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Poyry Forest Industries Pte (formerly Jaakko Poyry Consulting) Maybank Tower 2 Battery Road #21-01 Singapore 049907 Page 1 (26) Gunns Limited Bell Bay Pulp Mill Project TASMANIA In the matter of the Bell Bay Pulp Mill Project: A project of State Significance Resource Planning and Development Commission Inquiry Proponent: Gunns Limited EXPERT WITNESS STATEMENT MR. HANNU JUHANI JÄPPINEN EXPERT OF GUNNS LIMITED Contents 1 Name And Address 2 Area of Expertise 3 Introduction 4 Scope 5 Overview of Mill Operations Relevant to My Expertise 6 Submissions to the Draft Integrated Impact Statement 7 Declaration Attachments 1 2 3 CV of Mr. Hannu Jäppinen Description of Water and Effluent Systems of the Bell Bay Pulp Mill Attachment Description of the Methodology Used to Estimate Liquid Effluent Loads

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Page 1: Expert witness statement - svc028.wic009tp.server-web.comsvc028.wic009tp.server-web.com/iis/supp/hannu_jappinen_ews.pdf · power boiler areas is collected and sent to the main

Poyry Forest Industries Pte (formerly Jaakko Poyry Consulting) Maybank Tower 2 Battery Road #21-01 Singapore 049907

Page 1 (26)

Gunns Limited Bell Bay Pulp Mill Project TASMANIA

In the matter of the Bell Bay Pulp Mill Project: A project of State Significance Resource Planning and Development Commission Inquiry Proponent: Gunns Limited

EXPERT WITNESS STATEMENT MR. HANNU JUHANI JÄPPINEN EXPERT OF GUNNS LIMITED Contents 1 Name And Address

2 Area of Expertise 3 Introduction 4 Scope 5 Overview of Mill Operations Relevant to My Expertise 6 Submissions to the Draft Integrated Impact Statement 7 Declaration

Attachments 1

2

3

CV of Mr. Hannu Jäppinen

Description of Water and Effluent Systems of the Bell Bay Pulp Mill Attachment

Description of the Methodology Used to Estimate Liquid Effluent Loads

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1 NAME AND ADDRESS Mr Hannu Juhani Jäppinen Senior Consultant Poyry Forest Industries Pte (formerly Jaakko Poyry Consulting) Maybank Tower 2 Battery Road #21-01 Singapore 049907

2 AREA OF EXPERTISE My area of expertise is in pulp and paper mill process engineering, with a particular emphasis on pollution control planning, environmental pollution control technology, and waste water treatment technology. I hold the degree of Master of Science from the University of Helsinki (1967) and a Diploma in Environmental Science and Technology from the Delft University of Technology (1973). I have worked as a process engineer in the pulp industry since I joined Pöyry Forest Industry in 1974. From 1984-1992 I was the Manager of Pöyry’s Environment Protection Departments, and from 1992-1997 I was the Director of Environmental Projects in the Asia-Pacific Region in Pöyry’s Office in Thailand. Since then I have worked as a Senior Consultant in Pöyry’s Singapore office with the same responsibility. Prior to joining Pöyry I worked with the Finnish National Water Board and at the Technical and Environmental Research Laboratory of Oy Kaukas Ab (presently part of UPM-Kymmene), where I was responsible for monitoring and reporting the environmental performance of the Kaukas sulphate and sulphite pulp mills in Finland. My qualifications and experience are detailed in Attachment 1. In addition to my pulp mill experience, I also worked for the United Nations Environment Program in Nairobi from 1981-82. I was an international program officer in the Environmental Assessment Service. My main responsibility was to develop and manage global environmental programs. I have also been an environmental science and technology lecturer at the Pulp and Paper Industry Laboratory of the Asian Institute of Technology in Thailand. I have worked on various process and environmental design aspects for more than 30 pulp mill projects over the last 30 years, most of which have been bleached kraft pulp mills. On these projects I have undertaken the conceptual and basic design of the waste water and gaseous emission treatment systems. Since late 2004 I have been involved in the pre-feasibility and feasibility studies and conceptual and basic design of the Gunns’ proposed pulp mill at Bell Bay.

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3 INTRODUCTION Volumes 6 and 7 of the Draft Integrated Impact Statement (“Draft IIS) set out the conceptual design of Gunns’ proposed pulp mill.

I wrote the sections of that report that deal with the water and effluent balances, effluent loads, and effluent and sludge treatment systems. I also made the basic design of the effluent treatment plant.

In addition, I wrote Chapter 4 of Volume 6 describing the overall environmental strategies and safeguards used in the design of the Bell Bay pulp mill. I adopt Volumes 6 and 7, which should be read in conjunction with this witness statement.

Although not personally responsible for all of the detail contained in those volumes, I adopt their content for the purposes of this witness statement.

I have had the opportunity to review the witness statement of Kari Tuominen and I adopt the remarks made by him in section 3 of that statement concerning the involvement of Pöyry in the design development of the Bell Bay project.

4 SCOPE

4.1 Instructions I have been instructed to:

− Describe the operation of the fresh water, cooling water, boiler feedwater, and effluent treatment plant (incl. sludge treatment) systems;

− Explain the effluent loads and sludge generation, and noise emissions described in the draft IIS, in particular the Poyry report at Volumes 6 and 7 of the draft IIS for the Bell Bay pulp mill;

− Describe how the start-up, shut-down and potential operation upsets are expected to influence effluent loads;

− Address any issues within my field of expertise that are raised by the Tasmanian Government and Beca AMEC in their submissions to the Resource Planning and Development Commission (RPDC), or other submissions made by the members of the public to the Draft Integrated Impact Statement.

While the conceptual design and environmental emission estimates prepared by myself and my colleagues at Pöyry underpin the environmental impact assessment of the proposed pulp mill, the impact assessment has been undertaken by other consultants. In particular, I note that:

− The impacts of effluent emissions on the marine environment have been assessed by GHD and Toxikos.

− The impacts of air emissions from the pulp mill have been assessed by GHD, Pacific Air & Environment and Toxikos.

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− The impacts of noise emissions from the pulp mill have been assessed by GHD.

− The design of the solid waste landfill has been undertaken by Pitt & Sherry.

I have not been asked, nor am I fully qualified, to verify or confirm the results of those impact assessments.

4.2 Reports Reviewed Among the material I have considered, I have been instructed to specifically consider the following reports, documents, and submissions:

− The report prepared by Poyry, which is at Volumes 6 and 7 of the draft IIS for Gunns’ proposed kraft pulp mill at Bell Bay;

− Report (Volumes 1 and 2) prepared by Beca AMEC dated August 2004 for the Resource Planning and Development Commission;

− Report prepared by Beca Amec in October 2006 titled; “Gunns IIS Peer Review IU01 of Gunns Limited Bell Bay Pulp Mill Draft Integrated Impact Statement”.

− Environmentally relevant sections of the technical proposals and guarantees submitted to Gunns by the pulp mill and effluent treatment plant Vendors.

− Consolidated submissions of the whole Tasmanian Government to the Engineering Issues relevant to the environmental protection technology of the pulp mill presented in the DIIS

5 OVERVIEW OF MILL OPERATIONS RELEVANT TO MY EXPERTISE

5.1 General I have prepared a power point presentation as a basis of my oral evidence. This presentation is attached (Attachment 2) to this statement. The presentation is divided into the following sections:

− Presentation of Process Area – Fresh Water Treatment and Supply: While I am familiar with the overall design concept and operation of the proposed pulp mill, this discussion will focus on the fresh water treatment and supply area of the pulp mill.

− Presentation of Process Area – Cooling Water Systems of the Pulp Mill: While I am familiar with the overall design concept and operation of the proposed pulp mill, this discussion will focus on the cooling water systems and circuits of the pulp mill.

− Presentation of Process Area – Boiler Feed Water and Demineralised Water Systems: While I am familiar with the overall design concept and operation of the proposed pulp mill, this discussion will focus on the boiler feed water and demineralised water systems of the pulp mill.

− Presentation of Process Area – Effluent Loads and Effluent Treatment Plant (incl. sludge handling): While I am familiar with the overall design concept and operation of the proposed pulp mill, this discussion will focus on the effluent loads and the effluent treatment plant of the pulp mill.

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, (ii) evaporation plant, (iii) chemical

perature of the cooling water making it available for

− tem comprises 4 main circuits:

1. cooling tower set for

2. cooling tower set where it is cooled, and returned to the turbine

3. icated cooling tower set where it is cooled, and returned to the chemical plant.

5.2 Overview of the Fresh Water Treatment and Supply System In summary the fresh water treatment and supply system features the following key elements:

− The raw fresh water is pumped to the mill via a 35 km pipeline from the Trevallyn Dam. Despite being of reasonably good quality, the water must be chemically treated and filtered before it can be used in manufacturing of bleached market pulp. Other users requiring high water quality are the boiler feed water make-up plant and the chemical plant.

− The design capacity of the FWTP is 100 000 kl/d.

− The average FW-consumption is about 72135 kl/d and the maximum continuous consumption about 80150 kl/d.

− The main unit operations in the treatment plant are: − Chemical mixing; − Flocculation;

− Flotation/Clarification;on; − Rapid sand filtrati

r basin − Mill wate− Pumping

− Potable water (for use in offices, rest rooms, wash rooms and canteens in the mill area) will be taken from the existing potable water supply.

5.3 Overview of the Cooling Water System In summary the cooling water system features the following key elements:

− Mill operations rely upon the use of water to control the heat balance within a number of areas of the plant: eg (i) fibre linerecovery area and (iv) steam and power area

Freshwater consumption of the mill can be minimised by recirculating the water that is used for controlling the heat balance through an evaporative cooling tower system. It reduces the temreuse.

The cooling water sys

Warm water from heat exchangers at the fiber line, chemical recovery, and power boiler areas is collected and sent to the maincooling and subsequent reuse at the cooling positions.

Warm water from the turbine condenser of the power plant is collected and sent to No. 1condenser.

Warm water from the chemical plant is collected and sent to a ded

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is issue is set out at

4. Fresh mill water will be used at dedicated heat exchangers in the secondary heat system of the mill to prepare the required amount of warm and hot process water. Any excess amount of warm and hot process water produced will be used as make-up water in the closed circuit cooling water systems instead of fresh water

− With this arrangement the net cooling water consumption of the mill can be reduced to about 3-4 % of the gross consumption, which typically amounts to 200-300 kl/ADt of pulp depending on the energy concept of a pulp mill.

5.4 Overview of the Boiler Feedwater and Demineralised Water System In summary the boiler feedwater and demineralised water system features the following key elements:

− Steam generated in the boilers (power and recovery boilers) is used to:

− Power the turbo-generator to produce electricity; and

− Generate process steam (medium or low pressure) for the mill.

− To minimise the amount of freshwater used to generate the steam in the boilers the condensate that results from the use of the process steam is cleaned and reused.

− Freshwater, which has undergone a process of demineralisation, is used to supplement the water supply to the boilers to compensate for condensate losses that occur in the mill processes and in the filtration and ion exchange processes that are carried out before pumping to the boilers.

− The filtration and ion exchange processes (resulting in very small water losses) are extremely important to avoid the intrusion of salt into the boiler system – which can cause corrosion and major damage.

− emineralisation plants are: The design capacities of the feed water and d20 − Feed water plant, l/s 2 x 1

− Demineralisation plant, l/s 120

5.5 Overview of the Raw Effluent Loads My estimates of raw effluent loads have been based upon:

− (i) design criteria and principles for the pulp mill, which correspond to commonly accepted engineering practice in the modern pulp mill industry, (ii) publicly available environmental emission data of existing, modern pulp mills , and (iii) Poyry’s data of emissions provided by the operating mills and equipment suppliers. This information is fundamental to developing the mill wide material and energy balances, which in turn are the basis of my estimation of effluent loads and sludge generation.

− The type and mix of wood feedstock proposed to be used for the mill. I have assumed that the pulp mill will produce 1.1 million ADt/t per annum, and that a maximum of about 100 000 ADt/a of the total production will be bleached softwood kraft pulp made from radiata pine. The balance will be eucalyptus bleached hardwood kraft pulp. A more fulsome description of thAnnex X of Jaakko Pöyry’s report at Volume 7 of the draft IIS.

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− The use of a four-stage bleaching sequence – A/D-EOP-D1-D2. Under this scenario, the main bleaching chemical in the D stages is chlorine dioxide. The acid stage (A/normal or hot) is utilised only during the eucalyptus pulp production. The Poyry report (at page 54 of Volume 6) also proposes that Gunns have the flexibility of using hydrogen peroxide instead of chlorine dioxide in the D2 stage. The effluent loads I prepared for Annex V of Volume 7 were based on the use of chlorine dioxide in the D2 stage. I make some brief comments later in this statement on the environmental aspects of using hot A- and Do-stages and hydrogen peroxide in the D2 stage (should Gunns ever pursue this option).

− The resulting raw effluent loads were also compared with the measured loads of recent ECF pulp mills to verify the models against corresponding emissions from operating mills. The compliance with the practical data is acceptable.

− In addition, my presentation takes into account the latest environmentally relevant information submitted to Gunns by the vendors of the main machinery. This information was not available at the time of the preparation of the DIIS. This data is, however, important to note since it includes environmentally important performance guarantees and detailed process solutions influencing the effluent loads.

5.6 Overview of the Effluent Treatment Plant

5.6.1 Effluent Treatment Plant – Design Overview I have undertaken the conceptual design of the effluent treatment plan described at sections 3.8.14 and 4.4 of Volume 6.

In summary, the effluent treatment plant will feature the following main unit operations:

− Pre-treatment, primary clarification and stabilisation of the raw effluent quality to remove coarse impurities, control effluent pH, remove suspended solids and to level down the variability of raw effluent quality. The latter will be achieved through the use of a large equalisation basin having a design hydraulic retention time of 12 hours. All these stages are necessary to safeguard the highest possible performance of the biological treatment process of the effluent;

− An emergency basin (volume about 100 000 kl) to prevent potential shock loads (such as high temperatures, high pH, high COD load, high TSS, etc. due to operational disturbance) from jeopardising the biological effluent purification process in the secondary treatment stage;

− A secondary treatment stage, where most of the dissolved organic matter and certain inorganic constituents in the raw effluent will be removed by a sequence of an anoxic reactor (chlorate removal), selector basins and the final aeration basin (COD and residual toxicity removal). The total volume of the basins is about 80 000 kl. In the selector and aeration basins the mixture of activated sludge and effluent will be aerated for about 20-35 hours (depending on the actual flow rate) to remove the biodegradable organic matter;

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− The final effluent is then clarified in two secondary clarifiers before being discharged into a surge basin and pumped to the effluent disposal pipeline

− Separated activated sludge (= return sludge) is pumped from the secondary clarifiers to the anoxic reactor and selectors and to the aeration basin on a continuous basis to maintain a sufficiently low food to micro-organisms ratio (= F/M-ratio) in the secondary treatment stage to achieve high treatment efficiency.

