled. Wood
minerals and salts produced in the bleaching process are removed at strategic locations in the
bleach plant and in the chemical recovery process. This allows the bleached kraft pulp mill to
reduce discharge of colored effluents to mill sewers, reduce water usage in pulp bleaching and
washing operations, and reduce other chemical discharges from the mill.
The BFRTM process at Blue Ridge Paper recycles filtrates from the pine bleach plant only. There
are two distinct components of bleach filtrate recycling: the Minerals Removal Process (MRP),
associated with the pine bleach plant, and the Chloride Removal Process (CRP), associated with
the chemical recovery area. The MRP removes the calcium, magnesium, manganese, and other
hard water elements from the bleaching waste. The CRP removes the sodium chloride and
potassium from the recycled chemicals before they enter the recovery furnaces.
The Chloride Removal Process (CRP) treats a portion of the chemical ash (produced by burning
the lignin waste in the recovery furnaces)removing chloride and potassium. This ash, which is
later converted into active cooking chemicals, is where the chloride and potassium compounds
accumulate. A schematic diagram of the CRP process is presented in the following figure.
March 2005 CRP Report Final.doc

March 205 CRP Color Reduction Technology Report
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March 2005 CRP Color Reduction Technology Report
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In the chemical recovery cycle, reclaimed spent cooking chemicals and lignin waste, known as
black liquor, are concentrated by an evaporation process. The concentrated black liquor is
burned as a fuel in the recovery furnaces to generate steam and electric power. The lignin and
other organic wood wastes burn off in the recovery furnaces. The ash, or smelt, remaining after
combustion contains the spent cooking chemicals, primarily sodium sulfate and sodium
carbonate. The smelt is removed from the bottom of the furnaces and dissolved in water to form
green liquor. The green liquor is chemically activated in the causticizing area. The reactivated
cooking chemical,known as white liquor, is sent to the pulp mill to be reused for cooking pulp.
Some of the ash that is produced in burning black liquor is carried out of the recovery furnace by
the flue gases produced by combustion. The Canton Mill has direct contact cyclone evaporators
on the recovery furnaces. These cyclones contact the flue gas with the incoming black liquor to
evaporate water from the liquor before combustion. Some of the lignin and other color material
from black liquor in the cyclones may also be carried out of the recovery furnace with fly ash.
This fly ash must be removed from the recovery furnace flue gas before the gases are exhausted
to the atmosphere. The flue gases pass through large wet-bottom, electrostatic precipitators that
remove fly ash from the gases.
Because of bleach filtrate recycling, the weak black liquor received by the chemical recovery
area from brown stock washing contains a higher percentage of sodium chloride salt than it
would in the conventional pulp bleaching process without filtrate recycling. The higher salt
content must be removed from the process to prevent corrosion of the recovery furnace
evaporator and boiler tubes and disruption of the recovery process.
The CRP takes advantage of the greater solubility of sodium chloride and potassium compared to
sodium sulfate. In a conventional chemical recovery process, fly ash from the electrostatic
precipitators is returned directly to black liquor to recover salts. In the CRP, fly ash from the
precipitators is dissolved in water instead of black liquor in the bottom of the precipitators. The
flow from the precipitators, now a salt solution instead of black liquor, is directed to a series of
three CRP evaporators instead of directly into the recovery furnaces.
The salt solution is introduced into the CRP evaporators with steam to evaporate a portion of the
water in the salt solution. Upon completion of the third evaporation stage, enough water has
been evaporated from the solution to cause the sodium sulfate to precipitate as salt crystals. The
sodium chloride and potassium remain in solution. A portion of the salt cake and salt solution is
continually pumped from the final evaporator stage to a filter system, which separates the
crystallized sodium sulfate"salt cake" from the liquid salt solution.
The sodium sulfate salt cake from CRP is mixed with heavy black liquor and returned to the
recovery furnace for chemical recovery. A portion of the salt solution containing concentrated
sodium chloride and potassium is also returned, and a portion is "purged" to control the
concentration and buildup of chloride and potassium in the chemical recovery and pulp cooking
liquors. The CRP purge stream is primarily salty water, but also contains a significant
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Page 5
concentration of color bodies. The CRP purge stream is the focus of the NPDES permit
requirement and of this report.
The technical feasibility of permit-specified technologies depends in large part on the chemical
composition and physical properties of the CRP purge stream. Average characteristics of the
CRP purge based on long-term monitoring by Blue Ridge Paper are listed below. The
temperature of the purge stream at the point of discharge to the mill sewer is about 74 degrees
Celsius (165 deg Fahrenheit). The design purge flow rate is 10 gpm or about 15,000 gallons per
day. This volume is 0.06 percent of the mill's average daily wastewater flow of 25 mgd. The
primary control method for chlorides and potassium in the chemical recovery cycle is to vary
CRP purge rate. As a result, the daily CRP purge stream flow can vary from the target of 10
gpm.
The CRP purge stream is best described as brine. Samples,of the purge stream will crystallize at
varying temperature depending on salt concentration. Sometimes the sample will remain in
liquid form when cooled to room temperature and at other times the sample will crystallize after
it has cooled several degrees. Crystallized samples will re-liquefy when subjected to shear. The
CRP purge stream is diluted as it is added to the mill sewer to prevent crystallization and
plugging. The mill experiences occasional operating problems with plugging in the CRP process
from crystallization. -
Average CRP purge stream characteristics
Average flow 10 gpm (15,000 gpd)
Total inorganic carbon (TIC, as carbonate) 30,500 mg/L
Total organic carbon(TOC) 6260 mg/L
Absorbable organic halides (AOX) 17.4 mg/L
Sodium(Na) 110,000 mg/L
Potassium(K) 22,200 mg/L
Conductivity 133,000 mmhos/cm
Chemical Oxygen Demand(COD) 19,100 mg/L
Sulfate (SO4-) 203,000 mg/L
Chloride(CY) 26,800 mg/L
Color (true filtered) 41,000 mg/L at 465 nm
pH 10.1
Total suspended solids 4020 mg/L
Total solids 33.5 percent
Total dissolved salts 360,000 mg/L
Temperature at discharge to mill sewer 165 degs F
The potential contribution of the CRP purge stream to primary influent and secondary effluent
color was documented in the 2001 Color Removal Technology Removal Assessment Report:
Primary influent color attributed to CRP purge stream - 5000 lbs/day
Secondary effluent color attributed to CRP purge stream <2300 lbs/day(estimated)
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The daily CRP purge stream flow rate can vary from 0 to 15 gpm(0 to 21,600 gpd) depending on
operating conditions and maintenance activities. The color contributions above are annual
average values based on the design CRP purge stream rate of 10 gpm(15,000 gpd). The
secondary effluent color attributed to the CRP purge stream is based on removal efficiency of
black liquor color in the Canton Mill's activated sludge treatment system. Color in the CRP
purge stream originates from black liquor in the recovery furnaces and is assumed to behave
similarly to black liquor wastewater treatment.
The average secondary effluent discharge for the Blue Ridge Paper Canton mill in 2004 was
41,4631bs/day. The 2300 lbs/day contribution to secondary effluent color from the CRP purge
stream is 5.6 percent of the 2004 average color and is approximately t/4 of the standard deviation
of the 2004 secondary effluent color. The small contribution of the CRP purge stream to
secondary effluent color creates problems confirming the effectiveness of technologies to
remove color in the CRP purge stream. It may not be possible to statistically confirm that
reductions in CRP purge stream color result in equivalent reductions in secondary effluent color.
Permit Specified Technologies
The 2001 NPDES permit specifies that Blue Ridge Paper evaluate the technical, economic and
operational feasibility of several specific technologies for treatment of the CRP purge stream
including land application, commercial incineration, coagulation/precipitation and solidification
for land disposal.
