NC0000272_Response to Request for BMP Review_20230503

EBS
An Employee-Owned Company
Comprehensive Wortewoter Solutions
Best Management Practices (BMP) Plan Review for Blue Ridge Paper Products
LLC
Environmental Business Specialist (EBS) LLC
May 3, 2023
At the request of Blue Ridge Paper Products LLC ("BRPP"), EBS reviewed the BMP Plan for the facility
located in Canton, North Carolina in light of the pending mill shutdown that is currently planned to begin
in the latter part of May 2023. BRPP specifically requested that EBS review the existing BMP Plan and
identify whether modifications are recommended to ensure leaks and spills are properly managed
during all phases of the shutdown, including the shutdown of manufacturing processes (Phase 1B) and
clean out of tanks,vessels, piping, and other mill equipment(Phase 2). As further discussed below, EBS
has concluded that the existing BMP Plan has adequate procedures and processes in place to monitor
influents to and manage operation of the wastewater treatment plant (WWTP)throughout the mill
shutdown.
EBS reached the findings described herein by review of a copy of the Mill's existing BMP Plan,the Mill's
WWTP transition plan (including a description of the phases of shutdown), and discussing the
implementation of the practices and procedures in the BMP Plan with personnel at the WWTP during
normal operation, as well as during upset conditions (such as unplanned releases of process materials to
the WWTP) and periodic cold mill outages.
Based upon the following findings, EBS concluded that the existing BMP Plan includes the needed
management systems and equipment to effectively manage discharges from the Mill to the WWTP
during the planned shutdown, and to treat those losses well within the current specified NPDES
discharge permit limits:
• The existing BMP Plan is comprised of an executive summary and four individual sections, as
follows: Review and Certification, Process Description, Best Management Practices, and
Amendment of Best Management Practices.
• The Mill reviews and amends the BMP Plan at least once every 5 years, as required in Condition
A.6, Section B.5 of the NPDES permit.
• The overall BMP Plan is very thorough and identifies numerous automatic 24-hour/7-day
detection and spill control systems that monitor process sewers, and alarm and notify
operations personnel of conditions that are not normal in the process sewers. Thirty-one
different points in the process are continuously monitored with a combination of level control,
conductivity meters, and audible alarms. Additionally, the combined process sewer to the
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WWTP is continuously monitored for conductivity, pH, and tested for color every two hours
using composite samples taken the previous two hours.
• During Phase 113, discharges will be comparable to discharges during the initial shutdown stages
of a cold mill outage—i.e.,emptying vessels. My understanding from conversations with mill
leadership is that for this shutdown the mill is selling/giving away materials where practical, so
loads to the WWTP may actually be less than during a typical mill outage. Additionally, emptying
of vessels is not expected to result in the WWTP receiving new or different streams, or heavier
loads,than it would receive during a typical shutdown.
• During Phase 2, discharges will be comparable to discharges during the latter half of a mill cold
outage,when tanks and vessels are being cleaned, although cleaning will take place over a
longer period of time and all the vessels/piping/etc. will be cleaned versus undergoing
maintenance or replacement during a traditional cold mill outage. As in Phase 113, the cleaning
of equipment during Phase 2 is not expected to result in the WWTP receiving new or different
streams, or heavier loads,than it would receive during a typical shutdown.
• The key sections of the BMP Plan that would apply to the shutdown of the mill are in Section 3
Best Management Practices. Important parts of Section 3 are Section 3.1 Management of Spills,
Leaks, and Diversions, Section 3.3 Continuous Monitoring, and Section 3.8 Wastewater
Monitoring.These three sections of the BMP Plan are included as an appendix(Appendix 1) on
pages 5-17 of this document.These Sections are also briefly discussed below with additional
clarification regarding the implementation of the procedures during Phase 1B and Phase 2 of the
shutdown:
o Section 3.1- Management of Spills, Leaks, and Diversions.
This Section identifies automatic detection and spill control systems for black liquor,
turpentines, and soap streams. Section 3.1 also identifies collection and containment
processes. Approximately twenty-three collection systems throughout the mill are
identified in this Section along with off-line primary clarification equipment in the
WWTP that can be used as a diversion system for any high strength wastewater that
makes it to the WWTP.This Section also describes the additional aeration or treatment
capacity in the WWTP that can be brought online if high loading is unexpectedly
received.
During Phases 1B and 2,the automatic detection and spill control systems will remain in
place, collections systems (including off-line primary clarification equipment at the
WWTP)will be available, and additional aeration and treatment capacity in the WWTP
will be available as needed to handle loads to the WWTP from the vessel emptying and
cleaning operations.
o Section 3.3—Continuous Monitoring.