5.6.2 Validation of Final Effluent Loads I have reviewed and double-checked the description of the treated effluent loads contained in Annex V in Volume 7 and Appendix 3 of Appendix 15 (in Volume 15) of the draft IIS.

I have verified this data, and set out my calculations and assumptions for this verification at Attachments 2 and 3. This data is based on the use of the four stage bleaching sequence, being A/D0-EOP-D1-D2.

I note the draft IIS also contemplates the potential to use hot A and Do-stages and hydrogen peroxide at the D2 stage instead of chlorine dioxide. If these were to occur, the AOX and chlorate in the effluent will be reduced further. More information about this issue is set out in Attachments 2 and 3.

The final effluent load validation also explains;

− The characteristics and values of the final effluent control parameters as defined in the RPDC guidelines;

− The likely variability of the final effluent loads as a function of pulp production, wood raw material, start-up and shut-down situations, and production disturbance situations due to possible failure of machinery, equipment, or process controls, and human errors;

− Final effluent loads of resin and fatty acids and other wood extractives.

5.7 Impacts of Possible Process Upsets and Equipment Breakdown on Effluent Loads

Annex V (at page 11) of Volume 7 includes graphs depicting variations in the effluent discharged from the bleached eucalyptus kraft pulp mill in Thailand, on which I have worked in a number of contexts for more than 15 years as follows:

− Pre-feasibility and feasibility studies;

− Conceptual, basic, and detailed engineering design;

− Environmental impact assessment; and

− Advising on minimising both gaseous and liquid emissions from the pulp mill, including most recently the required upgrade of the effluent treatment plant due to an increased pulp production capacity of the mill.

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In undertaking the latter task, I have analysed about two years of daily effluent monitoring data from the mill. The data indicates that little variation in final effluent quality has occurred over the two year period, even though the raw effluent loads have varied quite substantially as the result of shut downs, start-ups, process upsets, and the increase of the raw effluent COD due to achieved higher production capacity.

Because both the Thai mill and the Bell Bay mill basically feature comparable raw material, processes and production equipment, it can be concluded that there is a reasonably reliable correlation between the effluent loads and volumes of the Thai mill and the estimated effluent loads of the proposed Bell Bay pulp mill.

Consequently, the impact of start-ups, shut-downs, and other possible upset conditions on the variability of the Bell Bay Mill effluent is further discussed in Attachment 2 and summarised in item 6.1 below.

5.8 Effluent Disposal The final effluent disposal system including the surge basin, final effluent pumping and the effluent pipeline to Bass Strait has been outlined in the Pöyry Report at Volumes 6 and 7 of the DIIS. Details of the pipeline routing to from the mill to the Five Mile Bluff beach and the ocean outfall pipe, including a multi-port diffuser part, to the Bass Strait have also been presented in the DIIS, Volume 6.

5.9 Overview of Primary and Secondary Sludge Handling

− I have estimated the amounts of the primary and secondary effluent sludge based on the relevant design data and fibre, suspended solids, and COD balances of the pulp mill and its effluent treatment plant, respectively

− The primary sludge (avg. amount about 45 t DS/d) collected from the bottom of the primary clarifier will be dewatered to about 40 % dry solids, mixed with the wood derived biofuel, and incinerated in the power boiler.

− The secondary sludge (avg. amount about 15 t DS/d) will be thickened and dewatered. The dewatered sludge is mixed into the strong black liquor at the evaporation plant and incinerated together with the black liquor in the recovery boiler.

5.10 Overview of Noise Emissions and Noise Abatement The design principles for mitigation noise emissions from the pulp mill are described at section 4.7 of Pöyry’s report at Volume 6, and are:

− Selecting equipment with guaranteed noise limits, which should preferably be less than 85 dB(A).

− Use noise attenuation measures and absorbers.

− Insulate individual items of the plant and machinery that are the source of high (ie, above 85 dB(a)) noise emissions.

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ing and drying machine Lime Kiln d Demineralization Plants Facilities

− Locate the noisiest machinery (i.e., above 95 dB(A) in dedicated, noise-insulated spaces.

− Use machine foundations that absorb noise and vibrations.

The noise levels at Annex XI of the DIIS were retrieved from the Pöyry database. The given noise levels were measured at a new (less than 5 years old) kraft pulp mill in Finland.

6 SUBMISSIONS TO THE DRAFT INTEGRATED IMPACT STATEMENT I have reviewed the submissions made in this case that are related to my area of expertise and have identified those submissions that raise issues that require further substantive explanation or clarification beyond what is included in Volume 6 and 7 of the Draft IIS. I deal with those matters in this section of my statement.

In addition to submissions raising substantive matters, many submissions raising incidental issues or drafting queries were referred to me for comment, often arising from the text of Volumes 1 to 4 of the Draft IIS. I have considered these matters and provided my comments in a separate document and understand that these matters will be dealt with by others.

6.1 Raw and Final Effluent Loads Some submissions have made comments or sought further clarification on the main sources of liquid effluents, control strategies and variability of effluent loads in different stages of construction.

6.1.1 Sources of Liquid Effluents The sources of liquid effluents in the pulp mill have been presented in the EE-diagrams. The data given in the EE-diagrams are based on the preliminary engineering of the mill in mid 2005.

The calculated departmental liquid emissions based on the MWWB and the OMB during the average production of BEKP (at 3143 ADBt/d) are summarised in the following tables. The effluent flow codes in the tables refer to the following departments:

− F1 Chip storage and screening berline (incl. O2-delignification) − F2 Unbleached fi

− F3 Bleach plant − F4 Bleached pulp screen− R1 Evaporation Plant − R2 Recovery Boiler − R3 Causticizing and − P1 Power Boiler, Feedwater an− P2 Turbo-generator − P3 Steam Condensate Losses− C1 Chemical Plant − U1 Workshops − S1 Offices, Social

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ant

− Sl2 Biosludge handling −− ess an o th ration bas of the WWTP− E3 Final P c fflue the Sea

− W1 Fresh Water Treatment Pl− W2 Cooling Towers − StW Stormwater − Sl1 Primary sludge handling

E1 Raw Process Effluent Flow to the WWTP E2 Proc d Sanitary Effluent t e ae in ro ess E nt to

2. Breakdown f ge fluent rin dy State O ration o Avera Liquid Ef Loads du g Stea pe Parameter Effluent Flow Code F1 F2 F3 F4 R1 R2 R3 Flow, kl/d 212 144 53677 843 174 144 720 TSS, kg/d 1122 4 1571 10697 6370 9 7 432 BOD5, kg/d in F3 673 4052 31272 incl. 8061 1571 n/a COD, kg/d 2019 11707 99684 incl. in F3 16641 4714 n/a AOX, kg/d 0 n/a 1453 incl. in F3 n/a n/a n/a Chlorate, kg/d 0 n/a 4762 incl. in F3 n/a n/a n/a CP

olour, kg CU/d 2 15 9857 /a 44 15 /a 4 3 2 n 9 3 n

TDS, kg/d 595 3007 98710 cl. in F3 1615 863 440 1 1 1 in 1 3 1TDIS, kg/d 42 4336 112028 cl. in F3 1 0 40 in 52 72 14TDOS, kg/d 2 2 in F3 1553 867 8668 incl. 11094 3143 n/a Parameter Effluent e Flow Cod P1 P2 P3 C1 W1 W2 U1 Flow, kl/d 834 incl.in P1 2920 991 1472 778 200 TSS, kg/d 27 incl.in P1 n/a 9 6916 39 20 BOD5, kg/d n/a incl.in P2 n/a n/a n/a n/a n/a COD, kg/d n/a incl.in P3 n/a n/a n/a n/a n/a AOX, kg/d n/a incl.in P4 n/a n/a n/a n/a n/a Chlorate, kg/d n/a incl.in P5 n/a n/a n/a n/a n/a CP

olour, kg CU/d /a cl.in P6 /a /a /a /a /a n in n n n n n

TDS, kg/d 17 cl.in P7 /a 974 15 555 0 4 in n 2 5 1 4TDIS, kg/d 417 incl.in P8 n/a 74 5 55 29 51 15 40TDOS, kg/d P9 n/a incl.in n/a n/a n/a n/a n/a Parameter Effluent ow Code Fl S1 StW l1 2 E1 E2 E3 S SlFlow, kl/d 75 0 63109 8 4 63100 6306 8 31TSS, kg/d 30 0 41392 9500 877 4139 1892 3 12BOD5, kg/d 23 0 45652 40361 605 COD, kg/d 45 0 134810 120549 25315 AOX, kg/d n/a 0 1453 1162 436 Chlorate, kg/d n/a 0 4762 3572 119 Colour, kg PCU/d n/a 0 31473 31473 31473 TDS. kg/d 47 0 235778 230219 147834 TDIS, kg/d 9 0 124597 124597 124597 TDOS, kg/d 37.5 0 111181 105622 23237

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6.1.2 Control Strategies e systems to effectively recover, regenerate,

− leable product;

dissolved organic matter from

− oses;

e

Due to variations in the production level and performance of the above, relatively in the amount and

quality of the liquid effluents.

To

ment, and recovery systems. All storage tanks in these

− e fiberline are inherently very effective since fiber

as are

also recycled effectively to save fresh

In the chemical plant all process chemical processing, storage, and handling areas will be provided with spill monitoring, containment, and recovery systems.

Liquid EffluentA modern pulp mill features extensivand/or recycle;

Fibre, which is the sa

− Black liquor containing cooking chemicals andwood raw material;

Water both for process and cooling purp

− Cooking chemicals contained in black liquor through a regeneration process in thchemical recovery area of the mill; and

− Burnt lime used in the white liquor preparation process (recausticizing) trough a regeneration process in the lime kiln.

complex recovery and recycling systems there is also variability

mitigate these variations the following strategies are adopted:

Black liquor recovery and handling systems and department floor drains at the unbleached fiberline and evaporation plant-recovery boiler area are provided with spill monitoring, containareas are bunded to prevent any overflows or equipment failures to result in a spill to the effluent drains. The system is described in more detail in Attachment 2 of this Witness Statement;

The fibre recovery systems in this the saleable product. In addition, even the rejects from the unbleached and bleached screening and cleaning departments are collected, dewatered, and used as biofuel in the power boiler; and

− Cooking chemical and lime mud spills in the causticizing and lime kiln arecontrolled with the similar type systems as used in controlling black liquor spills; and

− Sufficient spare capacity (about 10 % of balance capacity) is included in the evaporation plant and in the recovery boiler to handle the collected spills and return them to the cooking chemical system.

In the bleach plant and drying machine areas the spill control systems focus on the monitoring and recovery of possible fibre spills due to possible overflows or equipment failures. The process filtrates are water. The excess bleaching filtrates containing reaction products of bleaching chemicals and dissolved organic matter from the process are monitored, but no recovery of these liquors is so far planned.

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6.1.3 Variability of Raw Effluent Loads Despite the comprehensive BAT-level control systems in place the variations of raw effluent loads are unavoidable.

The normal variations are due to the production level of the mill and way the water balance is managed. These two factors define the normal variability of effluent amounts.

The third factor influencing the raw effluent loads is the variability of the suspended and dissolved solids concentration in the combined effluent. The concentrations are influenced by the unavoidable losses during the normal operation and occasional losses due to spills, which may be caused by equipment failure, process control problem, or operator error or negligence.

The normal variability of the raw effluent load has been discussed in Attachments 2 and 3. The balance COD with no allocation to spills is 38.5 kg/ADt, while the average specific COD- load used in effluent load calculations is 44.5 kg/ADt. Furthermore, the design COD-load used in the design of the organic loading capacity of the WWTP is 53.6 kg/ADt. Hence, the design specific load is about 40 % higher than the balance load and about 20 % higher than the average load.

In addition to the above variability, process and equipment problems in start-up and shut-down situations may result in occasional peaks in specific load. Such peaks are normally due to black or cooking liquor spills due to foaming and tank overflows, wash-downs, or emptying of process equipment. The impacts of such incidents are usually observed as the variation of TSS and TDS concentrations in the raw effluent with no major changes in the effluent amount. This is due to very high TDS concentration in liquors. As an example, the COD of weak black liquor is typically about 100 000 g/kl. This implies that a mere 10 l/ADt additional spill of weak black liquor (total amount about 10 000 l/ADt) can increase the total raw effluent COD by about 50 mg/l. Due to this fact the COD is by far the best general indicator of the environmental performance of the pulp mill effluent system.

The aggregate impact of process, equipment, and human factors on the variability of raw effluent loads in various operational situations can best be analysed by analysing the daily effluent monitoring records of existing modern pulp mills. The data presented in the following tables and figures are based on statistical analysis of monitoring data from September 2003 to March 2006 of a modern BEKP mill in Thailand.

The period is of particular interest, because in late 2004 the mill was upgraded to produce about 40 % more pulp than the original design of the mill. This implies that the period covers a steady state operation period of 14 months, a shut-down, start-up, commissioning, and ramp-up period of about 10 months, and a production trimming period of about 6 months.