Land Application
Land application refers to the use of liquid wastewaters at agronomic rates for irrigation,
treatment and to recover beneficial nutrients. Microbes in the irrigated soil and vegetation
provide treatment. The liquid wastewater can be applied to forage grasses, food crops or
woodlands. Land application avoids direct discharge of wastewater to streams. The land-
applied wastewater moves through the soil and vegetation system, is "taken up"to a limited
degree by vegetation, is absorbed and "filtered"by the soil, is acted upon by microorganisms
present in the soil, and evaporates to some degree during periods of low humidity and sunlight.
The remaining"treated" water from land application is then indirectly discharged to streams
through surface runoff and groundwater. Treated municipal wastewater and some treated and
even untreated industrial wastewaters have been successfully land applied for many years.
Factors limiting the land application of wastewater are evaporation, accumulation of metals and
other pollutants in soils and vegetation, and the sensitivity of the irrigated vegetation to salts. Of
these factors, salt content is the limiting factor applicable to potential land application of the CRP
purge stream.
Blue Ridge Paper researched general design criteria for land application of wastewater. Principle
sources were Metcalf and Eddy, Wastewater Engineering, Third Edition and several state
agricultural extension service publications on the Web related to land application of organic
wastes. To be suitable for irrigation without restriction„wastewaters should have a chloride
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Page 7
_.` content of less than 100 mg/L. Wastewaters with chloride contents greater than 350 mg/L are
not suited for land application to due vegetative effects and changes to the percolation
characteristics of the soil. Similarly, the conductivity of wastewaters for land application should
be less than 35,000 mmhos/cm and the total dissolved salt concentration should be less than 2000
mg/L. With a chloride content of 26,800 mg/L, a conductivity of 133,000 mmhos/cm and a total
dissolved salts content of 360,000 mg/L, the CRP purge steam cannot be land applied without
significant dilution.
Based on chloride content, the CRP purge would have to be diluted by a ratio of at least 270:1 to
be land applied at agronomic rates without restriction. With dilution water, the daily volume for
land application would be 4,050,000 gallons per day. At an irrigation rate of 48 inches per year
(typical for southeastern forests under wastewater irrigation), a total of 1135 acres of suitable
land would be required. A 24-inch diameter pipeline to irrigation site would be required.
Assuming land was available, the design flow rate for transfer pumps, irrigation pumps and land
application equipment would be a minimum of 2800 gallons per minute. Land application
systems also require wet weather storage typically sized to hold 30 to 60 days of wastewater
production. A reservoir of 120 to 240 million gallons storage capacity would be required.
Conclusion of Land Application
Because of chloride salt content and associated technical and logistical issues, land application is
not a feasible technology for treatment and disposal of the CRP purge stream.
Commercial Incineration
Commercial incineration refers to off-site shipment of industrial waste for incineration in lime
kilns or dedicated waste incinerators. There are three reasons to incinerate an industrial waste:
• Off-set fuel use by recovering the heat content of the waste
• Destroy organic components in the waste
• Thermally recover valuable components of the waste.
The CRP purge stream originates from recovery furnace fly ash. It has essentially no heat value.
It has no constituents at concentrations economically attractive for recovery. The high chloride
content makes the purge stream very corrosive under combustion conditions. Incineration is not
an appropriate technology for the CRP purge stream.
To verify that incineration was not a viable option, Blue Ridge Paper requested a waste approval
and quote from Onyx Environmental for incineration disposal of the CRP purge stream. Onyx is
a commercial hazardous waste transportation and disposal company who matches industrial
wastes with appropriate recovery, recycling or disposal options based on technical, regulatory
and economic considerations. Onyx, in their own evaluation, confirmed that incineration is not a
technically appropriate or economically viable disposal option for the CRP purge stream. The
high chloride content and zero heat value of the purge stream would require blending with a
large volume of other more suitable waste before incineration. Quoted cost in December 2004
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for commercial incineration disposal of the CRP purge stream is $0.46 per lb of liquid CRP
purge excluding transportation. The quote for off-site transportation to the incineration facility
in a 5000-gallon tanker is $3635 per load including tanker cleaning, rental and fuel surcharges.
Based on the Onyx Environmental quote, 15,000 gallons per day of CRP purge and 5000 gallons
per tanker load, the annual estimated cost for commercial incineration disposal of the CRP purge
stream is:
Incineration: 15,000 gpd x 8.51bs /gallon x $0.46/lb x 360 days/year = $21,114,000
Transportation: 3 loads/day x $3635/load x 360 days/year = $3,925,800
Total annual cost in excess of$25 million.
Off-site hauling of the CRP purge stream will require a truck loading facility and heated storage
tank. The estimated capital cost of a truck loading and storage facility for the CRP purge stream
is in excess of$150,000.
Conclusion on Commercial Incineration
Based on both physical and chemical characteristics and on commercial quotes, incineration of
the CRP purge stream is not an economically or operationally feasible technology.
Coagulation/Precipitation
Coagulation and precipitation is a method of removing color bodies from wastewater by adding a
flocculating chemical. The flocculating chemical works in one of two ways:
• change the zeta potential (electrostatic charge) of the color body particles allowing the
particles to agglomerate into larger particles that will settle out.
• form a large chemical precipitant floc that"sweeps" the color body particles out of
solution as the floc settles.
Any coagulation and precipitation technology for color removal generates sludge that requires
disposal as a solid waste. Sweep floc precipitation generates large volumes of sludge relative to
the volume of color body particles removed.
The 2001 Color Removal Technology Assessment Report examined secondary effluent color
removal by sweep floc coagulation and precipitation with alum and with lime. These chemicals
worked on the relatively dilute secondary effluent color. However, because of the volume of
secondary effluent flow, coagulation and precipitation technology was capital intensive with high
operating costs for chemicals and sludge disposal. The 2001 report concluded that this
technology was not appropriate for secondary effluent color removal.
i
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` The focus of this report is color removal treatment of the concentrated CRP purge'stream. Color
in the CRP purge stream originates from lignin in the black liquor ash. Coagulation and
precipitation of color in the CRP purge stream is removal of dissolved lignin in the liquid CRP
purge stream. The high dissolved salt content and high alkalinity of the CRP purge can interfere
with coagulation chemicals and the formation of floc.
RMT Study
Blue Ridge Paper retained RMT Consultants to perform bench scale screening trials of different
chemical coagulations for treatment of the concentrated CRP purge stream. The coagulants
tested were lime, aluminum salts, iron salts and polyamine. The RMT bench scale tests were
completed during January 2005.
The color removal target for the RMT study was 85%. That is, coagulation technologies were
not considered technically viable unless they could achieve an 85% or greater removal of color
from the concentrated CRP purge stream. The basis of 85% removal is effect on secondary
effluent color. A large reduction in CRP color will be necessary to see any corresponding
reduction in secondary effluent color. The 85% target equates to a potential 2000 lbs/day
removal of secondary effluent color attributed to the CRP purge stream.
None of the coagulation chemicals tried—lime, alum, ferric sulfate and polyamine—met the
r 85% color removal goal. Lime and alum are not technically feasible coagulants for the
concentrated CRP stream. Massive doses of chemical are required to achieve any color
reduction and the resulting sludge did not settle. Highest color removal by chemical coagulation
and precipitation was 77%. This was achieved with a combination of ferric sulfate and
polyamine. However, to obtain a floc, settling and color removal, the concentrated CRP purge
stream must first be acidified to neutral pH. Polyamine addition alone after pH adjustment
achieved only 66% color removal. Polyamine treatment of the concentrated CRP purge stream is
not desirable because the high doses required can potentially cause problems with wastewater
effluent toxicity.
