NC0000272_Correspondence 2010-2019_20210210

NCD NR --
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H.Sullins Dee Freeman
Governor Director Secretary
May 26,2010
Mr.Dane Griswold,Plant Manager
Blue Ridge Paper Products
P.O.Box 4000
Canton,North Carolina 28716
Subject: NPDES Permit Issuance
Permit No.NC0000279 -
Blue Ridge Paper Products,Inc.
Haywood County
Dear Mr.Griswold:
The Division of Water Quality is forwarding herewith the Final NPDES permit for Blue Ridge Paper Product's Canton
mill. This permit renewal is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between North Carolina and the U.S.Environmental Protection Agency dated October 15,
2007(or as subsequently amended).
Public hearings were held in Tennessee and North Carolina seeking comments on the Draft permit and proposed removal
of the color variance. Subsequently,U.S. EPA submitted an objection letter(dated February 22,2010)on the Draft permit,
and required several permit changes. This Final permit addresses public comments,the specific EPA objections,and
incorporates additional recommendations of the DWQ Hearing Officer. The specific changes that have been incorporated
into this Final permit are as follows:
• Color Technology. The starting annual average color limit has been changed to 38,020 lb/day based on EPA's use
of the 95%confidence limits. The final annual average color limit(after 4 years)has beeri changed to a range of
32,000-36,000 lb/day. A Color Reduction implementation plan will be required within one year of permit
issuance,and a reopener clause has been added that will allow the Division to include interim requirements and
dates for their achievement following review of the Implementation Plan.A Low Flow Contingency Plan for color
control shall be submitted within one year of permit issuance.
• Color Variance. The consideration for color variance removal has been dropped from this permit renewal. The
facility will continue to operate under its current color variance,which will be subject to NC Environmental
Management Commission approval at a later date. Blue Ridge Paper may elect to conduct a color perception study
in the future to support removal of the color variance,and any such proposed study must be-approved by the
Division of Water Quality.
• CWA Section 316(a)Thermal Variance. The Balanced and Indigenous Population(BIP)study must conform with
EPA study guidelines,and is subject to EPA review.The monthly average delta temperature limit has been
changed to 8.5 degrees C based on EPA's use of a 95 h percentile,which can be modified in the future based on
1617 Mail Service Center,Raleigh,North Carolina 27699-1617
Location:512 N.Sarsbury SL Ralegh,North Cam1na 27604 .e 1�.. -
Phone:[phone] FAX [phone] Customer Service:1-877-623-6748 NOr u1Carohna
Internet vnwr.nnityIA naliv Ac Naturall
M Equal Oppanundyl NfirmativeAcaon Employer

results of the thermal modeling. Blue Ridge Paper will continue to monitor/report daily maximum and monthly
average effluent temperatures.
• Dioxin. A daily maximum dioxin effluent limit has been added,based on a 1.5 multiplier of the chronic limit.
Blue Ridge Paper will conduct three annual fish tissue monitoring events over the permit term. Two events must
be from Waterville Lake,while the third fish sampling may be from Waterville Lake or the mainstem Pigeon River
below the mill outfall.
• Turbidity. Instream turbidity monitoring(upstream and downstream at Fiberville Bridge)will be required the first
year,at 2/Month monitoring frequency. A turbidity reopener clause has been added to the permit.
•. Hardness. Quarterly effluent hardness monitoring has been added to the permit.
• AOX Limits. Though not required by EPA Effluent Guidelines,AOX production-based limits will be held at the
2001 permit levels,based on the facility's performance history.
The Division of Water Quality commends Blue Ridge Paper for the progress made to date in improving water quality in the
Pigeon River,including a 90%reduction in color since 1988 and successful fish reintroduction projects. The Division has
thorougbly considered the comments provided by Blue Ridge Paper,U.S.EPA,the State of Tennessee,local communities
and environmental interest groups to develop this Final permit,which requires additional color reductions.
If any parts,measurement frequencies,or sampling requirements contained in this permit are unacceptable to you,you
have the right to an adjudicatory hearing upon written request within thirty(30)days following receipt of this letter. This
request must be in the form of a written petition,conforming to Chapter 150B of the North Carolina General Statutes,and
filed with the office of Administrative Hearings,6714 Mail Service Center,Raleigh,North Carolina 27699-6714. Unless
such a demand is made,this permit shall be final and binding.
Please take notice that this permit is not transferable except after notice to the Division of Water Quality.The Division
may require modification or revocation and reissuance of the permit.This permit does not affect the legal requirements to
obtain other permits which may be required by the Division of Water Quality,the Division of Land Resources,the Coastal
Area Management Act,or any other federal or local governmental permit.
If you have any questions on this permit,please contact Tom Belnick at 919-807-6390.
Sincerely,
Sra\—�
Jen .Sul
Hardcopy: Central Files,NPDES Files
Asheville Regional Office,SWPS
Email: US EPA,Region 4
Aquatic Toxicology Unit
Shannon Deaton,NC Wildlife Resources Commission
Paul Davis,TN Division of Water Pollution Control
David McKinney,TN Wildlife Resources Agency
Hope Taylor,Clean Water for NC
Hartwell Carson,French Broad Riverkeeper
Iliff McMahan,Mayor Cooke County,TN
1617 Maid Service Center,Raleyh,North Cantina 276994617
Location:512 N.Salisbury SL Raleigh,North Carorma 27604 r,,�ne .
Phone:919-807-M I FAX:919A07-i4921 Customer Service:l-0 1V77-623-6748 OnAhCarO11Ila
Internet xvm.mwaterquatiyorg /� )/��{{rl ////
An Equal Opporlumlyl ARamahs Aceon Employer (NL A(ra{Ly

w. PermitNumber: NC0000272
• r -
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
Final PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1,other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission,
and the Federal Water Pollution Control Act,as amended,
Blue Ridge Paper Products Inc. dba Evergreen Packaging
is hereby authorized to discharge wastewater from a facility located at
Blue Ridge Paper Products Wastewater Treatment Plant
Off Highway 215
Canton
Haywood County
to receiving waters designated as the Pigeon River in the French Broad River Basin in accordance with
effluent limitations,monitoring requirements,and other conditions set forth in Parts I,11,III and IV
hereof.
This permit shall become effective July 1,2010.
This permit and authorization to discharge shall expire at midnight on June 30,2015.
Signed this day May 26,2010. j
Colee—nll. Sullins,Dtr cto
Division of Water Qu lity
By Authority of the Environmental Management Commission

i
Permit Number: NC0000272
SUPPLEMENT TO PERMIT COVER SHEET
Blue Ridge Paper'Products,Inc. dba Evergreen Packaging
is hereby authorized to:
1. Continue operation of a 29.9 MGD wastewater treatment plant for the treatment of wastewater
associated with the Blue Ridge Paper Products Inc, pulp and paper mill, the Town of Canton's
chlorinated domestic wastewater and landfill leachate. The treatment system consists of the
following treatment units:
• Grit Chamber
• Bar Screen
• Lift Pumps
• Polymer addition
• pH control(COZ injection or H2SO4 backup)
• Three primary clarifiers
• Nutrient Feed
• Aeration basins
• Three secondary clarifiers
• Residual belt presses
• Effluent flow measurement
• Cascade post aeration with oxygen injection
• Instream oxygen injection facilities
The facility is located at the Blue Ridge Paper Products WWTP, off Highway 215, Canton,
Haywood County,and;
2. Discharge treated wastewater from said treatment works at the location specified on the attached
map through outfall 001 into the Pigeon River,which is classified C water,in the French Broad
River Basin.
I

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Receiving Stream:Pigeon River glue Rid _
Stream Class:c Ridge Paper Products
Sabbasbt:40365 - Canton Mill ^ �
U/ l SCALE 1:24000

Permit Number: NC0000272
A. (1.)EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration,the Permittee
is authorized to discharge treated industrial,municipal,stormwater and landfill wastewater through
outfall(s)001. Such discharges shall be limited and monitored by the Permittee as specified below:
EffluentCharaetenshcs Efflue EAZ,MamtonngReamre rents r
a;j2€r� x
.� li`� �A 'x e ti} >i� r �r € 6 s+.. F S. r V=S•-n f s ., is k
€ t 's� r Montflty, Da11yr ' �Measureme¢t fjSampleType, a8b '0.1
� ' .^ �� >, '. x .q. � .� �.+f"ttvA f#"tart v sK-• r ���, � ibCv� � #
:Ave age, , Maxkmum Freyue�cY� yn, ? facafkonvV
Flow 29.9 MGD. Continuous Recording I or El
BOD,5-day,20°C 3205 lb/day 10897 lb/day Daily Composite I,Et
Total Suspended Solids 12549lb/day 49560 lb/day Daily Composite I,Et
NH3-N Daily Composite Et
AOX2 1556.9lb/day 2822.2 lb/day Weekly Composite E,
Colo 52,000lb/day 105,250 Daily Composite E,
lb/day
Dissolved Oxygen Daily Grab Et
T erature Dail Grab E,
Daily Grab E,
Conductivity Daily Grab El
Fecal Coliform 200/100 mL 4001100 mL Weekly Grab E,
COD Weekly Composite E,
Total Nitrogen Monthly Composite E,
(NO2-N+NO3-N+TKN)
Total Phosphorus Monthly Composite E,
Chronic Toxicity QuarterlyComposite E,
Trichloro henol 30.6 lb/day QuarterlyComposite E,
Pentachloro henol 4.9lb/day Quarterly Composite E,
Selenium Annual Composite E,
2,3,7,8 Tetrachloro-drbenzo- 0.04 pg/L 0.06 pg1L Annual Composite I,E,
dioxin'
Conductivity' Daily Grab Pigeon River
Flow Daily Grab Pigeon River
Fecal Coliform" Weekly Grab Pigeon River
CoiorloVariable Grab Pigeon River
Dissolved Ox en Variable Grab Pigeon River
Te eramre Variable Grab Pigeon River
Zinc Quarterly Composite E,
Hardnessu QuarterlyComposite 1 E,
Turbidity14 2/Month Grab E,,Pigeon
River
Footnotes:
1. Sample Location:I-Influent,E,—Effluent,Pigeon River-Instream sampling as specified in A.(5.)Instream
Monitoring Special Condition.
2. AOX monitoring shall be in accordance with the Sampling Plan for Cluster Rule Parameters(dated March 19,
2001)or subsequent modifications approved by the Division. AOX data shall be submitted on a quarterly basis
along with other Effluent Guideline chemical data;refer to A.(7.) Effluent Guideline Sampling Plan Special
Condition.
3. Annual average color limit is 38,0201b/day,which will decrease to 32,000-36,000 lb/day no later than 4 years
after the permit effective date. See A.(8.) Color Analysis and Compliance Special Condition.All color limits
are measured as true color.
4. The daily average effluent dissolved oxygen concentration shall not be less than 6.0 mg/L. See A.(10.)
Dissolved Oxygen Special Condition.
5. The permittee shall report daily and monthly average effluent temperature.

Permit Number: NC0000272
6. The pH of the effluent shall not be less than 6.0 nor greater than 9.0(on the standard units scale).
7. Chronic Toxicity(Ceriodaphnia)at 90%Effluent Concentration:March,June,September,December(see A.
(4.)Chronic Toxicity Permit Limit(Quarterly)).
S. Trichlorophenol and Pentachlorophenol limits and monitoring are provisionally waived since the facility has
certified that chlorophenolic biocides are not used at this facility. If the facility changes operations to include
chlorophenolic biocide,the Permittee shall notified the Division prior to use and the limits and monitoring
requirements shall become immediately effective.
9. See A.(9.) Dioxin Monitoring Special Condition.
10. See A.(5.) Instream Monitoring Special Condition.
11. The monthly average instream temperature measured at a point 0.4 miles downstream of the discharge location
shall not exceed 32°C during the months of July,August,and September and shall not exceed 29°C during the
months of October through June. The monthly average instream temperature measured at this location shall not
exceed the monthly average instream temperature of the upstream monitoring location by more than 8.5°C.This
value can be adjusted based on the results of thermal modeling[See Special Condition A.(12.)Temperature
Variance Review Special Condition].
12. Monitoring should be conducted in conjunction with whole Effluent Toxicity Testing.
13. Monitoring should be conducted in conjunction with zinc monitoring.
14. Monitoring shall be conducted upstream of the discharge(mile marker 63.8)and at Fiberville Bridge for 1 year
(12 months). The monitoring shall not occur within 72 hours of a rain event.This permit may be reopened and
modified to include a turbidity limit if a reasonable potential to exceed the State's numeric criterion is found to
exist.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
See A.(6.) Best Management Practices(BMP)Special Condition
See A.(11.) Town of Canton Inflow and Infiltration Special Condition.
Definftions:
MGD—Million gallons per day lb/day—Pounds per day
mL—Milliliter BOD—Biochemical Oxygen Demand
µg/L-Micrograms per liter AOX-Adsorbable Organic Halides
COD-Chemical oxygen demand pg/L-picograms per liter

Permit Number: NC0000272
A.(2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration,the
discharge of wastewater from the pine bleach plant to the wastewater treatment plant through
internal outfall(s)002(Ezr),shall be limited and monitored by the Permittee as specified below and in A.
(7.)Effluent Guideline Sampling Plan Special Condition:
h Efflnent'�f311aiaCf"ensfics�.�'• 'zC c ir•'c a_ �, w
+p � Lunl�s�,�„�,�,--. , r Momfortna Regwretnentsn x,
I`p� a•.. KK nn F+.p s 5�i-,L'�s
f➢.YF� MSY'�`l`.3i"9 tY f 1 Y X M VJS"b�S'.. �P (� RS fift l2�'ail'k 'y-��� �tl'PFitd*�`��> i
r i i� ,3 ",C 1 },+E.� 3 5 a. J! r>•c',•si, vl ..� F
5 yyyy 'appt * ,r Ma�t
�N�pnthlyDailtdeasure et tfatffple 7ypea� TSample�
�`�;GSUti Yi'S dYi'J 4Fi p.}; R T{JAIL 4�. '.'4P N( ah"1.
nf�um� '�`F��°D 0 �
Flow, Weekly Calculated Ez
Chloroform 5.1lb/day 8.6lb/day Quarterly Grab Ez
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Annual Composite EZ
dioxin TCDD
2,3,7,8 Tetrachloro-dibenzo- 31.9 pg/L Annual Composite EZ
furan TCDF)
Trichlorosyringol < 2.5 pg/L? Quarterly Composite Er
3,4,5-Trichlorocatechol -< 5.0 µg/L Quarterly Composite E1
3,4,6-Trichlorocatechol < 5.0 µg/L Quarterly Composite E2
3,4,5-Trichloroguaiacol < 2.5 µg/L Quarterly Composite Et
3,4,6-Trichloroguaiacol < 2.5 µg/L Quarterly Composite EL
4,5,6-Trichloroguaiacol < 2.5 µg/L Quarterly Composite E2
2,4,5-Trichlorophenol < 2.5 µg/L Quarterly Composite , E2
2,4,6-Trichlorophenol < 2.5 µg/L Quarterly Composite Et
Tetmchlorocatechol < 5.0 µg/L Quarterly Composite FZ
Tetrachloroguaiacol < 5.0 µg/L Quarterly Composite Ez
2,3,4,6-Tetrachlorophenol < 2.5 pg/L Quarterly Composite . Er
Pentachlorophenol < 5.0 µg/L Quarterly Composite Ez
Footnotes:
1. Sample Location:Ez—Effluent is composed of Bleach Plant Effluent-acid(acid sewer collected from tap
installed on filtrate pump from C102 bleaching stage D-100 and from tap installed on filtrate pump from C102
bleaching stage D-2)and Bleach Plant Effluent-alkaline(alkaline sewer collected from tap installed on filtrate
pump from alkaline extraction stage E").See A.(7.)Effluent Guideline Sampling Plan Special Condition
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters as prepared by the pennittee(Internal Outfall 002 parameters+internal Outfall 003
parameters+AOX from OutfaD 001)shall be reported on a quarterly basis or more frequently;refer to A.(7.)
Effluent Guideline Sampling Plan Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance or flow
meters,and report total bleach plant flow(acid+alkaline wastestreams)in DMRs. Grab-collect separate grab
samples every 4-hours for 24-hour period from both the acid and alkaline streams,which will then be
composited separately by the lab,and analyzed as separate 24-hr composite acid and allmline samples.
Composite-collect separate grab samples every 4 hours for 24-hour period from both the acid and alkaline
streams,then prepare and analyze a single flow-proportioned composite of the acid and alkaline wastestream
4. For compliance purposes,the pemrittee must report the total chloroform mass loading based on addition of
separate acid and alkaline chloroform mass loadings.
S. Limits are based on Minimum Levels(ML)specified in 40 CFR 430.01.
Definitions:
Ib/day—Pounds per day pg/L—Micrograms per liter
pg/L—Picograms per liter

Permit Number: NC0000272
A.(3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration,the
discharge of wastewater from the hardwood bleach plant to the wastewater treatment plant through
internal outfall(s)003(E31),shall be limited and monitored by the Permittee as specified below and in A.
(7.)Effluent Guideline Sampling Plan Special Condition:
Effluent - ractenstics; t tmlts;*K 5 i5 Molntonng Regmrements :;
t�,�-. z� �Monthty& S�Daifyg y x �ll7easurement SampfeTYPe' x �fSampl8�
sY2: �Y3efa90 i�'„1nlmllm�'�'` f!'.ARIIGy, r`k7"''Sis �� ` z:Locat�on y{
Flo Weekly Calculated E3
Chloroform 6.5lb/day 10.91b/day Quarterly Grab E3
2,3,7,8 Tetmchloro-dibenzo- < 10 pg1L Annual Composite E3
-dioxin TCDD . ..
2,3,7,8 Tetrachloro-dibenzo- ' 31.9 pg/L Annual Composite E3
furan TCDF
Trichlorosyringol < 2.5 µglV Quarterly Composite E3
3,4,5-Tricldorocatechol -]<—5.0 µg/L. Quarterly Composite . E3
3,4,6-Trichlorocatechol < 5.0 µg/L Quarterly Composite E3
3,4,5-Trichloroguaiacol < 2.5 µg/I2 Quarterly Composite E3
3,4,6-Trichloroguaiacol < 2.5 µg2 Quarterly Composite E3
4,5,6-Trichloroguaiacol < 2.5 µg/L Quarterly Composite E3
2,4,5-Trichlorophenol < 2.5 µg/L Quarterly Composite E3
2,4,6-Triclilorophenol < 2.5 pg/L' Quarterly Composite E3
Tetrachlorocatechol < 5.0 µg/L Quarterly Composite E3
Tetrachloroguaiacol < 5.0 µg/Ls I QuarterlyComposite
mposite E3.
2,3,4,6-Tetrachlorophenol < 2.5 µg/L Quarterly Composite E3
Pentachlorophenol < 5.0 µg/L Quarterly Composite E3
Footnotes:
1. Sample Location:E3—Effluent is composed of Bleach Plant Effluent-acid(acid sewer collected from tap
installed on filtrate pump from C10Z bleaching stage D-100)and Bleach Plant Effluent-alkaline(alkaline
sewer collected from tap installed on filtrate pump from alkaline extraction stage E.).See A.(7.)Effluent
Guideline Sampling Plan Special Condition.
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters,as prepared by the permittee(Internal Outfall 002 parameters+internal Outfall 003
parameters+AOX from Outfall 001)shall be reported on a quarterly basis or more frequently;refer to A.(7.)
Effluent Guideline Sampling Plan Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance or by flow
meter,and report total bleach plant flow(acid+alkaline wastestreams)in DMRs. Grab-collect separate grab
samples every 4-hours for 24-hour period from both the acid and alkaline streams,which will then be
composited separately by the lab,and analyzed as separate 24-hr composite acid and alkaline samples.
Composite-collect separate grab samples every 4 hours for 24-hour period from both the acid and alkaline
streams,then prepare and analyze a single flow-proportioned composite of the acid and alkaline wastestream.
4. For compliance purposes,the pemvttee must report the total chloroform mass loading based on addition of
separate acid and alkaline chloroform mass loadings.
S. Limits are based on Minimum Levels(ML)specified in 40 CFR 430.01.
Definitions:
lb/day—Pounds per day µg/L—Micrograms per liter
pg/L—Picograms per liter

r ,
Permit Number: NC00O0272
A.(4.) CIIRoxic TOXICITY PERMIT LIMIT(QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dabia at an effluent concentration of 90%.
The permit holder shall perform at a minimum,quarterly monitoring using test procedures outlined in the`North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure,"Revised February 1998,or subsequent versions or
"North Carolina Phase If Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or subsequent
versions.The tests will be performed during the months ojMarch,June,September,December.Effluent sampling
for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit
limit,then multiple-concentration testing shall be performed at a minimum in each of the two following months as
described in"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure'(Revised-February 1998)or
subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival.The definition of"detectable impairment,"collection
methods,exposure regimes,and further statistical methods are specified in the'North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form(MR-1)for the months in which tests were performed,using the parameter code TGP313 for the
pass/fail results and TBP3B for the Chronic Value.Additionally,DWQ Form AT-3(original)is to be sent to the
following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center t
Raleigh,North Carolina 27699-1621
Completed Aquatic Toxicity Test Form%shall be filed with the Environmental Sciences Branch no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete,accurate,include all supporting chemical/physical measurements and all
concentrationlresponse data,and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,the
pemnttee will complete the information located at the top of the aquatic toxicity(AT)test form indicating the
facility name,permit number,pipe number,county,and the mouth/year of the report with the notation of`No Flow"
in the comment area of the form The report shall be submitted to the Environmental Sciences Branch at the address
cited above.Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be-required during the following month. Should any test data from this monitoring requirement or
tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream
this permit may be re-opened and modified to include alternate monitoring requirements or limits.
If the Permittee monitors any pollutant more frequently then required by this pemtit,the results of such monitoring
shall be included in the calculation&reporting of the data submitted on the DMR&all AT Forms submitted.
NOTE: Failure to achieve test conditions as specified in the cited document,such as minimum control organism
survival,minimum control organism reproduction,and appropriate environmental controls,shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.

Permit Number: NC0000272
A. (5.) INSTREAM MONITORING SPECIAL CONDITION
Stream Mile Location Description Parameter Frequency
Designation Marker
UP 63.5 Pigeon River upstream of the Temperature Daily
waste treatment plant outfall D.O. Daily
(prior to mixing with the Conductivity 'Daily
discharge) Color' 2/Week
Flow' Daily
Fecal.Coliform Weekly
DN13 62.9 Pigeon River at Fiberville Bridge Temperature Daily
D.O. Daily
Conductivity Daily
Color' 21Week
DN23 57.7 Pigeon River Above Clyde Temperature Daily
D.O. Daily
DN3J 55.5 Pigeon River Below Clyde See Footnote 3 See Footnote 3
5N4 53.5 Pigeon River at NCSR 1625 See Footnote 3 See Footnote 3
bridge
DN5 42.6 Pigeon River at Hepco Temperature Weekly
D.O. Weekly
Color Weekly
Flow, Daily
DN6 26.0 Pigeon River prior to mixing with Color Weekly
_ Big Creek
BC —26.0 Mouth of Big Creek prior to Color Weekly
mixing with the Pigeon River
DN7 24.7 Pigeon River at Browns Bridge Temperature Weekly
(—NC/TN State Line) D.O. Weekly
Coloi Weekly
All instream samples shall be grab samples.
Footnotes:
I. Color(See A.(8.)Color Analysis and Compliance Special Condition). All instream samples collected
shall be representative of the Pigeon River and Big Creek,respectively. Both true and apparent color
shall be monitored using the methods specified in A.(8.)Color Analysis and Compliance Special
Condition. Samples shall be collected at stations DN6,BC,and DN7 only when at least one generator
at Progress Energy is in operation and releasing water to the Pigeon River. Samples collected at DNl
shall be collected from the middle or midpoint of the transect of the Pigeon River.
2. Flow monitoring is necessary,as specified above for the True Color calculation.
3. Dissolved Oxygen. The average daily dissolved oxygen concentration measured at River Mile 62.9
(DNI),and 57.7(DN2),shall not be less than 5.0 mg/L and the instantaneous minimum dissolved
oxygen concentration shall not be less than 4.0 mg/L(See A. (10.) Dissolved Oxygen Special
Condition). If the dissolved oxygen drops below 5.0 mg/L at station 57.7 then monitoring shall be
required at stations 55.5(DN3)and 53.5 (DN4).

Permit Number: NC0000272
A. (6.) BEST MANAGEMENT PRACTICES(BMP)SPECIAL CONDITION
The permittee must implement the BMPs specified below. The primary BMP objective is to prevent
leaks and spills of spent pulping liquors,soap,and turpentine. A secondary objective is to contain,
collect,and recover at the immediate.process area,or otherwise control,those leaks,spills,and intentional
diversions of spent pulping liquor,soap,and turpentine that do occur. BMPs must be developed
according to best engineering practices and must be implemented in a manner that takes into account the
specific circumstances at the mill.
Section A. BMP Implementation Requirements
1. The permittee must return spilled or diverted spent pulping liquors,soap,and turpentine to the
process to the maximum extent practicable as determined by the mill,recover such materials outside
the process,or discharge spilled of diverted material.at a rate that does not disrupt the receiving
wastewater treatment system.
2. The permittee must maintain a program to identify and repair leaking equipment items. This program
must include: (i)Regular daily visual inspections of process area with equipment items in spent
pulping liquor,soap,and turpentine service; (ii)Immediate repair of leaking equipment items,when
possible. Leaking equipment items that cannot be repaired during normal operations must be
identified,temporary means for mitigating the leaks must be provided,and the leaking equipment
items repaired during the next maintenance outage; (iii)Identification of conditions under which
production will be curtailed or halted to repair leaking equipment items or to prevent pulping liquor,
soap,and turpentine leaks and spills;and(iv)A means for tracking repairs over time to identify those
equipment items where upgrade or replacement may be warranted based on frequency and severity of
leaks,spills,or failures.
3. The permittee must operate continuous,automatic monitoring systems that the mill determines are
necessary to detect and control leaks,spills,and intentional diversions of spent pulping liquor, soap,
and turpentine.These monitoring systems should be integrated with the mill process control system
and may include,e.g.,high level monitors and alarms on storage tanks;process area conductivity(or
pH)monitors and alarms;and process area sewer,process wastewater,and wastewater treatment plant
conductivity(or pH)monitors and alarms.
4. The permittee must maintain a program of initial and refresher training of operators,maintenance
personnel,and other technical and supervisory personnel who have responsibility for operating,
maintaining,or supervising the operation and maintenance of equipment items in spent pulping
liquor,soap,and turpentine service.The refresher training must be conducted at least annually and
the training program must be documented.
5. The permittee must prepare a brief report that evaluates each spill of spent pulping liquor,soap,or
turpentine that is not contained at the immediate process area and any intentional diversion of spent
pulping liquor,soap,or turpentine that is not contained at the immediate process area.The report
must describe the equipment items involved,the circumstances leading to the incident,the
effectiveness of the corrective actions taken to contain and recover the spill or intentional diversion, _
and plans to develop changes to equipment and operating and maintenance practices as necessary to
prevent recurrence.Discussion of the reports must be included as part of the annual refresher training.
6. The permittee must maintain a program to review any planned modifications to the pulping and
chemical recovery facilities and any construction activities in the pulping and chemical recovery areas
before these activities commence. The purpose of such review is to prevent leaks and spills of spent
pulping liquor,soap,and turpentine during the planned modifications,and to ensure that construction
and supervisory personnel are aware of possible liquor diversions and of the requirement to prevent
leaks and spills of spent pulping liquors,soap,and turpentine during construction.
7. The permittee must install and maintain secondary containment(i.e.,containment constructed of
materials impervious to pulping liquors)for spent pulping liquor bulk storage tanks equivalent to the
volume of the largest tank plus sufficient freeboard for precipitation.An annual tank integrity testing
program,if coupled with other containment or diversion structures,may be substituted for secondary
containment for spent pulping liquor bulk storage tanks.

Permit Number: NC0000272
8. The permittee must install and maintain secondary containment for turpentine bulk storage tanks.
9. The permittee must install and maintain curbing, diking or other means of isolating soap and
turpentine processing and loading areas from the wastewater treatment facilities.
10. The permittee must conduct wastewater monitoring to detect leaks and spills,to track the
effectiveness of the BMPs,and to detect trends in spent pulping liquor losses. Such monitoring must
be performed in accordance with Section E.
Section B. BMP Plan Requirements
1. The permittee must maintain and implement a BMP Plan.The BMP Plan must be based on a detailed
engineering review as described in this section. The BMP Plan must specify the procedures and the
practices required for the mill to meet the requirements of Section A,the construction the mill
determines is necessary to meet those requirements including a schedule for such construction,and
the monitoring program(including the statistically derived action levels)that will be used to meet the
requirements of Section E.The BMP Plan also must specify the period of time that the mill
determines the action levels established under Section D may be exceeded without triggering the
responses specified in Section E.
'2. The permittee must conduct a detailed engineering review of the pulping and chemical recovery
operations—including but not limited to process equipment,storage tanks,pipelines and pumping
systems,loading and unloading facilities,and other appurtenant pulping and chemical recovery
equipment items in spent pulping liquor,soap, and turpentine service--for the purpose of determining
the magnitude and routing of potential leaks,spills,and intentional diversions of spent pulping
liquors,soap,and turpentine during the following periods of operation: (i)Process start-ups and shut
downs;(ii)Maintenance; (iii)Production grade changes; (iv) Storm or other weather events; (v)
Power failures;and(vi)Normal operations.
3. As part of the engineering review,the permittee must determine whether existing spent pulping liquor
containment facilities are of adequate capacity for collection and storage of anticipated intentional
liquor diversions with sufficient contingency for collection and containment of spills.The engineering
review must also consider:(i)The need for continuous,automatic monitoring systems to detect and
control leaks and spills of spent pulping liquor,soap,and turpentine;(ii)The need for process
wastewater diversion facilities to protect end-of-pipe wastewater treatment facilities from adverse
effects of spills and diversions of spent pulping liquors,soap,and turpentine; (iii)The potential for
contamination of storm water from the immediate process areas;and(iv)The extent to which
segregation and/or collection and treatment of contaminated storm water from the immediate process
areas is appropriate.
4. The permittee must amend its BMP Plan whenever there is a change in mill design,construction,
operation,or maintenance that materially affects the potential for leaks or spills of spent pulping
liquor,turpentine,or soap from the immediate process areas.
5. The permittee must complete a review and evaluation of the BMP Plan five years after the first BMP
Plan is prepared and,except as provided in Section B.4.,once every five years thereafter. As a result
of this review and evaluation,the permittee must amend the BMP Plan within three months of the
review if the mill determines that any new or modified management practices and engineered controls
are necessary to reduce significantly the likelihood of spent pulping liquor,soap,and turpentine leaks,
spills,or intentional diversions from the immediate process areas,including a schedule for
implementation of such practices and controls.
6. The BMP Plan,and any amendments thereto,must be reviewed by the senior technical manager at the
mill and approved and signed by the mill manager.Any person signing the BMP Plan or its
amendments must certify to the Division under penalty of law that the BMP Plan(or its amendments)
has been prepared in accordance with good engineering practices and in accordance with this
regulation.The permittee is not required to obtain approval from the Division of the BMP Plari or any
amendments thereto.

Permit Number: NC0000272
Section C. BMP Recordkeeping Requirements
1. The permittee must maintain on its premises a complete copy of the current BMP Plan and the
records specified in Section C.2 and must make such BMP Plan and records available to the Division
for review upon request.
2. The permittee must maintain the following records for three years from the date they are created:(i)
Records tracking the repairs performed in accordance with the repair program described in Section A;
(ii)Records of initial and refresher training conducted in accordance with Section A;(iii)Reports
prepared in accordance with Section A;and(iv)Records of monitoring required by Sections A and E.
Section D Establishment of Wastewater Treatment System Influent Action Levels
1. The permittee must conduct a monitoring program per Section D.2,for the purpose of defining
wastewater treatment system influent characteristics(or action levels),described in Section D.3,that
will trigger requirements to initiate investigations on BMP effectiveness and to take corrective action.
2. The permittee must employ the following procedures in order to develop the action levels required by
Section D:
■ Monitoring parameters.The permittee must collect 24-hour composite samples and analyze the
samples for a measure of organic content(e.g.,Chemical Oxygen Demand(COD)or Total
Organic Carbon(TOC)).Alternatively,the mill may use a measure related to spent pulping liquor
losses measured continuously and averaged over 24 hours(e.g.,specific conductivity or color).
• Monitoring locations.The permittee must conduct monitoring at the point influent enters the
wastewater treatment system. For the purposes of this requirement,the permittee may select
alternate monitoring point(s)in order to isolate possible sources of spent pulping liquor,soap,or
turpentine from other possible sources of organic wastewaters that are tributary to the wastewater
treatment facilities(e.g.,bleach plants,paper machines and secondary fiber operations).
3. The permittee must maintain an influent action levels monitoring program using the procedures
specified in Section D and must maintain action levels based on the results of that program.A
wastewater treatment influent action level is a statistically determined pollutant loading determined
by a statistical analysis of six months of daily measurements.The action levels must consist of a
lower action level,which if exceeded will trigger the investigation requirements described in Section
E, and an upper action level,which if exceeded will trigger the corrective action requirements
described in Section E.
4. The permittee must complete a second six-month monitoring program using the procedures specified
in Section D and must establish revised action levels based on the results of that program.The initial
action levels shall remain in effect until replaced by revised action levels based on Section D5
requirements.
5. Action levels developed under this Section must be revised using six months of monitoring data after
any change in mill design,construction,operation,or maintenance that materially affects the potential
for leaks or spills of spent pulping liquor,soap,or turpentine from the immediate process areas.
Section E BMP Monitoring Corrective Action and Reporting Requirements
1. The permittee must conduct daily monitoring of the influent to the wastewater treatment system in
accordance with the procedures described in Section D for the purpose of detecting leaks and spills,
tracking the effectiveness of the BMPs,and detecting trends in spent pulping liquor losses.
2. Whenever monitoring results exceed the lower action level for the period of time specified in the
BMP Plan,the permittee must conduct an investigation to determine the cause of such exceedance.
Whenever monitoring results exceed the upper action level for the period of time specified in the
BMP Plan,the permittee must complete corrective action to bring the wastewater treatment system
influent mass loading below the lower action level as soon as practicable.

�V f
Permit Number: NC0000272
3. Although exceedances of the action levels will not constitute violations of an NPDES permit,failure
to take the actions required by Section E.2 as soon as practicable will be a permit Violation.
4. The permittee must report to the Division the results of the daily monitoring conducted pursuant to
Section E.1.Such reports must include a summary of the monitoring results,the number and dates of
exceedances of the applicable action levels,and brief descriptions of any corrective actions taken to
respond to such exceedances. Submission of such reports shall be annually,by March 31"of the
following year.
Section F. BMP Definitions
1. Action Level:A daily pollutant loading that when exceeded triggers investigative or corrective action.
Mills determine action levels by a statistical analysis of six months of daily measurements collected at
the mill.For example,the lower action level may be the 75th percentile of the running seven-day
averages(that value exceeded by 25 percent of the running seven-day averages)and the upper action
level may be the 90th percentile of the running seven-day averages(that value exceeded by 10
percent of the running seven-day averages).
2. Division: North Carolina DENR,Division of Water Quality, 1617 Mail Service Center,Raleigh,
North Carolina 27699-1617.
3. Equipment Items in Spent Pulping Liquor, Soap,and Turpentine Service:Any process vessel,storage
tank,pumping system,evaporator,heat exchanger,recovery furnace or boiler,pipeline,valve,fitting,
or other device that contains,processes,transports,or comes into contact with spent pulping liquor,
soap,or turpentine.Sometimes referred to as"equipment items."
4. Immediate Process Area:The location at the mill where pulping,screening,knotting,pulp washing,
pulping liquor concentration,pulping liquor processing,and chemical recovery facilities are located,
generally the battery limits of the aforementioned processes. "Immediate process area"includes spent
pulping liquor storage and spill control tanks located at the mill,whether or not they are located in the
immediate process area.
5. Intentional Diversion:The planned removal of spent pulping liquor,soap,or turpentine from
equipment items in spent pulping liquor,soap,or turpentine service by the mill for any purpose
including,but not limited to,maintenance,grade changes, or process shutdowns.
6. Mill:The owner or operator of a direct or indirect discharging pulp,paper,or paperboard
manufacturing facility subject to this section.
7. Senior Technical Manager:The person designated by the mill manager to review the BMP Plan.The
senior technical manager shall be the chief engineer at the mill,the manager of pulping and chemical
recovery operations,or other such responsible person designated by the mill manager who has
knowledge of and responsibility for pulping and chemical recovery operations.
8. Soap:The product of reaction between the alkali in kraft pulping liquor and fatty acid portions of the
wood,which precipitate out when water is evaporated from the spent pulping liquor.
9. Spent Pulping Liquor:For kraft and soda mills"spent pulping liquor"means black liquor that is used,
generated, stored,or processed at any point in the pulping and chemical recovery processes.
10.Turpentine:A mixture of terpenes,principally pinene,obtained by the steam distillation of pine gum
recovered from the condensation of digester relief gases from the cooking of softwoods by the kraft
pulping process.Sometimes referred to as sulfate turpentine.

Permit Number: NC0000272
A. (7.) EFFLUENT GUIDELINE SAMPLING PLAN SPECIAL CONDITION
The bleach plant effluent samples(Outfalls 002 and 003)shall be analyzed for 2,3,7,8-TCDD in
accordance with EPA Method 1613. A single sample,from each of the bleach plant effluents,may be
analyzed to determine compliance with the daily maximum effluent limitation.
The bleach plant effluent samples(Outfall 002 and 003)shall be analyzed for the 12 chlorinated phenolic
compounds in accordance with EPA Method 1653. A single sample,from each of the bleach plant
effluents,may be analyzed to determine compliance with the daily maximum effluent limitation. The
Minimum Levels for each of the 12 chlorinated compounds are the same as the Daily Maximum
concentrations listed on the effluent pages for the respective outfall(s).
The final wastewater treatment plant effluent sample(Outfall 001)shall be analyzed for AOX in
accordance with EPA Method 1650,or subsequent test methods approved by the Division.
The pernuttee may request future monitoring modifications to the Effluent Guideline requirements,
including 1)use of ECF certification in lieu of monitoring for chloroform in the bleach plant effluents
(Outfall(s) 002 and 003)2)demonstrating compliance using samples collected less frequently than every
four hours; 3)using automated composite volatile samplers for chloroform sampling;and 4)using
automated composite samplers for chlorophenolic,2,3,7,8 TCDD and 2,3,7,8 TCDF sampling. Such
future requests will be evaluated in accordance with ISA NCAC 2H.0114.
The flow calculations for internal Outfall(s)002 and 003 shall not be subject to accuracy requirements
specified under Part II,Section D.3. This exclusion is similar to that provided for pump log flow
calculations.
Chemical data for Effluent Guideline parameters(Outfall(s)002 and 003 parameters+AOX from Outfall
001)shall be submitted to the Division on a quarterly basis or more frequently(January-March,April-
June,July-September,October-December). Quarterly submissions shall be due 60 days following the
last day of each quarter(Due dates=May 31,August 31,November 30,and February 28). Chemical data
shall be submitted on Division-approved DMR forms,with a separate form provided for each month.

Permit Number: NC0000272
A. (8.) REQUIREMENTS FOR COLOR ANALYSIS AND COMPLIANCE SPECIAL CONDITION
1. The color reduction requirements contained in this special condition have been derived directly
from the mill's efforts to identify possible reduction measures and from the EPA Technology
Review Workgroup (TRW report dated February 25, 2008)
2. The average annual discharge of true color for each calendar year shall not exceed 38,020 pounds
per day. The monthly average effluent true color loading shall not exceed 52,000 pounds per day.
For the purpose of this permit only, "pounds of true color"is calculated by the following
equation:
Effluent Flow(MGD)x Effluent True Color Level(Platinum Cobalt Units)x 8.34.
3. All samples collected for color analysis and for use in the above calculation shall be measured
and reported using the procedure referenced in 39 FR 430.11 (b) (May 29, 1974)-true and
apparent color or as amended by the EPA.
4. Four years after the permit effective date,the average annual discharge of true color for each
calendar year shall not exceed 32,000-36,000 pounds per day
5. The permittee shall not increase the mill's pulp production capacity during the term of this permit,
unless the permittee can demonstrate that the increased production can be achieved while
reducing color loading. In addition,increasing the mill's pulp production capacity may require
permit revision in accordance with North Carolina's NPDES Permitting rules.
6. The NPDES Permit shall be subject to reopening in order to modify the color requirements based
upon the following:
• Any breakthrough in color removal technologies.Such breakthroughs shall be brought to
the NPDES Committee for consideration,by Blue Ridge Paper and the Division of Water
Quality,as soon as they are discovered.
• An acceptable statistical analysis of effluent color discharge data demonstrating
significantly better color removal performance than that currently prescribed in the
permit,except as noted herein.
• Successful application of end-of-pipe color reduction technology or in-mill color
minimization effort that results in significant and measurable reduced mass color
discharge.
7. The transfer of this NPDES permit will not proceed until any successor-in-interest to the current
permittee has agreed to accept the provisions of this permit.
8. The facility will provide annual progress reports to the Division on the color reduction efforts.
9. To minimize color discharges during periods of lowest river flow and higher recreational use in
the river,no major maintenance outages will be scheduled during the months of June,July and
August.
10. Based on the EPA TRW recommendations,the permittee shall evaluate the technologies
identified below and develop an implementation plan that would either utilize these technologies

Permit Number: NC0000272
when technically,operationally,or economically feasible,or identify other options that will result
in similar increments of color reduction. The TRW may review and comment on the justification
for any item among the following recommendations found by Blue Ridge Paper to be technically,
operationally,or economically infeasible:
A. The following suite of items will be implemented by the pemrittee,upon further expedited
evaluation if necessary to refine detailed design and operating parameters,during this permit
term:
• further improvements in leak and spill prevention and control(BMP's) covering all
process lines,including probable color-generating sources(e.g.,sulfide containing)
among white and green liquors in the recovery cycle
• process optimization(enhanced extraction stages,reduced bleaching chemical use,etc.);
and
• addition of second stage oxygen delignification on the softwood/pine fiber line
The time necessary for Blue Ridge Paper to implement these items or alternatives in logical
sequence should realistically reflect the Mill's ability to design,fund, and install or implement
them at the earliest possible date. For example,an updated and detailed evaluation of the addition
of second stage oxygen delignification on the softwood fiber line should identify necessary
adjustments to upstream pulp digestion(e.g.,kappa number targets),bleaching(e.g.,bleaching
chemical usage rates,kappa factors)and downstream brightness/strength and other relevant
process control and product quality parameters,designing and costing,and refining color
reduction projections.
B. The following items will be evaluated and implemented as appropriate during this permit
term:
• increasing filtrate recycle and use of the existing BFR process for the hardwood fiber line
• reducing black liquor carryover by further evaluating in detail and adjusting operating
conditions in the direct contact evaporators(DCEs)
• reducing impact of Chloride Removal Process(CRP)purge on treated effluent color by
gathering data sets over as long a period as possible,preferably at full scale,with and
without the CRP purge to better understand the impact on treatability of this source of
color. If it is determined that CRP color is found not to be removed in the treatment
system,further study should assess:
o securing whatever additional reductions are possible based on any
demonstrated technology that works and can be economically applied to this
waste stream,either within the mill and sewer system,or chlorine dioxide
pretreatment to reduce color in the CRP purge stream prior to introduction to
the treatment system
o avoiding release of the CRP purge during periods of low flow in the receiving
stream
• better understanding and controlling,if possible,the physical and chemical mechanisms
underlying"sewer generated color". This will require a sustained effort going forward
beyond this permit term given that process changes and BMP improvements to be made
will more than likely further change the chemistry and mechanisms underlying"sewer
generated color".
• improving color removal by the Mill's wastewater treatment plant via:
o better equalizing and further optimizing treatment by using polymers and other
chemicals to pretreat highly-colored segregated wastewaters including streams
that are diverted to the extra primary clarifier,or by other operational and/or
treatment means not yet identified

� l
Permit Number: NC000O272
o investigating use of polymers or other chemicals upstream of the secondary
clarifiers,especially during periods of high influent color and/or low river flow
11. The facility shall submit the color reduction implementation plan within the first year of permit
issuance.The permit will be reopened and modified to include interim requirements and dates for
their achievement based on the submitted implementation plan.
12. The facility shall submit a low flow contingency plan for color control within the first year of
permit issuance.
A. (9.) DIOXIN MONITORING SPECIAL CONDITION
The permittee shall perform the analyses for dioxin and dibenzofuran as outlined below:
�� �' SamDllllePWnts +v MOD1I;OCIIIQ�3..�°''
Meadw emenl Sample Type
r�'7xiI"'
Influent to Wastewater Annual Composite
Treatment Plant] _
Eflluen Annual Composite
Sludge Annual Composite
Landfill Leachate Annual Composite
Footnotes:
1. The samples shall be analyzed for 2,3,7,8-TCDD and 2,3,7,8 TCDF in accordance with EPA Method
1613. A single sample maybe analyzed. Alternatively,the sample volumes maybe collected to
enable the sample to be split(duplicate analysis).The Minimum Level in the effluent for 2,3,7,8-
TCDD and 2,3,7,8 TCDF by EPA Method 1613 is 10 pg1l.
2. The effluent samples shall be analyzed for the full range of dioxin and fisan isomers as identified in
the list below and shall be in accordance with EPA Method 1613. A single sample may be analyzed.
Alternatively,the sample volumes may be collected to enable the sample to be split(duplicate
analysis).The minimum level using these methods for the purpose of compliance evaluation is
considered to be 10 picograms per liter
DIOXIN DIBENZOFURAN
Isomer Isomer
2,3,7,8 TCDD 2,3,7,8 TCDF
1,2,3,7,8 PeCDD 1,2,3,7,8 PeCDF
2,3,4,7,8 PeCDF
1,2,3,4,7,8 HxCDD 1,2,3,4,7,8-HxCDF
1,2,3,7,8,9 HxCDD 1,2,3,7,8,9.HxCDF
1,2,3,6,7,8- HxCDF
1,2,3,6,7,8 HxCDD 2,3,4,6,7,8 -HxCDF
1,2,3,4,6,7,8 HpCDD 1,2,3,4,6,7,8- HpCDF
1,2,3,4,7,8,9-HpCDF
If dioxins or dibenzofurans are detected in the effluent above the minimum level,the permittee shall
initiate Quarterly monitoring of sludge,landfill leachate,and effluent.

Permit Number: NC0000272
Additional Requirements
Annual dioxin fish tissue analysis shall be performed during the 1 , 3'a,and 5 h calendar year of this
permit term in accordance with the Division of Water Quality approved monitoring plan.The monitoring
plan is an enforceable part of this permit.All dioxin data collected as part of this monitoring requirement
will be reported as required in the plan,no later than 180 days after sampling.The tissue monitoring will
be performed in Waterville Lake,although the facility may substitute one lake event with a sampling in
the Pigeon River below the outfall.
A. (10.) DISSOLVED OXYGEN SPECIAL CONDITION
The permittee shall maintain an average daily dissolved oxygen concentration of not less than 5.0 mg/L
with a minimum instantaneous value of not less than 4.0 mg/L at River Miles 62.9(DN1)and 57.7
(DN2). The permittee shall operate oxygen injection facilities at the outfall.structure,at 0.9 miles
downstream of the discharge,and at 2.1 miles downstream of the discharge,as necessary,to comply with
this requirement. These facilities shall be operated in a manner which will maintain the water quality
standard for dissolved oxygen in the Pigeon River downstream of the discharge. Blue Ridge Paper shall .
report the date and duration of oxygen injection use as a supplement to the monthly Discharge Monitoring
Report(DMR)forms.If the dissolved oxygen drops below 5.0 mg/L at station DN2 then monitoring shall
be required at stations DN3 and DN4.
A. (11.) TOWN OF CANTON INFLOW AND INFILTRATION SPECIAL CONDITION .
The permittee shall make continued efforts to promote reduction of inflow/infiltration to the Town of
Canton's wastewater collection system.
A. (12.) .... TENTERATURE VARIANCE REVIEW SPECIAL CONDITION
Blue Ridge Paper shall complete an analysis of temperatire,including thermal modeling and shall submit
a balanced and indigenous species study,no later than 180 days prior to the permit expiration date. As
part of this analysis,Blue Ridge Paper shall submit a complete temperature variance report documenting
the need for a continued temperature variance.The temperature delta of 8.5°C can be adjusted based on
the results of the BIP thermal modeling.
The study shall be performed in accordance with the Division of Water Quality approved plan.The
temperature analysis and the balanced and indigenous study plan shall conform to the specifications
outlined in 40 CER 125 Subpart H and the EPXs Draft 316a Guidance Manual,dated 1977.The EPA
shall be provided an opportunity to review the plan prior to the commencement of the study.

TOTAL INFLUENT = LOW LIFT
RETURN ACTIVATED SLUDGE
1---------------------I
1 BE
1
PRIMARYINFLUENT I EFFLUENT OUTFALL
PRIMARY AERATION SECONDARY FLOW METER FINAL
CLARIFIERS *PE BASINS CLARIFIERS CASCADEAERATION EFFLUENT
PRIMARY EFFLUENTDIFFUSER 29.9 MGD
CANTON EFFLUENT
WW 'LL 1-....,
0.9 MGD 1 SECONDARY EFFLUENT -�
LOW LIFT i
MILL GRITCHAMBER AEROBIC.......... ............................... .....i
SEWER BAR SCREENS 1 DIGESTER(S)
26 to 29 MGD PUMPS-4X 15 MGD 1 WASTE SLUDGE
:...............'.
ACID FILTRATE
SEWER
0 to 3 MGD
•...• SLUDGE
DEWATERING
PROCESS AND COMPLIANCE SAMPLE LOCATIONS
I
. 'LL=LOW LIFT-TIME PACED
DEWATERED SLUDGE •PE=PRIMARY EFFLUENT-TIME PACED
TO LANDFILL •SE=SECONDARY EFFLUENT-FLOW PACED
FINAL EFFLUENT-GRAB(pH,temp,cond,DO&fecal)
PRIMARY CLARIFIERS AERATION BASINS/AEROBIC DIGESTERS SECONDARY CLARIFIERS J
2- 200 Fr DIA X 14.75 FT SWD 2-2.3 MGAL(ONE OR BOTH USED FOR AEROBIC DIGESTION) 2- 200 FT DIA X 12 FT SWD
3.47 MGAL,EACH 2-3.4 MGAL USED FOR ACTIVATED SLUDGE 2,82 MGAL,EACH
11.4 MGAL TOTAL AVAILABLE VOLUME
1-125 FT DIAXII FT SWD 1-150 FT CIA XI4 FT SWD
1.01 MGAL 20 SURFACE AERATORS 1.85 MGAL '
SPARE CLARIFIER USED FOR SPILL COLLECTION 125/56 HP, 1.3 LEIS 02 PER HP-HR SPARE CLARIFIER USED FOR SEASONAL USE
RETURN SLUDGE 50 TO 100%
WASTE SLUDGE 2 TO 5
�V
ry Figure 1 - 2001 to 2005 WASTEWATER FLOW DIAGRAM (typical)
qBlue Ridge Paper Products, Inc.
Canton Mill
NPDES NC 0000272

Page I
.. .........
TOTAL INFLUENT = LOW LIFE + ACID..SE. WER........••
RETURN ACTIVATED SLUDGE
ACID AS
SEWER ? r-____________________i
0 to 3 MGD ......................................• ;
SE
1 1•...................................
PRIMARY INFLUENT
EFFLUENT OUTFALL
PRIMARY AERATION SECONDARY FLOW METER FINAL
CLARIFIERS •••.••'PE BASINS CLARIFIERS CASCADE AERATION EFFLUENT
PRIMARY EFFLUENTDIFFUSER 29.9 MGD_
CANTON EFFLUENT
WW •LL
0.9 MGD 1
SECONDARY EFFLUENT
LOW LIFT
MILLIFGAR CHAMBER .......... ' AEROBIC .....I
SEWER BAR SCREENS 1 . DIGESTERS)
26 to 29 MGD PUMPS-4 X 15 MGD WASTE SLUDGE
1
FILTRATE
SLUDGE
DEWATERING
PROCESS AND COMPLIANCE SAMPLE LOCATIONS
I
. 'LL=LOW LIFT-TIME PACED
•AS=ACID SEWER-TIME PACED
DEWATERED SLUDGE •PE=PRIMARY EFFLUENT-TIME PACED
TO LANDFILL •BE=SECONDARY EFFLUENT-FLOW PACED
FINAL EFFLUENT-GRAB(pH,temp,cond,DO&fecal)
PRIMARY CLARIFIERS AERATION BASINS/AEROBIC DIGESTERS SECONDARY CLARIFIERS _
2- 200 FT DIA X 14.75 FT SWD 2-2.3 MGAL(ONE OR BOTH USED FOR AEROBIC DIGESTION) 2- 200 FT CIA X 12 FT SWD
3.47 MGAL,EACH 2-3.4 MGAL USED FOR ACTIVATED SLUDGE 2.82 MGAL,EACH
- 11.4 MGAL TOTAL AVAILABLE VOLUME
1 -125 FT DIA X II FT SWD 1-150 FT DIA X 14 FT SWD
1.01 MGAL 20 SURFACE AERATORS 1.85 MGAL
SPARE CLARIFIER USED FOR SPILL COLLECTION 125/56 HP, 1.3 LES 02 PER HP-HR SPARE CLARIFIER USED FOR SEASONAL USE
RETURN SLUDGE 50 TO 100 h
WASTE SLUDGE 2 TO 5%
C�
S7
Figure 2 - 2006 WASTEWATER FLOW DIAGRAM AFTER ACID SEWER PROJECT (typical)
�Q Blue Ridge Paper Products,Inc.
j Canton Mill
NPDES NC 0000272

Executive Summary
DWQ Responses to EPA Permit Objection Letter
Blue Ridge Paper/NC0000272
March 17, 2010
Specific Objection 1• Technology-Based Color Limits and Compliance Schedule
EPA objections:
• Permit must require initial annual avg. color permit limit of 37,9001b/day instead of 39,000 lb/day.
• Permit must require annual avg. color limit of 32,000-36,000Ib/day at end of 4-year compliance
schedule.
• Permit must require facility to submit implementation plan within first year of permit issuance
• Permit must include reopener to include interim requirements and dates for their achievement
DWO Response:
The first EPA TRW Report(2001)recommended a color range of 32,000-39,000 lbs/day annual average at end of
permit term(by 2006). Blue Ridge(2005) data supported 39,000 lb/day,and this value was applied as the starting
point for current Draft permit. EPA is requiring starting color limit of 37,900 lb/day,which would have been
violated in 2009.
The second EPA TRW Report(2008)recommended color range of 32,000-37,000 lbs/day as an annual average,
applied no later than end of upcoming permit term. EPA is now objecting to their 2008 proposal,and now
requires a color range of 32,000-36,000. Given uncertainties of color reduction efforts,DWQ staff believes
original EPA TRW recommended target range should remain.
DWQ can add an implementation plan submittal requirement into permit; however, it will only contain a color
evaluation schedule.It is impossible to predict which recommended measures will produce results. During the
previous permit term the Canton mill evaluated 35 different measures,and only a very few of them were effective
or found to be technically,operationally,and economically feasible.
Specific Objection 2: Effluent Limit for Color; Protection of Water Quality and Status of
Variance to Narrative Color Criterion
EPA objections/recommendations:
• DWQ has not established that narrative color standard is being met.
• DWQ must revise terms of the color variance to reflect proposed permit conditions that EPA stipulated
in Specific Objection I, and resubmit variance extension to EPA for approval.
• EPA recommends that BRPP provide funding for an independent, unbiased site-specific color study to
determine how the NC narrative color standard should be applied to Pigeon River near Canton.
DWO Response:
EPA historically interpreted the NC color standard as 50 PCU. However,this interpretation is based on old data
that is not defensible. EPA relied on one study(NCASI 1975)which was designed to determine detectable levels
of color,rather than objectionable levels.
In contrast,DWQ supported its decision regarding color compliance with its narrative standard utilizing more
relevant and up-to-date reports that included color perception studies conducted by Dr Prestrude(which evaluated
color objectionability as opposed to color detection, and included site specific evaluations in TN/NC Pigeon
River). These studies indicate color is not objectionable below 100-110 PCU. Also,NCASI study(1995)
1

4
indicates color has no aquatic life impacts at levels below 100 PCU. Only one color complaint has been logged at
the ARO over the past few years, and recent data shows the rafting community on the TN side of the Pigeon River
is booming. Overall,the color record supports the DWQ conclusion that the six components of its narrative
standard are being met.
Ultimately,DWQ will rely on the independent NC Environmental Management Commission(EMC)to determine
whether the narrative color standard is being met. This EMC meeting is scheduled for May. The EPA objection
includes a requirement for extension of the color variance,but NC has no legal authority to force the variance on
the facility. Also, if the EMC determines the color standard is being met,then the variance is unnecessary.
Specific Obiection 3. Temperature Variance
EPA objections.
• Permit must require completion of an updated BIP study that includes thermal modeling
• Permit must require monitoring/reporting of Daily Max and Monthly Avg. effluent temperatures
• Permit should include, in interim period, a reduction in Delta T limit to 8.2'C
DWO Response:
The Draft permit already requires the permittee to complete a BIP study during this permit term, and also requires
daily effluent temperature monitoring. DWQ can add a requirement for Monthly Average temperature
calculation.
The last BIP report(May 2006)concluded that there is a demonstrated presence of a Balanced and Indigenous
Population in the Pigeon River.This study was supervised and written by experts in the field(Dr.Larry Wilson
and Dr. David Etuier of the University of Tennessee-Knoxville), and reviewed by Dr. Charles Coutant(who was
one of the original panel members assisting EPA with 316(a)Technical Guidance). However,EPA objects to the
study conclusion and believes the study is not sufficient to make the required BIP demonstration.EPA sent
blanket objections to all facilities with 316(a)variances in Region W.
EPA is requiring a reduction in the Delta Temperature limit(from 13.9 degrees C to 8.2 degrees C)until the BIP
study is concluded. EPA's proposed delta T is arbitrary.During the period 2001-2009 the proposed delta T would
have caused at least 6 violations. Blue Ridge Paper may propose an alternative for consideration.A new
temperature study would cost—$500,000.
Specific Objection 4: Absence of Daily Maximum Dioxin Limit and Fish Tissue Monitorin>?
EPA objections.
• Permit must contain an effluent Daily Maximum dioxin limit.
• Permit must require fish tissue dioxin monitoring in the 1";3id and 5"'years of the permit term.
DWO Response:
The Draft permit contains a Monthly Average dioxin limit;we will add a Daily Max limit to appease objection.
DWQ staff recommends a compromise on the dioxin fish tissue monitoring. Since switching to ECF technology,
dioxin levels have been non-detect in the effluent and further up in the bleach plant wastestreams. Most fish
samples have no detectible level of dioxin/furan. In the few remaining samples, concentration of dioxin/furan is
well below FDA and NC DHHS thresholds.All fish consumption advisories have been removed, and the
dioxin/furan concentration in fish has been steadily decreasing since 1990.In order to achieve a compromise,
DWQ can suggest a fish monitoring event during 2°a year of the permit. If the observed concentration of
dioxin/furan is still below FDA and NC DHHS recommended thresholds,further monitoring would not be
required.Blue Ridge proposes to do the dioxin sampling in concurrence with the 316 (a)temperature study.
2

Specific Obiection 5. Absence of Turbidity Monitoring
EPA objections:
• Permit must require turbidity monitoring at Fiberville Bridge,2/Month,April-Oct,for one year.
• Permit must contain specific turbidity reopener to add turbidity limit if reasonable potential exists.
DWO Response:
DWQ can add this requirement to the permit.
Specific Obiection 6.Absence of Effluent Hardness Monitoring To Evaluate Zinc Toxicity
EPA objections:
• Permit must include quarterly effluent hardness monitoring.
DU Response:
DWQ can add this requirement to the permit. However, it will be noted that this is the only facility in NC that
EPA has required this from. Our current zinc water quality standard has no provision for hardness,and our
Action Level Policy would indicate no zinc issues since the facility has consistently passed the WET test.
Hardness data may be useful to facility in the long run,following Triennial Review proposed changes.
EPA Recommendation Regarding AOX Limits
• Recommends retaining reduced AOX limits from last permit.
DWO Response:
DWQ can add this recommendation to the permit provided Blue Ridge will not object,since there is no basis for
it. Basically EPA is recommending to the State to implement a performance based limit for AOX, and disregard
their own procedures for developing Effluent Guideline Limits. The basis for EPA's recommendation appears to
arise from a few public comments raised at the public hearing. Nevertheless,the facility has an excellent AOX
performance record, and the limits from the 2001 permit can be retained in the proposed 2010 permit.
EPA Recommendation Regarding TRW
• Recommends including provision in permit to ensure that TRW will assess color reduction
technologies and provide recommendations to DWQ at end of next permit term.
DWQ Response:
The TRW was established by the 1997 settlement agreement to serve during the term of the next permit cycle.Its
goal has been achieved. During the current permit renewal,the TRW added significant delays to the process(2
years). DWQ staff recommends that annual color reports and the color implementation plan be distributed to
EPA and TN for their comments,with specified deadlines. However,DWQ does not see the need to continue the
TRW process.
3

Pr
evergreen .0 Canton Office
packaging PO Box 4000• Conlon, NC 28716
JUL 12 2019 CERTIFIED MAIL RETURN RECEIPT REQUESTED
7018 3090 0001 6626 2740
Water Quality Regional Operations
Asheville Regional Office
July 10,2019 �(
s ,
Director of Division of Water Resources k
Wastewater Branch
Division of Water Resources �_ 4
1617 Mail Service Center
Raleigh,NC 27699-1617
Re: Notice of Violation and Assessment of Civil Penalty for Violations of North
Carolina General Statute (G.S.) 143-215.1(a)(6)
and NPDES WW Permit No. NC 0000272
Blue Ridge Paper Products, Inc. dba Evergreen Packaging/Canton Mill
Case No. LV-1019-0111 Haywood County
Dear Ms. Linda Culpepper:
Evergreen Packaging is in receipt of your letter of June 10, 2019 assessing a civil penalty
and enforcement costs for a fecal coliform violation on July 24, 2019. On May 14, 2019,
Evergreen sent you a letter describing the circumstances that gave rise to the violation. As you are
aware,the Town of Canton discharges its wastewater to Evergreen's Wastewater Treatment Plant.
The Town is supposed to disinfect/chlorinate its wastewater prior to discharging to the Evergreen
system; however, the system the Town had in place in July 2018 did not have sufficient capacity
or retention time to disinfect the waste. Accordingly, the Town of Canton's wastewater was not
properly disinfected on that day prior to discharging to Evergreen's Wastewater Treatment Plant.
Evergreen does not contest that the violation occurred. The violation mainly resulted from
the Town of Canton's failure to disinfect its wastewater.
Evergreen requests remission of the civil penalty. In support of its request for remission,
Evergreen has completed and encloses with this letter, the "Request for Remission of Civil
Penalties / Waiver of Right to an Administrative Hearing and Stipulation of Facts" and the
"Justification for Remission Request. "

evergreen- Canton Office
packaging I PO Box 4000• Conlon, NC 28716
Evergreen appreciates your consideration of its request.
Sincerely,
oho "(
Wallace McDonald
General Manager Canton &Waynesville Operations
cc: Landon Davidson,NCDEQ- DWR
Town of Canton

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIONMENTAL QUALITY
COUNTY OF HAYWOOD
IN THE MATTER OF ASSESSMENT WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
Blue Ridge Paper Products Inc
Canton Mill
PERMIT NO. NC0000272 CASE NO. LV-2019-0121
Having been assessed civil penalties totaling$469.59 for violation(s)as set forth in the assessment
document of the Division of Water Resources dated June 10, 2019, the undersigned, desiring to
seek remission of the civil penalty, does hereby waive the right to an administrative hearing in the
above-stated matter and does stipulate that the facts are as alleged in the assessment document.
The undersigned further understands that all evidence presented in support of remission of this
civil penalty must be submitted to the Director of Division of Water Resources within thirty(30)
days of receipt of the notice of assessment. No new evidence in support of a remission request
will be allowed after thirty(30) days from the receipt of the notice of assessment.
This the 10 day of July 2019
Yv \
SIGNATURE
ADDRESS
Blue Ridge Paper Products Inc
175 Main Street
Canton,NC 28716
TELEPHONE
828-646-2000

PV
JUSTIFICATION FOR REMISSION REQUEST
Case Number: LV-2019-0121 County: Haywood
Assessed Party: Blue Ridge Paper Products Inc.
Permit No.: NC0000272 Amount Assessed: $469.59
Please use this form when requesting remission of this civil penalty. You must also complete the 'Request
for Remission of Tight to an Administrative Hearing, and Stipulation of Facts"form to request remission
of this civil penalty. You should attach any documents that you believe support your request and are
necessary for the Director to consider in evaluating your request for remission. Please be aware that a
request for remission is limited to consideration of this five factors listed below as they may relate to the
reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper
procedure for contesting whether the violation(s)occurred or the accuracy of any of the factual statements
contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c),remission of a
civil penalty may be granted only when one of more of the following five factors apply. Please check each
factor that you believe applies to your case and provide a detailed explanation, including copies of
supporting documents,as to why the factor applies(attach additional pages as needed).
_X_ (a) One or more of the civil penalty assessment factors in N.C.G.S. § 143B-282.1(b) were
wrongfully applied to the detriment of the petitioner(the assessment factors are listed in
the civil penalty assessment document).
(b) The violator promptly abated continuing environmental damage resulting from the
violation (i.e. explain the steps that you took to correct the violation and prevent future
occurrences).Fecal coliform has a short life and likely dissipated before Blue Ridge Paper
was aware of the exceedance. Blue Ridge Paper has worked and continues to work with
the Town of Canton to address the fecal coliform issue originating in the Town of Canton.
(c) The violation was inadvertent or a result of an accident(i.e. explain why the violation was
unavoidable or something you could not prevent or prepare for). The violation resulted
from the failure of the Town of Canton to disinfect its wastewater prior to discharging to
Blue Ridge Paper's Wastewater system.
(d) The violator has not been assessed civil penalties for any previous violations.Blue Ridge
Paper has been assessed civil penalties for other fecal coliform violations resulting from
the failure of the Town of Canton to disinfect its wastewater.
(e) Payment of the civil penalty will prevent payment for the remaining necessary remedial
actions(i.e. explain howpayment of the civil penalty will prevent you from performing the
activities necessary to achieve compliance). Remaining necessary remedial actions,
operating and maintaining a consistent system to disinfect wastewater,is the responsibility
of the Town of Canton.