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Figure 5/1a Monthly COD Loads of a Modern BEKP Mill. (Standard Deviations: RE;FE 15;14 % of average monthly COD-load)

Figure 5/1b Monthly COD Loads of a Modern BEKP Mill. (Standard Deviations: RE;FE 41;36.3 % of average monthly COD-load)

Figure 5/1c. Monthly COD Loads of a Modern BEKP Mill. (Standard Deviations: RE;FE 13.0;19.9 % of average monthly COD-load)

Monthly Effluent Loads in September 2003-October 2004

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Figure 5/1c Monthly COD Loads of a Modern BEKP Mill. (Standard Deviations: RE;FE 15;17 % of average monthly COD-load)

Table 5-1 Average Variability of Raw Effluent COD in September 2003-March 2006

Raw Effluent COD, mg/lPeriod 09/03-10/04 12/04-10/05 11/05-03/06Maximum 2929 4297 2809Minimum 1129 1151 1466Average 1724 1922 2084STDEV 364 604 304STDEV% 21 32 15

Figure 5/2a Example of the Variability of Raw Effluent COD during Normal Operation (Period 09/03-10/04), Commissioning and Ramp-up Stage Period 12/04-10/05), and Production Stabilisation Stage (11/05-03/06)

0 1000 2000 3000 4000 5000

COD, mg/l

Maximum

Minimum

Average

STDEV

STDEV%

Raw Effluent COD in September 2003-March 2006

11/05-03/0612/04-10/0509/03-10/04

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Table 5-2 Average Variability of Final Effluent COD in September 2003-March 2006

Period Sep03-Oct04 Dec04-Oct05 Nov05-Mar06Maximum 285 776 583Minimum 151 171 218Average 209 336 294STDEV 35 145 83STDEV% 17 40 25

Figure 5/2b Example of the Variability of Final Effluent COD during Normal Operation (Period 09/03-10/04), Commissioning and Ramp-up Stage Period 12/04-10/05), and Production Stabilisation Stage (11/05-03/06)

Based on the above analysis of real monitoring data of a modern BEKP mill, the following general conclusions can be drawn:

Typical standard deviation of effluent quality (as % of average COD- concentration)

0 200 400 600 800

COD, mg/l

Maximum

Minimum

Average

STDEV

STDEV%

Daily Final Effluent COD in September 2003-March 2006

Nov05-Mar06

Dec04-Oct05

Sep03-Oct04

− Start-up, Shut-down, and Commissioning Periods: 30-40 %

− Production trimming period: 20-25 % − Normal operation period: 15-20 %

There seems not to be any major differences in the standard deviations expressed as % of the arithmetic average between the raw and final effluent. However, the absolute standard deviation of the final effluent quality as COD is only about 20 % of the raw effluent.

These figures imply that the typical %-tile distribution of effluent loads is as follows (monthly average marked as 100):

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Start-up, Commissioning, and Ramp-up Period

− Monthly average: 100

− 90 % of daily values: less than 138-150 (~ Monthly/Annual ratio) − 97.5 % of daily values: less than 160-180 (~Daily/Monthly ratio) − 99.9 % of daily values: less than 190-220 (~ Short-term/Monthly ratio)

Production Trimming Period

− Monthly average: 100

− 90 % of daily values: less than 125-131 (~ Monthly/Annual ratio)− 97.5 % of daily values: less than 140-150 (~Daily/Monthly ratio) − 99.9 % of daily values: less than 160-175 (~ Short-term/Monthly ratio)

Normal Operation

− Monthly average: 100

− 90 % of daily values: less than 119-125 (~ Monthly/Annual ratio) − 97.5 % of daily values: less than 130-140 (~Daily/Monthly ratio) − 99.9 % of daily values: less than 145-160 (~ Short-term/Monthly ratio)

Clarification of Variability of the Final Effluent Quality

Figure 5/3 presents the variability of the monthly average final effluent COD-concentration during the 2.5 years of monitoring data of the example mill discussed above.

nal Effluent COD under Normal, Start-up, and

The impact of the start-up and production phase after the upgrade of the mill is clearly shown. The total time required to achieve a more steady state operation was about 1 year.

Figure 5/3 Example of the Variability of FiProduction Trimming Phases

Monthly Final Effluent COD in September 2003-March 2006

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ormal operation, start-up and ramp-uction trimming phases of the mill.

n04-p-Up (May05-Oct05), and Production Trimming

The statistical analysis of the variability of the final effluent concentrations was presented above. More detailed data on the daily variability of the FE-COD concentrations is presented in table 5-4 for the nup, and prod

Table 5-4 Variation of Daily COD-concentrations in Final Effluent during Normal (JaJun04), Start-up and Ram(Nov05-Mar06) Phases Monitoring Statistics of FE COD-Concentrations, g/kl

Jan04 Feb04 Mar04 Apr04 May04 Jun04Max.daily 328 270 263 288 272 259Min.daily 158 170 113 154 164 160Average 228 229 180 178 208 201STDEV 48 22 33 25 32 2

May05 Jun05 Jul056

Aug05 Sep05 Oct05Max.daily 530 777 344 1656 771 660Min.daily 201 180 197 191 119 167Average 280 332 264 526 368 320STDEV 74 141 39 315 145 118

Nov05 Dec05 Jan06 Feb06 Mar06Max.daily 1033 837 451 337 583Min.daily 224 226 216 221 218Average 348 360 272 260 294STDEV 189 143 44 23 83

6.2 ns have raised consideration of the possibility of land disposal of the

essive

Handbook 60] “Used only on well drained soils with low cation exchange capacity”.

Land Disposal of the Final Effluent Some submissioliquid effluent.

This is in my opinion not practical in this case.

To use effluent as irrigation water a necessary precondition is the existence of environmental conditions, which are conducive to mitigating the accumulation of salt, contained in the effluent, on the soil to acceptable levels. To safeguard that no excessive salt levels in the soil water at the bottom of the root zone are established, sufficient leaching (by rainfall) is required to flush the salt away. Another important target of leaching is the protection of soil structure against impacts of excamounts of exchangeable sodium in the soil which may result in alkali soils.

Figure 5/4 shows a US Department of Agriculture graph describing the classification of irrigation waters as function of sodium adsorption ratio (SAR) and electrical conductivity of water. The position of the Bell Bay Mill effluent in this graph suggests that the effluent could be [ref. USDA

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Figure 5/4 Suitability of the Bell Bay Pulp Mill Effluent for Irrigation according to the USDA Classification of Irrigation Waters

December, 200619

Classification of Irrigation Waters (USDA Handbook No. 60)

0 2 5 10 15 SAR 20

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ACCEPTABLE RANGE LIMITED RANGE

UNACCEPTABLERANGE

There are few unbleached and bleached pulp mills in the world which are using the biologically treated effluent as irrigation water.

Visy’s integrated unbleached kraft pulp and kraftliner mill in Tumut, NSW is one of those mills. Since the Tumut mill does not have any bleach plant it is possible to operate the water system of the mill on an almost closed cycle basis. The main sources of excess effluent are actually secondary condensates from the black liquor evaporation plant and the cooling tower blowdown.

There are three bleached kraft pulp mills in operation in Thailand which are using their biologically treated effluent as irrigation water on their eucalyptus plantations. There is also one mill in South Africa using its biologically treated effluent as irrigation water at their pasture land and tobacco plantations.

The typical average irrigation intensity used by all these BKP mills is about 3 mm/d. This implies that at the design effluent load of the Bell Bay Mill the theoretical minimum required irrigation area would be about 2000 ha. However, the actual requirement would be at least twice the theoretical assuming that the maximum length of the growing season is about 6 months in NE Tasmania.

In order to store the water over the wintertime, a winter storage, say about 13 Gl should be built. The required area would probably be about 200 ha.

It is believed that the construction of the required irrigation system is as such hardly possible in Tasmanian conditions.

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6.3 Benchmarking of the Final Effluent Loads against the RPDC and International BAT Guidelines

The benchmarking of the final effluent loads against the RPDC guidelines, the European Union BAT-guidelines, and a number of guidelines enforced to recent BKP mills in the world, has been presented in Attachment 3 of this Witness Statement.

Table 5-5 below presents the expected compliance of the Bell Bay mill final effluent with the RPDC guidelines. The loads given in the table refer to monthly averages except for TCDD, TCDF, and trihalomethanes which are absolute concentration limits applicable to any sample analysed.

Based on the typical variability of the annual, monthly, and daily average loads it is estimated that the normal range for effluent flow, BOD, COD, colour, TDS, and TSS between monthly, annual averages and daily averages are normally as follows:

− Annual average = 0.8---1.15 * Monthly average − Daily average: 0.6---1.5 * Monthly average

The specific AOX and chlorate loads depend exclusively on the actual charge of chlorine dioxide and the actual removal efficiency in the WWTP. It is estimated that these two combined could result in the following ranges:

− Annual average: 0.8---1.15 *Monthly average − Daily average: 0.7---1.2 *Monthly average

Table 5-5 Comparison of the Estimated Final Monthly Average Effluent Loads of the Bell Bay Mill with the RPDC Guidelines

Parameter Load, kg/ADBt

Load, t/d Concentration, mg/l

RPDC-Guideline

Effluent Flow 20290 63770 N/A N/A TSS 0.4 1.27 20 2.6 kg/ADt

BOD5 0.21 0.66 11 2.1 kg/ADt COD 9.45 29.7 466 20 kg/ADt AOX 0.14 0.44 6.8 0.2 kg/ADt Colour 10 31.4 493 42 kg/ADt TDS 45.7 143.7 2253 N/A Chlorate 0.063 0.197 3.1 < 10 mg/l Chlorinated Low-MW Compounds

< 0.0005 < 0.00157 < 0.025 < 2 mg/l (as THM)

PCDD/PCDF < LOR < LOR < LOR <10 pg 2,3,7,8-TCDD/l <30 pg 2,3,7,8-TCDF/l

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6.4 Response to Submissions Requiring Clear Demonstration that the Design of the Effluent Treatment Plant is based on the “Worst Case Scenario” and Covers all Production Options and Wood Raw Materials The design criteria of the Effluent Treatment Plant has been described and discussed in Attachment 2 of this Witness Statement.

It is confirmed that the design of the ETP is based on the “Worst Case Scenario” and covers all production options and wood raw materials.

The design criteria and the estimated raw effluent loads during the normal and upset conditions are presented in the following table (Table 5-6).

Table 5-6 Resilience of the Bell Bay WWTP against the Estimated Variability of Raw Effluent Flow and Organic Load

Theoretical Situation at Bell Bay WWTP based on the Example Mill Statistics: • Variability of Hydraulic Loading:

• Average raw process effluent flow: 63932 kl/d

• Standard deviation: max. 17 % or 10868 kl/d

• 90 % of all values less than 78197 kl/d (= 315 d/a)

• 97.5 % of all values less than 85668 kl/d (= 341.25 d/a)

• 99.9 % of all values less than 96536 kl/d (= 349.65 d/a)

• Maximum continuous capacity of the WWTP at normal hydraulic loading: 93627 kl/d

• Variability of Raw Effluent COD:

• Average Raw Effluent COD 139.9 t//d

• Standard Deviation: max. 18 % or 25.2 t/d

• 90 % of all values less than 173.0 t/d ( 315 d/a)

• 97.5 % of all values less than 190.3 t/d (341.25 d/a)

• 99.9 % of all values less than 215.5 t/d) (349.65 d/a)

• Max. continuous COD-removal based on the design oxygen transfer capacity : 200 t/d

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Figure 5/5 Comparison of the Organic Loading Capacity of the Bell Bay WWTP with the Estimated Variability of Raw Effluent Loads

December, 200611

Estimated Percentile Distribution of the Raw Effluent COD-Load

RE-Loadt COD/d

125

150

175

200

225

Average

60 70 80 90 97.5 99.9

Estimated %-tile Distribution of RE-COD Loads

97.5 %-tile

90 %-tile

99.9 %-tileCOD-Capacity at 80 % Removal Efficiency

Figure 5/6 Expected Development of Pulp Production of the Bell Bay Mill from the Start of Commercial Production

December, 20062

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Month % of Design1 403 606 70 9 7512 8015 8518 9021 9524 100

Impacts of Start-ups, Shut-downs, and Process Upsets on Effluent Loads

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Figure 5/7 Estimated Redundancy Factors of the Bell Bay WWTP during the Start-up and Production Ramp-up Phase of the Mill

December, 20063

Impacts of Start-ups, Shut-downs, and Process Upsetson Effluent Loads

Designed Tolerance Limits of the WWTP Against Process Upsets and Spills during the Mill Start-up

1. Design Loading of the WWTP• Hydraulic, kl/d 77947+15680 kl/d (= 93627 kl/d)• Organic, t COD/d 182835 +8927 kg/d (= 191762 kg/d)

2. Tolerable Hydraulic and Organic Load Factors during the Production Ramp-up Phase without Adverse Impact of the WWTP Performance

Time from start-up Max.Target Production Redundancy Factor(Months) (t/d) (Hydraulic) (Organic)1 1400 2.93 3.003 2100 2.00 1.956 2400 1.80 1.759 2620 1.69 1.6012 2800 1.62 1.5018 3143 1.47 1.3424 3492 1.33 1.20

Based on the calculations presented in Figures 5/5 and 5/6 it is concluded that the WWTP features a sufficient redundancy during the start-up and production ramp-up phase. For instance, during the first 6 months of operation the WWTP would be able perform as planned even in case the specific effluent amount was 1.75-3 higher than the average figure (i.e. up to about 60 kl/ADt) and the specific COD 1.8-2.9 times higher than the average figure (i.e. up to about 130 kg/ADt).

6.5 Generation of Chlorate in ECF-Bleaching and its Removal in Effluent Treatment Plant

In the Beca AMEC October 2006 report additional clarification of the generation of chlorate in ECF bleaching presented in the DIIS was requested. This issue is discussed in detail in Attachment 3 and can be summarised as follows:

The generation of chlorate per tonne of pulp depends primarily on the charge of chlorine dioxide in bleaching. The formula used for chlorate formation is that each kg of chlorine dioxide generates about 0.235 kg chlorate. At the preliminary design stage the active chlorine charges of 40 kg/ADt of BEK pulp and 47 kg/ADt of BSK pulp were used. The corresponding original chlorate generation is about 3.6 kg ClO3/ADt and 4.2 kg/ADt, respectively.

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In the original effluent models from early 2005 the formation of chlorate was expressed as equivalent amount of chlorate-chlorine by multiplying the actual ClO2-charge by factor 0.1. This inaccuracy has been corrected and the resulting true chlorate emission has been used in the subsequent hydrodynamic modelling.

However, based on the process guarantees currently available from the bleach plant suppliers it is probable that the actually required charges of chlorine dioxide are substantially less, or within the range of 21-35 kg ClO2 (as act.Cl)/ADt of BEK pulp. This would imply that the chlorate generation during the BEKP production could range from about 1.9 kg/ADt to about 3.1 kg/ADt. During the pine pulp production the maximum chlorate generation is likely to be at about 4.2-4.4 kg/ADt.