During the bench scale trials,RMT collected 5-gallon grab samples of the CRP purge stream for
testing over a period of two days. RMT noted a large variability in the color concentration and
physical characteristics of these grab samples. The CRP color concentration in grab samples
doubled between the first and second day of testing. RMT also observed an increase in CRP
color during the day as the buckets of CRP sample sat in the lab between tests. Because of this
variability, chemical dose process control for coagulation/precipitation of the CRP purge may
be difficult. Color removal effectiveness in a full-scale system would vary. There is no
indication that color removal by coagulation/precipitation of the CRP purge stream will result
in an equivalent reduction of secondary effluent color.
RMT prepared chemical cost estimates for acidification of the concentrated CRP purge stream
followed by chemical coagulation and precipitation with ferric sulfate and polyamine. The
estimate assumes the design purge rate of 10 gpm. Chemical prices are based on commercial
quotes for bulk quantities.
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March 2005 CRP Color Reduction Technology Report
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Projected annual chemical costs are:
Acid $175,000
Ferric Sulfate $ 28,000
Polyamine 77,000
Total chemicals $280,000
The RMT study did not include capital equipment or sludge disposal costs. Blue Ridge Paper
developed these cost estimates using EPA cost curves and other sources. The capital cost is in
excess of more than$1.7 million. This does not include the cost of special materials that may be
required to handle the high chloride content of the CRP purge stream. Estimated sludge
generation is 6.1 tons per ton of color removed. The sludge disposal cost estimate is in excess of
$90,000 per year.
Conclusion on Coagulation/Precipitation
Coagulation/precipitation is an infeasible technology for the CRP purge stream. The large
quantities of chemicals required and large sludge volume relative to color removed, makes the
use of this technology unrealistic. There is no indication that color removal by coagulation/
precipitation of the CRP purge stream will result in an equivalent reduction of secondary effluent
color. The use of polyamine may have adverse effects on secondary effluent toxicity.
Based on these factors, coagulation/precipitation of color in the CRP purge stream is not a
technically, economically or operationally feasible technology.
Solidification for Land Disposal
Solidification for land disposal refers to treating liquid waste materials with various pozzolanic
materials and/or heat to form a solid (non-liquid) waste suitable for burial in a commercial
landfill or dedicated land disposal site.
VOPAK
Vopak Industrial Services is a provider of off-site non-hazardous waste treatment and disposal,
located in Mauldin, South Carolina. VOPAK evaluated the CRP purge stream in 2002 for
solidification and landfill disposal. Disposal through VOPAK would consist of using 5,000
gallon tankers to transport the CRP purge to the treatment facility, eliminating 100% of the CRP
color from Blue Ridge Paper's wastewater. At 5,000 gallons per tanker, at least 3 tankers per
day, seven days per week, and 52 weeks per year, would be required. The cost for this disposal
would be$2.6 million- $2.7 million per year. This estimate does not include any of the capital
costs, nor operating costs that Blue Ridge would incur in implementing this technology.
f
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Page 11
Onyx Environmental
To verify that off-site solidification and landfill disposal was not a viable option, Blue Ridge
Paper requested a waste approval and quote from Onyx Environmental for off-site solidification
and landfill disposal of the CRP purge stream. Onyx is a commercial hazardous waste
transportation and disposal company who matches industrial wastes with appropriate recovery,
recycling or disposal options based on technical,regulatory and economic considerations. Onyx
confirmed that solidification is not a technically appropriate or economically viable disposal
option for the CRP purge stream. Quoted cost in December 2004 for commercial solidification
and landfill disposal of the CRP purge stream is $115 per ton of liquid CRP purge excluding
transportation. The quote for off-site transportation to the land disposal facility in Mauldin,
South Carolina in a 5000-gallon tanker is $855 per load including tanker cleaning, rental and fuel
surcharges.
Based on the Onyx Environmental quote, 15,000 gallons per day of CRP purge and 5000 gallons
per tanker load, the annual estimated cost for commercial off-site solidification and landfill
disposal of the CRP purge stream is:
Solidification: 15,000 gpd x 8.51bs/gallon x 1 ton/2000 lbs x$115/ton x 360 days/year
_ $2,639,250
Transportation: 3 loads/day x $855/load x 360 days/year = $923,400
Total annual cost in excess of$3.6 million.
Off-site hauling of the CRP purge stream will require a truck loading facility and heated storage
tank. The estimated capital cost of a truck loading and storage facility for the CRP purge stream
is in excess of$150,000
Evaporation
As part of the 2001 Color Removal Technology Assessment, Blue Ridge Paper evaluated the
feasibility and cost of treating the CRP purge stream through crystallization (i.e., solidification)
and disposal at the landfill. Basically, this technology would add one additional crystalizer,
tanks, pumps, and a plate-and-frame filter press to the CRP process. The current brine purge
stream would be further concentrated to form a crystalline solid, which would be sent to the
landfill. This would remove the entire CRP stream form the WTP influent.
The estimated capital cost for this crystallization system was $11,151,000 in January 2001. The
annual operating cost associated with the system was estimated to be$2,137,000 per year. These
estimates indicate that crystallization would not be a cost-effective option for treatment of the
CRP stream. Additional details of this process and cost estimates were included in the 2001
Color Removal Technology Assessment Report.
V
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March 2005 CRP Color Reduction Technology Report
Page 12
-ti Conclusion on Solidification
Blue Ridge Paper investigated commercially available technologies and services for
solidification and landfill disposal of the CRP purge stream. These have the advantage of
completely removing CRP purge stream color from the mill wastewater plant. However, none of
the solidification options are economically or operationally feasible for treating color in the CRP
purge stream.
Other Technologies —Bleaching/Oxidation
i
Bleaching involves use of oxidants to destroy lignin and related color bodies in wastewater.
Bleaching has the potential advantage of removing color without generating a sludge that
requires landfill disposal. At a conceptual level, bleaching appeared to be a promising
technology for cost-effective treatment of the CRP purge stream. Blue Ridge Paper investigated
bleaching of the CRP purge stream with a series of bench and field trial tests.
Ozonation
Laboratory tests were conducted during the summer of 2003 on samples of the CRP purge
stream. In the laboratory, pilot-scale batch reactors were able to achieve between 68% to 92%
decolorization of the CRP purge stream at ozone dose rates of 2.8 to 6.8 grams/liter. The
reaction time was 3 hours. A byproduct of ozone treatment of the CRP purge was foam. It is
important to note that the lab reactor foamed over during the pilot scale trial of ozone
dechlorization of CRP wastewater. The foaming was so severe it was concluded that treatment
of the concentrated CRP purge stream was not technically feasible. Dilution was necessary for
successful treatment, which significantly increases the size and operating cost of the treatment
equipment required.
Preliminary engineering estimates were prepared based on laboratory pilot-scale trials for a CRP
purge treatment system that mixed and diluted the CRP purge with other wastewaters from the
Canton Mill. The estimated capital cost was in excess of$2.7 million USD. Estimated operating
costs including power and oxygen were in excess of$2 million USD per year.
The laboratory tests represent high rate ozone treatment, which requires a liquid oxygen ozone
generator and a moderately pressurized reaction vessel with off-gas controls. The ozone
generator controls and safety systems are complex. Foaming that occurs when treating the
concentrated CRP purge stream with high rate ozone makes this technology infeasible for full-
scale application.