EXPLANATION:
• The duration of the permit exceedance was short-lived (less than 1 day);
• No adverse impact to the receiving waters, i.e. Pigeon River due to this exceedance;
• There was no cost to rectify the damage;
• Blue Ridge Paper Products Inc did not save any money as a result of the non-compliance;
• The violation was not willful or intentional and resulted from factors over which Blue
Ridge Paper Products has little or no control;
• Blue Ridge Paper Products Inc has an otherwise excellent compliance record with the
Division of Water Resources.

Canton Office
evergree PO Box 4000• Canton, NC 28716
packaagingging
RI
JUL 12 2019
CERTIFIED MAIL RETURN RECEIPT REQUESTED
7018 3090 0001 6626 2733
Water Quality Regional Operations
Asheville Regional Office
July 10, 2019
Director of Division of Water Resources
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh,NC 27699-1617
Re: Notice of Violation and Assessment of Civil Penalty for Violations of North
Carolina General Statute (G.S.) 143-215.1(a)(6)
and NPDES WW Permit No. NC 0000272
Blue Ridge Paper Products, Inc. dba Evergreen Packaging/Canton Mill
Case No. LV-2019-0122 Haywood County
Dear Ms. Linda Culpepper:
Evergreen Packaging is in receipt of your letter of June 10, 2019 assessing a civil penalty
and enforcement costs for a fecal coliform violation on February 4, 2019. On May 14, 2019,
Evergreen sent you a letter describing the circumstances that gave rise to the violation. As you are
aware,the Town of Canton discharges its wastewater to Evergreen's Wastewater Treatment Plant.
The Town is supposed to disinfect/chlorinate its wastewater prior to discharging to the Evergreen
system; however, the system the Town had in place in Februray 2019 did not have sufficient
capacity or retention time to disinfect the waste. Accordingly, the Town of Canton's wastewater
was not properly disinfected on that day prior to discharging to Evergreen's Wastewater Treatment
Plant.
Evergreen does not contest that the violation occurred. The violation mainly resulted from
the Town of Canton's failure to disinfect its wastewater.
Evergreen requests remission of the civil penalty. In support of its request for remission,
Evergreen has completed and encloses with this letter, the "Request for Remission of Civil
Penalties / Waiver of Right to an Administrative Hearing and Stipulation of Facts" and the
"Justification for Remission Request. "

evergreen* Canton Office
packaging FO Box 4000• Conlon, NC 28716
Evergreen appreciates your consideration of its request.
Sincerely,
PA4 V t j I
Wallace McDonald
General Manager Canton&Waynesville Operations
cc: Landon Davidson,NCDEQ - DWR
Town of Canton

PPV " ,
WATER POLLUTION CONTROL SYSTEM OPERATOR DESIGNATION FORM (WPCSOCC)
NCAC 15A 8G .0201
Press TAB to enter information
Permittee Owner/Officer Name: Wallace McDonald
Mailing Address: 175 Main Street Phone: [phone]
city: Canton State: NC Zip: 28716
Email Address: [e-mail] q
Signature: 0JtDate:
Facility Name: Blue Ridge Paper Products WWTP Permit# NC0000272
County: Haywood
Y l
YOU MUST SUBMIT A SEPARATE FORM FOR EACH TYPE AND CLASSIFICATION F SYSTEM:
Facility Type: WW APR 3 2019� Q
Facility Grade: JIV 0
Water Ovo1!!,ns7°,^^!Ocgrations
OPERATOR IN RESPONSIBLE CHARGE(ORC)
Print Full Name: Tracy James Willis Work Phone: [phone]
Certificate Type: WW El Certificate Grade: IV Q Certificate#: 998768
Email Address: [e-mail]// /
Signature: �� /�2n! . Effective Date: H bq
"I certify that I agree to my designation as the Operator in Responsible Charge for the facility noted. I unders a d and will abide by the
rules and regulations pertaining to the responsibilities of the ORC as set forth in ISA NC4C 08G.0204 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
BACKUP ORC
Print Full Name: Philip Lynn Teague Work Phone:[phone]
Certificate Type: WW 0 Certificate Grade: IV Q Certificate#:994359
Email Address: [e-mail]
Signature: fk,le ''ram r.WA, Effective Date: g/1/j oI
certify that I agree to my designation as o Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by
the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 09G.0204 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control5ystem Operators Certification Commission."
Mail,fax or email WPCSOCC, 1618 Mail Service Center, Fax:[phone] Email:[e-mail]
ORIGINAL to: Raleigh, NC 27699-1618
Mail or Fax Asheville Fayetteville Mooresville Raleigh
a COPY to: 2090 US Hwy 70 225 Green St.,Suite 714 610 E.Center Ave.,Suite 301 3800 Barrett Dr.
Swannanoa,NC 28778 Fayetteville,NC 28301-5043 Mooresville,NC 28115 Raleigh,NC 27609
Fax:[phone] Fax:[phone] Fax:[phone] Fax:[phone]
Phone:[phone] Phone:[phone] Phone:[phone] Phone:[phone]
Washington Wilmington Winston-Salem
943 Washington Sq. Mall 127 Cardinal Dr. 45 W.Hanes Mall Rd.
Washington,NC 27889 Wilmington,NC 284OS-2845 Winston-Salem, NC 27105
Fax:[phone] Fax:[phone] Fax:[phone]
Phone:[phone] Phone:[phone] Phone:[phone] Reviwd4/2016

�. 033
VwPCSOCCperator Designation Form(continued) Page 2
APR 3 2019
Facility Name: Blue Ridge Paper Products Inc. WWTP Permit#: NC 00j9g7,;, ,, Ions
BACKUP ORC
Print Full Name: John J. Pryately Work Phone:[phone]
Certificate Type: WW 0 Certificate Grade: IV 0 Certificate#:14109
Email Address: [e-mail]
Signature: — r Effective Date:
"I certify that I agree my designation as a B ck-up Operator in Responsible Charge for the facility noted. I understand and will abide by
the rules and regulations pertaining to the responsibilities of the ORC as set forth in ISA NCAC a8G.0204 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
BACKUP ORC
Print Full Name: Work Phone:
Certificate Type: Select Certificate Grade: Select Certificate#:
Email Address:
Signature: Effective Date:
"I certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by
the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G.0104 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
BACKUP ORC
Print Full Name: Work Phone:
Certificate Type: Select Certificate Grade: Select Certificate#:
Email Address:
Signature: Effective Date:
01 certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by
the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G.0204 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
BACKUP ORC Ll
Print Full Name: Work Phone:
Certificate Type: Select Certificate Grade: Select Certificate#:
Email Address:
Signature: Effective Date:
"I certify that/agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by
the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G.0204 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
ReWsed 4,2016

Untitled
-Inspection date : 3/11/15
-Report date: 4/2/15
-Extension to reply until 5/29/15 granted 5/20/15
-Lab Reply : 5/29/15
-WW/GW Response : 6/5/15, response due 6/23/15
-Lab Reply : 6/25/15, late and did not adequately address findings
and was essentially the same as previous reply
-Initial Decertification letter sent : 6/26/15 stating that
decertification would be effective 7/20/15
-On 7/7/15, Mr . Deaver requested a meeting to discuss - and meeting
was scheduled 7/15/15
-At 7/15/15 meeting, Mr. Deaver expressed his point of view and
said that he would like a meeting with lay Zimmerman
-On 7/17/15, lay Zimmerman said to delay decertification until he
meets with Mr. Deaver .
-Meeting with Mr . Deaver and Mr. Zimmerman on 7/29/15 .
-8/24/15 Mr . Deaver submitted comparison between meters .
-9/8/16 Dana Satterwhite sent email to Mr . Deaver after receiving
feedback from Hach .
-9/8/16 we received copy of settlement dated 8/12/16, but unsure
if it was signed and mailed
-9/10118 Dana emailed Shari Knight the 9/8/16 email indicating
this was the last we had heard
-Per Charles Weaver 9/13/18 email, settlement was mailed 9/9/16
and received 9/16/16.
-Settlement required using an appropriate meter by March 1, 2017,
notifying WSRO of meter use by March 16, 2017 and pay civil
penalty of $3000 (reduced from $10,000)
-No response to the settlement/letter was received .
Page 1

revergreeft,�I Canton Office
packaging 175 Main Street• Canton, NC 28716
May 18, 2018
Landon Davidson
Asheville Regional Supervisor
Division of Water Resources
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton, Haywood County,North Carolina
Daily Max Fecal Coliform Exceedance, 04/24/2018.
NPDES Permit: NC0000272
On April 24, 2018, Evergreen Packaging collected a permitted weekly fecal coliform sample
from our secondary effluent flume. Additionally, samples were taken from the Town of
Canton's Influent as well as the Up-stream location as an indicator of river conditions leading
into the Mill. The samples were processed and sent to ETS for analysis. On April 25th, 2018
Evergreen Packaging received a preliminary analysis via email from ETS which indicated>600
col/l00ml at the permitted secondary effluent sampling location. The results also indicated that
the upstream river conditions also contained the same fecal coliform concentrations at>600
col/100m1 while the Town of Canton's Influent results showed 20 col/100ml.
An investigation in the cause of the exceedance was initiated and two issues were identified.
One that was believed to be the most plausible was high river levels. The Mill experienced
nearly three inches of rain fall and river levels were elevated more than average and as such, the
mill's intake pumps increase their back flushing rate. All back flushing waters goes directly into
the 4A sewer. The 4A sewer goes directly into the low lift. Essentially the river water used for
back flushing goes untreated directly into the low lift. As stated previously, the river conditions
demonstrated fecal coliform levels of>600 col/100 nil which was identical to what Evergreen's
secondary compliance sample was>600 col/100 nil. Evergreen collected a sample on April 26,
2018 at the 4A manhole once the river levels had subsided to evaluate the fecal coliform readings
and sent them to Statesville Analytical. The results for fecal coliform was <1 CFU/100ml.
Moving forward, Evergreen Packaging will ensure that a representative sample of its operation
will be collected within the allowable timeframe to collect the sample.
As part of the actionable items working with the Town of Canton in the identification of possible
Fecal/coliform sources internal to the Mill, an evaluation of Mill sewer lines as well as sump
areas have been initiated. Upon initial notification by ETS of our Fecal/Coliform exceedance,
the WTP management team further continued the efforts to examine any influent lines coming
fresh by design.
Doing Busnens in Califamla cs Evemreen Beveraea Packaging
IleverpacklcalEOHSISHAREI Water ResWlcles Water ReslDEQ

NCDWR Page 2
into the WTP that may or may not carry a fecal/coliform source. A sewer line was identified in
our records many years ago (2012) as having a breach that required a repair/replacement in the
line. The WTP management inspected the general area where the line resides and found no
evidence of line disruption. Due to the excess rain, while performing the analysis, the WTP
management identified the storm water runoff basin had water in it that comes from around the
pine chip pile. This basin flows directly into the#3 clarifier and so the WTP Management team
collected a sample on April 26, 2018 to test for fecal/coliform. The results showed>6000
CFU/100ml. Upon review of historical records, it was found that during elevated rain events,
Champion/Blue Ridge Paper would add chlorine tablets in a bucket with holes in it to allow for a
slow dissolve just at the discharge of the basin and before it could be sent to the#3 clarifier. The
WTP management applied this method of treatment to the basin and resampled on April 27,
2018. The results showed<1 CFU/I00ml.
It should be further noted that on April 24, 2018, Evergreen Packaging at the compliance
location performed a E.coli analysis as well and the results indicated as follows: S.A. E. coli
(10) 100ml mpn. Evergreen Packaging is working with BCN to establish a process to delineate
the E.coli species but this process is taking a longer to get worked out than anticipated.
Evergreen is working with local certified laboratories to determine if they can perform this
testing and meet the hold time for future needs and will keep the Regional office informed of the
progress. Any additional observations found during the identification/evaluation of sources as
outlined in the FISS Environmental RFQ between the Town of Canton and Evergreen Packaging
through the partnership of D WR Regional Office will be submitted in writing as part of the
continuing effort to seek resolution of the fecal/coliform issues.
Evergreen Packaging received the official results of the Fecal/Coliform tests on May 4, 2018 and
on May 8, 2018, the Regional Office of D WQ was informed of the information contained in this
letter. Should additional information be request, please contact me.
Sincerely,
Jacob Trantham
WWTP Supervisor
Evergreen Packaging—Canton Mill
828-646-2365
Jacob.tranthain everyack.com

VNCDWR Page 3
cc:
Mr. Tim Heim
Environmental Engineer, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778

F
g.reen, �/ Canton Office
175.Main Street• Canton, NC 28716
packaging
May 18, 2018
Landon Davidson
Asheville Regional Supervisor
Division of Water Resources
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton, Haywood County,North Carolina
Daily Max Fecal Coliform Exceedance, 04/24/2018.
NPDES Permit: NC0000272
On April 24, 2018, Evergreen Packaging collected a permitted weekly fecal coliform sample
from our secondary effluent flume. Additionally, samples were taken from the Town of
Canton's Influent as well as the Up-stream location as an indicator of river conditions leading
into the Mill. The samples were processed and sent to ETS for analysis. On April 25th, 2018
Evergreen Packaging received a preliminary analysis via email from ETS which indicated>600
col/100ml at the permitted secondary effluent sampling location. The results also indicated that
the upstream river conditions also contained the same fecal coliform concentrations at>600
col/100ml while the Town of Canton's Influent results showed 20 col/100ml.
An investigation in the cause of the exceedance was initiated and two issues were identified.
One that was believed to be the most plausible was high river levels. The Mill experienced
nearly three inches of rain fall and river levels were elevated more than average and as such, the
mill's intake pumps increase their back flushing rate. All back flushing waters goes directly into
the 4A sewer. The 4A sewer goes directly into the low lift. Essentially the river water used for
back flushing goes untreated directly into the low lift. As stated previously, the river conditions
demonstrated fecal coliform levels of>600 col/100 ml which was identical to what Evergreen's
secondary compliance sample was>600 col/100 ml. Evergreen collected a sample on April 26,
2018 at the 4A manhole once the river levels had subsided to evaluate the fecal coliform readings
and sent them to Statesville Analytical. The results for fecal coliform was <1 CFU/100ml.
Moving forward, Evergreen Packaging will ensure that a representative sample of its operation
will be collected within the allowable timeframe to collect the sample.
As part of the actionable items working with the Town of Canton in the identification of possible
Fecal/coliform sources internal to the Mill, an evaluation of Mill sewer lines as well as sump
areas have been initiated. Upon initial notification by ETS of our Fecal/Coliform exceedance,
the WTP management team further continued the efforts to examine any influent lines coming
fresh by design,
Doing Busines in Caffunio as Bvergr ._n Beveroae Packaging
11everpack1calEOHSISHAREI Water FilesWick's Water ResIDEQ

NCDWR Page 2
a
G
into the WTP that may or may not carry a fecal/coliform source. A sewer line was identified in
our records many years ago (2012) as having a breach that required a repair/replacement in the
line. The WTP management inspected the general area where the line resides and found no
evidence of line disruption. Due to the excess rain, while performing the analysis, the WTP
management identified the storm water runoff basin had water in it that comes from around the
pine chip pile. This basin flows directly into the#3 clarifier and so the WTP Management team
collected a sample on April 26, 2018 to test for fecal/coliform. The results showed>6000
CFU/100ml. Upon review of historical records, it was found that during elevated rain events,
Champion/Blue Ridge Paper would add chlorine tablets in a bucket with holes in it to allow for a
slow dissolve just at the discharge of the basin and before it could be sent to the#3 clarifier. The
WTP management applied this method of treatment to the basin and resampled on April 27,
2018. The results showed<1 CFU/100ml.
It should be further noted that on April 24, 2018, Evergreen Packaging at the compliance
location performed a E.coli analysis as well and the results indicated as follows: S.A. E. coli
(10) 100ml mpn. Evergreen Packaging is working with BCN to establish a process to delineate
the E.coli species but this process is taking a longer to get worked out than anticipated.
Evergreen is working with local certified laboratories to determine if they can perform this
testing and meet the hold time for future needs and will keep the Regional office informed of the
progress. Any additional observations found during the identification/evaluation of sources as
outlined in the FISS Environmental RFQ between the Town of Canton and Evergreen Packaging
through the partnership of DWR Regional Office will be submitted in writing as part of the
continuing effort to seek resolution of the fecal/coliform issues.
Evergreen Packaging received the official results of the Fecal/Coliform tests on May 4, 2018 and
on May 8, 2018, the Regional Office of DWQ was informed of the information contained in this
letter. Should additional information be request,please contact me.
Sincerely,
Jacob Trantham
WWTP Supervisor
Evergreen Packaging—Canton Mill
828-646-2365
[e-mail]
cc:Mr. Tim Heim
Environmental Engineer, Asheville Regional Office,North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70,Swannanoa,NC 28778

net
Heim,Tim
Thursday, May 17, 2018 2:54 PM
Cantwell,Janet
Cc: Davidson, Landon;Willmer, Mikal
Subject: FW: [External] Fecal Exceedance Detailed
Attachments: Daily Max Fecal Exceedance Submittal 5-18-2018.doc
Janet,
This one has some significant mitigating circumstances.When it comes through eDMR/BIMS make sure Landon and I
know and can discuss before issuing an NOV. (If you are the one that ends up doing it)
Thanks
-Tim
From:Trantham,Jacob [mailto:[e-mail]]
Sent: Thursday, May 17,2018 2:34 PM
To: Davidson, Landon<[e-mail]>
Cc:Heim,Tim<[e-mail]>;Satterfield, Brian<[e-mail]>
Subject: [External] Fecal Exceedance Detailed
,iCAUTION:External email. Do not click links or open attachments unless verified.Send all suspicious email as an attachment to
Good afternoon Landon,attached is a letter detailing Evergreen's investigation and response to our high fecal result on
4/24/18.
Please contact me if you have any questions.
Jacob Trantham
WWTP Lab Supervisor
Evergreen Packaging
175 Main Street Canton, NC 28716
[e-mail]
Office: 828-646-2365 1 Cell: 828-558-1928 1 Fax: [phone]
DISCLAIMER:This electronic message together with any attachments is confidential. If you are not the intended
recipient, do not copy,disclose or use the contents in any way. Please also advise us by return e-mail that you have
received the message and then please destroy.The sender is not responsible for any changes made to this message and
/or any attachments after the message and attachments are initial sent.We use virus scanning software but exclude all
liability for viruses or anything similar in this email or any attachment.
RLSAutogeneratedDiscla imer
1

evergreen.,/ v`f
packaging
March 26, 2018
Certified Mail
Return receipt Requested 7008 3230 0002 2595 7838 and 7008 3230 0002 2595 7845
North Carolina Department of Environmental CC: Asheville Regional office
And Natural Resources 090 US Highway 70
Division of Environmental Quality DmiloED
natr '�w"p4sq wrar 3wannanoa NC 28778
Water Quality Section
ATTENTION: Central Files APR _ 2 tAttn: Landon Davison PG
1617 Mail Service Center Regional Supervisor
Raleigh, NC 27699-1617 Z & i
WOW Many RapbNl Opuloti
AsheAft t)row
RE: NPDES NO. NC0000272
Best Management Practices 2017 Annual Report
Blue Ridge Paper Products Inc. D/b/a Evergreen Packaging
Canton, NC
This Letter report (two copies) is the 2017 summary of Best Management Practices (BMP)
Daily monitoring for the Canton Mill. The report is required on or before March 31 of
Each year by Special Conditions A. (6.) Best Management Practices EA and Section F. 1 of
the mills NPDES Permit No. NC0000272
The BMP action levers established in accordance with Permits and in effect for 2017 are
As follows
Effective Dates: 1 Jan 2017- 31 Dec 2017
Action Level Total Influent(TI) Color Action Required
Daily monitoring results
1-day upper action >72,500lbs./day for one day Immediate Investigation and
Document corrective action
2 day upper action >59,400lbs./day for two Investigate and document
Level(UAL) consecutive day's corrective action
2 day lower Action >55,400lbs./day for two Investigate and document
Level(LAL) consecutive days
Daily Records of total influent are maintained in the Mill. These daily color data are
Compared to BMP action levers every morning. Total influent color exceeded BMP
Action levels on the date outline in the following table.

rA
Brief summary of information for these dates are included as required by permit
conditions A. (6), section EA. The permit-required BMP investigation reports are
maintained at the mill. No of the BMP action level days resulted in disruption to the
Waste water treatment plant. The Canto mill met all the NPDES average effluent limits
For the period July 12016 to June 30,2017.
Date(s) Total influent color Action Level Summary
June 22, 2017 SE 82, 9961bs. per day Mill outage- Boiler/Fiber line
June 23 2017 SE 53, 162 Ibs.per day Recovery Boiler# 10 overflowed
June 24, 2017 SE 39,812 lbs. per day Weak wash from the north mud
Washer. CRP had a small leak
Plugged the Swenson evaporator set.
During start up Pine Brown Spill
Tank/Hardwood fiber line became
Unbalanced and caused color to be
Carried to bleach plant filtrate.
Corresponding Sewer with elevated Color#3A&#513
Operation personal notified, Chad Dawdle, Brian Farley, Rob Luther
The second BMP event of 2017 was Dec 11, 2017
Date Total influent Color Action Level Summary
12/11/2017 109,528 330 am High color first discovered
Color samples taken every 30
Minutes. Crew leaders were
Informed at Paper mill and
Recovery. 520am Recovery—
Formal call reported a leak in-
Swenson Liquor into the U-drain.
Leak stopped at 6 am
Color#returned to 275 at 9am
At 11am 171 color test
12/12/2017 51,112 Return to normal
Please find the BMP reports from these two incidents
James Pikul-828-384-5199 cell
Env./Waste Water Manager
Treatment Manager
Canton Mill

Investigative and Corrective Action Documentation
BMP Action Level Exceedance—Form E-2
Canton Mill
==*usem,facsimile or electronic report to document BMP action level exceedances
Date of Report: 7/10/17
Daily Color: 6/22/17 SE 81,9961bs/day
6/23/17 SE 53,1621bs/day
6/24/17 SE 39,812 lbs/day
Date of Color: 6/21/17- 6/23/17
Investigative Action Required: X Corrective Action Required: X
Person Conducting Investi ag tion: Nick McCracken
Primary Influent Action Levels:
Upper Action Level=59,400 lbs/day
Lower Action Level=55,400 lbs/day
Out of Control Level=72,500 lbs/day(must initiate Corrective Action after 1 day at this
level)
Dates Lower/Upper Action Levels Exceeded (LAL and UAL) and corresponding color:
Note: Investigative and/or Corrective Action must occur after 2 consecutive days at the
respective level.
6/21/17 PI63,2101bs/day
6/22/17 PI 85,900 lbs/day
6/23/17 PI 67,262 lbs/day
Corresponding Sewer Areas with Elevated Color: #3A&#5B
Operations Personnel Notified: Chad Dowdle, Brian Farley, Rob Luter,Nick McCracken
Day/Time: 6/21 -23/17; continuous loss during period
Revision 3, 10/1/08
Blue Ridge Paper Products Inc. dba Evergreen Packaging

Cause(s) for exceedance: Multiple sources from outage related activities
BMP related incident X * Primary Cause: Outage related activities and
unbalanced operation
Non-BMP incident ❑
Test Method Interference ❑ New Method= Turbidity=
Secondary Effluent(with one day lag time)_
Outage X
Other ❑
Is problem ongoing?No.
Have efforts been made to mitigate the occurrence? Yes.
Is corrective action recommended? Yes.
Corrective Action Implemented: Bring mill back up to steady state; steady loads on
recovery boilers, reestablish green liquor balance and filtrate balance in fiberlines.
*Describe incident in detail including regulated substance(black liquor, turpentine or
soap)that went to the Wastewater Treatment plant
On Wednesday, 6/21, the#10 Recovery Boiler had a planned outage to wash the cyclones
and address green liquor lines that had become plugged. Weak green liquor overflowed
from the#10 RB dissolving tank and Weak Wash overflowed from the North Mud
Washer to the mill sewer system contributing elevated pH material to wastewater
treatment plant. Sewer generated color was observed in the Primary Effluent color
numbers as a result. Other contributors were a small leak that was observed in the CRP
evaporator feed pump when the seal water became plugged and the condition of the
chevrons in the Swenson evaporator set. The set was not washed during this outage and
will need to be at the next opportunity. Condensates with elevated color can be a result
of increased black liquor scale that accumulates on the chevrons.
During this outage, the Pine fiberline also took a scheduled outage. Due to the amount of
material sent from the Pine Brown Spill tank,the Hardwood fiberline became unbalanced
and caused color to be carried over into the bleach plant filtrate. When the Pine fiberline
started back, there were imbalances that resulted in excess filtrate being discharged to the
sewer.
Describe any other necess=information:
Revision 3, 10/1/08
Blue Ridge Paper Products Inc. dba Evergreen Packaging

Return this form to the Environmental Manager for Record Keeping Requirements
Revision 3, 10/1/08
Blue Ridge Paper Products Inc. dba Evergreen Packaging

Investigative and Corrective Action Documentation
BMP Action Level Exceedance—Form E-2
Frl� Canton Mill
Date of Report: 12/13/17
Investigative Action Required: Yes Primary influent color reached 109,528 Ibs/day on
12/11/17
Corrective Action Required: Yes
Person Conducting Investigation: Jacob Trantham
Primary Influent Action Levels:
Upper Action Level=59,400 Ibs/day
Lower Action Level=55,400 Ibs/day
Out of Control Level = 72,500 lbs/day(must initiate Corrective Action after 1 day at this
level)
Dates Lower/Upper Action Levels Exceeded (LAL and UAL) and correspondingc olor:
Note: Investigative and/or Corrective Action must occur after 2 consecutive days at the
respective level.
Corresponding Sewer Areas with Elevated Color: 4
Operations Personnel Notified: Rec Foreman W.Harkins Day/Time: 12/11/17 3:30am
Pulp Mill Foreman Jared Saintsing — 12/11/17 6:OOam
Cause(s)for exceedance:
BMP related incident X * Primary Cause: Black Liquor leak in transfer line of
Swenson 211 effect.
Non-BMP incident ❑
Test Method Interference ❑ New Method= Turbidity=
Secondary Effluent(with one day lag time)_
Outage ❑
Other ❑
Is problem ongoing?No
Have efforts been made to mitigate the occurrence? Influent flow was diverted into#1
clarifier at 5:15 am so the system didn't take the hit all at once.
Revision 3, 10/1/08
Blue Ridge Paper Products Inc. dba Evergreen Packaging

Is corrective action recommended?Yes
Corrective Action Implemented: Swenson evaporator was taken down and the leak was
repaired.
*Describe incident in detail including regulated substance (black liouor, turpentine or
soap)that went to the Wastewater Treatment plant
At 3:30am 12-11-17
- High Color was first discovered after a color sample collected by the room runner
at 3:30am came back at 596
- The Crew leader contacted both the Pulp Mill and Recovery Foreman to notify
them of the high color number.
- Nothing was found by either foreman.
- Color samples were then taken about every 30 minutes ranging from in value
from 349-857, from 3:50am-7:OOam
- At 5:20am the Recovery Foreman called back to report a leak from the Swenson
evaporator had breached the bark dam constructed to funnel the leaking black
liquor into a U-drain and back to the Recover wash water tank.
- The bark dam was reconstructed and the leak to #4 sewer was stopped at 6:OOam.
- The decision was made by recovery supervision to take the evaporator down at
8:30.
Once offline maintenance repaired the leaking transfer line on the 2"d effect of the
Swenson evaporator.
- Color numbers returned to normal with the 9:OOam sample reading 275 and the
11:OOam sample reading 173
- Effects from the high PI color level of 109,528 for 12/11/17 were seen the
following day 12-12-17 in the form of a SE color number of 51,112 which is
slightly over the action limit.
Describe any other necessary information:
i
Revision 3, 10/1/08
Blue Ridge Paper Products Inc. dba Evergreen Packaging

Return this form to the Environmental Manager for Record Keeping Requirements
I
Revision 3, 10/1/08
Blue Ridge Paper Products Inc. dba Evergreen Packaging

revergreen..0 Canton Office
packaging 175 Main Street• Canton, NC 28716
January 4, 2017
JAN - 8 2018
CERTIFIED MAIL
Return Receipt Requested
W +� O r' n bral n,arations
r _
Landon Davidson �-
Asheville Regional Supervisor
Division of Water Resources
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton, Haywood County,North Carolina
Daily Maximum Fecal Coliform 12/22/2017& 12/29/2017
NPDES Permit: NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
December 22°d at approximately 8:30 am and was picked up and delivered by laboratory courier.
Proper sampling procedures were followed by plant personnel. The result of the analysis showed
a value of 24200 MPN per 100 ml. The fecal coliform excursion on December 22'was limited
to that sample parameter and day. A phone call was placed to the NCDEQ regional office on
December 28'to discuss the results once discovery had been made.
After the value from the laboratory was observed, all systems in the treatment facility were
inspected. They were found to be operating correctly leading up to and during the time of
sample.
Leading up to December 22nd Fecal Coliforrn (FC) exceedance, EPI had been further
investigating on-going but varied data reported back from our certified laboratory Pace
Analytical Services dating back to the week of November 19d. The reason for the investigation
was due to a reported FC exceedance of the daily maximum for December 1'. EPI submitted to
DWR a letter on December l Ph that outlined its investigation into the alleged exceedance. On
December 8' after conducting an investigation into the December 1"exceedance, EPI received
the FC compliance lab results from Pace. The results indicated the following: Town of Canton,
4.1 MPN/ 100 ml; Upstream, 95 CFU/100ml and the Secondary Effluent, 1300 MPN/100m1.
EPI questioned this data given the historical data collected from each source coupled with the
fresh by design,. /
P - r',- .w Evergreen Beverage Packaging
IleverpacklcalEOHSISHAREI Water FilesWick's Water FileslDEQ

VNCDWR Page 2
fact that no changes operationally have occurred. When EPI presented this information to Pace,
Pace reviewed their internal-procedures and EPI was informed that Pace believes that the
samples had switched during the evaluation of the data. Pace then sent EPI a revised Laboratory
Analysis report which then reflected the values of the Town of Canton(TOC) and the Secondary
Effluent to now be switched(4.1 MPN/100ml for the Secondary Effluent and 1300 MPN/100ml
for the TOC.
Given the now questionable reliability of Pace, EPI felt the need to explore other
laboratories that could test for FC. In speaking with Jason Smith from DWR, EPI was presented
a list of laboratories in the region who could perform the Colilert 18 method. After analysis of
our options,EPI identified only one other lab alternative, Statesville Analytical. As part of the
FC study with the TOC and working with FISS environmental,.the proposal-within the scope of
work was if any exceedance were to occur, then have the sample analyzed via Membrane
filtration or sent to another lab and have an e.coli speciation performed. To date, EPI has not
sent any samples off for e.coli speciation testing but is considering this a probable next step.
Back in 2016 when a series of weekly exceedances occurred, EPI did send off at that time
samples to-the Eden,NC lab for e.coli determination_. It was determined at that time to not be of
any human or animal origins but rather plant based. This echoed the information EPI obtained
from NCASI when informed of the on-going issues.
EPI wanted to detemune the ability or differences in running the Colilert 18 versus the
membrane filter test for FC. The reason for this analysis was to determine if this was a
contributing cause to the varying data that has been received for the multiple sampling
conditions. The week of December 18'h, EPI began to split the samples to be analyzed into four;
two samples going to Pace and two samples going to Statesville Analytical (SA)with each lab
being requested to test for FC using both the Colilert 18 and the Membrane Filter methods. The
FC results for the week showed that,Pace labs had major differences in FC counts given.the two
methods while the SA lab had very similar results between the two methods. Furthermore, the
FC counts from Pace were on average 3-10 times higher than those from SA. Not knowing the
aforementioned information, EPI performed the normal compliance test on December 22nd and
only had the Colilert 18 method performed.
On December 27'h, EPI received the laboratory analysis report from PACE which
indicated that the compliance test performed on December 22nd, was 24,200 MPN/100m1. EPI
contacted Pace to question the results to determine if the results obtained were switched at the
laboratory. At that time, the Pace representative, speaking on behalf of their Microbiologist,
indicated that given the recent samples EPI has submitted to run both Colilert 18 and Membrane
Filtration, Pace has identified other non-fecal bacteria in large concentrations that in their words
was most likely causing interferences in obtaining accurate counts via both test methods. On
December 28h, EPI contacted the DWR and informed them of the results and EPI's steps to
investigate the issue. EPI requested from DWR that a formal conference call be had between the
two to discuss the facts and investigational findings. The meeting was scheduled for January Yd.
EPI contacted SA and had discussions around the general observations of the EPI samples and if

VNCDWR Page 3
there was any difficulties in running the samples and to obtain accurate data from those samples.
SA responded that they observed non-fecal bacteria present but the samples provided were not
such that accurate results could not be obtained.
Given the information obtained from the discussions from both labs, the decision was
then to have SA perform the analysis. However, the week of December 25te, SA did not have a
currier to pick up samples and as such, EPI sent the weekly routine samples again to Pace with
the December 29a'compliance sample.split to run both the Colilert-18 and the Membrane Filter.
test. The results for the December 29a'test was received-on January 2rd and indicated a wide
difference between both test procedures (2910 MPN/100m1 for the Colilert-18 versus 610
MPN/100m1) for membrane filtration. EPI investigated its operations and found no change in its
operations. EPI then formulated the sampling scheduled-to have-SA ran both FC testson the
TOC and#4 flume on January 3rd and the same on January 4°i but also include the secondary
effluent. For the week of January 8`s, the following sampling schedule has been developed:
January 9`h: Pace—TOC and#4 Flume with both FC test procedures.
SA—TOC, Upstream, #4 Flume and Secondary Effluent with both FC test
procedures. An additional split sample of the Secondary Effluent will be collected
to have a heterotrophic classification test.performed.
January 1 Od': SA-TOC and#4 Flume with both FC test procedures. An additional split sample
of the#4 Flume will be collected to have a heterotrophic classification test
performed.
January 110': Pace—TOC and#4 Flume with both FC test procedures.
SA—TOC,Upstream,#4 Flume and Secondary Effluent with both FC test
procedures. An additional split sample of the Secondary Effluent will be collected
to have a heterotrophic classification test performed.
The reason for the additional testing, switching the testing to another certified laboratory
and to obtain heterotrophic classifications of the material present in the discharge samples is
because EPI believes the current laborato_rydata acquired from.Pace is not accurate nor is it _
representative of the effectiveness of the'treatment abilities conducted at EPI.
EPI had a formal conference call with the DWR on January 3rd to discuss the
investigative approach and DWR has requested to split samples on January 9'and-1 ld'and have
the results tested in their laboratory. DWR also requested to witness the entire preparation,
capture, collection and preparation of the samples. EPI requests to the DRW that enforcement
discretion be given pending the outcome of the sampling results submitted to the certified lab SA
and also the results obtained through DWR's split sampling and internal testing.

VNCDWR Page 4
If you have any questions or comments,please feel free to contact us at your earliest
convenience.
Sincerely,
Brian Satterfield
EHS Manager
Evergreen Packaging—Canton Mill
828-646-2381
brian.satterfieldAevernack.com
cc:
Mr. Tim Heim
Environmental Engineer, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778

EF ' SNTAL S I� C �—(J�
MEMO DRAFT
TO: JASON BURRELL
BRIAN SATTERFIELD
FROM: NED FISS
BOB STEIN
MATT FISS
FISS ENVIRONMENTAL SOLUTIONS,INC
DATE: MARCH 22,2018
SUBJECT: STATUS REPORT&ACTION PLAN
FECAL COLIFORM INVESTIGATION&CONTROL
TOWN OF CANTON/EVERGREEN PACKAGING
FISS JOB NO.N558-01
Sanitary wastewater from the Town of Canton sanitary sewer system is discharged to the
Evergreen Packaging Canton mill wastewater treatment plant(W WTP)for biological
treatment in combination with the mill process and sanitary wastewaters. The Town of
Canton provides chlorination of the Town wastewater prior to discharge to the Evergreen
WWTP for disinfection of the sanitary wastewater to kill Fecal Coliform(FC)bacteria in
the wastewater before treatment through the W WTP. Fiss Environmental Solutions,Inc
(FISS)is assisting the Town of Canton and Evergreen Packaging, Inc(EPI)in a review of
available data and development of a plan for investigation and compliance with the
NPDES Fecal coliform criteria.Our findings to date are presented below:
• A review of the literature by FISS indicates that Pulp and Paper mill wastewater discharges
can contain bacteria from non-fecal sources that are measured as positive counts in Fecal
Coliform test procedures.
• The Town feeds a gaseous chlorine solution into the Town sanitary sewer line
for disinfection of the wastewater and reduction of Fecal Coliform counts before
discharging to the mill W WTP. The Town modified the sewer piping ahead of
the discharge to the mill W WTP in August 2017 in order to increase the chlorine
contact time in the upstream sewer section and effectiveness of the chlorine
disinfection process.
• Based on review of residual total chlorine measurements at the Town's sewer
discharge, it appears that organic and inorganic constituents in the wastewater
are reacting with the added free chlorine to forth oxidized compounds and that
the reactions exert a chlorine demand which reduces the measurable
concentrations of free chlorine and chloramines in the wastewater and,therefore,
the effectiveness of the chlorine disinfection process. Based on the available
data,the chlorine demand of these constituents and the residual total chlorine
concentrations in the Town's sewer discharge are highly variable on a day to day
basis. The Town's discharge includes wastewater from several industrial sewer
discharges along with leachate from an EPI solid waste landfill that is pumped to
the Town sanitary sewer system on an as-needed basis depending on rainfall and
7251 Pineville-Matthews Rd Fiss Environmental Solutions, Inc. Main: 704-374-5400
Suite 300, Charlotte, NC 28226 Fax: [phone]

groundwater conditions.
• During 2017,FC tests on the Town's sewer discharge to the W WTP and the Evergreen
treated effluent discharge were being performed by Pace Analytical Services,LLC in
Asheville,NC using the-Colilert 18 test method.These analyses showed highly variable and
sometimes elevated counts of FC bacteria in the chlorinated Town wastewater. Split sample
analyses using the Membrane Filtration procedure by Statesville Analytical,Inc were initiated
on December 19,2017 and indicated that the Colilert 18 analytical results being provided by
Pace were erroneous and falsely indicating elevated FC results.
• Results of FC analyses performed since December 19,2017 using the Membrane Filtration
procedure have indicated that both the Town sewer discharge and the EPI treated effluent
discharge have consistently contained FC levels of less than 200 colonies/100 ml. The NC
Department of Environmental Quality(NCDEQ)performed some limited FC sampling and
analyses during the week of January 8,2018,which confirmed these results.
• A review by FISS of the available FC data on the Town's wastewater discharge to
the mill W WTP since the Colilert 18 analyses were halted has indicated that the
Town of Canton's gaseous chlorine feed and modified chlorine disinfection
system are significantly reducing the FC bacteria levels in the sanitary wastewater
discharged to the EPI W WTP from the Town's sanitary sewer system.
• The Town of Canton has initiated an industrial survey program to update their
information and data on industrial discharges to the Town's sanitary sewer
system.
Based on FISS' review of the available data and alternatives to eliminate Fecal Coliform
exceedances in the Evergreen W WTP effluent discharge,we recommend the following
Plan of Action:
• Continue monitoring the disinfection performance of the upgraded chlorine
disinfection system for the wastewater carried by the Town's sanitary sewer
system.This will include collection of weekly samples of the Town disinfected
wastewater for measurement of Total Chlorine residual by the Town and FC testing
by Statesville Analytical using the Membrane Filtration method.
The Town of Canton should prepare Quarterly FC disinfection evaluation reports
for submittal to the NCDEQ during 2018 that will present the 90-day FC
disinfection results for each quarter.A Fecal Coliform count of 200 colonies/100
ml or less(which is equivalent to the Monthly Average discharge limitation in the
Evergreen NPDES permit)will be used as the standard for determination of good
Fecal Coliform reduction for the purposes of this performance monitoring.
• If the current chlorination disinfection modifications are unable to control FC counts in
the Town's sewer discharge to consistently meet the FC criteria during 2018,the Town of
Canton,as a continued short-term approach,will investigate the substitution of Sodium
Hypochlorite,Peracetic Acid(PAA), or Chlorine Dioxide for the current gaseous chlorine
disinfectant in the sewer chlorine contact segment during 2019.
• If the 2018 FC disinfection monitoring does not indicate that the upgraded Town
chlorination system is normally preventing elevated FC counts in the Town's wastewater
discharge,then a further study of potential(long-term)upgrades of the Town's wastewater
disinfection system will be implemented in 2019.The long-term upgrade,if needed,may
require a capital project including a wastewater pump station and above-ground disinfection
contact tank. The alternative approaches for disinfection of the Town's sewer discharge are
expected to include:
• Construction of a wastewater pump station and above-ground disinfection contact
Draft 2 3/22/18

PV
tank;
• Continued use of Chlorine Gas;
• Convert to Sodium Hypochlorite;
• Convert to Peracetic Acid(PAA); or
• Convert to Chlorine Dioxide.
An engineering analysis will be required to evaluate these alternatives and to design the
long-term disinfection system for the Town's sewer discharge.The Town plans to initiate
the engineering analysis and design activities in 2019, if found to be necessary,followed by
the implementation of the disinfection upgrade capital project in 2020.The failure of the
initial modifications to meet the desired FC criteria in the Town's sewer discharge and the
subsequent investigation of alternative disinfection chemicals would result in an extended
enforcement discretion request by EPI to NCDEQ and submittal of a revised action plan for
follow-up investigations and implementation of the new disinfectant chemical.
• The Town of Canton has initiated an Industrial User Survey to determine the characteristics
of the industrial discharges to the Town's sanitary sewer system. The Town believes that
this survey can be completed by the users and returned to the Town by May 31,2018. A
summary of findings will be submitted to the NCDEQ by the Town by July 31,2018.
Samples of industrial discharges and EPI landfill leachate will also be collected and tested
by the Town to measure chlorine demands,as part of this industrial survey.
• EPI should continue testing of the weekly Mill W WTP effluent FC compliance samples by
Statesville Analytical,Inc(or another laboratory approved by NCDEQ)for Membrane
Filtration(MF)testing.The MF test results will be used to determine compliance with the
NPDES FC standard.
Whenever MF test results on the Mill NPDES discharge during 2018 show a FC exceedance,
EPI should request that Statesville Analytical immediately overnight ship the positive MF
test agar sample to BCN Research Laboratories in Rockford,TN(or other qualified lab
selected by EPI)for DNA testing of the test agar to identify the species of FC bacteria
causing the positive FC count,which will be used to determine whether the positive bacteria
originated from a human source. EPI will use these DNA test results to determine if an in-
mill and in-W WTP survey program should be initiated in 2019 to identify potential sources of
bacteria which may be contributing to positive Fecal Coliform test counts on samples of the
NPDES discharge.
Hopefully,this status report and action plan recommendations will be helpful to the Town of
Canton and Evergreen Packaging for investigation and resolution of Fecal Coliform issues. Please
feel free to call Ned Fiss,Bob Stein or Matt Fiss if you have any questions or want to discuss.
Draft 3 3/22/18

evergreen*
i Canton Office
packaging 175 Main Street• Canton, NC 28716
October 18, 2016 rr-nr NMM 55-16
RECE
"'..ti{lfl cf wdterl Fesu�,'�ce�
CERTIFIED MAIL
Return Receipt Requested
7099 3220 0007 0371 4781 OCT '116
Water On�np,(t—it naj Onerations
Landon Davidson ^" c A
Asheville Regional Supervisor
Division of Water Resources
North Carolina Department of Environmental Quality
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton,Haywood County,North Carolina
Notice of Violation: NOV-2016-LV-0524 &NOV-2016-LV-0526
NPDES Permit: NC0000272
Dear Mr. Davidson:
This letter serves as Evergreen Packaging's (EPI) formal response to two Notices of Violation
dated September 19, 2016. Copies of the NOV's are attached. Thank you for granting EPI
additional time to respond to the NOV's and for speaking with me about this matter on October
7, 2016.
As you are aware, EPI treats all of the wastewater from the Town of Canton's collector sewer
system pursuant to contract (the "Contract").' EPI's waste stream includes little, if any,
biological waste. The Town of Canton is required to and does dose its wastewater with chlorine
prior to entering the EPI wastewater treatment plant("WWTP"). The Town has upgraded its
system over the years to an automatic chlorine injection system.
There have been issues with fecal coliform in EPI's effluent over the years and particularly
since early in 2015. EPI believes the fecal coliform exceedances in its effluent result from the
' The wastewater discharge from the Town of Canton is approximately nine hundred thousand gallons per day.
t In 2007-08,the Town added the chlorine injection system,doubling its capacity to add chlorine and constructed a
flood wall to protect the system. /
fresh by design /

NCDWR Page 2
failure of the Town to adequately treat its wastewater and from characteristics of the Town's
waste stream.
When issues with fecal coliform arose in May of this year, EPI consulted with experts at the
National Council for Air and Stream Improvement(NCASI) in an attempt to better characterize
any public health concern arising out of the exceedances of the daily maximum limit. EPI
collected samples and sent them off to a certified lab to characterize the E. coli present in the
fecal. The current Coliform test method screens for markers which may or may not be indicators
of good water quality. Accordingly, EPI asked for the E. coli analysis as a better measure of the
quality of the water being discharged.3
Multiple samples over different days were sent to Pace Analytical Laboratories. All results
showed the total E. coli count to be less than that which EPA recommends for E. coli (applied to
municipalities) which is 126 counts/100 mL monthly geometric mean and 410 counts/100mL
daily maximum. At the request of your office, additional Coliform tests were performed both
upstream and downstream of the mill and both were within the acceptable range.
Additional information that has not been sent to your office but was communicated to you on
October 7`s is as follows:
1. Upon receiving the first weekly fecal Coliform failure on May 27`s, an investigation into
the volume and make-up of flow through the town's chlorination system began. .
2. Chlorine residuals were found to be depleted during two events, one when leachate was
being pumped while the other appeared to be a"random event".
3. Several meetings with the Canton Town Manager and their Collection System Manager
occurred discussing these findings. The Town insisted that the leachate was causing
depletion of the chlorine residual.
4. EPI evaluated the effects of leachate on chlorine residual and found that the leachate had
limited effect. Data was also captured that represents when no leachate is pumped and
when a"random event"occurs through the town's effluent which overwhelms the
existing chlorine treatment system and results in zero chlorine residuals.
5. All chlorine residuals data being captured moving forward, thus began to include the
"appearance" of the sample. The reason for this was during the "random events", the
effluent often appeared to be different in appearance versus typical high chlorine residual
effluent.
6. EPI,because we are the permit holder,has performed the following in an effort to
increase the chlorine residuals at the Wastewater Treatment Plant;
a. Installed a Hypochlorite pump feed system at the Landfill operations that is
designed to actuate and respond to when leachate is being pumped. EPI has the
hypo injection feed rate set at its maximum feed of-400gpd.
3 The nearest laboratory that could do this analysis is located in Eden,NC.Shipping time to the lab actually exceeds
the required hold time for samples, however,NCASI advised EPI the results would still be valid.

NCDWR Page 3
b. At the Wastewater Treatment Plant, EPI has the Hypochlorite feed at its
maximum feed rate of--400gpd.
Note: Even with the additional hypochlorite feed, data has shown that this max feed rate
still does not effectively and consistently maintain adequate chlorine residuals
when a"random event" occurs.
7. Once EPI identified the magnitude of the"random event", EPI began contacting some of
Canton's industrial users to try and identify any recent changes in discharges that may
have occurred. This resulted in no additional information.
8. EPI, more specifically, Brian Satterfield, EHS Business Unit Manager for the Canton
Mill, reached out to other Municipalities and compliance authorities to seek help to
address these"random event"issues.
9. EPI has most recently,upon discussing with various Wastewater Treatment experts,
begun the following:
a. Hourly Chlorine residual data collection (The reason behind this is because on
the week of September 16'h, EPI failed a weekly fecal Coliform. The chlorine
residual data showed dramatic decreases in residuals over time. Collecting
data every three hours does not reflect the potential of the effluent to achieve
zero within that timeframe.)
b. Investigating continuous Chlorine monitors. Current literature indicates that
placing these monitors in a pre-treatment set-up will give false positives and
would require frequent maintenance and cleaning.
c. Establish testing requirements,whereby if or when a"random event"takes
place which is seen via a sudden drop in the chlorine residuals, the sample will
undergo a series of additional tests to better understand the makeup of these
events.
10. EPI requested via a phone call to Mr. Davidson for assistance as to what, if anything else
may also be included as additional preventive and/or proactive measures to address the
ongoing"random events"that is being seen.
11. EPI has recently had follow-up meetings with the Town of Canton in regards to these on-
going issues and the Town has agreed to initiate a Request for Qualification (RFQ)
whereby an independent expert engineer will assess their system and provide
recommended corrective actions.
12. EPI has agreed to work with the Town of Canton on the RFQ to ensure that a feasible
solution to the ongoing fecal Coliform issue is addressed.
Given the complexity of the issue, the relationship with the Town of Canton, and the ongoing
study of this issue,.EPI requests that both NOV's be reconsidered and a Notice of Deficiency be
issued. EPI will continue to work with the Town of Canton to identify the cause(s) of this issue
and will update the Division of Water Resources on any information that is discovered.
Representatives of EPI will be happy to coordinate a meeting with representatives of the Town
and DWR.

NCDWR Page 4
Your cooperation and assistance in this matter are most appreciated. If you have any
questions or comments, please feel free to contact us at your earliest convenience.
Sincerely,
Nick McCracken
Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick.MaCracken a)evgpack.com
cc:
Mr. Tim Heim
Environmental Specialist, Asheville Regional Office
North Carolina Department of Environmental Quality
2090 U.S. Highway 70
Swannanoa, NC 28778
C. File—Water Notebook

XAsaz ,.
1110 ,3 7 I�r VAN DEILT�AAi T-
Certified Mail # 7014 0510 0000 4466 4897
Return Receipt Requested
September 19, 2016
Stephen J Hutchins, General Manager
Blue Ridge Paper Products Inc
175 Main St
Canton, NC 28716
SUBJECT: NOTICE OF VIOLATION &INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2016-LV-0524
Permit No. NC0000272
Canton Mill WWTP
Haywood County
Dear Permittee:
A review of the May 2016 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated below:
Limit Exceedance Violation(s):
Sample Limit Reported
Location Parameter Date Value Value Type of Violation
001 Effluent Coliform, Fecal MF, MFC Broth, 5/27/2016 400 2,420 Daily Maximum Exceeded
44.5 C(31616)
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (.G.S.) 143-215.1 and the facility's NPDES Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not
more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails
to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice.
A review of your response will be considered along with any information provided on the submitted Discharge
Monitoring Report(s). You will then be notified of any civil penalties that may be assessed regarding the
violations. If no response is received in this Office within the 10-day period, a civil penalty
assessment may be prepared.

Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
If you have any questions concerning this matter, please contact Janet Cantwell of the Asheville Regional
Office at 828-296-4500.
Sincerely,
G. Landon Davidson, P.G.�upervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Asheville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit- Enforcement File
Nick McCracken/ ORC
i:\WR\WQ\HaywoodlWastewateAIMustrialXBlue Ridge Pdp3 00272\N0V-N0I-2016-LV-0524.rtf

€itvgsoFiu°�ati[bc�ti3ktn' _ s�,�`. , �('�TIiXXyIEi�i�3#:I+7;.
Certified Mail # 7014 0510 0000 4466 4903
Return Receipt Requested
September 19, 2016
Stephen J Hutchins, General Manager
Blue Ridge Paper Products Inc
175 Main St
Canton, NC 28716
SUBJECT: NOTICE OF VIOLATION &INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2016-LV-0526
Permit No. NC0000272
Canton Mill WWTP
Haywood County
Dear Permittee:
A review of the 3une 2016 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated below:
Limit Exceedance Violatlon(s):
Sample Limit Reported
Location Parameter Date Value Value Type of Violation
001 Effluent Coliform, Fecal MF, MFC Broth, 6/2/2016 400 600 Daily Maximum Exceeded
44.5 C(31616)
001 Effluent Coliform, Fecal MF, MFC Broth, 6/9/2016 400 1,410 Daily Maximum Exceeded ,
44.5 C(31616)
001 Effluent Coliform, Fecal MF, MFC Broth, 6/16/2016 400 435 Daily Maximum Exceeded
44.5 C(31616)
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's NPDES Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not
more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails
to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
State of North Carolina I Environmental Quality I Water Resources
2090 U.S.70 Frigrway,Swannanoa,NC 28778

If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice.
A review of your response will be considered along with any information provided on the submitted Discharge
Monitoring Report(s). You will then be notified of any civil penalties that may be assessed regarding the
violations. If no response is received in this Office within the 10-day period,a civil penalty
assessment may be prepared.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
Please refer to the latest letter titled"Electronic Reporting Requirements"concerning registering to use the
Division's new a-DMR system for the completion and electronic submittal of monthly Discharge Monitoring Reports
DMRs .
Your facility will be required to report your Discharge Monitoring Reports electronically by December 21, 2016.
For more information, please visit the eDMR Website at the following address:
http•//portal ncdenr org/web/wo/admin/bog/ir)u/edmr
If you have any questions concerning this matter, please contact Janet Cantwell of the Asheville Regional
Office at 828-296-4500.
Sincerely,
G. Landon Davidson, . Regi al Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Asheville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit- Enforcement File
Nick McCracken/ ORC
'u:\WR\WQ\Haywood\Wastewater\Industrial\Blue Ridge Paper 00272\N0V-NOI-2016-LV-0526.rtf

Historical Reference of Fecal Coliform based on Electronic records that were found.
Date Issue Cause/Resolution
O1/28/03 NOV, Fecal Coliform The probable cause of the fecal coliform violation
was insufficient retention time in the Town of
Canton's chlorine contact chamber. Resolution-
Faulty valves requiring lengthy time for rebuilt,
the town will install a plug(s)that will allow the
chamber to operate normally as well as improve
the notification system to Mill when system is
not operating as designed.
06/26/12 Fecal Coliform Excursion Unable to determine Root Cause.
08/14/12 Fecal Coliform Excursion Unable to determine Root Cause.
11/20/12 Fecal Coliform Excursion The two breaks in the Town's chlorinated water
line were preventing the incoming waste stream
from getting the full necessary dose prior to
entering the low lift. Both breaks were repaired.
11/27/12 Fecal Coliform Excursion The two breaks in the chlorinated water line
were preventing the incoming waste stream from
getting the full necessary dose prior to entering
the low lift.. Both breaks were repaired.
05/17/13 Fecal Coliform Excursion The construction progress on the Town's new
chlorine pretreatment feed system. Evergreen
continues to supplement the Town's feed at the
upper manhole via a gravity fed,sodium
hypochlorite tote. The feed rate of the tote has
since been increased along with adjustments to
the Town's chlorine feed system.
08/16/13 Fecal Coliform Excursion (NOV Canton area experienced a heavy rainfall event
Issued) resulting in over two inches of rain within a 35
minute period. Flow to the wastewater
treatment plant,from the town and mill, peaked
at approximately 50 million gallons. In order to
manage flow and protect plant operations the
plant's spare primary clarifier was partially filled.
After the event,flow normalized and the spare
clarifier was slowly drained back into the
treatment process over the next three days. This
material from the spare clarifier was from the
first flush of the rainfall event and believed to
hold the most concentrated waste.
2/20/14 Fecal Coliform Excursion Unable to determine Root Cause.
2/28/14 Fecal Coliform Excursion Unable to determine Root Cause.
06/05/14 Fecal Coliform Excursion It was believed that the Secondary Effluent and
Primary Effluent samples on 6/5 were swapped
and that the mill continued to be in compliance
with permit limits at that time.

12/30/14 Fecal Coliform Excursion The likely explanation is limited to a significant
rain event that occurred the previous day. This
event deposited—0.40"of rain, in the Canton
area,over period of approximately 6 hours.
Historically, increased flow and fecal loading from
the Town,to the treatment plant, has been
observed during similar rainfall events.
5/27/16 Fecal Coliform Excursion (NOV- Investigation has revealed that there is an event
Pending) taking place during normal flows within the
town's system that is depleting the excessive use
of both hypo and chlorine treatment being used.
6/02/16 Fecal Coliform Excursion (NOV- Investigation has revealed that there is an event
Pending) taking place during normal flows within the
town's system that is depleting the excessive use
of.both hypo and chlorine treatment being used.
6/09/16 Fecal Coliform Excursion (NOV- Investigation has revealed that there is an event
Pending) taking place during normal flows within the
town's system that is depleting the excessive use
of both hypo and chlorine treatment being used.
6/16/16 Fecal Coliform Excursion (NOV- Investigation has revealed that there is an event
Pending) taking place during normal flows within the
town's system that is depleting the excessive use
of both hypo and chlorine treatment being used.
-9/16/16 Fecal Coliform Excursion Investigation has revealed that residuals dropped
to zero when leachate was pumped even when
additional hypo was added at the land fill. Time
was allotted to achieve 10 residuals again and
then samples were collected. Leachate pumping
was minimal. Still believe a slug event occurred
within the town's system that contributed to the
reading as all other Hypo systems was on full.

Town of Camnn . Grab Sample Tom]Chlorine R�Wuals
Chlorine AMoverim of P%WW Speed Alto
0We Ttne ReAdwl OPFMr 1110 e
1 �,:20]6 1230 AM
t JO AM
190AM
3:30 AM
� 0^r" No Leachate pumping over the
s:90 AM
630AM — weekend. Chlorine residuals
7_31) dropped from 10 to 2.
830 Am Measurements taken every hour.
430 AM
10c3CAM Color observed to change from
11:3oAM "cloudy"to 'Blackish". EPlcannot
17�DPPA I ` e' confirm if residuals dropped below
1:W PM
2:30 PM r
2 without having a continuous real
3:30PPA ,, time monitor. This is but one of
430 PM •1 „ many examples EPI is experiencing
5:30 PM
690 PM in the current treatment of
7:30 PM r " incoming Town material.
U0 PMto a
Y30 PM —
30PM
11:30 PM `- h
12:30 AM 10
130AM rr
230 AM
3:30 AM
t30 AM I
53D AIA R

pppppp�
evergreen./ Office
packaging 75 M S,,ee'• .o,ion, NC 28716
June 16, 2016 NMM#29-16
CERTIFIED MAIL
Return Receipt Requested RECEIVED 1
7006 0100 0003 6622 5613 D"m of waxer Resources
Landon Davidson J p
Asheville Regional Supervisor
UN
Division of Water Resources
North Carolina Department of Environment w�t�OuelRYaet +n+�tfe'8�O"°
and Natural Resources Asnevile Regional O+rceq_,_,,
Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton, Haywood County, North Carolina
Daily Maximum Fecal Coliform 6/9/2016
NPDES Permit: NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
6/9 at approximately 11:35 am and picked up by the laboratory for analysis. Proper sampling
procedures were followed by plant personnel. We received the laboratory report via email the
afternoon of 6/10. The result of the analysis showed a value of 1410 MPN per 100 ml. The fecal
coliform excursion on 6/9 was limited to that sample parameter and day. A phone call was
placed to the NCDEQ regional office on 6/10.
Once we received the value from the laboratory all systems in the treatment facility were
inspected. They were found to be operating correctly leading up to and during the time of
sample. The Town of Canton's chlorine injection system was also inspected.
We are continuing our in depth investigation into the cause of these recent results. If an
identified source or cause is determined, a follow up notice to your office will occur describing
the results of our findings.
If you have any questions or comments, please feel free to contact us at your earliest
convenience.
IleverpacklcalEOHSISHARBWater FilesWick's Water Files OWR

'CDWR Page 2
Sincerely,
Nick McCracken
Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCracken(&everpack.com
cc:
Mr. Tim Heim
Environmental Specialist, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
C. File—Water Notebook

evergreen'.0 Canton Office
packaging I 175 Main Street• Canton, NC 28716
June 9, 2016 NMM#28-16
CERTIFIED MAIL
Return Receipt Requested oraC D
7099 3220 0007 0371 4743
Landon Davidson JUN 13 2016
Asheville Regional Supervisor
Division of Water Resources Water t"WY*@§bnet p M
North Carolina Department of Environment Asnevme Regional O fice
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill,Canton, Haywood County,North Carolina
Daily Maximum Fecal Coliform 5/27/2016 &6/2/2016
NPDES Permit: NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform samples were taken
on 5/27 at approximately 8:00 am and on 6/2 at approximately 7:00 am. On both occasions a
laboratory courier picked up the samples and took them back for analysis. Proper sampling
procedures were followed by plant personnel. We received the first laboratory report the
afternoon of 6/1. The second test result was given by email on 6/3. The result of the first
analysis showed a value of>2420 colonies per 100ml. The second test analysis showed a value
of>600 colonies per 100 ml. The fecal coliform excursion on both days was limited to that
sample parameter. All other parameters were within permitted limits. A phone call was placed
to the NCDWR regional office on 6/2 &6/3.
Once we received the value from the laboratory analysis for the 5/27 sample all systems in the
treatment facility were checked. They were found to be operating correctly leading up to and
during the time of sample. After the second test analysis was received these systems were once
again checked but nothing abnormal was observed. We are continuing our in depth investigation
into the cause of these results. This includes laboratory QA/QC and also reaching out to the
National Council on Air& Stream Improvement (NCASI)to see if other mills are seeing
abnormal test results when all systems are operating normally and no disruption has occurred. If
fresh by design
IleverpackVcaIEOHSISHAREJWater FilesWick's Water FilesIDWO

FPNPCDWR Page 2
an identified source or cause is determined, a follow up notice to your office will occur
describing the results of our findings.
If you have any questions or comments, please feel free to contact us at your earliest
convenience.
Sincerely,
i�
Nick McCracken
Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCrackenna evgMack.com
cc:
Mr. Tun Heim
Environmental Specialist, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778

ppppp-
PP
evergreen.. Canton Office
packaging 175 Main Street • Conton, NC 2871 b
June 9, 2016 NMM#28-16
CERTIFIED MAIL
Return Receipt Requested
7099 3220 0007 0371 4743
Landon Davidson
Asheville Regional Supervisor
Division of Water Resources
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton,Haywood County,North Carolina
Daily Maximum Fecal Coliform 5/27/2016&6/2/2016
NPDES Permit: NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform samples were taken
on 5/27 at approximately 8:00 am and on 6/2 at approximately 7:00 am. On both occasions a
laboratory courier picked up the samples and took them back for analysis. Proper sampling
procedures were followed by plant personnel. We received the first laboratory report the
afternoon of 6/1. The second test result was given by email on 6/3. The result of the fast
analysis showed a value of>2420 colonies per 100ml. The second test analysis showed a value
of>600 colonies per 100 ml. The fecal coliform excursion on both days was limited to that
sample parameter. All other parameters were within permitted limits. A phone call was placed
to the NCDWR regional office on 6/2 &6/3.
Once we received the value from the laboratory analysis for the 5/27 sample all systems in the
treatment facility were checked. They were found to be operating correctly leading up to and
during the time of sample. After the second test analysis was received these systems were once
again checked but nothing abnormal was observed. We are continuing our in depth investigation
into the cause of these results. This includes laboratory QA/QC and also reaching out to the
National Council on Air& Stream Improvement(NCASI)to see if other mills are seeing
abnormal test results when all systems are operating normally and no disruption has occurred. If
f
i
I1everpacklcalE0HSISHARE1Water FilesWick's Water FilesIDWO /

pppp-
NCDWR Page 2
an identified source or cause is determined, a follow up notice to your office will occur
describing the results of our findings.
If you have any questions or comments, please feel free to contact us at your earliest
convenience.
Sincerely,
Nick McCracken
Water Supervisor
Evergreen Packaging-Canton Mill
828-646-2874
Nick.McCracken(o,everyack.com
cc:
Mr. Tim Heim
Environmental Specialist, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778

e ergreen �I ca�ia� o1�e
175 Main Street• Canton, NC 28716
packaging
JAG 72-15
October 26, 2015 Certified: 7008 3230 0002 2595 6008
Return Receipt Requested
Ms. Janet Cantwell /
NC DENR- Division of Water Resources
2090 U. S. 70 Highway
Swannanoa, NC 28778
RE: Canton Mill,Landfill Number 6 Leachate Line
Sanitary Sewer Overflow(SSO) Report
NPDES Permit# NC0000272
Dear Ms.Cantwell:
In compliance with G. S. 143-215.9B,attached is the completed Collection System Sanitary
Sewer Overflow Reporting Form CS-SSO for the October 20, 2015, release of leachate
originating at the Blue Ridge Paper Products Inc., Landfill Number 6, Permit Number 44-06.
The release was identified as a break in the leachate line at a glued joint,which caused a
leak of approximately 400 gallons of landfill leachate to the Pigeon River. Please see the
attached report for details of the leak and the subsequent response and repair.
Please let me know if you have questions. Thank you for your time and consideration.
Sincerely,
9amWesA'*Giauque
Waste Compliance&Landfill Supervisor
Blue Ridge Paper Products Inc.
jim.giaau ue0everpack.com
828-646-2028 Fax [phone]
File:CS-SS0102015
Attachment
Copy: Brian Satterfield
Nick McCracken
fileAx\ roacklctnsharedVeohslShargGSofid Waste and Landfi[IVI chateS50102315
— — {reblt by design
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State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
DlvWon of Wafer Resources Form CS-SSO
PART 1:
This form shall be submitted to the appropriate DW R Regional Office within five b ness da s of the first knowledge of the
sanitary sewer overflow(SSO).
Permit Number: NPDES#NC0000272 (WQCS#if active,otherwise u QCSD#)
Facility:Blue Ridge Paper Products,Inc(BRPP) Incident#: Owner:Blue Ridge Paper Products,Inc
Region: City:Canton County:Haywood
Source of SSO(check applicable): ® Sanitary Sewer ❑ Pump Station/Lift Station
SPECIFIC location of the SSO(be consistent in description from past reports or documentation-i.e.Pump
Station 6,Manhole at Westall&Bragg Street,etc.):Leachate line from Landfill Number 6(Permit Number 44-06)at
location adjacent to Champion Drive(SR 1643)in Canton,NC. The location is approximately 0.3 miles south of the
intersection of Champion Drive and Thickety Road(SR 1513),and approximately 10 feet north of the leachate line
cleanout box Number 2.
Manhole#:NA
Latitude(degrees/minute/second): Longitude(degrees/minute/second):
Incident Started Dt: 10-20-2015 Time: 08:00 AM Incident End Dt: 10-20-2015 Time: 11:00 AM
(mm-dd-yyyy) (hh:mm)AM/PM (mm-dd-yyyy) (hh:mm)AM/PM
Estimated volume of the SSO: 400 gallons Estimated Duration(round to nearest hour): 3 hour(s)
Describe how the volume was determined: 2 gpm estimated flow from storm drain end of pipe for duration of
approximately 3 hours.
Weather conditions during the SSO event: Clear
Did the SSO reach surface waters? ® Yes ❑ No ❑ Unknown
Volume reaching surface waters: 400 gallons Surface water name: Pigeon River
Did the SSO result in a fish kill? ❑Yes ® No ❑Unknown
If Yes,what is the estimated number of fish killed? NA
SPECIFIC cause(s)of the SSO:
❑Severe Natural Conditions ❑ Grease ❑Roots []inflow&Infiltration
❑Pump Station Equipment Failure ❑ Power Outage ❑Vandalism ❑Debris in line ZPipe Failure(Break)
❑Other(Please explain in Part II)
24-hour verbal notification(name of person contacted):Janet Cantrell
®DWR ❑Emergency Management Date(mm-dd-yyy): 10-20-201.STime:(hh:mm AMLPM): 12:27 PM
Per G.S. 143-215.1 C(b),the owner or operator of any wastewater collection system shall:
In the event of a discharge of 1,000 gallons or more of untreated wastewater to the surface waters of the Stale,issue
a press release to all print and electronic news media that provide general coverage in the county where the
discharge occurred setting out the details of the discharge. The press release shall be issued within 24 hours after
the owner or operator has determined that the discharge has reached surface waters of the State.
In the event of a discharge of 15,000 gallons or more of untreated wastewater to the surface waters of the State,
publish a notice of the discharge in a newspaper having general circulation in the county in which the discharge
occurs and in each county downstream from the point of discharge that is significantly affected by the discharge. The
Regional Office shall determine which counties are significantly affected by the discharge and shall approve the form
and content of the notice and the newspapers in which the notice is published.
Form CS-SSO Page I

"'N
State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Divlslon of Water Resources Collection System Sanitary Sewer Overflow Reporting Form
Form CS-SSO
WHETHER OF NOT PART II IS COMPLETED.A SIGNATURE IS REQUIRED SEE PAGE 13
Form CS-SSO Page 2

In order to submit a claim fbi-justification of an SSO,you must use Part1I of form CS-SSO with additional documentation as
necessary. DWR staff will review the justification claim and determine if enforcement action is'appropriate.
PART 11:
ANSWER THE FOLLOWING QUESTIONS FOR EACH RELATED CAUSE CHECKED IN PART I OF THIS FORM AND
INCLUDE THE APPROPRIATE DOCUMENTATION AS REQUIRED OR DESIRED
COMPLETE ONLY THOSE-SECTONS-PERTAINING TO THE CAUSE OFTHE SSO AS CHECKED IN PART I
(In the check boxes below,NA=.Not Applicable and NE=Ndt Evaluated)
A HARD_ COPY OF THIS FORM SHOULD BE SUBMITTED TO THE APPROPRIATE DWR REGIONAL OFFICE UNLESS,
IS HAS BEEN SUBMITTED ELECTRONICALLY THROUGH THE ONLINE REPORTING SYSTEM
Form CS-SSO Page.3

Severe Na(ural Conditions(hurricane, tornado, etc.)
Describe the"severe natural condition"in detail: NA
How much advance warning did you have and what actions were taken in pieparationfor the event?NA
Comments:
. A
gx
pR
I
1
Form CS-SSO Pagel

Grease Documentation such'as cleaning, inspection; enforcement actions, past overflow:reports .educational
material and distribution date,etc..shouldbe available upon request.),
When'vvas the last time this specific line(or Wet Well)wasmleaned? NA
Do you have an enforceable grease Ordinance that requires,new orreProfit of
grease traps/interceptors? ❑Yes ❑ No ®:NA ❑NE
Have there.been recent inspection and/or:enforcement actions taken on near-
by restaurants or other nonresidential grease contributors? ❑Yes ❑ No MNA ❑ NE
Explain:
Have there,been other SSOs:pr blockages in this areas that were,also caused
by grease ❑ Yes ❑ No [gNA ❑ NE
When?
If yes,.describe them:
Have cleaning and inspections`ever been done at this location? ❑Yes' ❑ No ®NA ❑ NE
Explain.
Have educational material about grease been distributed in the past? ❑.Yes ❑ No ONA ❑ NE
When:
and to:whom:
Explain:
If the SSO occurred at a pump station,when was the wet well and pumps last checked
for grease accumulation:
Were the floats clean? ❑,Yes ❑ No ®NA ❑ NE
Comments:
Form CS-SSO Cage 5

Roots
Do you have an active root.control program on the line{area in question? ❑ Yes ❑ No ®NA ❑ NE
Describe:
Have cleaning and inspectioris,ever been increased at this location because
of roots? ❑ Yes ® No ❑NA ❑ NE
Explain:
What corrective actions.have been accomplished at the SSO location(and
surrounding,system if associated with the SSO)? NA
WhatcoRective actions are planned at the SSO location to reduce root intrusion? NA
Has the Tine been smoke tested or videced within the past year? ❑ Yes ® No ❑NA ❑I NE
If Yes,-when?
Comments:
u
Form CS-SSO Page:6
g1
1

Inflowand Infiltration
Are you under an SOC(Special Order by Consent)or do-you have a.schedule ❑ Yes ® No ❑NA ❑NE
in any permit that addresses III?
Explain.if Yes:
What corrective actions have been taken to reduce or elirninate,l 81 related overflows this spill location
within the,lastyear?
Has there been any flow studies to determine 1/1 problems'in the ❑ Yes ®No DNA ❑ NE
collection system at the SSO location?
If Yes,when was the study completed and what actions did it recommend?
Has the line been smoke tested or videoed within the past year! ❑ Yes ® No DNA ❑NE
If Yes,when and what actions are necessary and the status of such actions:
Are there 1/1 related projects in your Capital Improvement Plan? ❑ Yes ® No DNA ❑ NE
If Yes,explain;
Have:there been any grant or loan applications for III reduction projects? ❑ Yes ® No DNA ❑ NE
If Yes,explain:
Do you suspect any major soyr0aof inflow orcross'connections - El Yes ® No DNA ❑ NE
with storm sewers?
If Yes,explain:
Have all lines contacting-surface waters in the SSOlocation and upstream ❑ Yes ❑ No ®NA ❑ NE
been inspected recently?
If Yes,-explain:
What other corrective actions are planned to prevent future III related,SSOs at this location?
Comments:
Form CS-SSO Page 7

Pump Station Equipment Failure (Documentation of testing records, etc should be provided upon request)I
What kind of notification/alarm systems are present?
Auto-dialer/telemetry(one-way communication) ❑ Yes
Audible Yes
Visual ® Yes
SCADA(two-way communication) ❑ Yes
Emergency Contact Signage ❑ Yes
Other ❑ Yes
If Yes,explain:
Describe theequipment that failed: No failure
What kind of situations trigger an alarm condition at this station(i.e.pump failure,power failure,high water,etc.)?
Werenotification/alarm systems operable? N Yes ❑ No ❑NA ❑ NE
In no,explain:
If a pump failed,when was the last maintenance and/or inspection performed? NA pr
What specifically was checked/maintained? {
If a valve failed,when was it last exercised? NA
Were all pumps set to alternate? ® Yes ❑ No ❑NA ❑ NE
Did any pump show above normal runtimes prior to and during the SSO event? ❑Yes ® No ❑NA ❑ NE
M
Were adequate spare parts on hand to fix the equipment ❑Yes ❑ No ®NA ❑ NE
Was a spare or portable pump immediately available? ® Yes ❑ No ❑NA ❑ NE
If a float problem,when were the floats last tested? How? NA
S
If an auto-dialer or SCADA,when was the system last tested? How?NA '
�I
Comments: �
J�1
4
i
Form CS-SSO Page 8
9
I

Power outage{Documentation of testing, records,tec., should be provided of alternative power source upon
request.)
What Is your alternate power or pumping source? NA
Didit function properly? ❑ Yes ❑No [KNA ❑ENE
Describe? NA
When was the alternate power or pumping source last tested under load? NA
If caused by a weather event,how much advance warning did.you have and what actions were taken to prepare for the
event? NA
Comments:
Form CS-SSO Page

Vandalism
Provide police report number: NA
Was the site secured? ❑'Yes ❑ No ®NA NE
If Yes,how?
Have there been previous pfoblems.with vandalism at the SSO location?No
If Yes,explain:
What`securiry measures:have been put in place'to•prevent similar ❑Yes ❑,No ®NA NE
occurrences in the-future?
Comments:
Form CMSO' Page;to

Debris in line(Rocks, sticks,rags and other items not allowed in the collection system etc.)
What type ofdebris has been found in the line? None
Suspected cause or source of debris: NA
Are manholes in the area secure and intact? ❑ Yes ❑ No ®NA ❑NE
When was the area last checked/cleaned? NA
HaVe.cleaning and inspections ever been increased at this location ❑ Yes ❑ No ®NA ❑ NE
due to previous problems with debris?
Explain:
Are appropriate educational materials being developed and distdbuted ❑ Yes [-]'No ®NA ❑ NE
to prevent future similar occurrences?
Comments:
Fonn-CS-SSO Page Il.