The removal of chlorate in the waste water treatment plant is also discussed in more detail in Attachments 2 and 3. Based on the data available from modern waste water treatment plants in Sweden, the achievable chlorate removal efficiency is up to 99 %. However, a more conservative figure of 98 % has been used for the Bell Bay Mill.

6.6 Overall Material Balances In the Beca AMEC October 2006 report additional clarification of the Overall Material Balances (OMB) presented in the DIIS was requested.

The Overall Material Balances presented in the DIIS are based on the main design data, process concepts, wood raw material, and process chemical consumption figures developed during the pre-engineering phase of the mill in 2005.

The OMB models developed are steady state models using the above data as input values.

However, the mill concept has been developed further during the subsequent preparatory engineering phase including the binding technical designs of the mill departments and consumption data of various process utilities from machinery suppliers. In general, this data seems to result in improvements in overall environmental performance of the mill.

Under these circumstances it is appropriate that the OMB’s presented in the DIIS are updated for the final IIS to correspond to the current status of the pulp mill project and the RPDC Final Scope Guidelines.

6.7 Mill Wide Water Balances In the Beca AMEC October 2006 report corrections and clarifications of some inconsistencies noticed in the Mill Wide Water Balances (MWWB) presented in the DIIS were requested.

The Mill Wide Water Balances presented in the DIIS are based on the main design data, process concepts, wood raw material, and process chemical consumption figures developed during the pre-engineering phase of the mill in 2005.

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The MWWB models developed are steady state models using the above data as input values. The observed “inconsistencies” in various MWWB’s are primarily due to the production level and type of pulp produced. In general, a mill which is designed to produce 3492 ADt/d pulp inherently uses somewhat more water per tonne of pulp when producing less pulp. This is due to a number of water consumption positions, which feature a constant water demand per unit of time irrespective of the actual production level. Typical examples of such positions are pump, agitator, equipment, and vacuum pump seals.

Other factors causing “inconsistent” variability are different water inputs due to different process chemical requirements. It should also be noted that a substantial amount of water is introduced to the pulp mill with wood raw material, since the normal moisture contents of fresh wood is about 50 %. In wintertime the moisture can be even higher. The moisture contents of wood combined with different pulp yields of eucalyptus and pine chips can alone result in a 1-1.5 kl/ADt difference in the water balance.

However, the mill concept has been developed further during the ongoing preparatory engineering phase including the binding technical designs of the mill departments and

consumption data of fresh water from machinery suppliers. In general, this data seems to result in improvements in overall environmental performance of the mill.

Under these circumstances it may be appropriate that the MWWB’s presented in the DIIS are updated for the final IIS to correspond to the current status of the pulp mill project and the RPDC Final Scope Guidelines.

6.8 Revision of the Environmental Emission Diagrams to Include the Performance Ranges in Addition to Long Term Average Data

In the Beca AMEC October 2006 report additional clarification of the Environmental Emission Diagrams (EE-diagrams) presented in the DIIS was requested.

The EE-diagrams presented in the DIIS are based on the main design data, process concepts, wood raw material, and process chemical consumption figures developed during the pre-engineering phase of the mill in 2005.

The EE-diagrams developed are steady state models using the above data as input values. They are based on the OMB models and highlight the types and amounts of gaseous, liquid, and solid emissions as real material flows per annum released from the mill to the environment. These flows are then converted into the normally used pollutant parameters in the subsequent descriptions of liquid effluent loads, gaseous emissions, and solid wastes. Descriptions of the average emissions and their estimated ranges are presented only for the normal environmental parameters, like TSS, COD, BOD, NOx, TRS, SOx, etc., which provide the required basis for the environmental impact assessments.

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However, the mill concept has been developed further during the on-going preparatory engineering phase including the binding technical specifications of the mill departments and consumption data of various process utilities from the machinery suppliers. In general, this data seems to result in improvements in overall environmental performance of the mill.

Under these circumstances it may be appropriate that the EE-diagrams presented in the DIIS are updated for the final IIS to correspond to the current status of the pulp mill project and the detailed requirements of the RPDC Final Scope Guidelines.

7 DECLARATION I have made all the inquiries that I believe are desirable and appropriate and no matters of significance which I regard as relevant have, to my knowledge, been withheld from the Commission.

Hannu Jäppinen 29.1.2007

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Attachment 1 Curriculum Vitae

Pöyry Forest Industry Oy Jaakonkatu 3 FI-01620 Vantaa Finland Domicile Vantaa, Finland Business ID. 1071411-1

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Curriculum Vitae December 2006 1 (5)

HANNU JÄPPINEN

Born 1942, citizen of Finland

Education

M.Sc., Agriculture and Forestry University of Helsinki, 1967 Diploma in Environmental Science and Technology. Delft University of Technology, 1973

Current Position

Senior Consultant

Languages

Finnish, English, Swedish, German

Specialty

Pulp and paper process engineering/integrated production and pollution control planning, environmental assessment, auditing, and management, environmental pollution control technology, water treatment technology.

Pöyry Experience

Mr Jäppinen joined the Jaakko Pöyry Group in 1974 as a Process Engineer. In 1984-1992 he worked as Manager of the Environmental Protection Departments both of Jaakko Pöyry Engineering and Jaakko Pöyry Consulting Oy. In 1992 he was appointed Director of Environmental Projects in the Asia-Pacific region of Jaakko Pöyry (Thailand). In 1997 he rejoined Jaakko Pöyry Consulting Oy as a Senior Consultant in Helsinki. In 1999 he was appointed Senior Consultant of JP Management Consulting (Asia-Pacific) in Singapore responsible for the pulp and paper technology and environmental projects in the Asia-Pacific region. Mr Jäppinen has been in charge of a wide range of environmental issues related to forest industries, including environmental engineering and management, as well as environmental audits and impact assessments of forest resources development projects. He has travelled extensively in Europe, Asia, Africa, Australia, North and South America gaining in-depth knowledge of practical environmental engineering and management in the forest industry.

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H Jäppinen 2 Major Projects

2006-2007 2006 2005-2007 2004-05 2003 2002

Mr Jäppinen has been involved in the following selected studies and projects: StoraEnso, Finland Pre-feasibility Study for a Greenfield BEKP Mill in Guangxi Province, PRC. Area Manager, Environmental Protection. Affinity Equity Partners (HK) Ltd., Hong Kong Technological, Environmental, and Economical Due Diligence of the Existing and Planned Pulp and Paper Mills of Tiger Forest and Paper Group in Hunan Province, China. Gunns Ltd., Australia Pre- and Basic engineering of a Market Bleached Kraft Pulp Mill in Tasmania. Environmental Expert Gunns Ltd., Australia Pre-feasibility Study of a Market Bleached Kraft Pulp Mill in Tasmania. Environmental Expert Australian Paper, Maryvale Mill, Australia Water and Effluent Management Plan of the Maryvale Pulp and Paper Mill. Process Expert Norske Skog Industry, Albury Mill, Australia Process Engineering of the Water and Effluent System and the Expansion of the Existing Activated Sludge Plant for the PM 1 Rebuild Project. Process Expert Hebei Pan Asia Long-teng Paper Co., Ltd., Peoples Rebublic of China Due Diligence of a Greenfield DIP-Newsprint Mill in Hebei Province, PRC. Area Manager Confidential Client Assessment of Site Resources and Environmental Issues for a Proposed World-scale Pulp and Paper Mill Integrate in Thailand. Project Manager Norske Skog Industry, Albury Mill, Australia Water and Effluent Optimisation Study for the Expansion of the Newsprint Mill in Albury. Environmental Expert Visy Pulp and Paper Pty., Ltd., Australia Technical Odour Audit and Operations Improvement Plan of Tumut Kraft Pulp Mill, Project Manager/Technical Expert Advance Agro pcl, Thailand Technical Odour Audit and Operations Improvement Plan of Pulp Mills # 1 and # 2. Project Manager/Technical Expert

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H Jäppinen 3

2002 2001 2000 1999 1998

UPM-Kymmene, Finland Feasibility Study of a Greenfield Kraft Pulp Mill in Peoples Republic of China. Area Manager/Environment and Infrastructure Thai Power Generating Co., Ltd., Thailand Environmental Impact Assessment of a 100 MW(e) Biofuel Fired Power Plant, Project Manager/Technology Expert 304 Service Co., Ltd., Thailand Environment Impact Assessment (EIA) of a 150 MW(e) Biofuel Fired Power Plant, Project Manager/Technology Expert Pan Asia Paper (Thailand) Co.,Ltd., Thailand Operations Improvement Plan of the Effluent Recycling and Treatment Plant of the Singburi DIP-Newsprint Mill, Project manager/Technical Expert Visy Paper Pty. Ltd., Australia Due Diligence of a Greenfield Integrated Kraftliner Mill for a Consortium of Financiers, Environmental, Infrastructure and Utilities Expert Warburg Dillon Read España, S.A. Spain Informe medio ambiental de nueve fábricas del Grupo Torraspapel, Project Manager Phoenix Pulp and Paper pcl, Thailand Environmental Performance Audit of the Pulp Mill; Audit Period January 1998– June 1999, Project Manager Shandong Huazhong Paper Co. Ltd. People’s Republic of China Technical Operations Evaluation and Development of an Action Plan for Water and Fibre Recovery of a Duplex Board Mill, Project Manager Torraspapel S.A., Spain Environmental Management Plan of La Montañanesa Pulp Mill, Project Manager The World Bank, USA, Ministry of Waters, Forest, and Environmental Protection, Romania. Pollution Abatement Project; Feasibility Studies on Seven Specific Industries in Romania, Project Supervisor. Confidential, USA/Canada Environmental Site Audit of Three Stone-Consolidated Pulp and Paper Mills in Canada, Project Advisor. Australian Paper, Maryvale Pulp and Paper Mill, Australia Audit of Maryvale Odour Control Systems, Project Manager

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H Jäppinen 4

1998 1997 1996-1997 1996 1974-95

April-Changshu Fine Paper Co. Ltd., P.R. China Basic Engineering and Procurement of the Fresh Water and Effluent Treatment Plants of a Fine Paper Mill in P.R. China, Area Manager. Enso Group, Finland Site Selection and Environmental Control Plan for a Greenfield Bleached Kraft Pulp Mill in Kalimantan, Indonesia, Area Manager. A.A. Pulp Mill No.3 Co., Ltd., Thailand Environmental Impact Assessment of a Bleached Kraft Pulp Mill in Thailand, Project Supervisor Phoenix Pulp and Paper pcl, Thailand Environmental Auditing of a Bleached Kraft Pulp Mill in Thailand (Audits implemented twice a year), Project Manager. A.A. Pulp Mill No.2 Co., Ltd., Thailand Environmental Impact Assessment of an Integrated Bleached Kraft Pulp and Fine Paper Mill, Project Manager. PT. Nityasa Prima, Indonesia Feasibility Study of a Greenfield Bleached Kraft Pulp Mill in Kalimantan. Assessment of Site Resources, Water Supply and Environmental Protection Measures, Area Manager. National Power Supply, Thailand Environmental Impact Assessment of a 2 x 150 MW(e) Coal Fired SPP Power Plant, Project Manager. Australian Paper Ltd., Australia. Medium-term Water and Effluent Management Plan of Maryvale Pulp and Paper Mill, Project Manager. Mr Jäppinen worked in and managed more than 20 long- and short-term projects in Asia, Europe, Africa, North America and Australia.

Other Experience

1967-74 1964-66

Mr Jäppinen worked for the Finnish National Board of Waters as an expert of water quality management of Finnish water resources. He was a member of a team of engineers and scientists, responsible for long-range planning of the utilisation and protection of Finnish water resources. Mr Jäppinen worked as an Environmental Expert at the Technical and Environmental Research Laboratory of Oy Kaukas Ab (presently part of UPM-Kymmene). His main responsibilities were environmental monitoring and reporting of the performance of the Kaukas Sulphite and Sulphate Pulp Mills.

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H Jäppinen 5 Publications

Several publications and proceedings in the field of environmental technology and management of pulp and paper industries in Europe, Asia and Australia.

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Attachment 2 Description of Water and Effluent Systems of the Bell Bay Pulp Mill Attachment

Pöyry Forest Industry Oy Jaakonkatu 3 FI-01620 Vantaa Finland Domicile Vantaa, Finland Business ID. 1071411-1

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ATTACHMENT 2 16B0104-E0071

1

December, 2006ATTACHMENT 2.EWS/HJ 1

December, 2006ATTACHMENT 2.EWS/HJ 2

Introduction

2. Chip silos

1. Chip screening

1. Biofuelstorage

2. Biosludgedewatering

Powerboiler

2. Recoveryboiler

Turbine

3. Fibreline

Chemicalplant

1. Evaporation4. Drying

1. Effluent treatment

3. Recausticizing/lime kiln

December, 2006ATTACHMENT 2.EWS/HJ 3

Scope of Presentation

Description of the Fresh Water Treatment and Supply System

Description of the Cooling Water System

Description of the Boiler Feed Water and Demineralised Water Systems

Description of the Effluent, Rain Water, and Sludge Treatment Systems

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ATTACHMENT 2 16B0104-E0071

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December, 2006ATTACHMENT 2.EWS/HJ 4

Fresh Water Treatment and Supply

December, 2006ATTACHMENT 2.EWS/HJ 5

Water Treatment

December, 2006ATTACHMENT 2.EWS/HJ 6

Water Treatment – Source, Treatment, and Capacity

• The raw fresh water is pumped to the mill via a 35 km pipeline from the Trevallyn Dam. Despite of being reasonably good quality, the water must be chemically treated and filtered before it can be used in manufacturing of bleached market pulp. Other users requiring high water quality are the boiler feed water make-up plant and the chemical plant.

• The main impurities, which must be removed include suspended solids, dissolved and colloidal organic matter and metal ions, like iron and manganese. The brownish colour of the water will also be removed. It is due to the presence of natural humic acids in the river water.

• The water treatment chemicals used are the same as used in drinking water plants, ie. caustic soda, aluminium sulphate (or poly-aluminium chloride), polyelectrolyte

• The design capacity of the FWTP is 100000 kl/d.