Clozone(Ozone and Chlorine Dioxide)—2002/2003
Blue Ridge Paper investigated bleaching technology during fall of 2002 and winter of 2003. A
proprietary package system was offered for point-of-use generation of moderate quantities of
chlorine dioxide(C102) and ozone for bleaching and decolorization of colored materials. The
name of the proprietary chlorine dioxide process is "TST"-and the application of the ozone
March 2005 CRP Report Final.doc

March 2005 CRP Color Reduction Technology Report
Page 13
} technology "Clozone". The raw materials associated with the "TST" technology are sodium
chlorate, hydrogen peroxide, and sulfuric acid. The "Clozone" technology is proprietary only in
the point of application of the ozone. Ozone in the system is generated with electricity from
ambient air.
A bench-scale study of Clozone treatment of the CRP purge stream was performed in December
of 2002 with favorable results. A four-day field trial of the TST/Clozone process was then
conducted in February 2003. The field trial had two goals:
• Determine effectiveness of Clozone for CRP purge stream bleaching at design purge
rates.
• Determine optimum C102 and Ozone concentrations for extended field trials.
The field trial equipment included a 1000-gallon plastic tank for mixing and reacting Clozone
with the CRP purge stream. The Clozone mix water flow rate was 40 gpm and the CRP purge
rate was 10 gpm. Detention time in the mixing tank was approximately 20 minutes. The field
trial involved a series of 2-hr continuous flow bleaching tests at different C102 and ozone mass
dose rates and mixing tank concentrations. Bleaching chemical dose rates and concentrations
would be adjusted and allowed to run for 2 hours to reach steady state conditions in the mixing
tank. Color samples were then collected from the mixing tank influent and effluent. The trial
was therefore a series of short duration tests. There was no attempt to relate color reductions in
the CRP purge stream to secondary effluent color.
The technology removed color from the CRP purge stream by an average of 93% over the 4-day
trial. However, bleaching effectiveness was inconsistent. The dose rate of C102 ranged from
750 mg/L to,1700 m/L and ozone input ranged from 0 to 90 lbs/day. Some two-hr trials
involved chlorine dioxide alone without ozone. The color removal without ozone averaged 89
percent. Foaming and overflow of mix tank was observed during the trial and became a
problem. Off gassing of C102 from the mixing tank at C102 concentrations above 1200 mg/L in
the Clozone mix water was also encountered.
Operating and Clozone equipment cost estimates were provided based on the 4-day field trial.
The estimated operating cost, including chemicals and electricity, is $615,000 per year. The
quoted purchase price of the Clozone generator was $370,000. A complete Clozone equipment
installation for CRP bleaching would require a mixing tank, chemical storage tanks, CRP
transfer equipment, an off-gas scrubber and process controls. The estimated capital cost is in
excess of$1.8 million USD.
The Clozone trial indicated that chlorine dioxide alone could be effective for color reduction of
the CRP purge stream. The extra complexity, safety issues and cost of Clozone compared to
C102 alone are not technically or operationally justified. Clozone is an infeasible technology
for color reduction in CRP purge stream.
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March 2005 CRP Color Reduction Technology Report
Page 14
C1O2 Bleaching Trial - 2004
Blue Ridge Paper investigated an additional bleaching technology that involved only the use of
C1O2. A 30-day trial of CRP bleaching with C1O2 was conducted. The trial had two goals:
• Determine optimum dose rates of C1O2 for CRP purge stream bleaching at design purge
rates.
• Run full-scale CRP bleaching for a 30-day period to establish a relationship between
color reductions in the CRP purge stream and reduction in secondary effluent color.
The 30-day trial was planned to start in July 2004. However, a series of problems with
equipment, chemical contamination, and safety issues prevented any extended CRP bleaching
runs during July. The trial resumed in early August and ran for several 1 to 2 day periods
between failures of the C1O2 generator. Analysis of color samples during early August showed
little, if any, effective bleaching of the CRP.
Changes were made to improve efficiency of the C1O2 generator and a 4—day continuous CRP
bleaching trial was completed in mid-August. Color removal in the CRP purge stream during
this 4-day period was 75 to 90 percent. This was the longest continuous successful run,but it
was not long enough to see any color effect on the mill's secondary effluent. Variability in the
CRP purge stream and problems with the C1O2 generator caused unreliable bleaching
effectiveness.
Because of reliability problems with the C1O2 generator, Blue Ridge Paper shut down the trial in
late August 2004 and made arrangements with another vendor to provide C1O2 equipment. The
CRP bleaching trial was to resume in late September following the scheduled semi-annual mill
outage in the middle of that month. Unfortunately, back-to-back historic floods hit the Blue
Ridge Paper Canton Mill during September 2004. The flood disruptions required postponing
restart of CRP bleaching trials until December 2004.
Blue Ridge CRP Bleaching Trial—2004/2005
Blue Ridge Paper rented another C1O2 generator and set up an extended bleaching trial using the
mix tank from the earlier field trials. The trial started in December 2004 and was run entirely by
Blue Ridge Paper personnel. The trial was suspended during the Christmas holiday and resumed
in January 2005. The Blue Ridge CRP Bleaching Trial had several goals:
• Understand the process variables and dynamics involved in CRP bleaching with C1O2.
• Develop a process for possible full-scale application.
• Run full-scale CRP bleaching for an extended period to establish a relationship between
color reductions in the CRP purge stream and reduction in secondary effluent color.
It took most of December and the first half of January 2005 to tune the C1O2 generator and dose
rate to obtain consistent bleaching. A static mixer was added to the inlet of the mixing tank to
improve contact of C1O2 with the CRP purge stream. There were some problems with foaming
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March 2005 CRP Color Reduction Technology Report `
Page 15
and overflow of the mix tank. Off gassing of C1O2 was controlled by limiting C1O2
concentration in the mix water to 1.7 g/L or less. Variability in the CRP purge stream caused hit
and miss bleaching effectiveness. The CRP bleaching process was not easy to control. A 1 to 4
dilution of the concentrated CRP purge stream with mix water was necessary for effective
bleaching and to avoid handling problems with plugging of CRP transfer lines and equipment.
CRP transfer lines had to be frequently flushed.
The C1O2 generator was reliable and allowed a 20-day extended CRP bleaching run from
January 24 until February 12, 2005. Color reduction in the CRP purge stream during the Blue
Ridge CRP Bleaching Trial ranged from 39% to 82%. The color reduction was strongly
influenced by CRP purge rate and the capacity of the generator. At a steady CRP purge rate of 8
gpm, the color reduction averaged 79%.
Color in the 5B sewer was monitored during the Blue Ridge CRP Bleaching Trial. The CRP
purge stream mixes with the 5B sewer prior to wastewater treatment. Color reduction in the 5B
sewer averaged 45% and was statistically significant. However, there was no corresponding
statistically significant reduction in secondary effluent color during the Blue Ridge CRP
Bleaching trial.
Conclusion on CRP Bleaching Technology
Bleaching of the CRP purge stream for color proved difficult to control in extended field trials.
` . Bleaching effectiveness was unreliable due to variability in the CRP purge stream. None of the
CRP bleaching trials achieved a consistent color removal. Color removal at time during
extended trials was 50% or less. There is no indication that color reduction in the CRP purge
stream from C1O2 bleaching resulted in an equivalent reduction in secondary effluent color.
Based on field trials and C1O2 from the existing bulk C1O2 system at the Blue Ridge Paper
Canton Mill, the annual chemical cost for CRP bleaching would be$145,000 per year. The
estimated capital cost including mix tank, C1O2 transfer piping, an off-gas scrubber and controls
is in excess of$1.2 million.
Although initially promising, bleaching proved to be an infeasible technology for the CRP purge
stream. Based on full-scale field trials, the level of effort and quantity of chemical necessary to
sustain a C1O2 bleaching effect on the CRP purge stream do not render any significant reduction
in secondary effluent color. Bleaching is not a technically, economically or operationally
feasible technology for color reduction in the CRP purge stream.