Other(Pictures and police report, as applicable, must be available.upon request.)
Describe:,
Were adequate equipment and resources available to fix the problem? [D'Yes ❑ No ❑NA I NE
If Yes,explain: Personnel,backhoe,and vacuum truck immediately available.
If the problem could not be immediately repaired,what actions ❑ Yes ❑ No ®NA Q NE
were taken to lessen the impact of the SSO?
Comments:
Faun CS-SSO Page 12

Pipe Failure(break)
Pipe size(inches) 6 inches id
What is the pipe material PVC
What is the approximate age of the line/pipe(years old) ,30 years
Is this a,gravity line? ❑ Yes ® No DNA ❑ NE
Is this,a force main line? ® Yes ❑ No DNA ❑ NE
Is the line a"High Priority"line? ❑ Yes ❑ No ❑NA ® NE
Last inspection date and findings System pumps and lines visually inspected each working day
If a force.main'then,
Was the break on the force main vertical? ❑ Yes ® No DNA ❑ NE
Was the,break on the force main horizontal? ® Yes ❑ No DNA El NE
Was the leak at the joint due to gasket failure?° ❑ Yes ® No DNA ❑ NE
Was the leak at the joint dueto split bell? ❑ Yes ® No DNA ❑NE
When was the last inspection or test of the nearest air.-release valve to determine if operable? 9-29-2015,
When was the last maintenance of the air release performed? 9-29-2015
If gravity sewer then,
Does:the line receive flow from a force main immediately upstream ❑Yes ® No DNA ❑ NE.
of the failed section of pipe?
If yes,what measures are taken to control the hydrogen.sulfide-production? NA
When wasthe line last inspected or videced? NA
If line-collapsed,what Is the condition of the line up and down stream,ofthe failure? NA
What type of repair was made? Stainless steel tepairjoint secured with handi-bands
If temporary„when is the,permanent repair planned? NA
Have there been other failures of this line in the past five years? ❑ Yes ® No DNA ❑NEE
If so,;then,describe
Form GS-SSO Page`13

System Visitation
ORC ❑ Yes.
Backup ❑ Yes
Name: James.A.Giauque
Certification Number. NA
Date visited: Daily visits during normal operating days
Time visited: Variable
How was the SSO remediated(i./e.Stopped and cleaned up)?
Upon discovery, the leachate system pumps were turned off. The underground line was exposed by exca1vation
with a backhoe, leaking water was vacuumed by vacuum truck,a stainless steel joint was fabricated, and i
attached with handi-bands.The exposed line was monitored while in operation for appproximately 8 hours to
check for leaks prior'to the excavation being backfilled. No leaks were found to the repaired line.The
excavation was backfilled with clean fill, and the leachate-contacted excavated soil disposed at the BRPP'
Landfill Number 6.Vacuumed leachate.was taken to the BRPP waste water treatment plant for treatment. The
leachate system was then put back into normal service.
As a representative for the responsible party. I certify that the information contained in this report istrue.and accurate to the.
best of my knowledge.. i
Person submitting claim: James•A. Giauque- _ Date: 10-23-2015'
Signature: ,,L - Title:..�/45 Cor•uD��Gk4 X ZI�Ia4il
�«?rvrsc n
Telephone Number: 828-646-2028
I
Any additional information desired to be submitted should be sent to the appropriate Division Regional Office within five
business days of first knowledge of the SSO with reference to the incident'number(the incident number is only generated
when electronic entry of this form is completed,if used): WVI
Y
Farm-CS-SS0 Page!14 .
1

evergreen. ! Canton Office
packaging 175 Main Street- Canton, NC 28716
March 31, 2015 NMM #26-15
CERTIFIED MAIL
Return Receipt Requested RECEIVED
7099 3220 0007 0371 4668 Division w water Hesoumy
North Carolina Department of Environment APR - 6 2015
and Natural Resources
Division of Water Resources
Water otr 1!c Regional 0peretlona
Water Quality Section
Ashw llc Regional Office
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, NC 27699-1 6 1 7
Re: NPDES NO. NC0000272
Best Management Practices 2014 Annual Report
Blue Ridge Paper Products Inc. d/b/a Evergreen Packaging
Canton, NC
This letter report (two copies) is the 2014 summary of Best Management Practices (BMP) daily
monitoring for the Canton Mill. The report is required on or before March 31 st of each year by
Special Condition A.(6.) Best Management Practices, Section EA and Section F.1, of the mills
NPDES Permit No. NC0000272.
The BMP action levels established in accordance with permit requirements and in effect for 2014
are as follows:
Effective Dates: 1 Jan 2014— 31 Dec 2014
Total Influent (TI) Color —
Action Level daily monitoring result Action Required
1-Day Upper Action > 72,500 Ibs/day for one day Immediate investigation and documented
Level (UAL) corrective action
2-day Upper Action > 59,400 Ibs/day for two Investigation and documented corrective
Level (UAL) consecutive days action
2-day Lower Action > 55,400 Ibs/day for two
Level (LAL) consecutive days Investigation and documentation
Daily records of total influent color are maintained at the mill. These daily color data are
compared to BMP action levels every morning. Total influent color exceeded BMP action levels
Blue Ridge Paper Products Inc. dba Evergreen Packaging —Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 . 828-646-2000
\\everpack\CTN\Shared\EOHS\Share\Water FilesWick's Water Files\DWR\Annual Reports\2014 Annual BMP Summary.doc

31 Mar 2015,Page 2
Daily records of total influent color are maintained at the mill. These daily color data are
compared to BMP action levels every morning. Total influent color exceeded BMP action levels
on the dates outlined in the following table. A brief summary of information for these dates are
included as required by permit Condition A.(6.), Section EA. The permit-required BMP
investigation reports are maintained at the mill. None of the BMP action level days resulted in
disruption to the wastewater treatment plant excluding the period of January 7 through January
13. During this time an extreme cold front caused an unscheduled cold mill outage resulting in
numerous frozen lines and unplanned downtime for the mill. The Canton Mill met all NPDES
annual average effluent limits for the period July 1, 2013 to June 30, 2014.
Total Influent
Date(s) (TI) Color Action Level and Summary
7- 13 Jan 57,339 Ibs/day 1-day UAL/2-day UAL—Investigation and documented
2014 108,218 Ibs/day corrective action
139,375 Ibs/day
89,886 Ibs/day Cause and Corrective Action(s) Non-BMP event. During
103,211 Ibs/day the period of early January the Canton Mill was
85,136 Ibs/day experiencing extremely cold winter temperatures. On the
60,316 Ibs/day morning of 1/7, the temperature was -6° F with a wind chill
of-30' F. The level cell on the Deaerator Tank in the
Utilities department froze giving a false signal to the DCS
system. The signal indicated that the tank was full. This
caused the pumps to stop providing feed water to the
boilers. At that time power boilers began to trip off one at a
time until all boilers supplying the Mill were down. This
resulted in an unplanned, unscheduled cold mill outage.
As the Mill began to restart, the current conditions caused
many lines, including transfer lines, to freeze. This
prevented any movement of spill material to.spill collection
tanks. Elevated color was observed at the treatment plant
at the time of shutdown. Material was caught in the spare
clarifier and batch treated with polyamine.
Conditions for the next several days did not improve.
Without the ability to transfer materials, the Mill was forced
into releasing elevated pH and colored materials to the
sewer in order to position for a restart. This resulted in a
much higher than normal effluent color over the course of a
week. The corrective actions taken were to provide heaters
and freeze protection to all areas of the Mill to prevent any
reoccurrence and bring the Mill back up to a steady state.
Blue Ridge Paper Products Inc. dba Evergreen Packaging—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 e 828-646-2000
IleverpacklCTMSharedlEOHSIShamlWater Files Wick's Water F11esIDWRl4nnua1 Reports12014 Annual BMP Summary.doc

31 Mar 2015,Page 3
Total Influent
Date(s) (TI) Color gand
Level and Summary
14 Feb 2014 78,844 Ibslday AL—Investigation and documented corrective
nd Corrective Action(s)—BMP event. The#11
Boiler was taken offline to repair the Center
blower motor. During the downtime, the
ng Tank overflowed sending high pH material to the
This created sewer generated color in the Primary
system.
In the digester building pine digesters were being washed.
After washing #9 it was put back into service. The digester
was filled per normal operating procedure. The bottom
wash out valve had been left inadvertently open resulting in
the contents of the digester to be released to the sewer
system. This material overwhelmed the sump and traveled
to the WWTP.
The material was then observed in the low lift and diverted
to the spare clarifier for capturing. It was then batch treated
with polyamine and fed back into the treatment system at a
non-disruptive rate.
After the initial loss the #9 digester was then taken back out
of service. The bottom valve was inspected before putting
it back into service.
Blue Ridge Paper Products Inc. dba Evergreen Packaging—Canton Mill
175 Main Street a PO Box 4000
Canton, North Carolina 28716 a 828-646-2000
IleverpacklCTMShamcAEOHSIShamlWaterFilesWick's Water FileS10WR14nnualReports12014 Annual BMPSummary.doc

31 Mar 2015,Page 4
Total Influent
Date(s) (TI) Color Action Level and Summary
22 Feb 2014 75,342 Ibs/day 1-day UAL—Investigation and documented corrective
action
Cause and Corrective Action(s)—Non-BMP event.
Contaminated condensate, used to keep transfer lines from
freezing, had leaked by a valve in the Camp Branch
compound and began filling the West Camp Branch
storage tank. Operations employees called the WWTP to
plan an intentional diversion of material to the WWTP.
Once released, the WWTP operators noticed elevated color
in the low lift and diverted the material into the spare
clarifier. The material was captured for approximately 1
hour. After that time the valve was closed on the West
Camp Branch storage tank and flow was then put back into
the#2 & #3 clarifiers.
The material captured was batch treated with polyamine
and fed back into the treatment system at a non-disruptive
rate. No corrective action(s)were taken.
Blue Ridge Paper Products Inc. dba Evergreen Packaging—Canton Mill
175 Main Street a PO Box 4000
Canton, North Carolina 28716 a 828-646-2000
IleverpacklCTNIShareolEOHSISharelWater FilesWick'3 Water FilesIDWRIAnnual Reports12014 Annual BMP Summary.doc

31 Mar 2015,Page 5
%cyclone.
ent
Date(s) Action Level and Summary
4- 7 Mar 2014 day 2-day UAL— Investigation and documented corrective
day action
day
day Cause and Corrective Action(s)— Non-BMP event. The
#10 Recovery Boiler was scheduled to go down for an
outage along with the#2 fiberline on 3/3. That evening the
boiler operator was performing a routine cyclone wash.
The operator opened the recirculation line going to the
south cyclone, which is typical when washing a selected
cyclone. The large cage inside the cyclone was blinded
over with material causing the cyclone to overflow to the
sewer. The gate was down in the sewer allowing
operations to capture the material but because of the large
volume, a portion of the material bypassed the gate and
went to the WWTP. Due to the weak wash from the
dissolving tank overflowing, it was difficult to differentiate
between the spikes in conductivity at that time. The
material was then observed at the WWTP low lift. Once the
Recovery area was notified the overflow was stopped.
Other elevated material coming into the influent was routine
and is typically seen during outage activities. This includes
high pH material, which has shown to increase sewer
generated color numbers. No corrective action(s)were
taken beyond those needed to stop the flow of material to
the mill sewer.
9 & 10 Mar 61,721 Ibs/day 2-day UAL—Investigation and documented corrective
2014 68,893lbs/day action
Cause and Corrective Action(s)—Non-BMP event. On the
evening of 3/9 it was observed that the 2-hr color numbers
became elevated. This trend occurred for approximately 24
hours and ended on 3/10 at approximately 9 pm. During
this time the Mill was experiencing elevated flows into the
treatment plant. Had flows been more normalized coming
out of the outage action levels for influent color would have
not been triggered.
All areas were checked for sources of color and elevated
pH material. A small tube leak was detected at the #12
digester. The digester was pulled out of service and
repaired.
Blue Ridge Paper Products Inc. dba Evergreen Packaging—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpacklCTMShamdlEOHSIShamIKIater Files Wick's Water FilesIDWRIAnnual Reports12014 Annual BMP summary.doc

31 Mar 2015,Page 6
Total Influent
Date(s) (TI) Color Action Level and Summary
12 & 13 Mar 64,023 Ibs/day 2-day—Investigation and documented corrective
2014 64,426lbs/day action
Cause and Corrective Action(s)— Non-BMP event. On
3/12 the #11 Recovery Boiler went down for a scheduled
outage to wash the cyclones. During the process, wash
material was being captured in the Mill's sump system for
reprocessing back through the evaporator sets. After a
period of time, the material was determined to be too dilute
for processing and was released to the sewer.
At the same time the CRP system was boiled out. The
material that was generated during the boil out was also
captured in the Mill's sump system. After a series of
washes the material being generated was determined to be
too dilute for processing and was released to the sewer.
Both instances were communicated and observed in the
WWTP influent. No corrective action(s)were taken at this
time.
Blue Ridge Paper Products Inc. dba Evergreen Packaging—Canton Mill
175 Main Street a PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpacklCTMSharedlEOHSISharel Water FilesWick's Water FilesDWRIAnnual Reports12014 Annual BMP summary.doc

31 Mar 2015,Page 7
Total Influent
Date(s) (TI) Color Action Level and Summary
25—30 Mar 58,531 Ibs/day 1-day UAL/2-day—Investigation and documented
2014 74,900 Ibs/day corrective action
64,275 Ibs/day
61,546 Ibs/day Cause and Corrective Action(s)— Non-BMP event. On
61,562 Ibs/day 3125 the#5 digester was taken out of service and repaired
56,342 Ibs/day because of a heater leak causing weak black material to
enter the mill sewer system. After the repair was made, the
2-hr color monitoring samples began to decrease and spent
most of the day below 200 pcu. The following day the north
cyclones ran over on the#11 Recovery Boiler around 3:30
pm for a short duration. This was observed in the 2-hr
color monitoring samples taken at the low lift. The release
was too brief to capture the material in the spare clarifier.
On the evening of 3/27 the 2"d stage washer bogged down
after a restart. In order to get the fiberline back online the
washer was dumped several times to the basement to
allow the sump to capture the material and put it back into
the process. Elevated conductivity was observed by
WWTP personnel around 7:15 pm and a grab sample was
taken at the low lift. The color observed required the use of
the spare clarifier to capture the material. After
communicating with the Pulp Mill it was discovered that the
East Sump discharge line had ruptured and allowed the
material to reach the outside sewer. As the Pulp Mill
worked to repair the line for use elevated color material
continued to enter the low lift. Around 10:20 pm another
release of elevated material was captured in the spare
clarifier. The material captured was batch treated with
polyamine and fed back into the system at a later date as to
not disrupt WWTP operations.
Also, during this time the Dregs Filter Vat had been
overflowing to the sewer resulting in high pH material being
discharged. This resulted in increased sewer generated
color numbers.
Blue Ridge Paper Products Inc. dba Evergreen Packaging—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 e 828-646-2000
IleverpacklCTMSharedLcOHSIShaml Water FllesWick's Water F1lesIDWRIAnnual Reports12014 Annual BMP Summary.doc

31 Mar 2015,Page 8
Total Influent
Date(s) (TI) Color Action Level and Summary
2 & 3 May 55,541 Ibs/day 2-day— Investigation and documented corrective
2014 60,417lbs/day action
Cause and Corrective Action(s)— Non-BMP event. After
reviewing the data there was no specific cause for the
elevated color. All conductivity meters and sumps were
working as designed. Mill flow was also within its normal
operating range. No corrective action(s) taken.
2 Aug 2014 75,015 Ibs/day 1-day UAL—Investigation and documented corrective
action
Cause and Corrective Action(s)—Non-BMP event. During
the afternoon of 8/1, an increase in bypassing was
observed from the Metals Removal Process (MRP). The
system was then taken offline for inspection. This resulted
in an excess of Eo filtrate being released to the mill sewer.
The system was put back into service but was still
bypassing. A later inspection determined the East Media
valve was not functioning correctly and needed to be
replaced. The MRP system was then taken down and the
valve replaced.
Other occurrences in the digester building also contributed
to elevated color. The #14 digester developed a tube leak
and was discharging to the hog line which bypasses the
west digester sump. Once discovered the digester was
taken out of service and repaired. Sewer conductivities
confirmed the repair after it was put back into service.
Blue Ridge Paper Products Inc. dba Evergreen Packaging—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpacklCTMSharedlEOHSISharel Water Fileswtck's Water ResIDWRIAnnual ReportsMM Annual BMP Summary.doc

31 Mar 2015,Page 9
Total Influent
Date(s) (TI) Color Action Level and Summary
24 Sep 2014 93,691 Ibs/day 1-day UAL—Investigation and documented corrective
action
Cause and Corrective Action(s)— BMP event. During
preparation for a cyclone wash on the#10 Recovery Boiler,
the material in the cyclones was released to the sump
where it was picked up and put back into the system for
processing. Once the cyclones were empty they were filled
with water and a drum of defoamer was hooked up. The
defoamer had become old and gelled inside the drum. This
prevented defoamer to be fed into the process and allowed
the cyclones to foam over.
The foam traveled to the sump where it could not be
pumped. The material crossed over the containment and
entered the#5B sewer. The WWTP was notified and the
material was captured in the spare clarifier. This material
was batch treated with polyamine and fed back into the
treatment process at a non-disruptive rate.
5 & 6 Oct 2014 66,426 Ibs/day 2-day—Investigation and documented corrective
70,133lbs/day action
Cause and Corrective Action(s)— Non-BMP event. The#2
fiberline and the #11 Recovery Boiler had a scheduled
annual outage to address maintenance concerns within the
two areas. Tank dumping and process operation
positioning began the day of 10/5. This continued
throughout the evening into 10/6.
Materials released to the mill sewer constituted elevated
color material as tanks were opened and washed in
preparation for work. High pH material was also sewered
during this time. The Eimco white liquor tank was opened
on the weekend and efforts were made to wash the
remaining mud out of the tank.
Due to the scheduled outage and the associated release of
elevated color material and high pH material the influent
color was elevated during this time. No corrective action(s)
taken.
Blue Ridge Paper Products Inc. dba Evergreen Packaging—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpacklCTMSharedlEOHSISharelWater FilesWick's Water F®es10WR14nnual Reports12014 Annual BMP Summary.doc

31 Mar 2015,Page 10
Please contact us if you have questions regarding this information.
Sincerely,
Nick McCracken
EHS Water Supervisor
Evergreen Packaging—Canton Mill
[e-mail]
cc:
Mr. Landon Davidson
DWR Regional Supervisor, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778
C. File—Water
BMP Notebook
Blue Ridge Paper Products Inc. dba Evergreen Packaging—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpacklCTMSharedlEOHSISharel Water FilesWick's Water F11esIDWRIAnnual Reports12014 Annual BMP Summary.doc

Cantwell,Janet
From: Davidson, Landon
Sent: Wednesday, December 31, 2014 1:58 PM
To: Menzel,Jeff
Cc: Cantwell,Janet
Subject: Horsehead and Evergreen topics
Just fyi.
1) Nick McCracken called to state that the lab gave him a verbal notice of a 430 colonies of fecal which is above
their daily max. Sample was collected yesterday. Nick believes related to higher rain fall and just a large flush of
material they've received in last few days. He has checked their supplemental system and having the town check
theirs with emphasis on checking flow meter which he said the town apparently has not checked recently.
2) Jim Harris of Horsehead stated that due to necessary maintenance coming up, he'll need to collect aquatic tox
samples next week. He'd like for us to split but I did not commit not knowing your schedule Jeff. I told him you'd
be back in touch once you returned to office and checked your schedule. In regard to NOVs, for the May and
June, he stated those were'turned in' and he is double-checking that. For Cd exceedance in June, he has not
seen that notice yet but believes that was part of startup and was to be waived in that regard.Said he talked
with Jeff and also Sergei.
Thanks
G. Landon Davidson, P.G.
NCDENR-Division of Water Resources
Water Quality Regional Operations Section
Regional Supervisor-Asheville Regional Office
2090 U.S. Hwy.70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: lando n.davidson@ ncden r.gov
website: www.ncwaterguality.org
Notice:Per Executive Order No. 150,all emails sent to and from this account are subject to the North Carolina Public Records Law
and may be disclosed to third parties.
i

evergreen.* Canton Office
packaging 175 Moin Sireei• Conton, NC 28716
October 1, 2014 NMM#61-14
CERTIFIED MAIL FIREICEIVED
Return Receipt Requested >�fies umn
7099 3220 0007 03714576
Mrs. Laura Herbert 6 2014
Land Quality Supervisor, Asheville Regional Office
North Carolina Department of Energy, Minerals emmy Re*nw owm%m
& Land Resources
2090 U.S. Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton, Haywood County,North Carolina
Stormwater Release 5-day Submittal 9/25/2014
NPDES Permit: NCS000105
Dear Mrs. Herbert:
This is the 5-day written submission for the storm water release reported to NCDEMLR on
September 26,2014. In the early morning of the 25a',one of the wastewater treatment plant
operators noticed a water leak coming up through the ground beside the east gravel road between
the#1 &#2 primary clarifiers. We traced the path of the water to determine if it had reached a
storm drain. Once we confirmed the water's path a sample of the water was taken and brought
back to the lab for analysis. It was determined that the water had low levels of chlorine present.
At that time a call was placed to the Town of Canton Water Department to inform them of the
water line break.
The Town arrived on site promptly and turned the flow of water flow off to the W WTP
effectively stopping the loss. They then began excavation of the area. After location of the line,
a crack was observed in the city piping. The pipe was immediately repaired and put back in to
service. No other leaks were observed. We were unable to determine the amount of water lost to
the storm drain for this event but believe the impact, if any, was de minimus.
If you have any questions or comments, please feel free to contact me at your earliest
convenience.
IleverpacklcalEOHSISHAREIWater FilesWick` !Hater FilesIDWQ

NCDEMLR Page 2
Sincerely,
Nick McCracken
EHS&S Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCracken(&evpMack.com
cc:
Mr. Landon Davidson
Water Quality Supervisor,Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778

RECEIVED
evergreen' I 175Can M Office OlV s on a waver Resw,rcee
packaging 175 �;� sh�el. cash,, N� 2 ,b
OCT - 1 zoia
September 30, 2014 YVete owft9WRiAns
Asheville Reaior3l
CERTIFIED MAIL
Return Receipt Requested
7099 3220 0007 0371 4569
Landon Davidson
Asheville Regional Supervisor
Division of Water Resources
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill,Canton,Haywood County, North Carolina
Request for Total Suspended Solids and Effluent Color Comparison Testing
NPDES Permit: NC0000272
Dear Mr. Davidson:
On May 12, 2014 the Canton Mill received a Notice of Deficiency(NOD-2014-PC-0105)in
regards to the method by which effluent compliance samples are composited. During the
WWTP inspection on April 16,2014 it was observed by NCDWR staff that effluent samples
were being collected, flow proportionally, every 8 hours. These samples were then poured
together in equal parts to create the 24-hour composite compliance sample.
This method began many years ago prior to the Canton Modernization Project (CMP)which
began in 1990. Prior to the CMP the WWTP treated flows in the range of 60 MGD. Total
suspended solids were a major concern, thus the practice of checking the samples every eight
hours to remain compliant with our permit.
As directed by your request, we began comparison testing between the three, 8-hr composite
samples and a straight 24-hr composite sample. This comparison study was run for the required
60-day period.
Results of the study showed an average effluent color of 145.7 pcu for the three, 8-hr composite
sample versus a concentration of 144.0 pcu for the 24-hr composite sample. The difference
showing a lower average color concentration of 1.67 pcu for the 24-hr composite sample.
fresh by design J
\\cverpack\C71N\Shared\EOHS\Shere\Watcr Filcs\Nick's Water Files\DWR

NCDWR Page 2
Total suspended solids results showed an average concentration of 11.02 mg/1 for the three, 8-hr
composite sample while the 24-hr composite sample was 11.15 mg/l. The difference showing a
higher average solids concentration of.13637 mg/I for the 24-hr composite sample.
To date we have continued to use the 24-hr composite sample to report compliance with our
current NPDES permit. The 8-hr composite sample is still being used in the lab for process
control only. If you have any questions or comments,please feel free to contact us at your
earliest convenience.
Sincerely,
Nick McCracken
EHS Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCracken(&everpack.com
cc:
Mr. Jeff Menzel
Environmental Specialist, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778

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Color & TSS Comparison for SE 24 Hour Composites
3-8hr=24 24 hr 3-8hr=24 24 hr
Color Color TSS TSS
Date PCU PCU mg/I mg/I
7/1/2014 179 175 10 10
7/2/2014 173 171 10 11
7/3/2014 202 203 12 12
7/4/2014 196 198 30 10
7/5/2014 194 195 12 11
7/6/2014 98 99 12 12
7/7/2014 115 136 12 13
7/8/2014 124 135 12 12
7/9/2014 137 147 12 14
7/10/2014 165 152 14 16
7/11/2014 168 171 21 20
7/12/2014 155 149 18 16
7/13/2014 154 146 16 16
7/14/2014 138 139 12 15
7/15/2014 157 158 16 16
7/16/2014 159 164 16 18
7/17/2014 141 123 15 16
7/18/2014 152 142 14 14
7/19/2014 129 117 14 14
7/20/2014 127 130 18 19
7/21/2014 132 133 16 16
7/22/2014 131 122 16 18
7/23/2014 138 144 14 14
7/24/2014 152 152 12 12
Average 145.7 144.0 11.02 11.15
24 hour Color sample 1.6666 PCU's less than 3-8hr=24 sample
24 hour TSS sample 0.13637 mg/I greater than 3-8hr-24 sample

evergreen.* Canton Office
packaging 175 Main Street• Canton, NC 28716
September 30, 2014 NMM#59-14
CERTIFIED MAIL
Return Receipt Requested
7099 3220 0007 0371 4569
Landon Davidson
Asheville Regional Supervisor
Division of Water Resources
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton,Haywood County,North Carolina
Request for Total Suspended Solids and Effluent Color Comparison Testing
NPDES Permit: NC0000272
Dear Mr. Davidson:
On May 12, 2014 the Canton Mill received a Notice of Deficiency(NOD-2014-PC-0105) in
regards to the method by which effluent compliance samples are composited. During the
W WTP inspection on April 16, 2014 it was observed by NCDWR staff that effluent samples
were being collected, flow proportionally, every 8 hours. These samples were then poured
together in equal parts to create the 24-hour composite compliance sample.
This method began many years ago prior to the Canton Modernization Project(CMP) which
began in 1990. Prior to the CMP the WWTP treated flows in the range of 60 MGD. Total
suspended solids were a major concern, thus the practice of checking the samples every eight
hours to remain compliant with our permit.
As directed by your request, we began comparison testing between the three, 8-hr composite
samples and a straight 24-hr composite sample. This comparison study was run for the required
60-day period.
Results of the study showed an average effluent color of 145.7 pcu for the three, 8-hr composite
sample versus a concentration of 144.0 pen for the 24-hr composite sample. The difference
showing a lower average color concentration of 1.67 pcu for the 24-hr composite sample.
\\cwrpackC N\Shared\EOHS\Share\Wafer FilesWiWs Water Files\DWR

NCDWR Page 2
Total suspended solids results showed an average concentration of 11.02 mg/1 for the three, 8-hr
composite sample while the 24-hr composite sample was 11.15 mg/l. The difference showing a
higher average solids concentration of.13 63 7 mg/1 for the 24-hr composite sample.
To date we have continued to use the 24-hr composite sample to report compliance with our
current NPDES permit. The 8-hr composite sample is still being used in the lab for process
control only. If you have any questions or comments,please feel free to contact us at your
earliest convenience.
Sincerely, �.
Nick McCracken
EHS Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick McCracken(devgMack.com
cc:
Mr. Jeff Menzel
Environmental Specialist, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778

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Color & TSS Comparison for SE 24 Hour Composites
3-8hr--24 24 hr 3-8hr=24 24 hr
Color Color TSS TSS
Date PCU PCU mg/I mg/I
7/1/2014 179 175 10 10
7/2/2014 173 171 10 11
7/3/2014 202 203 12 12
7/4/2014 196 198 10 10
7/5/2014 194 195 12 11
7/6/2014 98 99 12 12
7/7/2014 115 136 12 13
7/8/2014 124 135 12 12
7/9/2014 137 147 12 14
7/10/2014 165 152 14 16
7/11/2014 168 171 21 20
7/12/2014 155 149 18 16
7/13/2014 154 146 sJ 16 16
7/14/2014 138 139 f 12 15
7/15/2014 157 158 t 16 16
7/16/2014 159 164 16 18
7/17/2014 141 123 15 16
7/18/2014 152 142 ; 14 14
7/19/2014 129 117 14 14
7/20/2014 127 130 18 19
7/21/2014 132 133 16 16
7/22/2014 131 122 16 18
7/23/2014 138 144 14 14
7/24/2014 152 152 12 12
Average 145.7 144.0 11.02 11.15
24 hour Color sample 1.6666 PCU's less than 3-8hr-24 sample
24 hour TSS sample 0.13637 mg/I greater than 3-8hr=24 sample

i �

evergreen .4 Canton Office
packaging 175 Main Street• Conlon, NC 28716
June 10,2014 NMM#06-14
CERTIFIED MAIL
Return Receipt Requested
7008 3230 0002 2595 6909 FAN
iVE.D
te8Landon Davidson
Asheville Regional Supervisor 1 2014Division of Water Resources
North Carolina Department of Environment
�crat+aneand Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton,Haywood County,North Carolina
Daily Maximum Fecal Coliform 6/5/2014
NPDES Permit: NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
6/5 at approximately 8:30 am,was picked up by courier and then taken to the laboratory for
analysis. We received notification from the lab on the afternoon of 6/6 by email. The result of
the analysis showed a value of>600 colonies per 100ml. The fecal coliform excursion on 6/5
was limited to that sample parameter and day. A phone call was placed to the NCDWR regional
office on 6/6.
Once we received the results from the laboratory all systems in the treatment facility were
checked. They were found to be operating correctly leading up to and during the time of sample.
On this day, we also sampled the Primary Effluent (PE), as well as, the Park Street Bridge
location (Upstream). The Upstream sample results appeared within the typical range observed
during prior sampling events (156 col/ 100ml). The PE sample was not what we expected.
Over the last month, fecal coliform values for the primary effluent samples have ranged from
2,000 col/ 100ml to >600,000 col / 100ml. On 6/5,the result for the PE sample was<20 col /
100m1.
fresh byrdes;gn
IleverpacklcalEDHSISHARDWater FilesWick's Water F'resIDWO ///

NCDWR Page 2
Mill personnel contacted the laboratory to discuss these results. The lab stated that the
Secondary Effluent (SE) sample had lots of floating material and was difficult to filter. The
Primary Effluent sample was clear and had no difficulty being set up for analysis. After our
conversation, we pulled the saved SE sample from the refrigerator and checked for these
observations. Our observation of the SE sample did not match what the laboratory had seen.
The SE sample was clear of prolific floating material. Interviews with plant personnel confirmed
that the PE sample during previous events possessed a greater amount of floating material when
compared to the secondary sample. A review of the mill's database showed that the SE sample
Total Suspended Solids (TSS)results for 6/5 to be 6 mg/l and the PE TSS results to be 70 mg/l.
On 6/6 another set of fecal samples was collected and sent out for analysis. The result of the
Secondary Effluent fecal coliform test from 6/6 was none detected.
Taking into account the fecal coliform results (both previous and current) for PE/SE, WWTP
personnel observations of sampled PE/SE and a review of the mill's laboratory database we
believe that the Secondary Effluent and Primary Effluent samples on 6/5 were swapped and that
the mill continued to be in compliance with permit limits at that time.
If you have any questions or comments,please feel free to contact us at your earliest
convenience.
Sincerely, /
G "
John Pryately
Laboratory Supervisor& W WTP ORC
Evergreen Packaging—Canton Mill
828-646-6720
iohn.pryately(a,everpack.com
cc:
Mr. Jeff Menzel
Environmental Specialist, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778

NCDENR F L
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvada, III
Governor Secretary
May 12, 2014
CERTIFIED MAIL 70121010 0002 1967 8456
RETURN RECEIPT REQUESTED
Mr. Dane Griswold
Blue Ridge Paper Products Inc.
P.O. Box 4000
Canton NC 28716
SUBJECT: NOTICE OF DEFICIENCY
NOD-2014-PC-0105
Canton Mill
Permit No: NC0000272
Haywood County
Dear Mr. Griswold:
Enclosed please find a copy of the completed Compliance Evaluation Inspection form for the inspection conducted on
April 16, 2014. The compliance evaluation inspection was conducted by Jeff Menzel and Landon Davidson of the
Asheville Regional Office. Mr.John Pryately and Mr. Nick McCracken were also present during the inspection.
During the inspection it was observed that the effluent composite sample was not being collected in accordance with
the standard conditions of NPDES permit NC0000272 and 15A NCAC 02B .0503(4). Currently, the facility runs process
control using flow proportional samples pulled every 8 hours to monitor any shifts or trends which may be occurring in
the effluent. These three, 8-hour flow proportional samples are then blended, with equal amounts from each, to
produce the composite samples which are used for final reporting. It is the blending of the three individual 8-hour
composite samples by equal amounts which is non-compliant.To achieve compliance, the permitee shall use a 24-hour
flow proportional composite sample for reporting requirements and use another sampler to run their 8-hour process
control checks.
The Division is requiring Blue Ridge Paper to begin collection of composite samples in accordance with the permit and
above-referenced rule within 14 days of receipt of this Notice. In an effort to evaluate any measurable differences
between your current sample collection methodology and the required methodology, samples are to be collected using
both methods for a period of 60 days. Samples collected using your current method (i.e.,8-hour intervals with blending
of equal volumes)are to be analyzed using only color and TSS. Samples collected using the approved methodology(refer
to permit and above-referenced rule) are to be analyzed for those parameters listed in your permit and reported in
accordance with your permit.
Within 90 days,the Division is requiring you to submit a narrative comparing and contrasting any observed differences
between the two data sets.Statistical methods are recommended in this evaluation. If Blue Ridge Paper determines that
60 days of sampling is inadequate for comparative purposes or that alternate parameters in addition to color are
necessary, please provide an explanation and recommendation to the Division to this regard.
Water Quality Regional Operations—Asheville Regional Office
2090 U.S.Highway 70,Swannanoa,North Carolina 28778
Phone:828-29BA500 FAX:[phone]
Internet http:llportal.ncdenr.orglweblwglws
An Equal Opportunity 1 Affirmative Action Employer

Mr. Dane Griswold
May 12,2014
Page Two
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff have any
questions, please call Jeff Menzel or me at 828-296-4500.
Sincerely,
C�
G. Landon Davidson, P.G.
Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Enc.
cc:John 1 Pryately, ORC
Chet Chiles/Manager: Environment, Health &Safety
Nick McCracken EHS&S Water Supervisor
MSC 1617-Central Files-Basement
Asheville Files
G:\WR\WQ\Haywood\Wastewater\tndustrial\Blue Ridge Paper 00272W0D-2014-PC-0105.doc

United States Environmental Protection Agency Form Approved.
EPA Washington,D.C.20460' OMB No.2040-0057
.. -. ..._..__.. .._..,. .. Approval expires 8-31-98'•- .
Section A: National Data System Coding (i.e.,PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 I N I 2 151 31 NC0000272 j 11 121 14/04/16 117 101 r I 191 c 201 I
IJ Remarks LJ LJ
21I1111111IIIIIIIIIIIIIIII- IIIIIIIIIIIIIIIIIIIIIII6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA Reserved
67I 169 70 71 J 72LI 73 74 75 I I I 80
Section B: Facility Data Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number)
Canton Mill 01:00 PM 14/04/16 10/07/01
175 Main St Exit Time/Date Permit Expiration Dale
Canton NC 28716 04:00 PM 14/04/16 15/06/30
Names)of Onsite Representative(s)Ttles(syPhone and Fax Number(s) Other Facility Data
John J Pryately/ORCf828-646-6720/
Name,Address of Responsible OfficialMile/Phone and Fax Number
Dane Griswold, !// Contacted
Yes
Section C: Areas Evaluated During Inspection(Check only those areas evaluated)
Permit N Flow Measurement Operations&Maintenance E Self-Monitoring Program
Sludge Handling Disposal N Facility Site Review Effluent/Receiving Waters
Section D: Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s).and Signature(s)of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Jeff Menze"<( ARO WQ//828-2964500/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Dale
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.
Page# 1

NPOES yr/mo/day Inspection Type (cot.) 1
3I NC0000272 I11 12I 14/04/16 I17 18I^
Section D: Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
II
The Compliance Evaluation Inspection was conducted by Jeff Menzel and Landon Davidson of the Asheville
Regional Office. Mr. John Pryately and Mr. Nick McCracken were also present during the inspection.
This facility has three samplers at the outfall to collect samples for the extensive list of parameters required
by the permit.Information gathered during this inspection indicated a practice which should be corrected to
ensure a representative composite sample as defined by the standard conditions of NPDES permit
NC0000272 and 15A NCAC 02B .0503(4). Currently the facility runs process control using flow proportional
samples pulled every 8 hours to monitor any shifts or trends which may be occurring in the effluent. These
three, 8-hour flow proportional samples are then blended,with equal amounts from each, to achieve the 24
composite samples which are used for final reporting. It is the blending of three composite samples by equal
amounts which should be corrected.The permitee should be using a 24-hour flow proportional composite
sample for reporting requirements and use another sampler to run their 8-hour checks. The permit definition
for this type of flow proportional sampling is as follows;
PART I I
STANDARD CONDITIONS FOR NPDES PERMITS
Section A.
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100
mL in such a manner as to result in a total sample representative of the wastewater discharge during the
sample period.
Variable time/constant volume: a series of grab samples of equal volume collected over a 24 hour period
with the time intervals between samples determined by a preset number of gallons passing the sampling
point. Flow measurement between sample intervals shall be determined by use of a flow recorder and
totalizer, and the preset gallon interval between sample collection fixed at no greater than 1/24 of the
expected total daily flow at the treatment system. . - - - 1
The Division is requiring Blue Ridge Paper to immediately begin collection of 24-hour composite samples in
accordance with the permit and above-referenced rule. In an effort to evaluate any measurable differences
between your current sample collection methodology and the required methodology, samples are to be
collected using both methods for a period of 60 days. Samples collected using your current method (i Vie.,
8-hour intervals with blending of equal volumes)will be analyzed using only color and TSS. Samples
collected using the approved methodology(refer to permit and above-referenced rule)are to be analyzed
for those parameters listed in your permit and reported in accordance with your permit.
Within 90 days, the Division is requiring you to provide a narrative comparing and contrasting any observed
differences between the data sets. Statistical methods are recommended in this evaluation. If Blue Ridge
Paper determines that 60 days of sampling is inadequate for comparative purposes or believes additional
parameters are necessary, please provide an explanation and recommendation to the Division to this
regard.
Page# 2

Permit: NC0000272 Owner-Facility: Canton Mill
.-.Inspection.Date:. 0 411 612 01 4 .....__ Inspeptign Type,9gmpliance.Evaluation ,.•._..
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑ ❑
Does the facility analyze process control parameters,for ex:MLSS,MCRT,Settleable Solids,pH,DO,Sludge ■ ❑, ❑ ❑
Judge,and other that are applicable?
Comment:
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application? 01111 ❑
Is the facility as described in the permit? ■ ❑ ❑ ❑
#Are there any special conditions for the permit? ■ ❑ ❑ ❑
Is access to the plant site restricted to the general public? ■ ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? ■ ❑ ❑ ❑
Comment:
Effluent Pipe Yes No NA NE
Is right of way to the ouffall properly maintained? ■ Cl ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? ■ ❑ ❑ fl
If effluent (diffuser pipes are required) are they-operating properly? ■ ❑ ❑ ❑
Comment:
Bar Screens Yes No NA NE
Type of bar screen
a.Manual ❑
b.Mechanical ■
Are the bars adequately screening debris? ■ ❑ ❑ ❑
Is the screen free of excessive debris? ■ ❑ ❑ ❑
Is disposal of screening in compliance? ■ ❑ ❑ Cl
Is the unit in good condition? ■ ❑ ❑ ❑
Comment:
Aeration Basins Yes No NA NE
Mode of operation Ext.Air
Type of aeration system Surface
Is the basin free of dead spots? ■ ❑ ❑ ❑
Are surface aerators and mixers operational? ■ ❑ ❑
13
Page# 3

Permit: NC0000272 Owner-Facility: Canton Mill
--- _.. . Inspection Date:...04/16.12014 Inspection Type: Compliance.Evaluaflon _
Aeration Basins
Yes No NA NE
Are the diffusers operational? ■ ❑ ❑ Q
Is the foam the proper color for the treatment process? ■ ❑ ❑
LU
Does the foam cover less than 25%of the basin's surface? ■ ❑ ❑
01
Is the DO level acceptable? ❑ ❑ ❑
Is the DO level acceptable?(1.0 to 3.0 mg/I) ❑ ❑ ❑
Comment:
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater? ■ ❑ ❑
Is the site free of excessive buildup of solids in center well of circular clarifier? ■ ❑ ❑ Q
Are weirs level? f
■ ❑ ❑ ❑
Is the site free of weir blockage?
■ ❑ ❑ ❑
Is the site free of evidence of short-circuiting? ■ fl LiI
Is scum removal adequate? I
■ ❑ ❑
Is the site free of excessive floating sludge? I■ ❑ ❑
Is the drive unit operational? ■ 00
I
Is the return rate acceptable(low turbulence)? ❑ ❑ ❑
Is the overflow clear of excessive solids/pin floc? ■ ❑ fl Q
Is the sludge blanket level acceptable?(Approximately''/<of the sidewall depth) ❑ D ❑ M
Comment:
Influent Sampling
Yes No NA NE
#Is composite sampling flow proportional? ■ ❑ ❑ 0
Is sample collected above side streams?
Is proper volume collected?
■ ❑ ❑ '❑
Is the tubing clean? ■ ❑ ❑ fl
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees Celsius)? ■ ❑ ❑ ❑
Is sampling performed according to the permit?
■ ❑ ❑ ❑
Comment:
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional? ■ ❑ ❑ ❑
Is sample collected below all treatment units? ■ ❑ ❑ ❑
Page 4 4

Permit: NC0000272 Owner-Facility: Canton Mill
- -- ---Inspection Date:-0a176P-014 . .._... Inspection Type: Compliance Evaluation--
Effluent Sampling Yes No NA NE
Is proper volume collected? ❑ 0 ❑ ❑
Is the tubing clean? ■ ❑ ❑ ❑
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees Celsius)? 001111
Is the facility sampling performed as required by the permit(frequency,sampling type representative)? ❑ N ❑ ❑
Comment: This facility has three samplers at the outfall to collect samples for the
extensive list of parameters required by the permit. Information gathered during this
inspection indicated a practice which should be corrected to ensure a representative
composite sample as defined by the standard conditions of NPDES permit NC0000272
and 15A NCAC 02B .0503(4). Currently the facility runs process control using flow
proportional samples pulled every 8 hours to monitor any shifts or trends which may be
occurring in the effluent. These three, 8-hour flow proportional samples are then
blended , with equal amounts from each, to achieve the 24 composite samples which is
used for final reporting. It is the blending of three composite samples by equal amounts
which should be corrected. The permitee should be using a 24-hour flow proportional
composite sample for reporting requirements and use another sampler to run their
8-hour checks.
Page# 5

,.* Canton Office
evergreen
packaging 175 Main $creel • Conton, NC 28716
March 31, 2014 NMM #23-14
CERTIFIED MAIL
Return Receipt Requested RECEIVED
7099 3220 0007 0371 4460 ovks6mdWSWPASO"m"
North Carolina Department of Environment APR - 3 2014
and Natural Resources
Division of Water Resources
Water Quality Section water YRegt10
Asheville R tonal Office
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDES NO. NC0000272
Best Management Practices 2013 Annual Report
Blue Ridge Paper Products Inc. d/b/a Evergreen Packaging
Canton, NC
This letter report (two copies) is the 2013 summary of Best Management Practices (BMP) daily
monitoring for the Canton Mill. The report is required on or before March 31" of each year by
Special Condition A.(6.) Best Management Practices, Section EA and Section F.1, of the mill's
NPDES Permit No. NC0000272.
The BMP action levels established in accordance with permit requirements and in effect for 2013
are as follows:
Effective Dates: 1 Jan 2013— 31 Dec 2013
Total Influent (TI) Color —
Action Level daily monitoring result Action Required
1-Day Upper Action > 72,500 Ibs/day for one day Immediate investigation and documented
Level (UAL) corrective action
2-day Upper Action > 59,400 Ibs/day for two Investigation and documented corrective
Level (UAL) consecutive days action
2-day Lower Action > 55,400 Ibs/day for two Investigation and documentation
Level (LAL) consecutive days
Daily records of total influent color are maintained at the mill. These daily color data are
compared to BMP action levels every morning. Total influent color exceeded BMP action levels
Blue Ridge Paper Products Inc. dba Evergreen Packaging —Canton Mill
175 Main Street • PC Box 4000
Canton, North Carolina 28716 • 828-646-2000
\\everpack\CTN\Shared\EOHS\Share\Water FilesWick's Water Files\DWR\Annual Reports\2013 Annual BMP Letter.doc

1

31 Mar 2014,Page 2
on the dates outlined in the following table. A brief summary of information for these dates are
included as required by permit Condition A.(6.), Section EA. The permit-required BMP
investigation reports are maintained at the mill. None of the BMP action level days resulted in
disruption to the wastewater treatment plant. The Canton-Mill met all NPDES annual average
effluent limits during 2013.
Total Influent
Date(s) (TI) Color Action Level and Summary
28 - 30 Jan 65,110 Ibs/day 2-day UAL—Investigation and documented corrective
2013 62,150lbs/day action
65,5691bs/day
Cause and Corrective Action(s)=Non-BMP event. Influent
color was elevated from activities associated with a
scheduled outage for the lower end of the mill. No
corrective actions)taken.
13 & 14 Apr 84,979 Ibs/day 1-day UAL/2-day UAL—Investigation and documented
2013 58,011 Ibs/day corrective action
Cause and Corrective Action(s)—Non-BMP event. The
lower end of the mill was preparing fora month long
extended outage so that the#10 Recovery Furnace could
be rebuilt. This included taking the hardwood fiberline
down for a semi-annual outage. Elevated influent color
was associated with cyclone wash material generated
during the shutdown of#10.
The material was originally thought to be too dilute for -
processing and was released to the sewer. After a sample
at the WWTP, the material was diverted to the#1 spare
clarifier. The remaining material from the cyclone wash
was captured and processed through the recovery system.
The material in the #1 clarifier was batch treated with
polyamine and released back into the treatment process at
a non-disruptive rate. No corrective action(s)taken.
Blue Ridge Paper Products Inc. dba Evergreen Packaging—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpaoklCTHlSharedlEOHSISharelWater FilesWick's Water FileslDWRl9nnual Reporfs12013 Annual BMP Letter.doc

31 Mar 2014,Page 3
Total Influent
Date(s) (TI) Color Action Level and Summary
19 & 20 Apr 57,823 Ibs/day 2-day UAL—Investigation and documented corrective
2013 60,362lbs/day action
Cause and Corrective Action(s)—Non-BMP event. During
this time, outage activities continue for the#10 Recovery
Furnace rebuild. This includes the periodic release of
elevated.pH material from various tanks in the mill. The
increased load in elevated pH material is thought to have
caused a sewer generated color effect in the influent.
Also, during this time the pine fiberline MRP system has
been down for maintenance. It is often observed that
influent color is elevated during periods when this system is
not operating. No corrective action(s)taken.
I
Blue Ridge Paper Products Inc. dba Evergreen Packaging—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 287.16 • 828-646-2000.
IleverpacklCTNlShareolEOHSISharelWater ResWick's Water ResIDWRVlnnual Reports=13 Annual BMP Lehecdoc

31 Mar 2014,Page 4
Total.Influent
Date(s) (TI) Color Action Level and Summary
2 -6 Jul 2013 89,830 Ibs/day 1-day UAL/2-day UAL— Investigation and documented
55,475 Ibs/day corrective action
55,411 Ibs/day
63,390 Ibs/day Cause and Corrective Action(s)—Non-BMP event. On the
57,184 Ibs/day evening of 7/2, the#11- Recovery Furnace was performing
a scheduled cyclone wash. During the maintenance
operation, an unmetered amount of elevated color material
reached the mill sewer system. This loss of material was in
short succession and did not offer an opportunity to capture
the material in the spare clarifier at the WWTP.
After the May outage, the fiber loss at the WWTP from the
acid sewer was elevated. Previous observed periods of
elevated fiber loss to the WWTP from the acid sewer can
create adverse conditions in the secondary clarifiers. In
order to combat these potential conditions, the acid sewer
was valved into the main mill sewer. This typically will
create elevated influent color numbers because of the
phenomena known as sewer generated color. During 7/2 &
7/3, the dregs filter from the green liquor system ran over to
the sewer for approximately 48 hours. This loss supports
the elevated primary effluent numbers at that time.
On the#12 paper machine there was an extended order of
Sunkraft Brown paper that required the use of yellow dye
after the outage. This dye cannot be treated and has
shown to increase influent and effluent color numbers
because of the wavelength at which it reflects light.
The pulp mill's MRP system was also having issues with
runability during this time. Although process trends show
more uptime, the process on the whole was up and down.
Weather also played a factor in the increased color load to
the WWTP. Recent rainfall events around the mill elevated
the flow into the treatment plant. When looking at the mass
balance equation, the higher flow numbers are what led to
the action levels being exceeded. The influent color
concentrations were, at times, elevated but by using a more
typical flow input BMP action levels were not exceeded for
this entire period. No corrective action(s)taken.
Blue Ridge Paper Products Inc. dba Evergreen Packaging—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpacklCTWhamdLcCHSISharel Water FilesWick's Water FilesIDWRI4nnual Reports12013 Annual BMP Letter.doc

1

31 Mar 2014,Page 5
Total Influent
Date(s) (TI) Color Action Level and Summary
5 - 7 Nov 2013 61,199 Ibs/day 2-day UAL— Investigation and documented corrective
58,492lbs/day action
60,543 lbs/day
Cause and Corrective Action(s)—Non-BMP event.
Leading up to the scheduled outage of the#2 fiberline and
#11 Recovery Furnace, the Sample Tank at Causticizing
overran for a short period of time contributing elevated pH
material to the mill sewer system. Also, the MRP system
on the#2 fiberline was bypassing due to tears in the fiber
strainer resulting in the main flow of filtrate not being able to
be screened.
Once the outage began on 11/6, the#11 Smelt Dissolving
Tank was released to the sewer, contributing elevated pH
material. This material was too dilute for processing and
had to be purged. The North Mud Washer also overran at
this time, contributing additional elevated pH material. This
was done in order to clean up the lime mud prior to entering
the kilns.
On 11/7, after restart, the MRP system bypassed the
majority of the day until the fiberline was able to run steady
and process instability taken out. In addition, the hardwood
Eo filtrate was elevated due to carryover from brownstock
washing. No corrective action(s)taken.
Blue Ridge Paper Products Inc. dba Evergreen Packaging—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpacklCTMSharecAEOHSISharel Water FilesWick's Water ResIDWROnnual Reports12013 Annual BMP Letter doc

31 Mar 2014,Page 6
Total Influent
Date(s) (TI) Color Action Level and Summary
28 &29 Nov 58,280 Ibs/day 2-day/ 1-day UAL— Investigation and documented
2013 74,953 Ibs/day corrective action
Cause and Corrective Actions— BMP event. On
Wednesday 11/27, the pine fiberline secondary screen
began flushing frequently. Operators swapped to the swing
screen and used it as the secondary in the system to
prevent interruption. The secondary screen was found to
be plugged. The plug was cleared and a new basket was
put into service.
The morning of Thursday 11/28, the secondary screen was
put back into service but began flushing very frequently
again after a short period of time. The quaternary screen
then plugged and overflowed the quaternary screen feed
tank to the sewer for approximately 20 minutes.
That same evening, around midnight, the secondary screen
plugged again. Operators attempted to bring the swing
screen online but had difficulty. The pine fiberline then
went down along with the screen room. This resulted in all
screen feed tanks overflowing to the mill sewer. After
repairs were made to the secondary screen, the fiberline
was brought back up to a steady state.
Corrective actions included pulling, cleaning &jetting the
pine secondary screen basket,jetting the line to the tertiary ,
screen tank, replacing the rejects control valve and
changing the DP cell. All corrective action have been
completed.
Please contact us if you have questions regarding this information.
Blue Ridge Paper Products Inc. dba Evergreen Packaging—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpacklCTMSharechEOHSISharelWater ResWick's Wafer ResIDWRIAnnual Reports12013 Annual BMP Letter doc

31 Mar 2014,Page 7
Sincerely
(,\/�/,'
Nick McCracken
EHS Water Supervisor
Evergreen Packaging—Canton Mill
[e-mail]
cc:
Mr. Landon Davidson
DWR Regional Supervisor,Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2000 U.S. Highway 70
Swannanoa,NC 28778
C. File—Water
BMP Notebook
Blue Ridge Paper Products Inc. dba Evergreen Packaging—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpacklCTMSharedlEOHSISharelWater FllesWicka Water ResIMM4nnual ReportsT013 Annual BMI Letter.doc

evergreen Canton Office
packaging 175 Moin Street• Canton, NC 28716
June 23, 2014 NMM#31-14
CERTIFIED MAIL
Return Receipt Requested
7099 3220 0007 0371 4507 �'_ _ gas
Laura Herbert JUN 25 2014
Regional Engineer '
Division of Energy, Mineral & Land Resources—Land Quality Section
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton,Haywood County,North Carolina
Storm Water Hardwood Chip Sump Overflow 6/18/2014
NPDES Permit: NCS000105
Dear Mrs. Herbert:
Per your request and requirement by the mill's NPDES storm water permit,this is the 5-day
written submission for the storm water release reported to NCDEMLR. On Wednesday,June
18f,the Canton area experienced a severe thunderstorm accompanied by heavy rainfall. The
amount of rainfall received overwhelmed the hardwood chip sump, which resulted in an
overflow of collected storm water to the Pigeon River.
The hardwood chip sump system is designed to collect storm water that falls onto the hardwood
chip pile, as well as,the surrounding area and transfer it to the pine chip sump. This water is
then pumped to the low lift of the wastewater treatment facility for processing. During the rain
event,both hardwood sump pumps were functioning as designed and did not experience any
mechanical and/or electrical interruptions. The amount of rain water collected was more than the
capacity of the pumps.
The rain began around 1:45 PM and lasted until approximately 3:00 PM. The storm deposited
rainfall in the amount of 1.63 inches. The river level rose from 99 MGD to a peak of—152 MGD
during that time.
lleverpaMklcatEOHSISHAREI Water FilesWtck's Water FilesOWR

1

NCDEMLR Page 2
If you have any questions or comments, please feel free to contact us at your earliest
convenience.
Sincerely,
Nick McCracken
Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCracken( evemack.com
cc:
Landon Davidson
Asheville Regional Supervisor
Division of Water Resources
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
C. File—Water Notebook

Canton Office
evergreen,*
packaging 175 Main Street• Canton, NC 28716
NMM #38-14
June 30,2014 CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 4521
Landon Davidson
Regional Supervisor
Division of Water Resources
North Carolina Department of Environment and Natural Resources
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa,North Carolina 28778
Re: Annual Progress Report on Color
NPDES Permit No.NC0000272
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill
Dear Mr.Davidson—
Enclosed is the Annual Progress Report on Color required by Part I A.(8.)item 8 of the May 26,2010
NPDES permit. This report covers the fourth year of the permit(July 2013 through June 2014).
Very truly yours,
BLUE RIDGE PAPER PRODUCTS INC.
DOING BUSINESS AS EVERGREEN PACKAGING
By:
140,
JUL
1.
Nick McCracken
Water Compliance Coordinator
828-646-2874
nick.mccrackenAeveWack.com
Enclosure: July 2014 Annual Progress Report on Color
cc: NC DWR—Complex NPDES Permitting Unit,Raleigh
Billy Clarke,Roberts and Stevens
Internal distribution
EOHS\Share\Water\Color Reports 2010 Print

July 2014 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
I: Introduction
Part I A.(8.) item 8 of the May 2010 NPDES permit states — The facility will provide
annual progress reports to the Division on the color reduction efforts. This report fulfills
the requirement of Part I A.(8.) item 8 for the fourth year of the permit , July 2013
through June 2014, with emphasis on the mill's Best Management Practices (BMP)
program refinements.
Color-related reports previously submitted to the NC Division of Water Quality (DWQ)
under terms of the May 2010 NPDES permit include the following:
o July 2011 Annual Progress Report on Color[Evergreen 2011]
o February 2012,Update to the Color Reduction Implementation Plan [Evergreen
2012a]
o July 2012 Annual Progress Report on Color [Evergreen 2012d]
o July 2013 Annual Progress Report on Color [Evergeeen 2013]
These reports are incorporated by reference.
II. Background
Levels of color in the wastewater effluent from the Canton Mill are among the best of
Kraft pulp and paper mills in the world [EKONO 2005,NCASI 2006]. This high level of
color performance is achieved by in-process controls and BMP's. The Canton Mill
continues to operate the controls and practices proven successful for color prevention.
Page 1

