NC0000272_NCASI Color Loading Analysis_20220401 (2)

NATIONAL COUNCIL FOR AIR AND STREAM IMPROVEMENT, INC.
Nick McCracken
EHS Water Supervisor
Evergreen Packaging Inc. Canton Mill
[e-mail]
Dear Nick:
NORTHERN REGIONAL CENTER
A-114 Parkview Campus, Mail Stop 5436
Western Michigan University
Kalamazoo, MI 49008
[phone]
FAX: [phone]
Laurel Eppstein
Associate Scientist
[e-mail]
You requested recent color loadings from bleached kraft mills. We have analyzed
data downloaded from EPA's DMR (discharge monitoring reports) database.
In the first analysis, we have used only those data that we were able to transform into
units of average pounds/day of color. This excluded reports that: 1) were maximum
values (daily or monthly, seven mills); 2) were based upon tons of pulp (Ib/ton, five
Maine mills); or 3) had no effluent flow associated with color data, so couldn't be
converted to a daily mass (one mill). We used EPA's permit formula for transforming
color units to mass:
Effluent Flow (MGD) x Effluent True Color Level (Platinum Cobalt Units) x 8.34.
This left us with only ten bleached kraft mills' data with which to work, four from EPA
region 4; one, region 2; three, region 3; and two, region 10. Each of the mill's report
dates range from early in 2010 to the end of 2011, with an average of 21 report dates
per mill. These are the statistics of the set:
Minimum
Maximum
Average
Color
lb/day
13,132
159, 757
59,030 J
A frequency distribution of the average annual daily color Toad per mill is displayed on
the next page. Canton's data point is shown, at the 22nd percentile. In terms of
Toads, this mill performs better than 7 of the mills in the group. If the new permit limit
is 36,000 lb/day averaged over a year, your mill is right at that limit in this data set.

180,000
160,000
140,000
120,000
co
t 100,000
1
0
0
0
80,000
60,000
40,000
20,000
MIM
Color Loadings Ten Bleached Kraft Mills
EPA DMR Data
Canton
0% 10% 20% 30% 40% 50% 60% 70%
% of Mills with Color Loads Less Than
80%
90% 100%
A second analysis of only those DMR data where the unit was PT -CO (PCU) and the
report statistic was `average' was also performed. Ten mills were in this group also,
with similar representation in the EPA regions as above, with the exception of one
more mill in region 3 and one less in region 4. The average number of report dates
per mill was 20, with similar date ranges.
The range of this analysis was much tighter:
Minimum
Maximum
Average
Color
(PCU)
117
781
361
A frequency distribution of the average annual daily effluent color value per mill is
displayed on the next page. Canton's data point is shown, at the llth percentile.
There are 8 mills with higher daily values than Canton's.

900
800 ---
700
600
ca 500
a
400
300
200
100
Color Concentration (PCU), Ten Bleached Kraft Mills
EPA DMR Data
Canton
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
% of Mills with Color Loads Less Than
A third analysis was performed using the pounds of color per ton of brownstock pulp
to the bleach plant. This enabled use of the Maine mills, which had reported in units
of Ibs/ton pulp. Transforming the PCU and lb/day data for the remaining mills
required using 2010 pulp data from AF&PA's EHS database. Dates were limited in
this group to the year 2010, to match the pulp data year. This pairing of monthly
reports of color data with annual pulp production was imperfect, as 1/12 the pulp per
month was not an actual match -up with the color reported. Therefore, this analysis
should be given less merit than the previous two.
This group contained 16 bleached kraft mills, four from EPA region 4; one, region 2;
four, region 3; five, region 1; and two, region 10. The number of dates in 2010
ranged from 3 to 12.
These are the statistics of the set:
Minimum
Maximum
Average
Color
lb/ton kraft
pulp
20 _j
188
77

A frequency distribution of the average pounds color/ton brownstock kraft pulp to the
bleach plant is displayed below. Canton's data point is shown, at the 7th percentile.
There are 14 mills with higher production -weighted color values than Canton's.
200
180
160 -
a 140 - -
120
L
0 100
4-1
80
0
0
0 60 --
40
20
Color Normalized to Brownstock Kraft Pulp before Bleaching
16 Mills, EPA DMR Data & AF&PA 2010 Pulp
Canton
0' , f ( I I I I i
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
% of Mills with Color lb/ton kraft pulp Less Than
Nick, we hope this helps you in addressing your re -permitting concerns. Please
contact me if you need something other than what we have provided here.
Sincerely,
Laurel Eppstein