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March 2005 CRP Color Reduction Technology Report
Page 16
t
Other Technologies - CRP on Lime Precoat Filter
During summer of 2004, Blue Ridge Paper conducted a bench scale test of filtering the CRP
purge stream through lime mud from the precoat filter. This idea to use lime mud as a filter
media for the CRP purge originated from a process supervisor in the Recovery area of the mill.
This process, if successful, would largely remove the CRP purge stream from the mill sewers.
Only filtrate would be sewered. The CRP purge solids including color would be hauled to the
mill's landfill facility for disposal.
Results from the lab experiment for CRP filtering though lime mud looked promising. A short
duration trial of the idea was scheduled to take place in September 2004. Unfortunately, the
Canton Mill was hit by back-to-back historic floods during September. The CRP on lime precoat
filter trial was postponed until 2005 following completion of CRP bleaching trial work.
Three 4-hour and one 36-hour trials of CRP filtering through lime mud on the lime precoat filter
were conducted in February and March 2005. The full CRP purge stream at an average rate of
10 gpm was applied to the No. 6 precoat filter during each trial. Lime mud and filtrate samples
were collected and analyzed for color removal and dissolved salts. Color reduction results for
the CRP purge stream were mixed. Average color removal was 77 percent, but ranged from 34
to 94 percent. Because the CRP on Lime Precoat Filter trials were short duration, there was no
attempt to relate color reductions in the CRP purge stream to secondary effluent color.
Conclusion of CRP on Lime Precoat Filter
Based on field trial results to date, the idea to filter CRP through lime mud is an unproven
technology for color reduction. Several equipment and technical issues remain to be quantified
including:
• effect of high chlorides in the CRP purge on lime mud precoat filter equipment
• storage of CRP during periods when the No. 6 lime precoat filter is down(about 20% of
mill operating time)
• release of CRP color from lime mud in the landfill and possible return of this color to the
mill wastewater plant in landfill leachate.
The technical, economic and operational feasibility of treating the CRP purge stream on the lime
precoat filter is undetermined. More trial work is needed to reach a definite conclusion.
Other Technologies — Proprietary Third Party
Blue Ridge Paper Products contacted various waste treatment technology vendors to investigate
options for color treatment of the CRP purge stream. These are discussed below. Some of the
vendors conducted bench scale tests. Others used information on the physical and chemical
characteristics of the CRP purge stream to make an evaluation of technical and economic
viability.
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March 2005 CRP Color Reduction Technology Report
Page 17
None of the proprietary technologies evaluated are technically, economically or operationally
feasible for color removal from the CRP purge stream.
Wet Air Oxidation and PACT- 2002
Blue Ridge Paper investigated a patented wet air oxidation and powered activated carbon
treatment or PACT technology. This technology is typically used on high strength organic waste
streams. In this technology, powered activated carbon- or PAC - is added to the waste stream to
absorb waste constituents of concern. The PAC is then settled and regenerated in a wet air
oxidation unit. During regeneration, organics absorbed on the PAC are destroyed or broken
apart so they can be more easily removed in subsequent biological wastewater treatment steps.
The wet air oxidation technology can be directly applied to concentrated waste streams. In this
application, PAC is not used. Organics in the high strength liquid waste are directly oxidized.
It seemed that the technology might be applicable for the removal and oxidation of color
constituents in the CRP purge stream. However, there were no existing similar treatment
installations for comparison and the ability to conduct bench scale tests was non-existent. The
wet air oxidation technology involves moderately high temperatures and pressures (600 deg F at
100 psig), which would add additional thermal load to the Blue Ridge Paper wastewater
discharge. The technology is also capital equipment intensive. Preliminary equipment cost
estimates for a CRP purge stream treatment system ranged from$1.7 to $2.9 million and
operating cost estimates were on the order of$1000 per day.
To refine preliminary cost estimates and determine if the technology would actually work, a
series of rather expensive field trials were proposed. One significant concern, besides cost of
trials, was the corrosive effect of high chlorides in the CRP purge stream on pilot scale
equipment. Blue Ridge Paper decided that it was better to direct such field trial expenditures
towards CRP bleaching and other technologies.
High Temperature Peroxide Oxidation- 2002
Blue Ridge Paper evaluated the use of extreme temperature and pressure with hydrogen peroxide
to decolorize the CRP purge stream. Samples were sent for bench scale testing. No color
reduction was observed. It was then proposed to perform an additional laboratory trial using
evaporation enhancements to the technology. However, a fee$25,000 for the additional work
was required. Again, there weren't any existing similar treatment installations for comparison
and there was no indication that the second fee-trial would be successful. Based on the
preliminary results and commercial trial costs, Blue Ridge Paper decided to suspend further
investigation of this technology.
Filter Papers - 2002
Filter papers have been used in machining and other industries to separate solids and other
r_ contaminates from process fluids and wastes. The spent filter paper and captured solids are then
processed for material recovery or shipped to a landfill for disposal. The filter paper process can
March 2005 CRP Report Final.doc

March 2005 CRP Color Reduction Technology Report
Page 18
be continuous or batch. Blue Ridge Paper evaluated a proprietary technology using treated paper
to remove color from the CRP purge stream. The treated paper coagulates and filters solids
including color bodies from the waste.
Bench-scale tests of the filter paper were run at the Canton mill. The filter paper removed
approximately 90% of the color from the CRP purge stream. There were no pilot or full-scale
operations using this technology for color removal. The equipment required for a full-scale
system for the CRP purge stream is not well defined.
A budgetary quote of$1 to 2 million per year for filter paper to treat the CRP purge stream was
provided. Capital cost of equipment was not estimated. In addition, the filter paper technology
would generate 2.25 tons/day, or an additional 820 tons/year of waste paper requiring landfill
disposal. Although this technology did initially appear promising, the costs for the treated paper,
as well as costs for additional equipment and waste disposal prevent this technology from being
economically viable. It was determined that the filter paper technology was not a commercially
competitive option for Blue Ridge Paper. A field trial was not pursued for this technology.
Proprietary Oxidation Technology`
Blue Ridge Paper evaluated a proprietary oxidation technology that could possibly destroy lignin
compounds and color in the CRP purge stream. Blue Ridge Paper provided CRP purge stream
samples for bench scale testing. The bench scale work was not effective for color removal and
r' Blue Ridge Paper was informed that the CRP purge stream was not a feasible application for this
technology.
Ultra/Nano Filtration—2002
Several manufacturers of ultra/nano filtration equipment were contacted concerning color
removal from the CRP purge stream. When these companies received detailed information on
the characteristics of the CRP purge stream—especially the very high dissolved salt content—
they expressed serious reservations about the viability of ultra/nano filtration for this
application. The technical issue was salt plugging of the filter membranes. None of the
companies offered to do bench scale tests or field trials. Ultra/nano filtration is not a feasible
technology for the CRP purge stream.
Summary/ Conclusions
Blue Ridge Paper Products Inc. has and continues to evaluate every possible methodology
available for the effective treatment of the CRP purge stream. This report illustrates a concerted
effort to deal with this color source and to evaluate many possible alternatives. As specific
details concerning the use of each technology have been examined in more "real world"
application terms, significant problems have arisen. These issues are hugely important from a
logistics, technology, performance and overall effectiveness standpoint. A technology that
doesn't work in a real, full-scale application for the significant reduction of color provides no
benefits to the water quality. Continued improvement in secondary effluent color is the overall
March 2005 CRP Report Final.doc

March 2005 CRP Color Reduction Technology Report
Page 19
objective of Blue Ridge Paper, those interested in these issues, and the NPDES Permit for the
mill.