July 2014 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
These controls and practices go well beyond the requirements of the EPA Cluster Rule
for Pulp and Paper (40 'CFR 430, Subpart B). Many, such as the -Bleach Filtrate
Recycling ProcessTY, are unique to the Canton Mill.
The May 2010 NPDES permit includes a daily maximum effluent true color limit of
105,250 lbs per day. The permit also specifies a monthly average true color limit of
52,000 lbs per day and a current annual average (calendar year) true color limit of 38,020
lbs per day. The annual average color limit for the Canton Mill will change beginning
July 1, 2014. As it states in Part I A.(8.) item 4 in the permit, "Four years after the
permit effective date, the average annual discharge of true color for each-calendar year
shall not exceed 32,000—36,000 pounds per day". Compliance with these,effluent limits
requires significant management of mill operations related to color. Prevention of
wastewater effluent color is a priority for mill operations every day.
III. Color Performance
Figure 1 illustrates the color performance of the Canton Mill since 1997. Annual average
effluent true color•in Figure 1 is presented in units of 1000 lbs per day. The calculation
of effluent color as a daily mass (Ibs) is defined in Part I A.(8.) items 2 & 3 of the permit:
color (lbs/day) = effluent flow (mgd) x effluent true color (platinum cobalt units) x
8.34. Effluent true color is measured using NCASI method 253 (1971).
Page 2

July 2014 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No. NC0000272
Figure 1 - Annual Average Effluent Color
Evergreen Packaging Canton Mill, 1997 thru 2013
a
80
a
70 62
0 60
0
50 -- �-43- 43 q� 45 d0
40 39 37 36 38 36 35 3
0
u 30
20
10
W 0 -
0� O� 00 OO ON O� OO O� � OO O� OO OO NO �N �rL �fb
KO 'O �O O O O O O (0. O O O O O O O O
The best color performance for the Canton Mill occurs during normal, or full, production.
At full production,the internal recycling and recovery of process filtrates,pulping liquors
and other process wastewaters is balanced. Color materials are contained within the
Kraft pulping process at efficiency greater than 99 percent. Color performance is
affected by process variability. Color materials can be lost during startup and shutdown
associated with a process upset, production curtailment or unplanned outage. The Canton
Mill has an environmental and economic incentive to maintain process reliability and
operate at full production.
Effluent color performance in 2013 continued to be excellent. The increased outage
schedule for the lower end of the mill continues to help with reliability. The associated
Page 3

July 2014 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina-
NPDES Permit No.NC0000272
-shortened time between Recovery Boiler cyclone washes allowed pulp mill operations to
continue to run with reduced unscheduled downtime. These operational strategies and
improvements contributed to color performance in 2013.
IV. Color Proiects and Refinements to Best Management Practices
The Canton Mill has a standing Color Team that meets regularly to review color
performance. The Color Team members include managers; supervisors and engineers
involved with production, maintenance, wastewater treatment and regulatory affairs. The
Color Team's scope includes:
• Monitoring color performance and the effectiveness of mill systems to prevent
effluent color
• Identifying and tracking corrective actions related to Cluster Rule BMP color
events
• Planning and reviewing process trials related to effluent color
• Planning and reviewing the effectiveness of capital and expense projects related
to effluent color
• Reviewing production and wastewater treatment issues that may affect operating
reliability and effluent color.
The Color Team evaluates projects, trials and process initiatives. Not all are successful.
The July 2013 Color.Progress Report [Evergreen 2013] documented significant Color
Team activities between May 2006 and May 2013. Significant activities since 2010 are
Page 4

July 2014 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
outlined in Tables 1 and 2. Capital projects in Table 1 are identified by Capital
Improvement Project (CIP) number. Other projects were completed on operations and
maintenance expense. Direct spending on Color Team related projects, trials and
initiatives identified in Tables 1 and 2 during the period May 2010 through May 2014
exceeded $3.5 MM. These costs are in addition to the on-going cost to operate and
maintain color prevention systems at the Canton Mill.
Table,1
Color Team Capital and Maintenance Projects
2010 - Forward
Year Project Description and Cost Information for Capital Projects
2010 East Heavy/Tall Oil Sump transfer line repair. This was a proactive
measure to prevent color material losses from this transfer line. BMP
sustaining measure.
o Completed August 2010, cnsd*
Replaced decant line from Turpentine loading to 4A manhole. This was a
proactive measure to prevent losses from this transfer line. BMP sustaining
measure.
o Completed 2010
o CIP—315223
o Cost-$275,000
Repair and recoating of west side of Camp Branch compound. 'Project to
maintain integrity of spill containment. BMP sustaining measure.
o Completed 2010
o CIP—315588
o Cost- $235,000
Several black liquor transfer line replacements including East Heavy storage
tank and West GB Discharge. BMP sustaining measure.
o Completed 2010, cnsd*
Page 5

July 2014 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No. NC0000272
Table 1
Color Team Capital and Maintenance Projects
2010 - Forward
Year Project Description and Cost Information for Capital Projects
2010 Replaced conductivity and level switches in East Heavy compound with
new,more reliable type. BMP improvement.
o Completed 3Q 2010, cnsd*
Relocation of sewer conductivity meter below Digester Area sumps. BMP
optimization in this area.
o Completed November 2010, cnsd*
West Heavy Liquor(former Red Liquor Tank) shell replacement/repairs.
BMP sustaining measure.
o Completed May 2010
o CIP— 266446
o Cost—$265,000
Mini-Hoods on No. 11 Smelt Dissolving Tank(SMDT). Allows substitution
of weak wash for clean water in SMDT demister creating more process
demand for weak wash and reducing high pH material discharged to sewer.
Related to the weak wash purge strategy(Table 2) and TRW
Recommendations regarding prevention of sewer-generated color—high pH.
o Completed 3Q 2010, cnsd*
Installation of spray bar on the 5s' effect of the Swenson evaporator set.
Spray allows the 5 effect chevrons to be cleaned on the run reducing the
amount of carryover color in the condensate system during normal operation
between evaporator outages. Color material carry over from evaporators into
condensates is related to TRW Recommendations to prevent sewer-generated
color.
o Completed October 2010, cnsd*
North White Liquor Tank shell replacement/repairs. BMP sustaining
measure and project related to TRW Recommendations regarding prevention
of sewer-generated color—high pH white liquor.
o Completed Dee 2010
o CIP—322435
o Cost—$724,000
Page 6

July 2014 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No. NC0000272
Table 1
Color Team Capital and Maintenance Projects
2010 - Forward
Year Project Description and Cost Information for Capital Projects
2011 Process lines to allow front-end boil out of West GB evaporator set. Allows
more frequent, less intense evaporator cleaning. BMP improvement for
process reliability to avoid carryover of color material into condensate
systems. Reduces the volume of color material generated by evaporator boil
out during outages. Color material carry over from evaporators into
condensates is related to TRW Recommendations to prevent sewer-generated
color.
o Completed May 2011, cnsd•
Repaired drain valves on No. 2 and 3 Primary Clarifiers. Allows reliable
isolation of one of these larger volume clarifiers as the spare clarifier for
high color material diversion during semi-annual outages. BMP sustaining
measure.
o Completed March 2011, cnsd'
Pine Weak Liquor Tank shell replacement/repairs. BMP sustaining
measure.
o Completed May 2011
o CIP—331985
o Cost—$349,000
Installed soft start on motors for the hardwood weak black liquor transfer
pumps and hardwood blow tower dilution pumps. Project reduces pump start
water hammer in pipes containing black liquor and reduces risk of gasket
failure, valve failure and/or pipe hanger failure from water hammer pipe
movement. Project was identified by a water hammer valve failure in May
2011 that was contained within the process and did not reach the wastewater
plant.
o Completed May 2011 on hardwood blow tower dilution pumps
o Completed Jul 2011 on hardwood weak black transfer pumps
0 4 soft starts at $7540 each, project cost of$30,160 plus installation
cost on maintenance expense
Page 7

July 2014 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
Table 1
Color Team Capital and Maintenance Projects
2010 - Forward
Year Project Description and Cost Information for Capital Projects
2012 Installation of new Oramac shower bars on the East Decker at the Hardwood
Fiberline. These shower bars help improve washing efficiency and reduced
carry-over of sodium compounds into the bleach plant,which in turn, will
reduce D 1 stage C102 demand and effluent color from the bleach plant.
o Completed April 2012
o Cost-440,000
Replaced shower bars on hardwood East Decker with improved design
matching shower bars previously installed on hardwood brownstock
washers. These shower bars improve washing-and reduce carryover of color
materials into the bleach plant. Liebergott Recommendation.
o Completed during May 2012 hardwood semi-annual outage as part of
larger East Decker vat repair project
o CIP—358168
o Cost— $32,000 for shower bar portion of project
Replaced level controls on condensate flash tanks on the West GB
evaporator set. The new controls are more reliable and less prone to
plugging and false level indication that can cause color material carryover
into the combined condensate system,which contributes to sewer generated
color. Related to TRW Recommendations regarding prevention of sewer
generated color.
o Completed during May 2012 semi-annual outage
0 2 capillary level elements and isolation valves at$9500 each,project
cost of$ 29,000 including installation on maintenance expense
West GB Skim Tank cleaning and repair of leaks. BMP sustaining measures.
o Completed July 2012
o Cost- $125,000
West Heavy Liquor Tank compound sealing and lining. BMP sustaining
measure.
o . Completed August 2012
o . Cost- $150,000
Page 8

July 2014 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
Table 1
Color Team Capital and Maintenance Projects
2010 -Forward
Year Project Description and Cost Information for Capital Projects
2012 Replacement of floor drain piping in Hardwood fiberline. Floor drains carry
spill material directly to the Hardwood Spill Tank. This replacement
minimized losses to the mill sewer system.
o Completed Fall 2012, cnsd*
Sealing and lining of the West Unoxidized Black Liquor compound. BMP
sustaining measure to reduce potential leakage of high pH material and to
reinstate the integrity of the containment and sump.
o Completed August 2012
Cost-$150,000
West GB Feed Tank cleaning and repair of leaks. BMP sustaining measures.
o Completed September 2012
o' Cost- $75,000
Replacement of floor drains on#10 Recovery Boiler. BMP sustaining
measure.
o Completed October 2012
o Cost- $150,000
Wash Water line replacement (phase In. Project identified to improve line
integrity and prevent potential elevated color losses from reaching the mill
sewer system.
o Completed December 2012
o CIP - 371577
o Cost- $99,333
2013 Relocation of#5B Sewer conductivity meter and sampler. BMP
improvement measure related to TRW Recommendations to further improve
leak detection and process monitoring.
o Completed January 2013, cnsd*
South Green Liquor Clarifier shell replacement/repairs. BMP sustaining
measure and project related to TRW Recommendations regarding prevention
of sewer-generated color—high pH green liquor.
o Completed February 2013
o CIP - 370243
o Cost- $581,442
Page 9

July 2014 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
Table 1
Color Team Capital and Maintenance Projects
2010 - Forward
Year Project Description and Cost Information for Capital Projects
2013 Installation of an additional u-drain located on the north side of the
Hardwood Blow Tower. This drain will allow the capture and redirection of
weak black liquor material from around the blow tower to the mill sump
system.
o Completed March 2013
o Cost- $36,641
West Green Liquor Clarifier shell replacement/repairs. BMP sustaining
measure and project related to TRW Recommendations regarding prevention
of sewer-generated color—high pH green liquor.
o Completed March 2013
o CIP - 370243
o Cost- $122,000
Installation of new Oramac shower bars on the West Decker at the
Hardwood Fiberline. These shower bars help improve washing efficiency
and reduced carry-over of sodium compounds into the bleach plant, which in
turn,will reduce Dl stage C102 demand and effluent color from the bleach
plant.
o Completed April 2013
o Cost--$40,000
West White Liquor Storage Tank shell replacement/repairs. BMP
sustaining measure and project related to TRW Recommendations regarding
prevention of sewer-generated color—high pH white liquor.
o Completed April 2013
o Cost- $122,000
West GB 2Id Effect pump upgrade. Obsolete pump replaced with different
style to increase reliability and reduce downtime which in some cases can be
attributed to increase color loading to the mill sewer system.
o Completed April 2013
o Cost= $72,869
Page 10

July 2014 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
Table 1
Color Team Capital and Maintenance Projects
2010 - Forward
Year Project Description and Cost Information for Capital Projects
2013 Mini-Hoods on No. 10 Smelt Dissolving Tank(SMDT). Allows substitution
of weak,wash for clean water in SMDT demister creating more process
demand for weak wash and reducing high pH material discharged to sewer.
Related to the weak wash purge strategy(Table 2) and TRW
Recommendations regarding prevention of sewer-generated color—high pH.
o Completed May 2013, cnsd*
2014 Curbing at#10 Recovery Boiler sewer sump gate. BMP measure designed to
prevent black liquor material from going around sewer gate and to be
directed to sump.
o Completed March 2014
o Cost-$15,000
West GB Evaporator capillary level elements and isolation valves. Reduces
the amount of carryover to the combined condensate tank and potential
sewer generated color.
o Completed April 2014
o Cost- $29,000
West GB Evaporator black liquor piping replacement from product liquor
flash tank back to the 3`d effect. BMP sustaining measure.
o Completed April 2014, csnd*
North Oxidizer feed piping upgrade to stainless steel. BMP sustaining
measure.
o Completed April 2014, esnd*
Floor drain replacement and material upgrade on#11 Recovery Boiler. This
piping carries spill material to the mill sump system minimizing losses. BMP
sustaining measure.
o Completed April 2014
o Cost- $150,000
Causticizing Sample Box piping upgrade. Reduced frequency of plugging.
and for white and green liquors to enter the mill sewer system causing sewer
generated color.
o Completed May 2014, cnsd*
Page 11

July 2014 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
Table 1
Color Team Capital and Maintenance Projects
2010 - Forward
Year Project Description and Cost Information for Capital Projects
2014 Black liquor transfer piping replacements around West Unoxidation and East
Unoxidation storage tanks. BMP sustaining measure.
o Completed June 2014, cnsd*
*cnsd—cost not separately determined, completed on operations and
maintenance expense
Table 2
Color Team BMP Refinements, Trials and Process Improvements
2010 forward
Years Refinement,Trial and/or Improvement
2010 Weak wash purge strategy to minimize potential sewer-generated color
on-going during process upset, outage or reduced pulp mill production when demand
for weak wash is out of balance with supply in causticizing.
2011 When both fiberlines are down, process contents of one of the spill tanks
through the evaporators to free up spill tank volume before starting up. Was
used successfully during and after the May,2011 cold mill outage to
minimize loss of dilute color material to the W WTP.
2011 Alternative polymer study by Chemtreat at W WTP. Compared against
current polyamine polymer in use for batch treatment of black color
materials.No difference in color performance. Existing batch treatment
olyamine polymer was retained.
201'1 West GB Evaporator partial boil out strategy. Ability to clean process during
on-going short outages as opportunity arises. Improves process reliability and reduces
volume of color material to recover during outages.
2012 Reliability focus - 7 to 8 week planned maintenance outage cycle for
on-going recovery,furnaces and fiberlines. Prior to 2012,planned outage cycle was 10
to 12 weeks and additional unplanned outages were often necessary. Mill
experience is that more frequent planned outages result in more reliable
process operation between outages and lower color. Color associated with
planned outages is also generally lower than color associated with an
unplanned outage.
Page 12

July 2014 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
Table 2
Color Team BMP Refinements, Trials and Process Improvements
2010 forward
Years Refinement, Trial and/or Improvement
2012 Color prevention MOC/pre-task review process for outage and maintenance
on-going tasks associated with black liquor. This is in addition to the permit-required
review of modifications to systems managing black liquor, turpentine and
soap.
In 2013 and in 2014, the Color Team has focused on the reliability of the Recovery
Furnaces and Fiberlines. When the mill experiences a process upset, and in particular an
upset requiring an unplanned outage to correct, effluent color is not as good. The team
targeted planned maintenance outages every eight weeks. The frequency of outage work
allows mill operations to stay ahead of potential issues that could necessitate an
unplanned outage. Fewer unplanned outages and shorter periods of downtime help the
mill maintain steady operations leading to better color performance.
V. TRW Recommendations
The Canton Mill continues to evaluate and improve existing BMPs and reduce
opportunities for sewer generated color,which historically, has been associated with high
alkali material mixing with acidic materials.
During the spring semi-annual in 2014, the West GB evaporator set replaced two level
control elements with new controls and valves on the condensate flash tanks. These
Page 13

July 2014 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
controls increased reliability and reduced plugging and/or false readings that can cause
black liquor material carryover to the combined condensate system. Other improvements
include the larger diameter and upgraded piping from the causticizing sample box. The
sample box contains green and white liquors and weak wash material that is collected.for
process analysis. In previous times,the smaller diameter piping had the potential to plug
causing an overflow to the mill sewer system. Prevention of this reduces the potential for
sewer generated color.
BMP sustaining measures allow the mill to strengthen and enhance its color prevention
program. This year the mill replaced many transfer and feed lines to various tanks in the .
mill. Some of these replacements included upgrades to the material design of the existing
piping. This will promote longevity and reliability going forward. Another project was
the curbing placed around the#10 Recovery Boiler sewer sump gate. In the past, some
elevated color material would flow around this gate and enter the mill sewer system
bypassing the sump. Although, the quantity and frequency was limited, we were still
able to determine that a small portion of material was reaching the mill sewer system.
Placement of this curbing will prevent any future releases from taking the same path.
Page 14

July 2014 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
VI. Summary
Prevention of effluent color is a priority for Canton Mill operations every day. The
Canton Mill's focus on process reliability and uptime has resulted in excellent annual
color performance. The Canton Mill will continue to utilize the processes and practices
proven successful for wastewater effluent color prevention.
Page 15

July 2014 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
REFERENCES
EKONO 2005 —Environmental Performance, Regulations and Technologies in the Pulp
and Paper Industry, EKONO Inc, August 2005.
Evergreen 2011 — Annual Progress Report on Color, submitted to NC DWQ to meet
requirements of Part I A.(8) item 8 of the May 2010 NPDES Permit, Evergreen
Packaging,July 1,2011.
Evergreen 2012a -February 2012 Update to the Color Reduction Implementation Plan,
submitted to NC DWQ to meet requirements of Part I A.(8) item 11 of the May 2010
NPDES Permit,Evergreen Packaging, February 20,2012.
Evergreen 2012b — Response to EPA Comments dated 22 March 2012 concerning
February 2012 Update to the Color Reduction Implementation Plan, letter to NC DWQ
Complex NPDES Permitting Unit from Evergreen Packaging dated April 10, 2012.
Evergreen 2012c — April 2012 Color Perception Study Plan and Response to EPA
Comments dated 28 March 2012 concerning the March 2012 Revised Color Perception
Study Plan, submitted to NC DWQ Complex NPDES Permitting Unit by Evergreen
Packaging on April 17,2012.
Evergreen 2012d — Annual Progress Report on Color, submitted to NC DWQ to meet
requirements of Part I A.(8) item 8 of the May 2010 NPDES Permit, Evergreen
Packaging,July 1, 2012.
Evergreen 2013 — Annual Progress Report on Color, submitted to NC DWR to meet
requirements of Part I A.(8) item '8 of the May 2010 NPDES Permit, Evergreen
Packaging, July 1, 2013.
NC OAH 2O12 — Partial Settlement Agreement and Joint Stipulation to Stay, 10 EHR
4341 and 10 EHR 4982, North Carolina Office of Administrative Hearings, April 24,
2012. .
NCASI 2006—Technical Bulletin No. 919—Review of Color Control Technologies and
Their Applicability to Modem Kraft Pulp and Paper Mill, National Council.for Air and
Stream Improvement,August 2006.
Page 16

Canton Office
evergreen. 0 175 Main Street• Conlon, NC 28716
packaging
RECEIVED
pvision of h`rafar Resource•
30 December 2014 DEC 3 i
Mr. Tom Belnick watcn OunRy Rentonal opere ons
Division of Water Resources _ nsne,-nor: rrrP
North Carolina Department of Environment and Natural Resources
WQ Permitting Section-NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Application for Permit Renewal
NPDES Permit NC 0000272
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill
Haywood County
Dear Mr. Belnick:
The subject NPDES permit expires on June 30, 2015. In accordance with Part II, Section B,
Condition 10 of the permit, Blue Ridge Paper Products Inc. requests renewal of the NPDES
permit for our mill located in Canton,North Carolina. We are submitting one original and two
copies of the signed permit application, including EPA Form 1 and Form 2C with attachments, to
you and additional copies to the Asheville Regional Office.
Evergreen Packaging is providing the following information regarding its NPDES permit.
• The Dioxin Fish Tissue Monitoring program required in Paragraph A(9.)of the permit
was completed, with the final sampling results being submitted to NCDENR on February
2, 2015. Evergreen Packaging requests that the fish tissue monitoring requirements be
removed from the renewed permit.
• The Balanced and Indigenous Species report was submitted to NCDENR in January,
2013.
• Trichlorophenol and pentachlorophenol are not used on site. Evergreen Packaging
requests that the monitoring requirements for these chlorophenolic biocides continue to
be waived for Outfall 001.
Under separate cover, Evergreen Packaging is submitting a Request for Termination of the
variance from the North Carolina Water Quality Standard for color with supporting information.

Mr.Tom Belnick, NC DENR DWQ
• 30 December 2014, Page 2
Please contact us if you have any questions concerning the permit renewal application.
Sincerely,
Chet Chiles Dane Griswold
Manager— Environmental Health & Safety General Manager— Canton/ Waynesville
[phone] [phone]
chet.chilesC everpack.com dane.griswold0everpack.com
Enclosure:
r1c:
Mr. Landon Davidson
North Carolina Department of Environment and Natural Resources
Asheville Regional Office
Dr. Sergei Chernikov
North Carolina Department of Environment and Natural Resources
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617

Please print or type In the unshaded areas only. Form Approved.OMB No.2040-0086.
FORM U.S.ENVIRONMENTAL PROTECTION AGENCY I.EPA I.D.NUMBER
1 111MpA GENERAL INFORMATION s c
Consolidated Permits Program F NC0000272 D
GENERAL (Read the"GenemlInstructions"before starting.)
LABEL ITEMS GENERAL INSTRUCTIONS
d a pried sad label has been provided,carefully:
aifu It in the
designated space.Review the Information rarefuily;H any of it
1. EPA I.D.NUMBER is kncortecL was through it and emerge=act data in the
appropriate fiIWn area below.Also.H any of the prepdnled data
Is absent (the area to the left of the label space lists the
III: FACILITY NAME PLEASEPLACE LABEL IN THIS SPACE information that should appen),please provide it in the proper
- - fill4n areas)below.If the label Is complete and correct,you
V. FACILITY MAILING need net complete Items I,III,V.and W(except vlA which
ADDRESS must be completed regardless).Complete all items H no label
has been provided.Refer to the instructions for detailed Item
VI. FACILITY LOCATION descriptors and for me legal autho dragon under which this
_ _ _ data is selected.
11.POLLUTANT CHARACTERISTICS
INSTRUCTIONS:Complete A through J to determine whether you need to submit any permit application forms to the EPA If you answer*yes*to any questions,you must
submit this forth and the supplemental form listed in the parenthesis following the question.Mark'X"in the box in the third column if the supplemental forth is attached.If
you answer'no'to each question,you need not submit any of these forms.You may answer'no'g your activity is excluded from permit requirements;see Section C o1 the
instructions.See also,Section D of the Instructions for definitions of bold-faced terms.
Mark'R MM-r
SPECIFIC QUESTIONS YEs NO Arr RMEn Es SPECIFIC QUESTIONS v no AsioOW
A Is this facility a publicly owned treatment works which B.Does or will this facility (either existing or pmposed)
results in a discharge to waters of the U.S.?(FORM 2A) X Include a concentrated animal feeding operation or
aquatic animal production facility which results in a
,s +. is discharge to waters of the U.S.?(FORM 2B) +k e r
C.Is this a facility which currently results in discharges to Is this a proposed facility(otherthan those descdhedin A
D.
waters of the U.S.other than those described in A or B X X or B above)which will result in a discharge to waters of X
above?(FORM 2C)See page 3 of 27. a a 24 the U.S.?(FORM 2D) a e n
E.Does or will this facility treat, store, or dispose of F. Do you or will you inject at this facility industrial or
hazardous wastes?(FORM 3) X municipal effluent below the lowermost stratum X
containing, within one quarter mile of the well bare,
m e as underground sources of drinking water?(FORM 4) e a a
G.Do you or will you.inject at this facility any produced water H.Do you or will you inject at this facility fluids for special
or other fluids which are brought to the surface in processes such as mining of sulfur by the Frasch process,
connection with conventional oil or natural gas production. X solution mining of minerals, in s'Im combustion of fossil X
inject fluids used for enhanced recovery of oil or natural fuel,or recovery of geothermal energy?(FORM 4)
gas, or inject fluids for storage of liquid hydrocarbons?
(FORM 4) m e e
I. Is this facility a proposed stationary source which is one J. Is this facility a proposed stationary source which is
of the 28 Industrial categories listed.in the instructions and �/ NOT one of the 28 industrial categories listed in the
which will potentially emit 100 tons per year of any air X instructions and which will potentially emit 25o tons per X
pollutant regulated under the Clean Air Act and may affect year of any air pollutant regulated under the Clean Air Act
or be located In an attainment area?(FORM 5) o e+ c and may affect or be located in an attainment area? n
(FORM 5)
Ill. NAME OF FACILITY
c
1 3lgP I B ue Ridge Paper Products I clLal Evergreen Packaging
e
N. FACILITYCONTACT
A NAME&TITLE(lost,first,&tide) B.PHONE(area code&no.)
c
2 C e C. C i es, HS& Manager
V.FACILTY MAILING ADDRESS
A.STREET OR P.O.BOX
c
3 P.O. ox 4000
u,s ,s B.CITY OR TOWN C.STATE D.ZIP CODE
c
4 1 can o dC 2 716
o is w a a o e+
VI. FACILITY LOCATION
A STREET,ROUTE NO.OR OTHER SPECIFIC IDENTIFIER
g 1 S Main treet
+s m
B.COUNTY NAME
Haywood
m _
C.CITY OR TOWN D.STATE E.ZIP CODE 6 F.COUNTY CODE(jAsoam)
cii C n o C 2 716
EPA Forth 3510-1(8-90) CONTINUE ON REVERSE

CONTINUED FROM THE FRONT
VIL SIC CODES 4di i in orderof priority)
A.FIRST " B.SECOND
7 2621 (speeo)intee9rated Pulp Mill (specify)
B p
C.THIRD D.FOURTH
(sped) (sped)
7
Vill.OPERATOR INFORMATION
A NAME - B.Is the name listed in Item -
VIII-A also the
s Blue Ridge Paper Products tiba Evergreen Packaging ®YES O NO en
15 I6 65 80
C.-STATUS OF OPERATOR(Enter lheappropriare lerrerinro she answer bw.'if"Other,"spec.) ID.PHONE(area code&naJ
F=FEDERAL M=PUBLIC(other lhonfrderalorerate), P (spedfY)
S=STATE 0=OTHER(specify) q (828) 646-2381
P=PRIVATE si 1. m
E STREET OR P.O.BOX
1 5 Main• Street
m se
F.CITY OR TOWN - G.STATE I H.ZIP CODE I IX.gXO LAND
Is the facility located on Indian lands?
B Canton el Q
NC 28716 ❑YES -Ir7 NO
es
tl _ �] 51
X.EXISTING ENVIRONMENTAL PERMITS
A NPDES Trim vroS aceE D.PSDAIrEmkriam mPro sedSoums
1
g N NC0O00272 g p
s u
v B.UIC rtde &emion o Fluids E.OTHER s ci
c r c r i (specify)s u g See Attachment :Ful ist
n l s a m b m s
C.RCRA Harardow Wastes E.OTHER s ci
c r . c r (specIO)
9 R 1 9
n m 1 v n so IS v n a
XI.MAP
Atlech to this application a topogrephtc map of the area eldending to at least one mile beyond property boundaries.The map must show the outline of the facility,the
location of each of its ebsting and proposed Intake and discharge structures,each of its hazardous waste treatment storage,or disposal facilities,and each well where a
injects fluids underground.Include all springs,rivers,and other surface water bodies in the map area.See instructions for precise requirements.see Aaachment I,page 17 of27.
)(II.NATURE OF BUSINESS provide a brief descd "on
Canton Mill is an integrated bleached papergrade kraft pulp and paper manufacturing facility producing
paperboard and fine papers. The-applicable categorical effluent standards are 40 CPR 430 subpart B - Bleached
Papergrade Kraft and soda. - -
XIII.CERTIFICATION(see instructions)
l certify underpena/y,of law that I have personally examined and am familiar with the information submitted In this application and all attachments and that based on my
inquiry of those persons immediately responsible for oblaining the information contained in the application,I believe that the information is hue,accurate,and complete.I
am aware that them are significant penalties for submitting false isdmmation,including the possibifry offi endimpnsonment.
A NAME B OFFICIAL TITLE(ope orprinr) - B.SIGNATURE .�-��j.yn ho(d JC.DATESIGNED
Dane A. Griswold, General Manager
h'Ifti fv-rti5.dtvro r. 1213Q•1 4-
.COMMENTS FOR OFFICIAL USE ONLY
c -
C
IS 1
EPA Form 3510-1(8-90)

a
EPA I.D„NUMBER(rnpyfm.It..I fForm/) Form Approved.
OMB No.2040-0086.
Please print or type in the unshaded areas only. Approval expires 3J7-98.
FORM U.S.ENVIRONMENTAL PROTECTION AGENCY
APPLICATION FOR PERMIT TO DISCHARGE WASTEWATER
2C "EPA EXISTING MANUFACTURING,COMMERCIAL,MINING AND SILVICULTURE OPERATIONS
NPDES Consolidated Permits Program
1.OUTFALL LOCATION
For each outfall,list the latitude and longitude of its location to the nearest 15 seconds and the name of the receiving water.
A OUTFALL NUMBER B.LATITUDE C.LONGITUDE
(list) 1.DEG. F 2 MIN. 3.SEC. 1.DEG. 2 MIN. 3.SEC. D.RECEIVING WATER(name)
001 35 32 8 82 50 42 Pigeon River
IL FLOWS,SOURCES OF POLLUTION,AND TREATMENT TECHNOLOGIES
A Attach a line drawing showing the water flow through the facility.Indicate Sources of intake water,operations contributing wastewater to the effluent,and treatment units
labeled to Correspond to the more detailed descriptions in Item B.Construct a water balance on the line drawing by showing average flows between intakes,operations,
treatment units,and outfalls.If a water balance Cannot be determined(e.g.,for Certain mfning acAdfies),provide a pictorial description of the nature and amount o1 any
sources of water and any Collection or treatment measures.Sao a6chment II-A,page 19 of 27.
B. For each outfall,provide a description of:(1)All operations contributing wastewater to the effluent including process wastewater,sanitary wastewater,cooling water,
and storm water mnoB; (2)The average flow Contributed by each operation; and (3)The treatment received by the wastewater.Continue on additional sheets if
necessary.
1 OUT- 2.OPERATION(S)CONTRIBUTING FLOW 3.TREATMENT
FALL b.AVERAGE FLOW b.UST CODES FROM
NO.(list) a.OPERATION'(fist). (include vela) a.DESCRIPTION TABLE 2C-1
001 Average Storm Plater ,42 MGD based an 9/13 - 6/19 Grrc CEaaDer 2-M 5-0
Rainfall
Bar Sores=
1-T 2-D
2-If
001 Pulp will
13.5 MD
primary Clarifiers
3-D 5-0
5-C
001 Paper Mill 8,1 MGD saccndary Treatment 3-A
Secondary Clarifiers
1-u
001 steam a Power Generation 3.9 MGD Aeration tasted. 4-A
Oxygen injection capability at 0.9 a 2.2 miles
l[E
d..tream of discharge
Unmetered B MSacellaneaue
001 3.5 MGD
See Attachment 1I-B for details, page 20 of 27
001 Town of Canton 0.75 MGD vith West Canton
Sewer Baronets.
.See Attachment II-B for detail. See page 20 of 27
OFFICIAL USE ONLY(eJJluentgurdelinessab-mtegories)
EPA Form 3510-2C(8-90) PAGE 1 of 4 CONTINUE ON REVERSE

CONTINUED FROM THE FRONT
C.Except for stems nmoff,leaks,or spills,are any of the discharges described in Items II-A or B intermittent or seasonal?
❑YES(complete thefollowtng fable) m NO(go to Section Ill)
3.FREQUENCY 4.FLOW
a.DAYS PER B.TOTAL VOLUME
2.OPERATION($) WEEK b.MONTHS a.FLOW RATE(M.gd) (s"af,with vnir)
1.OUTFALL CONTRIBUTING FLOW (rpadfy PER YEAR ?.LONGTERM 2.MAxIMUM 1.LONGTERM 2.LWIMUM C.DURATION
NUMBER(/iu) (On) average) (epee awmge) AVERAGE DAILY AVERAGE DAILY
III.PRODUCTION
A Does an effluent guideline limitation promulgated by EPA under Section 304 of the Clean Water Act apply to your facility?
mYES(comple.1m.111-B) ❑NO(go to Secnon ly)B.Are the limitations in the applicable effluent guideline expressed in terms of production(or other measure of operation)?
©YES(romplem Item 111-0 ❑NO(go to Section 1k)
C.If you answered'yes'to Item III-B,list the quantity which represents an actual measurement of your level of production,expressed in the terms and units used in the
applicable effluent guideline,and indicate the affected ouffalls.
1.AVERAGE DAILY PRODUCTION
2.AFFECTED OUTFACES
a.QUANTITY PER DAY b.UNITS OF MEASURE c.OPERATION,PRODUCT,MATERIAL,ETC. (list ovefdllnambe.)
(tpecM
656 ADTBP Food grade bleached paperboard 001
791 ADTBP Bleached free sheet fine paper. 001
IV.IMPROVEMENTS
A Are you now required by any Federal, State or local authority to meet any implementation schedule for the construction, upgrading or operations of wastewater
treatment equipment or practices or any other environmental programs which may affect the discharges described in this application?This Includes,but is not limited to,
permit conditions,administrative or enforcement orders,enforcement compliance schedule letters,stipulations,court orders,and grant or loan condtions.
YES(romplem Nefollowing mble) ❑NO(go to Ire.IV-B)
1.IDENTIFICATION OF CONDITION, 2.AFFECTED OUTFALLS - 3.BRIEF DESCRIPTION OF PROJECT 4.FINAL COMPLIANCE DATE
AGREEMENT,ETC.
e.NO. b.SOURCE OF DISCHARGE a.REQUIRED b.PROJECTED
Special condition. in NPDBS 001 Pulp Mill on-going effluent color reductions N/A N/A
permit regarding color
reduction See A nual Progress Report on Color
Color Reduction Implementation Plan - Feb
2012
B. OPTIONAL: You may attach additional sheets describing any additional water pollution control programs (or other environmental projeds whch may aHecf your
dscharges)you now have underway or which you plan.Indicate whether each program is now underway or planned,and indicate your actual or planned schedules for
construction.
❑MARK-X-IF DESCRIPTION OF ADDITIONAL CONTROL PROGRAMS IS ATTACHED
EPA Form 351D-2C(8-90) PAGE 2 of 4 CONTINUE ON PAGE 3

EPA I.D.NUMBER(ropyjrom Item I ojForm I)
CONTINUED FROM PAGE 2
V.INTAKE AND EFFLUENT CHARACTERISTICS
A,B,&C: See instructions before proceeding—Complete one set of tables for each outfall—Annotate the oudall number in the space provided.
NOTE:Tables V-A,V-B,and V-C are included on separate sheets numbered V-1 through V-9.
D. Use the space below to list any of the pollutants listed in Table 2o-3 of the Instructions,which you know or have reason to believe is discharged or may be discharged
from any oudall.For every polutant you list,briefly describe the reasons you believe it to be present and report any analytical data in your possession.
1.POLLUTANT 2.SOURCE 1..POLLUTANT 2.SOURCE
VI.POTENTIAL DISCHARGES NOT COVERED BY ANALYSIS
Is any pollutant listed in Item V-C a substance or component of a substance which you currently use or manufacture as an intermediate or final product or byproduct?
❑YES(11sra11sueh pollutants below) NO(ga m Item VI-B)
EPA Form 3510-2C(9-90) PAGE 3 of 4 CONTINUE ON REVERSE

CONTINUED FROM THE FRONT
VII.BIOLOGICAL TOXICITY TESTING DATA
Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on a receiving water In
rotation to your discharge within the last 3 years?
©YES(Idenr f the rco(s)anddescnbe tbeirpurposn below) ❑NO(go to Secrlon V!I!)
See Attachment IV (page 25 of 27)
VIII.CONTRACT ANALYSIS INFORMATION
Were any of the analyses reported in Item V performed by a contract laboratory or consulting firm?'
®YES(Int the name,addrs.,a.dmleplime number of,ondpollutants analysed by, ❑NO(go to Section LY)
each such laboratory orflrm below)
A.NAME B.ADDRESS C.TELEPHONE b.POLLUTANTS ANALYZED
(area code&no.) (tst)
Pace Analytical 2325 Riverside Drive [phone] All 2C data
Asheville, NC 28804
Environmental Testing Solutions 351 Depot Street [phone] Toxicity testing and fecal
Asheville, NC 28801 coliform analysis
TestAmeriea 880 Riverside Parkway [phone] Dioxin in fish tissue and
West Sacramento, CA 95605 paperboard
DC CERTIFICATION
I cerbly ,underpene/ty oflaw Mat this document and all attachments were prepared undermy direction orsupervision in accordance with a system designed to assure that
qualified personnel prepedy gamer and evaluate the information submitted.Based on my inquiry of the person or persons who manage the system or those persons
directly responsible for gathering the Infomnation,the information submitted is,to the best ofmy knowledge and belief,true,accurate,and complete.1 am aware that Mom
are significant penalties forsubmitfing false information,inducing the possibility offine and imprisonment for knowing vialafions.
A.NAME&OFFICIAL TITLE(type orprint) B.PHONE NO.(area mde&no.)
Dane A. Griswold, General Manager
C.SIGNATURE ,(yrf$v.•e') D.DATE SIGNED
EPA Form 3510-2C(8-9D) PAGE 4 of 4

PLEASE PRINT OR TYPE IN THE UNSHADED AREAS ONLY.You may report some or all of this information EPA I.D.NUMBER(ropyjrom Item i ojForm 1)
on separate sheets(use the same fommi)Instead of completing these pages. NC0000272
SEE INSTRUCTIONS.
V.INTAKE AND EFFLUENT CHARACTERISTICS(continued/horn page 3 of Form 2-C)
OUTFALL NO.
oos
PART A-You must provide the results of at least one analysis for every pollutant in this table.Complete one table for each outfall.See instructions for additional details.
2.EFFLUENT 3.UNITS 4.INTAKE
(speck gblank) (opdona0
b.MAXIMUM 30 DAY VALUE c.LONG TERM AVRG.VALUE
a.MAXIMUM DAILY VALUE (Ijavallable) (l wadable a.LONG TERM
1.POLLUTANT (1) (1) j ) d.NO.OF a.CONCEN- AVERAGE VALUE
CONCENTRATION (2)MASS CONCENTRATION (2)MASS 1)CONCENTRATION b.NO.OF
(2 MASS ANALYSES TRATION b.MASS CONCENTRATION (2)MASS ANALYSER
a.Biochemical Oxygen 15.35 3,675 7.2 1,617 5.29 1,181 365 m 1 lbs da Demand(BOD) g/ / y
b.Chemical Oxygen 179 37,066 140 30,953 107.1 23,945 52 m 1 lbs da g/ / y Demand(COD)
(7D.Total Organic Carbon 76.9 16,867 76.9 16,867 1 mg/1 lbs/day
d.Total Suspended
Solids(7S.S) 49 11,438 15.8 3,691 12.3 2,744 365 mg/1 lbs/day
e.Ammonia(as 6.3 1,029 0.9 145 0.3 45.5 365 mg/1 lbs/day
VALUE VALUE VALUE - VALUE
fFlow 33.4 28.6 26.8 365 MGD
g.Temperature VALUE VALUE VALUE VALUE
(wlnrer) 30.8 27.3 26.6 90 °C
h.Temperature VALUE VALUE VALUE VALUE
(summer) 34.7 33.3 32.9 92 °C
MINIMUM MAXIMUM MINIMUM MAXIMUM
I.pH 7.2 8.2 7.6 7.9 j0Njjjjjjj 365 STANDARD UNITS
PART B- Mark'X'in column 2-a for each pollutant you know or have reason to believe is present.Mark'X'in column 2-b for each pollutant you believe to be absent.If you mark column 2a for any pollutant which is limited either
directly,or indirectly but expressly, in an effluent limitations guideline,you must provide the results of at least one analysis for that pollutant.For other pollutants for which you mark column 2a,you must pmvide
quantitative data or an explanation of their presence In your discharge.Complete one table for each outing.See the Instructions for additional details and requirements.
2.MARK )(* 3.EFFLUENT 4.UNITS S.INTAKE(opuonvl)
1.POLLUTANT b.MAXIMUM 30 DAY VALUE c.LONGTERM AVRG.VALUE a.LONG TERM AVERAGE
AND a, p, a.MAXIMUM DAILY VALUE Wow'1lable) Q(f adable) VALUE
CAS NO. BELIEVED BELIEVED (1) (1) (1) d.NO.OF a.CONCEN- 1 b.NO.OF
(Ijwallable) PRESENT ABSENT CONCENTRATION (2)MASS CONCENTRATION (2)MASS CONCENTRATION (2)MASS ANALYSES TRATION b.MASS CONCENTRATION (2)MASS ANALYSES
a.Bromide �/
(249SM7-9) X 2.9 648 1 mg/1 lbv/day
b.Chlorine,Total �/ -
Residual X
c.Color X 380 77,360 200 41,755 163 36,380 365 mg/1 lb./day
d.Fecal Coliform X 6,000 301.8 9.5 52 #100/ml
e.Fluadde
(16984-40-8) 4
0.5 ND 1 mg/1
f.NltrateNiUlte
(as AD X c0.02 ND 1 mg/1
EPA Form 351 D-2C(8-90) PAGE V-1
CONTINUE ON REVERSE

ITEM V-B CONTINUED FROM FRONT
2.MARK'X' 3.EFFLUENT 4.UNITS S.INTAKE(optional)
1.POLLUTANT b.MAXIMUM 30 DAY VALUE c.LONGTERM AVRG.VALUE a.LONG TERM
AND a. b. a.MAXIMUM DAILY VALUE (fwallableJ (7Jwalfable) AVERAGE VALUE
CAS NO. BELIEVED BELIEVED (1) (t) 1 d.NO.OF a.CONCEN- b.NO.OF
(Jwal(ab(e) PRESENT ABSENT CONCENTRATION (2)MASS CONCENTRATION (2)MASS CONCENTRATION (2)MASS ANALYSES TRATION b.MASS CONCE(1NTRATION (2)MASS ANALYSES
g.Nitrogen, \
Ial Organic(as /�[\ 2.4 537 1 mg/1 lba/aay
h.011 and
Grease x <5 ND 1 mg/1
I.Phosphorus ` /
(as P),Total X 1.2 276 1.2 276 .8 179 12 Il lba/aay
(7723-14-0)
1.Radioacavily ` '
(1)Alpha,Total 7(
(2)Beta,Total X
(3)R
Total
adlum, x
(4)Radlum 226,
Toted x
k.Sulfate
(as SO,)
(14808-79-8) x 510 113,991 1 Tel lb./ay
I.Sulfide
lass) X <0.10 ND 1 mg/1 lba/aay
m.Sulfite
(as SOS) ND
`7(/
(14265.45-3) / ` <1 1 Tel
n.Sudeclents X <0.050 ND 1 mg/1
o.Aluminum,
Total
V429-90.5) 0.256 57.2 1 rl1 lbe/aay
p.Badum,Total
(7440-3") X 0.031 6.9 1 rl lbe/aay
q.Boron,Total
(744042-8) X 0.084 18.8 1 Il lb./day
r.Cobalt,Total(7440-48.4) X <0.'005 ND 1 mg/1 lb./day
9.Iron,Total
(7439-09-B) x 0.075 16.8 1 rl lb./day
L Magnesium,
Total
(7439-95-4) 3.57 798 1 mg/1 lba/aay
u.Molybdenum,
Total
(7439-98-7) 0.008 1.8 1 mg/1 1be/aey
v.Manganese,
Total
(7439-96-5) 0.134 30 1 mg/1 lbe/aey
w.Tin,Total(7440-31-5) X <0.005 ND 1 rl lb./any
a Titanium, -
To al
(7440.32-0) <0.005 ND 1 mg/1 lbe/aay
EPA Form 3510-2C(8-90) PAGE V-2 '
CONTINUE ON PAGE V-3

EPA 1,13.NUMBER(copyfrom item 1 of Form 1) OUTFALL NUMBER
CONTINUED FROM PAGE 3 OF FORM 2-C NC0000272 001
PART C- If you are a primary industry and this ouffall contains process wastewater,refer to Table 2c-2 in the instructions to determine which of the GC/MS fractions you must test tor.Mark W in column 2-a for all such GCIMS
fractions that apply to your industry and for ALL toxic metals,cyanides,and total phenols.If you are not required to mark column 2-a(secondary industries,nonpmcess wastewater out/alls, and nonrequired GC✓MS
fractions),mark'X'in column 2-b for each pollutant you know or have reason to believe is present Mark'X'in column 2c for each pollutant you believe is absent If you mark column 2a for any pollutant,you must
provide the results of at least one analysis for that pollutant.If you mark column 2b for any pollutant,you must provide the results of at least one analysis for that pollutant d you know or have reason to believe it will be
discharged in concentrations of 10 ppb or greater.If you mark column 2b for acrolein,acrylonitrile,2,4 dlnitrophenol,or 2-methyl4,6 dinitmphenol,you must provide the results of at least one analysis for each of these
pollutants which you know or have reason to believe that you discharge in concentrations of 100 ppb or greater.Otherwise,for pollutants for which you mark column 2b,you must either submit at least one analysis or
briefly describe the reasons the pollutant Is expected to be discharged.Note that there are 7 pages to this part please review each carefully.Complete one table(all 7 pages)for each ougall. See Instructions for
additional details and requirements.
2.MARK'X' 3.EFFLUENT 4.UNITS 5.INTAKE(optional)1.POLLUTANT b.MAXIMUM 30 DAY VALUE c.LONG TERM AVRG. a.LONG TERM
AND a b d a.MAXIMUM DAILY VALUE ( e"cloble) VALUE(ffavaflable) AVERAGEVALUE
CAS NUMBER TESTING BELIEVED BELIEVED (t) (1) (1) d.NO.OF a.CONCEN- (1) b.NO.OF
(ALL,fCble)YA REQUIRED PRESENT ABSENT OF
(2)MASS CONCENTRATION (2)MASS CONCENTRATION .(2)MASS ANALYSES TRATION b.MASS CONCENTRATION (2)MASS ANALYSES
METALS,CYANIDE,AND TOTAL PHENOLS
1 M.Antimony,Total
(7"D-36-0) X <0.005 ND 1 mg/1
2M.Arsenic,Total
(7440J8-2) X <0.010 ND 1 mg/1
(744"1-7) Total X <0.001 ND 1 mg/1
4M,Cadmium,Total
(744D.43.9) X <0.001 ND 1 mg/1
5M.Chromium,
Total(7440.47-3) X <0.005 ND 1 mg/1
6M.Copper,Total
(7440-SM) X 0.005 1.1 1 mg/1 lb./day
7M.Lead,Total
(7439-92-1) X <0.005 ND 1 mg/1
BM.Mercury,Total 0.000003 .0007
.. (7439.97-6) 1 mg/1 lba/day
9M.Nickel,Total v _
V44D-02-0) ^ <0.005 NO 1 mg/1
10M.Selenium
Total(7762-09,-2) X <0.010 NO 1 mg/1
11 M.Silver,Total
(7440.224) X <0.005 ND 1 mg/1
12M.Thallium,
Total(7440-28-0) X <0.010 ND 1 mg/1
13M.Zinc,Total v
(744D-66a) ^ 0.0226 5.1 1 mg/1 lb./day
14M.Cyanide,
Total(57-12-5) X <0.000005 ND 1 mg/1
15M.Phenols, .
JE
Total X 0.016 3.6 1 mg/1 lb./say
DIOXIN
2,3,7 8-Tetra- DESCRIBE RESULTS
chlorodlbenzo-P- X All data for permit term were non-detect (less than the detection limit of to pg/1) by Method EPA-15 1613A.
Dloxin(1764-01-6) / \
EPA Form 3510-2C(8-90) PAGE V-3
CONTINUE ON REVERSE

CONTINUED FROM THE FRONT
2.MARK W 3.EFFLUENT 4.UNITS S.INTAKE(opNoneo
1.POLLUTANT b.MAXIMUM 30 DAY VALUE c.LONG TERM AVRG. a.LONG TERM
AND e. b. C. a.MAXIMUM DAILY VALUE (jevel(eble) VALUE(ffavalleble) AVERAGE VALUE
CAS NUMBER TESTING BELIEVED BELIEVED 1) tl.NO.OF a.CONCEN b.-
(Ifavaileble) REQUIRED PRESENT ABSENT CONCENTRATION (2)MASS CONCENTRATION (2)MASS CONCENTRATION (2)MASS ANALYSES TRATION b.MASS CONCENTRATION (2)MASS �ANALYSESO
GClMS FRACTION-VOLATILE COMPOUNDS
1V.Acciolein
(107-02.8) <0.005 ND 1 mg/1
2V.Acrylonildle
(107-13-1) X <0.050 ND 1 mg/1
3V.Benzene
(7143.2) X <0.002 ND 1 mg/1
4V.Bie(CMoro-
merhy!)Ether
(542-88-1) <0.005 ND 1 mg/1
SV.Bmmofonn
(75.25-2) x <0.002 ND 1 mg/1
SV.Carbon
Tetrachloride
(56-23-5) x <0.002 ND 1 mg/1
TV.Chlorobemene
(108-90-7) <0.002 ND 1 mg/1
BV.Chlorodl.
bromome91ene
(1244&1) <0.002 ND 1 mg/1
9V.Chloroethane v '
(7"03) ^ <0.002 ND 1 mg/1
10V.2-Chloro-
ethyMnyl Ether
(110.75.8) x <0.005 ND 1 mg/1
11 V.Chlomfenn
(67-66-3) X <0.002 ND 1 mg/1
12V.Dichlon-
bromomelhene
(75-274) x <0.002 ND 1 mg/1
13V.Dichloro-
di9ueromelhane(75-71-8) x <0.002 ND 1 mg/1
14V.1,1-01chloro-
ethane(76343) <0.002 ND 1 mg/1
15V.1.2-Dichloro-
ethene(107-06-2) <0.002 ND 1 mg/1
16V.1d-Dlchlcr
etWene(7&35.4) X <0.002 ND 1 mg/1
17V.1,2-Dichlene' �/ -
propene(78.87-5) X <0.002 ND 1 mg/1
16V.1,3-Dichloro-
propylene `X/
(542-75-6) / \ <0.002 ND 1 mg/1
19V.Ethylbenzene
(100-414) X <0.002 ND 1 mg/1
20V.Methyl
Bromide(7483-9) x <0.002 ND 1 mg/1
21V.Methyl
Chloride(74-87-3) <0.002 ND 1 mg/1
EPA Form 3510-2C(8-90) PAGE V4
CONTINUE ON PAGE VS

CONTINUED FROM PAGE V-4
2.MARK'X' 3.EFFLUENT 4.UNITS S.INTAKE(opllonoo
1.POLLUTANT b.MAXIMUM 30 DAY VALUE c.LONG TERM AVRG. a.LONG TERM
AND e. D. c, a,MAXIMUM DAILY VALUE (Iif-actable) VALUE(Y'.11able) AVERAGE VALUE
CAS NUMBER TESTING BELIEVED BEUEVED
1 (1) (1) (1) d,NO.OF a.CONCEN- b.NO.OF
(javailable) REQUIRED PRESEPII ABSENT CONCENTRATION (2)MASS. CONCENTRATION (2)MASS. CONCENTRATION (2)MASS]ANALYSES TRATION b.MASS CONCENTRATION (2)MASS ANALYSES
GC/MS FRACTION-VOLATILE COMPOUNDS(continued)
22V.Methylene
Chloride(75-09.2) x <0.002 ND 1 mg/1
23V 1,1,2,2- '
T9-345omelhana X <0.002 ND 1 mg/1
24V.Teharhloro
ethylene(127-18-4) <0.002 ND 1 mg/1
25V.Toluene \/
(108.88-3) x <0.002 ND 1 mg/1
26V.1,2-Trans
Dichloroethylene X <0.002 ND
158-60.5 ' ` 1 mg/1
27V.1,1,1-Tdchlor
ethane(71-55.6) x <0.002 ND 1 mg/1
28V.1,1,2-Trlchlor
ethane(79-00-5) x <0.002 ND 1 mg/1
29V Tdchlo
ethylene(79-01-6) x <0.002 ND 1 mg/1
30V.Tdchlono - -
fluommethane <0.002 ND
�yd 1 mg/1
31V.Vinyl Chloride
(75-01-4) x <0.002 ND 1 mg/1
GC/MS FRACTION-ACID COMPOUNDS
IA 2-Chlorophenal
(95-57.8) x <0.005 ND 1 mg/1
2A 2,4-Dichloro_ \/
phenol(120.83-2) x <0.005 ND 1 mg/1
3A 2,4-Dimethy4
phenol(1.05-67-9) <0.010 NO 1 mg/1
4A 4,6.D1nitm-O- \/
Creeol(534-52-1) x <0.020 NO 1 mg/1
5A.2,4-Dinitm-phenol(51-28.5) X <0.050 ND 1 mg/1
BA 2-Nlaophenol
(88-715,5) x <0.005 ND 1 mg/1
7A.4-Nittophenol v
(100-02-7) ^ <0.050 ND 1 mg/1
BA P-Chlot M- �/
Crewl(59-5(.7) X <0.005 ND 1 mg/1
BA.Pentachlora-
phenol(87-86.5) <0.010 ND 1 mg/1
10A Phenol
(108-95-2) x 0.016 3.6 1 mg/1 lb./dny
11A 2,4,6-Tdchlor v
phenol(88-05-2) v <0.010 ND 1 mg/1
EPA Form 3510-2C(8-90) PAGE V-5
CONTINUE ON REVERSE

CONTINUED FROM THE FRONT
2.MARK'X' 3.EFFLUENT 4.UNITS S.INTAKE o
1.POLLUTANT (Piona D
AND b.MAXIMUM 30 DAY VALUE C.LONG TERM AVRG. a.LONG TERM
CAS NUMBER a. b. a a.MAXIMUM DAILY VALUE (lfuvallabk) VALUE(if".8,ebk) AVERAGE VALUE
TESTING BEUEVED BELIEVED (1) (1) (1) d.NO.OF a.CONCEN- b.NO.OF(If.edable) REQUIRED PRESEM ABSENT CONCENTRATION (2)MASS CONCFMRATION (2)MASS CONCEMRATION 2 MASS ANALYSES TRATION b.MASS NT
O CONCENTRATIONS (2)MASS ANALYSES
GCIMS FRACTION-BASE/NEUTRAL COMPOUNDS
1B.A enaphthene
(83-32-9) <0.005 NO 1 mg/1
2B.Amnaphtylene �/
(208.98.8) x <0.005 NO 1 mg/1
38.Anthrawne �/
(12(-12-7) X <0.005 NO 1 mg/1
48.Benzidine �/
(92-87-5) X <0.050 NO 1 mg/1
513.Benzo(a)
Anthraw(55 )ne X <0.005 ND 1 m
4/1
6B,Benzo(50-3 �/
Pyrene(So-3zA) /� <0.005 ND 1 mg/1
7B.3,4-Benzo-
9uoranthena
(205-99-2) <0.005 NO 1 mg/1
88.Benzo(gho
Perylene(191-24-2) X <0.005 ND 1 mg/1
9B.Benzo(k)
Fluomnthene
(207-08-9) c0.005 ND 1 mg/1
108.Bis(2-Cbloro-
erhory)Methane �/
(111-91-1) X <0.010 ND 1 mg/1
118.BIB(2-ChlOro-
ethyl)Ether �/
(11144-4) X <0.005 NO 1 mg/1
128.BIs(2.
Chterviw-pyl) �/
Ether(102-8D.1) X <0.005 NO 1 mg/1
138.BIB(2.Ethyl-
beryl)Phmalale X c0.005 ND
(117-81-7) 1 mg/1
14B.4.Bmmophenyl
Phenyl Ether
(101-55-3) x <0.005 ND 1 mg/1
158.Butyl Benzyl
Phlhelale(8568-7) x <0.005 ND 1 mg/1
169.2.Chloro-
naphthalene
(91-se-7) <0.005 ND 1 mg/1
17B.4-Chloro-
phenA Phenyl Ether �/
(7005-72-3) X <0.005 ND 1 mg/1
18B.Chrysene
(218-01.9) <0.005 NO 1 mg/1
19B.Dibenzo(qh)-
Anlhracene �/
(53-70.3) x <0.005 NO 1 mg/1
208.1,2-0Ichl 21B.13Di-chloro-
aro- v
benzene(95-50-1) ^ <0.002 NO 1 mg/1
�/ -
bemene(541-73.1) x <0.002 ND 1 mg/1
EPA Form 3510-2C(8-90) PAGE V-6 CONTINUE ON PAGE V-7

CONTINUED FROM PAGE V-6
2.MARK'X' 3.EFFLUENT 7UNITS5.INTAKE o Ilona1.POLLUTANT (P 0AND b.MAXIMUM 3. DAY VALUE o.LONGTERM AVRG.CAS NUMBER a. b. e.MAXIMUM DAILY VALUE WI Wlable) VALUE(Ijwallable)
TESTING BELIEVED BELIEVED (1) (i) - (1) d.NO.OF a.CONb.NO.OF
(fwa!!able) REQUIRED PRESENT ABSENz CONCENTRATION (2)MASS CONCENTRATION (2)MASS CONCENTRATION (21 MASS ANALYSES ' TRATIANCFMRATION (2)MASS ANALYSES
GCIMS FRACTION-BASE/NEUTRAL COMPOUNDS(conrinned)
22B.1,4-Dichloro-
benzene(106-0a7) ^ <0.002 NO 1 mg/1
23B.3,3-Dlchlaro-
benzidlne(91.94-1) x <0.025 ND 1 mg/1
24B.Diethyl
Phlhalete(64-66.2) X <0.005 ND 1 mg/1
25B,Dimemyl
Phthalate
(131-11-3) X <0.005 NO 1 mg/1
26B.D4o(84-7 X <0.005 ND
Phthalate(ed-742) 1 mg/1
27B.2,4-Dinitn- �/
toluene(121-14-2) x <0.005 ND 1 mg/1
28B.2,6-Dinitno
toluene(606-20-2) X <0.005 ND 1 mg/1
298.DI-N=Octyl
Phihalele(117-84.0) X <0.005 NO 1 mg/1
30B.1,2-Diphenyi. -
hydrezine(asAzo-benzene)(122-66-7) x <0.005 ND 1 mg/1
318.Fluarenmene v
(206-4") ^ <0.005 ND 1 mg/1
32B.Flue no
(86-73-7) x <0.005 ND 1 mg/1
33B.Heaechloro-
benzene(118-74-1) X <0.005 NO 1 mg/1
34B.Hexachlora-
buladiene(87-6Ba) X <0.005 NO 1 mg/1
35B.Hexachlora-
cyclopentadiene
(77-47-4) X <0.010 ND 1 mg/1 ,
36B Hexachloro- X
ethane(67-72-1) <0.005 ND 1 m
g/1
378.Indena
(1,2,3-cd)Pyrene
(193.39-6) x <0.005 NO 1 mg/1
�&59-1B.Iso;horone X <0.010 ND 1 mg/1
(9B.Naphthalene X <0.005 ND 1 m 1
s1za3 g/
40B.Nitrobenzene
(98-953) X <0.005 NO 1 mg/1
418.N-Nitro-
sodlmemylamine
(62.7&9) X <0.005 NO 1 Ta
42B.N-Nitroso&
N-Propylamine
(621-64-7) <0.005 ND 1 mg/1
EPA Form 3510-2C(8-90) PAGE V-7 CONTINUE ON REVERSE

CONTINUED FROM THE FRONT
1.POLLUTANT riona
2.MARK'X' 3.EFFLUENT 4.UNITS S.INTAKE o
( 9
➢b.MAXIMUM 30 DAY VALUE c.LONG TERM AVRG. a.LONG TERM
AND a. p, c. a.MAXIMUM DAILY VALUE (fjavaflable) VALUE(ifavaflab(e) AVERAGE VALUE
CAS NUMBER TESTING BELIEVED BELIEVED d.NO.OF a.CONCEN- b.NO.OF
(lfavallab(e) REQUIRED PRESEIdf ABSENT CONCENTRATION (2)MASS CONCENTRATION (2)MASS CONCENTRATION (2)MASS ANALYSES TRATION b.MASS CONCENTRATION (2)MASS ANALYSES
GC/MS FRACTION-BASE/NEUTRAL COMPOUNDS(ronrinued)
43B.N-Nit o
sadiphenylamine
(86-30-6) x <0.010 ND 1 mg/1
44B.Phenenthmne
(e5-01-e) X <0.005 NID 1 mg/1
45B.Pymne
(129-00-0) X <0.005 ND 1 mg/1
468.1,2,4-Tr4
chlombemene
(120-82-1) X <0.005 - ND 1 mg/1
GC/MS FRACTION-PESTICIDES --
1P.AJddn �/
(30"(a2) x <0.00005 ND J. mg/1
(3 M") X <0.00005 NO 1 m
g/1
3P.P-BHC
(319-85-7) x <0.00005 ND 1 mg/1
4P.y-BHC �/
(5mg.9) x <0..00005 ND 1 mg/1
(3l BHC X <0.00005 ND(319-ass) 1 mg/1
6P.7-74l9rdana x <0.0005 ND(s7-74-9) /� 1 mg/1
7P.4,4'-DDT X
(50.29-3) /� <0.00005 ND 1 mg/1
6P.2-654-DOE
pz-5s x <0.00005 ND s) /� 1 mg/1
(7y5q$j DD X <0.00005 ND 1 m
g/1
10P.Dielddn
(6(-57-1) X <0000005 ND 1 mg/1
11P.a-Enosullen x <0.00005 ND(11s2B-7) /� 1 mg/1
12P.P-Endosufan �/
(115-29-7) x <0.00005 ND 1 mg/1
13P.Endosulfan
Sulfale(1031-07-8) x <0.00005 DID
- 1 mg/1
14P.Endrin �/
(72-20-g) ^ <0.00005 ND 1 mg/1
15P.Enddn
Aldehyde <0.00005 NO(7421-93d) 1 mg/1
16P.Heptachlor(76-44A) 5;/ <0.00005 ND 1 mg/1
EPA Farm 3510-2C(8-90) PAGE V-e
CONTINUE ON PAGE V-9

EPA I.D.NUMBER(wpyfmmlmm l of Form l) OUTFALL NUMBER
CONTINUED FROM PAGE V-e
NC0000272 001
2.MARK'X' 3.EFFLUENT 4.UNITS 5.INTAKE o llana
1.POLLUTANT - - (P 0
b.MAXIMUM 30 DAY VALUE cLONG TERM AVRG.
AND a b. e. a.MAXIMUM DAILY VALUE a-LONG TERM
CAS NUMBER TESTING BEUEVED BELIEVED (Im'alfabfe) VALUE(Ifavalfable) AVERAGE VALUE
i available REQUIRED PRESENT ABSENT (1) (1) NT d.NO. E a. RATIOCONC N- (1J b.NLYSE
(f ) CONCENTRATION (2)MASS CONCENTRATION (2)MASS CONCENTRATION (2)MASS ANALYSES ' TRATION b.MASS CONCENTRATION (2)MASS ANALYSES
GClMS FRACTION—PESTICIDES(conlinued)
17P.Heptachlor
Epmdde <0.00005 ND
(1024.57-3) 1 mg/1
(&M69C21-9) x <0.0005 ND(534ss-2t-s) /� 1 mg/1
19P.PCB-1254 �/
(11097-69-1) x <0.0005 ND 1 mg/1
20P.PCBA221
(11104-28-2) X <0.0005 ND 1 mg/1
21P.PCB-1232
(1114146-5) X <0.0005 ND 1 mg/1
22P.PCB-1248
(12672-29-6) X <0.0005 ND 1 mg/1
23P.PCB-1260
(11096-.82-5) X <0.0005 ND
24P.PCB-1016
(12674-11-2) X <0.0005 NO 1 mg/1
25P.Tonphene
(8001-35-2) X <0.0005 ND 1 mg/1
EPA Farts 3510-2C(8-90) PAGE V-9

Attachment I
Form I, Section XI
NC0000272
Site Map
Blue Ridge Paper Products dba Evergreen Packaging
Canton Mill
Canton, NC

Attachment I : Site Location Map
Location Map
NPDES Permit No.
eve " , NC0000272
Cove +
r ,
n
Facility
N 35°32' 6",W 82°50' 22"
mn
ery. • Outfall001 le
�I
N 35° 32' 8",W 82°50'42" - �
-1 Mile Radius
.y Mill Property Line
i
0 O'' ' Canton
Raw Water Intake ibsontown
W 82° 50'
N
y
l
Evergreen Packaging Inc.
/ Haywood County
%' Canton, NC

Attachment II-A& II-B
Form 2C, Section 11-A&B
NC0000272
Flows, Sources of Pollution, and Treatment Technologies
Blue Ridge Paper Products dba Evergreen Packaging
Canton Mill
Canton, NC

PIGEON RIVER TREATED EFFLUENT DISCHARGE-29.9 MGD Permitted Monthly C2p8City
INCLUDING STORMWATER FLOW OF OA7 MGD
RIVER INTAKE-32.78 MGD
EVAP -
COOLING WATER 0.5 MGD
RETURN .........�
PUMP WASTEWATER
HOUSE RAW WATER USE 2.0 MGD TREATMENT
_._._._._._._._._._._._._._._.^ PLANT
FILTER _ _ FILTER PLANT SLUDGE-0.30 MGD _�_ _
PLANT ._ - -"'---•_ _
0.6 MGD 0.6 MGD
WASTEWATER TREATMENT
DI�LJL 8.0 MGD SERVICE WATER
NG
PAPER MILL - EVAP 0.7 MGD
...........�
No.11 PM 1.8 MGD
10.8 MGD No.12 PM 1.3 MGD
10 No.20 PM 1.7 MGD
No.19 PM 2.9 MGD
Chemical Prep 1.3 MGD 8.1 MGD
•PCC Plant 0.3 MGD
Pulp Distribution 1.5 MGD
1 WHITE WATER-2.0 Man
PULP MILL
11.5 MGD ERCO C102 Get 1.2 MGD 13.5 MGD
Chemical Prep 0.6 MGD .
Cooking 1.4 MGD
Bleaching 4.9 MGD Bleach Plant
Recovery 3.4MGD OuOalls
002 8 003
EVAP 1.1 MGD
...........�
5.0 MGD STEAM
AND
.POWER GENERATION 3.9MGD
0.9 MGD MISCELLANEOUS 0.9 MGD
AND
UNMETERED
TOWN OF CANTON 0.9 MGD
SANITARY WASTEWATER 10
'MILL LANDFILL LEACHATE
0.02 MGD MIII SanHary W W
TOWN OF CANTON MILL POTABLE WATER 0.02 MG0
CITY WATER Of
I SYSTEM
ATTACHMENT II -A WATER BALANCE LINE DIAGRAM
Evergreen Packaging Inc.
Canton Mill
NPDES Permit No. NC0000272

Attachment II-B
Description of Operations Contributing Flow
Pulp Mill
Chip cooking, pulp washing,screening and bleaching, recovery and regeneration of cooking chemicals,
production of chlorine dioxide for bleaching, condensates collection and treatment.
Paper Mill
Production of fine papers and paperboard.
Unmetered and Miscellaneous
City water, raw water, mill water production, sludge dewatering, groundwater recovery, mill sanitary
wastewater.
Town of Canton
Municipal wastewater, mill landfill leachate(variable with rainfall)
Description of Treatment
Grit Chamber
32'x 8'x 16',29.9 MGD, 1 minute retention solids to landfill
Bar Screens
Two 6'wide each, pH control by COZ injection. Coagulation by polymer addition.
Primary Clarifiers
Circular, two 200'diameter x 14.75 swd, 3.47 MM gal/each, 5.6 hr retention; one 125'diameter x 11'swd
for spill control, 1.01 MM gal capacity skimmed floating solids to landfill. Settled solids dewatered by belt
press to landfill.
Secondary Treatment
Activated sludge process.Aeration basins, 11.4 MM gal total vol,29.9 MGD flow plus recycle one or two
of four basins operated as aerobic digester at low influent loading.At low influent loading, secondary
treatment by activated sludge process(and stand-by capacity of 4.6 MM gal)with 6.8 MM gal treatment
and 5.5 hours retention.
Secondary Clarifiers
Circular, two 200'diameter x 12'swd,2.82 MM gal/each,4.5 hours retention; one standby for cold
weather clarifier, 1 50'diameter x 12'swd, 1.85 MM gal-

Oxygen Aeration Cascade
Oxygen injection into secondary effluent prior to discharge into the Pigeon River.