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Comprehensive Wostewoter Solutions This Section describes the areas of the Mill that continuously monitor flow and
conductivity in the Mill's process sewers that alert operating personnel if excessive
amounts of discharge or conductivity are observed in the sewers. It states in this section
that the Pulp Mill and Recovery areas use distributive control system (DCS)graphics in
the various control rooms to alert operators to sewer conditions that do not meet
normal conditions, and that if this occurs that operations personnel notify WWTP
operating personnel. In addition to the process sewers monitoring, incoming
wastewater to the WWTP is continuously monitored for conductivity that also alerts
WWTP personnel to any potential spill events. In addition to conductivity, composite
samples are collected and analyzed for color every 2 hours to monitor for process
upsets.
During Phases 1B and 2,the Mill will continue to continuously monitor flow and
conductivity in the Mill's process sewers and composite samples for color will continue
to be collected and analyzed.The WWTP staff will also be informed of the tank/vessel
emptying activities during Phase 113 and the equipment cleaning schedule during Phase
2.
o Section 3.8—Wastewater Monitoring.
This Section describes what wastewater monitoring is completed in the WWTP to detect
leaks, spills,to track the effectiveness of the BMPs, and to detect trends in spent pulping
liquor losses. Conductivity is monitored continuously (i.e., 24 hours/day and 7
days/week) and color is monitored every two hours with composited samples. If
elevated color conditions are detected, the frequency of monitoring composited
samples is increased to hourly. The WWTP is (and will continue to be)staffed 24 hours
per day and 7 days a week and, in the event an abnormal conductivity or color is
observed,the WWTP staff must alert recovery and/or pulp mill shift managers, who in
turn alert area operators to respond and take appropriate actions as required to stop
any process upset or unexpected loss of material to the process sewer. This section of
the plan also describes and sets action levels for various color levels and specifies the
response by the Mill when these action levels are exceeded.
During Phases 1B and 2, WWTP operators will continue to continuously monitor the
process sewers as described in the BMP Plan to detect and stop any unexpected loss of
material to the process sewer. During Phase 113,WWTP staff will alert shift managers of
abnormal/unexpected conductivity or color in accordance with the procedures in the
BMP Plan. During Phase 2,when there will be reduced staffing in the Mill,WWTP will
have area managers on-site during the day, and on-call during evening hours. Although
unexpected releases or spills to the WWTP are unlikely during Phase 2 (when
tanks/vessels will be largely emptied,with only tank heals and residual fluids
remaining), WWTP will alert area managers (whether on-site or on-call) in the event of
abnormal/unexpected conductivity or color in accordance with the procedures in the
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Comprehensive Wostewoter Solutions BMP Plan. In addition, by the time Phase 2 is started the WWTP will have 1-2 idle
primary clarifiers that can also serve as impoundment basins for any unexpected spills
or loss of materials from the mill.
In summary, considering the comprehensiveness, detail, and completeness of this BMP Plan, and the
equipment and personnel in the mill dedicated to the management and control of spills and leaks
that will remain in place during Phases 1B and 2 of the shutdown, it is our conclusion that the existing
BMP Plan, and specifically the procedures described above and included in the excerpts of the BMP
Plan provided in the attachment, are adequate to cover Phases 1B and 2 of the upcoming permanent
mill shutdown without further modification.
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Appendix 1
Section 3 Best Management Practices
Best Management Practice No. 1 - Management of Spills, Leaks, and
Diversions
Regulatory Requirements
�430.03(c)(1)and NPDES Permit Part A(6) Section B. The mill must return spilled or diverted
spent pulping liquors, soap, and turpentine to the process to maximum extent practicable as
determined by the mill, recover such materials outside the process, or discharge spilled or diverted
material at a rate that does not disrupt the receiving wastewater treatment system.
Spill Collection System and Treatment Overview
Spills,leaks,and overflows of black liquor,turpentine and soap from industrial
equipment,tanks,pumps, and transfer lines can impact the WTP. To prevent this from
happening,the Canton Mill has a continuous automatic detection and spill control
system in place. This system is designed to identify spills and either return them to the
process, divert them for later treatment,or allow for additional treatment capacity to be
added to the WTP. These measures are in place to prevent upsets to the WTP and
reduce the potential for violations of the NPDES permit. The spill control system
consists of continuous automatic detection and has three tiers of protection:
sumps/collection tanks,a diversion clarifier, and standby additional treatment capacity.