In the testing of the potential technologies for color reduction in the CRP purge stream, even in
cases where a significant color reduction was indicated (still not near the 85 % goal), no
statistically significant reduction in the mill's secondary effluent could be demonstrated. The
characfer and pollutant content of the CRP waste stream represents an already concentrated
"waste" from an extensive, in-mill effort to reduce color. The purge stream is the wastewater of
a wastewater treatment process. By its very nature it carries the pollution that was removed from
another wastewater stream so that stream can now be recycled. The ability to "further" treat
such a concentrated stream and remove its impact from the overall mill discharge is a
challenging and almost overwhelming engineering problem. The day-to-day variation in mill
effluent color is greater than the contribution of color from the CRP purge stream. The actual
amount of color related to the CRP purge discharge results in only about 2000 lbs/day in the
secondary effluent. At 42,000 lbs./day of color in the discharge, this represents only about 5 %
of the loading. While the Canton Mill has essentially reduced its color discharge by over 90 %
from the late 1980s, the CRP purge stream is a difficult color source to manage and additionally
reduce.
The overall objective of meeting NPDES permit requirements regarding CRP color can be
illustrated by the following sentence in the permit condition: "The CRP analysis shall
concentrate on the technical, economic and operational feasibility of implementing the
applicable technologies on all or a portion of the purge stream." Blue Ridge Paper takes very
seriously the need to further reduce color in the Canton Mill wastewater discharge and has taken
a very comprehensive look at not only the technologies identified in the permit condition,but
many more. At this juncture, Blue Ridge Paper cannot recommend the implementation of any of
the evaluated technologies. The search for an effective CRP management strategy should
continue, and the company is committed to doing that in conjunction with mill-wide color
reduction efforts.
Blue Ridge Paper has diligently placed into operational use all of the applicable technologies
identified by the TRW(Technology Review Workgroup) during the 2001 permit renewal process
that were identified as "highest certainty" steps and those that were appropriate and identified as
"reasonable certainty" steps. The CRP treatment consideration was identified by the TRW as
having reduced potential for application as compared to the"highest certainty" and "reasonable
certainty" items and is referred to in TRW reporting and the permit as "technologies for further
color reduction." The NPDES permit specifically identifies color treatment of the CRP purge
stream as a "lowest certainty" method for additional effluent color reduction.
Initial consideration of this waste stream identified a number of possible treatment approaches.
The trials summarized in this report and used to evaluate potential treatment approaches have
frankly raised many questions, eliminated several technologies from reasonable consideration
and have failed to identify any one or combination of technologies that can be implemented at
this time. As Blue Ridge Paper continues to evaluate technical approaches to the CRP purge
stream, the company remains committed to finding ways to further reduce color overall in the
mill effluent and to meet all the conditions of the NPDES Permit.
March 2005 CRP Report Final.doc

December 2005
Color Performance Following Highest
and Reasonable Certainty Actions

BLUE RIDGE
PAPER PRODUCTS INC.
Certified Mail
Return Receipt Requested
30 November 2005 7099 3220 0007 0371 5900
Mr. Alan W. Klimek, P.E.
Director
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Effluent Color Performance Following Highest Certainty and Reasonable
Certainty Actions
NPDES Permit No. NC0000272
Blue Ridge Paper Products hic.
Canton, North Carolina
Dear Mr. Klimek:
r" Enclosed are two (2) copies of the subject report in accordance with Part I, Condition A.(8.),
Paragraph 8 of the December 2001 NPDES permit. With this report Blue Ridge Paper has
completed Highest Certainty, Reasonable Certainty, and Lowest Certainty actions for color
reduction identified in the NPDES permit. The report also documents on-going mill-identified
color reduction initiatives.
The Blue Ridge Paper Canton Mill is committed to continued color performance improvement
and recommends an annual average secondary effluent true color limit of 39,000 pounds per day
and a monthly average true color effluent limit of 52,000 pounds per day. Based on recent color
performance and color-related projects underway, we believe that these limits are technically,
economically and operationally feasible.
Please contact us if you have any questions.
Sincerely,
Paul S. Dickens Robert V. Williams
Manager,Environmental Affairs Director, Regulatory Affairs
828-646-6141 828-646-2033
[e-mail] [e-mail]
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Alan W. Klimek, NC DENR DWQ
30 November 2005, Page 2
' Enclosure: Effluent Color Performance Following Highest Certainty and Reasonable
Certainty Actions
cc: (w/encl): Dave A. Goodrich
Environmental Supervisor
Point Source Branch
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Roger Edwards
Surface Water Protection Supervisor
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778
Keith Haynes
Environmental Specialist
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office {
2090 US Highway 70
Swannanoa, North Carolina 28778
Don Anderson
US Environmental Protection Agency
Office of Water
Office of Science and Technology (4301 T)
1200 Pennsylvania Avenue,NW
Washington,DC 20460
Sergei Chemikov
Environmental Engineer I
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
f
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Alan W. Klimek, NC DENR DWQ
30 November 2005, Page 3
Internal Distribution:
C. File Water
Engr File—NPDES Color Reports
B. Shanahan
J. Clary
M. Ferguson
K. Hennessy
D. Brown
R. Medford
C. Dowdle
D. Cherry
J. Pryately
L. Cooper
1
_ I
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina_ 28716. 828-646-2000
Raising Your Expectations

BLUE RIDGE
PAPER PRODUCTS INC.
Blue Ridge Paper Products Inc.
Canton Mill, Canton, North Carolina
NPDES No. NC 0000272
Effluent Color Performance Following
Highest Certainty and Reasonable Certainty
Actions
Update on Mill-Identified Color Reduction Initiatives
December 2005

December 2005 Effluent Color Report, BRPP Canton Mill
Page i
Executive Summary
This report documents the ability of the Blue Ridge Paper Products Inc., Canton Mill to attain
annual average and monthly average color limits following Highest Certainty and Reasonable
Certainty actions identified in the December 2001 NPDES permit. The report is submitted to
satisfy requirements of Part I, Section A.(8.), Paragraph 8 of the permit.
"...By December 1, 2005, the permittee shall submit, as related to implementation of the
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. ..."
Based on the Canton Mill's performance from December 2003 through September 2005 and the
mill's continued commitment to color improvement,Blue Ridge Paper believes that an annual
average secondary effluent true color limit of 39,000 pounds per day and a monthly average
secondary effluent true color limit of 52,000 pounds per day are technically, economically and
operationally feasible.
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Table of Contents
ExecutiveSummary.........................................................................................................................i
Introduction..................................................................................................................................... 1
Purpose........................................................................................................................................ 1
PermitRequirement.................................................................................................................... 1
Previous Color Limits,Evaluations and Reports........................................................................ I
Blue Ridge Paper Color Reduction Initiatives................................................................................2
Hardwood Fiberline Six Sigma Team......................................................................................... 2
Pine Brown Recovery Transfer Line.......................................................................................... 3
Milkof Lime............................................................................................................................... 3
Pine and Hardwood Quaternary Screen Rejects Press................................................................3
GreenLiquor Sump.....................................................................................................................4
AcidSewer Rerouting................................................................................ ...............................4
Color Process Improvement Six Sigma Team............................................................................5
ColorReliability Projects............................................................................................................ 5
Statistical Analysis of Color Data...................................................................................................5
Summary and Recommendation..................................................................................................... 6
Attachment I: Color Reduction Initiatives Under 2001 NPDES Permit, December 2005
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December 2005 Effluent Color Report, BRPP Canton Mill
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Introduction
Purpose
This report documents the ability of the Blue Ridge Paper Products hie., Canton Mill to attain
annual average and monthly average color limits following Highest Certainty and Reasonable
Certainty actions identified in the December 2001 NPDES permit. The report also documents
recent mill-identified color reduction initiatives.