Attachment III
Wastewater Treatment Plant Diagram
Blue Ridge Paper Products dba Evergreen Packaging
Canton Mill
Canton, NC

. TOTAL INFLUENT = LOW LIFT + ACID SEWER
ACID RETURN ACTIVATED SLUDGE
SEWER 1,______________________—
0 to 3 MGD I I
I
PRIMARYINFLUEM 1
1 FffFLOUTFACE
PRIMARY AERATION SECONDARYETER FINAL
CLARIFIERS BASINS CLARIFIERS ERATION EFFLUENT
PRIMARY IFFUSER. 29.9 MGD
CANTON EFFLUENT
WW
0.9 MGD 1 SECONDARYEFFLUENT
LOW LIFT
MILL GRIT CHAMaER ............ AEROBIC
SEWER .. � - .......
DIGESTER(S) :
26 to 29 MGD PUMPS-dX15 MGD 1' WASTE SLUDGE
I
I RLTRATE
SLUDG
DEWATERIE
NG
1
V
DEWATERED SLUDGE
TO LANDFILL
PRIMARY CLARIFIERS AERATION BASINS/AEROBIC DIGESTERS SECONDARY CLARIFIERS
2- 200 FT DIA X 14.75 FT SWD 2-2.3 MGAL(ONE OR BOTH USED FOR AEROBIC DIGESTION) 2- 200 FT DIA X 12 FT SWD
3.47 MGAL,EACH 2.3.4 MGAL USED FOR ACTIVATED SLUDGE 2.82 MGAL,EACH
11.4 MGAL TOTAL AVAILABLE VOLUME
1-125FTDIAX11 FTSWD 1-150 FT DIA X 14 FT SWD
1.01 MGAL 20 SURFACE AERATORS 1.85 MGAL
SPARE CLARIFIER USED FOR SPILL COLLECTION 125/56'HP. 1.3 LES 02 PER HP-HR SPARE CLARIFIER USED FOR SEASONAL USE
RETURN SLUDGE 50 TO 100%
WASTE SLUDGE 2 TO 5%
TREATMENT CHEMICALS
Primary Influent pH control-carbon dioxide
Primary Effluent pH control-sulfuric acid
Primary settling-polymer as required .ATTACHMENT III -SIMPLIFIED WASTEWATER FLOW DIAGRAM
Activated Sludge-supplemental ammonia and phosphate nutrients as required
Sludge Dewatering-polymer Evergreen Packaging Inc.
Effluent Aeration-oxygen Canton MITI
Defoamer-as required in primary effluent and final effluent NPDES NC0000272

Attachment IV
Form 2C, Section VII
NC0000272
Chronic Toxicity Data
Blue Ridge Paper Products dba Evergreen Packaging
Canton Mill
Canton, NC
R

Attachment IV
Summary of Historical Toxicity Data from 2011—2014
Results of 7-day Ceriodap6ia Survival and Reproduction
No Observable Effect Concentration(COEC)
Sample Date NOEL% Effluent
3/3/2011 100%
6/2/2011 100%
9/8/2011 100%
12/15/2011 100%
3/15/2012 100%
6/14/2012 100%
9/13/2012 100%
12/13/2012 100%
3/14/2013 100%
6/13/2013 100%
9/19/2013 100%
12/12/2013 100%
3/13/2014 100%
6/12/2014 100%
Testing Performed by: Pace Analytical Environmental Testing Solutions
2225 Riverside Drive 351 Depot Street
Asheville,NC 28804 Asheville, NC 28801
[phone] [phone]

Attachment V
Form 1, Section 10
NC0000272
Existing Environmental Permits
Blue Ridge.Paper Products dba Evergreen Packaging
Canton Mill
Canton, NC

Attachment V
Canton Mill Existing Environmental Permits
Water
• Major, Permit : NC0000212
• Minor, Permit: NCG120098
Resource Conservation and Recovery Act (RCRA)
• Active (H)SQG (NCD003148889)
Air Emissions Inventory(EIS)
• 7920511
Clean Air Act
• Operating Major: 3708700159
• Greenhouse Gas Emissions(eGGRT): 1000230
Toxic Release Inventory(TRI)
• 8716CHMPNMAINS

olevergreeff
Blue Ridge Paper Products Inc. - Canton Mill
May 23, 2013 NMM#34-13
HAND DELIVERED
Chuck Cranford
Asheville Regional Supervisor
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Secondary Effluent Fecal Coliform 5/17/2013
NPDES NC0000272
Evergreen Packaging
Canton,NC
Dear Mr. Cranford:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
5/17 at approximately 7:30 am and delivered to the laboratory for analysis at 8:10 am. Proper
sampling procedures were followed by plant personnel. The wastewater treatment plant
supervisor, Roger Edwards,was informed of the result the morning of 5/18. The result of the
analysis showed a value of>600 colonies per 100ml. The fecal coliform excursion on 5/17 was
limited to that sample parameter and day. All other effluent parameters were within permit
requirements. A phone call was placed to the NCDWQ Regional office on 5/18 at approximately
9:00 am.
Evergreen met with the Town of Canton to discuss recent fecal coliform trends on Friday, 5/17
and the construction progress on the new chlorine pretreatment feed system. Evergreen
continues to supplement the Town's feed at the upper manhole via a gravity fed, sodium
hypochlorite tote. The feed rate of the tote has since been increased along with adjustments to
the Town's chlorine feed system. Process control trends indicate compliance for the remainder
of the month.
If you have any questions or comments, please feel free to contact us at your earliest
convenience.
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpacklcalEOHSISHAROWater Resftck's Water ResIDWO

NCDWQ Page 2
Sincerely,
Nick McCracken Roger Edwards
Water Compliance Coordinator Supervisor, Waste Water Treatment Plant
Evergreen Packaging—Canton Mill Evergreen Packaging—Canton Mill
828-646-2874 828-646-2382
Nick McCracken(aeverpack.com Roger.Edwards(&eveMack.com
cc:
Mr. Jeff Menzel
Environmental Specialist, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
C. File—Water
BMP Notebook
Internal distribution -
D. Griswold
M. Ferguson
R. Edwards
C. Chiles
N. McCracken
J. Pryately
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
lleverpacklce EOHstsHAREiwafer Fileswick's Wafer FileSOW0
Division of Evergreen Packaging

fevergreeff
packaging
Blue Ridge Paper Products Inc. - Canton Mill
May 23, 2013 NMM#34-13
HAND DELIVERED
Chuck Cranford
Asheville Regional Supervisor
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Secondary Effluent Fecal Coliform 5/17/2013
NPDES NC0000272
Evergreen Packaging
Canton, NC
Dear Mr. Cranford:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
5/17 at approximately 7:30 am and delivered to the laboratory for analysis at 8:10 am. Proper
sampling procedures were followed by plant personnel. The wastewater treatment plant
supervisor, Roger Edwards, was informed of the result the morning of 5/18. The result of the
analysis showed a value of>600 colonies per 100ml. The fecal coliform excursion on 5/17 was
limited to that sample parameter and day. All other effluent parameters were within permit
requirements. A phone call was placed to the NCDWQ Regional office on 5/18 at approximately
9:00 am.
Evergreen met with the Town of Canton to discuss recent fecal coliform trends on Friday, 5/17
and the construction progress on the new chlorine pretreatment feed system. Evergreen
continues to supplement the Town's feed at the upper manhole via a gravity fed, sodium
hypochlorite tote. The feed rate of the tote has since been increased along with adjustments to
the Town's chlorine feed system. Process control trends indicate compliance for the remainder
of the month.
If you have any questions or comments, please feel free to contact us at your earliest
convenience.
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpacklcalEOHSISHARE1Water ResWick's Water FilesV)WQ

NCDWQ Page 2
Sincerely,
Nick McCracken Roger Edwards
Water Compliance Coordinator Supervisor, Waste Water Treatment Plant
Evergreen Packaging-Canton Mill Evergreen Packaging-Canton Mill
828-646-2874 828-646-2382
Nick.McCracken(a-_)everpack.com Roger.EdwardsAeverpack.corn
cc:
Mr. Jeff Menzel
Environmental Specialist, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2040 U.S. Highway 70
Swannanoa, NC 28778
C. File-Water
BMP Notebook
Internal distribution-
D. Griswold
M. Ferguson
R. Edwards
C. Chiles
N. McCracken
J. Pryately
Blue Ridge Paper Products Inc. -Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpackloalEOHSISHAREMater FilesWick's Water FIIes0WQ
Division of Evergreen Packaging

NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E.Skvada, III
Govemor Secretary
October 15,2014.
Mr. Dane Griswold
Blue Ridge Paper Products Inc.
P.O. Box 4000
Canton NC 28716
Subject: Incident Closure
NOD-2014-PC-0105
Canton Mill
Permit No: NC0000272
Haywood County
Dear Mr. Griswold:
The Division of Water Resources has received the status report dated September 30, 2014, from
Blue Ridge Paper Products Inc. related to the Notice of Deficiency NOD-2014-PC-0105.
The written response and the change in sampling protocol have satisfactorily resolved the
deficiency noted in the subject NOD.
Your attention and cooperation is greatly appreciated. Should you have any questions regarding
this matter or other water quality issues or concerns,please contact me at(828) 296-4500 or
[e-mail].
Sincerely,
Jeff Menzel
Environmental Specialist
Water Quality Regional Operations
Asheville Regional Office
cc: John J Pryately, ORC
Chet Chiles/Manager: Environment, Health& Safety
Nick McCracken EHS&S Water Supervisor
MSC 1617-Central Files-Basement
Asheville Files
Water Ouafity Regional Operations—Asheville Regional Office
2090 U.S.Highway 70,Swannanoa,North Carolina 2877E
Phone:[phone] FAX:[phone]
Internet httpl/portal.ncdenr.org/web/wq
An Equal Cpportunity 1Affinnative Action Employer
G:IWRIWOIHaywoocRWastewateNndustdallBlue Ridge Paper 00272WOD-2014-PC-0105 closure.doc

NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E.Skvarla, III
Governor Secretary
October 15, 2014
Jim Harris
Horsehead Holding Corporation
Horsehead Metal Products Inc.
484 Hicks Grove Rd
MQoresboro,NC 28114
SUBJECT: Compliance Evaluation Inspection
Rutherford County Production Facility
Permit No: NCO089109
Rutherford County
Dear Mr. Harris:
Enclosed please find. a copy ,of the Compliance Evaluation Inspection conducted on 9/17/2014. The
Compliance Evaluation Inspection was conducted by Jeff Menzel and Landon Davidson of the Asheville
Regional Office. No violations, of permit requirements or applicable regulations were observed during this
inspection.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff
have any questions,please call me at 828-296-4500.
Sincerely,
Jeff Menzel
Environmental Specialist
cc: MSC 1617-Central Files-Basement
Asheville Files
Water Quality Regional Operations—Asheville Regional Once
2090 U.S.Highway 70,Swannanoa,North Carolina 28778
Phone:[phone] FAX:[phone]
Internet http1/portal.ncdenr.orghveb1wq
An Equal Opportunity 1 Affirmative Action Employer
G:IWRIWQ1RuthedordlWastewaterVndushiaNiorsehead 89109189109 CEI 2014.doe

United Slates Environmental Protection Agency Form Approved.
VEP A Washington,D.C.20460 OMB No.204UC57
Water Compliance Inspection Report Approval expires8-31-98
Section A:National Data System Coding(i.e.,PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fee Type
1 (s, ( 2 15 1 3 I NCOUS9109 I11 12 14/09117 17 18 Lr j 19 t s t 20 1 . )
211111 I I I I I I II ,I 11 11 III I I I I I l I I I I I I I I I II 1 I I I I f66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 CA Reserved —
67I 70L J 71 [ 72 J 73 I
yDL 4 75L_L_W_L SO
Section B:FacilityData
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date permit Effective Date
POTW name and NPDES permit Number) 10:00AM 14/09/17 14/01/01
Rutherford County Production Facility
484 Hicks Grove Rd Exit TimelDate Permit Expiration Date
Mooresboro NO 28114 12:30PM 14/09/17 18/07/31
Name(s)of Orate,Represents ive(s)/Tfles(s)lPhone and Fax Number(s) Other Facility Data
Ill
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Jim Hanis,Homehead Metal Pmducfs Inc Mooresboro NO ,
2811411628-748-528318282458931 Yes
Section C:Areas Evaluated During Inspection(Check only those areas evaluated)
Flow Measurement Records/Reports Self-Monitoring Program Facility Site Review
Effluent/Receiving Waters
Section D:Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s)and Signata�tlurle(s)of Inspector(s) Agency/Office/Phone and Fax Numbers Dale
Jeff Menzel /,I.rll ARO WQ//828-2964500/ 7p/r7/1I
Signatureof Management Q A Reviewer Agency/OfficelPhone and Fax Numbers Date ll
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.
Page# 1

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NPDES ydmo/day Inspection Type (Go
mo ut.) 11
31 NC0089109 111 12 lsm 17 18 1,.1
Section D:Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
The intent of this inspection was to evaluate the facility's sampling protocol.Analytical results and
DMRs were reviewed for consistency and found to be accurate.The composite sampling program was
reviewed and was found to be in compliance with permit conditions. No violations of permit conditions I
or applicable regulations were observed during this inspection.
I
Other observations made during the inspection include several containment areas where process
overflows had occurred. Most of these overflows appeared to have been contained with the exception
of the gypsum staging area where some material had been pushed over the containment wall.This
area was being cleaned at the time of inspection.
Also observed at the outfall was an area which had been eroded during a recent storm event.
Regarding the construction storm water pond and the impacted area on the riverbank,a 404 is not
required if the repair work is all above the ordinary high water mark. If you are going to remove any
sediment below the ordinary high water mark you should contact us and the Army Corps to discuss.
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Page# 21
9
I

Permit. NCO089109 Owner-Facility: Rutherford County Production Facility
Vction Date: 09/17/2014
Inspection Type: Compliance Evalua0on
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit? 0 ❑ ❑ ❑
Is all required information readily available,complete and current? M ❑ ❑ ❑
Are all records maintained for 3 years(lab. reg.required 5 years)? ❑ ❑ M ❑
Are analytical results consistent with data reported on DMRs? M ❑ ❑ ❑
Is the chain-of-custody complete? M ❑ ❑ ❑
Dates,times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete:do they include all permit parameters? ❑ ❑ ❑
Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ 0 ❑
(If the facility is=or>5 MGD permitted flow)Do they operate 2417 with a certified operator ❑ ❑ M ❑
on each shift?
Is the ORC visitation log available and current? 0 ❑ ❑ ❑
Is the ORC certified at grade equal to or higher than the facility classification? ❑ ❑ ❑
Is the backup operator certified at one grade less or greater than the facility classification? ❑ ❑ M ❑
Is a copy of the current NPDES permit available on site? M ❑ ❑ ❑
Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑
Comment:
Flow Measurement- Effluent Yes No NA NE
#Is flow meter used for reporting? M ❑ ❑ ❑
Is flow meter calibrated annually? M ❑ ❑ ❑
Is the flow meter operational? M ❑ ❑ 0
(If units are separated)Does the chart recorder match the flow meter? 0 ❑ ❑ ❑
Comment:
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? M ❑ ❑ ❑
Is sample collected below all treatment units? M ❑ ❑ ❑
Is proper volume collected? M ❑ ❑ ❑
Page# 3

{
Permit N00089109 Owner-Facility: Rutherford County Productlon Fadlity
Inspection Date: 0 9/1 712 014 Inspection Type: Compliance Evaluation
r
Effluent SamDlln_q Yes No NA NE
Is the tubing clean? ❑ ❑
Ej
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees M ❑ ❑ 0
Celsius)?
Is the facility sampling performed as required by the permit(frequency,sampling type N ❑ ❑ ❑
representative)?
Comment:
Effluent Pipe Yes No NA NEi
Is right of way to the ouffall properly maintained? 0 ❑ ❑ ❑
i
Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ El
I
If effluent (diffuser pipes are required) are they operating properly? 0 0 ❑ El
_ � I
Comment:
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Page# 4

evergreen.. Canton Office
packaging 175McinSfree— Co,lon NC 2871A
September 16, 2014 NMMit58-14
CERTIFIED MAIL Return Receipt Requested
7099 3220 0007 0371 4545
Laura Herbert RECEIVED
Regional Engineer 01vls;on of Water Resourcee
Division of Energy, Mineral& Land Resources—Land Quality Section
North Carolina Department of Environment and Natural Resources
Asheville Regional Office SEP 1 8 2014
2090 US Highway 70
Swannanoa, NC 28778
water ouallly Regbnal OperaBona
Re bnal Office
Subject: Blue Ridge Paper Products Inc.dba Evergreen Packaging Asheville
Canton Mill,Canton,Haywood County,North Carolina
Storm Water Hardwood Chip Sump Overflow 9/12/2014
NPDES Permit: NCS000105
Dear Mrs. Herbert:
Per the requirement by the mill's NPDES storm water permit,this is the 5-day written submission for the storm
water release reported to NC DEMLR. On Friday,September 12`h,the Canton area experienced an intense rainfall
event. During the rainfall event the hardwood chip sump pumps plugged with wood chips allowing the level in the
sump to rise and allow storm water runoff to reach the Pigeon River.
The hardwood chip sump system is designed to collect storm water that falls onto the hardwood chip pile,as well
as,the surrounding area and transfer it to the pine chip sump. This water is then pumped to the low lift of the
wastewater treatment facility for processing. During the rainfall event,the pumps inadvertently became plugged
with wood chips and would not function properly. Once restored,the pumps drew the water level down and
stopped the overflow to the river. The overflow began around 7:53 PM and lasted until approximately 8:10 PM.
The storm deposited rainfall in the amount of 1.16 inches in about 30 minutes.The river level at the time of the
event was 94 MGD.
If you have any questions or comments,please feel free to contact us at your earliest convenience.
Sincerely,
Nick McCracken
Water Supervisor
Evergreen Packaging—Canton Mill Received
828-646-2874
[e-mail]
SFP 1 8 ?014
cc: Landon Davidson,Asheville Regional Supervisor, Division of Water Resources
North Carolina Department of Environment and Natural Resources,Asheville Regional Office Land Quality Section
2090 US Highway 70,Swannanoa, NC 28778 Asheville
1Wverpack1ca1EOHS0HARE1Water FilesWtck's Water FtlesIDWR

er:
T%
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lanr
en p
erot NCDWR Meeting
TakE
_re a�
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daily , February 27, 2014
110 &
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Eiv—
ROY COOPER
MICHAEL S. REGAN
5'eaerory
kVa rlt S. JAY ZIMMERMAN
Wenor
October 26, 2017
Mr. Brian Satterfield, Manager,EHS&S Business Unit
Blue Ridge Paper Products Inc.
P.O. Box 4000
Canton NC 28716
SUBJECT: Compliance Evaluation Inspection e�
Blue Ridge Paper Products Inc. Canton Mill
Permit No.:NC0000272 COp
Haywood County
Dear Mr. Satterfield:
On October 24, 2017, Mikal Willmer, and I conducted a Compliance Evaluation Inspection of the
NPDES Discharge Permit that serves the Blue Ridge Paper Products Inc. Canton Mill WWTP. Based
on records reviewed, on-site evaluation and interviews with staff, the system was determined to be in
compliance with permit NC0000272. An inspection report is attached for your records with findings
summarized. The system and its components appear to be well maintained and operated.
The following additional observations were made at the time of the inspection:
1. Continue to investigate and pursue a solution to the fecal coliform exceedances and associated
chlorine demand. The effort and resources applied to the problem to date,cooperation with the town,
and continued communication with DEQ staff is acknowledged and appreciated.
2. Since the last annual inspection (summer of 2016) staff for the WWTP appear to have been reduced
(departure of the BORC/lab manager). Verify that the facility has adequate staffing resources
available.
The assistance of Nick McCracken, ORC during the inspection was greatly appreciated, as
previously noted, Mr. McCracken is highly knowledgeable about the WWTP and its components. If
there are questions or additional information is needed regarding system operation, maintenance, or
permit questions, please feel free to contact me at 828-296-4500. Please refer to the enclosed
inspection report for additional observations and comments.
State of North Carolina I Env menmt Quahty I Wald Resomaea
2090 U.S.Highway 70 Swam M NC 28778
828 296 4500

Sincerely,
Tim Heim,P.E.
Environmental Engineer
Enc.
cc:Nick McCracken, ORC
MSC 1617-Central Files-Basement
Asheville Files
G:\WR\WQ\Haywood\Wastewater\Industrial\Blue Ridge Paper 00272\Inspections\2017 CEI\CEI letter 10-24-2017.doc

United States Environmental Pmtectim Agency Form Approved.
Washin Ion,D.C.20460
EPA 9 OMB No.2040-0657
Water Compliance Inspection Report Appro6a[expires 8-31-98
Section A:.National Data System Coding(i.e.,PCS)
Transaction Code NPDES. .. yrlmo/day Inspection Type Inspector . Fee Type
1 IN I 2 15 I 3 I NOOOOD272 111 12. .17110123 IT 181cl 191 c l . 201 I
211111111111111111111111111111' 11111111111111 r6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 CA Reserved
67 I�I 70 L_j 71 I I 72 L.J - 73 74 76L Ll_L 1 J I80
Section B:Facility Data
Name and Location of Facility Inspected(For Industrial Users discharging to POT W,also include Entry Time/Date Permit Effective Date
POTW name and NPDES Permit Number)
Oi:00PM 17l10/23 10/07101
Canton Mill
175 Main St ExitTimelDate Permit Expiration Date
Canton NC 28716 04:OOPM 17/10/23 15/06/30
Names)of Onsite Representative(s)/ritles(s)/Phone and Fax Number(s) Other Facility Data
/I/
Nicholas Morgan McCmckeiVORC/828-646-2874/
Name,Address of Responsible Officlal/ritle/Phone and Fax Number
Demo Brovm,PO Box 4000 Canton NC 28716//828-646-2318/ Contacted
Yes
Section C:Areas Evaluated During Inspection(Check only those areas evaluated)
. . Permit Flow Measurement Operations&Maintenance Self-Monitoring Program
Sludge Handling Disposal 0 Facility Site Review Effluent/Receiving Waters
Section D:Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s)and Signatures)of Inspectors) Agency/Office/Phone and Fax Numbers Date
Timothy H Heim - ARO WQY828-29646651
Mika] Willmar M� ARD WD/1828-2984686/ 5-
Signature of Management CA Reviewer Agency/Office/Phone and Fez Numbers Date
t'Q-19- 14--
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.
Page# 1

NPDES yr/mo/day Inspection Type (Cont.) 1
31 Nc0000z z I11 12 .17,1o/23 17 18 I C I
Section D:Summary F of nd m ing/Coments(Attach additional lssheets of narrative and cheddists as necessary)
Tim Heim and Mika[Wllmer of the Asheville Regional Office performed a Compliance Evaluation
Inspection on October 24,2017. Nick McCracken(ORC) assisted with the inspection and facility
review.The facility appeared well maintained and operated,and in compliance with Permit N00000272.
The following additional observations were made at the time of the inspection:
1. Continue to investigate and pursue a solution to the fecal coliform exceedances and associated
chlorine demand.the effort and resources applied to the problem to date,cooperation with the town,
and continued communication with DEQ staff is acknowledged and appreciated.
2.Since the last annual inspection (summer of 2016)staff for the W WrP appear to have been reduced
(departure of the BORChab manager).Verify that the facility has adequate staffing resources available.
Page# 2

.Permit: NC0000272 Oxne-r-Facility: Canton Mill
PFInn Data: 10/23/2017 - - Inspection Type: Compliance Evaluation . ,
Operations&'Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ®'❑ ❑ '❑
Does the facility analyze process control parameters, for ex:MLSS, MCRT,Settleable E ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Housekeeping and facility organization was in good condition at time of the inspection
Permit Yes.No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new 0 ❑ ❑ ❑
application?
Is the facility as described in the permit? ® ❑ ❑ ❑
#Are there any special conditions for the permit? ■ 0 ❑ ❑
Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑
Commerit: New permit application still under review.
Grit Removal Yes No NA NE
Type of grit removal
a.Manual ❑
b.Mechanical
Is the grit free of excessive organic matter? 0 ❑ ❑ ❑
Is the grit free of excessive odor? E ❑ ❑ ❑
#Is disposal of grit in Compliance? N ❑ ❑ ❑
Comment:
Bar Screens Yes No NA NE
Type of bar screen
a.Manual ❑
b.Mechanical
Are the bars adequately screening debris? ❑ ❑ ❑
Is the screen free of excessive debris? N ❑ ❑ ❑
Is disposal of screening in compliance? E ❑ ❑ ❑
Is the unit in good condition? 0 ❑ ❑ ❑
Comment:
Page# 3

..�NN
Permit NC0000272 Owner-Facility: Canton Mill
Inspection Date: 10/23/2017 -Inspection Type: 'Compliance Evaluation
Puma Station -Influent Yes.No NA NE
Is the pump wet well free of bypass lines or structures? �. ❑ ❑ ❑
Is the wet well free of excessive grease? ® ❑ ❑ ❑
Are all pumps present? 0 ❑ ❑ ❑
Are all pumps operable? E ❑ ❑ ❑
Are float controls operable? ® ❑ ❑ ❑
Is SCADA telemetry available and operational? ® ❑ ❑ ❑
Is audible and visual alarm available and operational? ® El ❑ ❑
Comment:
Primary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? N ❑ ❑ ❑
Is the site free of excessive buildup of solids in center well of circular clarifier? E ❑ ❑ ❑
Are weirs level? _ ® ❑ ❑ ❑
Is the site free of weir blockage? ® ❑ ❑ ❑
Is the site free of evidence of short-circuiting? N ❑ ❑ ❑
Is scum removal adequate? ® ❑ ❑ ❑
Is the site free of excessive floating sludge? ® ❑ ❑ ❑
Is the drive unit operational? ® ❑ ❑ ❑
Is the sludge blanket level acceptable? ❑ ❑ ❑
Is the sludge blanket level acceptable?(Approximately'/.of the sidewall depth) ❑ ❑ ❑ 0
Comment: Sludge blanket depth is managed based on torque on drive arm
Aeration Basins Yes No NA NE
Mode of operation Ext.Air
Type of aeration system Surface
Is the basin free of dead spots? 0 ❑ ❑ ❑
Are surface aerators and mixers operational? E ❑ ❑ ❑
Are the diffusers operational? 0 ❑ ❑ ❑
Is the foam the proper color for the treatment process? E ❑ ❑ ❑
Does the foam cover less than 25%of the basin's surface? ■ ❑ ❑ ❑
Is the DO level acceptable? 0 ❑ ❑ ❑
Is the DO level acceptable?(1.0 to 3.0 mgA) ® ❑ ❑ ❑
Comment: DO level on meters ranged between 1.7 and 3.8 mg/L.
Page# 4

Permit NG0000272 Owner-Facility: Canton Mill
Inspection Date: 10.12312017 Inspectlon?ype: Compliance Evaluation
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? ® ❑ ❑ ❑
Is the site free of excessive buildup of solids in center well of circular clarifier? 0 ❑ ❑ ❑
Are weirs level? 0 ❑ ❑ ❑
Is the site free of weir blockage? N ❑ ❑ ❑
Is the site free of evidence of short-circuiting? ❑ 0 ❑
Is scum removal adequate? 0 ❑ ❑ El
Is the site free of excessive floating sludge? 0 ❑ .❑ ❑
Is the drive unit operational? ® ❑ ,❑ ❑'
Is the return rate acceptable(low turbulence)? B ❑ ❑ ❑
Is the overflow clear of excessive solids/pin floc? N ❑ ❑ ❑
Is the sludge blanket level acceptable?(Approximately''/a of the sidewall depth) ❑ ❑ ❑
Comment: Sludge blanket level managed by monitoring torque on drive ar.m
Effluent Pipe Yes No NA NE
Is right of way to the outfall property maintained? 0 ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑
If effluent (diffuser pipes are required) are they operating properly? N ❑ ❑ ❑
r
Comment:
Page# 5

Outfall -Location Limits
Permit: NC0000272 Version:"-1 Status: Expired OFNum' 001 Site:
Parameter !M... A Q-. MAvg W., iD Max;._ M Ge -.. Unit MsmtFr--�Smpi.-. Smpl 3
23,7;8-Tetradil6roditienzo-p-di6xn_34675 0`: 0'04' 0.06 - pg1l . Annually Comp,fEl
-.2,3,7,8:Tetrachlor6ckbenzo-p-di6xn,-34675;- On pgfl Annually C6mp::: 1
,..Adsorbable.organichalides(aox)-79855 0" 1556:9 2822_- ibs/day:WeeKiy, Comp_: E �I`,
BOD,57Day(20Deg.C)-.Corrcentration,7C0310 0• mg4 5Xweek Comp...'.l
BOD,'5-Day(20Deg:C)-.Quantity Daily-QD310: 0, -3205, 10897, Ibs/day 5Xweek Comp..:,E
CHVSTATRE7DayChronicCeriodaphnia=TNP3B 0 f 190 .. percent:. Quarterly Comp- E y!
Coliform,Fecal MFj MFCBrotb 44.5C-31616:. 01, 1 1#1100mliWeekly, - Grab; U N
Coliform FecaIMF,MFCBroth;44-5C 316i6`= 0 400 200" #NODmI Weekly, Grab': E
4:...Coliform,'Fecal tdF,MFC Broth;A4:5C 31616 D _ � #f100ml See Per Grab UD
Color(PT=CO Units)-00080 0": , pt=co See Per Grab: U,D dei2ils.-,
YColor-.00084 D 52000 1052. Ibs/day ,5Xweek Comp-' E'
Color,Apparent(Pt-Co)-0008'1% 0" mg41 2XWeek Grab- U,D j
-Color,Tfn..(Pt-Co)-80114; 0•; 52000 10522 ibslday 5Xweek Comp::,E_ Remove .
jColorjrue.(PtCo)-80114: D, mglli ;2Xweek Grab:; U;D .
-Conductivity-00094', 0, 1 lumho—' 5Xweek Grab,, _ U,D
Conductivty-40094;. 0i1 �urilho_ 5Xweek Grati E` EDP "
Conductivity-,00094 0-. umho_ See Per Grab'- U,D
Fiow,in conduit orthruheatmenfplant=50050: D; mgd 'i5Xweek Grab U'
Flow,in'conduitorthru treatment plant-50050 0; 29,9.: mgd, Confinu--- Recoi'_ E
I
❑Expand VOCParameters
4K Cl6§6
a
42 Parameters found,^ " —"- - - - Ready _- _ _ — - �ID:LTLL� �'

Fnd PerrratQutfall
Cutfall Location ( LimitsT
Permit NC0000272 Version: F07 Status: Expired OF Num: D01 Site:
Parameter Unit Msmt...SmpfT ,Sm-. Effective Dt Expiration._ ,
2:3,7,3-Tetrachlorodibenzo-p-dioxin=34675 61 0.04`,' ; pglf Ahnua'_Comp; E'_ 07/010010
2,37,8-Tetrachlorodibenio-p�oxih,34675 0 pgn! ' Annua Comp:_ 1 0710112010
Adsorbable organic halides faux)-,79855•' 0 1556... . . Ibs/day Weekly Comp._.E 0710112010' ,
BOD;5-Day(20 Deg.C)-Concentration-C031 01 10, mgA - 5 X we-.Comp 1 0710112010 i
BOD,5-Day(20 Deg.C)'=Quantity Daily-QD310 0 : 3205, Ibs/day, 5Xwe...Comp— E 07/01/2Q10 '
CHVSTATREMay.ChronicCerio'daphnia-THP3B0 _ percent QuarL_�Comp:_ E' 0 710 1/2 0 1 0
Coliforni,Fecal MF,MFGBroth,.44.5'C=31616' 0 #I100mI Weekly- Grab` U. 0710 1/2 0 1 7
Coliform;Fecal MF,MF.CBroth,444;5 C-31616, 10. _ #k100mI Weekly;;Grab. : E, 0710112Q10
Coliform;Fecal MF;MFGBroth 44.5,C=31516` 0 #1100mt See P_ Grab: U,D' 13710 112 0 1 0'06130/2017 4
Color(PT-COUnits)-00080; 0 pt-co" .SeeP_ Grab , U,D- 07/01/2010 06130t2017 Patalls..-
Color -00084., - - 0. 52000 Ibs/day, 5X we—Comp E; • 07101f2010 06130/2017
CalorApparent(Pt-Co)=00081 0 mgfi 2Xwe:..Grab . U,D' 07/0112017 , Remove
Col or,TfUe(Pt-Co)-80144: 0 52000 _ Ibs/day: 5Xwe_.Comp E, 07101P2017
Color,'True(Pt-Co)-80114, 0 , mg16 2Xwe: Graff U,D 0710112017';..
Conductivity.=00094 -" 01 5%we:::Grab- U,D' 071D1/201T:,
Conductivity- 0 %weGrali E '`0710112010' Copy_.
Conductivity-00D94 0 umho__.:See P_ Grab- U,D 0710112010-0613012017
Flow,imconduitorthm treatment plant-50050 0 mgd ' 5Xwe'_.Gra6, Ur 07/01/2017' . _
Fl ow;16 con duitoithru treatment plant-50050, 0 29.9, mgd Conlin-.Recor.:. E (1710 112 0 1 0
_ _
III. .... ._ ._.
El Expand VOC Parameters
OK Ciose`*y'
42 Parameters fo . .. --
and j Rea S dy ID:LTLL

Find PermitOutfali' a l
Outfall Location (Limits ,!
� � Num:,
Permit NC0000272 Version: 0' Status: Expired OF Num:,001 Site:
Si
't. Parameter �dAvg ' I t ,_ Und ,Msmt_SmplT.. !Sm_. .EffectiveOt IExpiratio I
- - -
- ^-: , awpin7cai7duit,oreihru;Veaiment;IanU>50Q50 Pill � tngd Seep Recai U?D 071011120,1 06t3Ot20,r`i
E]Hardness;Total(as CaCO3)-00900' 0 mgll i• Quait._ Comp-_ E. 071010010, .
ONiVogen,AminoniaTotal(as N)-ConcenVation-_ 0 ; mgll, 5Xwe Comp:_ E '07/0112010
Nitrogen,Total`Concentration-CO600, .0 mgU .Monthly Comp:-_ E 071D1/2010,
E]Oxygen Demand,Chem.(High Level)(COD)-00_.,0 mgk Weeldy Comp_.E 07l0112010 .
D Oxygen;Dissolved(DO) 00300 0 5 -r mgfl 5'X we._Grab . :D 0710 1/2 0 17`:"
- Oxygen,Dissolved'(DO)-00300: 0 - mgfl. 5Xwe-Grab' U, ,071011201T
0 Oxygen;Dissolved'(DO) 00300 .._ _ 0 _.-; mgll See'P,:� Graff- . U,D,' 0710112010 06130120
L]IOxygen,,Disiolved(DO)40300 0' 6 mgfl, 5 X we_Grab E 071010014-
0 PasslFail Static Renewal May ChronicCeriodap--: 0 passifail Quart_. Comp_ E - 071010010<
Pentachlorophenol-,39032 0 Ibslday Quart_ Comp_"E '0710112010r
pH-0040D 0' 96 , -. su _.. 5Xwe Grab E . ' 07/01/2010
Phosphorus;Total(as P)'-Concentration-CO665-0 mgll Monthly Comp' E ,• 0710112010,' k Remove
0 Selenium,Totai(as Se) ',01147 ' 0 ugfl Annua Comp_ E :07101P1010
OSolids;TotaiSuspended-Concentration-0053D,0 mgA' 5Xwe Comp:_ 1' ,07101Y201Q !1
O Solids'Total Suspended-Quantity Daily' QD530 0 12549 . _ Ibslday, 5Xwe_.Comp_ 6 . 0710 112 0 1 0
0 Temperature,Water Deg.Centigrade,-00010 . 0, deg c 15Xwe__Grab U,D 07/01/2017
O Temperature,Water Deg.Centigrade.-00010• ' 0 deg c . See'R:: Grab U,D` 0710112010,0613020
0 Temperature;Water Deg.Centigrade,-00010 Dj deg c 5Xwe_ Grab' E 0710112010; e
_—_ _.._
❑Expand VOC Parameters.'
OK - Close,-
_--- --- - ----- --- -- - --- -- -- -- - :,LTLL
f- - - - - — --- - --- --_- —_.
42Parametersfound --! Ready -- �I�.._____ SID
—

Find PermitOutiall;`� `
Outfall Location ( Limits,;;
Permit: NCO000272 Version: Status: Expired OFNum' 001 Site:
1._ Parameter Und .Msmt Effective Dt Expiratio:
owlfnTconduitortttru�treatmentl`13nt 50050 0,i Ow EEO See?ff R2COr.;: ga 0710112010$46130120
Hardness;TotaL(as CaCD3)-00900i„ ._ 0 mgAr Quart- Comp--E 0 7/0112 0 1 0, .
ONitrogen;AmmoniaTotal'(asN)-Concentrabon.-_ 0 mgfl', 5Xwd—Comp.-,E ' 07101P1010-,
0 Nitrogen„Total-Concentration'=C0600• 0 mg/I . 'Monthly.Comp_.E 071010010
Oxygen'Demand,Chem.(High Level)(COD)-00_. 0 mg/1 Weekly. Comp_ E . ' 07/0112010.
E]Oxygen;Dissolved(DO)-00300.- 0 5 ;mg11 5Xwe Grab : :D ' 07/DMO17--
DOxygen;Dtssolved(DO)-00300 0 mgfl,. 5Xwe Grab' - U 07101f20171
Oxygen;Dissolved(DO)-OD300 0 - mg/l. : See P Grab I-- 'U,D' 07ID112010'06130/20
0
EdO4gen;Dissolved(DO)-00300. 0 .1 61 1 mgfl. 5Xwe Grab E 0710=010 .
OPasslFail Static Renewal 7Day Chronic Ceriodap�0 passffailQuwt_. Comp_-E 071D112010 �} { Details
Pentachl6rnphenot-39032 :0 Ibsfday QuajL Comp'-':E 07101/201D S
PH,, 00400 0 96 su 5Xwe Grab E '0 710 11201 0: .
5 Phosphorus,Total(as P)-'Concentration;=C0665.0, mgA, Monthly Comp_,E ,0710112010, 11 Remove
Selemom-Total(as Se) 0114T 0 ugfl; , Annua Comp_ E 07101/2010, —
El Solids,Total Suspended 'Concentration,-00530; 0 mgll 5 Xwe Comp 14 07101/20104
EY]Solids,Total'Suspended-Quantity Daily-QD530. 0 12549 Ibslday- 5X we—Comp E 07/0112010.1 C4�"
0 Temperature',WateiDeg,Centigrade 00010 : 0 -_ degc 5Xwe:_Grali' U,D",07/01f2017
El Temperature,Water Deg.Centigrade-00010'• 0 Idegc See'P,_ Grab u,D 0710 112 0 1 0.'06/30120
OTemperature,Water Deg.Centigrade-000.10•, 0 degc _ 5Xwe._Grau ;E 0710112010..
i
❑Expand VOC Parameters
42 Parameters found. Ready J I SID:LTLL

Find PermitOutfall__' NNEW
tea. tom.
Outfall r LocationLimiTs?
Permit FC0000272 Version: Status_ Expired OFNum: D1 Site:
Parameter Unit ;Msmt .Smpl T.. ;Sm.. _E fedive nt Expiration .. Phased Flory
ttorltimltreatmenti lant_50050 0)N i i R mg(t See PA Recor 0!51 07/01120,10.06130120;17�t , . _.RA
I(as CaCO3)-00900 0 mgh, Quart_ Comp._: E 07ID112010
oniaTotal(asN)-,Concentration-_ 0 mg8, 5X we—Comp-' E 07M112DIT
-Concentration-'C0600 10 mgA,: Monthly Comp_., E ;0710112010,
id,Chem:(High Levep(GOD)-00,_ 0 mg1I4 Weekly Comp- E • 0 710 112 01 0
Ived'{130)40300 0 5 - mgll. 5Xwe=Grab D ' ;07/0112017
Ived(DO)-00300 0 mgll:: 15X we—Grab U '07101/2017,
Ived{DO)'-00300" 0 - mg1l: 'TSbdP— Grab• _ UA, 071 2010 06/3012Q17 _
Ived{DO)-00300' - 0 6 ^ mglt' 5Xwe:_.Grab' E 7 0710112010>
T
0 pass/fall Quart. Comp E 0710112010;.
e o1n39032 ayChrorncCenodap_;0 ibslday Quart Comp E i07101120105 €� Remov
-10 96,1, su 5X we_Grab E = 0710112010,
otal(As P)-Concentration-00665 0- mglf:, Monthly Comp— E '07/0 112 0 1 0+ I
I (as Se),01147 ' 10 ugll - Annua Camp E ;07/01/201 Q-
uspended Concentration-00530°`0 mgil,: 5Xwe-_C6mp I ,0710112010;:
uspended=Quantity Daily-QD530 0 12549 Ibs/day 5Xwe.-Comp E .0710112010: Cygy"
aterDeg.Centigrade-00010 0 deg 5Xwe_Grab, U,D, 07/0112017 ;
aterDeg.Centigrade-00010 0 degic See,P- Grab, U,D; 07/01/2010 0613012017'
aterDeg:Centigrade. 0001T; 0 deg SXwe...Grati! E •.07101120M
❑Expand VOC Parameters
gK Close p
42 Parameters found. Ready J� I aID_LTLL

Find Permitwi l
Outfall r Location r,9fffs-
Permit C0000272 Version: FO I Status: Expired OF Num: D01 Site:
I... Parameter C. MAvg '_U i_ -Unit ;tvlsmt...SmpIT 'Sm...;EfectiveDt 'Expiratia 4
-
0 Oxygen Demand;Chem.(High Levely(COD)-00_ 0( mgll:. ,Weekly_.Comp_ E -07f01/2010
❑oxygen,Dissolved(DD)-00300 01 5'.. mgB4 ;5X We_Grab-'� D. ' 0710112017 .
B Oxygen,Dissolved(DO)-00300- 10 mg/l` 5Xwe.!.Giab U - ovoi 2017
Oxygen,Dissolved(DO);00300 :0 mgfh See P_ Grab U;D 0710112010'06/30/20
Oxygen;-Dis"solved(DO)-00300. 10 6 " mgB 5Xwe Grab'- E -07101P1010 ,
PasslFailStaticRenewal70ayChromcCeriodap-0, , passffailQuart: Comp..: E 071010010,' add...
Pentachlorophenol'-39032 N1 , 111 Ibsfday:Quart- Comp E 07/0112010 ,
pH=A0400- 0 96:. su, ZXvve Grab =.E r07101f2010'
❑Phosphorus,TOtal(asP)7Concentration=C0665 0 1 mgn Mohthlyj Comp:a E - .07t0112010'. Details
E]ISelenium,T6tal(asSe)-.0-1147', "0 1 ugh Anna Comp_ E 0 710112 0 1 0:.
OSolids,TotalSuspe6ded-ConcentraUon-=CO530' 0 - nigh', 5Xwe Comp I' D71DV201D.,
Solids,Total Suspended-Quantity Daily-QD530 .0 12549 Ibsfday, 5XweL Comp- E. 07f0112010 � ' Remove
Temperature,WaterDeg.Centigrade=00010 �0 degc,i 5Xwe._Grab - U,D:071012017
❑Temperature,Water Deg.Centigrade 00010' 0"� � deg c' :See P_ Grab U,D 071011201D*06130l20 + i
em eratur6 Watet.De�CCenti Tade'.00010 0J 1 deg c 5%iw- Grab E OM1120A01 r i Copy`_
❑Tnchlorophenol-81848 ' 0 . Ibsfday_Quart_, Comp_�E• 07/01/2010 - !
❑Turbidity,HCH Turbidimiter=00076 0 ntu See P Grab . U O . 07t0112010, 06130120
0 Turbidity;HCH Turbidimiter=00076'. 0 ntu 2 X m Grab— i E 07/01=10'06/30120 t i s{
0 zincTotal.(a:sZn)-01092 Lugh, Quart Comp
E 07101f20104 l
❑Fxpand VOC Parameters.
OK ""clo"se"•�`'
42 Parameters found. Ready: r ID.LTLL

Find PermitOutfall' lJ
Outfall r Location limits ;''.
Permit: NC0000272 Version: 07 Status: Expired OF Num: 001 Site:
Parameter j. Avg i J. Unit ;tvlsmt... SmpIT::.;Sm_ EffectiveQt Expiration...`Phased Flow
d,Chem:(Higfi Level)'(COD)-00— 0 mg4. •Weekly Comp,. E -07101/2010
Ned(DO)-00300 0 5'. mgll 5Xwe._Grab D 0710112017
Ned(DO)-00300 0- mgfl 5Xwe."Grab U 07101/2017
Ived(DO)-00300 0 mglb 'SeeP_.. Grab U,D 07/0112010 06/30/2017
Ived'(00)-00300 0 6, mg/t 5Xwe._Grab E 0 710 1/201 0
c Renewal May ChronicCeriodap... 0 passTfail QuaIL_-Comp.:. E -07(0112010 Add...
en6l-39032 D bs/day Quart' -Como— E - 07/01/2010 I
0 -I 1 98 su 5Xwe:_Grab R-. 0710112010
12010
otal(as P)-Concentration-00665 0 mgH Monthly Comp_. 12010.. ! Details...
I(as Se)-01147 0 ugfl Annua._Comp_. 12 0 1 0
uspended-'Concentration,C0530' 0 mgA, 5Xwe-.Comp_. /2010 rt
uspended-Quantity Daily-OD530 '0 12549 _ Ibslday 5Xwe.cComp_. 112010aterDeg.Centigrade-00010 -0 degc 5Xwe._Grab 1/2017
' Grab 1/2010 06f30f2017
ater De Cenh rade00010 0 deg c y See -e Grab R 12010y
g• 9 9
1a81v ?[Gents rade.-00040 Di = bstda 'Quart. Comp_ E 10710112010
Turbidimiter-.00076 D ntu. See .. 1
Grab iE 10710112010 06/3012011 1•
Zn)-01092, .0 1.1 jugA Quart_ Comp_. JE 0 710 1/2 0 1 0
❑Expand VOC Parameters
i OK Clcrse
42 Parameters found

PV
evergreen Conlon o(Fka
pack-alging
December 11e 2017 'I
z,
MnFIED
Uivlsion�i�:u.::r fic:.,b�rcas
MAIL
Return Receipt Requested DEC 1 5 2017
Landon Davidson W dnr O "w R^^lonr!OnPrations
Asheville Regional Supervisor —
Division of Water Resources
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton,Haywood County,North Carolina
Daily Maximum Fecal Coliform 12/1/2017
NPDES Permit:NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
December I"at approximately 9:20 am and was picked up and delivered by laboratory courier.
Proper sampling procedures were followed by plant personnel. The result of the analysis showed
a value of 517 MPN per 100 ml. The fecal coliform excursion on December 11 was limited to
that sample parameter and day. A phone call was placed to the NCDEQ regional office on
December 111 to discuss the results once discovery had been made.
After the value from the laboratory was observed, all systems in the treatment facility were
inspected. 'they were found to be operating correctly leading up to and during the time of
sample.
In an ongoing effort to identify the potential shortcomings to the Town of Canton's (TOC)
Chlorination system,EPI has been slowly backing off its supplemental feed of Sodium
Hypochlorite both at the WTP and at the Landfill locations. During the past two weeks leading
up to this event, the TOC believed they have identified a potential cause to their chlorination
depletion. A closed landfill,previously operated by IP,having a large drain line that is sending
leachate to the town's sewers was believed to be a potential cause. The town has been in contact
with IP representative's to gain permission to access this line to collect samples of this leachate
and has done so. Preliminary data suggests that it contains ammonia based compounds which
are chlorine scavengers.
INYC Intlrof Y�S.oYtn� ::FH.+,i^n Nm+a,p.Wf":<fA0
tWWrpeckiC8W0HSISHARE ftW FYIesWbYs Wslsr Fri#M

VNCDWR Page 2
While this investigation was on-going, EPI shut off all supplemental hypo feed at the waste
treatment plant but continued to feed at the landfill when leachate was pumping into the TOC's
chlorination system in order it determine the effectiveriess of the Town's system. However,
upon receipt of the most recent laboratory data of fecal coliform weekly exceedance, EPI
immediately instituted the following: Re-introduce sodium hypochlorite treatment at the waste
treatment facility.
When EPI began to investigate the timeliness of the exceodance, what was identified was for a
period of approximately ten days there was sporadic chlorine residual readings even when
landfill leachate was not pumping which is atypical. EPI spoke to TOC leading up to this event
about the possibility of illegal dumping which might be causing the system to be depleted at
varying times of the day. The TOC agreed to investigate truck locations where this could occur.
When EPI received the data on the failed test and communicated this with the TOC, it was
disclosed then that the TOC performed work on the'"r-valve by opening it up to allow the
solids to escape. This work occurred on 11/20 or 11/21 the TOC indicated. Giver the solids
build up for several months in this line,EPI believes that the slug released into the system most
likely was a significant contributor to the exceedance measured. EPI is working with the TOC
on measures to prevent future re-occurrmces and also identify next steps in the identification of
the cause(s)of the shortcomings of the chlorination system EPI requests that enforcement
discretion be continued as this project continues to identify solutions to improve effective
treatment.
We will continue to work closely with the Town to identify the cause(s)to the chlorination
depletion to their system which affects EPI's ability to comply with their fecal coliform
permitted limits.
If you have any questions or comments, please feel free to contact us at your earliest
convenience.
Sincerely,
Brian Satterfield
EHS Manager
Evergreen Packaging—Canton Mill
828-646-2381
Aa everpack.com
cc:

VNCDWRPagc3
Mr.Tim Heim
Environmental Engineer,Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S.Highway 70
Swannanoa,NC 28778
f
i

evergreen 0 Coat" Office
packaging
December 11,2017 bi cn a v o,
CERTIFIED MAIL
Return Receipt Requested DEC 1 4 2017
Landon Davidson Water Quality R-olonal Operations
Asheville Regional Supervisor a,ne.:'i.,^.,�,,,.,I�H;,,e
Division of Water Resources
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton MIiI,Canton, Haywood County,North Carolina
Daily Maximum Fecal Coliform 12/1/2017
NPDES Permit:NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
December 1"at approximately 9:20 am and was picked up and delivered by laboratory courier.
Proper sampling procedures were followed by plant personnel. The result of the analysis showed
a value of 517 MPN per 100 ml. The fecal eoliform excursion on December 1°was limited to
that sample parameter and day. A phone call was placed to the NCDEQ regional office on
December l I'to discuss the results once discovery had been made.
After the value from the laboratory was observed, all systems in the treatment facility were
inspected. They were found to be operating correctly leading up to and during the time of
sample.
In an ongoing effort to identify the potential shortcomings to the Town of Canton's(TOC)
Chlorination system,EPI has been slowly backing off its supplemental feed of Sodium
Hypochlorite both at the WTP and at the Landfill locations. During the past two weeks leading
up to this event,the TOC believed they have identified a potential cause to their chlorination
depletion. A closed landfill, previously operated by IP,having a large drain line that is sending
leachate to the town's sewers was believed to be a potential cause. The town has been in contact
with IP representative's to gain permission to access this line to collect samples of this leachate
and has done so. Preliminary data suggests that it contains ammonia based compounds which
are chlorine scavengers.
IWwrpecfteIEOHSISHAREIWefer FBea~s Wafer FOeeM

NCDWR Page 2
While this investigation was on-going, EPI shut off all supplemental hypo feed at the waste
treatment plant but continued to feed at the landfill when leachate was pumping into the TOC's
chlorination system in order it determine the effectiveness of the Town's system. However,
upon receipt of the most recent laboratory data of fecal ooliform weekly exceedance, EPI
immediately instituted the following: Reintroduce sodium hypochlorite treatment at the waste
treatment facility.
When EPI began to investigate the timeliness of the exceedance,what was identified was for a
period of approximately ten days there was sporadic chlorine residual readings even when
landfill leachate was not pumping which is atypical. EPI spoke to TOC leading up to this event
about the possibility of illegal dumping which might be causing the system to be depleted at
varying times of the day. The TOC agreed to investigate truck locations where this could occur.
When EPI received the data on the failed test and communicated this with the TOC, it was
discloses]then that the TOC performed work on the"r-valve by opening it up to allow the
solids to escape. This work occurred on 11/20 or 11/21 the TOC indicated. Given the solids
build up for several months in this line,EPI believes that the slug released into the system most
likely was a significant contributor to the exceedance measured. EPI is working with the TOC
on measures to prevent future reoccmtmmces and also identify next steps in the identification of
the cause(s) of the shortcomings of the chlorination system. EPI requests that enforcement
discretion be continued as this project continues to identify solutions to improve effective
treatment.
We will continue to work closely with the Town to identify the causes)to the chlorination
depletion to their system which affects EPI's ability to comply with their fecal ooliform
permitted limits.
If you have any questions or comments, please feel free to contact us at your earliest
convenience.
Sincerely,
Brian Satterfield
EHS Manager
Evergreen Packaging—Canton Mill
828-646-2381
_ldw evelpack.com
cc:

NCDWR Page 3
W.Tim Heim
Environmental Engineer,Asheville Regional Office
North Carolina Department of Enviromnent
&Natural Resources
2090 U.S.Highway 70
Swannanoa,NC 28778

ROY COOPER
MICHAEL S. REGAN
N, I a Srmtoiy
Water Resources S. JAY ZIMMERMAN
ENVIRONMENTAL OUALITV Mmrw
January 20,2017
Stephen J Hutchins, General Manager
Blue Ridge Paper Products Inc
175 Main St
Canton,NC 28716
Subject: Payment Acknowledgement
Canton Mill
Permit NC0000272
Case No. LV-2016-0251
County Haywood
Dear Mr. Hutchins:
This letter is to acknowledge receipt of payment in the amount of$366.62 received from you on
01/20/2017. This payment satisfies in full the above civil assessment(s)levied against the subject facility,
and this case has been closed. Payment of this penalty in no way precludes future action by this Division for
additional violations of the applicable Statues, Regulations,or Permits.
If you have any questions,please contact Wren Thedford at 919-807-6397.
Sincerely,
-OR�
Wren Thedford
cc: Central Files
NPDES
Asheville Regional Office
E
Dources2017al Operatlonaal 010ce
State of North Carolina I Eeviror mental Quality I Water Resumes
2090 U.S.70 Highway,Swannanoa,NC 28778
828-2%4500

ROY COOPER
Gavcrlw
N.-c-
MICHAEL S. REGAN
Serretary
Water Resources S. JAY ZIMMERMAN
aNV1a %N TALOUA VTV Q'IY w
January 20,2017
Stephen J Hutchins, General Manager
Blue Ridge Paper Products Inc
175 Main St
Canton,NC 28716
Subject: Payment Acknowledgement
Canton Mill
Permit NC0000272
Case No. LV-2016-0252
County Haywood
Dear Mr. Hutchins, General Manager:
This letter is to acknowledge receipt of payment in the amount of$616.62 received from you on
01/20/2017. This payment satisfies in full the above civil assessment(s)levied against the subject facility,
and this case has been closed. Payment of this penalty in no way precludes future action by this Division for
additional violations of the applicable Statues, Regulations, or Permits.
If you have any questions,please contact Wren Thedford at 919-807-6397.
Sincerely, J
U4,
Wren Thedford
cc: Central Files Woo..
NPDES
Asheville Regional Office
JAN 2 4 2017
Water OueRty RegWW Opumor
Ashevihe Regional ORbe
State of North Carolina I Enviro ntal Quality I Water Resources
2090 U.S.70 Highway,Sw�oa,NC 28778
828-2%-4500

®/ Canton Office
evergreen
175 Main Street Canton, NC 2871
packaging a Dces
APR 1 7 2011
April 13, 2017
Certified Mail: 70161370 0000 5175 3095 water oaal ty Regtonet oPeraitons
Return Receipt Requested Asheville Re tonal O1fIce
Tim Heim
North Carolina Department of Environmental Quality
Division of Water Resources
2090 US 70 Highway
Swannanoa,North Carolina 28778-8211
Subject: CERCLA RQ—Sodium Hypocblorite(15%) Release
Blue Ridge Paper Products Inc. d.b.a. Evergreen Packaging- Canton Mill
National Response Center notification provided Sunday,April 9,2017
Dear Mr. Heim,
Evergreen Packaging(EPI) is providing written follow-up notification per EPCRA Section 304
— Emergency Planning and Community Right-to-Know Act in response to a CERCLA RQ
release that occurred on Sunday, April 9, 2017 at the Canton Mill located at 175 Main Street,
Canton, North Carolina 28716.
Following the release, the National Response Center was contacted and provided initial details
of the release.
Update information:
• Chemical Name: Sodium Hypochlorite(15%)
• Extremely Hazardous: No—CERCLA RQ— 100 pounds
• Quantity Released: 663 gallons (estimated)
• Release Time and Duration: First noticed at 3:00 am Sunday, April 9, 2017 following a
completed fill of the tank at 3:59 pm Saturday, April 8, 2017.
• Release to the Environment: Release was to land with no release to surface water.
• Associated Risks: None
• Proper Precautions: Area cordoned off to limit access until remediation began.
• Contact Person(s): Wanda Webb — [phone] (office) / [phone] (mobile)
and/or John Frazier(828) 646-2028 /[phone] (mobile)
• Response Actions: Free liquids were vacuumed and placed in WWTP containment for
processing. Soil(s) were removed to berm containment and covered. Samples were
pulled to determine disposal method.
• Medical Attention Required: None /
fresh by design /
Uona Brrslness in GaWto-nio a,E-+erg,.en 0everao,Pac as nr.