Collection Tanks, Sump Pumps, and Containment Processes
The startup and shutdown of various processes at the mill,malfunctions,equipment
failures,and maintenance activities may result in the release of spilled or diverted spent
liquor, soap,and/or turpentine to the WTP. In general,if spent liquor/soap is released
or diverted, the formed curbing directs the material to the floor drains or U-drain. The
material flows through the floor drains and U-drain and into a sump,which is equipped
with a conductivity sensor and a level transmitter. Under normal circumstances these
sumps are allowed to fill and flow to the WTP. If the conductivity in the sump reaches a
predetermined set point or level, the flow is recycled to a spill collection tank for
containment in the immediate process area. Under certain circumstances,it may be
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necessary to operate the sump manually to collect material and return it to the spill
collection tank.
Black liquor, turpentine,and soap in varying concentrations are stored in two of the
three general process areas of the mill (pulp mill and recovery area). Within each of
these areas are sump/sewer systems. These areas will be defined by their collection
system. In some cases,a tank might be in two collection systems, defined by the curbing
around the drainage area. All of the storage tanks are completely located within at least
one of the collection areas. See Appendix B (BMP Site Plan) for detailed information on
the tank locations and the sump areas. Appendix C (BMP Sumps Table) contains
detailed information on tanks, sumps,pumps,conductivity set points and reference tank
numbers.
Boilout Sump (A)
This collection system area contains the pine weak liquor storage tank No. 1
(-615,000 gallons) and the evaporator boilout tank No. 6 (-190,000 gallons). If a leak,
spill,or overflow occurs,the spent liquor will be directed to the boilout sump pump. If
the conductivity exceeds the conductivity set point,the spent liquor will be pumped into
the evaporator boilout collection tank and reclaimed back through the evaporator by
blending the liquor into the pine and hardwood weak liquor systems. If the leak
overwhelms the pumps,the spent liquor/soap will drain into the sewer system and into
the WTP,where,if necessary,it can be diverted into the offline spare clarifier or treated
with the additional capacity available from the stand-by aeration basin.
Tank Farm Sump (B)
This collection system area contains the east GB feed tank No.4 (-376,000 gallons) and
Swenson feed tank No. 5 (-376,000 gallons). If a leak,spill,or overflow occurs,the spent
liquor will be directed to the tank farm sump pump. If the conductivity exceeds the set
point,the spent liquor will be pumped into the evaporator boilout collection tank and
reclaimed back through the evaporator by blending the liquor into the pine and
hardwood weak liquor systems. If the leak overwhelms the pumps,the spent
liquor/soap will drain into the sewer system and into the WTP,where,if necessary,it
can be diverted into the offline spare clarifier or treated with the additional capacity
available from the stand-by aeration basin.
Evaporator "'U"' North Sump (C)
This collection system contains the east GB feed tank No. 4 (-376,000 gallons),west GB
feed tank No. 3 (-376,000 gallons),Swenson feed tank No. 5 (-376,000 gallons),and the
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currently out of service Swenson evaporator skim tank No. 7(-158,000 gallons). If a
leak, spill, or overflow occurs,the spent liquor will be directed to the evaporator"'U"'
north sump pump. If the conductivity exceeds the set point, the spent liquor will be
pumped into the evaporator boilout collection tank and reclaimed back through the
evaporator by blending the liquor into the pine and hardwood weak liquor systems. If
the leak overwhelms the pumps,the spent liquor/soap will drain into the sewer system
and into the WWTP,where,if necessary,it can be diverted into the offline spare clarifier
or treated with the additional capacity available from the stand-by aeration basin.
Evaporator"'U"' South Sump (D)
This collection system contains the Swenson evaporator No. 8 (-20,390 gallons) and west
GB evaporator No. 9 (-17,480 gallons). If a leak,spill,or overflow occurs,the spent
liquor will be directed to the evaporator"'U"' south sump pump. If the conductivity
exceeds the set point,the spent liquor will be pumped into the evaporator boilout
collection tank and reclaimed back through the evaporator by blending the liquor into
the pine and hardwood weak liquor systems. If the leak overwhelms the pumps,the
spent liquor/soap will drain into the sewer system and into the WTP,where,if
necessary,it can be diverted into the offline spare clarifier or treated with the additional
capacity available from the stand-by aeration basin.