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ATTACHMENT 2 16B0104-E0071

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December, 2006ATTACHMENT 2.EWS/HJ 7

Water Treatment – Source, Treatment, and Capacity

• The average FW-consumption is about 72135 kl/d and the maximum continuous consumption about 80150 kl/d. The redundancy factors are 1.39 and 1.25.

• The main unit operations in the treatment plant are (see also next slide):– Chemical mixing;– Flocculation;– Flotation/Clarification;– Rapid sand filtration; – Mill water basin; and – Pumping

• N.B Potable water (for use in offices, rest rooms, wash rooms and canteens in the mill area) will be taken from the existing potable water supply.

December, 2006ATTACHMENT 2.EWS/HJ 8

Water Treatment

General Block Diagram of the Fresh Water Treatment Plant

TrevallynDam

ChemicalMixing

Flocculation Flotation -Sandfiltration

Mill WaterTank

CoolingWaterTank

SludgeTank

WaterRecycleTank

MillWaterSystem

Mill CoolingWaterSystem

CoolingTowers

FireWaterTank

Fire WaterSystem

Clean RainWater

Water TreatmentChemicals

SludgeDewatering

December, 2006ATTACHMENT 2.EWS/HJ 9

Water Treatment

Gunns – Similar layout but may require 4 or 5 tanks

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ATTACHMENT 2 16B0104-E0071

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December, 2006ATTACHMENT 2.EWS/HJ 10

Cooling Water

Cooling Towers

December, 2006ATTACHMENT 2.EWS/HJ 11

Cooling Water System: Purpose

• Mill operations rely upon the use of water to control the heat balance within a number of areas of the plant: eg fibre line, evaporation plant, chemical recovery area and steam and power area; and

• Freshwater consumption of the mill can be minimised by recirculating the water that is used for controlling the heat balance through an evaporative cooling tower system. It reduces the temperature of the cooling water making it available for reuse.

• The amount of water evaporated depends on the required temperature drop over the cooling towers. At a temperature drop of 20 C the evaporation is about 2.7 % of the cooling water flow. The actual amount depends on the temperature and relative humidity of cooling air.

• In order to control the accumulation of TDS into the system a small amount of water in circulation must be purged from the system. This amount depends on the evaporation requirement, TDS contents of the make-up water, and the maximum acceptable TDS in the cooling water circulation. A typical amount of purged water is <1 % of the circulating cooling water.

• A simplified water and TDS balance of the cooling water system is presented in next slide.

December, 2006ATTACHMENT 2.EWS/HJ 12

Cooling Water System: Principle

CoolingTowers

Q (i); C (i)E

Q (o);C (o)

Sankey Diagram and Material Balance of the Cooling Water System

Water Balance: Q (i) = E + Q (o)TDS Balance: Q (i)*C (i) = Q (o)*C (o)C (o) = (E/Q(o)+1)*C (i) E = EvaporationQ (i) = Make-up WaterQ (o) = Purged WaterC (i) = TDS in make-up waterC (o) = TDS in purge waterTotal Cooling Water Flow: ~200 kl/ADt

100; 6

2.7 ; 0.0

0.54 ; 6

3.24 ; 1.0

HeatExchangers

100; 6ConditioningChemicals

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ATTACHMENT 2 16B0104-E0071

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December, 2006ATTACHMENT 2.EWS/HJ 13

Cooling Water System: Operation

The cooling water system comprises 4 main circuits:

1. Warm water from heat exchangers at the fiber line, chemical recovery, and power boiler areas is collected and sent to the main cooling tower set for cooling and subsequent reuse at the cooling positions.

2. Warm water from the turbine condenser of the power plant is collected and sent to No. 1 cooling tower set where it is cooled, and returned to the turbine condenser.

3. Warm water from the chemical plant is collected and sent to a dedicated cooling tower set where it is cooled, and returned to the chemical plant.

NB: Each of these circuits:

Are equipped with a closed cycle circuit allowing recirculation of the cooled water through each system. Salinity is controlled by the use of a small purge which either discharges to the drain or is recycled to the FWTP. The make-up water input is equivalent to the sum of water evaporated and purged;

Controls the growth of microbes, including Legionella spp, with appropriate biocides. If necessary, scaling is controlled with chelating agents.

4. Fresh mill water will be used at dedicated heat exchangers in the secondary heat system of the mill to prepare the required amount of warm and hot process water. Any excess amount of warm and hot process water produced will be used as make-up water in the closed circuit cooling water systems instead of fresh water

December, 2006ATTACHMENT 2.EWS/HJ 14

Line Diagram: Water Treatment and Cooling Towers

December, 2006ATTACHMENT 2.EWS/HJ 15

Cooling Towers

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ATTACHMENT 2 16B0104-E0071

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December, 2006ATTACHMENT 2.EWS/HJ 16

Boiler Feed Water and Make-up Water Systems

December, 2006ATTACHMENT 2.EWS/HJ 17

Boiler Feed Water Makeup System

Boiler Feed Water Plant

December, 2006ATTACHMENT 2.EWS/HJ 18

Boiler Feed Water and Make Up System: Purpose

• Steam generated in the boilers (power and recovery boilers) is used to:– Power the turbo-generator to produce electricity; and– Generate process steam (medium or low pressure) for the mill.

• To minimise the amount of freshwater used to generate the steam in the boilers the condensate that results from the use of the high, medium, and low pressure steam is cleaned and reused.

• Freshwater, which has undergone a process of demineralisation, is used to supplement the water supply to the boilers to compensate for condensate losses that occur in the mill processes and in the filtration and ion exchange processes that are carried out before pumping to the boilers.

• The filtration and ion exchange processes (that results in very small water losses) are extremely important to avoid the intrusion of salt into the boiler system – which can cause corrosion and major damage.

• The design capacities of the feedwater and demineralisation plants are:– Feedwater plant, l/s 2 x 120– Demineralisation plant, l/s 120

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ATTACHMENT 2 16B0104-E0071

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December, 2006ATTACHMENT 2.EWS/HJ 19

Boiler Feed Water and Make Up System• Block Diagram of the Boiler Feedwater and Feedwater Make-up Preparation System

FreshWater

TreatmentPlant

Feed WaterPlant

CondensatePolishing

RecoveryBoiler

PowerBoiler

DemineralizationPlant

Turbo-Generator (s)

TurbineCondenser (s)

PulpMill

CondensateLoss

RegenerationLiquor

Blow-downSoot blowing

Blow-downSoot blowingRegeneration/

Backwash Liquor Demin.

Water

Steam condensate

High-PressureSteam

Medium-Pressure Steam

Low-Pressure Steam

Make-up Waterto Demin.Plant Steam

Condensate

BoilerFeed Water

December, 2006ATTACHMENT 2.EWS/HJ 20

Feedwater system

December, 2006ATTACHMENT 2.EWS/HJ 21

Water Demineralisation

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ATTACHMENT 2 16B0104-E0071

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December, 2006ATTACHMENT 2.EWS/HJ 22

Effluent, Rain Water, and Sludge Treatment Systems

December, 2006ATTACHMENT 2.EWS/HJ 23

Effluent Treatment

Primary Clarifier

Equalisation Basin & Spill Basin

Activated sludge plantChlorate Removal

Secondary Clarifiers

December, 2006ATTACHMENT 2.EWS/HJ 24

Effluent Treatment

• All effluent from the mill site is taken to the effluent treatment plant. This includes mill process effluent, sanitary effluent, as well as chip mill and storm water from the mill site.

• The main sources of raw effluent loads from the mill are the following mill departments:

– Fibre line;– Chemical plant;– Recovery area; and– Auxiliary Departments (eg workshops, offices, water treatment etc).

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ATTACHMENT 2 16B0104-E0071

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December, 2006ATTACHMENT 2.EWS/HJ 25

Effluent and Storm Water Drains, Monitoring, and TreatmentSchematic Presentation of the Mill Effluent System

Chip Handling

Power Plant

Recovery Boiler

Power Boiler

DigesterPlant

Brown StockWashing &Screening,O2-Delign.

Bleach Plant

Bl. StockScreening,Pulp Drying

Machine

Bale Handling,Bale Storage

EvaporationPlant

Causticizing,Lime Kiln

Fresh WaterPlant

WorkshopsChemicalPlant

Waste WaterTreatment Plant

Stormwater

Offices,ControlRoom,SocialFacili-ties.Process Effluent Drain

Storm WaterDrains/Site

To BassStrait

Overflow toDirty Bay

Storm WaterDrains/Roofs

Sewage

Monitoring Station

Septic Tanks

Chip Mill

December, 2006ATTACHMENT 2.EWS/HJ 26

Effluent Treatment - Raw Effluent Loads

Raw Pulp Mill Effluent Chip Mill EffluentParameter and Storm Water

Average Design (Design) • Effluent Flow (incl.sewage), kl/d 63932 78046 15860• Total Suspended Solids (TSS), t/d 47.2 55.87 3.039• Biological O2 Demand (BOD5), t/d 48.4 64.3 2.056• Chemical O2 Demand (COD), t/d 139.9 187.2 8.927• Adsorbable Organic Halides (AOX), t/d 1.45 1.62 0• Colour (Platinum-Cobalt Units), t/d 31.4 52.4 1.586• Total Dissolved Solids (TDS), t/d 250.0 307.6 9.025• Chlorate (ClO3), t/d 9.84 12.57 0

December, 2006ATTACHMENT 2.EWS/HJ 27

Effluent Treatment - Unit Operations

• Pre-treatment:– Coarse and fine screening;– Removal of heavy particles and sand;– pH control;

• Primary Clarification:– Removal of suspended solids – collected as primary sludge, dewatered and

sent to the power boiler as fuel; • Equalisation:

– Equalising the variability of the effluent quality; • Chlorate Removal:

– Special anoxic reactor to remove chlorate from the effluent• Selector Basins:

– The first part of the activated sludge process which promotes the growth of those microbes able to grow effectively in this pulp mill effluent and become the dominating species in the mixed liquor

• Final Aeration Basin: – The main part of the activated sludge process in which bulk of the removal

of organic matter takes place

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ATTACHMENT 2 16B0104-E0071

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December, 2006ATTACHMENT 2.EWS/HJ 28

Effluent Treatment - Unit Operations (cont’d)

• Secondary clarifiers (2 pcs):– In the secondary clarifiers the activated sludge (so-called mixed liquor

solids) is separated from the treated effluent and recycled back to the selector basins as the so-called return sludge. Part of the return sludge may also be introduced to the chlorate removal reactor

– Together with the aeration basins the secondary clarifiers comprise the activated sludge process

• Final Effluent Surge and Pumping Tank– The function of this tank is to provide buffering capacity for the final

effluent pumping in case of potential problems with the pumps; ie. mechanical failures and power black-outs

• Primary and Secondary Sludge Storage and Handling Facilities– There are separate primary (fiber) and secondary (biosolids) sludge

systems. Both systems comprise the sludge storage tanks, sludge thickening, and/or sludge dewatering. Dewatered primary sludge is incinerated in the power boiler while the secondary sludge is thickened, mixed with the strong black liquor and incinerated in the recovery boiler

December, 2006ATTACHMENT 2.EWS/HJ 29

Secondaryclarifiers

Thickenerfor excess

sludge

Primaryclarifier

Pr.Sludge Bio sludgetreatment Treatment

Return sludge

Excess sludge

FinalAerationClO3-

Rem.Selectors

Emergency Basin

Equalization Basin

PumpingBasinRaw Effluent

ContaminatedStormwater

ChipMill

to Power boiler to Evaporation plant

To Bass Strait

Control Room ,Aer. EquipmentChemical handling, Lab, MCC’s, etc.

Stand-by Cooling

Clean Stormwater

Effluent Treatment; Block Diagram

December, 2006ATTACHMENT 2.EWS/HJ 30

Effluent Treatment

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ATTACHMENT 2 16B0104-E0071

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December, 2006ATTACHMENT 2.EWS/HJ 31

Principle of Biological Effluent Treatment

December, 2006ATTACHMENT 2.EWS/HJ 32

Effluent Treatment – Key Design Data

The design criteria of the key unit operations of the plant are;

– Primary Clarification; hydraulic loading 1 kl/m2/h– Equalisation; hydraulic retention time (HRT) 12 hours; mixing power 5 W/m3– (Emergency basin; hydraulic retention time 24 hours)– Chlorate Removal; HRT 2 hours; anoxic conditions at Redox -200..-300 mV– Selectors; HRT 4 hours; F/M > 1 kg COD/kg MLVSS/d; DO 1-2 mg/l, MLVSS 3-

5 kg/kl– Final aeration; HRT 20-35 hours; F/M 0.4 kg COD/kg MLVSS/d; DO 2-3 mg/l,

MLVSS 3-5 kg/kl– Secondary Clarification; hydraulic loading 0.5 kl/m2/h – Return sludge pumping capacity ratio; 120 % of design effluent flow

December, 2006ATTACHMENT 2.EWS/HJ 33

Effluent Treatment – Design Treatment Efficiencies

The design treatment efficiencies of the Effluent Treatment Plant are:

• Total Suspended Solids; final effluent TSS max. 20 mg/l

• BOD5 , (1-BOD(FE) : BOD(RE) )*100; 99 %

• COD, (1-COD(FE) : COD (RE) )*100; 80 %

• AOX, (1-AOX (FE) :AOX (RE) )*100 ; 70 %

• Chlorate, (1-ClO3 (FE) : ClO3 (RE) )*100 ; 99 %

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ATTACHMENT 2 16B0104-E0071

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December, 2006ATTACHMENT 2.EWS/HJ 34

Example of a Modern Effluent Treatment Plant

15

December, 2006ATTACHMENT 2.EWS/HJ 35

Effluent Treatment Plant: Final Effluent LoadsTable 4-2. Monthly Average Final Effluent Loads and Quality (excl. chip mill effluent and storm water)

< 10< 30

<LOR<LOR

<LOR<LOR

<LOR<LOR

2,3,7,8 TCDD, pg I-TEQ/l2,3,7,8 TCDF, pg I-TEQ/l

< 2 mg/l (as THM)< 0.025< 0.00157< 0.0005Chlorinated Low-MW Substances

< 10 mg/l3.10.1970.063Chlorate

N/A2253143.745.7TDS

42 kg/ADt49331.410Colour

0.2 kg/ADt6.80.440.14AOX

20 kg/ADt46629.79.45COD

2.1 kg/ADt110.700.21BOD5

2.6 kg/ADt201.270.4TSS

n/an/a6377020290Effluent Flow

RPDC-GuidelineConcentration, mg/lLoad, t/dLoad, kg/ADBt

Parameter

December, 2006ATTACHMENT 2.EWS/HJ 36

Samples of Modern ECF Pulp Mill Effluent

Raw Effluent Primary Effluent Final Effluent

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ATTACHMENT 2 16B0104-E0071

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December, 2006ATTACHMENT 2.EWS/HJ 37

Effluent System; Spill collection and recovery

• Spillage of fibres and black liquor may occur in the digester plant and the pulp screening and washing plants. There may also be black liquor spills from the chemical recovery island and from the tank farms. Spillage of white liquor, green liquor, lime mud etc. may occur in the causticizing and lime kiln area.