Should you have questions or need clarification of the information provided, please contact me
at your convenience.
Respectfully,
John R. Frazier Jr.
Landfill Supervisor
iohn.fraziera,everpack.com
office: 828.646.2028
cell: 828.412.2471
CC:
Matthew Claypool—EPI
Brian Satterfield—EPI
Wanda Webb - EPI
Ryan Adams—NC SERC
Greg Shuping—Haywood County LEPC
Stan Aiken—NCDEQ/DEMLR
Shawna Riddle—NCDEQ/DEMLR
File—CMRRR JRF 01-17 MISC

evergreerl'.0 Canton Office
packaging 175 Main Street• Canton, NC 28716
September 5, 2017 NMM#57-17
CERTIFIED MAIL
Return Receipt Requested
7099 3220 0007 0371 4866
RECEIVED
Landon Davidson DMsion of Water Resources
Asheville Regional Supervisor
Division of Water Resources SEP 8 2017
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office water Quality Regional Operations
Asheville Reabnal Office
2090 US Highway 70
Swannanoa, NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton,Haywood County, North Carolina
Daily Maximum Fecal Coliform 7/14/2017
NPDES Permit: NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
7/14 at approximately 10:30 am and was picked up and delivered by laboratory courier. Proper
sampling procedures were followed by plant personnel. The result of the analysis showed a
value of 495 MPN per 100 ml. The fecal coliform excursion on 7/14 was limited to that sample
parameter and day. A phone call was placed to the NCDEQ regional office to discuss the results
once discovery had been made.
After the value from the laboratory was observed, all systems in the treatment facility were
inspected. They were found to be operating correctly leading up to and during the time of
sample.
In an effort to increase chlorine contact time for the incoming wastewater, influent piping
modifications have been under construction by the Town of Canton. For the period leading up to
the time of sample, the Town had been working to install a 16"tee fitting and stainless butterfly
valve to their portion of piping that discharges into the W WTP low lift. Under typical operation
the Town's chlorination system feeds—250 lbs/day of chlorine to the incoming wastewater.
Because of the proximity of the Town's construction workers to the pipe opening and the /
fresh by design,. /
I1everpacklcalEOHSISHARE1Water FilesW/ck's Water Files DEQ ///

Kb Sall

NCDWR Page 2
potential dangers associated with off-gassing of chlorine from the incoming wastewater, it was
decided to reduce the chlorine feed by 60%to—100 lbs/day while workers were present. This
decision made by the Town of Canton's Safety Coordinator. W WTP operators were unaware of
the reduction in chlorine feed from the Town's system during this time. The mill however,
maintained its supplemental feed of sodium hypochlorite throughout the construction phase of
this project.
Attached with this letter is a written statement from Town Manager,Jason Burrell stating what
actions were taken during construction. In an additional separate letter also included, Mr. Burrell
states that construction to the influent piping is now complete. We will continue to work closely
with the Town to monitor the new piping modifications and to observe the effect it has on the
treatment process.
If you have any questions or comments,please feel free to contact us at your earliest
convenience.
Sincerely,
Nick McCracken
Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCracken(&evemack.com
cc:
Mr. Tim Heim
Environmental Engineer, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778

CANTON
�--� NORTH CAROLINA
OFFICE OF THE TOWN MANAGER
TO: Evergreen Packaging
Brian Satterfield
PO Box 4000
Canton, NC 28716
FROM: Jason Burrell; Town Manager
Town of Canton
58 Park Street
Canton, NC 28716
SUBJ: Chlorine modification during T and value installation
August 29'h, 2017
Gentlemen,
I hope this letter finds each of you well. I did want to report that for sporadic periods of time in the
course of installing the T and valve in the above referenced low-lift pump station it was determined by
Richard Hodge, Town of Canton Water/Sewer Superintendent and Safety Coordinator,that it was
necessary to cut back the level of gas chlorine being fed at this location slightly in an effort to ensure
safety of the employees completing said work. These periods ranged from 1—2 hours on no more than
8 occasions while work was begin performed. The level of chlorine normally and consistently fed is
equivalent to 250 pounds(Ibs) of chlorine. As far as I am aware,when chlorine was idled back it was
done to a level that did not drop below 100 pounds (Ibs) and for as short of periods in time necessary to
allow chlorine built-up to dissipate to an acceptable level, ensuring that the environment was safe for
employees to perform said work.
If you have any further questions related to the contents of this letter or would like to schedule a
conference call next week to discuss next steps, please feel free to contact me.
Respectfully,
Jason Burrell
Town Manager
58 Park Street.Canton, NC 28716
1 828.648.2363 F 828.646.3419
www.cantonnc.com

� CANTON
NORTH CAROLINA
OFFICE OF THE TOWN MANAGER
TO: Evergreen Packaging
Stephen Hutchins& Brian Satterfield
PO Box 4000
Canton, NC 28716
FROM: Jason Burrell;Town Manager
Town of Canton
58 Park Street
Canton, NC 28716
SUBJ: Action Plan Status: Fecal Coliform Investigation&Control
August 25", 2017
Gentlemen,
I hope this letter finds each of you well. On behalf of the Town of Canton, I wish to report that while
faced with a number of unforeseen obstacles,the Town of Canton has completed the proposed and
committed to chlorine contact modification work on the existing gravity sewer tie-ins from the point of
chlorination to the discharge into Evergreen Packaging's Low Lift Pump Station.
It would now be my recommendation that Evergreen Packaging communicate to the Regional Office of
the North Carolina Division of Water Resources(NCDWR)that said chlorine contact modification work
has been completed and that monitoring/testing to determine its effectiveness can begin.
If you have any further questions related to the contents of this letter or would like to schedule a
conference call next week to discuss next steps,please feel free to contact me.
Respectfully,
r7
Jason Burrell
Town Manager
58 Park Street.Canton,NC 28716
T 828.648.2363 F 828.646.3419
www.cantonnc.com

l
ROY COOPER
ammor
MICHAEL S. REGAN
. Se�ttrry
Water'Resaurces S.JAY ZIMMERMAN
vM"NkiNrALuueim Dfrectar
Certified Mail # 7015 1520 0003 5463 1674
Return Receipt Requested
January 26, 2017
Stephen J Hutchins, General Manager
Blue Ridge Paper Products Inc
175 Main St
Canton, NC 28716
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2017-LV-0066
Permit No. NC0000272
Canton Mill
Haywood County
Dear Permittee:
A review of the September 2016 Discharge Monitoring Report (DMR) for the subject facility revealed the
violation(s) indicated below:
Limit Exceedance Violation(s):
Sample Limit Reported
Location Parameter Date Value Value Type of Violation
001 Effluent Coliform, Fecal MF, MFC Broth, 9/16/2016 400 985 Daily Maximum Exceeded
44.5 C(31616)
Remedial actions, if not already implemented, should be taken to correct any noted problems. The Division of
Hater Resources may pursue enforcement actions for this and any additional violations.
State of North Carolina I Environmental Quality I Water Resources
2090 U.S.70 Highway,Swannanoa,NC 28778
828-296-4500

If you have any questions concerning this matter, please contact Janet Cantwell of the Asheville Regional
Office at 828-296-4500.
Sincerely,
G. Landon Davidson, P.G., e upervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Asheville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
G:\WR\WQ\Haywmd\WasMater\IMus 1\8h�Rk1ge Rape 00272\ROV-2017-LV-0066.rtf

Canton Office
evergreen./packaging 175 Main Street• Conlon, NC 28716
July 21, 2016 NMM#35-16
Landon Davidson
Asheville Regional Supervisor
Division of Water Resources
North Carolina Department of Environmental Quality
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill,Canton, Haywood County,North Carolina
Notification of Change in Responsible Official
NPDES Permit: NC0000272
Dear Mr. Davidson:
This is to inform you of a recent change in the responsible official at our facility.
As of July 6, 2016, Mr. Dane A. Griswold is no longer the General Manager of Blue Ridge Paper
Products' Canton and Waynesville Operations. Mr. Michael P. Ferguson has been assigned this
responsibility on an interim basis while a successor to Mr. Griswold is identified. Mr.
Ferguson's contact information is as follows:
Mr. Michael P. Ferguson
Acting General Manager—Canton and Waynesville Operations
Blue Ridge Paper Products, Inc.
175 Main Street
PO Box 4000
Canton,NC 28716
Phone(direct): 828-646-2461
We will update your office as soon as possible with any changes in this information.
Respectfully,
fresh by design .
IleverpacklcalEOHSISHARE1Water FilesWick's Water Files DWR

NCDWR Page 2
Nick McCracken
Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCracken()evemack.com
cc:
Mr. Tim Heim
Environmental Engineer, Asheville Regional Office
North Carolina Department of Environmental Quality
2090 U.S. Highway 70
Swannanoa,NC 28778

PpevergreenAM Canton Office
packaging 175 Main Street• Canton, NC 28716
February 13, 2014 NMM#13-14
CERTIFIED MAIL
Return Receipt Requested RECEIVED
7099 3220 0007 0371 4415 Divlslon of Water Resources
Landon Davidson F E B 1 8 2014
Asheville Regional Supervisor
Division of Water Resources Water Quality Regional Operations
North Carolina Department of Environment Asheville Regional Office
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill,Canton,Haywood County,North Carolina
Daily Maximum Secondary Effluent Color 1/10 & 11/2014
NPDES Permit: NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring results required by NPDES
permit Standard Conditions Section E: 6(a). The secondary effluent color samples taken on
1/10/14 and 1/11/14 were shown to have exceeded the permitted daily maximum value of
105,250 lbs/day. Proper sampling procedures were followed by plant personnel. The result of
the analyses showed a value of 125,731 lbs/day for 1/10 and 129,856 lbs/day for 1/11. All other
effluent parameters were within permit requirements. A phone call was placed to the NCDWR
regional office to relay information about the current conditions at the mill.
On Tuesday 1/7, the Canton area experienced subzero temperatures (-6oF). As a result of the
extraordinary low temperatures, a level cell in the Deaerator Tank froze at approximately 6:30
a.m., sending a false"high level"signal to the DCS system. As a result of the false signal, each
boiler ran out of feed water causing the boilers to trip off. Additionally, the mill experienced a
loss of power and a cold mill shutdown.
During the process of restarting the mill, elevated color material was sent to the sewer and
captured in the mill's extensive sump system for subsequent processing. This continued until all
available spill tanks were full. The continued freezing temperatures made it difficult to get the
mill back to steady operations., Lines typically used to transfer spill materials were frozen and
\\everpack\CTN Shared\EOHS\Shara\Water Files\Nick's Water Files\DWR

FCPDWR Page 2
inoperable. Moreover, Evergreen personnel were diligent in their efforts to minimize color and
are confident that no environmental impact resulted from the excess color. Additional mitigating
measures included utilizing the WWTP spare clarifier to capture material that could not be
processed within the mill, and using polyamine to help with the elevated color.
The conditions causing the cold mill shutdown and release of color in excess of the daily
maximum limit on 1/10 and 1/11 were beyond the control of the Canton Mill.
If you have any questions or comments, please feel free to contact us at your earliest
convenience.
Sincerely
Nick McCracken
EHS Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCrackenna,everpack.com
cc:
Mr. Jeff Menzel
Environmental Specialist,Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
C. File—Water Notebook
Internal distribution -
D. Griswold
M. Ferguson
C. Chiles
B. Covington

P Fpever7green,.4 Canton Office •ackaging 175 Main Street• Conlon, NC 28716
December 13,2013 uOilOalad ia}mb\y
80l)}0 jt?UO1698 BjjlAGLIS\ NMM#101-13
Certified Mail-Return Receipt Requested
7011 3500 00018863 8003 E ^ i 330
Landon Davidson 4 3 n 3
Asheville Regional Supervisor _ .
338
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc.dba Evergreen Packaging
Canton Mill,Canton,Haywood County,North Carolina
Request to Rescind NOV;NOV-2013-LV-0677
NPDES Permit:NC0000272
Dear Mr.Davidson:
On November 5,2013 we received a Notice of Violation(NOV)in regards to a daily maximum value for fecal
coliform. We respectfully request that the NOV be rescinded.
After a formal discussion,at the regional office on November 141^,you requested additional information
about the circumstances surrounding the prior and most recent test values. Please see below for an
explanation of the events that occurred for elevated fecal coliform test results in 2012 and 2013.
On June 26,2012 an elevated fecal coliform test value was reported. Laboratory results showed a geometric
mean of 477 colonies/100ml. We were unable to determine the cause of the elevated value. A complete
walk through of the treatment system was conducted. The Town of Canton owns and operates a
pretreatment chlorination system.This system is owned and operated as part of an agreement between the
Town and Mill. This system was checked and appeared to be functioning as designed.
On August 14,2012 the Mill received an elevated fecal coliform value of 600 colonies/100ml. At the time of
discovery,we were unable to determine a cause for the elevated value. A complete walk through of the
treatment system was conducted. The Town of Canton,once again,checked the pretreatment chlorination
system,and it appeared to be functioning as designed without any downtime in operation. After review,it
was determined the results were a laboratory anomaly.
On November 20,2012 and November 27,2012 two additional test results showed values of 600 colonies/
100ml and 6000 colonies/ 100ml,respectively. During this time,a construction upgrade of the Champion
Drive force main and Bridges pump station was occurring. Construction crews were onsite installing the
force main working towards the W WTP low lift The last section of the new piping occurs at the tie-in to the
South force main before entering the head of the plant This is also the location of the Town of Canton's
pretreatment piping. As crews excavated,they discovered that the chlorinated water line that pretreats the
Town of Canton's wastewater had broken in three sections underground. The HDPE pipe was installed in
fresh by design
Z:\Share\Water Files\Nick's Water Files\DWQ\NOV Resc Ltr 816213 NMM30113.doc

r
1-13
age 2
3
sections with each new section welded to the other. It appeared the pipe had contracted,pulling these welds
apart Along with our notification,we submitted a letter from the Town of Canton explaining the breaks in
the line and also their repair. With this discovery,we determined the Town's chlorinated waterline had
been broken for some time which resulted in the elevated fecal coliform results in June and August that are
discussed above.
In consultation with the Town of Canton and their consultants,we collectively decided to improve the
current pretreatment design of the system. A single run of HOPE piping would be used to prevent past
failures from recurring. Additionally,there would be two points of entry for the chlorinated water and a new
distribution system within the manhole to evenly dose the incoming wastewater. These design
improvements required additional funding from the Town prior to installation.
On May 17,2013 the Mill received a fecal coliform test result of 600 colonies/100ml. Upgrades to the
Town's pretreatment system were not complete at this time. The Mill was continuing to supplement the feed
of chlorinated water from the Town with a sodium hypochlorite tote at the upper manhole. This practice
continued until construction was completed during the month of Jurie. -
On August 16,2013 the Mill experienced a heavy rainfall event resulting in over two inches of rainfall within
35 minutes. This act of God resulted in flow to the treatment plant from the Town of Canton and Mill peaking
at approximately 50 million gallons. In order to manage this abnormal flow and protect plant operations,the
plant's spare primary clarifier was partially filled. After the event,flow normalized and the spare clarifier
was slowly drained back into the treatment process over the next three days. This material from the spare
clarifier was from the first flush of the rainfall event and believed to hold the most concentrated waste.
Based on these events and our findings,we request that the NOV issued on November 5,2013 be rescinded.
If you have any questions or comments,please feel free to contact us at your earliest convenience.
Sincerely,
Chet C.Chiles
EHS&S Manager
Canton&Waynesville
828-646-2381
chetchiles@everpack com
NMM\
cc: Chuck Cranford,Asheville Regional Office
Jeff Menzel,Asheville Regional Office

revergreen,, & Canton Office
packaging I 175 Main Street• Canton, NC 28716
December 13,2013 N M M#101-13
Certified Mail-Return Receipt Requested
7011 3500 0001 8863 8003 R C'f�
Landon Davidson
Asheville Regional Supervisor
Division of Water Quality 1' c 2013
North Carolina Department of Environment
and Natural Resources DWQ/ScrFnc,i, r,
Asheville Regional Office Asheville Iic Tonal price echon
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc.dba Evergreen Packaging
Canton Mill,Canton,Haywood County,North Carolina
Request to Rescind NOV;NOV-2013-LV-0677
NPDES Permit:NC0000272
Dear Mr.Davidson:
On November 5,2013 we received a Notice of Violation(NOV)in regards to a daily maximum value for fecal
coliform. We respectfully request that the NOV be rescinded.
After a formal discussion,at the regional office on November 14a,you requested additional information
about the circumstances surrounding the prior and most recent test values. Please see below for an
explanation of the events that occurred for elevated fecal coliform test results in 2012 and 2013.
On June 26,2012 an elevated fecal coliform test value was reported. Laboratory results showed a geometric
mean of 477 colonies/ 100ml. We were unable to determine the cause of the elevated value. A complete
walk through of the treatment system was conducted. The Town of Canton owns and operates a
pretreatment chlorination system.This system is owned and operated as part of an agreement between the
Town and Mill. This system was checked and appeared to be functioning as designed.
On August 14,2012 the Mill received an elevated fecal coliform value of 600 colonies/100ml. At the time of
discovery,we were unable to determine a cause for the elevated value. A complete walk through of the
treatment system was conducted. The Town of Canton,once again,checked the pretreatment chlorination
system,and it appeared to be functioning as designed without any downtime in operation. After review,it
was determined the results were a laboratory anomaly.
On November 20,2012 and November 27,2012 two additional test results showed values of 600 colonies/
100ml and 6000 colonies/100ml,respectively. During this time,a construction upgrade of the Champion
Drive force main and Bridges pump station was occurring. Construction crews were onsite installing the
force main working towards the W WTP low lift The last section of the new piping occurs at the tie-in to the
South force main before entering the head of the plant This is also the location of the Town of Canton's
pretreatment piping. As crews excavated,they discovered that the chlorinated water line that pretreats the
Town of Canton's wastewater had broken in three sections underground. The HOPE pipe was installed in
Z:\Share\Water Files\Nick's Water Files\DWQ\NOV Resc Ltr 816213 NMM10113.doc

VNM
e2M 101-13
Dec 13
sections with each new section welded to the other. It appeared the pipe had contracted,pulling these welds
apart Along with our notification,we submitted a letter from the Town of Canton explaining the breaks in
the line and also their repair. With this discovery,we determined the Town's chlorinated waterline had
been broken for some time which resulted in the elevated fecal coliform results in June and August that are
discussed above.
In consultation with the Town of Canton and their consultants,we collectively decided to improve the
current pretreatment design of the system. A single run of HDPE piping would be used to prevent past
failures from recurring. Additionally,there would be two points of entry for the chlorinated water and a new
distribution system within the manhole to evenly dose the incoming wastewater. These design
improvements required additional funding from the Town prior to installation.
On May 17,2013 the Mill received a fecal coliform test result of 600 colonies/100ml. Upgrades to the
Town's pretreatment system were not complete at this time. The Mill was continuing to supplement the feed
of chlorinated water from the Town with a sodium hypochlorite tote at the upper manhole. This practice
continued until construction was completed during the month of June.
On August 16,2013 the Mill experienced a heavy rainfall event resulting in over two inches of rainfall within
35 minutes. This act of God resulted in flow to the treatment plant from the Town of Canton and Mill peaking
at approximately 50 million gallons. In order to manage this abnormal flow and protect plant operations,the
plant's spare primary clarifier was partially filled. After the event,flow normalized and the spare clarifier
was slowly drained back into the treatment process over the next three days. This material from the spare
clarifier was from the first flush of the rainfall event and believed to hold the most concentrated waste.
Based on these events and our findings,we request that the NOV issued on November 5,2013 be rescinded.
If you have any questions or comments,please feel free to contact us at your earliest convenience.
Sincerely,
Chet C.Chiles
EHS&S Manager
Canton&Waynesville
828-646-2381
[e-mail]
NMM\
cc: Chuck Cranford,Asheville Regional Office
Jeff Menzel,Asheville Regional Office

r
M- -
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
November 5, 2013
Mr. Dane Griswold
Blue Ridge Paper Products Inc.
175 Main Street
P.O. Box 4000
Canton, North Carolina 28716
Subject: NOTICE OF VIOLATION
NOV-2013-LV-0677
Permit No. NC0000272
Canton Mill WWTP
Haywood County
Dear Mr. Griswold:
A review of Canton Mill's monitoring report for August 2013 showed the following
violation:
Parameter Date Limit Value Reported Limit Type
Value
Coliform, Fecal MF, M- 08/16/2013 400 - 600 #/100mI Daily
FC Broth,44.5C #/100ml Maximum
Exceeded
Remedial actions, if not already implemented, should be taken to correct any problem. Since
the comments section on the reverse of the relevant DMR provided an adequate explanation for the
subject violation, it is not requested that a response be submitted.
Water Quality Regional Operations—Asheville Regional Office
2090 U.S.Highway 70,Swannanoa,North Carolina 28778
Phone:[phone] FAX [phone]
Internet htlpllpoital.nodenrogjWeblwghvs
An Equal Oppodun4l Af rmabe Action Employer

Mr. Dane Griswold
November 5, 2013
Page Two
The Division of Water Resources may pursue enforcement action for this and any additional
violations of State law. If you should have any questions, please do not hesitate to contact
Janet Cantwell or me at 828/296-4500.
Sincerely,
G. Landon Davidson, P.G.
Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
cc: WQ Asheville Files
WQ Central Files
John Pryately/ ORC
Michael Ferguson/ Manager: Pulp, Recovery & Utilities
Chet Chiles/ Manager: Environment, Health & Safety
G:1WQ\SWPUHaywood\WastewaterlIndustrial\Blue Ridge Paper 00272WOV-2013-LV-0677.doc

r
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E. t Dee Freeman-"
Governor Director ! --- Secretary
, ;
April 2, 2012 '
AP i 11 2012 -
Mr.Jim Giauque
Blue Ridge Paper Products Inc.
(dba Evergreen Packaging—Canton Mill Facility)
r ;
175 Main Street . ::.
Canton, NC 28716
Subject: Tax Certification for Pollution Abatement
Equipment, Real and Personal Property
Tax Certification Number TCS-AV-115
NPDES Permit NC0000272
Haywood County
Dear Mr. Giauque:
As per your request, the staff of the Division of Water Quality has completed the review of
the Tax Certification Request for real and personal property that was initially received from your
office on August 19, 2011.
Please find attached a copy of Tax Certification Number TCS-AV-115 that has been issued
by this office to Blue Ridge Paper Products Inc. (dba Evergreen Packaging—Canton Mill Facility)for
the facility located in Haywood County. A copy of this Certification is being sent to the Haywood
County Tax Office along with a copy of this letter.
If there is a need for any additional information or clarification, please do not hesitate to
contact either Mr. Antonio Evans of our staff at [e-mail] or 919-707-9168 or Mark
Hubbard at [e-mail] or 919-707-9162.
Si n ceer/re``ll�y,
kr
14141
Mark L. Hubbard, P.E.,Assistant Chief
Infrastructure Finance Section
AVE/sd
Attachment(s)
Cc: Ms.Judy H.Ballard, Haywood County Assessor, w/a
Infrastructure Finance Section, w/a
Asheville Regional Office(Mr. Keith Haynes), w/a
Infrastructure Finance Section
1633 Mail Service Center,Raleigh,North Carolina 27699-1633 Clne
Location:8' Floor Archdale Building,512 N.Salisbury St.Raleigh,North Carolina 276D4 NO Carolina
Phone:[phone] FAX:919-7 15 M Q//�
Internet:w .naralaroualitv.ora Q`i�C'[L/„ l

r ,
A=4'
NCDENR.
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
North Carolina Division of Water Quality
TAX CERTIFICATION NUMBER TCS-AV-115
In accordance with the provisions of the North Carolina General Statutes G.S. 105-275.(8) this is
to certify that:
Blue Ridge Paper Products
(dba Evergreen Packaging—Canton Mill Facility)
175 Main Street
Canton,North Carolina 28716
Haywood County
filed a request for tax certification for real and personal property covered under the Division of
Water Quality NPDES'Permit NC0000272.
On March 23, 2012, staff of the Division of Water'Quality inspected the facility and found or
observed, based on the information supplied by the applicant, that the facility listed on the
attached application meets the following requirements for Tax Certification:
1. The property has been, constructed and installed;
2. The property complies with, the requirements of the Environmental Management
Commission(EMC);
3. The property and facilities appear to be effectively operated, in accordance with the terms and
conditions of approvals issued by the EMC; and
4. The property has, as its primary rather than incidental purpose the reduction of water
pollution resulting from the discharge of sewage or waste.
Please note that as part of this Tax Certification process the DENR staff did not make any
efforts:to confirm either the cost of the items certified or the year of their acquisition.
DATE TAX CERTIFICATION ISSUED: April 02, 2012
2
Mark L. Hubbard, P.E., Assistant Chief
Infrastructure Finance Section
cc: Ms Judy H. Ballard., Haywood County Tax Administrator
Asheville Regional Office (Mr. Keith Haynes)
Central Files—Permit NC0000272
2009-03-30

Tax Certification Inspection Report Determination
Facility:....................................Blue Ridge Paper Products (Evergreen Packaging)
Tax Certification Number:..............TCS-AV-115
Inspection Date:..........................3/23/2012
ALL ITEMS LISTED QUALIFY FOR TAX CERTIFICATION: Yes k No ❑
1. Landfill Area 6D South leachate pump system structure, three pumps and
associated electrical control panel, leachate collection lines and laterals, force
main, force main clean-out boxes, and valves.
Qualifies? Yes No
Comments: 3 �vnn�S Cr`�, dmSt�XJ1c� Gl)y`�l bye �p �
2. Upgrade to existing leachate system pump station, including three pumps, wet
well lining and improvements, piping and valves and associated electrical
control panel.
Qualifies? Yes No
Comments:_ 3 4LA_ri p� <o� os Jc� cum 6YA-4-
h�o iz ;1 rrk rt na�m nam cA slurt�_
3. Upgrade to existing leachate line from the landfill to the Canton Mill wastewater
treatment plant, including installation of 3 clean-out boxes and associated .
valves.
Qualifies? Yes No
Comments:
File name: Blue Ridge Paper Products(Evergreen Packaging)Insp-Repott.doe
Dateprinted: December7,2011
Page No. I of 1

Picture Index
No. Description
1. Overall view of Landfill Cell D
2. Closer view of Landfill Cell D (WWTP Biosolids, calcium carbonate(green material), & Boiler
Ashe)
3. Gravel used to construct the chimney drain for the leachate main collection lines.
4. Gravel used to cover the submerged pumps and 12-inch HDPE pump discharge lines encased
in larger HDPE casing running along the slope at new pump station.
5. New pump station control panel.
6. Spare submerge pump at new pump station.
7. 4-inch header pipe discharge to a subsurface 6-inch force main through the floor(not
shown).
8. Electrical controls(lights power panel, pump power panel, pump controls,and transformer)
at the new pump station.
9. 6-inch force main runs parallel along the road at the base of the slope and one of the two
cleanout boxes on the line.
10. Discharge piping at the pump station that was upgraded.
11. Electrical controls at the pump station that was upgraded.
12. Wet well for the pump station that was upgraded(near the bottom of picture) and the old
wet well above it now used to settle grit.
13. Inside of one of the five clean out boxes.

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° ° ' • This application is to be used only for waste treatment systems and
equipment under the authority of the NC Division of Water Quality (DWQ) Rev. 06/01/2007
DIRECTIONS:Complete and mail signed copies of the application form and all supporting information to both: 1)the County Tax Administrator for the County in which the facility is located(one copy)AND 2)
to the NC Division of Water Quality;Construction Grants and Loans Section,1633 Mail Service Center,Raleigh,NC 27699-1633(two copies). Type or print in blue or black ink. A separate application
package is required for each facility where property proposed for tax certification is located.
THIS APPLICATION WILL NOT BE PROCESSED WITHOUT COMPLETE AND ACCURATE INFORMATION. If you have any questions regarding this application,please call the local lax office or the NC
Division of Water Quality at 919f733-6900 or their web site at www.nccel.net for more specific contact information.
Please Note:
a)Tax Certifications will only be processed for facilities under the authority of the DWQ and only if the DWQ has found that the described property:
1.Has been or will be constructed or installed;
2.Complies with or that plans therefore which have been submitted to the DWQ indicate that it will comply with the requirements of the Environmental Management Commission;
3.Is being effectively operated or will,when completed,be required to operate in accordance with the terms and conditions of the permit,certificate of approval,or other document of approval issued by the
DWQ;and
4.Has or,when completed,will have as its PRIMARY rather than incidental purpose the reduction of water pollution.
5).Is being used exclusively(100%)for waste treatment.
b)If approved,the Tax Certification issued will incorporate all requested assets at the facility that meet the criteria for Tax Certification by DWQ. Therefore this application must include any new assets for
which Tax Certification Is being requested,as well as any assets previously receiving Tax Certification from DWQ for which Tax Certification is still needed.
A.Applicant(Applicant is the owner of,and taxpayer for,the propert described in this a lication for lax certification.
Name of Applicant: Name of Facility:
Blue Ride Paper Products Inc. dba Evergreen Packa in Evergreen Packaging — Canton Mill Facility
Address of Applicant,if different from facility where property located: Physical Address of Facility where property located(no P.O.Box):
175 Main Street, P.O. Box 4000, Canton, NC 28716 175 Main Street, Canton, NC 28716
(address) (city) (zip) (streetaddress) (city) (zip)
Business Relationship of Applicant to facility where property located: County where property located: Haywood
Owner
Name of Contact Person at Facility where property located:
Jim Giau ue
Does the Applicant hold any NC Division of Water Quality Permits? 0 Yes / ❑ No Title: Waste Compliance&Landfill Supervisor Phone Number: 828-646-2028
If yes,please list NPDES: NC0000272; Stormwater NCS000105
Permit Nos:
If approved,will this be the first Tax Certification issued for this Facility? If no,attach any previously issued tax See Attached
❑ Yes / ❑x No certifications
B.Complete this Section only if the Operator/User of the facility and equipment is different from the Owner of the facility.
Name of
Operator/User:
Operator/User a
Address:
(address) (dty) (zip)
Operator/User Contact
Name:
RelaUonship between Operator/User of facilit and equipment and applicant: .,,,71
***ATTACH A PROCESS SCHEMATIC TO YOUR APPLICATION The number of each item for which Tax Certification is being requested must be shown on the $NdrhtIM t
Application Continues on Next Page ->
LG;AN SECT 0,

DIVISION OF WATER QUALITY TAX CERTIFICATION & EXEMPTION APPLICATION PAGE2
Waste Treatment Systems B Equipment: Waste treatment systems&equipment must be used exclusively for the abatement of water pollution mpreLelneO
re na, Assal Number, %of Use for Is this asset
aagv. I . , W..essatlshdintho Vslddeldengfiolson P.11.0on Ye...f OriginalK.bdcet mplacing a poor
Dealers—or West.Treatment& tems orE olefin Pehmill(restrict Number IN How Is this e W ment user for nedon abatement? Abatement Acculation Con•• asep
awm JlmawbmmmAa°nMnm.^rn6unuu[Nfeaupavaar YppP..'x" vM a1 Nnntl°IIaWmNmwPam.[aprm[e®y Ile�ewYa:emau nww
.mapnawnJertW.rmynLw[apneump[ul,pq[Npmnmwnv mNmra m.nnl umlttwm"s"',,tun4 Snt.y
t[a[ bia mnur[pane.i
;.ampeaulnrn[unimvr team;uv.p r[wN[�un..rtrmamenrpinrbruawentl 4mm]rtwmrb
mamw
ef,
at
Anach edolans plea r..11
"b a—W-Ilarae M qe pWGprmM,Na aoWpibnmuaib IeenikJu Nua mr N°[ummr pmmlL sT.euelu nebw[Inuly uawa M rn.pWe p,mlL u.epplkmlmuamu[A aabnaa In1°,merien ut°wny Ina en[r.naU.v.auyfpriaa Cmlhwtan.
^Wnmea,lRying ay[trma°r.aulpm[nLpEVPhn°temaylne...........°uipnmlorW y[nola[yuYlh'M
Facilities: To qualify for tax Cenification,the building or section of building being applied for,must be used exclusively for water pollution prevention. A sketch of the building,square footage along with details as to
how the budding is used for water pollution prevention,is required.
Land: To qualify for tax certification,the land must be used exclusively for water pollution prevention. A schematic diagram of the facility detailing the land being applied for is required. The amount of land(acreage)is
required and how this land is being used to prevent water pollution. For wastewater treatment and irrigation system tisl separately the acreage used for actual treatment from the acreage required by the facility's water
quality permit for buffers and setbacks. "
SIGNATURE:
I herebycenity that the bove equip t,todilifiesclorland areused for the purpose stated,and[hat the information presented in this application is accurate. Furthermore,I certify that any portable or mobile
equipment listed on th' application I be usively in the state of North Carolina _
Applicant cf Signature: Title:Q �tA. ^�La,�1y Date: XI(� ZOIo(
rprmmama meal ,� t)G J l •µme u�.� ^"( �•r�G,a°
NOTICE:lues hope for fella eWtomen mpreientauonoreorUnwt[on Of:
herein Includes imprisonment and l or ere assessment of civil penalties. (Name of Applicant Bu ea.Eng '

evergreen.. i Canton Office O I
packaging VED
175 Main Street• Conlon, NC 28716
JAG 27-12 6E ' ctur�F41zan
Certified Mail
Return Receipt Requested
7008 3230 0002 2591 1625
March 23, 2012
Mr. Tony Evans
North Carolina Division of Water Quality
Infrastructure Finance Section
1633 Mail Service Center
Raleigh,NC 27699-1633
Subject: Evergreen Packaging—Canton Mill Facility
Request for Tax Certification
NPDES NC0000272,NCS000105
Dear Mr. Evans:
Thank you for your visit and tour of the Canton Mill Landfill Number 6 on 23 March 2012. We
appreciate you taking the time to review our tax certification request for the landfill leachate
system improvements associated with the construction of Area 6D South.
Per your request we have attached a summary of the three major project components, each
numbered for identification purposes, to supplement page 2 of the Division of Water Quality Tax
Certification &Exemption Application. The details of each are provided in the original
application for tax certification package submitted 15 August 2011.
Should you have any additional questions at this time please do not hesitate to ask.
Sincerely,
James A. Giauque Paul Dickens
Waste Compliance& Landfill Supervisor Manager—Environmental Affairs
828-646-2028 Canton Mill—Waynesville Plant
iim.eiauqueO,,evemack.com 828-646-6141
paul.dickens(a-)everpack.com
file:6D5032312
Attachment
cc(letter only):
Jeff Menzel,NCDENR DWQ
Heidi Howard,Evergreen Packaging
Roger Edwards,Evergreen Packaging
\\everpack\ga\EOHS\SHARE\Canton\Water\NPDES Permit\Request for Tax Certification .- •�� •,/
,._ .umF<, . -n it F^.CIcn-c

Supplement to Page 2 of DWQ Tax Certi0cation 8,Exemption Application of August 15,2012
Waste Treatment Systems & Equipment: Waste treatment systems&equipment must be used exclusively for the abatement of water pollution
of use for Is this asset
Description of Waste Treatment Systems or Was asset listed In t196773,196774,
How is this equipment used for pollution Year of Original replacing a
Equipment permit? as,Nomber pollution abatement? abatement Acquisition Historical Cost prior asset?
1 Landfill Area 6D South leachate Pump system structure,3 Yes(landfill leachat070, Removal of leachate and 100% 2010 $ 546,944 Original
pumps and associated electrical control panel,leachate 7076, conveyance to treatment facility
collection fires and laterals,force main,force main clean-out
boxes,and valves
2 Upgrade to existing leachate system pump station,including 3 Yes(landfill leachate) 774, Removal of leachale and 100% 2010 $ 162,164 Padial
pumps,wet well lining and improvements,piping and valves, conveyance to treatment facility
and associated electrical control panel
3 Upgrade to existing leachate line from the landfill to the Canton Yes(landfill leachate) 101180 Removal of leachate and 100% 2010 $ 63,388 Partial
MJI waste water treatment plant,including installation of 3 conveyance to treatment facility
clean-out boxes and associated valves
file:6DS lax can
1

Evergreen Packaging
Tax Certificate Application
Leachate Collection and Removal System(LCRSf and Improvements associated with Cell 6D South Construction
Description: This sheet conlainS finished costs for the sectlom of the leacalo removals stemfmm Ne6Dlandfllpelltolhetie-in heex'ti leac to tam'
Itemized Casts: cv,LLy�`- IOVWt\r .v�`FP41V/LII
Spending Reference lN.es
-Ewr9men DoNnenl
t VeNes far Standard boxes-presM1kam E 15418 '...GP Pra{2011-LIAl Valves forcomay meandtieinafnew LCRB aedion to existing LCRS
Eeergreanmesevenl Houses piping and electrical Composite to collect and transfer leehade,
'...GP Roj2mbLW ilsr See System Dravdng"Of(atlached)for Skemh and deszil including square
Sol $ 13]91 real
6namrack Wcwnme
1-ann611No.6AmeMment-Nea 6Smdh
Structure-Foundation E 32163 Coistmckm Parllalvalue complete value with added to above value for•Sdmesure•
Evergreen Cavmenl
Dolts $ 655 •...GP Pro'201 11W.Wf Atltlllion of$411.and$244 from she referenced Everyrean Document
Evegreen 00cument
Steel E 1,155 -...LIP Pro[2011-till
SNnuork Mamens
'1,eno611 No.S Amenemenl."a D-S-11
New Pump Somon Electrical E 13145 Constmceom
Evergreen WaoneN
Pumps S 90000 'Fuetl Pssel Atld4ona YlE tViV3o1o• 3pumps
Sha mob Document
1ene6ll Na.6 PmeMment-Area 0.Si
ConsVONon•mud Eveil Dimsee l Addition ofE]1,]]4,and$65,975from he referenced Shumroek Document and
Assailed Kill $ 169909 l..cipprgtall-ovi $32,160 from line referenced Evergreen Document
Evmgreen 0ocument
Roof 5 9366 t.top Prod 2.1I1yul
steel comealm,pumphouse Evergreen comment
In $ 9913 '...GP Pot 20114w.Nsx
fine mends,Document
C _ _-'Landoll No.6 Amen nb Aree 0.SwM
--•NpPEs meat tin _ __. E 2360 Consliroeon•
12—n T_m nF__ _ -_-- 38,01 "Lendhll NoS.Mfi cmormarYmsd s00sciovn n-eNnle e OSoutF
_
snamraNrDaa.Z
_ .:Lili Na.6Nnewmw-aa.Osorm
B In Collatllan Lateral."" - - E - ]B 1B1 compound - _
Snsemok Document
_ - -- •Innarn No.6 Amertlma As.DSUM
-610 CelleNbn Leleral Cleapaut S 4651 - Seen fnrt6on----- --
larvidy No.6 PmeMmW.Nee 0.5ouN
6 in Force Main s 23255 Canmueemf
¢ narrcork Doovn:a0.3ousn
dmenl
Foe Main Cleanoul E 336]3 l-dfill NeS.6Amer
egnslnrt4on'
Taylor S Murphy Document
Varies and A urlenarmas S 313516 •9itl SCM1edule'
Castilian
Taylor S Murphy Document
-- ----- 'Did Sdiedule'and Evergreen '
-Grovel der LeacM1ateS lam s 15.15 Infartregoh
TOTAL CAPITAL(New LRCSSecllon) S 54g94d
Note:
1-Cass for sordidly scnedule Slone for leachate system design purposes;provided by L.William
'Evergreen Tax Cert PttacM1ment-SummaryspreatlsM1eet vl_O.vlzx New LOPS

Evergreen Packaging -
Tax Certificate Application
Leachate Collection and Removal System(LCRS)and Improvements associated with Cell 60 South Construction
Description: This sheet contains itemized costs for the upgrade of the existing leachate system pump station -
Itemized Capital:
S endin Reference 71,10tes
Evegreen Document
Pum s for Lift Station $ 32,160 •...CIP Prg'2011-LW.xlsx• anew leachale pumps
Evergreen Document Addition of$4,850,$15,489,$3,641.$662,$879.and
Material for lift Station $ 32.166 ••••CIP Prof 2011-LW.xlsi $6,645 from the referenced Evergreen Document
Evergreen Document
Upgrade to existing lift station $ 54,413 •...CIP Pro 2011-LW.xlsz
Evenlreen Document
Wet well coating �$ 26,570 � •...CIPP '2011-LW.xlsx'
Electrical and control panel Evergreen Document Addition of$10,800 and$6,055 from the referenced
ImprovmenIs $ 16,855 '•..CIPPmj 2011-LW.xlsx• Evergreen Document
TOTAL CAPITAL (Improvement to existing LRCS( $ 162,164
t Evergreen Tax Cert Attachment-Summary Spreadsheet vl O.xlsx Improv,to Existing LCRS

PV
Evergreen Packaging
Tax Certificate Application
Leachate Collection and Removal System(LCRS)and improvements associated with Cell 6D South Construction
Descriptir This sheet contains itemized costs for the installation of three clean-out boxes in the existing leachate line from the Landfill to the wastewater treatment plant facility
Itemized Capital: 3 b��7CX+� dr
Spending Reference
Notes
Valves for cleanout boxes-LF to W WTP Evergreen Document
$ 14,g43 "...CIPPrcJ2011-LW.xlsx"
Concrete Boxes $ 46,756 Taylor&Murphy Document
"Bid Schedule"
SS Stands for Clean out boxes $ 1 bag Evergreen Document
2011-LW.xlsx"
TOTAL CAPITAL (Cleanout Addition) $ 63,388
Evergreen Tax Cert Attachment-Summary Spreadsheet vl_o.xlsx Clean-outs Additions

Evergreen Packaging
Tax Certificate Application
Leachate Collection and Removal System(LCRS)and improvements associated with Cell 6D South Construction
Capital Expense Summary
LCRS Component' Total Eligible Cost
New LCRS $ 546,944
Improvement to Existing LCRS $ 162,164
Clean-out Additions(between Landfill&WWTP) $ 63,388
Total Eligible Spending $ 772,496
1-Detail for each component provided on separate sheet
Evergreen Tax Cert Attachment-Summary Spreadsheet vl_O.xlsx Summary

Attachment B
Existing Certificate Listing

Blue Ridge Paper Products-Canton Mill Apr-08
Pollution Control Tax Certificates for Currently Active Facilities Dickens/Greene
Jertl kale ermlt escnphon- o utfon. onlro gmpment associate wit rocess
Number Number Equipment and/or Specific Pollution Control Projects (Yes/No) Medium Date Issued
Pollution Controls Associated with Process Equipment
51 20065 No.11 Recovery Furnace-ESP&SMUT Demister-includes N Air 9/12/1974
MACT II upgrades
153 20066 Riley Bark Boiler-Multi-Cyclones&Wet Scrubber N Air 9/12/1974
155 20067 N0.10 Recovery Furnace-ESP&SMUT Demister-includes N Air 9/1 211 9 7 4
MACT II upgrades
51 20152 Black Liquor Oxidation System N- Air 9/12/1974
29 20068 Riley Coal Boiler-ESP and fly ash handling system N Air 9/12/1974
29 20069 Big Bill Coal Boiler-ESP and fly ash handling system N Air 9/12JI974
29 20070 Peter G Coal Boiler-ESP and fly ash handling system N Au 9/12/1974
20294 20269 N,4 Coal Boiler-ESP and fly ash handling system N Air 10/27/1987
20386 20386 No.4 Kiln Lime Slaker-Natural draft scrubber N Air 5/1 711 9 9 5
20055 20392 No,4 Lime Kiln-Wet Scrubber System N. Air 2/2 311 9 7 9
20427 20427 Tall Oil Scrubber N Air 5/1 711 9 9 5
20055 20451 No.5 Lime Kiln-Wet Scrubber System-includes MACT II upgrades N Air 2/23r1979
NCG&Foul Condensate Collection and Treatment Systems,Including NCG y Au 2/6/1992
20468 20468 Scrubber and the Foul Condensate Stripper e/2/1993
20503 20503 Dino - y Air 81W 993
20485 20485 No. 1 Filberline(Hwd)Scrubber Y Air 2/6/1992
20486 20486 No.2 Filberline(Pine)Scrubber y Air 2/6/1992
20487 20487 No.5 Kiln Lime Slaker-Natural draft scrubber y Air 2/6/1992
Y Air 2/6/1992
20488 20488 No.5 Kiln Lime Slaker-Lime Silo Dust Collector y Air 2/6/1992 -
( 20496 20496 White Liquor Oxidation System-Demister y Air 2/6/1992
< 26067-A 20067-A No.10 Recovery Furnace-SMUT Demister y Air 2/6/1992
20497 20497 No.11 Recovery Furnace SMUT Demister
20498 20498 No.4 Lime Kiln-Lime Silo Dust System (No.6 dust collector upgrade) N Air 8/2/1993
Specific Pollution Control Protects
Water Pollution Control Facilities required to comply with the.2001 NPDES 2
TCS-401 NC000272 //31199 permit including the WTP.CMP water conservation systems,thermal discharge y Water 1 3/31/199
control systems, black liquor spill and chemical systems for OD100 2
process(updated by TCS-502&TCS-AV-103)
TCS-292 44-01 No.5 Landfill teachate system,(asset retained by Champion/International N Solid 2/5/1982
Paper in May 1999)
1978 Hill Filter Plant Upgrades to settle and return backwash water including Water 6114/1978
TCS-238 1533 Clad-Vac system,backwash return piping and the cooling lower&mud sewer N
to the WTP-Eliminated backwash water and-cooling lower outfalls to river
7/25/1995
TCS-502 NC000272 WTP Facilities&Bleach Filtrate Recycling(MRP and CRP) N Water 1/16/2003
No.4 Coal Boiler Separated Overflow Air(SOFA)System- N Air 3/19/2003
4400159.03E 08961R02 NOx SIP Call' N Air 10/13/2005
4400159.05C 08961R06 No.4 Coal Boiler SNCR Urea System-NOx SIP Call'
4400159.070 08961TIO BLOX-RTO System-MACT I,Phase 2 (excludes Hardpipe) N Air 1/15/2008
TCS-AV-103 NG0002721 Acid Sewer System/Water Pollution Control Facility N Water 2/12/2008
'Note: Noah Carolina as matter of policy did not approve tax cerlilicale[or any low NO burner installations
in the the state,the fuel burners are considered a normal sleanl production component of the power boilers.
Poll Cntrl Tax Cenil Master List
Page 1 of 1 - Printed 4/9/20081

Attachment C
System Drawings

--------- - _-. -_ --- -- —yf-------
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GLUE RIDGE PAPER PRODUCTS INC. -
'i CAN ,MILL
CANTON, NORTH CAROLINA
mw• ..
` LANDFILL NO. 6 AMENDMENT
PIPELINE LOCATION & ELECTRICAL PLAN
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DUIT NDUIT AND SCREEN
eh ( I I ems fw.ff..»a vJ.sJna he Iw,n�
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a!rtwyf�»onr�Wp n.mu ave.nwl+m,hR.om erx LEACHATE COLLECTION HEADER PIPING SYSTEM WITH CHIMNEY DRAIN
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' f41If'a"°""""'[l^I•I r u+m�.n]p lf.e�.R mucrm wale LANDFILL NO. 6 AMENDMENT
TI 1
FAND END SECTIONS AND DETAILS eo
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ANCHOR TRENCH
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CANTON MILL
CANTON. NORTH CAROLINA
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_7
CANTON MILL
/ A CANTON, NORTH
CAROLINA
LANDFILL N0. 6 AMENDMENT
-.mPvn.s�,,.� w� rxnr imc<::;r"`t � .'.'nx°'Y •0•� SECTIONS AND DETAILS
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North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H.Sullins Dee Freeman
Governor Director Secretary
May 26,2010
Mr.Dane Griswold,Plant Manager
Blue Ridge Paper Products
P.O.Box 4000
Canton,North Carolina 28716
Subject: NPDES Permit Issuance
Permit No.NC0000272
Blue Ridge Paper Products,Inc.
Haywood County
Dear Mr. Griswold:
The Division of Water Quality is forwarding herewith the Final NPDES permit for Blue Ridge Paper Product's Canton
mill. This permit renewal is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between North Carolina and the U.S.Environmental Protection Agency dated October 15,
2007(or as subsequently amended).
Public hearings were held in Tennessee and North Carolina seeking comments on the Draft permit and proposed removal
of the color variance. Subsequently,U.S.EPA submitted an objection letter(dated February 22,2010) on the Draft permit;
and required several permit changes. This Final permit addresses public comments,the specific EPA objections,and
incorporates additional recommendations of the DWQ Hearing Officer. The specific changes that have been incorporated
into this Final permit are as follows:
• Color Technology. The starting annual average color limit has been changed to 38,020 lb/day based on EPA's use
of the 95%confidence limits. The final annual average color limit(after 4 years)has been changed to a range of
32,000-36,000lb/day. A Color Reduction implementation plan will be required within one-year of permit
issuance;and a reopener clause has been added that will allow the Division to include interim requirements and
dates for their achievement following review of the Implementation Plan.A Low Flow Contingency Plan for color
control shall be submitted within one year of permit issuance.
• Color Variance. The consideration for color variance removal has been dropped from this permit renewal. The
facility will continue to operate under its current color variance,which will be subject to NC Environmental
Management Commission approval at a later date. Blue Ridge Paper may elect to conduct a color perception study
in the future to support removal of the color variance,and any such proposed study must be-appioved by the
Division of Water Quality.
• CWA Section 316(a)Thermal Variance. The Balanced and Indigenous Population(BIP)study must conform with
EPA study guidelines, and is subject to EPA review.The monthly average delta temperature limit has been
changed to 8.5 degrees C based on EPA's use of a 95`b percentile,which can be modified in the future based on
1617 Mail Service Center,Raleigh,North Carolina 27699-1617 -
Laotian:512 N..Salisbury St Ralegh,North Carolina 27604 One
Phone:91H07-63001 FAX:919A07-64921 Customer Service:1-877-623-6748 North{CaNrolina
InternetEqual wpornudwatertlunalwe Action
a ah ally
An Equal Opportunilyl AKrtnalive AG�n Employer ��/

results of the thermal modeling. Blue Ridge Paper will continue to monitor/report daily maximum and monthly
average effluent temperatures.
• Dioxin. A daily maximum dioxin effluent limit has been added,based on a 1.5 multiplier of the chronic limit.
Blue Ridge Paper will conduct three annual fish tissue monitoring events over the permit term. Two events must
be from Waterville Lake, while the third fish sampling may be from Waterville Lake or the mainstem Pigeon River
below the mill outfall.
• Turbidity. Instream turbidity monitoring(upstream and downstream at Fiberville Bridge)will be required the first
year,at 2/Month monitoring frequency. A turbidity reopener clause has been added to the permit.
• Hardness. Quarterly effluent hardness monitoring has been added to the permit.
• AOX Limits. Though not required by EPA Effluent Guidelines,AOX production-based limits will be held at the
2001 permit levels,based on the facility's performance history.
The Division of Water Quality commends Blue Ridge Paper for the progress made to date in improving water quality in the
Pigeon River, including a 90%reduction in color since 1988 and successful fish reintroduction projects. The Division has
thoroughly considered the comments provided by Blue Ridge Paper,U.S.EPA,the State of Tennessee,local communities
and environmental interest groups to develop this Final permit,which requires additional color reductions.
If any parts,measurementfrequencies,or sampling requirements contained in this permit are unacceptable to you,you
have the right to an adjudicatory hearing upon written request within thirty(30)days following receipt of this letter. This
request must be in the form of a written petition,conforming to Chapter 150B of the North Carolina General Statutes, and
filed with the office of Administrative Hearings,6714 Mail Service Center,Raleigh,North Carolina 27699-6714. Unless
such a demand is made,this permit shall be final and binding.
Please take notice that this permit is not transferable except after notice to the Division of Water Quality.The Division
may require modification or revocation and reissuance of the permit.This permit does not affect the legal requirements to
obtain other permits which may be required by the Division of Water Quality,the Division of Land Resources, the Coastal
Area Management Act,or any other federal or local governmental permit.
If you have any questions on this permit,please contact Tom Belnick at 919407-6390.
Sincerely,
en . Sullin
Hardcopy: Central Files,NPDES Files
Asheville Regional Office,SWPS
Email: US EPA,Region 4
Aquatic Toxicology Unit
Shannon Deaton,NC Wildlife Resources Commission
Paul Davis,TN Division of Water Pollution Control
David McKinney,TN Wildlife Resources Agency
Hope Taylor,Clean Water for NC
Hartwell Carson,French Broad Riverkeeper
Iliff McMahan,Mayor Cocke County,TN
1617 Mail Service Center,Raleigh,North Carolina 27699-1617
Location:512 N.Salisbury St Raleigh,North Carolina 27604 ()Re
Phone:919�D7 63001 FAX:919907-;492I Customer Service:1-877.623-6746 NorthCarolina
InternetEqual www.ncwatergoallveAc �t��rtmrall)/
An Equal OpponunitylAffirmalrve Action Employer G'/�/hL KL

Permit Number: NCO00O272
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
Final PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1,other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission,
and the Federal Water Pollution Control Act,as amended,
Blue Ridge Paper Products Inc. dba Evergreen Packaging "
is hereby authorized to discharge wastewater from a facility located at
Blue Ridge Paper Products Wastewater Treatment Plant
Off Highway 215
Canton
Haywood County
to receiving waters designated as the Pigeon River in the French Broad River Basin in accordance with
effluent limitations,monitoring requirements,and other conditions set forth in Parts I,II,III and IV
hereof.
This permit shall become effective July 1,2010.
This permit and authorization to discharge shall expire at midnight on June 30,2015.
Signed this day May 26,2010.
Coleen . Sullins,Dn cto
Division of Water Qu lity
By Authority of the Environmental Management Commission

Permit Number: NCO000272
SUPPLEMENT TO PERMIT COVER SHEET
Blue Ridge Paper Products,Inc. dba Evergreen Packaging
is hereby authorized to:
1. Continue operation of a 29.9 MGD wastewater treatment plant for the treatment of wastewater
associated with the Blue Ridge Paper Products Inc, pulp and paper mill, the Town of Canton's
chlorinated domestic wastewater and landfill leachate. The treatment system consists of the
following treatment units:
Grit Chamber
• Bar Screen
• Lift Pumps
• Polymer addition
• pH control(COz injection or H2SO4 backup)
• Three primary clarifiers
• Nutrient Feed
• Aeration basins
• Three secondary clarifiers
• Residual belt presses
• Effluent flow measurement
• Cascade post aeration with oxygen injection
• Instream oxygen injection facilities
The facility is located at the Blue Ridge Paper Products WWTP, off Highway 215, Canton,
Haywood County,and;
2. Discharge treated wastewater from said treatment works at the location specified on the attached
map through outfall 001 into the Pigeon River, which is classified C*water, in the French Broad
River Basin.

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SCALE 1:24000

Permit Number: NC0000272
A. (1.)EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration,the Permittee
is authorized to discharge treated industrial,municipal,stormwater and landfill wastewater through
outfall(s)001. Such discharges shall be limited and monitored by the Permittee as specified below:
.Effluent Characteristics Effluent Limits ', Wnitorintl Requirements
Monthly.. Dally ';- Measurement Sample Type Sample
Average. :- Maximum :- , Frequency Locationt 2-
Flow 29.9 MGD Continuous Recording I or E,
BOD, 5-day,200C 32051b/da 10897 lb/day Daily Composite I,E,
Total Suspended Solids 12549 lb/day 49560 lb/day Daily Composite I,El
NH3-N Daily Composite El
AOX 1556.9 lb/day 2822.2lb/day Weekly Composite E,
Colo 52,000lb/day 105,250 Daily Composite E,
lb/day
Dissolved Oxygen' Daily Grab E,
Te erature Daily Grab E,
Daily Grab E,
Conductivity Daily Grab E,
Fecal Coliform 200/ 100 mL 400/100 mL Weekly Grab E,
COD Weekly Composite E,
Total Nitrogen
(NO2-N+NO3-N+TKN) Monthly Composite E,
Total Phosphorus Monthly Composite E,
Chronic Toxici Quarterly Composite E,
Trichloro henol 30.6 lb/day Quarterly Composite E,
Pentachloro henol 4.9lb/day Quarterly Composite E,
Selenium Annual composite E,
2,3,7,8 Tetrachloro-dibenzo- 0.04 pg/L 0.06 pg/L Annual Composite 1,E,
E�dioxins
Conductivi Daily Grab Pigeon River
Flow Daily Grab Pigeon River
Fecal Coliform" Weekly Grab Pigeon River
Color Variable Grab Pigeon River
Dissolved Oxygen" Variable Grab Pigeon River
Te emture Variable Grab Pigeon River
Zinc QuarterlyComposite E,
Hardness QuarterlyComposite E,
Turbidity 2/Month Grab E,,Pigeon
River
Footnotes:
1. Sample Location:I-Influent,E,—Effluent,Pigeon River-Insueam sampling as specified in A.(5.)Instream
Monitoring Special Condition.
2. AOX monitoring shall be in accordance with the Sampling Plan for Cluster Rule Parameters(dated March 19,
2001)or subsequent modifications approved by the Division. AOX data shall be submitted on a quarterly basis
along with other Effluent Guideline chemical data;refer to A.(7.) Effluent Guideline Sampling Plan Special
Condition.
3. Annual average color limit is 38,0201b/day,which will decrease to 32,000-36,000 lb/day no later than 4 years
after the permit effective date. See A.(8.) Color Analysis and Compliance Special Condition.All color limits
are measured as true color.
4. The daily average effluent dissolved oxygen concentration shall not be less than 6.0 mg/L. See A.(10.)
Dissolved Oxygen Special Condition.
5. The pemrittee shall report daily and monthly average effluent temperature.

Permit Number: NCO0OO272
6. The pH of the effluent shall not be less than 6.0 nor greater than 9.0(on the standard units scale).
7. Chronic Toxicity(Ceriodyphnia)at 90%Effluent Concentration:March,June,September,December(see A.
(4.)Chronic Toxicity Permit Limit(Quarterly)).
8. Trichlorophenol and Pentachlorophenol limits and monitoring are provisionally waived since the facility has
certified that chlorophenolic biocides are not used at this facility. If the facility changes operations to include
chlorophenolic biocide,the Permittee shall notified the Division prior to use and the limits and monitoring
requirements shall become immediately effective.
9. See A.(9.) Dioxin Monitoring Special Condition.
10. See A.(5.) Instream Monitoring Special Condition.
11. The monthly average instream temperature measured at a point 0.4 miles downstream of the discharge location
shall not exceed 32°C during the months of July,August,and September and shall not exceed 29'C during the
months of October through June. The monthly average instream temperature measured at this location shall not
exceed the monthly average instream temperature of the upstream monitoring location by more than 8.5°C.This
value can be adjusted based on the results of thermal modeling[See Special Condition A.(12.)Temperature
Variance Review Special Condition). r
12. Monitoring should be conducted in conjunction with Whole Effluent Toxicity Testing..
13. Monitoring should be conducted in conjunction with zinc monitoring.
14. Monitoring shall be conducted upstream of the discharge(mile market 63.8)and at Fiberville Bridge for 1 year
(12 months). The monitoring shall not occur within 72 hours of a rain event.This permit may be reopened and
modified to include a turbidity limit if a reasonable potential to exceed the State's numeric criterion is found to
exist.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
See A.(6.) Best Management Practices(BMP)Special Condition.
See A.(11.) Town of Canton Inflow and Infiltration Special Condition.
Definitions: '
MGD—Million gallons per day lb/day—Pounds per day
mL—Milliliter BOD—Biochemical Oxygen Demand _
µg/L-Micrograms per liter AOX-Adsorbable Organic Halides
COD-Chemical oxygen demand pg/L-picograms per liter

Permit Number: NC0000272
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration,the
.discharge of wastewater from the pine bleach plant to the wastewater treatment plant through
internal outfall(s)002 (E2'),shall be limited and monitored by the Permittee as specified below and in A.
(7.)Effluent Guideline Sam ling Plan Special Condition:
>EfflueiifClihracteristic's Llmlts';;' -MOn1t6ring Re'Wr6rnents ;:. -
Monthly Daily : Measurement,, SampleTypba Sample i
Average Maximum FrequenCY Locationl-,
Flow2 Weekly Calculated E2.
Chloroform 5.1lb/day 8.6lb/day Quarterly Grab E_
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Annual Composite E2
dioxin TCDD
2,3,7,8 Tetmchloro-dibenzo- 31.9 pg/L Annual Composite E2
furan(TCDF
Trichlorosyringol < 2.5 µW Quarterly Composite E_
3,4,5-Trichlorocatechol < 5.0 pg/L Quarterly Composite E2
3,4,6-Trichlorocatechol < 5.0 µg/I. Quarterly Composite E2
3,4,5-Trichloroguaiacol < 2.5 µg/L Quarterly Composite E2
3,4,6-Trichloroguaiacol < 2.5 pg/L Quarterly Composite E2
4,5,6-Trichloroguaiaeol < 2.5 pg/L Quarterly Composite E2
2,4,5-Trichlorophenol < 2.5 µg/L Quarterly Composite . E2
2,4,6-Trichlorophenol < 2.5 pg/L Quarterly Composite E2
Tetmchlorocatechol < 5.0 µg/L Quarterly Composite E2
Tetrachloroguaiacol < 5.0 µg/L Quarterly Composite E2
2,3,4,6-Tetrachlorophenol < 2.5 pg/L? Quarterly Composite E2
Pentachlompbenol < 5.0 µg/L Quarterly Composite E2
Footnotes:
1. Sample Location:E2—Effluent is composed of Bleach Plant Effluent-acid (acid sewer collected from tap
installed on filtrate pump from C102 bleaching stage D-100 and from tap installed on filtrate pump from C102
bleaching stage D-2)and Bleach Plant Effluent-alkaline(alkaline sewer collected from tap installed on filtrate
pump from alkaline extraction stage E.). See A.(7.)Effluent Guideline Sampling Plan Special Condition
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters as prepared by the permittee(Internal Outfall 002 parameters+internal Outfall 003
parameters+AOX from Outfall 001)shall be reported on a quarterly basis or more frequently;refer to A.(7.)
Effluent Guideline Sampling Plan Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance or flow
meters,and report total bleach plant flow(acid+alkaline wastestreams)in DMRs. Grab-collect separate grab
samples every 4-hours for 24-hour period from both the acid and alkaline streams,which will then be
composited separately by the lab,and analyzed as separate 24-hr composite acid and alkaline samples.
Composite-collect separate grab samples every 4 hours for 24-hour period from both the acid and alkaline
streams,then prepare and analyze a single flow-proportioned composite of the acid and alkaline wastestream
4. For compliance purposes,the pemdttee must report the total chloroform mass loading based on addition of
separate acid and alkaline chloroform mass loadings.
5. Limits are based on Minimum Levels(ML)specified in 40 CFR 430.01.
Definitions:
lb/day—Pounds per day pg/L—Micrograms per liter
pg/L—Picograms per liter

Permit Number: NC0000272
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration,the
discharge of wastewater from the hardwood bleach plant to the wastewater treatment plant through
internal outfall(s)003 (E31),shall be limited and monitored by the Pennittee as specified below and in A.
(7.)Effluent Guideline Sam ling Plan Special Condition:
EftfuentCha'rac&hstiEs Llmlts Monitoring.Reguiiements ,
p J
Monthly , lF +Daffy Measurement. Sample Type3 , ,Sample'
Aveiage t McRlmam 'FregSency,<<N +
> Location••-,
Flo Weekly Calculated E3
Chloroform 6.5lb/day 10.9lb/day Quarterly Grab E3
2,3,7,8 Tetmchloro-dibenzo- < 10 pg/L Annual Composite E3
-dioxin(TCDD).
2,3,7,8 Tetrachloro-dibenzo- 31.9 pg/L Annual Composite E3
furan(TCDF
Trichlorosyringol < 2.5 µg/LS Quarterly Composite E3
3,4,5-Trichlorocatechol < 5.0 µg/L Quarterly Composite E3
3,4,6-TrieWorocatechol < 5.0 µg/L3 Quarterly Composite E3
3,4,5-Trichloroguaiacol < 2.5 pg/L' Quarterly Composite E3
3,4,6-Trichloroguaiacol < 2.5 µg/L Quarterly Composite E3
4,5,6-Trichloroguaiacol < 2.5 µITV Quarterly Composite E3
2,4,5-Trichlorophenol < 2.5 µg/L Quarterly Composite E3
2,4,6-Trichlorophenol < 2.5 pg/L Quarteily Composite E3
Tetrachlorocatechol < 5.0 µg/L Quarterly Composite E3
Tetrachloroguaiacol < 5.0 µgIV Quarterly Composite E3
2,3,4,6-Tetrachlorophenol < 2.5 pg/L' Quarterly Composite -E3
Pentachlorophenol .< 5.0 pg/L Quarterly Composite E3
Footnotes:
1. Sample Location:E3—Effluent is composed of Bleach Plant Effluent-acid(acid sewer collected from tap
installed on filtrate pump from CIOr bleaching stage D-100)and Bleach Plant Effluent-alkaline(alkaline
sewer collected from tap installed on filtrate pump from alkaline extraction stage E.).See A.(7.)Effluent
Guideline Sampling Plan Special Condition.
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters,as prepared by the pemuttee(Internal Outfa11002 parameters+internal Outfall 003
parameters+AOX from Outfall 001)shall be reported on a quarterly basis or more frequently;refer to A.(7.)
Effluent Guideline Sampling Plan Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance or by flow
meter,and report total bleach plant flow(acid+alkaline wastestreams)in DMRs. Grab-collect separate grab
samples every 4-hours for 24-hour period from both the acid and alkaline streams,which will then be
composited separately by the lab,and analyzed as separate 24-hr composite acid and alkaline samples.
Composite-collect separate grab samples every 4 hours for 24-hour period from both the acid and alkaline
streams,then prepare and analyze a single flow-proportioned composite of the acid and alkaline wastestream.
4. For compliance purposes,the pennittee must report the total chloroform mass loading based on addition of
separate acid and alkaline chloroform mass loadings.
5. Limits are based on Minimum Levels(ML)specified in 40 CFR 430.01.
Definitions:
lb/day—Pounds per day pg/L—Micrograms per liter
pg/L—Picograms per liter

1
Permit Number: NC00OO272
A.(4.) CHRONIC TOXICITY PERMIT LIMIT(QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 90%.
The permit holder shall perform at a minimum , uag rlerh monitoring using test procedures outlined in the'North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure,"Revised February 1998,or subsequent versions or
"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or subsequent
versions.The tests will be performed during the months of March,June,September,December.Effluent sampling
for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit
limit,then multiple-concentration testing shall be performed at a minimum,in each of the two following months as
described in"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or
subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival.The definition of"detectable impairment,"collection
methods,exposure regimes,and further statistical methods are specified in the"North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form(MR-1)for the months in which tests were performed,using the parameter code TGP3B for the
pass/fail results and THP313 for the Chronic Value.Additionally,DWQ Form AT-3(original)is to be sent to the
following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete,accurate,include all supporting chemical/physical measurements and all
concentration/response data,and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the
permittee will complete the information located at the top of the aquatic toxicity(AT)test form indicating the
facility name,permit number,pipe number,county,and the month/year of the report with the notation of"No Flow"
in the comment area of the form.The report shall be submitted to the Environmental Sciences Branch at the address
cited above.Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month. Should any test data from this monitoring requirement or
tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream,
this permit may be re-opened and modified to include alternate monitoring requirements or limits.
If the Pemmittee monitors any pollutant more frequently then required by this permit,the results of such monitoring
shall be included in the calculation&reporting of the data submitted on the DMR&all AT Forms submitted.
NOTE: Failure to achieve test conditions as specified in the cited document,such as minimum control organism
survival,minimum control organism reproduction,and appropriate environmental controls,shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.

Permit Number: NC0000272
A. (5.) INSTREAM MONITORING SPECIAL CONDITION
Stream Mile Location Description Parameter Frequency
Designation Marker
UP 63.8 Pigeon River upstream of the Temperature Daily
waste treatment plant outfall D.O. Daily
(prior to mixing with the Conductivity Daily
discharge) Color' 2/Week
Flog Daily
_ Fecal Coliform Weekly
DNV 62.9 Pigeon River at Fiberville Bridge Temperature Daily
D.O. Daily
Conductivity Daily
Color' 2/Week
DN2 57.7 Pigeon River Above Clyde Temperature Daily
D.O. Daily
DN3 55.5 Pigeon River Below Clyde See Footnote 3 See Footnote 3
DN4 53.5 Pigeon River at NCSR 1625 See Footnote 3 See Footnote 3
bridge
DN5 42.6 Pigeon River at Hepco Temperature Weekly
D.O. Weekly
Colon Weekly
Flow, Daily
DN6 26.0 Pigeon River prior to mixing with Color Weekly
Big Creek
BC —26.0 Mouth of Big Creek prior to Color Weekly
mixing with the Pigeon River
DN7 24.7 Pigeon River at Browns Bridge Temperature Weekly
(—NUIN State Line) D.O. Weekly
Color' Weekly
All instream samples shall be grab samples.
Footnotes:
1. Color(See A.(8.)Color Analysis and Compliance Special Condition). All instream samples collected
shall be representative of the Pigeon River and Big Creek,respectively. Both true and apparent color
shall be monitored using the methods specified in A. (8.)Color Analysis and Compliance Special
Condition. Samples shall be collected at stations DN6,BC, and DN7 only when at least one generator
at Progress Energy is in operation and releasing water to the Pigeon River. Samples collected at DNl
shall be collected from the middle or midpoint of the transect of the Pigeon River.
2. Flow monitoring is necessary,as specified above for the True Color calculation.
3. Dissolved Oxygen. The average daily dissolved oxygen concentration measured at River Mile 62.9
(DNI),and 57.7(DN2),shall not be less than 5.0 mg/L and the instantaneous minimum dissolved
oxygen concentration shall not be less than 4.0 mg/L(See A. (10.) Dissolved Oxygen Special
Condition). If the dissolved oxygen drops below 5.0 mg/L at station 57.7 then monitoring shall be
required at stations 55.5(DN3)and 53.5 (DN4).

r
Permit Number: NC0000272
A. (6.) BEST MANAGEMENT PRACTICES (BMP)SPECIAL CONDITION
The permittee must implement the BMPs specified below. The primary BMP objective is to prevent
leaks and spills of spent pulping liquors, soap;and turpentine. A secondary objective is to contain,
collect, and recover at the immediate process area,or otherwise control,those leaks, spills,and intentional
diversions of spent pulping liquor,soap, and turpentine that do occur. BMPs must be developed
according to best engineering practices and must be implemented in a manner that takes into account the
specific circumstances at the mill.
Section A. BMP Implementation Requirements
1. The permittee must return spilled or diverted spent pulping liquors,soap, and turpentine to the
process to the maximum extent practicable as determined by the mill,recover such materials outside
the process, or discharge spilled or diverted material at a rate that does not disrupt the receiving
wastewater treatment system.
2. The permittee must maintain a program to identify and repair leaking equipment items. This program
must include: (i)Regular daily visual inspections of process area with equipment items in spent
pulping liquor, soap,and turpentine service; (ii)Immediate repair of leaking equipment items,when
possible. Leaking equipment items that cannot be repaired during normal operations must be
identified,temporary means for mitigating the leaks must be provided,and the leaking equipment
items repaired during the next maintenance outage; (iii)Identification of conditions under which
production will be curtailed or halted to repair leaking equipment items or to prevent pulping liquor,
soap,and turpentine leaks and spills; and(iv)A means for tracking repairs over time to identify those
equipment items where upgrade or replacement may be warranted based on frequency and severity of
leaks,spills, or failures.
3. The permittee must operate continuous, automatic monitoring systems that the mill determines are
necessary to detect and control leaks, spills,and intentional diversions of spent pulping liquor, soap,
and turpentine.These monitoring systems should be.integrated with the mill process control system
and may include,e.g.,high level monitors and alarms on storage tanks;process area conductivity(or
pH)monitors and alarms; and process area sewer,process wastewater, and wastewater treatment plant
conductivity(or pH)monitors and alarms.
4. The pern ittee must maintain a program of initial and refresher training of operators,maintenance
personnel,and other technical and supervisory personnel who have responsibility for operating,
maintaining,or supervising the operation and maintenance of equipment items in spent pulping
liquor, soap,and turpentine service.The refresher training must be conducted at least annually and
the training program must be documented.
5. The permittee must prepare a brief report that evaluates each spill of spent pulping liquor, soap, or
turpentine that is not contained at the immediate process area and any intentional diversion of spent
pulping liquor, soap, or turpentine that is not contained at the immediate process area.The report
must describe the equipment items involved,the circumstances leading to the incident,the
effectiveness of the corective actions taken to contain and recover the spill or intentional diversion,
and plans to develop changes to equipment and operating and maintenance practices as necessary to
prevent recurrence.Discussion of the reports must be included as part of the annual refresher training.
6. The permittee must maintain a program to review any planned modifications to the pulping and
chemical recovery facilities and any construction activities in the pulping and chemical recovery areas
before these activities commence. The purpose of such review is to prevent leaks and spills of spent
pulping liquor,soap,and turpentine during the planned modifications,and to ensure that construction
and supervisory personnel are aware of possible liquor diversions and of the requirement to prevent
leaks and spills of spent pulping liquors,soap,and turpentine during construction.
7. The permittee must install and maintain secondary containment(i.e.,containment constructed of
materials impervious to pulping liquors) for spent pulping liquor bulk storage tanks equivalent to the
volume of the largest tank plus sufficient freeboard for precipitation.An annual tank integrity testing
program,if coupled with other containment or diversion structures,may be substituted for secondary
containment for spent pulping liquor bulk storage tanks.