East and West Double-Chambered Sump (E)
This pump collection system captures spills, leaks, or overflows from the 18 digesters
area No. 2 (-81,000 gallons),the pine blow tower No. 38 (-125,100 gallons),hardwood
blow tower No. 53 (-99,860 gallons),the hardwood primary knotter No. 50,the
hardwood secondary knotter No. 51,four (4) hardwood washers No. 45,the hardwood
first pre-02 filtrate tank No.46 (-289,027 gallons),the hardwood second pre-02 filtrate
tank No. 47(-289,027 gallons),the hardwood third pre-02 filtrate tank No.48 (-238,762
gallons),the hardwood forth pre-02 filtrate tank No. 49 (-238,762 gallons),the
secondary knotter accepts tank No. 52 (-57,103 gallons),the No. 1 foam tank No. 43
(-130,526 gallons),and the No. 2 foam tank No.44 (-93,996 gallons). If the conductivity
exceeds the set point,the sump will pump the spent liquor to the hardwood brown spill
collection tank No. 29. From the hardwood brown spill collection tank,the spilled
substances are pumped back to either the hardwood or softwood first-stage pre-oxygen
washer for recycling,minimizing losses to the sewer and to the WTP.
This pump has a manual isolation valve and under certain circumstances will be opened
to allow flow from one chamber to the other. This will allow for continued collection of
liquor during periods of maintenance on one of the submersible sump pumps or allow
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both pumps to pump during appropriate times. In the event of a catastrophic failure,
the manual gate valves on the south end of the east and west chambers can be closed to
stop the flow of liquor to WTP and both pumps could be started. This will provide
additional capacity for the sump pumps to collect the liquor. This will result in the
filtrate backing up into the courtyard until the failure can be stopped and the process
shut down. Under either circumstance the wastewater treatment operators will be
notified of problems. If the leak overwhelms the pumps,the spent liquor/soap will
drain into the sewer system and into the WTP,where,if necessary,it can be diverted
into the offline clarifier or treated with the additional capacity available from the
stand-by aeration basin.
No. 11 Recovery furnace Sump (F)
This collection system contains the north oxidizer tank No. 12 (-211,000 gallons),center
oxidizer tank No. 13 (-211,000 gallons), south oxidizer tanks No. 14 (-211,000 gallons),
red liquor storage tank No. 17(-376,000 gallons),west unoxidized storage tank No. 16
(-376,000 gallons),east unoxidized storage tank No. 15 (-376,000 gallons),unoxidized
liquor soap standpipe No. 22 (-1,800 gallons),and No. 11 Recovery furnace. If a leak,
spill or overflow should occur in this area,the spill will be directed to the No. 11
Recovery furnace sump pump. If the conductivity exceeds the set point,the black liquor
will be pumped into the evaporator wash water tank No. 28 and reclaimed back through
the evaporator by blending the liquor into the pine and hardwood weak liquor systems.
If the leak overwhelms the pumps,the spent liquor/soap will drain into the sewer
system and into the WTP,where,if necessary,it can be diverted into the offline spare
clarifier or treated with the additional capacity available from the stand-by aeration
basin.
East Heavy Liquor Compound Sump (G)
This collection system contains the west GB evaporator skim tank No. 11
(-116,000 gallons),east heavy liquor storage tank No. 10 (-116,000 gallons), soap
collection tank No. 23 (-43,000 gallons) and soap pump tank No. 24 (-1,970 gallons). If a
leak, spill, or overflow should occur in this area,the spill will be directed into the east
heavy liquor compound sump pump. If the conductivity exceeds the set point,the black
liquor, spent liquor and/or soap will be pumped into the evaporator wash water tank
No. 28 and reclaimed back through the evaporator by blending the liquor into the pine
and hardwood weak liquor systems. If the leak overwhelms the pumps,the spent
liquor/soap will drain into the sewer system and into the WTP,where,if necessary,it
can be diverted into the offline spare clarifier or treated with the additional capacity
available from the stand-by aeration basin.
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Red Liquor Tank Farm Sump (H)
This area contains the same tanks in sump area F as well as the truck loading and
unloading of spent liquor. This area is completely contained. The pump in this sump
operates on level control.Material accumulating in this sump is pumped into the area
contained by the No. 11 Recovery Furnace Sump (F) (see Subsection 3.1.9).
No. 10 Recovery Furnace Sump (I)
This collection system area contains the No. 10 Recovery Furnace. If a leak, spill, or
overflow occurs,the spent liquor will be directed to the No. 10 Recovery Furnace sump
pump. If the conductivity exceeds the set point,the black liquor will be pumped into
the wash water tank and reclaimed back through the evaporator by blending the liquor
into the pine and hardwood weak liquor systems. If the leak overwhelms the pumps,
the spent liquor/soap will drain into the sewer system and into the WTP,where,if
necessary,it can be diverted into the offline spare clarifier or treated with the additional
capacity available from the stand-by aeration basin.
