NC0000272_Email_20120130

Cranford, Chuck
From: Paul Dickens [[e-mail]]
Sent: Monday, January 30, 2012 4:51 PM
To: Francies, Gary; Smith, Jason M.
Cc: Cranford, Chuck; John Pryately
Subject: Follow-Up to 30 Jan 2012 Meeting, Turbidity Interference during True Color Testing
30 Jan 2012
Gary and Jason -
Thank you for meeting today with John Pryately and myself to discuss turbidity interference that may occur during
analysis of secondary effluent true color at the Canton Mill. Our mutual goal is accurate representation of the true color in
mill effluent. The discussion helped our understanding of how to achieve this goal within the approved test method and
rules for data reporting that DWQ must follow. Starting with the January 2012 DMR, we will report the average of the daily
secondary effluent true color analyses. We will begin work on a modified true color testing procedure that addresses
turbidity interference for discussion with you and other appropriate officials.
The data shared with you today demonstrate that a significant number of secondary effluent true color analyses are
affected by turbidity interference that either passes through filtration or that forms in the filtered sample. The development
document for NCASI Test Method 253 warns that"even a slight turbidity causes the measured color to be noticeably
higher than the true color." I agree with your observation that there is technical uncertainty about how to distinguish
between true color tests that are valid and tests that are affected by turbidity. You described a situation in the Eastern
Carolinas where a small high bias in low level phosphate testing had a large consequence for TMDL allocations when
concentrations were converted to effluent mass discharge. We face a similar situation with turbidity interference during
true color testing of our secondary effluent.
Again, thank you for meeting with us and for a very good technical discussion to define the path forward.
Paul
Paul Dickens
Manager Environmental Affairs
Canton Mill -Waynesville Plant
Evergreen Packaging
175 Main Street, Canton, NC 28716
828-646-6141
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