I
Permit Number: NC0000272
8. The perrnittee must install and maintain secondary containment for turpentine bulk storage tanks.
9. The permittee must install and maintain curbing, diking or other means of isolating soap and
turpentine processing and loading areas from the wastewater treatment facilities.
10. The permittee must conduct wastewater monitoring to detect leaks and spills,to track the
effectiveness of the BMPs,and to detect trends in spent pulping liquor losses. Such monitoring must
be performed in accordance with Section E.
Section B. BMP Plan Requirements
1. The permittee must maintain and implement a BMP Plan.The BMP Plan must be based on a detailed
engineering review as described in this section. The BMP Plan must specify the procedures and the
practices required for the mill to meet the requirements of Section A,the construction the mill
determines is necessary to meet those requirements including a schedule for such construction,and
the monitoring program(including the statistically derived action levels)that will be used to meet the
requirements of Section E.The BMP Plan also must specify the period of time that the mill
determines the action levels established under Section D may be exceeded without triggering the
responses specified in Section E.
2. The permittee must conduct a detailed engineering review of the pulping and chemical recovery
operations--including but not limited to process equipment, storage tanks,pipelines and pumping
systems,loading and unloading facilities,and other appurtenant
st pulping
determining
equipment items in spent pulping liquor,soap, and turpentine
the magnitude and routing of potential leaks, spills,and intentional diversions of spent pulping
liquors, soap,and turpentine during the following periods of operation: (i)Process start-ups and shut
downs; (ii)Maintenance; (iii)Production grade changes; (iv) Storm or other weather events; (v)
Power failures;and(vi)Normal operations.
3. As part of the engineering review,the permittee must determine whether existing spent pulping liquor
containment facilities are of adequate capacity for collection and storage of anticipated intentional
liquor diversions with sufficient contingency for collection and containment of spills.The to den ern and neering
review must also consider: (i)The need for continuous, automatic monitoring systems
control leaks and spills of spent pulping liquor,soap,and turpentine;(ii)The need for process
wastewater diversion facilities to protect end=of--pipe wastewater treatment facilities from adverse
effects of spills and diversions of spent pulping liquors,soap,and turpentine; (iii)The potential for
contamination of storm water from the immediate process areas;and(iv)The extent to which
segregation and/or collection and treatment of contaminated storm water from the immediate process
areas is appropriate.
4. The penmittee must amend its BMP Plan whenever there is a change in mill design,construction,
operation;or maintenance that materially affects the potential for leaks or spills of spent pulping
liquor,turpentine,or soap from the immediate process areas.
5. The permittee must complete a review and evaluation of the BMP Plan five years after the first BMP
Plan is prepared and,except as provided in Section BA.,once every five years thereafter. As a result
of this review and evaluation,the permittee must amend the BMP Plan within three months of the
review if the mill determines that any new or modified management practices and engineered controls
are necessary to reduce significantly the likelihood of spent pulping liquor, soap,and turpentine leaks,
spills,or intentional diversions from the immediate process areas,including a schedule for
implementation of such practices and controls.
6. The BMP Plan,and any amendments thereto,must be reviewed by the senior technical manager at the
mill and approved and signed by the mill manager.Any person signing the BMP Plan or its
amendments must certify to the Division under penalty of law that the BMP Plan(or its amendments)
has been prepared in accordance with good engineering practices and in accordance with this
regulation.The permittee is not required to obtain approval from the Division of the BMP Plan or any
amendments thereto.

Permit Number: NC0000272
Section C. BMP Recordkeeping Requirements
1. The permittee must maintain on its premises a complete copy of the current BMP Plan and.the
records specified in Section C.2 and must make such BMP Plan and records available to the Division
for review upon request.
2. The permittee must maintain the following records for three years from the date they are created: (i)
Records tracking the repairs performed in accordance with the repair program described in Section A;
(ii)Records of initial and refresher training conducted in accordance with Section A; (iii)Reports
prepared in accordance with Section A;and(iv)Records of monitoring required by Sections A and E.
Section D. Establishment of Wastewater Treatment System Influent Action Levels
l. The permittee must conduct a monitoring program per Section D.2,for the purpose of defining
wastewater treatment system influent characteristics(or action levels),described in Section D.3,that
will trigger requirements to initiate investigations on BMP effectiveness and to take corrective action.
2, The permittee must employ the following procedures in order to develop the action levels required by
Section D:
• Monitoring parameters.The permittee must collect 24-hour composite samples and analyze the
samples for a measure of organic content(e.g.,Chemical Oxygen Demand (COD)or Total
Organic Carbon(TOC)).Alternatively,the mill may use a measure related to spent pulping liquor
losses measured continuously and averaged over 24 hours (e.g.,specific conductivity or color).
• Monitoring locations.The permittee must conduct monitoring at the point influent enters the
wastewater treatment system. For the purposes of this requirement,the permittee may select
alternate monitoring point(s)in order to isolate possible sources of spent pulping liquor,soap, or
turpentine from other possible sources of organic wastewaters that are tributary to the wastewater
treatment facilities(e.g.,bleach plants,paper machines and secondary fiber operations).
3. The pennittee must maintain an influent action levels monitoring program using the procedures
specified in Section D and must maintain action levels based on the results of that program.A
wastewater treatment influent action level is a statistically detemtined pollutant loading determined
by a statistical analysis of six months of daily measurements.The action levels must consist of a
lower action level,which if exceeded will trigger the investigation requirements described in Section
E, and an upper action level,which if exceeded will trigger the corrective action requirements
described in Section E.
4. The permittee must complete a second six-month monitoring program using the procedures specified
in Section D and must establish revised action levels based on the results of that program.The initial
action levels shall remain in effect until replaced by revised action levels based on Section D5
requirements.
5. Action levels developed under this Section must be revised using six months of monitoring data after
any change in mill design,construction,operation,or maintenance that materially affects the potential
for leaks or spills of spent pulping liquor, soap, or turpentine from the immediate process areas.
Section E. BMP Monitoring,Corrective Action,and Reporting Requirements
1. The permittee must conduct daily monitoring of the influent to the wastewater treatment system in
accordance with the procedures described in Section D for the purpose of detecting leaks and spills,
tracking the effectiveness of the BMPs,and detecting trends in spent pulping liquor losses.
2. Whenever monitoring results exceed the lower action level for the period of time specified in the
BMP Plan,the permittee must conduct an investigation to determine the cause of such exceedance.
Whenever monitoring results exceed the upper action level for the period of time specified in the
BMP Plan,the permittee must complete corrective action to bring the wastewater treatment system
influent mass loading below the lower action level as soon as practicable.

r
Permit Number: NC0000272
3. Although exceedances of the action levels will not constitute violations of an NPDES permit,failure
to take the actions required by Section E.2 as soon as practicable will be a permit Violation.
4. The permittee must report to the Division the results of the daily monitoring conducted pursuant to
Section E.I.Such reports must include a summary of the monitoring results,the number and dates of
exceedances of the applicable action levels,and brief descriptions of any corrective actions taken to
respond to such exceedances. Submission of such reports shall be annually,by March 31'`of the
following year.
Section F. BMP Defmitions
1. Action Level:A daily pollutant loading that when exceeded triggers investigative or corrective action.
Mills determine action levels by a statistical.analysis of six months of daily measurements collected at
the mill.For example,the lower action level may be the 75th percentile of the running seven-day
averages(that value exceeded by 25 percent of the running seven-day averages)and the upper action
level may be the 90th percentile of the running seven-day averages(that value exceeded by 10
percent of the running seven-day averages).
2. Division: North Carolina DENR,Division of Water Quality, 1617 Mail Service Center,Raleigh,
North Carolina 27699-1617.
3. Equipment Items in Spent Pulping Liquor, Soap,and Turpentine Service:Any process vessel,storage
tank,pumping system,evaporator,heat exchanger,recovery furnace or boiler,pipeline,valve,fitting,
or other device that contains,processes,transports,or comes into contact with spent pulping liquor,
soap,or turpentine.Sometimes referred to as"equipment items."
4. Immediate Process Area:The location at the mill where pulping,screening,knotting,pulp washing,
pulping liquor concentration,pulping liquor processing,and chemical recovery facilities are located,
generally the battery limits of the aforementioned processes. "Immediate process area"includes spent
pulping liquor storage and spill control tanks located at the mill,whether or not they are located in the
immediate process area.
5. Intentional Diversion:The planned removal of spent pulping liquor,soap, or turpentine from
equipment items in spent pulping liquor, soap, or turpentine service by the mill for any purpose
including,but not limited to,maintenance, grade changes,or process shutdowns.
6. Mill:The owner or operator of a direct or indirect discharging pulp,paper,or paperboard
manufacturing facility subject to this section.
7. Senior Technical Manager:The person designated by the mill manager to review the BMP Plan.The
senior technical manager shall be the chief engineer at the mill,the manager of pulping and chemical
recovery operations,or other such responsible person designated by the mill manager who has
knowledge of and responsibility for pulping and chemical recovery operations.
8. Soap:The product of reaction between the alkali in kraft pulping liquor and fatty acid portions of the
wood,which precipitate out when water is evaporated from the spent pulping liquor.
9. Spent Pulping Liquor:For kraft and soda mills"spent pulping liquor"means black liquor that is used,
generated, stored,or processed at any point in the pulping and chemical recovery processes.
10.Turpentine:A mixture of terpenes,principally pinene,obtained by the steam distillation of pine gum
recovered from the condensation of digester relief gases from the cooking of softwoods by the kraft
pulping process. Sometimes referred to as sulfate turpentine.

Permit Number: NC0000272
A. (7.) EFFLUENT GUIDELINE SAMPLING PLAN SPECIAL CONDITION
The bleach.plant effluent samples(Outfalls 002 and 003)shall be analyzed for 2,3,7,8-TCDD in
accordance with EPA Method 1613. A single sample,from each of the bleach plant effluents,may be
analyzed to determine compliance with the daily maximum effluent limitation.
The bleach plant effluent samples(Outfa11002 and 003)shall be analyzed for the 12 chlorinated phenolic
compounds in accordance with EPA Method 1653. A single sample, from each of the bleach plant
effluents,may be analyzed to determine compliance with the daily maximum effluent limitation. The
Minimum Levels for each of the 12 chlorinated compounds are the same as the Daily Maximum
concentrations listed on the effluent pages for the respective outfall(s).
The final wastewater treatment plant effluent sample(Outfa11001)shall be analyzed for AOX in
accordance with EPA Method 1650,or subsequent test methods approved by the Division.
The permittee may request future monitoring modifications to the Effluent Guideline requirements,
including 1)use of ECF certification in lieu of monitoring for chloroform in the bleach plant effluents
(Outfall(s)002 and 003)2)demonstrating compliance.using samples collected less frequently than every
four hours;3)using automated composite volatile samplers for chloroform sampling; and 4)using
automated composite samplers for chlorophenolic, 2,3,7,8 TCDD and 2,3,7,8 TCDF sampling. Such
future requests will be evaluated in accordance with 15A NCAC 2H.0114.
The flow calculations for internal Outfall(s) 002 and 003 shall not be subject to accuracy requirements
specified under Part II,Section D.3. This exclusion is similar to that provided for pump log flow
calculations.
Chemical data for Effluent Guideline parameters(Outfall(s)002 and 003 parameters+AOX from Outfall
001)shall be submitted to the Division on a quarterly basis or more frequently(January-March,April-
June,July-September,October-December). Quarterly submissions shall be due 60 days following the
last day of each quarter(Due dates=May 31,August 31,November 30,and February 28). Chemical data
shall be submitted on Division-approved DMR forms,with a separate form provided for each month.

Permit Number: NC0000272
A. (8.) REQUIREMENTS FOR COLOR ANALYSIS AND COMPLIANCE SPECIAL CONDITION
1. The color reduction requirements contained in this special condition have been derived directly
from the mill's efforts to identify possible reduction measures and from the EPA Technology
Review Workgroup(TRW report dated February 25,2008) c.
2. The average annual discharge of true color for each calendar year shall not exceed 38,020 pounds
per day. The monthly average effluent true color loading shall not exceed 52,000 pounds per day.
For the purpose of this permit only, "pounds of true color"is calculated by the following
equation:
Effluent Flow(MGD)x Effluent True Color Level(Platinum Cobalt Units)x 8.34.
3. All samples collected for color analysis and for use in the above calculation shall be measured
and reported using the procedure referenced in 39 FR 430.11 (b)(May 29, 1974)-true and
apparent color or as amended by the EPA.
4. Four years after the permit effective date,the average annual discharge of true color for each
calendar year shall not exceed 32,000-36,000 pounds per day.
5. The permittee shall not increase the mill's pulp production capacity during the term of this permit,
unless the permittee can demonstrate that the increased production can be achieved while
reducing color loading. In addition,increasing the mill's pulp production capacity may require
permit revision in accordance with North Carolina's NPDES Permitting rules.
6. The NPDES Permit shall be subject to reopening in order to modify the color requirements based
upon the following:
• Any breakthrough in color removal technologies. Such breakthroughs shall be brought to
the NPDES Committee for consideration,by Blue Ridge Paperand the Division of Water
Quality,as soon as they are discovered.
• An acceptable statistical analysis of effluent color discharge data demonstrating
significantly better color removal performance than that currently prescribed in the
permit, except as noted herein.
• Successful application of end-of-pipe color reduction technology or in-mill color
minimization effort that results in significant and measurable reduced mass color
discharge.
7. The transfer of this NPDES permit will not proceed until any successor-in-interest to the current
permittee has agreed to accept the provisions of this permit.
8. The facility will provide annual progress reports to the Division on the color reduction efforts.
9. To minimize color discharges during periods of lowest river flow and higher recreational use in
the river,no major maintenance outages will be scheduled during the months of June,July and
August.
10. Based on the EPA TRW reconuiiendations,the permittee shall evaluate the technologies
identified below and develop an implementation plan that would either utilize these technologies

Permit Number: NC0000272
when technically,operationally,or economically feasible, or identify other options that will result
in similar increments of color reduction. The TRW may review and comment on the justification
for any item among the following recommendations found by Blue Ridge Paper to be technically,
operationally, or economically infeasible:
A. The following suite of items will be implemented by the permittee,upon further expedited
evaluation if necessary to refine detailed design and operating parameters, during this permit
term:
• further improvements in leak and spill prevention and control (BMP's) covering all
process lines,including probable color-generating sources(e.g.,sulfide containing)
among white and green liquors in the recovery cycle
• process optimization(enhanced extraction stages,reduced bleaching chemical use, etc.);
and
• addition of second stage oxygen delignification on the sofiwood/pine fiber line
The time necessary for Blue Ridge Paper to implement these items or alternatives in logical
sequence should realistically reflect the Mill's ability to design,fund, and install or implement
them at the earliest possible date. For example,an updated and detailed evaluation of the addition
of second stage oxygen delignification on the softwood fiber line should identify necessary
adjustments to upstream pulp digestion(e.g.,kappa number targets),bleaching(e.g.,bleaching
chemical usage rates,kappa factors)and downstream brightness/strength and other relevant
process control and product quality parameters,designing and costing,and refusing color
reduction projections.
B. The following.items will be evaluated and implemented as appropriate during this permit
term:
• increasing filtrate recycle and use of the existing BFR process for the hardwood fiber line
• reducing black liquor carryover by further evaluating in detail and adjusting operating
conditions in the direct contact evaporators(DCEs)
• reducing impact of Chloride Removal Process(CRP)purge on treated effluent color by
gathering data sets over as long a period as possible,preferably at full scale,with and
without the CRP purge to better understand the impact on treatability of this source of
color. If it is determined that CRP color is found not to be removed in the treatment
system,further study should assess:
o securing whatever additional reductions are possible based on any
demonstrated technology that works and can be economically applied to this
waste stream, either within the mill and sewer system,or chlorine dioxide
pretreatment to reduce color in the CRP purge stream prior to introduction to
the treatment system
o avoiding release of the CRP purge during periods of low flow in the receiving
stream
• better understanding and controlling, if possible,the physical and chemical mechanisms
underlying"sewer generated color". This will require a sustained effort going forward
beyond this permit term given that process changes and BMP improvements to be made
will more than likely further change the chemistry and mechanisms underlying"sewer
generated color".
• improving color removal by the Mill's wastewater treatment plant via:
o better equalizing and further optimizing treatment by using polymers and other
chemicals to pretreat highly-colored segregated wastewaters including streams
that are diverted to the extra primary clarifier, or by other operational and/or
treatment means not yet identified

Permit Number: NC0000272
o investigating use of polymers or other chemicals upstream of the secondary
clarifiers,especially during periods of high influent color and/or low river flow
11. The facility shall submit the color reduction implementation plan within the first year of permit
issuance.The permit will be reopened and modified to include interim requirements and dates for -
their achievement based on the submitted implementation plan.
12. The facility shall submit a low flow contingency plan for color control within the first year of
permit issuance.
A. (9.) DIOXIN MONITORING SPECIAL CONDITION
The permittee shall perform the analyses for dioxin and dibenzefuran as outlined below:
5amolmePomt '' '� , �SMonitonng
»Re tilrements
a s Measuremeril Sample Type ;.
Pre
Influent to Wastewater Annual Composite
Treatment Plant]
Effluen Annual Composite
Sludge Annual Composite
Landfill Leachate Annual Composite
Footnotes:
1. The samples shall be analyzed for 2,3,7,8-TCDD and 2,3,7,8 TCDF in accordance with EPA Method
1613. A single sample may be analyzed. Alternatively,the sample volumes may be collected to
enable the sample to be split(duplicate analysis).The Minimum Level in the effluent for 2,3,7,8-
TCDD and 2,3,7,8 TCDF by EPA Method 1613 is 10 pg/l. -
2. The effluent samples shall be analyzed for the full range of dioxin and furan isomers as identified in
the list below and shall be in accordance with EPA Method 1613. A single sample may be analyzed.
Alternatively,the sample volumes may be collected to enable the sample to be split(duplicate
analysis).The minimum level using these methods for the purpose of compliance evaluation is
considered to be 10 picograms per liter
DIOXIN DIBENZOFURAN ,
Isomer Isomer
2,3,7,8 TCDD 2,3,7,8 TCDF
1,2,3,7,8 PeCDD 1,2,3,7,8 PeCDF
2,3,4,7,8 PeCDF
1,2,3,4,7,8 HxCDD 1,2,3,4,7,8 HxCDF
1,2,3,7,8,9 HxCDD 1,2,3,7,8,9 HxCDF
1,2,3,6,7,8 HxCDF
1,2,3,6,7,8 HxCDD 2,3,4,6,7,8 HxCDF
1,2,3,4,6,7,8 HpCDD 1,2,3,4,6,7,8 HpCDF
1,2,3,4,7,8,9 HpCDF
If dioxins or dibenzofurans are detected in the effluent above the minimum level,the permittee shall
initiate Quarterly monitoring of sludge,landfill leachate,and effluent.

Permit Number: NC0000272
Additional Requirements
Annual dioxin fish tissue analysis shall be performed during the 1", 3rd,and Sd'calendar year of this
permit term in accordance with the Division of Water Quality approved monitoring plan.The monitoring
plan is an enforceable part of this permit.All dioxin data collected as part of this monitoring requirement
will be reported as required in the plan,no later than 180 days after sampling.The tissue monitoring will
be performed in Waterville Lake, although the facility may substitute one lake event with a sampling in
the Pigeon River below the outfall.
A. (10.) DISSOLVED OXYGEN SPECIAL CONDITION
The permittee shall maintain an average daily dissolved oxygen concentration of not less than 5.0 mg/L
with a minimum instantaneous value of not less than 4.0 mg/L at.River Miles 62.9 (DNl)and 57.7
(DN2). The permittee shall operate oxygen injection-facilities at the outfall.structure,at 0.9 miles
downstream of the discharge,and at 2.1 miles downstream of the discharge,as necessary,to comply with
this requirement. These facilities shall be operated in a manner whicli will maintain the water quality
standard for dissolved oxygen in the Pigeon River downstream of the discharge. Blue Ridge Paper shall
report the date and duration of oxygen injection use as a supplement to the monthly Discharge Monitoring
Report(DMR)forms.If the dissolved oxygen drops below 5.0 mg/L at station DN2 then monitoring shall
be required at stations DN3 and DN4.
A. (11.) TOWN OF CANTON INFLOW AND INFILTRATION SPECIAL CONDITION
The permittee shall make continued efforts to promote reduction of inflow/infiltration to the Town of
Canton's wastewater collection system.
A. (12.) - TEMPERATURE VARIANCE REVIEW SPECIAL CONDITION .
Blue Ridge Paper shall complete an analysis of temperature,including thermal modeling and shall submit
a balanced and indigenous species study,no later than 180 days prior to the permit expiration date. As
part of this analysis,Blue Ridge Paper shall submit a complete temperature variance report documenting
the need for a continued temperature variance.The temperature delta of 8.5°C can be adjusted based on
the results of the BIP thermal modeling.
The study shall be performed in accordance with the Division of Water Quality approved plan.The
temperature analysis and the balanced and indigenous study plan shall conform to the specifications
outlined in 40 CFR 125 Subpart H and the EPA's Draft 316a Guidance Manual,dated 1977.The EPA
shall be provided an opportunity to review the plan prior to the commencement of the study.

peverg Canton Office
175 Main Street • Coon, NC 28716
packaging
May 14, 2019
I
Certified Mail: 7015 0640 0004 43317522
Return Receipt Requested MAY 1 7 2019
Mr. G. Landon Davidson, P.G., Regional Supervisor Wxe,
North Carolina Department of Environmental Quality P"
Division of Water Resources—Water Quality Regional Operators Section
2090 US 70 Highway
Swannanoa, North Carolina 28778-8211
Subject: Notice of Violation—Formal Response
Tracking Number: NOV-2019-LV-0014
Permit Number: NC0000272
Blue Ridge Paper Products (d.b.a. Evergreen Packaging)—Canton Mill
Haywood County
Dear Mr. Davidson,
The facility provided information on this exceedance in the July, 2018 eDMR. A more detailed
response follows:
On July 24, 2018, Evergreen Packaging (EP) exceeded the secondary effluent fecal coliform
daily limit of 400 colonies per 100 ml, with a result of greater than 600 colonies per 100 ml. On
that day, the Town of Canton (TOC) effluent showed a fecal coliform of greater than 60,000
colonies per 100 ml, At the time of the exceedance, the TOC failed to properly disinfect the
influent that entered into the EP Waste Water Treatment Plant (WWTP). Additionally, EP
identified a source of fecal coliform within the contained mill chip system storm water collection
system.
The TOC maintains a chlorine injection system on the EP property that is designed to
completely disinfect the TOC effluent prior to its introduction into the EP WWTP. EP
employees check the TOC effluent hourly for chlorine residual. In the 24 hours preceding the
sample collection time the chlorine residual ranged from zero to ten mg/l, with zero residual
demonstrating insufficient disinfection. The current design of the TOC system does not provide
an adequate contact time to properly disinfect the TOC effluent. It has been expressed to the
TOC the need for a different chemical that requires a shorter contact time.
i

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Following the exceedance on July 24, 2018 the investigation into the cause revealed higher
than normal levels of fecal coliform in the EP wood chip area storm water collection system. It
was determined that a sanitary sewer line that serves the chip system area had ruptured. This line
break allowed fecal matter to enter the waste water treatment system. The chip system sanitary
line was replaced. Following the replacement, no fecal coliform have been noted from the chip
system area.
In the weeks and months following this exceedance, there have been numerous conversations
and two meetings with the TOC in which proper disinfection of the influent is the central topic of
discussion. There is a plan in place for the TOC to run a trial of Peracetic Acid (PAA) as a
supplemental disinfection resource with hopes that the results will be such that the current
chlorine system can be replaced and PAA used as the sole means of TOC effluent disinfection.
One of the benefits of the PAA system is a shorter required contact time. The TOC has assured
EP that the PAA trial will be underway no later than June 1, 2019. EP strongly believes that
these efforts will eliminate fecal coliform exceedances in the future.
EP is dedicated to working with the TOC and the State of North Carolina to protect state water
resources and can assure you that all efforts are being made to avoid future fecal issues.
If I can answer further questions, please feel free to contact me.
Thank you.
Tracy Wi 11 is
Waste Water Treatment Plant Operations Supervisor/ORC
NCWPCS Waste Water Grade 4—Certificate#998768
tracy.willis(a�everpack.com
office: 828.646.2874
cell: 828.424.9955
CC:
Matthew Claypool—EPLLC
Michael Ferguson—EPLLC
Scott Bragg- EPLLC

reve7rg 75 Men.% Office
175 oin Street• Canton, NC 28716
packaging
May 14, 2019 °'`'�' rr "D
Certified Mail: 7015 0640 0004 43317539 MAY 1 7 2019
Return Receipt Requested
Water OuP14%,r- 7-ram!n-111N ns
Mr. G. Landon Davidson,P.G., Regional Supervisor n r
North Carolina Department of Environmental Quality
Division of Water Resources—Water Quality Regional Operators Section
2090 US 70 Highway
Swannanoa,North Carolina 28778-8211
Subject: Notice of Violation—Formal Response
Tracking Number: NOV-2019-LV-0264
Permit Number: NC0000272
Blue Ridge Paper Products (d.b.a. Evergreen Packaging)—Canton Mill
Haywood County
Dear Mr. Davidson,
The facility provided information on this exceedance in the February, 2019 eDMR. A more
detailed response follows:
On February 4, 2019, Evergreen Packaging (EP) exceeded the secondary effluent fecal
coliform daily limit of 400 colonies per 100 ml,with a result of greater than 600 colonies per 100
ml. On that day, the Town of Canton (TOC) effluent showed a fecal coliform of greater than
7272 colonies per 100 ml. A subsequent investigation into the fecal coliform exceedance found
that the TOC drained and cleaned a water treatment plant settling basin the evening before at a
rate much faster than is their standard practice.
The TOC employee who drained the basin at a higher rate was new to the position and did not
understand the impact that the speed at which he drained the vessel would have on the hydraulic
load and the introduction of fecal coliform to the EP Waste Water Treatment Plant (WWTP).
The material in this settling basin is mud and organic material that is settled from river water as it
is being processed into drinking water. The result of this rapid dumping caused a period of at
least two hours in which there was no chlorine residual measure in the TOC influent into the EP
WWTP.
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It has been EP WWTP experience in the past that the material that is received when settling
basins are drained has a very high chlorine demand, and it is difficult to maintain a chlorine
residual without adding additional chlorine during the drain. The hydraulic timing of the TOC
zero chlorine residual and the secondary effluent fecal sample collection coincides with the
higher fecal test result.
In working with the TOC following this exceedance, a small batch water plant disinfection
procedure has since been instituted in which chlorine is added at the source with discharge
chlorine residual testing completed before release. Additionally, the TOC Water Department
employees now call to inform EP when they plan to discharge settling basin material so that EP
can discuss the procedure and make sure all steps are taken to provide proper disinfection of the
influent prior to introduction to the EP WWTP.
In the weeks following this exceedance, there have been two meetings with the TOC in which
proper disinfection of the influent is the central topic of discussion. There is a plan in place for
the TOC to run a trial of Peracetic Acid (PAA) as a supplemental disinfection resource with
hopes that the results will be such that the current chlorine system can be replaced and PAA used
as the sole means of influent disinfection. The TOC has assured EP that the PAA trial will be
underway no later than June 1, 2019. These efforts will eliminate fecal coliform exceedances in
the future.
EP is dedicated to working with the TOC and the State of North Carolina to protect water
resources and can assure you that all efforts are being made to avoid future fecal issues.
If I can be of further assistance,please feel free to contact me.
Thank you,
lit/��
Tracy Willis
Waste Water Treatment Plant Operations Supervisor/ORC
NCWPCS Waste Water Grade 4—Certificate#998768
tracv.willis(i,everpack.com
office: 828.646.2874
cell: 828.424.9955

PPPPPP�
CC:
Matthew Claypool—EPLLC
Michael Ferguson—EPLLC
Scott Bragg- EPLLC

evergreen Canton Office
75 Main Street Canton, NC 28716
packaging
PSD 94-12
November 30,2012 CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Chuck Cranford vajawOr2 2595 4660
Regional Supervisor -
Division of Water Quality, Surface Water Protection
3JI'�J fV
North Carolina Department of Environment and Natural Resource N2; -?s .Ln`i,ti H3 vrn
Asheville Regional Office
2090 U.S.Highway 70
Swannanoa,North Carolina 28778
Re: SE Fecal Excursions 11/20 and 11/27/2012
NPDES Permit No.NC0000272 1>
Blue Ridge Paper Products Inc. dba Evergreen Packaging --,:
Canton Mill
Dear Mr. Cranford-
This is the 5-day notice letter required by permit for the subject daily maximum excursions of secondary
effluent fecal coliform. The result for Tuesday 11/20/2012 was>600 MPN/100 ml. The result for
Tuesday 11/27/2012 was>6000 MPN/100 ml. The results for the first two weekly November samples
were 4 MPN/100 ml and 2 MPN/100 ml, respectively. The near non-detect fecal results for the first of
November are what we normally see. The monthly geometric mean for November 2010 calculates as
73.3 MPN/100 ml which is compliant with the monthly limit. Nick McCracken and Roger Edwards made
verbal notifications of these results to Ms. Linda Wiggs of your staff on 11/27 and 11/29 after we had
received and confirmed the sample analytical results for each sample.
The 11/20 and 11/27 results are very unusual for our wastewater treatment plant. We are working
diligently to understand the cause of these excursions. A detailed investigation with special process
sampling is underway. Following the 11/29 telephone notification, Ms. Wiggs requested by e-mail that
we prepare a report that summarizes our findings by 12/14/2012.
Very truly yours,
BLUE RIDGE PAPER PRODUCTS INC.
DOING BUSINESS AS EVERGREEN PACKAGING
By:
Paul Dickens Nick McCracken
Manager-Environmental Affairs Water Compliance Coordinator
828-646-6141 828-646-2874
paul.dickensCa)eveMack.com nick.mccrackenAeverpack.com
fresh by design w
EOHS\Share\Water\SE Fecal Excursion Nov 2012-5day Letter 000,g 13. e.,n Conom,a�:Evergreen ee�e,o9e ro�koom9

AjZA
y1LE UPI
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman
Governor Director Secretary
September 27, 2012
Mr. Dave Griswald/Plant Manager
Blue Ridge Paper Products Inc.
175 Main Street
P.O. Box 4000
Canton, North Carolina 28716
Subject. NOTICE OF DEFICIENCY
NOD-2012-LV-0088
Permit No. NC0000272
Canton Mill WWTP
Haywood County
Dear Mr. Griswald:
A review of Canton Mill's WWTP monitoring report for June 2012 showed the following violation:
Parameter Date Limit Value Reported Value Limit Type
Fecal coliforrn 06/26/2012 400*100 ml 477#/100 ml Daily Maximum
Exceeded
Remedial actions, if not already implemented, should be taken to correct any problem. Since the
comments section on the reverse of the relevant DMR provided an adequate explanation for the subject
violation, it is not requested that a response be submitted.
The Division of Water Quality may pursue enforcement action for this and any additional violations of
State law. if you should have any questions, please do not hesitate to contact Janet Cantwell or me at
828/296-4500.
Sincerely,
Chuck Cranford, Regional Supervisor
Surface Water Protection Section
cc: DWQ Asheville Files
DWQ Central Files
John Pryately/ORC
Michael Ferguson/Manager: Pulp, Recovery& Utilities
Chet Chiles/ Manager: Environment, Health & Safety
Roger Edwards/Supervisor: WWTP
S\SWP\Haywood\Wastewater\industrlaRSive Ridge Paper 00272\NOD-2012-LV-OO88,doc
N���nCaro wa
�vahrray
North Carolina Division of Water Quality 2090 U.S.Highway 70 Swannanoa,N.C. 28778 ho e(882B8)2996-450
Internet www ncwatemuaWy.orc W.- FAX

OriLt Er .
' "
Ir
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman
Governor Director Secretary
September 27, 2012
Mr. Dave Griswald/Plant Manager
Blue Ridge Paper Products Inc.
175 Main Street
P.O. Box 4000
Canton, North Carolina 28716
Subject: NOTICE OF DEFICIENCY
NOD-2012-LV-0087
Permit No. NC0000272
Canton Mill WWTP
Haywood County
Dear Mr. Griswald:
A review of Canton Mill's WWTP monitoring report for May 2012 showed the following violation:
Parameter Date Limit Value Reported Value I Limit Type
BOD, 5-Day (20 Deg. C) - 05/17/2012 10,897 Ibs/day 11,901 Ibs/day Daily Maximum
Quantity Daily Exceeded
Remedial actions, if not already implemented, should be taken to correct any problem. Since the
comments section on the reverse of the relevant DMR provided an adequate explanation for the subject
violation, it is not requested that a response be submitted.
The Division of Water Quality may pursue enforcement action for this and any additional violations of
State law. If you should have any questions, please do not hesitate to contact Janet Cantwell or me at
8281296-4500.
Sincerely,
i
Chuck 6fainford, Regional Supervisor
Surface Water Protection Section
cc: DWQ Asheville Files
DWQ Central Files
John Pryately!ORC
Michael Ferguson/Manager: Pulp, Recovery& Utilities
Chet Chiles/ Manager: Environment, Health & Safety
Roger Edwards/Supervisor: WWTP
S:1SWPkHaywoodlWastewaterUndustriallBlue Ridge Paper 00272\NOD-2012-LV-0087 doc TyZ Caro ina
✓I�ru���y
North Carolina Division of Water Quality 2090 U.S.Highway 70 Swannanoa,N.C. 28778 Phone[phone]
Internet: www.ncwateroualitv.ora , FAX [phone]

evergreen./ �
packaging AUG 3 0 2012
Blue Ridge Paper Products Inc. - Canton Mill "t"r=a ' :ry s`cTION
August 29, 2012 :,NMM#73-12
k_.
CERTIFIED MAIL
Return Receipt Requested
7008 3230 0002 2595 5001
Chuck Cranford
Asheville Regional Supervisor
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Subject: Secondary Effluent Fecal Coliform 8/14/2012
NPDES NC0000272
Evergreen Packaging
Canton,NC
Dear Mr. Cranford:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal Coliform sample was taken the
morning of 8/14. Proper sampling procedures were followed by plant personnel. The sample
was then sent to an off-site laboratory for testing. The wastewater treatment plant supervisor,
Roger Edwards, was informed of the preliminary result the morning of 8/17. A phone call was
then placed to Janet Cantwell in the NCDWQ Regional office to discuss the preliminary results
from the laboratory.
The official laboratory report was received on 8/27. The result of the analysis showed 600
colonies per 100ml. Lab supervisor and ORC,John Pryately, completed a QA review of the
contract laboratory data prior to this notification. The fecal Coliform excursion on 8/14 was
limited to that sample parameter and day. All other effluent parameters were within permit
requirements.
After further review of the influent and operational data we are unable to determine the cause of
the elevated daily value. The Town of Canton operates a pretreatment chlorination system that is
flow proportional. During the sample period this system was functioning as designed and did not
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpacklcalEOHSISHARE1Water FilesWick's Water FilesIDWO

rNCDWQ Page 2
experience any downtime in system operation. We feel that the results from this test were a
laboratory anomaly.
If you have any questions or comments,please feel free to contact us at your earliest
convenience.
Sincerely,
Nick McCracken Roger Edwards
Water Compliance Coordinator Supervisor, Waste Water Treatment Plant
Evergreen Packaging-Canton Mill Evergreen Packaging-Canton Mill
828-646-2874 828-646-2382
Nick.McCracken(a,everpack.com Roger.Edwards d(eevpMack.com
cc:
Mr. Jeff Menzel
Environmental Specialist, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778
Mrs. Wanda Frazier
Environmental Specialist, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778
C. File-Water Notebook
Internal distribution-
D. Griswold
M. Ferguson
Blue Ridge Paper Products Inc. -Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
MverpackkcalEOHSISHAREI Water ResUck's Water Res0WO
Division of Evergreen Packaging

rN(CDWQ Page 3
i
C. Chiles
P. Dickens
R.Edwards
J. Pryately
N. McCracken
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
11everpack1calEOHSISHAREI Water ResWick's Water ResIDWQ
Division of Evergreen Packaging
I

Cantwell, Janet
From: Nick McCracken [[e-mail]]
Sent: Wednesday,August 01, 2012 4:31 PM
To: Cantwell, Janet
Cc: Cranford, Chuck; Wilson, Susan A;Roger Edwards; John Pryately; Paul Dickens
Subject: Hardwood Chip Sump Overflow ,-
Janet,
This is our email notification that you requested earlier today during our phone conversation regarding the Hardwood
Chip Sump overflow that occurred last night(7/31) at the Wastewater Treatment Plant. The overflow occurred for
approximately five minutes at 10:45pm. All equipment and associated controls were functioning properly but
unfortunately due to the intense rainfall in such a short duration the pumps could not keep up with the amount coming
in. Leading up to the period of overflow,the mill saw approximately 1.13" of rainfall in the first hour. As the storm
began tapering off the mill received an additional 0.30 inches. Flow in the Pigeon River reached a peak of 989 million
gallons at Canton during the,-heavy rains.
If you have any questions or.comments please feel free to cont'a,,rtme.at your earliest convenience.
Nick
Nick McCracken
Water Compliance Coordinator
Evergreen Packaging
nick.mccracken Cdleve rpack.com
828-646-2874 FAX [phone]
PAGER 828-444-3278
DISCLAIMER This electronic message together with any attachments Is confidential If you are not the intended recipient,do not copy,disclose or use the
contents in anyway. Please also advise us by return e-mail that you have received the message and then please destroy. Evergreen Packaging is not
responsible for any changes made to this message and/or any attachments after'sending by Evergreen Packaging. We use virus scanning software but exclude
all liability for viruses or anything similar in this email or any attachment.
DISCLAIMER: This electronic message together with any attachments is confidential If you are not the intended recipient,do not copy,disclose or use the
contents in anyway. Please also advise us by return e-mail that you have received the message and then please destroy. Evergreen Packaging is not
responsible for any changes made to this message and/or any attachments afterisending by Evergreen Packaging. We use virus scanning software but exclude
all liability for viruses or anything similar in this email or any attachment
i' it�itr•:� si •
1

evergreeff
packaging
Blue Ridge Paper Products Inc. - Canton Mill
July 26, 2012 " ' NMM#57-12
CERTIFIED MAIL
Return Receipt Requested t
7008 3230 0002 2595 1560 lF
JUL 3 0 2012
Chuck Cranford t `
i ' ATER QUALITY S7CTION
Asheville Regional Supervisor d=y E R_s o,^r L or-r-Ice
Division of Water Quality
North Carolina Department of Environment !
and Natural Resources i
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Secondary Effluent Fecal Coliform 6/26/2012
NPDES NC0000272
Evergreen Packaging
Canton,NC
Dear Mr. Cranford:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
6/26 at approximately 9:10 am. Proper sampling procedures were followed by plant personnel.
The sample was then sent to an off-site laboratory for testing. The wastewater treatment plant
supervisor, Roger Edwards,was informed of the result the morning of 7/23. The result of the
analysis showed a geometric mean of 477 colonies per 100m1. Lab supervisor and ORC, John
Pryately, completed a QA review of the contract laboratory data prior to notification. A phone
call was placed to Janet Cantwell in the NCDWQ Regional office on 7/23 at 4:11 pm.
The fecal coliform excursion on 6/26 was limited to that sample parameter and day. All other
effluent parameters were within permit requirements.
After further review of the influent and operational data we are unable to determine the cause of
the elevated daily value. The Town of Canton operates a pretreatment chlorination system that is
flow proportional. During the sample period this system was functioning as designed and did not
experience any downtime in system operation. Subsequent samples of the effluent showed
acceptable values well below permit requirements.
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street a PO Box 4000
Canton, North Carolina 28716 a 828-646-2000
Ileverpack1ca1E0HSISHAREI Water Files Wick's Water FdeslOWQ

VNCDWQ Page 2
If you have any questions or comments,please feel free to contact us at your earliest
convenience.
'Sin/comer/
Nick McCracken Roger Edwards
Water Compliance Coordinator Supervisor, Waste Water Treatment Plant
Evergreen Packaging—Canton Mill Evergreen Packaging—Canton Mill
828-646-2874 828-646-2382
N1ck.MCCraeken(Q7eyerpaek.com Roeer.Edwards(a�eveMack.com
cc:
Mr. Jeff Menzel
Environmental Specialist, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778
C. File—Water
BMP Notebook
Internal distribution-
D. Griswold
M. Ferguson
R. Edwards
C. Chiles
P. Dickens
N. McCracken
J. Pryately
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpacklcalEOHSISHARO Water FitesWick's Water Files DWQ
Division of Evergreen Packaging

f.evergreeff
packaging "
Blue Ridge Paper Products Inc. - Canton MiFAF'i7V'L;
May 25, 20122 9 2012CERTIFIED MAILReturn Receipt Requested 'tALITY SECTION
7008 3230 0002 2591 1762 % E_rIONAL oFrlce �q$
14 S s:
Chuck Cranford
Asheville Regional Supervisor
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Subject: Secondary Effluent BOD 5/17/2012
NPDES NC0000272
Evergreen Packaging
Canton,NC
Dear Mr. Cranford:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent (SE) BOD5 sample for 5/17 was
taken off on 5/22 at approximately 9:30 pm. Proper sampling and testing procedures were
followed. The wastewater treatment plant (WWTP) supervisor, Roger Edwards, was informed
of the result at 6:00 am the morning of 5/23. The result of the analysis showed a daily value of
11,901 lbs per day. Lab supervisor and ORC, John Pryately, completed a QA review and
validated the sample. A phone call and voicemail was left at your office on 5/23 at 1:35 pm. A
follow-up email notification was also sent that same day.
The SE BOD5 excursion on 5/17 was limited to that sample parameter and day. All other
effluent parameters were within permit requirements. The effluent and river dissolved oxygen
readings on 5/17 were all 7 mg/l or greater.
During the afternoon of 5/14,the Swenson evaporators developed a tube leak in the condenser
that resulted in an unplanned total pulp mill outage. The mill followed its Best Management
Practices plan to protect the WWTP. The process was not restarted until the WWTP was able to
Blue Ridge Paper Products Inc. —Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpackkalEOHSISHARE1Water FilesWick's Water FIIesV)WQ

NCDWQ Page 2
handle the wastewater associated with startup. In similar future circumstances the mill will do
the same—an orderly process shutdown and restart when the W WTP is stable.
If you have any questions or comments,please feel free to contact us at your earliest
convenience.
Sinter
Nick McCracken
Water Compliance Coordinator
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCracken(&everpack.com
cc:
Mr. Jeff Menzel
Environmental Specialist,Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
C. File—Water
BMP Notebook
Internal distribution -
D. Griswold
M. Ferguson
R. Edwards
C. Chiles
P. Dickens
N. McCracken
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Iteverpacklca%EOHSISHAREI Water ResWick's Water Filesowo
Division of Evergreen Packaging

PPV AvotuAvy
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Pat McCrory Thomas A. Reeder John E. Skvada, III
Governor Director Secretary
NOTICE OF RENEWAL INTENT
[Required by 15A NCAC 02H .0127(d)l; [term definition see 15A NCAC 02H.0103(19)]
Application for renewal of existing coverage under General Permit NCG500000
Existing Certificate of Coverage (CoQ: NCG500151
(Press Tab to navigate form)
1) Mailing address of facility ownerloperator: (address to which all correspondence should be mailed)
Company Name Evergreen Packaging Inc.
Owner Name Chet C. Chiles
Street Address 175 Main Street
city Canton State NC ZIP Code W;91VED/DENR/DWR
Telephone# 828 - 646 -2381 Fax# [phone] JAN 2 & 2015
Email Address [e-mail] Water Quality
Permitting Section
2) Location of facility producing discharge:
Facility Name Blue Ridge Paper Products Inc. dba Evergreen Packaging Inc.
Facility Contact Chet C.Chiles
Street Address 1329 Howell Mill Road
City Waynesville State NC ZIP Code 28786-
County Haywood
Telephone# [phone] Fax# [phone] I
�,GCr�rVED
Email Address [e-mail] Division o7 V saw Rasouraa
3) Description of Discharge: F E B - 6 2015
a) Is the discharge directly to the receiving stream?
Vrater QuelRy Reglonai operations
® Yes Asheville Re Tonal urce
❑ No—Please submit a site map with the pathway to the potential receiving waters clearly marked. This
includes tracing the pathway of the storm sewer to the discharge point,if the storm sewer is the only
viable means of discharge.
b) Number of discharge outfalls(ditches,pipes, channels, etc. that convey wastewater from the property): 1
Page 1 of 3

NCG500000 Renewal Application
Additional Application Requirements:
The following information must be included in duplicate [original+ 1 copy] with this application or it
will be returned as incomplete.
➢ Site map. If the discharge is not directly to a stream;the pathway to the receiving stream must
be clearly indicated. This includes tracing the pathway of a storm sewer to its discharge point.
➢ Authorization for representatives. If this application will be submitted by a consulting
engineer(or engineering firm), include documentation from the Permittee showing that the
consultant submitting the application has been designated an Authorized,Representative of the
applicant,per 15A NCAC 02H .0138(b)(1).
CERTIFICATION
I certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information is true, complete, and accurate.
Printed Nan
of Person Signing: Dane A. G 'swold Title: Mill Manager Canton/
Waynesville per
(Please review 5A NCAC 02H. 106 a or auth 'z signing officials)
` January 22,2015
Signatur of Applicant Date Signed
North Carolina General Statute$ 143-215.6B provides that:
Any person who knowingly makes any false statement representation, or certification in any application, record,
report, plan, or other document filed or required to be maintained under this Article or a rule implementing this
Article; or who knowingly makes a false statement of a material fact in a nilemaking proceeding or contested case
under this Article; or who falsifies,tampers with,or knowingly renders inaccurate any recording or monitoring device
or method required to be operated or maintained under this Article or Hiles of the Commission implementing this
Article, shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed ten thousand dollars
($10,000). 18 U.S.C. Section 1001 provides a punishment by a fine or imprisonment not more than 5 years, or both,
for a similar offense.
This Notice of Renewal Intent does NOT require a separate fee.
The permitted facility already pays an annual fee for coverage under NCG500000.
Mail the original and one copy of the entire package to:
NC DENR/DWR/Water Permitting Section
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
Attn: Charles Weaver
Page 3 of 3

NCG500000 Renewal Application
c) What type of wastewater is discharged?Indicate which discharge points,if more than one.
® Non-contact cooling water Outfall(s)#: 1
❑ Boiler Blowdown Outfall(s)#:
❑ Cooling Tower Blowdown Outfall(s)#:
❑ Condensate Outfall(s)#:
❑ Other Outfall(s)#:
(Please describe"Other"):
d) Volume of discharge per each discharge point(in GPD):
#001:—14,400 GPD #002: GPD #003: GPD #004: GPD
4) Please check the type of chemical[s] added to the wastewater for treatment,per each separate discharge
point(if applicable, use separate sheet):
❑Chlorine ❑Biocides - ❑Corrosion inhibitors ❑Algaecide ®Other Calcium Thiosulfate
❑None
If any box other than None is checked, a completed Biocide 101 Form and manufacturers'information on the
additive must be submitted to the following address for approval:
NC DENR/DWR/Environmental Sciences Section
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh,NC 27699-1621
5) Is there any type of treatment being provided to the wastewater before discharge?(i.e., retention ponds,
settlingponds, etc.) i
❑ Yes-Please include design specifics(i.e.,design volume,retention time, surface area,etc.)with submittal
package. Existing treatment facilities should be described in detail.
® No
6) Discharge Frequency:
a) The discharge is: ❑ Continuous ® Intermittent ❑ Seasonal
i) If the discharge is intermittent,describe when the discharge will occur.
ii) If seasonal, check the month(s)the discharge occurs:
❑Jan ❑Feb ❑Mar. ❑Apr ❑May ❑Jun ❑ Jul ❑Aug. ❑Sept. ❑ Oct. ❑Nov. ❑Dec.
b) How many days per week is there a discharge? 7
c) Please check the days discharge occurs: ® Sat. ® Sun. ® Mon. ® Tue. ® Wed. ®Thu. ®Fri.
Page 2 of 3

evergreerl'.0 Canton Office
packaging 175 Main Street• Conlon, NC 28716
January 7, 2015 aM�onofJWaWR ourwt NMM#02-15
CERTIFIED MAIL JAN - 9 2015
Return Receipt Requested
7099 3220 0007 0371 4613
Water Marty Reglonal Operatknn
Landon Davidson
Asheville Regional QBice
Asheville Regional Supervisor
Division of Water Resources
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton,Haywood County,North Carolina
Daily Maximum Fecal Coliform 12/30/2014
NPDES Permit: NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
12/30 at approximately 11:35 am and picked up by the laboratory for analysis. Proper sampling
procedures were followed by plant personnel. We received a verbal, preliminary laboratory
report the afternoon of 12/31. The result of the analysis showed a value of 430 colonies per 100
ml. The fecal coliform excursion on 12/30 was limited to that sample parameter and day. A
phone call was placed to the NCDWR regional office on 12/31.
Once we received the value from the laboratory all systems in the treatment facility were
inspected. They were found to be operating correctly leading up to and during the time of
sample. The Town of Canton's chlorine injection system was also checked. Annual
maintenance was performed in November of this year as well as a flow meter calibration check
on 12/2/14.
At this time our likely explanation is limited to a significant rain event that occurred the previous
day. This event deposited—0.40"of rain, in the Canton area, over a period of approximately 6
hours. Historically, increased flow and fecal loading from the Town,to the treatment plant, has
IleverpacklcalEOHSISHARE1Water FilesWick's Water FilesIDWQ

II
I
A

NCDWR Page 2
been observed during similar rainfall events. We will continue to investigate and monitor the
influent samples for any changes.
If you have any questions or comments, please feel free to contact us at your earliest
convenience.
Sincerely,
Nic McCracken
Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCrackenna everpack.com
co:
Mr. Jeff Menzel
Environmental Specialist, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778
C. File—Water Notebook

evergreen. Canton Office
packaging 175 Morn Stree • Conlon, NC 28716
January 7, 2015 NMM#02-15
CERTIFIED MAIL
Return Receipt Requested
7099 3220 0007 0371 4613
Landon Davidson
Asheville Regional Supervisor
Division of Water Resources
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Subject: Blue Ridge Paper Products Inc.dba Evergreen Packaging
Canton Mill, Canton, Haywood County,North Carolina
Daily Maximum Fecal Coliform 12/30/2014
NPDES Permit: NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
12/30 at approximately 11:35 am and picked up by the laboratory for analysis. Proper sampling
procedures were followed by plant personnel. We received a verbal,preliminary laboratory
report the afternoon of 12/31. The result of the analysis showed a value of 430 colonies per 100
ml. The fecal coliform excursion on 12/30 was limited to that sample parameter and day. A
phone call was placed to the NCDWR regional office on 12/31.
Once we received the value from the laboratory all systems in the treatment facility were
inspected. They were found to be operating correctly leading up to and during the time of
sample. The Town of Canton's chlorine injection system was also checked. Annual
maintenance was performed in November of this year as well as a flow meter calibration check
on 12/2/14.
At this time our likely explanation is limited to a significant rain event that occurred the previous
day. This event deposited—0.40"of rain, in the Canton area, over a period of approximately 6
hours. Historically, increased flow and fecal loading from the Town, to the treatment plant, has
IleverpG01%-8lE0HSISHAREI Water Files Wick's Water Res0WQ

NCDWR Page 2
been observed during similar rainfall events. We will continue to investigate and monitor the
influent samples for any changes.
If you have any questions or comments,please feel free to contact us at your earliest
convenience.
Sincerely,
Nic McCracken
Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick McCracken(d�evemack.com
cc:
Mr. Jeff Menzel
Environmental Specialist, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778
C.File—Water Notebook

evergreen,* Canton Office
packaging 175 Main Street • Contort, NC 28716
June 10, 2014 NMM#06-14
CERTIFIED MAIL
Return Receipt Requested PE,t FAlED
7008 3230 0002 2595 6909 pNsian"r tvam Hcmu ON
Landon Davidson J U N 1 1 2014
Asheville Regional Supervisor
Division of Water Resources r, ,, a,�tNr R ,r s o:•r 3 rcns
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill,Canton,Haywood County,North Carolina
Daily Maximum Fecal Coliform 6/5/2014
NPDES Permit: NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
6/5 at approximately 8:30 am, was picked up by courier and then taken to the laboratory for
analysis. We received notification from the lab on the afternoon of 6/6 by email. The result of
the analysis showed a value of>600 colonies per 100ml. The fecal coliform excursion on 6/5
was limited to that sample parameter and day. A phone call was placed to the NCDWR regional
office on 6/6.
Once we received the results from the laboratory all systems in the treatment facility were
checked. They were found to be operating correctly leading up to and during the time of sample.
On this day, we also sampled the Primary Effluent (PE), as well as, the Park Street Bridge
location(Upstream). The Upstream sample results appeared within the typical range observed
during prior sampling events (156 col / 100ml). The PE sample was not what we expected.
Over the last month, fecal coliform values for the primary effluent samples have ranged from
2,000 col / 100ml to>600,000 col/ 100ml. On 6/5, the result for the PE sample was <20 col/
100m1.
fresh by design,. /
IleverpacklcaWOHSISHAROWater ReslNlck's Water FileslD WO

rNCDWR Page 2
Mill personnel contacted the laboratory to discuss these results. The lab stated that the
Secondary Effluent(SE) sample had lots of floating material and was difficult to filter. The
Primary Effluent sample was clear and had no difficulty being set up for analysis. After our
conversation,we pulled the saved SE sample from the refrigerator and checked for these
observations. Our observation of the SE sample did not match what the laboratory had seen.
The SE sample was clear of prolific floating material. Interviews with plant personnel confirmed
that the PE sample during previous events possessed a greater amount of floating material when
compared to the secondary sample. A review of the mill's database showed that the SE sample
Total Suspended Solids (TSS)results for 6/5 to be 6 mg/1 and the PE TSS results to be 70 mg/l.
On 6/6 another set of fecal samples was collected and sent out for analysis. The result of the
Secondary Effluent fecal coliform test from 6/6 was none detected.
Taking into account the fecal coliform results (both previous and current) for PE/SE, WWTP
personnel observations of sampled PE/SE and a review of the mill's laboratory database we
believe that the Secondary Effluent and Primary Effluent samples on 6/5 were swapped and that
the mill continued to be in compliance with permit limits at that time.
If you have any questions or comments,please feel free to contact us at your earliest
convenience.
Sincerely,
,��44 11/
John Pryately
Laboratory Supervisor& WWTP ORC
Evergreen Packaging—Canton Mill
828-646-6720
iohn.prvately(a)everpack.com
cc:
Mr. Jeff Menzel
Environmental Specialist,Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778

evergreen. Canton Office
packaging I 175 Win sV b ee�• Conn, NC 29716
March 3, 2014 NMM#20-14
CERTIFIED MAIL
Return Receipt Reguested
7099 3220 0007 0371 4439
Landon Davidson
Asheville Regional Supervisor
Division of Water Resources
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton, Haywood County,North Carolina
Daily Maximum Fecal Coliform 2/20/2014
NPDES Permit: NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
2/20 at approximately 8:05 am and picked up by courier to be taken to the laboratory for
analysis. Proper sampling procedures were followed by plant personnel. We received the
laboratory report the afternoon of 2/26. The result of the analysis showed a value of 440
colonies per 100ml. The fecal coliform excursion on 2/20 was limited to that sample parameter
and day. A phone call was placed to the NCDWR regional office on 2/26.
Once we received the value from the laboratory all systems in the treatment facility were
checked. They were found to be operating correctly leading up to and during the time of sample.
We are conducting an in depth investigation, along with the Town of Canton, into the cause of
this result.
If you have any questions or comments,please feel free to contact us at your earliest
convenience.
fresh by design _ /
4evarpack%c&%E0HS&i4R0Water FilesWick's Water FilesOWO

NCDWR;PNge 2
Sincerely; -
/ 2
1Vick MgGiackeu
WaterSup.gmsor
Evergreen Packaging-_Csnton'Mill
828-646-2834
Nick McCracken@everpack:eom•
Ec:
Mz':Jeff. Mengel
Environmental Speci;4 AshevilleRegional.Office
North:Carolina Departrn&t:of Environment
NaturaLResonf mf
.1090 U.$.Highway,70
S,wannanoa;NO N778
G.File—Water Notebook.

Cantwell, lanet
From: Davidson, Landon
Sent: Monday, March 03,2014 4:08 PM
To: Cantwell,Janet
Subject: FW: 2-20-14 5-day Submittal
Attachments: Daily Max Fecal Submittal 2-20-14.pdf
fyi
G. Landon Davidson, P.G.
NCDENR-Division of Water Resources
Water Quality Regional Operations Section
Regional Supervisor-Asheville Regional Office
2090 U.S.Hwy.70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax:[phone]
email: [e-mail]
website:www.ncwaterguality.org
Notice:Per Executive Order No.150,all emails sent to and from this account are subject to the North Carolina Public Records Law
and maybe disclosed to third parties.
From: Nick McCracken [mailto:[e-mail]
Sent: Monday, March 03, 2014 4:02 PM
To: Davidson, Landon
Cc: Cranford, Chuck, Menzel,Jeff
Subject: 2-20-14 5-day Submittal
Gentlemen,
I hope you all had a wonderful weekend. Attached is the 5-day letter we will have in the mail tomorrow regarding the
fecal result from 2-20-14. Please let me know if you have any questions or comments.
Nick
Nick McCracken
EHS&S Water Supervisor
Evergreen Packaging
nick.mccracken0evemack.com
Office(828) 646-2874
Cell [phone]
Fax[phone]
DISCLAIMER This electronic message together with any attachments is confidential. If you are not the intended recipient,do not copy,disclose or use the
contents in anyway. Please also advise us by return e-mail that you have received the message and then please destroy. Evergreen Packaging is not
responsible for any changes made to this message and/orany attachments aftersending by Evergreen Packaging. We use virus scanning software but exclude
all liability for viruses or anything similar in this email or any attachment.

DISCLAIMER: This electronic message together with any attachments is confidential. If you are not the intended recipien ,
do not copy, disclose or use the contents in any way. Please also advise us by return e-mail that you have received the
message and then please destroy. Evergreen Packaging is not responsible for any changes made to this message and
or any attachments after sending by Evergreen Packaging.We use virus scanning software but exclude all liability for
viruses or anything similar in this email or any attachment.