Tall Oil Compound Sump (J)
This collection system area contains the #1 soap storage tank No. 25 (-65,200 gallons)
and #2 soap storage tank No. 26 (-65,200 gallons). If a leak, spill, or overflow occurs, the
spent liquor will be directed to the tall oil compound sump pump. If the conductivity
exceeds the set point,the spent liquor will be pumped into the evaporator wash water
tank No. 28 and reclaimed through the evaporator. If the leak overwhelms the pumps,
the spent liquor/soap will drain into the sewer system and into the WTP,where,if
necessary,it can be diverted into the offline spare clarifier or treated with the additional
capacity available from the stand-by aeration basin.
Tall Oil Manufacturing Sump (K)
This collection system area contains the Tall oil cook pot No. 27(-13,000 gallons). If a
leak, spill, or overflow occurs,the spent liquor will be directed to the tall oil
manufacturing sump pump. When the level in the sump reaches a certain point,the
spent liquor will be pumped into the Saveall collection tank and reclaimed through the
heavy liquor systems. If the leak overwhelms the pumps,the spent liquor/soap will
drain into the sewer system and into the WTP,where,if necessary,it can be diverted
into the offline spare clarifier or treated with the additional capacity available from the
stand-by aeration basin.
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Turpentine Storage Area (L) - Self-contained
The turpentine storage tank is fully contained. This containment is of sufficient volume
(-25,483 gallons) to contain the contents of the tank (-18,100 gallons),with additional
freeboard for precipitation. The turpentine tanks are equipped with level transmitters to
alert the operator when material is going into the containment. If a leak or spill occurs,a
manual sump pump may be used to recover and reclaim the release. Stormwater
collected in this area is normally discharged to the WTP. The turpentine system is
normally isolated from the WTP but must be periodically drained of tramp water (i.e.,
rainwater and small amounts of seal water) under normal and upset conditions. This
shall be performed under operator supervision to insure turpentine is not released to the
WTP. Before draining any water from the turpentine system, the operator must notify
the WTP.
Pine Turpentine System Area (M) - Self-contained
The pine transfer tank No. 20 (-140 gallons) and the pine turpentine decanter No. 20
(-4,200 gallons) are fully contained. This containment is of sufficient volume to contain
the contents of the tank,with additional freeboard for precipitation. The turpentine
tanks are equipped with level transmitters to alert the operator when material is going
into the containment from those tanks. Depending on the severity of the release, a
portable pump may be used to recover and reclaim the release. The turpentine system is
normally isolated from the WTP but must be periodically drained of tramp water (i.e.,
rainwater and small amounts of seal water) under normal and upset conditions. This
shall be performed under operator supervision to ensure turpentine is not released to
the WTP. Before draining any water from the turpentine system,the operator must
notify the WTP.
Hardwood Turpentine System Area (N) - Self-contained
The hardwood turpentine transfer tank No. 21 (-140 gallons) and the hardwood
turpentine decanter No. 21 (-2,350 gallons) are fully contained. This containment is of
sufficient volume to contain the contents of the tanks,with additional freeboard for
precipitation. The turpentine tanks are equipped with level transmitters to alert the
operator when material is going into the containment from these tanks. Depending on
the severity of the release, a portable pump may be used to recover and reclaim the
release. The turpentine system is normally isolated from the WTP but must be
periodically drained of tramp water (i.e.,rainwater and small amounts of seal water)
under normal and upset conditions. This shall be performed under operator
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supervision to ensure turpentine is not released to the WTP before draining any water
from the turpentine system,the operator must notify the WTP.
Hardwood Knotter Sump - No. 1 Fiberline (0)
The collection system catches knot bin drainage. If a leak, spill,or overflow occurs,the
spent liquor will be directed to the hardwood knotter sump or to the east section of the
double chambered sump. If the conductivity exceeds the set point,the spent liquor will
be pumped into the hardwood brown spill collection tank and reclaimed back through
the pre-02 washers. If the leak overwhelms the pumps,the spent liquor/soap will drain
into the sewer system and into the WTP,where,if necessary,it can be diverted into the
offline spare clarifier or treated with the additional capacity available from the stand-by
aeration basin.
Brown Stock U-Drain West Sump - No. 2 Fiberline (P)
This collection system area contains three (3) pine washers No. 31, the pine first pre-02
filtrate tank No.32 (-57,100 gallons), the pine second pre-02 filtrate tank No. 34 (-53,300
gallons),the pine second pre-02 mix tank No. 35 (-14688 gallons),the pine third pre-02
filtrate tank No.36 (-44,734 gallons) No.45,the pine third pre-02 mix tank No. 37
(-14,688 gallons),and the pine surge tank No.42(-56,402 gallons). If a leak, spill, or
overflow occurs,the spent liquor will be directed to the brown stock U-drain west sump.