Permit Requirement
The requirement of the 2001 NPDES permit for this report is specified in Section A.(8.),
Paragraph 8:
"By December 1, 2005, the permittee shall submit, as related to implementation of the
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 per as related to color, and all available data necessary to derive the
lowest achievable annual average and monthly average color loading limits.
By February 1, 2006, the Division of Water Quality(in consultation with the Technology
r' 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. If the limits determined to be
achievable by the Division of Water Quality (in consultation with the Technology Review
Workgroup) are above the target range, the Permit shall be modified in accordance with
North Carolina's permitting process to reflect those limits."
Previous Color Limits, Evaluations and Reports
Effluent color limits in Part I, Section A (8), Paragraph 2 of the December 2001 NDPES are as
follows:
"The average annual discharge of trite color for each calendar month shall not exceed
48,000 pounds per day. The monthly average effluent true color loading shall not exceed
55,000 pounds per day. For the purpose of this permit/variance only, `pounds of true
color' is calculated by the following equation:
Effluent flow (mgd)x Effluent True Color([ppm, sicfPlatinum Cobalt Units)x 8.34"
The 2001 NPDES permit also established a series of actions and reports related to color
reduction at the Blue Ridge Paper Canton Mill. "Highest Certainty" actions were projects
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December 2005 Effluent Color Report, BRPP Canton Mill
Page 2
identified by Blue Ridge Paper and the Technology Review Workgroup (TRW) as technically,
/ economically and operationally feasible. These projects were implemented during 2002 and
2003. Canton Mill effluent color performance following implementation of the Highest
Certainty projects was documented in the October 2003 Color Report required under Part I,
Section A (8), Paragraph 5 of the NPDES permit.
"Reasonable Certainty" actions were projects identified by the TRW with possible application to
the Canton Mill. Blue Ridge Paper completed evaluation of the technical, economic and
operational feasibility of Reasonable Certainty actions during 2002 and 2003. Results were
documented in the December 2003 Color Report required under Part I, Section A (8), Paragraph
7 of the NPDES permit. None of the Reasonable Certainty actions were deemed feasible.
However, based on mill performance with Highest Certainty actions and other initiatives, Blue
Ridge Paper recommended an annual average color limit of 42,000 pounds per day. In addition,
the Mill voluntarily accepted a reduced monthly average color limit of 52,000 pounds per day.
The Division of Water Quality(DWQ)revised the NPDES permit for these limits on February
27, 2004.
"Lowest Certainty" actions involve possible technologies to treat or eliminate the Chloride
Removal Process (CRP)wastestream. Part I, Section A(8.),Paragraph 9 of the NPDES permit
specified several specific technologies for evaluation including land application, commercial
incineration, coagulation/precipitation and solidification for land disposal. Blue Ridge Paper
identified and evaluated several other possible technologies including ozone and chlorine dioxide
bleaching. However, based on engineering evaluation and/or bench and pilot scale testing, no
feasible Lowest Certainty actions were found. These results were reported in the March 2005
CRP Color Reduction Technology Assessment Report. The CRP Report was originally due in
December 2004, but the DWQ granted a 3-month extension following floods that affected the
Canton Mill in September 2004.
Blue Ridge Paper Color Reduction Initiatives
Attachment I outlines major color reduction initiatives at the Blue Ridge Paper Canton Mill
under the 2001 NPDES permit. As of December 2005, Blue Ridge Paper has completed
NPDES requirements related to Highest Certainty,Reasonable Certainty and Lowest Certainty
actions for color reduction. The Canton Mill has undertaken other color initiatives beyond those
specified in the NPDES permit. These are included in Attachment I. Mill-identified color
projects not included in previous permit-required color reports are documented in sections
below.
Hardwood Fiberline Six Sigma Team
The October and December 2003 Color Reports identified hardwood fiberline washing as a
statistically significant contributor to secondary effluent color. A Six Sigma team was chartered
in spring of 2004 to evaluate opportunities to decrease hardwood color through improved
hardwood brownstock washing and process control. The team looked at process procedures,
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December 2005 Effluent Color Report, BRPP Canton Mill
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operating practices and process control parameters to understand their effect on process
reliability and color. A new operating strategy was implemented including new performance
metrics and tracking. The team also identified opportunities to improve brown stock washing
through shower bar adjustments and replacements. New design shower bars were recently
installed on the Number 1 Hardwood Brownstock Washer. A performance evaluation of the new
shower bar design is underway. Shower bar replacements on additional fiberline washers may
be considered during 2006.
Pine Brown Recovery Transfer Line
This project was introduced in the December 2003 Color Report. The Pine Brown Recovery
Transfer Line was completed during the Spring 2004 semi-annual outage. The project provided
a transfer pipeline between the Pine Brown Spill Tank and the Hardwood Blow Tower. The
transfer pipeline increases the effective recovery volume of the Pine Brown Spill System by
allowing excess color materials from the pine fiberline to be pumped into the hardwood fiberline
for recovery. This extra recovery volume is used during maintenance outages and other events to
improve overall capture and recovery of color materials that otherwise would not be reclaimed.
The estimated annual average secondary effluent color reduction from the Pine Brown Recovery
Transfer line is 500 pounds per day.
NEIk of Lime
This project was included in the May 2004 Supplement to the December 2003 Color Report.
During Spring of 2004, Blue Ridge Paper conducted a full-scale trial on the color reduction
effect of adding a continuous slurry of hydrated lime to the mill sewer system prior to
wastewater treatment. This "milk of lime"provides calcium, which in bench scale studies was
effective in removing brown color. Milk of lime addition produced a reduction in primary
influent color. However, there was no statistically significant reduction in secondary effluent
color associated with milk of lime. In addition, milk of lime addition has adverse effects on
sludge dewatering and wastewater sludge volume. Based on the dose rate and cost, milk of lime
is not an economically or operationally feasible technology for color reduction.
Pine and Hardwood Quaternary Screen Rejects Press
This project was introduced in the December 2003 Color Report and was implemented during
2004. The Pine and Hardwood Screening Systems follow brownstock washing and remove
shives and undigested pulp from brownstock fiber before bleaching. The screen reject flow
includes a sizable volume of filtrate that contains dissolved color materials. The Quaternary
Screen Reject Presses allow separation of the rejects and filtrate so that color materials in the
filtrate can be reclaimed. During summer of 2004, Blue Ridge Paper worked with a specialty
equipment vendor to fabricate, install and test prototype mechanical screw presses on the reject
drains for the hardwood and pine quaternary screens. After pressing, the reject filtrates are
returned to brownstock filtrate tanks. The dewatered rejects are burned in the Canton Mill bark
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December 2005 Effluent Color Report, BRPP Canton Mill
Page 4
boiler. The prototype screw presses were successful, and permanent units were purchased and
installed in the fall of 2004.
Based on monitoring during trials of the Quaternary Screen Reject Presses, color reduction is
approximately 1000 pounds per day. Blue Ridge Paper is working with the equipment
manufacturer to improve reliability and uptime for the Quaternary Screen Reject Presses. The
Blue Ridge Paper installation on the quaternary screen rejects is the first application of its kind
for screw press equipment.
Green Liquor Sump
This Green Liquor Sump project was introduced in the May 2004 Supplement to the December
2003 Color Report. The project was completed in August 2005. The Green Liquor sump allows
segregation of green liquor from black liquor recovery sumps in the recovery furnace area. This
segregation is important to in-mill color control because green liquor contamination of black
liquor materials prevents their capture and recovery. The green liquor is corrosive to evaporators
and other chemical recovery cycle equipment.