• The main reasons to potential spills are process upsets, tank overflows, mechanical breakdowns, operator errors, and maintenance and construction activities.

• An extensive mill wide monitoring, containment, and recovery system will be built to control the potential spills. The conductivity and/or pH of individual effluent drains are continuously monitored in order to select which streams must be recycled in the process and which are directed to waste water treatment plant. The calibration and maintenance of the conductivity and pH probes will be carried out on a regular and scheduled basis since they are crucial to the performance of the spill prevention system.

• The spills, contaminated condensates and sealing waters, equipment drainage, wash-downs, etc. are collected in special floor canal sumps and pumped either directly or via intermediate tanks for recycling. The intermediate tanks are used to store the spills to prevent excessive peak loads which may result in upsets in the departmental spill recovery systems. Finally, a 4500 m3 main spill tank in the evaporation plant provides sufficient buffer volume to prevent upsets in the evaporation.

• The evaporation plant has also a 10 % excess capacity above the maximum balance capacity of the liquor recovery circuit to enable the processing of the recovered spills in all production conditions.

December, 2006ATTACHMENT 2.EWS/HJ 38

Effluent System; Spill collection and recovery

• All critical process areas are bunded to avoid concentrated or harmful streams entering the external effluent treatment or contaminating storm water drains. The bunded tank farm areas include;

– Liquor and washing liquor tanks in the unbleached fibre line area– Soap and turpentine handling– Evaporator tank farm– Causticising tank farm– Recovery boiler area– Evaporator plant area

• All tanks have control and alarm levels to ensure that the safe level is not exceeded. If overflows do occur they are recovered in the spill collection and control system described above.

• In order to eliminate the environmental and occupational safety risks associated with the storage and handling of the hazardous chemicals the pulp mill operations must comply with the SRC protocol defined for any Major Hazard Facility.

December, 2006ATTACHMENT 2.EWS/HJ 39

Effluent System; Spill collection and recovery

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ATTACHMENT 2 16B0104-E0071

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December, 2006ATTACHMENT 2.EWS/HJ 40

Effluent System; Spill collection and recoveryBasic spill collection arrangement for fiber line

BLOW TANK

SPILL TANK

Vent collection

Coarse screenLIC QISA

LIA

Overflows

Drains

Leaks

Floor channel

Pump sump Sewer pipe

Sewer water lock

Equipment drains from operating floor

Direct overflows

Spills from other pump sumps

Fibre detectorConductivity

KS

December, 2006ATTACHMENT 2.EWS/HJ 41

Rain Water System

• Clean rain water from the large building roofs and comparable areas, which do not feature any contamination risk, will be either reclaimed to the water treatment system or discharged directly into a rain water drain and sent to the treated effluent pumping basin for ocean discharge with the effluent.

• Rain water from other areas at the mill site, including unused land between mill departments, site roads, and process storage tank and equipment areas, will be collected into another rain water drain system and taken to a rain water clarification lagoon, in which suspended solids and floating debris is separated (especially from the first flush waters). The lagoon is also provided with an oil separation equipment to safeguard that no potential oil spills are discharged into the recipient.

• In case of contamination is detected (by continuous conductivity measurement or oil detection instruments), the rain water is pumped through the emergency basin to the effluent treatment.

• From the first storm water clarification lagoon the clean rain water is led to the second lagoon and further pumped to the treated effluent surge basin. During an extremely severe storm, featuring a return period beyond once in ten years, the second basin may overflow to Dirty Bay in the Tamar Estuary.

December, 2006ATTACHMENT 2.EWS/HJ 42

Rain Water System

• Rain water from the harbour will be collected to a trash and oil catchment well. The clean water is then pumped to the effluent treatment plant.

• The rain and leachate water from the landfill site will be collected into a holding basin at the site and pumped to the process effluent treatment plant. No contaminated water from the landfill site is discharged to Williams Creek.

• Appropriate reservations in the hydraulic and organic loading capacity of the effluent treatment plant have been made to accommodate efficient rain water treatment in all production conditions of the mill.

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ATTACHMENT 2 16B0104-E0071

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December, 2006ATTACHMENT 2.EWS/HJ 43

Rain Water System

December, 2006ATTACHMENT 2.EWS/HJ 44

Rain Water System

December, 2006ATTACHMENT 2.EWS/HJ 45

Sources and Handling of Primary and Secondary Sludge

Primary Clarifier

Secondary Clarifiers

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December, 2006ATTACHMENT 2.EWS/HJ 46

Sources and Handling of Primary and Secondary Sludge

• Sources of Primary Sludge– Screening and Cleaning Rejects– TSS in Chip Handling and Chip Mill Effluent– Inorganic Solids from the Causticizing and Lime Kiln area– TSS in the Fiberline and Recovery Island Floor Canal Effluent– TSS in the Power Boiler and Power Plant Floor Canal Effluent

• Estimated Amount of Primary Sludge– Estimated TSS in raw effluent about 10-15 kg/ADt of pulp (1-1.5 % of

production)– Removal efficiency in primary clarifier 90-95 %– Typical organic matter contents about 70-90 %– Typical ash contents about 10-30 %

• Sludge Consistency from the Primary Clarifier– Range 1-3 %, average about 2 %. – Average sludge flow about 0.7 kl/ADt; (= about 2200 kl/d)

December, 2006ATTACHMENT 2.EWS/HJ 47

Sources and Handling of Primary and Secondary Sludge

Sources of Primary Sludge:• Primary sludge carryover; (about 5-10 % of TSS in raw effluent)

• Excess activated sludge biomass; (about 0.10-0.15 kg DS/kg COD(s) (rem.)

Estimated Amount of Secondary Sludge:• Estimated TSS in primary effluent; about 0.5-1.5 kg/ADt• Excess Biomass; about 3.5-4.0 kg DS/ADt• TSS in Final Effluent; about 0.4 kg DS/ADt• Net Secondary Sludge; 3.6-5.1 kg DS/ADt; avg. about 4 kg DS/ADt• Typical ash contents about 10-15 %

Sludge Consistency and Flow from the Secondary Clarifiers:• Range 0.5-1.5 %, average about 1 %. • Average sludge flow about 0.4 kl/ADt; (= about 1260 kl/d)

Secondary Sludge Thickening:• Optional technologies; (i) Gravity thickener or (ii) Decanter centrifuge. • Preferred option; Decanter centrifuge

December, 2006ATTACHMENT 2.EWS/HJ 48

Sources and Handling of Primary and Secondary Sludge

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December, 2006ATTACHMENT 2.EWS/HJ 49

Modern Screw Press for Dewatering of Primary and Mixed Sludge

December, 2006ATTACHMENT 2.EWS/HJ 50

Sources and Handling of Primary and Secondary Sludge

• Primary effluent sludge

• Secondary effluent sludge

• Mixing with biofuels and incineration in the power boiler

• Typical LHV about 6 MW(t)

• Mixing with strong black liquor inthe evaporation plant and incineration in the recovery boiler

• Typical LHV about 1.5 MW(t)

Disposal of Primary and Secondary Sludge

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Attachment 3 Description of the Methodology Used to Estimate Liquid Effluent Loads

Pöyry Forest Industry Oy Jaakonkatu 3 FI-01620 Vantaa Finland Domicile Vantaa, Finland Business ID. 1071411-1

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1

DRAFT IIS OF THE BELL BAY PULP MILL PROJECT SOURCES, LOADS, TREATMENT, AND DISPOSAL OF LIQUID EFFLUENTS

Assessment Methodology

December 2006

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SOURCES, LOADS, TREATMENT, AND DISPOSAL OF LIQUID EFFLUENTS Outline of Methodology Used to Calculate Water Balances and Effluent Loads and to Design the Effluent Treatment Plant

Contents

1. INTRODUCTION

2. EFFLUENT AMOUNTS

3. RAW EFFLUENT LOADS

4. WASTE WATER TREATMENT PLANT AND FINAL EFFLUENT LOADS

5. FINAL EFFLUENT DISPOSAL

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1 INTRODUCTION

1.1 General Approach

• The purpose of calculating effluent loads is to demonstrate the environmental performance of the mill against the identified targets.

• The effluent loads are calculated based upon the design of the mill.

• The design of a mill is an iterative process that is influenced by various factors including machinery selection and impact assessment.

• Original effluent load calculations were completed in mid 2005. Following that initial work, impact assessment was carried out and further information was obtained relating to a number of process solutions that influenced the process design.

• The effluent loads contained in the Draft IIS were the result of further refinement of the mill design following initial impact assessments in late 2005 and early 2006.

• This statement explains the method of arriving at the effluent loads contained in Appendices 6 and 7 of the Draft IIS.

1.2 Methodology Used to Assess Liquid Effluent Loads

Emission targets

• The objective is to achieve the lowest possible environmental emissions for the mill.

• The starting point has been that all emissions must comply with;

– RPDC “Emission limit guidelines”; and

– EU-BAT guidelines

• In investigating possible further reduction of emissions below these guidelines it was necessary to examine:

– emission levels at the most recent operating pulp mills in Europe and elsewhere in the world

– environmental performance of the key machinery to be used in the Mill

• In looking at environmental performance of machinery it is important to recognize that the vendors’ guarantees are of only limited usefulness because they are either too conservative, or not conservative enough, depending on the commercial considerations and terms of supply contracts.

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• Eventually, all of this analysis must be related to the particular site conditions and the results of impact assessments undertaken as part of an iterative mill design process (Ref. Figure 1/1)

Figure 1/1: Principle of the Iterative Environmental Design Process

DRAFT. November 10, 2006ATTACHMENT 2.WATER AND EFFLUENT ISSUES 39

1. Methodology Used to Assess Liquid Effluent Loads

RPDC Emission limit

guidelines

International BAT practice

Targetvalue

Process/SafeguardSelection and

Design

Environmental/Social considerations

Safety and security

Emission target determination

Impact Assessment

Acceptable

Yes

No

1.3 Use of Data from Other Mills • There are four sources of information that Poyry has had available in arriving at predicted

emissions:

– published scientific studies of emissions,

– emission data collected in compliance with regulatory requirements in Scandinavian countries,

– data provided to Poyry on a commercial in confidence basis by other clients; and,

– data given by third parties, such as machinery vendors, about the environmental performance of mills

• Some of this material is more reliable than others. For example, information from third parties such as machinery vendors must always be treated with some caution, whereas data published following scientific research or required to comply with environmental regulations is more transparent and useful.

1.4 Emission Performance Margin Determination

In addition to calculating balance emissions in steady state operation, it is necessary to include consideration of occasional process upsets (eg. start-up and shut-down situations) and then incorporate redundancies in the design of the in-plant and external safeguards to contain potential emission peaks in the mill system and to eliminate or significantly mitigate the variability of final effluent quality.

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This is achieved by :

o adopting a design of relevant component parts of the plant that are sufficiently generous to accommodate the potential for upsets due to (i) equipment failures, (ii) failure of process control systems, (iii) human errors. Such redundancies must cover the whole mill and in particular are related to:

o fibre line,

o black liquor and cooking chemical recovery area, and

o chemical plant and purchased process chemical storage and handling,

o having a Distributed Control System (“DCS”) that relies upon extensive monitoring and control equipment across the whole of the mill. An integral part of the DCS is the real time and preventive control of the environmental parameters. In particular this includes; (i) spill monitoring, (ii) containment, and (iii) recovery,

o Over-dimensioning of the evaporator plant and recovery boiler by 10 % to ensure proper control of environmental parameters during potential process upset involving black liquor and cooking chemical spills.

o Generous design of the primary clarifier, emergency basin, equalization basin, aeration basin, and secondary clarifiers to cope with the daily variability of effluent loads such that the final effluent loads to Bass Strait are virtually constant and change only slowly as a function of longer term production levels.

Figure 1-2. Determination of Emission Variability

DRAFT. November 10, 2006ATTACHMENT 2.WATER AND EFFLUENT ISSUES 42

1. Methodology Used to Assess Liquid Effluent Loads

Vendorguarantees

RPDC Guidelines,International BAT practice

Guaranteevalue

Finalvalue

PerformanceVariability

of Safeguards

Variations tooperating value

Typical operatingvalue

Emission variability determination

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Figure 1/3. Mitigation of Emission Variability

DRAFT. November 10, 2006ATTACHMENT 2.WATER AND EFFLUENT ISSUES 44

1. Methodology Used to Assess Liquid Effluent Loads

Oversizingequipment

Design for highershort-term flows

Lowersvalue

Finalvalue

Using higherconcentrations

in design

Lowersvalue

Lowersvalue

Mitigation of Emission Variability

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2 SOURCES OF LIQUID EFFLUENTS

2.1 Mill Wide Water Balance (MWWB) Based on the IIS Guidelines issued by RPDC, mill wide water balances were developed both for the BEKP and BSKP production alternatives. In addition, such balances were prepared for summer and winter conditions.

The MWWB’s developed are interactive Excel models calculating the water balances and raw effluent loads in steady state production conditions for the following annual production capacities:

BEKP Production: 1 100 000 ADt/a at available annual production days of 350 d/a

BSKP production: 100 000 ADt/a at available annual production days of 49 d/a

2.2 Key Input Data of the MWWB Models The key input data required in the Excel models are as follows:

Pulp Production and Steam and Power Generation

Wood raw material/pulp yield/wood moisture

Brown stock washing and screening concept

Post-oxygen washing concept

Bleach plant washer and filtrate recycling concept

White water concept at pulp drying machine

Process chemicals supply concepts

Recycling of process and cooling waters, cooling tower system

Treatment and reuse of secondary condensates

Backwash water from fresh water treatment

= Total Water Input

Balance liquid effluents from process and auxiliary departments

Evaporation from drying machine, cooling towers, recovery boiler, lime kiln, etc.