If the conductivity exceeds the set point,the spent liquor will be pumped into the pine
brown spill collection tank No. 30 and reclaimed back through the evaporator by
blending the liquor into the pine and hardwood weak liquor systems. If the leak
overwhelms the pumps,the spent liquor/soap will drain into the sewer system and into
the WTP,where,if necessary,it can be diverted into the offline clarifier or treated with
the additional capacity available from the stand-by aeration basin.
Brown Stock U-Drain East Sump - No. 2 Fiberline (Q)
This collection system area contains the pine primary knotters No. 39,the pine
secondary knotters No. 40 and the pine secondary knotter accepts tank No.41 (-5,916
gallons). If a leak, spill, or overflow occurs,the spent liquor will be directed to the brown
stock U-drain east sump. If the conductivity exceeds the set point,the spent liquor will
be pumped into the pine brown spill collection tank and reclaimed back through the
pine pre-02 washers. If the leak overwhelms the pumps,the spent liquor/soap will
drain into the sewer system and into the WTP,where,if necessary,it can be diverted
into the offline spare clarifier or treated with the additional capacity available from the
stand-by aeration basin.
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Hardwood Weak Liquor Storage Tank (R)
Hardwood weak liquor storage tank No.18 (-274,000 gallons) is partially contained. The
overflow on this tank is equipped with a temperature probe,which will alarm a manned
control room to notify them that material is being released into the containment area.
Under normal circumstances,this containment drains through a sump to the sewer.
The sump is equipped with a conductivity probe. If the conductivity reaches the set
point,the valve on the drain line automatically closes, containing released material in
the containment structure. The sump is equipped with pipe that can be connected to a
portable pump to recover the spilled material.
If the leak overwhelms the containment or the portable pumps, the spent liquor/soap
will drain into the sewer system and into the WTP,where,if necessary, it can be
diverted into the offline spare clarifier or treated with the additional capacity available
from the stand-by aeration basin.
Pine Knotter Sump - No. 2 Fiberline (S)
The collection system catches knot bin drainage. If a leak,spill, or overflow occur,the
spent liquor will be directed to the No. 2 Fiberline pine knotter sump. If the
conductivity exceeds the set point,the spent liquor will normally be pumped into the
pine brown spill collection tank and reclaimed back through the pre-02 washers. If the
leak overwhelms the pumps,the spent liquor/soap will drain into the sewer system and
into the WTP,where,if necessary,it can be diverted into the offline spare clarifier or
treated with the additional capacity available from the stand-by aeration basin.
Turpentine Loading and Unloading Area (T)
This containment is of sufficient volume to contain the contents of a spill in the area and
is constructed to accommodate both rail cars and tank trucks. The containment directs
spills back into the existing turpentine storage area (L),which is self-contained. Once
there,manual pumps are used to recover and reclaim the material. The turpentine
loading/unloading area is normally isolated from the WTP.
Tall Oil Loading Area (U)
This containment is of sufficient volume to contain the contents of a spill in the area.
The containment directs spills back into the existing tall oil/soap storage compound
where the material will be directed to the tall oil compound sump pump. If the
conductivity exceeds the set point,the material will be pumped into the wash water tank
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and reclaimed through the evaporator. If the leak overwhelms the pumps,the spent
liquor/soap will drain into the sewer system and into the WTP,where,if necessary,it
can be diverted into the offline spare clarifier or treated with the additional capacity
available from the stand-by aeration basin.
Camp Branch Containment (V)
The containment contains the east,north,and west storage tanks. The east tank is
infrequently used for temporary storage of spent pulping liquor as dictated by liquor
inventory levels. The volume of the containment(— 778,OOOgallons) is sufficient to
contain the contents of the largest tank (—375,522 gallons),with additional freeboard for
precipitation. However,the containment is equipped with a sump to drain seal and
stormwater. Under normal circumstances,this material drains through the sump to the
sewer. The sewer is equipped with a conductivity probe and alarm. If the conductivity
reaches the set point and the sump controls are in automatic,the valve on the drain line
automatically closes,containing released material in the containment structure. An
alarm will also sound in the evaporator and fiberline control rooms to alert the operators
of a release. Upon receiving an alarm and if the sump is being operated in manual
mode,the operators will investigate the cause of high conductivity and manually shut
the gate if needed.