The estimated annual average secondary effluent color reduction from the Green Liquor Sump is
500 pounds per day.
Acid Sewer Rerouting
As documented in the October 2003 Color Report, unaccounted color has become a larger
percentage of mill sewer color as Blue Ridge Paper has successfully reduced brown color
discharges to wastewater treatment. Unaccounted color is calculated as the difference between
measured primary influent color in pounds per day and the sum of color measured in mill sewers
upstream of wastewater treatment. Unaccounted color is primarily the result of sewer-generated
color that occurs when acid bleach plant filtrates are exposed to alkaline conditions in the mill
sewer and primary clarifiers. Sewer generated color consists of dissolved color materials and is
not effectively removed by filtration and conventional coagulation and precipitation technology.
The current acid sewer at the Blue Ridge Paper Canton Mill mixes with the alkaline mill sewer at
the 4A manhole upstream of primary treatment. This configuration creates conditions that may
contribute to sewer generated color. To minimize the creation of sewer generated color, it is
desirable to keep acid bleach plant filtrates away from alkaline pH conditions.
A project was engineered during early 2005 to reroute acid bleach filtrates directly to the primary
clarifiers downstream of initial pH adjustment for the alkaline mill sewer. With rerouting, the
acid filtrates will see a neutral pH range of 6 to 9 when mixed with other mill wastewaters for
treatment. The design allows the bleach plant filtrates to mix with either primary influent or
primary effluent wastewater prior to secondary treatment. The Acid Sewer Project was
constructed during summer and fall of 2005 and will go into full operation in early 2006. Startup
testing is scheduled for December 2005.
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Blue Ridge Paper believes the Acid Sewer Project will achieve reduction in sewer generated
color. The reduction in secondary effluent color, however, is difficult to predict. The Acid
Sewer Project is a full-scale trial in terms of secondary effluent color reduction.
Color Process Improvement Six Sigma Team
As a result of color reduction projects implemented under the 2001 NPDES permit, secondary
effluent color from the Blue Ridge Paper Canton Mill for the period January through September
2005 averaged 39,465 pounds per day. This average includes several months of color
performance in the range of 32,000 to 38,000 pounds per day and several months of color
performance in the range of 41,000 to 46,000 pounds per day. This variability in monthly color
performance is a result of maintenance outages and normal process variability. Reducing the
variability of color performance is the next color reduction challenge for the Blue Ridge Paper.
A Six Sigma Team was chartered in September 2005 to examine the primary operating
conditions associated with periods of lowest color performance.
Color Reliability Projects
In addition to the Color Process Improvement Team, Blue Ridge Paper will dedicate capital in
2006 to improve the reliability of processes that have a demonstrated impact on color
rr� performance. These capital projects will focus on pulp washing efficiency, engineering controls
J to improve early detection of process upsets that may release color, and further mechanical
reliability improvements to the Bleach Filtrate RecyclingTm (BFR)process. Engineering design
of the Color Reliability Projects is underway with implementation planned during the first half of
2006. The 2006 Color Reliability Projects are included in Attachment I.
Statistical Analysis of Color Data
The average daily secondary effluent true color from the Blue Ridge Paper Canton Mill for the
period December 2003 through September 2005 - excluding the period of mill outage and restart
in September and October 2004 due to Hurricanes Frances and Ivan—is 39,548 pounds per day.
The upper 95 percent confidence interval for the average of this period is 40,280 pounds per day.
The average monthly secondary effluent color for the period December 2003 through September
2005 —excluding the flood-affected months - is 39,545 pounds per day. The upper 95 percent
confidence interval for monthly average color is 41,350 pounds per day. The maximum monthly
average color during this period occurred in August 2005 at 45,842 pounds per day. If the
flood-affected months of September and October 2004 are included, the maximum monthly
average color occurred in October 2004 at 59,539 pounds per day.
l a
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/ Summary and Recommendation
Blue Ridge Paper Products Inc. has completed Highest Certainty,Reasonable Certainty and
Lowest Certainty actions for color reduction identified in the December 2001 NPDES permit.
The mill has also identified, evaluated and implemented other initiatives for color reduction.
Several of these mill-identified projects are underway and will be completed during 2006.
The Blue Ridge Paper Canton Mill is committed to continued color performance improvement
and recommends an annual average secondary effluent true color limit of 39,000 pounds per day
and a monthly average true color effluent limit of 52,000 pounds per day. Based on recent color
performance and color-related projects underway, we believe that these limits are technically,
economically and operationally feasible.
Dec 2005 Color Report Final.doc

Attachment I - Color Reduction Initiatives Under 2001 NPDES Permit, December 2005 Update
Blue Ridge Paper Products Inc. - Canton Mill
Color Reduction Measure t 2002 2004
QOS 2006
1 2-Hour Color Testing --
2 Lieber ott Recommendations Implemented ------------►
3 Use of Off-line Clarifier for Spill Diversion - - -• • --• - -
4 Hwd Brown Recovery Tank Line to Pine Blow Tower ------------- ••• --
5 1-Hour color testing before and during maintenance outages - - --• -- •-- -
6 Installation of Mechanical Seals clean water se a ation ------- -
7 Improvement of equipment used for handling Pine and Hardwood Knot Rejects -------► -
8 $1.5MM spent on Bleach Filtrate Recycle Improvements -------------► :gym:..... . .... ..
9 1histalled Pine Brownstock Control Logic improvements -----------►
10 Determined multiple contributors and interaction effects causing Sewer Generated Color ----------- .......................
..,,
11 Bench-scale sewer-generated color work ------------- ------------
MINION
12 Hardwood Fiberline Six Sigma Team for process optimization and color improvements ----- ------- -------------
13 Improvements made to Pine Brownstock sumps for better recovery ------------- ------------ -
14 White Rot Fungus Trial-growth efforts unsuccessful,may re-visit in future ------------- -------------
15 Pine Brown Recovery Tank Line to Hwd Blow Tower -------------- -------------- ------------► :......-..-.
16 IMilk of Lime Trial not successful,no statistically significant SE color reduction) -------------- -------------- -------------- ►_
17 Pine and Hardwood Quaternary Screen Rejects Press(eliminate quaternary screen rejects ------------- -------------- -------------- ---- i
discharge to sewer,recover filtrate and shiver)
SOON
Trial to confirm and size system for C102 de-colorization of CRP/evaluate full-scale
18 application(trials completed after Sep 04 floods,not economically,technically or
operationally feasible
19 Green Liquor Sump at recovery furnaces(implementation delayed by Sep 2004 floods,
corn leted Aug2005)
20 Acid Sewer Rerouting-improved segregation of bleach plant filtrates from akaline ................................... ................................... ............................................................................................................ ...................................
------------- -------------- ------ ------- -------------- ----
wastewaters to reduce sewer generated color `°"'"'•'°""g^ --
21 Color Process Improvement Six Sigma Team to examine operating conditions associated
-------------- ----
with and color performance --------- -------------
sax •-••• ••-----'-'
22 2006 Color Reliability Projects-Pulp Washing Improvements(shower replacements and
-------------- -------------- --------------
re-bleach internal recycle um ) -------'----
23 2006 Color Reliability Projects-BRF Mechanical Improvements(MRP fiber detection and
- ---------- ----------
prevention) — ----
- '-----------►
..........
24 2006 Color Reliability Projects-Recovery Process Improvements(piping changes and
-------------t
------------- -------------- ---------------------------
instrumentation)
"'-""--- '-
25 2006 Color Reliability Projects-Color Monitoring Improvement(relocated and redundant _____________ ___________
instrumentation -------------- --------------
— Completed Process Change/Evaluation 1011101 Process Evaluation or Change
M- Continued Performance Improvement MMMMM Expected Performance Improvement