Miscellaneous water losses

= Total Water Output

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According to the water balance of the most important production case, ie. eucalyptus pulp production in summer conditions, the specific fresh water consumption is about 23.4 kl/ADt and the raw effluent amount about 20.3 kl/ADt. The difference is primarily due to net evaporation of water from various parts of the mill process.

Other MWWB cases do not differ substantially from the above case. The specific water consumption and effluent loads in case of pine pulp production are about 20 % higher than in case of eucalyptus pulp production primarily because of a substantially lower production capacity achievable during the pine pulp production.

The updated MWWB and the process effluent amounts during the plantation eucalyptus pulp production at the average rate of 3143 ADt/d are summarised in the Tables 2/1 and 2/2.

Figure 2/1. Summary of the Mill-Wide Water Balance

Figure 2/2. Raw Effluent Amounts by Mill Departments

Raw Effluent AmountTotal Raw Effluent Amount of the Pulp Mill:

Woodhandling, kl/Adt 0.076Digester, BS Washing and Screening, O2-Delign., Post O2 Washing, kl/Adt 0.046Bleach Plant and Secondary Screening, kl/Adt 17.080Drying Machine, kl/ADt 0.268Evaporation Plant, kl/Adt 0.275Recovery Boiler, m3/Adt 0.046Causticizing Plant, m3/Adt 0.046Lime Kiln, m3/Adt 0.183Chemical Plant, m3/Adt 0.32Power Boiler and Demin.Plant, m3/Adt 0.265Power Plant Cooling Tower Blowdown, m3/Adt 0.247Service Water from Workshops, m3/Adt 0.06Backwash Water from FWTP, m3/Adt % of Input 2 0.469Other Live Steam Condensate Losses to Raw Effluent, m3/ADt 0.929

Total Process Effluent, m3/Adt 20.309Sanitary Effluent, m3/Adt 0.024

Chip Moisture Fresh Water Misc.Water

1.871 23.443 0.098

Total In, kl/ADt 25.411

Bell Bay Pulp Mill 1100000 ADBt/a

Total Out, kl/ADt 25.411

20.333 1.015 1.053 2.966 0.044

Effluent Evapor'n Evapor'n Evapor'n MoistureFiberline Recovery CT's Solid w aste

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2.3 Effluent from the Existing Chip Mill and Storm Water System

Chip mill effluent based on existing data (design 2400 kl/d)

Storm water flows based on total potential storm water contamination risk areas at the site and the design rain intensity, return period 1 once in 10 years (13280 kl/d )

2.4 Hydraulic Design of the WWTP The average and maximum continuous process effluent loads based on the MWWB are as follows:

Average flow: 63 832 kl/d (= 20.309 kl/ADt * 3143 ADt/d)

Maximum continuous flow: 70 313 kl/d (= 20.135 kl/ADt * 3492 ADt/d)

The corresponding design process effluent flow is calculated by using an additional design factor of about 0.9. Hence the design process effluent flow to the WWTP is 78 126 kl/d.

According to the MWWB the effluent flow from the bleach plant is about 85 % of the total process effluent flow, or 17.080 kl/ADt. However, based on the currently available guarantees from Andritz the balance figure is rather conservative. The guaranteed bleach plant effluent flow the vendor is 10 kl/ADt.

This implies that the average and maximum continuous process effluent flows may be reduced to about 41 830 kl/d and 4 6478 kl/d, respectively. The corresponding design flow would then be 51 642 kl/d.

The selected hydraulic design of the WWTP is, however, 93906 kl/d comprising the following sources:

Pulp mill effluent 78 126 kl/d

Sanitary effluent 100 kl/d

Chip mill effluent 2400 kl/d

Storm water 13280 kl/d

Total design flow 93906 kl/d

Total Hydraulic Design 3913 kl/h

At this hydraulic capacity the redundancy factors at design and average production of the mill are as follows:

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Table 2-1: Hydraulic Redundancy Factors of the WWTP at Various Production Levels

Hydraulic Redundancy Factors Production Level

Dry Weather Incl. Storm Water

MWWB 1.20 1.091 Design Production

Vendors’ Bleach Plant Concept

2.016 1.500

MWWB 1.468 1.181 Average Production

Vendors’ Bleach Plant Concept

2.239 1.630

According to Table 2-1 the hydraulic capacity of the WWTP will be sufficient to accommodate all possible disturbance situations in during the continuous production.

There is also a 100 000 kl emergency basin, which is used to level down any short-term hydraulic surges. By experience the duration of such surges is normally limited to few hours.

2.5 References Main design data of the Bell Bay Pulp Mill

Water and effluent balances of several modern pulp mills designed by Poyry and other technology suppliers (Advance Agro Pulp Mills 1 and 2, Veracel, Orion, Aracruz 3, Metsa-Rauma, Stendahl, Joutseno, etc.)

Water and effluent amounts provided by main machinery suppliers in their bidding documents.

BAT benchmark ranges (see also Figure 2/4 below):

• Fresh water usage: 20-30 kl/ADt

• Liquid effluent: 15-25 kl/ADt

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Figure 2/4. Cumulative Variability of Effluent Amount in European BKP Industry

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3 RAW EFFLUENT LOADS

3.1 Calculated Raw Effluent Loads

The raw effluent loads are automatically calculated in the MWWB models with special built-in equations converting the key process variables and material balances and losses into commonly used effluent parameters, like TSS, BOD, COD, colour, AOX, chlorate, etc.

Some parameters, like the generation of chlorinated phenolics, dioxins, etc. must, however, be estimated based on empirical data from corresponding modern mills, since only minute amounts of such substances (if any) are generated in modern ECF mills.

3.1.1 Total Suspended Solids

TSS in woodhandling effluent (forest debarked wood); 0.1 kg/ADt

TSS in FWTP backwash, 50 g TSS/kl at 25 kl/ADt; 1.25 kg/ADt

Rejects from brown stock and bleached stock screening and cleaning (0.5 % + 0.2 % of production),

Bleach plant filtrates, estimated fiber concentration 200 mg/l,

TSS in fiber line and recovery island department drains, typical TSS 400 mg/l,

TSS in auxiliary department drains, typically 100 mg/l,

Unscheduled losses (wash downs, emptyings, etc.), 2.5 kg/ADt

Total TSS: (0.1 + 1.25 + 5 + 0.2*17 + 2 + 0.5*0.4 + 0.5*0.1 +2.5) = 14.5 kg/ADt

Total Daily TSS-load at Design BEKP Production: 50.6 t/d.

(Maximum load during BSKP production 34.0 t/d)

3.1.2 BOD5

Woodhandling (forest debarked wood); 0.1 kg/ADt

Brown stock/Post Oxygen washing (99 % efficiency); 3.0 kg/ADt

Bleach plant; bleaching yield 97 %; 7 kg/ADt

Secondary condensates; (net load after FC-stripping and reuse); 3.0 kg/ADt

Allocation for wash-downs, equipment drains, spills; 1.5 kg/ADt

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Allocation for TSS-BOD5; 10 % of organic TSS; about 1 kg/ADt

Sum RE-BOD5 ; (0.1+3.0+7+3.0+1.5+1.0) = 15.6 kg/ADt

Maximum Daily BOD5 –load at Design BEKP Production; 54.5 t/d.

(Max. load during BSKP production; 40.8 t/d)

3.1.3 COD Woodhandling (forest debarked wood); 0.3 kg/ADt

Brown stock/Post Oxygen washing (99 % efficiency); 7.5 kg/ADt

Bleach plant; bleaching yield 97 %; 24.2 kg/ADt

Secondary condensates; (net load after FC-stripping and reuse); 4.0 kg/ADt

Allocation for wash-downs, equipment drains, spills; 6.0 kg/ADt

Allocation for TSS-BOD5; 25 % of organic TSS; about 2.5 kg/ADt

Total RE-COD ; (0.3+7.5+24.2+4.0+6.0+2.5) = 44.5 kg/ADt

Total RE-COD at 100 % spill recovery: 38.5 kg/ADt

Daily maximum COD-load at design BEKP production = 155.4 t/d

Maximum COD-load at design BSKP production (53 kg COD/ADt) = 120.2 t/d

3.1.4 AOX

Maximum ClO2-charge during BEKP production, 40 kg act.Cl/ADt (Do 22 kg/ADBt; D1/D2 18 kg/ADt)

Minimum ClO2-charge during BEKP production; 21 kg act.Cl/ADt (Do 14 kg/ADt, D1 7 kg/ADt + hydrogen peroxide)

Maximum ClO2-charge during BSKP production; 47 kg act.Cl/ADt (Do 26 kg act.Cl/ADt + 21 kg act.Cl/ADt)

Minimum ClO2-charge during BSKP production; 28 kg act Cl/ADt (17 kg act.Cl/ADt + 11 kg act.Cl/ADt + hydrogen peroxide)

BEKP-Production

Maximum AOX (kg/ADt) = 0.114*act.Cl(Do)/5-0.011*act.Cl(D1/D2)/5

Max. act Cl(Do) = 22 kg/ADt; act.Cl (D1/D2) = 18 kg/ADt

Min. act Cl(Do) = 14 kg/ADt; act.Cl (D1/D2) = 7 kg/ADt

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AOX = 0.462 kg/ADt (max.)

Minimum AOX (kg/ADt) = 0.114*14/5-0.011*7/5

AOX = 0.304 kg/ADt (min.)

BSKP Production

Maximum AOX (kg/ADt) = 0.114*26/5-0.011*21/5 = 0.547 kg/ADt

Minimum AOX (kg/ADt) = 0.114*17/5-0.011*11/5 = 0.363 kg/ADt

Range of Raw Effluent AOX-loads at Average and Design BEKP Production: 955-1613 kg/d.

Raw Effluent AOX-loads at Design BSKP Production: 740-1241 kg/d

3.1.5 Chlorate

BEKP Production: ClO3-generation about 23.5 % of chlorine dioxide charge of 8-15.2 kg ClO2/ADt; 1.88-3.58 kg ClO3/ADt

BSKP Production: ClO3-generation 23.5 % of ClO2-charge of 10.6-17.9 kg/ADt ; 2.49-4.2 kg ClO3/ADt.

Maximum daily chlorate load in raw effluent during the design BEKP production: 12.57 t ClO3/d

Minimum daily chlorate load in raw effluent during the average BEKP production: 5.91 t ClO3/d

Maximum daily chlorate load in raw effluent during the design BSKP production: 9.52 t ClO3/d

Minimum daily chlorate load in raw effluent during the average BSKP production: 5.08 t ClO3/d

A small amount of chlorate will also be discharged to the drain from the chemical plant. The final amount depends on the selected chemical plant concept.

Note: The amount of chlorate given in the DIIS for ClO2-charge of 40 kg act. Cl/ADBt, 1.52 kg/ADBt, is expressed as equivalent chlorine contained in the chlorate molecule. Hence, the corresponding actual ClO3-load is (83.5/35.5)*1.52 = 3.575 kg ClO3/ADBt.

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3.1.6 Colour

BEKP Production

Typical effluent colour of modern ECF mills producing BEKP; 1 kg PCU/ POW kappa-unit

Specific effluent colour; 1*10 = 10 kg PCU/ADt;

Effluent colour; 492 mg PCU/l

BSKP Production

Typical effluent colour of modern ECF mills producing BSKP; 1.0-1.5 kg PCU/ POW kappa-unit

Specific effluent colour; (1.0---1.5)*12 = 12-18 kg PCU/ADt; Estimated average 15 kg PCU/ADt.

Effluent colour; 500-750 mg PCU/l, Average 625 mg PCU/l

3.1.7 Total Dissolved Solids

BEKP Production

Dissolved Organic Matter (DOM) (= COD-CODTSS)/1.2) = (44.5-2.5)/1.2 =

= 35.0 kg DOM/ADt

Dissolved Inorganic Matter (DIOM) (= process chemicals in effluent) =

= 42.9 kg DIOM/ADt

TDS = DOM+DIOM = 77.9 kg/ADt; Max. daily load 272 t/d

BSKP Production

Dissolved Organic Matter (DOM) (= (COD-CODTSS)/1.2) = (53-2.5)/1.2 =

= 42 kg DOM/ADt

Dissolved Inorganic Matter (DIOM) (= process chemicals in effluent) =

= 50 kg DIOM/ADt

TDS = DOM+DIOM = 92 kg/ADt; Max. daily load 209 t/d

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3.1.8 Chlorinated Aromatic Compounds

The following groups of chlorinated aromatic compounds have been found in bleach plant effluents from conventional elemental chlorine bleaching of hardwood pulps:

Chlorinated phenols, chlorinated vanillins, chlorinated guaiacols, chlorinated catechols, chlorinated syringols, and chlorinated syringaldehydes

The total raw effluent loads of these substances in conventional bleaching of type O-(C/D)-E-D-E-D were in order of 50 g/ADt of HW pulp

Modern ECF bleaching combined with low post-oxygen kappa number of 8-10 has reduced the generation of all chlorinated aromatics by more than 90 %.

In addition, the generation of chlorinated dioxins and furans has virtually been eliminated. This means that the PCDD and PCDD concentrations are well below the detection limits of accepted modern analytical methods, like USEPA 1613 (10 pg/l).

Table 3-1 presents a comparison of the process conditions and generation of chlorinated aromatic compounds in conventional and modern ECF bleaching of hardwood pulps. Table 3-2 depicts a theoretical calculation of the potential PCDD/PCDF emission of the Bell Bay Mill. This calculation is based on the available mill measurements in USA, Canada, and Sweden and the estimated capability of modern Low-OX ECF bleaching technology and effluent treatment to eliminate the emission.