If the conductivity probes fail,the spent liquor drains into the sewer system and into the
WTP,where,if necessary,it can be diverted into the offline spare clarifier or treated with
the additional capacity available from the stand-by aeration basin.
Chloride Removal Process Sump (W)
This sump collection system captures leaks,spills and overflows associated with the
Chloride Removal Process (CRP). The sump is located inside the CRP building and only
collects material from this specific process. In the event of a leak,spill or overflow the
pneumatic gate,in the u-drain,will close. This occurs because of a reaction to an
elevated conductivity meter reading above the determined set point. The black liquor
will then travel to the sump,which will pump the material over to the No. 11 Recovery
Furnace Sump (F). The material collected there will be pumped into the evaporator wash
water tank No. 28 and reclaimed back through the evaporator by blending the liquor
into the pine and hardwood weak liquor systems. If the amount of material overwhelms
the pumps,the spent liquor/soap will drain into the sewer system and into the WTP,
where,if necessary,it can be diverted into the offline spare clarifier or treated with the
additional capacity available from the stand-by aeration basin.
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Offline Spare Clarifier
If a significant amount of black liquor is released and is not adequately captured by the
sump collection systems,the liquor can end up traveling through one of the sewers and
into the WTP. Once at the WTP,if necessary,the flow can be diverted into the offline
spare clarifier and/or treated with the additional capacity available from the stand-by
aeration basin. The material will be held in the clarifier and then fed into the WTP at a
manageable,nondisruptive rate. This procedure is designed to minimize the possible
impact on the WTP and,potentially,the secondary effluent. The diversion can be
initiated via a phone call from the mill or process area or by elevated conductivity of the
incoming flow to the WTP. Planned releases, occurring normally during planned
maintenance outages, are coordinated for the best management of the released material.
However,in rare instances,the WTP can divert unplanned releases depending on their
severity and duration.
Standby Aeration Basin
The WTP is flexible and has the capability of additional treatment capacity if necessary.
The WTP operators monitor the dissolved oxygen(DO) of the residual aeration basin. If
the aeration basins in operation cannot maintain a minimum DO of at least 1 mg/L,the
operators bring the standby aeration basin(s) online. Also,if major increased loads are
anticipated,the WTP will bring the additional basin(s) online. Depending on the
operation of the WTP,this can increase the effective WTP capability to treat dissolved
organics by up to 40 percent.
1.1 Best Management Practice No. 3 - Continuous Monitoring
1.1.1 Regulatory Requirements
�430.03(c)(3)and NPDES Permit Part A(6) Section A.3. The mill must operate continuous,
automatic monitoring systems that the mill determines are necessary to detect and control leaks,
spills, and intentional diversions of spent pulping liquor, soap, and turpentine. These
monitoring systems should be integrated with the mill process control system and may include,
e.g., high level monitors and alarms on storage tanks;process area conductivity (or pH)monitors
and alarms;and process area sewer,process wastewater, and wastewater treatment plant
conductivity (or pH)monitors and alarms.
The BMP Plan requires that each applicable area of the mill continuously monitor its
systems. Separate from this BMP, associated with operating the processes,the operators
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monitor specific tank levels to prevent overflows. Both the operating areas and the WTP
operators then monitor various sewers for flow and conductivity. Finally,the WTP
operators monitor the incoming wastewater.
Monitoring the sewer systems enables personnel to determine if production is running
within normal ranges. It alerts operators to excessive amounts of discharge, or other
factors potentially indicating compliance issues. In such cases, operators notify WTP
personnel,who may alter their operating strategies accordingly. The pulp mill and
recovery areas have access to information on sewer conditions through distributive
control system(DCS) graphics in the control rooms. These graphics alarm operators to
sewer conditions that do not meet normal conditions for flow and conductivity. The
WTP generates a daily report on effluent conditions,including compliance data for
NPDES permit limitations. Compliance wastewater parameters are reported in the
monthly DMR.
1.1.2 Conductivity Monitoring
Conductivity meters located in specific sewer systems indicate high conductivity in the
areas with spent pulping liquor and soap. A list of these meters is located in Appendix
C. If a high conductivity material is detected in the pulp mill sewer system,potential
sources are checked for leaks and/or spills of spent pulping liquor. When leaks and
spills are located,corrective action will be taken as appropriate. Additionally,
conductivity is monitored in the sumps. This information is available to both the
operating areas and the WTP operators. For more detailed information, see
Subsection 3.1.
1.1.3 Wastewater Treatment Plant Influent Monitoring
In addition to the sewer monitoring,the incoming flow to the WTP is continuously
monitored for conductivity. A composite sample is also collected and analyzed for color
at least every 8 hours. See Subsection 3.8 for additional details.
In addition to the 8-hour composite sample,a composite sample of the WTP influent is
taken every two hours and analyzed for color. The purpose of this 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 (WTP)
operators communicate the information to mill operations and in-mill investigations
begin. If color levels are high enough,the material can be diverted to the off-line spare
clarifier using the procedure described in Section 3.1.27. During maintenance outages,
the frequency of testing increases to increments of 1 hour.
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Best Management Practice No. 8 - Wastewater Monitoring
Regulatory Requirements
The mill must conduct wastewater monitoring to detect leaks and spills, to track the effectiveness
of the BMPs, and to detect trends in spent pulping liquor losses. Such monitoring must be
performed in accordance with Section �430.03(i) of the regulations.
�1430.030) and NPDES Permit Part A(6) Section E.J. Monitoring, corrective action, and
reporting requirements. (1) Each mill subject to this section must conduct daily monitoring of
the influent to the wastewater treatment system in accordance with the procedures described in
paragraph (h) (2) of this section for the purpose of detecting leaks and spills, tracking the
effectiveness of the BMPs, and detecting trends in spent pulping liquor losses.
�430.030 and NPDES Permit Part A(6) Sections D.1 and D.2. Establishment of wastewater
treatment system influent action levels. (1) Each mill subject to this section must conduct a
monitoring program, described in paragraph (2) of this section,for the purpose of defining
wastewater treatment system influent characteristics (or action levels), described in paragraph
(3) of this section, that will trigger requirements to initiate investigations on BMP effectiveness
and to take corrective actions.
(2) Each mill subject to this section must employ the following procedures in order to develop the
action levels required by paragraph (h) of this section:
(i) Monitoring parameters. The mill must collect 24-hour composite samples and analyze
the samples for a measure of organic content (e.g., Chemical Oxygen Demand (COD) or
Total Organic Carbon (TOC)). Alternatively, the mill may use a measure related to
spent pulping liquor losses measured continuously and averaged over 24 hours
(e.g., specific conductivity or color).
(ii) Monitoring Locations. For direct dischargers, monitoring must be conducted at the point
the influent enters the wastewater treatment system. . . For the purposes of this
requirement, the mill may select alternative monitoring point(s) in order to isolate
possible sources of spent pulping liquor, soap, or turpentine from other possible sources of
organic wastewaters that are tributary to the wastewater treatment facilities (e.g., bleach
plants, paper machines, and secondary fiber operations).
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The mill's WTP conducts wastewater monitoring to detect leaks and spills,to track the
effectiveness of the BMPs, and to detect trends in spent pulping liquor losses.
— Conductivity
While color is the monitoring parameter selected for action level and diversion
evaluation,conductivity is used as a"real time' monitoring parameter for immediate
process operation feedback. Black liquor that is not collected and recycled may be
discharged to the WTP through one of the sewers. Once at the WTP it will register as
elevated conductivity in the primary influent. The WTP and area operators are
monitoring the sewer conductivities continuously and will alert the recovery and/or
pulping shift manager(s) of abnormal events. The shift manager(s) then alert the
appropriate operator to respond and inspect the sewer area processes and sumps. If
color events occur that cannot be handled by the area sump system,the area operators
notify the shift manager,who will in turn notify the WTP so the WTP operators can act
accordingly.
Color Action Levels
The mill collects a composite WTP influent sample at least every 8 hours. A 24-hour
composite sample is generated from the three 8-hour composites for the day. In
addition,a composite sample of the WTP influent is taken every 2 hours as described in
Section 3.3.3. If the mill experiences an upset that could result in significant losses,color
sampling frequency may increase for better monitoring and control of the system.
The Canton Mill has established wastewater treatment system influent color action
levels. The daily total influent (primary influent) color action levels are as follows:
Lower action level is 55,400 lbs./day of color
The upper action level is 59,4001bs./day
The out of control level is 72,500 lbs./day
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If the lower action level is exceeded for two consecutive days,the mill shall conduct an
investigation to determine the cause of such an exceedance. If the upper action level is
exceeded for two consecutive days,the mill will complete corrective action to bring the
wastewater treatment system influent mass loading below the lower action level as soon
as practicable. In addition,the Canton Mill has established an out of control level of
72,500 lbs./day that will trigger immediate investigative action and subsequent
corrective action. All investigations that are triggered by exceedances of the above
action levels will be documented using the Investigation and Corrective Action Form E-
2 in Appendix E.
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