Table 3-1. Comparison of Process Conditions and Generation of Chlorinated Organics in Conventional (Chlorine-Chlorine Dioxide) and Modern ECF Bleaching of Hardwood Pulp

< 0.1251Chlorinated Phenolics, g/kg act. Cl**/ <550Chlorinated Phenolics, g/Adt**/ 11.655.4AOX, g/kg act. Cl**/ 0.462 2.77 Generation of AOX, kg/ADt **/ 3.4 8.5 Stochiometric Cl-charge, Cl atoms/lignin

monomer

4025Total Chlorine Dioxide Charge, kg act.Cl/ADt 0 25Elemental Chlorine Charge, kg/ADBt 4050Total Active Chlorine Charge, kg/ADt A/D0-E/O-D-DC/D-E/O-D1-E-D2Final Bleaching Sequence 12.218.2Residual Lignin in Unbleached Pulp, kg/Adt*/ 1015Post-O2 Kappa Number9998.5Post-O2 Washing Efficiency, % Modern Low-OX MillConventional MillProcess Parameter

*/ 1 kappa unit = 0.135 % lignin in oven dry pulp, **/ Figures refer to raw effluent prior to external effluent treatment

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Table 3-2. Estimated Theoretical PCDD and PCDF Emissions of the Bell Bay Mill as International Toxicity Equivalents (I-TEQ)

Estimated I-TEQ-Emissions from the Bell Bay BEKP Mill Total Emission, g I-TEQ/a 0.248 Balance ConcentrationGaseous Emission, g I-TEQ/a 0.050 ng/Nm3 0.0069

% of total 20 FG ,Nm3/Adt 6563Final Effluent, g I-TEQ/a 0.074 pg/l 3.376

% of total 40 Flow, kl/Adt 20Red.in ETP,% 25

Pulp, g I-TEQ/a 0.099 micro-g/Adt 0.090% of total 40

I-TEQ with Effluent Sludge, g/a 0.025 ng/BDkg 1.61Total,g I-TEQ/a 0.248

3.1.9 Resin Acids

Resin acids occur in the effluent only during the pine pulp production and few days after the BSKP production campaign is finished.

The estimated extractives load in effluent during the pine runs is presented in Table 3-3. The total extractives in the raw effluent are estimated at about 0.26 kg/ADt or about 10.8 mg/l. The share of resin acids of total is about 45 %, or 0.117 kg/ADt and 4.9 mg/l.

Table 3-3. Estimated Wood Extractives Load in Raw Effluent during Pine Runs

Extractives Carry-over to Bleaching and Process EffluentResin Acids, kg/Adt 0.261Fatty Acids, kg/Adt 0.203Neutral Extractives, kg/Adt 0.058Total to Final Bleaching, kg/Adt 0.521Removal by Chemical Oxidation in O2- and Do-Stages, kg/Adt Efficiency,% 50 0.261Discharge of Extractives to Raw Process Effluent, kg/ADt 0.261

Resin Acids, kg/Adt 0.117Fatty Acids, kg/Adt 0.091Neutral Extractives, kg/Adt 0.026

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3.2 References

(i) Water and effluent balances of several existing modern pulp mills designed by Poyry and other technology suppliers (Advance Agro Pulp Mills 1 and 2, Veracel, Orion (in construction stage), Aracruz 3, Metsa-Rauma, Stendal, Joutseno, Valdivia, etc.)

(ii) Main design data (MDD) of the Bell Bay Pulp Mill.

(iii) Water and effluent amounts provided by the main machinery suppliers in their bidding documents for the project.

(iv) Raw and final effluent load data publicly available from all pulp mills in Finland and in Sweden.

(v) Extractives contents and composition of radiate pine. Data from Tasman Pulp Mill.

4 WASTE WATER TREATMENT PLANT (WWTP)

4.1 Main Design Data of the WWTP

4.1.1 Design Raw Effluent Load

Table 4-1 presents the calculated design effluent loads of the pulp mill, the chip mill effluent, and the storm water.

Table 4-1. Selected Design Raw Effluent Loads of the WWTP

Parameter Specific Design Load, kg/ADt (incl. all sources)

Pulp Mill, t/d

Chip Mill and Storm Water, t/d

Total, t/d

Effluent Flow 26892 78226 15680 93906

Total Suspended Solids (TSS) 16.87 55.87 3.039 58.909

Biological O2 Demand (BOD5) 19.00 64.30 2.056 66.356

Chemical O2 Demand (COD) 56.16 187.20 8.927 196.127

Adsorb able Organic Halides (AOX) 0.464 1.62 0 1.62

Colour (Pt-Co Units) 15.46 52.40 1.586 53.986

Total Dissolved Solids (TDS) 90.67 307.60 9.025 316.625

Chlorate (ClO3-) 3.6 12.57 0 12.57

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Figure 4/1 below presents the typical composition of the dissolved organic matter (DOM) in modern BKP Mill raw effluent. About 60 % of the DOM is easily biodegradable organic matter and about 40 % slowly biodegradable organic matter. The COD:BOD-ratio is typically 3:1.

Figure 4/1. Typical Composition of Dissolved Organic Matter in Raw BKP Mill Effluent

DRAFT. November 10, 2006ATTACHMENT 2.WATER AND EFFLUENT ISSUES 33

4. Effluent Treatment and Disposal/Process Concept of WWTP

Typical Composition of Dissolved Organic Matter in Raw BKP Mill Effluent

05

10152025303540

Lignin

deriv

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Carboh

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Organ

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)

Methan

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EDTA

Extra

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kg D

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/AD

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Fiber LineRecoveryTotal

4.1.2 Unit Operations in the WWTP

The WWTP features the state-of-the-art process design and unit operations used in the modern pulp industry. All recent pulp mills are operating similar types of plants although the detailed solutions used in various parts of the plant may differ due to differences in suppliers’ proprietary designs.

The WWTP comprises the following key unit operations:

Pre-treatment, including coarse and fine screening, sand separation, and pH-control

Continuous monitoring of effluent flow and quality and automatic composite sampling of effluent

Primary clarification

Equalisation basin

Emergency basin

Chlorate removal reactor

Selector basins

Final Aeration basin

Secondary clarification

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Final effluent surge basin and automatic composite sampling

Final effluent disposal pumps

Handling of primary sludge

Handling of secondary sludge

Process control room, laboratory, chemical storage and handling, and MCC

4.2 Design Criteria of the Key Unit Operations

(i) Primary Clarifier, hydraulic loading, m/h

Design 1.0

Average 0.7

(ii) Equalisation Basin, Hydraulic Retention Time (HRT), h

Design 12

Average 17

(iii) Emergency Basin, HRT, h

Design 22

Average 31

(iv) No evaporative cooling towers

(vi) Chlorate removal, HRT, h

Design 2

Average 2.85

(vii) Selectors

Number 2-3

HRT, max. 20 % of total aeration volume

F/M, kg COD(s)/kg MLVSS/d > 1.0

(viii) Aeration Basin

F/M, kg COD(s)/kg MLVSS/d

o Design 0.5

o Average 0.32

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MLVSS, kg/kl

o Design 5.0

o Average 3.5

Aeration basin volume (incl. selectors)

o Appr. Volume, kl 80000

o Water depth, m 7 - 9

o Max. Selector Volume, kl 16000

o Total MLVSS in aeration

Design, kg 380000

Average, kg 306250

Design COD(s)-removal-% 80

Design DO in Aeration, mg/l 0.5 - 3.0

Installed Compressor Power, kW 2500

O2-Transfer Capacity at mixed liquor DO 0.5 mg/l, kg O2/d: 114800

COD-removal capacity in aeration, kg COD(s)/d: 143500 (estimated specific O2-demand 0.8 kg O2/kg COD(s) removed)

Max. filtered COD-loading to aeration at 80 % removal efficiency, kg COD(s)/d: 179300

Max. estimated unfiltered COD-loading to primary clarifier, kg COD(t)/d: about 207000

(ix) Secondary Carifiers

Design hydraulic load; 0.5 kl/m2/h

Number of units; 2 pcs

Surface area per unit; 3900 m2

Diameter per unit; 71 m

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4.3 Redundancy Factors against Variability of Organic Loading

Table 4-2: COD Redundancy Factors of the WWTP at Various Production Levels

COD Redundancy Factors Production Level

Dry Weather Incl. Storm Water */

Design Production (euca) MWWB (155.4 t/d) 1.29 1.22

Average Production (euca) MWWB (139.9 t/d) 1.43 1.34

Design Production (pine) MWWB (120.2 t/d) 1.66 1.55

Average Production (pine) MWWB (108.2 t/d) 1.84 1.71

4.4 Final Effluent Quality

The estimated final effluent loads and quality at the average and design production of the mill are presented in Tables 4-3 and 4-4 below. The average loads given in Table 4-3 exclude the chip mill effluent and storm water (= average minimum loads), while the loads in Table 4-4 include also the chip mill effluent and storm water (= maximum daily).

Table 4-3. Estimated Monthly Average Final Effluent Loads and Quality (excl.chip mill and storm water)

Parameter Load, kg/ADBt

Load, t/d Concentration, mg/l

RPDC-Guideline

Effluent Flow 20333 63770 N/A N/A

TSS 0.4 1.27 20 2.6 kg/ADt

BOD5 0.21 0.70 11 2.1 kg/ADt

COD 9.45 29.7 466 20 kg/ADt

AOX 0.14 0.44 6.8 0.2 kg/ADt

Colour 10 31.4 493 42 kg/ADt

TDS 45.7 143.7 2253 N/A

Chlorate*/ 0.063 0. 198 3.1 < 10 mg/l

Chlorinated Low-MW substances < 0.0005 < 0.00157 < 0.025 < 2 mg/l (THM’s)

PCDD/PCDF < LOR < LOR < LOR <10 pg 2,3,7,8-TCDD/l <30 pg 2,3,7,8-TCDF/l

*/The chlorate load is based on A/Do-EOP-D1/D2 sequence at the guaranteed ClO2-charge of 35 kg act.Cl/ADt and at 98 % ClO3-removal efficiency in effluent treatment.

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Table 4-4. Estimated Maximum Daily Final Effluent Loads and Quality Including Chip Mill Effluent and Storm Water

Parameter Load, kg/ADt Load, t/d Concentration, mg/l RPDC-Guideline

Effluent Flow 26838 93718 N/A N/A

TSS 0.54 1.874 20 4.5 kg/ADt

BOD5 0.315 1.11 11.7 3.6 kg/ADt

COD 12.6 44.00 469 34 kg/ADt

AOX 0.18 0.629 6.7 0.4 kg/ADt

Colour 15 52.38 559 72 kg/ADt

TDS 48.0 167.616 1789 N/A

Chlorate*/ 0.072 0.251 2.68*/ < 10 mg/l

Chlorinated Low-MW Substances < 0.001 < 0.0035 <0.04 < 2 mg/l (THM’s)

PCDD/PCDF < LOR < LOR < LOR < 10 pg 2,3,7,8-TCDD/l < 30 pg 2,3,7,8-TCDF/l

*/ The chlorate load is based on the same bleaching sequence as in Table 4-3, the estimated maximum ClO2-charge of 40 kg act.Cl/ADt, and 98 % ClO3-removal efficiency. Excluding the chip mill effluent and storm water, the ClO3-concentration in the final effluent at the design pulp production would be3.7 mg/l. This concentration has been used as an input value in the hydrodynamic modelling of the marine environment.

Figure 4/2 presents a typical composition of the biologically treated BKP mill effluent. About 95 % of the dissolved organic matter comprises slowly biodegradable lignin derivatives. The COD:BOD-ratio is typically 40:1. This ratio implies that the decomposition rate of the residual slowly biodegradable organic matter is in order of 0.007 per day and its biochemical half life time about 140 days.

Figure 4/2. Typical Composition of Dissolved Organic Matter in Biologically Treated BKP Mill Effluent.

0123456

kg D

OM

/AD

t

Lignin Derivatives, kg/ADt

Organic Acids, kg/ADt

EDTA, kg/ADt

Total, kg/Adt

Typical Composition of Dissolved Organic Matter in Biologically Treated BKP Mill Effluent

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4.5 References

Main design data of the Bell Bay Pulp Mill

Water and effluent balances of several modern pulp mills designed by Poyry and other technology suppliers (Advance Agro Pulp Mills 1 and 2, Veracel, Orion (under construction), Aracruz 3, Metsa-Rauma, Stendahl, etc.)

Water and effluent amounts provided by the main machinery suppliers in their bidding documents for the Bell Bay Pulp Mill project

4.6 BAT and AMT Benchmarks

BOD5 References from Various Guidelines, Countries, and Recent Mills

System/Country/Mill BOD5 kg/ADt t/a RPDC Guideline 2.1 2310 Bell Bay Pulp Mill 0.2 220 US-EPA 2.41 2650 EU/IPPC 0.25 275 Finnish Mills, average < 1 Swedish Mills, average (~1) Mill A, Germany 0.9 Mill B, Brazil 0.8 Mill C, South America 0.7 Mill D, Brazil 1 Mill E, South Africa 0.8 Mill F, China (30 mg/l) Mill G, Thailand (< 20 mg/l) Mill H, Indonesia (< 100 mg/l)

COD References from Various Guidelines, Countries, and Recent Mills

System/Country/Mill COD(Cr) kg/ADt t/a

RPDC Guideline 20 22000 Bell Bay Pulp Mill 8-10 8800 US-EPA no limit no limit EU/IPPC 10 11000 Finnish Mills, average 20 Swedish Mills, average 22 Mill A, Germany 15 Mill B, Brazil 16 Mill C, South America 15 Mill D, Brazil 10 Mill E, South Africa 18 Mill F, China (100 mg/l) Mill G, Thailand < 200 mg/l Mill H, Indonesia 350 mg/l

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AOX References from Various Guidelines, Countries and Mills

System/Country/Mill AOX kg/ADt t/a

RPDC Guideline 0.2 220 Bell Bay Pulp Mill 0.14 165 US-EPA (0.272 for ECF

only) 299

EU/IPPC < 0.25 <275 Finnish Mills, average 0.15 Swedish Mills, average 0.12 Mill A, Germany 0.115 Mill B, Brazil 0.16 Mill C, South America 0.15 Mill D, Brazil 0.12 Mill E, South Africa 0.14 Mill F, China 0.8 Mill G, Thailand “BAT” Mill H, Indonesia 29 mg/l

5 FINAL EFFLUENT DISPOSAL

5.1 Disposal Pipeline Approximate total length, km 23

Approximate diffuser length, m 200

Approximate discharge depth (b.m.s.l.) 26

Target minimum dilution at the border of the mixing zone 500

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