RECEIVED
evergreen Canton Office Dlviaw of Water Resourow
packaging 175 Main Street• Canton, NC 28716
FEB — 3 2014
January 31,2014 NMM#04-14 Water Ouality Regional Operations
Asheville Regional Office
CERTIFIED MAIL
Return Receipt Requested
7099 3220 0007 0371 4408
Landon Davidson
Regional Water Quality Supervisor
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanca, NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton,Haywood County,North Carolina
2013 Secondary Effluent Color&Flow Summary
NPDES Permit: NC0000272
Dear Mr. Davidson:
This letter and attachment document the 2013 average annual color discharge from Evergreen
Packaging Canton Mill. Average secondary effluent color discharge for the period 1 Jan 2013
through 31 Dec 2013 was 36,3801bs/day and is compliant with the permit.
The attachment provides daily wastewater discharge flows and secondary effluent true color for
the mill during 2013.
Sincere ,
Nick McCracken
EHS&S Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
[e-mail]
Attachment: Daily secondary effluent flow and color discharge for 2013
IYwpx JCTM91aeE1EONSL JW&w FASs k's Wdw FYsa10WR1AmiW RBpYSW13Am Cab Letla.dc

Canton Mill 2013 Average Annual Color and Wastewater Flow
Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color
MGD "Ib/dav" MGD "Ib/dav" MGD "Ih/dav"
1/12013 26.79 28,152 2/1/2013 28.02 35,520 3/1/2013 27.99 49,255
1/2/2013 26.71 32.523 2/2/2013 28.21 33.409 3/2/2013 26.53 42,261
1/3/2013 25.64 32.931 2/3/2013 28.50 35.654 3/3/2013 26.92 36,596
1/4/2013 25.00 29,399 2/4/2013 27.77 33,814 3/4/2013 26.93 44,470
1/5/2013 25.31 30,396 2/5/2013 26.91 34,562 3/5/2013 29.99 43,770
1/6/2013 25.25 31.267 2/6/2013 27.54 27,562 3/5/2013 27.81 39.429
1/7/2013 24.94 37.648 2/7/2013 26.96 37,549 3/7/2013 28.71 59,142
1/8/2013 24.07 38.141 2/8/2013 26.10 43,099 3/8/2013 27.36 42,442
1/9/2013 25.96 36,373 2/9/2013 26.72 38,106 3/9/2013 27.87 39.282
2/10/2013 27.19 37.643 2/102013 27,87 35.795 3/10/2013 27.98 35,470
1/112013 27.80 31.996 2/11/2013 26.33 31,182 3/11/2013 28.48 34.441
1/12/2013 27.85 22.066 2/122013 26.47 34.218 3/12/2013 28.07 34.179
1/13/2013 27.85 21,136 2/132013 27.97 30.325 3/13/2013 26.75 31.456
1/242013 31.31 25,068 2/142013 26.71 32,523 3/14/2013 26.34 30.974
1/15/2013 33.04 31,138 2/152013 26.44 31.312 3/15/2013 24.28 29,362
1/16/2013 30.15 24,642 2/16/2013 27.10 27,574 3/16/2013 25.68 29,556
1/17/2013 33.40 27,577 2/17/2013 26.46 27,585 3/17/2013 26.26 30,880
1/18/2013 27.89 22,097 2/18/2013 26.26 28,690 3/18/2013 28.22 34,833
1/19/2013 27.52 23,870 2/19/2013 28.44 37,713 3/19/2013 27.35 28,740
120/2013 28.12 29,081 2/20/2013 27.35 32.618 3/20/2013 27.00 28,823
1/21/2013 27.64 24.896 2/21/2013 26.93 38,181 3/21/2013 27.35 29,197
1/22/2013 26.41 26.431 2/222013 28.46 40,588 3/22/2013 28.12 35.413
1/23/2013 27.67 25.384 2/23/2013 27.26 38,877 3/23/2013 28.26 31.347
1/242013 26.69 22,482 2/24/2013 25.74 28,981 3/24/2013 29.39 27.453
1/25/2013 27.50 32.109 2/252013 26.78 31,715 325/2013 27.60 25.090
1262013 28.26 41.717 2/26/2013 29.20 34.094 3/26/2013 26.96 23,834
127/2013 28.06 47.506 2/27/2013 27.35 35,812 3/27/2013 25.98 21.017
1/28/2013 27.09 45,638 2/28/2013 27.52 44,756 3/282013 25.91 24.418
1292013 28.12 48,780 3/29/2013 26.69 24.931
1/302013 32.08 53.777 3/30/2013 26.89 31.173
1/31/2013 28.88 36.851 3/31/2013 27.89 31.169
Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color
MGD "lb/dav" MGD "Ib/dav" MGD 91a/dav"
4/1/2013 27.10 31,642 5/12013 23.37 17.347 5/1/2013 26.58 33,473
4/2/2013 26.85 31.126 522013 23.53 13.737 62/2013 27.65 39.202
4/3/2013 26.37 33.429 5/32013 2323 10.849 6/3/2013 26.93 38,631
4/42013 28.40 43,818 5/4/2013 24.08 11.648 6/4/1013 26.56 44,967
4/5/2013 28.40 39,081 5/5/2013 31.53 15,515 6/5/2013 27.97 4SA98
4/6/2013 26.15 34,022 5/6/2013 25.73 14,377 5/6/2013 29.02 43,081
4/7/2013 25.44 32,986 52/2013 23.77 11,499 6/7/2013 28.94 40.649
4/8/2013 26.93 44.695 5/8/2013 24.98 17,292 6/8/2013 28.14 41,774
4/9/2013 27.19 49.888 5/92013 25.61 25.203 6/9/2013 28.20 38,100
4/10/2013 25.95 48,046 5/102013 25.37 20,735 6/10/2013 31.04 40.384
4/12/2013 28.26 51,380 5/11/2013 25.87 28.048 6/11/2013 28.30 37,764
4/12/2013 31A3 59.241 5/12/2013 25.25 40.011 6/12/2013 27.55 36,303
4/132013 26.07 47.398 5/23/2013 25.78 46,226 6/13/2013 27.66 29,989
4/142013 24.41 77.360 5/14/2013 26.33 51.604 6/14/2013 26.15 29,224
4/152013 22.53 60.692 5/15/2013 27.10 44,977 6/152013 26.23 29,751
4/162013 22.79 50.748 5/162013 27.13 32,356 6/16/2013 25.96 26.630
4/172013 23.03 44.752 5/172013 2753 35.129 6/17/2013 26.77 27.238
4/182013 23.01 45.289 5/18/2013 27A5 31.593 6/18/2013 27.21 31,090
4/192013 22.89 46.962 5/19/2013 27.28 35,720 6/19/2013 26.20 27.532
4202013 20.97 46,346 5/20/2013 27.49 36.683 6/20/2013 26.35 31,206
421/2013 21.36 42.220 5/21/2013 2651 32.290 6/21/2013 26.66 36.687
4222013 21.10 40,474 5/22/2013 27.49 32.556 622/2013 26.09 23,717
4232013 21.34 38,265 5/23/2013 27.88 32,088 623/2013 26.22 36337
4/24/2013 25.16 38.610 5/24/2013 26.03 30.393 6/24/2013 26.72 38,998
4/25/2013 22.85 32.968 5/25/2023 25.24 33,470 6/25/2013 27.74 35,629
4/26/2013 27.33 29,631 5/26/2013 27.57 35,870 6/26/2013 26.04 36.702
4/27/2013 26.63 22,654 527/2013 27.10 36,614 6/27/2013 26.42 37,899
4/282013 27.70 21,716 528/2013 25.82 32,085 6/28/2013 25.62 37.179
4/292013 26.09 16.319 5/29/2013 26.77 38,178 6/292013 26.80 37.327
4/30/2013 25.32 18,583 5/302013 27.06 39,043 6/30/2013 26.60 36,161
5/31/2013 26.86 34,946
RECEIVED
Division of Water Resources
FEB - 3 2014
','-ter n,.mllty Reoinnal Oneraflans

Canton Mill 2013 Average Annual Color and Wastewater Flow
Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color
MGD "16/dav" MGD "Ib/dav" MGD "Ib/dav"
7/1/2013 28.08 42.622 8/1/2013 25.04 29.863 9/1/2013 26.60 34,608
7/2/2013 27.74 62,234 8122013 26.47 36.867 9/2/2013 30.50 39,173
7/3/2013 30.51 59,542 8/32013 25.91 37.600 9/3/2013 26.75 32,126
7/4/2013 32.76 43.442 8/42013 25.89 36.491 9/4/2013 25.80 30,985
7/5/2013 28.95 35,492 8/5/2013 26.71 33.414 9/5/2013 24.72 35,460
7/6/2013 27.72 40,226 8/6/2013 25.94 38,941 9/6/2013 24.50 36.166
7/7/2013 28.29 41.289 82/2013 26.56 40.758 92/2013 26.86 44,802
7/8/2013 28.00 42,501 8/82013 26.96 29,005 9/8/2013 26.46 37,956
7/92013 27.36 38.563 8/92013 25.31 28.497 9/9/2013 25.59 32,653
7/10/2013 28.84 39,927 8/10/2013 25.36 30.245 9/10/2023 23.95 39,749
7/112013 30.54 44,573 8/11/2013 26.33 37.770 9/11/2023 24.33 40.582
7/12/2013 29.87 44,343 8/12/2013 28.13 34,487 9/12/2013 25.29 32.903
7/13/2013 29.63 43.492 8/13/2013 27.35 33,531 9/13/2013 27.25 32,272
7/14/2013 31.13 43,876 8/142013 27.77 33.814 9/14/2013 25.19 32,773
7/152013 29.66 35,620 8/15/2013 25.21 34.481 9/15/2013 26.44 33,297
7/16/2013 27.94 32.157 8/16/2013 25.93 38.061 9/16/2013 25.65 34,655
7/17/2013 28.76 42.695 8/17/2013 25.92 36.177 9/17/2013 27.40 37.934
7/19/2013 28.04 41,158 8/19/2013 26.31 37,741 9/18/2013 26.23 36.095
7/19/2013 29.11 47.342 8/19/2013 29.66 42.794 9/192013 25.80 34,858
7/20/2013 28.82 37.496 8/20/2013 28.57 35,741 9/20/2013 25.69 33,424
7/21/2013 30.D6 42.118 8/21/2013 27.02 32,675 9/21/2013 28.06 32,295
7222013 27.40 40,904 8/22/2013 26.71 40.765 9/222013 26.64 30,438
7/232013 27.63 42,861 8/23/2013 24.75 40.457 9/232013 26.45 34,413
7242013 28.46 45,098 8/24/2013 25.99 26,878 9/24/2013 26.80 41,350
725/2013 27.03 38,098 8/25/2013 25.22 28,606 9/252013 29.55 45.839
7/26/2013 27.77 35,435 8/26/2013 25.54 33,016 9/26/2013 27.11 37.984
7/27/2013 28.58 37,422 8/27/2013 25.64 28,868 9/27/2013 25.78 34,401
7282013 26.98 37,577 8/28/2013 25.15 32.511 9/28/2013 26.36 33,636
729/2013 26.90 34,549 8/29/2013 25.12 30.797 9/29/2013 25.68 36.409
7/30/2013 26.64 35,771 8/30/2013 25.65 29.735 9/302013 25.70 39.438
7/31/2013 27.11 41,376 8/31/2013 26.04 30,621
Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color Date WTP Flow Set Eff Color
MGD "16/dav" MGD "Ib/dav" MGD "Ib/dav"
10/1/2013 26.32 39.951 11/1/2013 25.57 39.665 12/1/2013 27.09 50.383
10/2/2013 26.36 41.330 112/2013 25.11 45.653 12/2/2013 27.02 42,140
1013/2013 25.79 44,954 11/3/2013 25.18 49.980 12/3/2013 28.39 40,488
10/4/2013 26.34 44,814 11/4/2013 24.84 49,720 12/4/2013 26.68 38,717
10/5/2013 25.74 42,076 11/5/2013 26.45 47,207 12/5/2013 27.08 45.169
10/6/2013 Mks 37.451 11/6/2013 25.65 47.063 12/6/2013 28.04 49,821
102/2013 28.21 35.761 11/7/2013 27.15 47.098 12/7/2013 26.72 46,575
10/8/2013 26.11 33,970 11/8/2013 26.15 45.799 12/8/2013 26.79 38.206
10/9/2013 25.91 31,981 11/9/2013 25.82 34,885 12/9/2013 27.42 41.392
10/10/2013 26.46 39,722 11/102013 25.27 32,456 12/10/2013 26.90 38.139
10/11/2013 26.51 40.018 11/11/2013 26.69 33.167 12/11/2013 26.32 39,292
10/12/2013 26.65 38.007 11/12/2013 26.69 41.403 12/12/2013 25.21 38.266
10/132013 26.72 40,112 11/13/2013 25.40 43.426 12/13/2013 24.79 32.046
10/14/2013 26.38 51.702 11/142013 25.16 36,301 12/14/2013 26.62 28.629
10/152013 2723 47.009 11/15/2013 26.08 37.846 12/15/2013 25.86 27.606
10/162013 26.94 41.116 11/162013 25.55 38.782 12/16/2013 25.94 29,206
10/272013 26.43 35,929 11/17/2013 26.65 39.785 12/172013 27.07 29.575
10/18/2013 25.51 33,402 11/18/2013 26.37 42.886 12/18/2013 26.27 28.044
10/19/2013 26.22 38.049 11/19/2013 25.71 37.524 12/19/2013 25.32 29,775
2020/2013 26.09 50.046 11/20/2013 26.42 41.204 12/20/2013 26.42 35,035
1021/2013 27.09 45,638 11/21/2013 25.65 40.859 12/21/2013 27.53 40,180
10/222013 26.60 36,161 1122/2013 26.85 44,114 1222/2013 30.94 35.609
10/232013 26.37 34,098 11/23/2013 24.94 38.896 12/23/2013 29.76 24,572
10/242013 26.35 44.611 11/24/2013 25.29 41.340 12/24/2013 26.89 29,827
1025/2013 27.54 45.707 11/25/2013 25.69 27.853 12/25/2013 25.57 35,187
10/26/2013 26.23 40.033 11/26/2013 28.47 52.237 12/26/2013 26.95 37.086
10/27/2013 27.47 35.052 11/27/2013 27.74 43,263 12/27/2013 27.26 32,283
10282013 27.06 37,237 11/28/2013 26.64 52.434 12/282013 27.64 26,971
10292013 25.50 39.982 11/29/2013 27.19 60.773 12/29/2013 27.95 28.439
10/302013 25.46 37,796 11/30/2013 26.80 57,666 12/302013 26.70 29,616
10/31/2013 26.65 39,118 12/312013 26.65 28,005
Average Annual Flow: 26.81 MGD RECEIVED
Division of Water Resources
Average Annual Color: 36,380 lbs/day
FEB - 3 2014
Water Quality Regional Operations
Asheville Regional Office

evergreen M�/ Canton Office Fwater
IVED
ter Resources
packaging 175 Moin Street• Canton, NC 28716
3 2014
January 31, 2014 NMM#04-14
gional operationse Tonal office
CERTIFIED MAIL
Return Receipt R uested
7099 3220 0007 0371 4408
Landon Davidson
Regional Water Quality Supervisor
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill,Canton, Haywood County,North Carolina
2013 Secondary Effluent Color&Flow Summary
NPDES Permit: NC0000272
Dear Mr. Davidson:
This letter and attachment document the 2013 average annual color discharge from Evergreen
Packaging Canton Mill. Average secondary effluent color discharge for the period 1 Jan 2013
through 31 Dec 2013 was 36,380 lbs/day and is compliant with the permit.
The attachment provides daily wastewater discharge flows and secondary effluent true color for
the mill during 2013.
Sincere ,
Nick McCracken
EHS&S Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
[e-mail]
Attachment: Daily secondary effluent flow and color discharge for 2013
Ibve WklCTMSha'e 0HSZh.1W&.Fi Nic WW FibSDWR W ftp .1 013 Mn.C[,b'LNt�. w'

Canton Mill 2013 Average Annual Color and Wastewater Flow
Date WFP Flow Sec Eff Color Date WFP Flow Sec Eff Color Date W!P Flow Sec Eff Color
MGD "Ib/dav' MGD "Ib/dav" MGD "Ib/dav"
1/1/2013 26.79 28.152 2/1/2013 28.02 35,520 3/1/2013 27.99 49.255
1/2/2013 26.71 32,523 2/2/2013 28.21 33,409 3/2/2013 26.53 42.261
1/3/2013 25.64 32,931 2/3/2013 28.50 35.654 3/3/2013 26.92 36,596
1/4/2013 25.00 29.399 2/4/2013 27.77 33,814 3/4/2013 26.93 44,470
1/512013 25.31 30,396 2/5/2013 26.91 34,562 3/5/2013 29.99 43,770
1/6/2013 25.25 31.167 2/6/2013 27,54 27.562 3/6/2013 27.81 39.429
1/7/2013 24.94 37,648 2/7/2013 26.96 37,549 3/7/2013 28.71 59.142
1/8/2013 24.07 38,141 2/8/2013 26.10 43,099 3/8/2013 27.36 42,"2
1/9/2013 25.96 36,373 2/9/2013 26.72 38,106 3/9/2013 27.87 39,282
1/10/2013 27.19 37,643 2/10/2013 27.87 35,795 3/10/2013 27.98 35,470
1/11/2013 27.80 31,996 2/11/2013 26.33 31,182 3/11/2013 28.48 34,441
1/12/2013 27.85 22,066 2/12/2013 26.47 34,218 3/12/2013 28,07 34,179
1/13/2013 27.85 21,136 2/13/2013 27.97 30,325 3/13/2013 26.75 31,456
1/14/2013 31.31 25.068 2/14/2013 26.71 32,523 3/14/2013 26.34 30.974
1/15/2013 33.04 31.138 2/15/2013 26.44 31,312 3/15/2013 24.28 29.362
1/16/2013 30.15 24,642 2/16/2013 27.10 27.574 3/26/2013 25.68 29,556
1/17/2013 33.40 27,577 2/17/2013 26.46 27,585 3/17/2013 26.26 30,880
1/18/2013 27.89 22,097 2/18/2013 26.26 28,690 3/18/2013 28.22 34.833
1/19/2013 27.52 23,870 2/19/2013 28.44 37,713 3/19/2013 27.35 28,740
1/20/2013 28.12 29.081 2/20/2013 27.35 32,618 3/20/2013 27.00 28,823
1/22/2013 27.64 24,896 2/212013 26.93 38,181 3/21/2023 27.35 29.197
1/22/2013 26.41 26,431 2/222013 28.46 40.588 3/22/2013 28.12 35,413
1/23/2013 27.67 25,384 2/23/2013 27.26 38.877 3/23/2013 28.26 31.347
1/24/2013 26,69 22.482 2/24/2013 25.74 28.981 3/24/2013 29.39 27,453
125/2013 27.50 32,109 2/25/2013 26.78 31,715 3/25/2013 27.60 25,090
126/2013 28.26 41.717 2/26/2013 29.20 34,094 3/26/2013 26.96 23,834
127/2013 28.06 47.506 2/27/2013 27.35 35,812 3/27/2013 25.98 21,017
1/28/2013 27.09 45,638 2/28/2013 27.52 44,756 3/28/2013 25.91 24,418
1/29/2013 28.12 48,780 3/29/2013 26.69 24,931
1/30/2013 32.08 53,777 3/30/2013 26.89 31,173
1/31/2013 28.88 36,851 3/31/2013 27.89 31,169
Date WTP Flow Sec Eff Color Date WFP Flow Sec Eff Color Date WfP Flow Sec Eff Color
MGD "Ib/dav" MGD "Ib/dav" MGD "Ib/dav'
4/1/2013 27.10 31,642 5/12013 23.37 17,347 6/1/2013 26.58 33,473
4/2/2013 26.85 31,126 5/2/2013 23.53 13,737 6/2/2013 27.65 39.202
4/3/2013 2637 33.429 5/3/2013 23.23 10,849 6/3/2013 26.93 38.631
4/4/2013 28.40 43,828 5/4/2013 24.08 11,648 6/4/2013 26.56 44,967
4/5/2013 28.40 39,081 5/5/2013 31.53 15,515 6/5/2013 27.97 45,488
4/6/2013 26.15 34,022 5/6/2013 25.73 14,377 6/6/2013 29.02 43,081
42/2013 25.44 32.886 52/2013 23.77 11,498 62/2013 28.84 40,649
4/8/2013 26.93 44.695 5/8/2013 24.98 17,292 6/8/2013 28.14 41.774
4/9/2013 27.19 49.888 5/9/2013 25.61 25,203 6/9/2013 28.20 38.100
4/10/2013 25.95 48,046 5/10/2013 25.37 20,735 6/10/2013 31.04 40,384
4/11/2013 28.26 51,380 5/11/2013 25.87 28.048 6/11/2013 28.30 37,764
4/22/2013 31.43 59,241 5/12/2013 25.25 40.012 6/12/2013 27.55 36.303
4/13/2013 26.07 47.398 5/13/2013 25.78 46,226 6/23/2013 27.66 29,989
4/14/2013 24.41 77,360 5/14/2013 26.33 51,604 6/14/2013 26.15 29,224
4/1S12013 22.53 60.692 5/15/2013 27.10 44,977 6/15/2013 26.23 29,751
4/16/2013 22.79 50,748 5/16/2013 27.13 32,356 6/16/2013 25.96 26,630
4/172013 23.03 44,752 5/17/2013 27.53 35,129 6/17/2013 26.77 27,238
4/18/2013 23.01 45,289 5/18/2013 27.45 31.593 6/18/2013 27.21 31,090
4/19/2013 22.89 46.962 5/29/2013 27.28 35,720 6/19/2013 26.20 27,532
4/20/2013 20.97 46.346 5/20/2013 27.49 36,683 620/2013 26.35 31,206
4/21/2013 21.36 42,220 5/21/2013 26.51 32.280 6/21/2013 26.66 36,687
4/22/2013 22.10 40474 5/22/2013 27.49 32,556 6/22/2013 26.09 23.717
4/23/2013 21.34 38,265 5/23/2013 27.98 32,088 6/23/2013 26.22 36,737
4/24/2013 25.16 38,610 524/2013 26.03 30,393 6/24/2013 26.72 38,998
4/25/2013 22.85 32,968 525/2013 25.24 33,470 6/25/2013 27.74 35,628
426/2013 27.33 29,631 5/26/2013 27.57 35,870 6/26/2023 26.04 36,702
427/2013 26.63 22,654 5/272013 27.10 36,614 627/2013 26.42 37,899
4/28/2013 27.70 21,716 5/28/2013 25.82 32.085 6/28/2013 25.62 37.179
429/2013 26.09 16,319 5/29/2013 26.77 38,178 6/29/2013 26.80 37,327
4/30/2013 25.32 18,583 5/30/2013 27.D6 39,043 6/302013 26.60 36,161
5/31/2013 26.86 34.946
RECEIVED
Division of Water Resources
f EB - 3 2014
Water Quality Regional Operations
Pshevllle Reg'onal 09ice

Canton Mill 2013 Average Annual Color and Wastewater Flow
Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color
MGD "Ib/dav" MGD "Ib/dav° MGO "lb/dav"
7/1/2013 28.08 42,622 9/1/2013 25.04 29.863 9/1/2013 26.60 34,608
7/2/2013 27.74 62.234 8/2/2013 26.47 36,867 9/2/2013 30.50 39,173
7/3/2013 30.51 59,542 8/3/2013 25.91 37,600 9/3/2013 26.75 32,126
7/4/2013 32.76 43,442 8/4/2013 25.89 36,491 9/4/2013 25.80 30,985
7/5/2013 28.95 35,492 8/5/2013 26.71 33,414 9/5/2013 24.72 35,460
7/6/2013 27.72 40.226 8/6/2013 25.94 38,941 9/6/2013 24.50 36,166
7/7/2013 28.29 41,289 8/7/2013 26.56 40,759 9/7/2013 26.86 44,802
7/8/2013 28.00 42,501 8/8/2013 26,96 29.00S 9/8/2013 26.46 37.9S6
7/9/2013 27.36 38,563 8/9/2013 25.31 28,497 9/9/2013 25.59 32.653
7/102013 28.94 39,927 8/10/2013 25.36 30,245 9/10/2013 23.95 39,749
7/11/2013 30.54 44.S73 8/11/2013 26.33 37.770 9/11/2013 24.33 40.582
7/12/2013 29.87 44.343 8/12/2013 28.13 34.487 9/12/2013 25.29 32.903
7/13/2013 29.63 43.492 8/13/2013 27.35 33,531 9/13/2013 27.25 32.272
7/14/2013 31.13 43.876 8/14/2023 27.77 33.814 9/14/2013 25.19 32.773
7/15/2013 29.66 35.620 8/15/2013 25.21 34,481 9/1S/2013 26.44 33,297
7/16/2013 27.94 32,157 8/16/2013 25.93 38,061 9/16/2013 25.65 34,655
7/17/2013 28.76 42,695 8/17/2013 25.92 36.177 9/17/2013 27.40 37,934
7/18/2013 28.04 41,158 8/18/2013 26.31 37,741 9/18/2013 26.23 36,095
7/19/2013 29.11 47,342 8/19/2013 29.66 42,794 9/19/2013 25.80 34,858
7/20/2013 28.82 37,496 8/20/2013 28.57 35.741 9/20/2013 25.69 33,424
7/21/2013 30.06 42,118 8/21/2013 27.02 32,675 9/21/2013 28.D6 32,295
7/22/2013 27.40 40,904 8/22/2013 26.71 40.765 9/22/2013 26.64 30,438
7/23/2013 27.63 42.861 8/23/2013 24.75 40,457 9/23/2013 26.45 34,413
7/24/2013 28.46 45,098 8/24/2013 25.99 26,878 9/242013 26.80 41,350
725/2013 27.03 38,098 8/25/2013 2522 28,606 9/252013 29.55 45.839
726/2013 27.77 35.435 8/26/2013 2554 33,016 9/26/2013 27.11 37.984
727/2013 2858 37,422 8/27/2013 25.64 28.858 9/272013 25.78 34.401
728/2013 26.98 37,577 8/28/2013 25.15 32.511 9/282013 26.36 33.636
729/2013 26.90 34.549 8/29/2013 25.12 30,797 9292013 25.68 36.409
7/30/2013 26.64 35.771 8/30/2013 25.65 29,735 9/30/2013 25.70 39.438
7/31/2013 27.11 41,376 8/31/2013 26.04 30,621
Date WrP Flow Sec EH Color Dale WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color
MGD "Ib/dav' MGD "lh/dav" MGD Ib/dav'
10/1/2013 26.32 39,951 11/1/2013 25.57 39,665 12/1/2013 27.09 50,383
10/2/2013 26.36 41,330 11/2/2013 25.11 45,653 12/2/2013 27.02 42,140
10/32013 25.79 44.9S4 11/3/2013 25.18 49.980 12/32013 28.39 40,488
10/4/2013 26.34 44,814 11/4/2013 24.94 49.720 12/4/2013 26.68 38,717
10/52013 25.74 42.076 11/5/2013 26.45 47.207 12/5/2013 27.08 45.169
10/6/2013 25.66 37,451 11/6/2013 25.65 47.063 12/6/2013 28.04 49.811
30/72013 28.21 35,761 112/2013 27.15 47,098 122/2013 26.72 46.575
30/8/2013 26.11 33,970 11/8/2013 26.15 45,799 12/8/2013 26.79 38,206
30/9/2013 25.91 31,981 11/9/2013 25.82 34.885 12/9/2013 27.42 41,392
10/10/2013 26.46 39,722 11/10/2013 25.27 32.456 12/10/2013 26.90 38.139
10/11/2013 26.51 40.018 11/11/2013 26.69 33,167 12/11/2013 26.32 39,292
10/12/2013 26.65 38,007 11/12/2013 26.69 41,403 12/12/2013 25.21 38,266
10/13/2013 26.72 40,112 11/13/2013 25.40 43,426 12/13/2013 24.79 32,046
10/14/2013 26.38 51,702 11/14/2013 25.16 36.301 12/14/2013 26.61 28,629
10/15/2013 27.23 47,009 11/15/2013 26.08 37,846 12/15/2013 25.86 27.606
10/16/2013 26.94 41.116 IV16/2013 25.55 38,782 12/16/2013 25.94 29,206
10/17/2013 26.43 35,929 11/17/2013 26.65 39.785 12/17/2013 27.07 29,575
10/18/2013 25.51 33.402 11/18/2013 26.37 42.886 12/182013 26.27 28.044
10/19/2013 26.22 38.049 11/19/2013 25.71 37,524 12/19/2013 25.32 29,775
1020/2013 26.09 50,046 11/202013 26.42 41,204 1220/2013 26.42 35,035
10/21/2013 27.09 45,638 1121/2013 25.65 40,859 1221/2013 27.53 40,180
10/22/2013 26.60 36,161 1122/2013 26.85 44.114 12/22/2013 30.94 35,609
10/23/2013 26.37 34.098 11/23/2013 24.94 38.896 12/232013 29.76 24.572
10/24/2013 26.35 44,611 11/24/2013 25.29 41,340 12/242013 26.89 29.827
10/25/2013 27.54 45,707 11/25/2023 25.69 27,853 1225/2013 25.57 35,187
10/26/2013 26.23 40.033 11/26/2013 28.47 52,237 12/26/2013 26.95 37,086
10/27/2013 27.47 35,052 11/27/2013 27.74 43.263 12/27/2013 27.26 32,283
10/28/2013 27.06 37.237 11/28/2013 26.64 52,434 12/28/2013 27.64 26,971
10/29/2013 25.50 39,982 11/29/2013 27.19 60,773 12/29/2013 27.95 28.439
10/30/2013 25.46 37,796 11/30/2013 26.80 57,666 12/30/2013 26.70 29,616
10/31/2013 26.65 39,118 12/31/2013 26.65 28,005
RECEIVED
Average Annual Flow: 26.81 MGD Division of Water Resources
Average Annual Color: 36,380 lbs/day
FEB - 3 2014
Water Quality Regional Operations
Asheville Regional Offae

'j
evergreen .0 Canton Office
packaging I 175 Main Street• Canton, NC 28716
NMM 44-13
July 1, 2013 CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7009 3220 0007 0371 4286
Chuck Cranford
Regional Supervisor
Division of Water Quality, Surface Water Protection
North Carolina Department of Environment and Natural Resources
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa,North Carolina 28778
Re: Annual Progress Report on Color
NPDES Permit No. NC0000272
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill
Dear Mr. Cranford—
Enclosed is the Annual Progress Report on Color required by Part I A.(8.)item 8 of the May 26,2010
NPDES permit. This report covers the second year of the permit(July 2011 through June 2012).
Very truly yours,
BLUE RIDGE PAPER PRODUCTS INC.
DOING BUSINESS AS EVERGREEN PACKAGING
By. RECEIVED
Nick
Water Compliance Coordinator DWQMurfhft Water Fouedees�otias
828-646-2874 Asheville Re Tonal Office
nick.mccrackenka eveMack.com
Enclosure: July 2013 Annual Progress Report on Color
cc: NC DWQ—Complex NPDES Permitting Unit,Raleigh
Billy Clarke,Roberts and Stevens
Internal distribution
fresh by design.,
EOHS\Share\Water\Color Reports 2010 Prmt Gong g,Mness in Corno,nio as Evergreen Beverage Packaging

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
I. Introduction
Part I A.(8.) item 8 of the May 2010 NPDES permit states — The facility will provide
annual progress reports to the Division on the color reduction efforts. This report fulfills
the requirement of Part I A.(8.) item 8 for the third year of the permit , July 2012 through
June 2013, with emphasis on the mill's Best Management Practices (BMP) program
refinements and the Color Perception Study on the Pigeon River.
Color-related reports previously submitted to the NC Division of Water Quality (DWQ)
under terms of the May 2010 NPDES permit include the following:
o July 2011 Annual Progress Report on Color[Evergreen 2011]
o February 2012 Update to the Color Reduction Implementation Plan [Evergreen
2012a]
o July 2012 Annual Progress Report on Color[Evergreen 2012d]
These reports are incorporated by reference.
II. Background
Levels of color in the wastewater effluent from the Canton Mill are among the best of
Kraft pulp and paper mills in the world [EKONO 2005,NCASI 2006]. This high level of
color performance is achieved by in-process controls and BMP's. The Canton Mill
continues to operate the controls and practices proven successful for color prevention.
These controls and practices go well beyond the requirements of the EPA Cluster Rule
Page 1

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
for Pulp and Paper (40 CFR 430, Subpart B). Many, such as the Bleach Filtrate
Recycling ProcessT", are unique to the Canton Mill.
The May 2010 NPDES permit includes a daily maximum effluent true color limit of
105,250 lbs per day. The permit also specifies a monthly average true color limit of
52,000 lbs per day and an annual average (calendar year) true color limit of 38,020 lbs
per day. Compliance with these effluent limits requires significant management of mill
operations related to color. Prevention of wastewater effluent color is a priority for mill
operations every day.
III. Color Performance
Figure 1 illustrates the color performance of the Canton Mill since 1997. Annual average
effluent true color in Figure 1 is presented in units of 1000 lbs per day. The calculation
of effluent color as a daily mass (lbs) is defined in Part I A.(8.) items 2&3 of the permit:
color (lbs/day) = effluent flow (mgd) x effluent true color (platinum cobalt units) x
8.34. Effluent true color is measured using NCASI method 253 (1971).
Page 2

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No. NC0000272
Figure 1 - Annual Average Effluent Color
Blue Ridge Paper Canton Mill, 1988 thru 2012
65
T60
W
55
U)
a
c 50
AIA 44.6
45
41.1 41.2
39
040 .1
37.1 36.1 36.5 35.9
35.3
V 3 34.8
5
C
30
Q
W 19g*1 Op
19g9 20p0 2pp'� v�02 Zpp3 ��pA 1��h 20p6 2op'1 2�p0 2�p9 ���0 �11 20N2
The best color performance for the Canton Mill occurs during normal, or full,production.
At full production, the internal recycling and recovery of process filtrates,pulping liquors
and other process wastewaters is balanced. Color materials are contained within the
Kraft pulping process at efficiency greater than 99 percent. Color performance is
affected by process variability. Color materials can be lost during startup and shutdown
associated with a process upset,production curtailment or unplanned outage. The Canton
Mill has an environmental and economic incentive to maintain process reliability and
operate at full production.
Effluent color performance in 2012 was excellent and demonstrated an improvement over
the prior year's color performance. The increased outage schedule for the lower end of
Page 3

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
the mill helped with reliability. The associated shortened Recovery Boiler cyclone
washes allowed pulp mill operations to continue to run with reduced unscheduled
downtime. Other opportunities were discovered within the Evaporator area, which
allowed an increase in throughput and a more reliable startup without carryover. These
changes and improvements contributed to improved color performance in 2012.
IV. Color Projects and Refinements to Best Manaeement Practices
The Canton Mill has a standing Color Team that meets regularly to review color
performance. The Color Team members include managers, supervisors and engineers
involved with production, maintenance, wastewater treatment and regulatory affairs. The
Color Team's scope includes:
• Monitoring color performance and the effectiveness of mill systems to prevent
effluent color
• Identifying and tracking corrective actions related to Cluster Rule BMP color
events
• Planning and reviewing process trials related to effluent color
• Planning and reviewing the effectiveness of capital and expense projects related
to effluent color
• Reviewing production and wastewater treatment issues that may affect operating
reliability and effluent color.
Page 4

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
The Color Team evaluates projects, trials and process initiatives. Not all are successful.
The July 2012 Color Progress Report [Evergreen 2012d] documented significant Color
Team activities between May 2006 and May 2012. Significant activities since 2010 are
outlined in Tables 1 and 2. Capital projects in Table I are identified by Capital
Improvement Project (CIP) number. Other projects were completed on operations and
maintenance expense. Direct spending on Color Team related projects, trials and
initiatives identified in Tables 1 and 2 during the period May 2010 through May 2013
exceeded $3.5 MM. These costs are in addition to the on-going cost to operate and
maintain color prevention systems at the Canton Mill.
Table 1
Color Team Capital and Maintenance Projects
2010 - Forward
Year Project Description and Cost Information for Capital Projects
2010 East Heavy/Tall Oil Sump transfer line repair. This was a proactive
measure to prevent color material losses from this transfer line. BMP
sustaining measure.
o Completed August 2010, cnsd*
Replaced decant line from Turpentine loading to 4A manhole. This was a
proactive measure to prevent losses from this transfer line. BMP sustaining
measure.
o Completed 2010
o CIP—315223
o Cost-$275,000
Repair and recoating of west side of Camp Branch compound. Project to
maintain integrity of spill containment. BMP sustaining measure.
o Completed 2010
o CIP—315588
o Cost-$235,000
Page 5

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
Table 1
Color Team Capital and Maintenance Projects
2010 - Forward
Year Project Description and Cost Information for Capital Projects
2010 Several black liquor transfer line replacements including East Heavy storage
tank and West GB Discharge. BMP sustaining measure.
o Completed 2010, cnsd*
Replaced conductivity and level switches in East Heavy compound with
new, more reliable type. BMP improvement.
o Completed 3Q 2010, cnsd*
Relocation of sewer conductivity meter below Digester Area sumps. BMP
optimization in this area.
o Completed November 2010, cnsd*
West Heavy Liquor(former Red Liquor Tank) shell replacement/repairs.
BMP sustaining measure.
o Completed May 2010
o CIP— 266446
o Cost—$265,000
Mini-Hoods on No. 11 Smelt Dissolving Tank(SMDT). Allows substitution
of weak wash for clean water in SMDT demister creating more process
demand for weak wash and reducing high pH material discharged to sewer.
Related to the weak wash purge strategy(Table 2) and TRW
Recommendations regarding prevention of sewer-generated color—high pH.
o Completed 3Q 2010, cnsd*
Installation of spray bar on the 5 h effect of the Swenson evaporator set.
Spray allows the 5's effect chevrons to be cleaned on the run reducing the
amount of carryover color in the condensate system during normal operation
between evaporator outages. Color material cant'over from evaporators into
condensates is related to TRW Recommendations to prevent sewer-generated
color.
o Completed October 2010, cnsd*
Page 6

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
Table 1
Color Team Capital and Maintenance Projects
2010 - Forward
Year Project Description and Cost Information for Capital Projects
2010 North White Liquor Tank shell replacement/repairs. BMP sustaining
measure and project related to TRW Recommendations regarding prevention
of sewer-generated color—high pH white liquor.
o Completed Dec 2010
o CIP—322435
o Cost—$724,000
2011 Process lines to allow front-end boil out of West GB evaporator set. Allows
more frequent, less intense evaporator cleaning. BMP improvement for
process reliability to avoid carryover of color material into condensate
systems. Reduces the volume of color material generated by evaporator boil
out during outages. Color material carry over from evaporators into
condensates is related to TRW Recommendations to prevent sewer-generated
color.
o Completed May 2011, cnsd*
Repaired drain valves on No. 2 and 3 Primary Clarifiers. Allows reliable
isolation of one of these larger volume clarifiers as the spare clarifier for
high color material diversion during semi-annual outages. BMP sustaining
measure.
o Completed March 2011, cnsd*
Pine Weak Liquor Tank shell replacement/repairs. BMP sustaining
measure.
o Completed May 2011
o CIP—331985
o Cost—$349,000
Page 7

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
Table 1
Color Team Capital and Maintenance Projects
2010 - Forward
Year Project Description and Cost Information for Capital Projects
2011 Installed soft start on motors for the hardwood weak black liquor transfer
pumps and hardwood blow tower dilution pumps. Project reduces pump start
water hammer in pipes containing black liquor and reduces risk of gasket
failure,valve failure and/or pipe hanger failure from water hammer pipe
movement. Project was identified by a water hammer valve failure in May
2011 that was contained within the process and did not reach the wastewater
plant.
o Completed May 2011 on hardwood blow tower dilution pumps
o Completed Jul 2011 on hardwood weak black transfer pumps
0 4 soft starts at$7540 each, project cost of$30,160 plus installation
cost on maintenance expense
2012 Installation of new Oramac shower bars on the East Decker at the Hardwood
Fiberline.These shower bars help improve washing efficiency and reduced
carry-over of sodium compounds into the bleach plant, which in turn,will
reduce D 1 stage C102 demand and effluent color from the bleach plant.
o Completed April 2012
o Cost-—$40,000
Replaced shower bars on hardwood East Decker with improved design
matching shower bars previously installed on hardwood brownstock
washers. These shower bars improve washing and reduce carryover of color
materials into the bleach plant. Liebergott Recommendation.
o Completed during May 2012 hardwood semi-annual outage as part of
larger East Decker vat repair project
o CIP-358168
o Cost— $32,000 for shower bar portion of project
Replaced level controls on condensate flash tanks on the West GB
evaporator set. The new controls are more reliable and less prone to
plugging and false level indication that can cause color material carryover
into the combined condensate system, which contributes to sewer generated
color. Related to TRW Recommendations regarding prevention of sewer
generated color.
o Completed during May 2012 semi-annual outage
0 2 capillary level elements and isolation valves at$9500 each, project
cost of$ 29,000 including installation on maintenance expense
Page 8

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
Table 1
Color Team Capital and Maintenance Projects
2010 - Forward
Year Project Description and Cost Information for Capital Projects
2012 West GB Skim Tank cleaning and repair of leaks. BMP sustaining measures.
o Completed July 2012
o Cost- $125,000
West Heavy Liquor Tank compound sealing and lining. BMP sustaining
measure.
o Completed August 2012
o Cost- $150,000
Replacement of floor drain piping in Hardwood fiberline. Floor drains carry
spill material directly to the Hardwood Spill Tank. This replacement
minimized losses to the mill sewer system.
o Completed Fall 2012, cnsd*
Sealing and lining of the West Unoxidized Black Liquor compound. BMP
sustaining measure to reduce potential leakage of high pH material and to
reinstate the integrity of the containment and sump.
o Completed August 2012
Cost-$150,000
West GB Feed Tank cleaning and repair of leaks. BMP sustaining measures.
o Completed September 2012
o Cost-$75,000
Replacement of floor drains on#10 Recovery Boiler. BMP sustaining
measure.
o Completed October 2012
o Cost-$150,000
Wash Water line replacement(phase I1). Project identified to improve line
integrity and prevent potential elevated color losses from reaching the mill
sewer system.
o Completed December 2012
o CIP - 371577
o Cost-$99,333
Page 9

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
Table 1
Color Team Capital and Maintenance Projects
2010 - Forward
Year Project Description and Cost Information for Capital Projects
2013 Relocation of#5B Sewer conductivity meter and sampler. BMP
improvement measure related to TRW Recommendations to further improve
leak detection and process monitoring.
o Completed January 2013, c»sd*
South Green Liquor Clarifier shell replacement/repairs. BMP sustaining
measure and project related to TRW Recommendations regarding prevention
of sewer-generated color—high pH green liquor.
o Completed February 2013
o CIP -370243
o Cost- $581,442
Installation of an additional u-drain located on the north side of the
Hardwood Blow Tower. This drain will allow the capture and redirection of
weak black liquor material from around the blow tower to the mill sump
system.
o Completed March 2013
o Cost-$36,641
West Green Liquor Clarifier shell replacement/repairs. BMP sustaining
measure and project related to TRW Recommendations regarding prevention
of sewer-generated color—high pH green liquor.
o Completed March 2013
o CIP-370243
o Cost-$122,000
Installation of new Oramac shower bars on the West Decker at the
Hardwood Fiberline. These shower bars help improve washing efficiency
and reduced carry-over of sodium compounds into the bleach plant, which in
turn,will reduce D 1 stage C102 demand and effluent color from the bleach
plant.
o Completed April 2013
o Cost-—$40,000
Page 10

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
Table 1
Color Team Capital and Maintenance Projects
2010 - Forward
Year Project Description and Cost Information for Capital Projects
2013 West White Liquor Storage Tank shell replacement/repairs. BMP
sustaining measure and project related to TRW Recommendations regarding
prevention of sewer-generated color—high pH white liquor.
o Completed April 2013
o Cost-$122,000
West GB 2"d Effect pump upgrade. Obsolete pump replaced with different
style to increase reliability and reduce downtime which in some cases can be
attributed to increase color loading to the mill sewer system.
o Completed April 2013
o Cost-$72,869
Mini-Hoods on No. 10 Smelt Dissolving Tank(SMDT). Allows substitution
of weak wash for clean water in SMDT demister creating more process
demand for weak wash and reducing high pH material discharged to sewer.
Related to the weak wash purge strategy(Table 2) and TRW
Recommendations regarding prevention of sewer-generated color—high pH.
o Completed May 2013, cnsd*
*cnsd—cost not separately determined, completed on operations and
maintenance expense
Table 2
Color Team BMP Refinements, Trials and Process Improvements
2010 forward
Year(s) Refinement,Trial and/or Improvement
2010 Weak wash purge strategy to minimize potential sewer-generated color
on-going during process upset, outage or reduced pulp mill production when demand
for weak wash is out of balance with supply in causticizing.
2011 When both fiberlines are down, process contents of one of the spill tanks
through the evaporators to free up spill tank volume before starting up. Was
used successfully during and after the May 2011 cold mill outage to
minimize loss of dilute color material to the WWTP.
Page 11

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
Table 2
Color Team BMP Refinements, Trials and Process Improvements
2010 forward
Years) Refinement,Trial and/or Improvement
2011 Alternative polymer study by Chemtreat at W WTP. Compared against
current polyamine polymer in use for batch treatment of black color
materials.No difference in color performance. Existing batch treatment
polyamine polymer was retained.
2011 West GB Evaporator partial boil out strategy. Ability to clean process during
on-going short outages as opportunity arises. Improves process reliability and reduces
volume of color material to recover during outages.
2012 Reliability focus -7 to 8 week planned maintenance outage cycle for
on-going recovery furnaces and fiberlines. Prior to 2012,planned outage cycle was 10
to 12 weeks and additional unplanned outages were often necessary. Mill
experience is that more frequent planned outages result in more reliable
process operation between outages and lower color. Color associated with
planned outages is also generally lower than color associated with an
unplanned outage.
2012 Color prevention MOC/pre-task review process for outage and maintenance
on-going tasks associated with black liquor. This is in addition to the permit-required
review of modifications to systems managing black liquor, turpentine and
soap.
In 2012 and in 2013, the Color Team has focused on the reliability of the Recovery
Furnaces and Fiberlines. When the mill experiences a process upset, and in particular an
upset requiring an unplanned outage to correct, effluent color is not as good. The team
targeted planned maintenance outages every seven to eight weeks. The frequency of
outage work allows mill operations to stay ahead of potential issues that could necessitate
an unplanned outage. Fewer unplanned outages and shorter periods of downtime help the
mill maintain steady operations leading to better color performance.
Page 12

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
V. TRW Recommendations
The Canton Mill continues to evaluate and improve existing BMPs and reduce
opportunities for sewer generated color,which historically, has been associated with high
alkali material mixing with acidic materials. In 2012,the mill focused on removing
contributions of white and green liquors from the mill sewer system through repairs to the
West White, West Green and South Green Liquor Tanks. This included taking the tanks
out of service, cleaning them and then proceeding with repairs that could not be done
during normal operation. The West Green Liquor Tank is located inside the West
Unoxidized Black Liquor Compound. As part of the BMP sustaining measures, the
compound was cleaned, sealed and lined to reinstate the integrity of the containment and
sump preventing losses of both green and black liquors.
A practice put into place in 2010 included a weak wash purge strategy reducing the
amount sent to the mill sewer system by installation of mini-hoods on the#11 Recovery
Boiler smelt dissolving tank. This practice allowed operators to substitute weak wash for
clean water in the dissolving tank demister. This created more process demand for weak
wash material and reduced the amount discharged to the mill sewer. During the spring
semi-annual outage, the#10 Recovery Boiler smelt dissolving tank hoods were replaced
increasing the demand and further reducing the amount purged to the mill sewer system.
Page 13

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
Reduction in black liquors to the mill sewer remains a priority. Two black liquor tank
repair projects were initiated in the fall of 2012. The West GB Feed Tank and Skim Tank
were taken out of service, cleaned and repaired. The floor drains in the#10 Recovery
Boiler were also replaced. The replacement of these drains allowed black liquor material
to be transferred to spill collection tanks instead of the mill sewer system. Although,the
material would have ultimately been processed through the area sump system, by
allowing the material to be transferred through piping it prevents dilution prior to
reaching the sump.
Improvements to the mill sewer monitoring system included the relocation of the#5B
sewer conductivity meter and sampler. Previous monitoring results indicated that the
location received high amounts of solids which periodically would block the flow to the
probe. By relocating the probe upstream, this improved BMP monitoring and collection
of daily samples for analysis.
VI. Color Perception Studv on the Pigeon River
In July 2010, Cocke County, Tennessee and a coalition of environmental groups,
represented by the Southern Environmental Law Center (SELC), filed a Petition for
Contested Case in the NC Office of Administrative Hearings (OAH) — 10 EHR 4341,
challenging color and temperature limits in the May 2010 NPDES permit. The
Petitioners also filed a second Petition for Contested Case challenging the revised Color
Page 14

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
Variance for the Canton Mill — 10 EHR 4982. The two cases were consolidated in
October 2010.
Discovery in the Contested Cases was conducted from October 2010 through June 2011.
Dispositive motions were filed in July 2011. A hearing on dispositive motions was held
in Haywood County, North Carolina on September 30, 2011. Following that hearing,
Adminstrative Law Judge (ALJ) Randall May entered an order dismissing all but one of
the Tennessee Petitioners. The Contested Cases where scheduled for administrative
hearing in April 2012.
Discussions between Evergreen legal counsel and legal counsel for the NC DWQ and the
SELC began in January 2012 and resulted in a Partial Settlement [OAH 2O12] to the
Constested Cases on April 24,2012. A copy of the agreement is attached in Appendix C.
In the Partial Settlement, Evergreen Packaging agreed to fund a Color Perception Study
on the Pigeon River in North Carolina, as outlined in the EPA letter of February 22, 2010
objecting to the December 2009 Draft NPDES permit proposed by the NC DWQ for the
Canton Mill. Evergreen Packaging, the NC DWQ and the petitioners agreed to stay the
hearing on color issues in the Contested Cases until 2013 after completion of the Color
Perception Study..
Page 15

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No. NC0000272
On February 20, 2012 Evergreen Packaging submitted a Color Perception Study Plan to
the NC DWQ. The DWQ coordinated review of the plan with the EPA. After several
rounds of comments and revisions, the plan was approved. The Color Perception Study
Plan revision dated April 17, 2012 [Evergreen 2012c] was approved by the DWQ on June
1, 2012. A copy of the approved study plan is attached in Appendix D. The cost to
complete the approved Color Preception Study is on the order of approximately
$200,000 USD.
The study took place during the months of June, September and November, 2012. The
study was conducted by Dr. Albert Prestrude and Dr. Don Cherry of Virginia Tech
University. Approximately 30 observers were recruited for each event in the study. Each
participant was asked to give an opinion, in the form of ratings for color, clarity, scenic
beauty and secondary recreation, for both upstream and downstream. The observers, for
all events, were first taken to the North Carolina /Tennessee stateline where they began
their observations and then ended at a point above the Canton Mill. There were a total of
eight observation sites along the river.
A report of the Study was submitted to DWQ in January, 2013. In response to DWQ
comments, the report was amended and supplemented in March. Evergreen and Drs.
Cherry and Prestrude are working on a final revision of the report in response to
additional DWQ comments. The report should be submitted to DWQ in early July,2013.
Page 16

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
V1I. Summary
Prevention of effluent color is a priority for Canton Mill operations every day. The
Canton Mill's focus on process reliability and uptime has resulted in the mill's best
annual color performance to date. The Canton Mill will continue to utilize the processes
and practices proven successful for wastewater effluent color prevention.
Page 17

July 2013 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
REFERENCES
EKONO 2005—Environmental Performance, Regulations and Technologies in the Pulp
and Paper Industry, EKONO Inc,August 2005.
Evergreen 2011 — Annual Progress Report on Color, submitted to NC DWQ to meet
requirements of Part I A.(8) item 8 of the May 2010 NPDES Permit, Evergreen
Packaging,July 1, 2011.
Evergreen 2012a —February 2012 Update to the Color Reduction Implementation Plan,
submitted to NC DWQ to meet requirements of Part I A.(8) item I I of the May 2010
NPDES Permit, Evergreen Packaging, February 20, 2012.
Evergreen 2012b — Response to EPA Comments dated 22 March 2012 concerning
February 2012 Update to the Color Reduction Implementation Plan, letter to NC DWQ
Complex NPDES Permitting Unit from Evergreen Packaging dated April 10, 2012.
Evergreen 2012c — April 2012 Color Perception Study Plan and Response to EPA
Comments dated 28 March 2012 concerning the March 2012 Revised Color Perception
Study Plan, submitted to NC DWQ Complex NPDES Permitting Unit by Evergreen
Packaging on April 17,2012.
Evergreen 2012d — Annual Progress Report on Color, submitted to NC DWQ to meet
requirements of Part I A.(8) item 8 of the May 2010 NPDES Permit, Evergreen
Packaging,July 1, 2012.
NC OAH 2O12 — Partial Settlement Agreement and Joint Stipulation to Stay, 10 EHR
4341 and 10 EHR 4982, North Carolina Office of Administrative Hearings, April 24,
2012.
NCASI 2006—Technical Bulletin No. 919—Review of Color Control Technologies and
Their Applicability to Modem Kraft Pulp and Paper Mill, National Council for Air and
Stream Improvement, August 2006.
Page 18

evergreen .0 CantonOffice
packaging 175 Main Street• Conton, NC 28716
August 21, 2013 NMM#63-13
CERTIFIED MAIL RECEIVED
Return Receipt Requested
7009 3220 00027 0371 4309
Chuck Cranford AUG 2 3 2013
Asheville Regional Supervisor DWQMvr1%ce warn Proteetkm Section
Division of Water Quality Asheville Rceional Office
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton, Haywood County,North Carolina
Daily Maximum Fecal Coliform 8/16/2013
NPDES Permit: NC0000272
Dear Mr. Cranford:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
8/16 at approximately 9:15 am and delivered to the laboratory for analysis. Proper sampling
procedures were followed by plant personnel. The wastewater treatment plant supervisor, Roger
Edwards, was informed of the result the afternoon of 8/17. The result of the analysis showed a
value of>600 colonies per 100m1. The fecal coliform excursion on 8/16 was limited to that
sample parameter and day. All other effluent parameters were within permit requirements. A
phone call was placed to the NCDWQ Regional office on 8/17 at approximately 2:30 pm.
On Monday 8/12, the Canton area experienced a heavy rainfall event resulting in over two inches
of rain within a 35 minute period. Flow to the wastewater treatment plant, from the town and
mill, peaked at approximately 50 million gallons. In order to manage flow and protect plant
operations the plant's spare primary clarifier was partially filled. After the event, flow
normalized and the spare clarifier was slowly drained back into the treatment process over the
next three days. This material from the spare clarifier was from the first flush of the rainfall
event and believed to hold the most concentrated waste. All systems were operating as designed
during this time with current process trends indicating compliance for the remainder of the
month.
fresh by design..
Fcing gyinexs n Col4�inio,a'reigieen Beve�ge FeJ.ugng
IleverpacklcaWOHSISHAREI Water Files Wick's Water RIes0WO

VNCDWQ Page 2
If you have any questions or comments, please feel free to contact us at your earliest
convenience.
Sincerely
Nick McCracken
Water Compliance Coordinator
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCracken( everpack.com
cc:
Mr. Jeff Menzel
Environmental Specialist,Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778
C. File—Water Notebook
Internal distribution -
D. Griswold
M. Ferguson
R. Edwards
C. Chiles
N. McCracken
J. Pryately

t
i.
evergreen.. Canton Office
packaging I 175 Main Street• Canton, NC 28716
August 21, 2013 NMM#63-13
CERTIFIED MAIL I =
Return Receipt Requested
7009 3220 00027 0371 4309
Chuck Cranford
Asheville Regional Supervisor
Division of Water Quality
North Carolina Department of Environment
- --and-Natural-Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton,Haywood County,North Carolina
Daily Maximum Fecal Coliform 8/16/2013
NPDES Permit: NC0000272
I_
Dear Mr. Cranford:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
8/16 at approximately 9:15 am and delivered to the laboratory for analysis. Proper sampling
procedures were followed by plant personnel. The wastewater treatment plant supervisor, Roger
Edwards,was informed of the result the afternoon of 8/17. The result of the analysis showed a
value of>600 colonies per 100m1. The fecal coliform excursion on 8/16 was limited to that
sample parameter and day. All other effluent parameters were within permit requirements. A
phone call was placed to the NCDWQ Regional office on 8/17 at approximately 2:30 pm.
On Monday 8/12, the Canton area experienced a heavy rainfall event resulting in over two inches
of rain within a 35 minute period. Flow to the wastewater treatment plant, from the town and
mill,peaked at approximately 50 million gallons. In order to manage flow and protect plant
operations the plant's spare primary clarifier was partially filled. After the event, flow
normalized and the spare clarifier was slowly drained back into the treatment process over the
next three days. This material from the spare clarifier was from the first flush of the rainfall
event and believed to hold the most concentrated waste. All systems were operating as designed
during this time with current process trends indicating compliance for the remainder of the
month.
fresh by design.
poingBuv�ess..�Ce.'.fmm.:cs Eveeie=n Ev:em9�Pari cptng
VeverpacklcalEOHS1SHARMWeter ResWick's Water Res0WO

. NCDWQ Page 2
If you have any questions or comments,please feel free to contact us at your earliest
convenience.
Sincerely
Nick McCracken
Water Compliance Coordinator
----Evergreen Packaging=Canton Mill — - - — _---- --- -- —
828-646-2874
Nick.McCrackenna,everoack.com
cc:
Mr. Jeff Menzel
Environmental Specialist, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778
C. File—Water Notebook
Internal distribution-
D. Griswold
M. Ferguson
R. Edwards
C. Chiles
N. McCracken
J. Pryately

evergreen Canton Office
packaging I 175 Main Street• Conlon, NC 28716
March 3, 2014 NMM#20-14
CERTIFIED MAIL
Return Receipt Requested
7099 3220 0007 0371 4439
RE
Landon Davidson VNIalon o Wattl REDS
Asheville Regional Supervisor
Division of Water Resources MAR - 6 2014
North Carolina Department of Environmell t
and Natural Resources
Asheville Regional Office Water'Qvatfty rtr"o eOperations
2090 us Highway 70 Astlev;!le R. ional Office
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill,Canton, Haywood County,North Carolina
Daily Maximum Fecal Coliform 2/20/2014
NPDES Permit: NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
2/20 at approximately 8:05 am and picked up by courier to be taken to the laboratory for
analysis. Proper sampling procedures were followed by plant personnel. We received the
laboratory report the afternoon of 2/26. The result of the analysis showed a value of 440
colonies per 100m1. The fecal coliform excursion on 2/20 was limited to that sample parameter
and day. A phone call was placed to the NCDWR regional office on 2/26.
Once we received the value from the laboratory all systems in the treatment facility were
checked. They were found to be operating correctly leading up to and during the time of sample.
We are conducting an in depth investigation, along with the Town of Canton, into the cause of
this result.
If you have any questions or comments, please feel free to contact us at your earliest
convenience.
fresh by design.. /
IleverpacklcalEOHSISHARE1Water Files Wick's Water FilesIDWO

NCDWR Page 2
Sincerely,
r
Nick McCracken
Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCrackenReverpack.com
cc:
Mr. Jeff Menzel
Environmental Specialist,Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778
C. File—Water Notebook

evergreen.4 Canton Alice
packaging 175 Morn Street Conlon, NC 28716
March 3, 2014 NMM#20-14
CERTIFIED MAIL
Return Receipt Requested RECEIVED�
7099 3220 0007 0371 4439
Landon Davidson MAN — 6 20
Asheville Regional Supervisor
Division of Water Resources werereuenr Roomwoan+mr
North Carolina Department of Environment I Asheville Regional Office
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill,Canton,Haywood County,North Carolina
Daily Maximum Fecal Coliform 2/20/2014
NPDES Permit: NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
2/20 at approximately 8:05 am and picked up by courier to be taken to the laboratory for
analysis. Proper sampling procedures were followed by plant personnel. We received the
laboratory report the afternoon of 2/26. The result of the analysis showed a value of 440
colonies per 100ml. The fecal coliform excursion on 2/20 was limited to that sample parameter
and day. A phone call was placed to the NCDWR regional office on 2/26.
Once we received the value from the laboratory all systems in the treatment facility were
checked. They were found to be operating correctly leading up to and during the time of sample.
We are conducting an in depth investigation, along with the Town of Canton, into the cause of
this result.
If you have any questions or comments, please feel free to contact us at your earliest
convenience.
fresh by design,.
lleverpacklcalEOHSISHAREAWater ResWick's Water ReslDWO /

NCDWR Page
Sincerely,
��4 ;�D
Nick McCracken
Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCracken(aD,evgWack.com
cc:
Mr. Jeff Menzel
Environmental Specialist,Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
C. File—Water Notebook

evergreemo Canton Office
175 Main Street• Canton, NC 28716
packaging
March 14,2014 NMM#21-14
CERTIFIED MAIL
Return Receipt Requested �ED CBS
7099 3220 0007 0371 4446 REC'w„e
Landon Davidson
Asheville Regional Supervisor MpR s
Division of Water Resources e\oae'a"°�
North Carolina Department of Environment ova°�v
and Natural Resources weke`Pshe\soe
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill,Canton,Haywood County,North Carolina
Daily Maximum Fecal Coliform 2/28/2014
NPDES Permit: NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
2/28 at approximately 1:10 pm and was delivered to the laboratory for analysis. Proper sampling
procedures were followed by plant personnel. We received the laboratory report the afternoon of
3/12. The result of the analysis showed a value of 488 colonies per 100m1. The fecal coliform
excursion on 2/28 was limited to that sample parameter and day. A phone call was placed to the
NCDWR regional office on 3/13.
Once we received the value from the laboratory all systems in the treatment facility were
checked. They were found to be operating correctly leading up to and during the time of sample.
We are continuing our in depth investigation, along with the Town of Canton,into the cause of
this result.
If you have any questions or comments, please feel free to contact us at your earliest
convenience.
IleveryacMlcaIE0HS0HARE1Wafer ResWldc's Wafer FilesIDWO

NCDWR Page 2
Sincerely,
Nick McCracken
Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCrackenAevemack.com
cc:
Mr. Jeff Menzel
Environmental Specialist, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778
C. File—Water Notebook

evergreen,* Canton Office
packaging 175 Main Street Conton, NC 28716
March 14, 2014 NMM#21-14
CERTIFIED MAIL
Return Receipt Requested a19naUsV
7099 3220 0007 0371 4446 301BO feu ol6ae kul�n0 retell
6UW}adp 18V
Landon Davidson
Asheville Regional Supervisor
Division of Water Resources
North Carolina Department of Environment �sad,or, w
and Natural Resources Q�nI3J3
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill,Canton, Haywood County,North Carolina
Daily Maximum Fecal Coliform 2/28/2014
NPDES Permit: NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
2/28 at approximately 1:10 pm and was delivered to the laboratory for analysis. Proper sampling
procedures were followed by plant personnel. We received the laboratory report the afternoon of
3/12. The result of the analysis showed a value of 488 colonies per 100ml. The fecal coliform
excursion on 2/28 was limited to that sample parameter and day. A phone call was placed to the
NCDWR regional office on 3/13.
Once we received the value from the laboratory all systems in the treatment facility were
checked. They were found to be operating correctly leading up to and during the time of sample.
We are continuing our in depth investigation, along with the Town of Canton, into the cause of
this result.
If you have any questions or comments,please feel free to contact us at your earliest
convenience.
l
I1everpacklaa1E0HSISHAREI Wafer FlesWick's Water FilesV)WQ

NCDWR Page 2
Sincerely,
Nick McCracken
Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCracken(a)everpack.com
cc:
Mr. Jeff Menzel
Environmental Specialist,Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778
C. File—Water Notebook

evergreen,%
F
l .
packaging 3
Blue Ridge Paper Products Inc. - Canton Mill gP IUN
January 14, 2013 NMM#01-13
CERTIFIED MAIL
Return Receipt Requested
7008 3230 0002 2595 4479
Chuck Cranford
Regional Supervisor
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Subject: NPDES NC0000272
2012 Annual Average Color
Evergreen Packaging
Canton,NC
Dear Mr. Cranford:
This letter and attachment document the 2012 average annual color discharge from Blue Ridge
Paper Products Canton Mill. Average secondary effluent color discharge for the period 1 Jan
2012 through 31 Dec 2012 was 34,800 lbs/day and is compliant with the permit.
The attachment provides daily wastewater discharge flows and secondary effluent true color for
the mill during 2012.
Sincerely,
Nick McCracken
Water Compliance Coordinator
Evergreen Packaging—Canton Mill
828-646-2874
Attachment: Daily flow and color discharge for 2012
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpacklCTNlSharedlEOHSISharel Water FileslNick's Water Files10WM4nnual Reports12012 Annual Color Letter.doc

Canton Mill 2012 Average Annual Color and Wastewater Flaw
Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color
MGD "Ib/dad' MGD "Ib/dav" MGD "Ib/dav"
1/1/2012 26.75 47.296 2/1/2012 27.89 38.612 3/1/2012 27.01 73.436
1/2/2012 26.18 52.402 2/2/2012 26.03 48.194 3/2/2012 26.87 54.007
1/3/2012 25.41 35,602 2/3/2012 26.98 49.953 3/3/2012 27.83 40,386
1/4/2012 26.78 40,649 2/4/2012 27.28 49,598 3/4/2012 26.72 35,209
1/5/2012 27.62 47,222 2/5/2012 26.23 42,439 3/5/2012 26.46 41,046
1/6/2012 26.57 46.535 2/6/2012 26.29 34.643 3/6/2012 26.05 39,324
1/7/2012 27.61 37.303 2/7/2012 26.28 31,561 3/7/2012 27.49 38,058
1/8/2012 27.27 34,570 2/8/2012 29.80 26,941 3/8/2012 28.51 34,715
1/9/2012 27.59 36,816 2/9/2012 25.30 28,274 3/9/2012 27.78 42,398
1/10/2012 26.72 -41.895-. --- - -2/10/2012 - -25.97 37,470 -- - - - -3/10/2012 - 25.92 - -28,535 - - -
1/11/2012 27.80 36.633 2/11/2012 25.91 34.142 3/11/2012 24.68 31,286
1/12/2012 29.12 33.525 2/12/2012 25.53 34,919 3/12/2012 26.40 29.063
1/13/2012 26.67 28,248 2/13/2012 25.51 32,339 3/13/2012 25.53 27.467
1/14/2012 26.55 26.128 2/14/2012 25.98 25,134 3/14/2012 27.12 32,796
1/15/2012 26.52 31.186 2/15/2012 26.70 25,831 3/15/2012 26.30 22.812
1/16/2012 26.32 35.341 2/16/2012 26.92 32.779 3/16/2012 25.37 38,932
1/17/2012 26.73 33.885 2/17/2012 26.24 30.638 3/17/2012 25.57 41,371
1/18/2012 24.37 39,836 2/18/2012 26.23 31.501 3/18/2012 25.91 38,464
1/19/2012 25.99 44.218 2/19/2012 27.18 32,189 3/19/2012 25.29 40,285
1/20/2012 25.31 29,763 2/20/2012 25.90 31.969. 3/20/2012 25.21 37.425
1/21/2012 26.41 27,092 2/21/2012. 27.02 41.464 3/21/2012 24.62 37.370
1/22/2012 26.37 33,429 2/22/2012 26.96 41,821 3/22/2012 25.09 31,388
1/23/2012 27.23 40.878 2/23/2012 28.02 37,390 3/23/2012 26.28 53.917
1/24/2012 27.27 39.346 2/24/2012 28.25 35.812 3/24/2012 29.62 56.323
1/25/2012 25.91 31,549 2/25/2012 27.31 38.720 3/25/2012 27.06 33.401
1/26/2012 26.55 31,221 2/26/2012 26.57 40,773 3/26/2012 25.88 33.887
1/27/2012 26.32 36,438 - - 2/27/2012 - 26.97 - 39,588. . - -3/27/2012 - --24.87 34,846.
1/28/2012 26.71 35.419 2/28/2012 23.62 40,580 3/28/2012 28.34 36.871
1/29/2012 25.98 29.034 2/29/2012 24.76 51,212 3/29/2012 25.22 33.023
1/30/2012 25.86 31.057 3/30/2012 26.00 21.250
1/31/2012 26.06 33,905 3/31/2012 25.39 27,104
Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color
MGD Ib/day" MGD "Ib/dav" MGD "Ib/dav"
4/1/2012 24.76 30.975 5/1/2012 27.63 29.265 6/1/2012 26.97 28.791
4/2/2012 26.33 39.307 5/2/2012 26.32 25.244 6/2/2012 26.30 39.920
4/3/2012 29.13 52.719 5/3/2012 27.39 23,300 6/3/2012 26.61 31.292
4/4/2012 27.51 43,133 5/4/2012 26.61 25,300 6/4/2012 26.30 32,243
4/5/2012 28.62 37,236 5/5/2012 26.69 22,927 6/5/2012 27.00 41,658
4/6/2012 24.77 31.814 5/6/2012 26.80 26.151 6/6/2012 28.21 35.761
4/7/2012 26.64 33.327 5/7/2012 27.29 26.857 6/7/2012 26.89 36.765
4/8/2012 27.29 37,781 5/8/2012 26.91 37.704 6/8/2012 25.42 29,044
4/9/2012 26.85 36,724 5/9/2012 27.20 37.657 6/9/2012 25.85 27,164
4/10/2012 27.52 26.624 5/10/2012 26.07 30.222 6/10/2012 26.75 27,218
4/11/2012 26.95 32,141 5/11/2012 26.70 34,292 6/11/2012 25.63 25,651
4/12/2012 26.53 29.428 5/12/2012 26.90 34.549 6/12/2012 25.68 28.056
4/13/2012 26.34 26,581 5/13/2012 28.23 33.668 6/13/2012 26.00 31.659
4/14/2012 25.43 33,510 5/14/2012 29.10 49,995 6/14/2012 27.20 37.657
4/15/2012 25.85 29,320 5/15/2012 25.51 101,058 6/15/2012 26.88 36,765
4/16/2012 26.09 34,814 5/16/2012, 25.55 88.005 6/16/2012 25.96 40.270 - -
4/17/2012 28.92 40,762 5/17/2012 24.31 67.311 6/17/2012 26.16 35,781
4/18/2012 32.32 35.041 5/18/2012 23.77 35,485 6/18/2012 27.77 35,435
4/19/2012 27.79 29.666 5/19/2012 26.40 55,044 6/19/2012 27.48 29.794
4/20/2012 27.39 30.838 5/20/2012 27.08 40.878 6/20/2012 26.76 25,442
4/21/2012 27.37 35.609 5/21/2012 27.62 34,553 6/21/2012 26.99 26.111
4/22/2012 27.14 26,935 5/22/2012 27.56 34,018 6/22/2012 26.87 21,737
4/23/2012 27.74 29,844 5/23/2012 29.92 35,933 6/23/2012 26.95 26,747
4/24/2012 27.92 34,462 5/24/2012 27.38 41,560 6/24/2012 26.36 25.062
4/25/2012 24.73 28,668 5/25/2012 26.35 22,855 6/25/2012 26.94 25,164
4/26/2012 29.79 43,230 5/26/2012 27.27 30,021 6/26/2012 26.10 29.821
4/27/2012 27.94 28,894 5/27/2012 25.75 26,415 6/27/2012 26.24 26.699
4/28/2012 26.82 23.486 5/28/2012 26.49 36,674 6/28/2012 26.04 25,626
4/29/2012 26.84 30.219 5/29/2012 27.96 35,444 6/29/2012 26.44 26.692
4/30/2012 26.57 27,921 5/30/2012 27.09 25,756 6/30/2012 26.06 26.081
5/31/2012 26.88 25,556

Canton Mill 2012 Average Annual Color and Wastewater Flow
Date WTP Flow Sec EH Color Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color
MGD "Ib/dav" MGD "Ib/dav" MGD "Ib/dav"
7/1/2012 27.24 26,807 8/1/2012 29.25 35.616 9/1/2012 26.13 46.200
7/2/2012 28.45 28.473 8/2/2012 27.59 35.896 9/2/2012 26.71 34.082
7/3/2012 27.17 22.884 8/3/2012 26.57 41,881 9/3/2012 26.78 31,938
7/4/2012 27.03 29,983 8/4/2012 25.77 41.050 9/4/2012 26.11 28.526
7/5/2012 27.06 27,759 8/5/2012 25.69 34,709 9/5/1012 26.94 37,158
7/6/2012 26.31 29.184 8/6/2012 27.13 34,618 9/6/2012 27.21 63.995
7/7/2012 26.54 33.866 8/7/2012 26.30 29,831 9/7/2012 26.56 65.346
7/8/2012 26.71 38.760 8/8/2012 25.62 37,179 9/8/2012 26.16 43,417
7/9/2012 27.17 40.108 8/9/2012 26.93 51,208 9/9/2012 26.12 31.369
7/10/2012 30.26 42,650 8/10/2012 26.74 38,804 9/10/2012 25.55 36.225
7/11/2012 29.89 52,349 8/11/2022 25.86 32.351 9/11/2012 25.23 35.771
7/12/2012 30.88 58.204 8/12/2012 26.14 27.033 9/12/2012 24.40 32,966
7/13/2012 28.80 43,475 8113/2D12 26.39 27,952 9/13/2012 25.50 34,878
7/14/2012 29.14 39,127 8/14/2012 27.01 32,213 9/14/2012 25.63 32.918
7/15/2012 28.34 31,199 8/15/2012 26.19 28.177 9/15/2012 25.41 33,483
7/16/2012 28.41 31,750 8/16/2012 26.35 27.690 9/16/2012 25.94 29.422
7/17/2012 28.59 30,520 8/17/2012 26.19 27,521 9/17/2012 26.39 31,693
7/18/2012 28.90 32,539 8/18/2012 26.97 28,791 9/18/2012 30.01 38.043
7/19/2012 27.64 35,961 8/19/2012 27.02 25.690 9/19/2012 26.90 32.755
7/20/2012 30.43 34,515 _8120/2012_ 26.58 _ 27,488_ _ _ 920/2012 25.79 29.037
7/21/2012 29.20 29.467 821/2012 27.59 34,055 9/21/2012 26.47 30,244
7/22/2012 28.13 32.845 8/22/2012 26.72 41.003 9/22/2012 26.85 29,335
7/23/2012 27.17 31,497 823/2012 26.84 37,158 923/2012 26.32 25.683
7/24/2012 27.17 33,990 8/24/2012 25.81 28.844 9/24/2012 26.23 29.095
7/25/2012 26.07 33.483 8/25/2012 26.24 27.136 9/252012 25.70 27,650
7/26/2012 25.64 31.648 8/26/2012 25.53 30,661 9/262012 25.74 38.212
727/2012 27.68 33.012 827/2012 26.05 3SA13 927/2012 25.40 37.071
7/28/2012 27.13 33,035 8/28/2012 25.95 27.269 9/28/2012 25.22 41.436
7/29/2012 26.94 37,746 8/29/2012 26.73 29,427 9/29/2012 26.71 39.206
7/30/2012 27.52 33.280 8/30/2012 25.35 30,444 9/30/2012 27.17 41.014
7/31/2012 29.29 34.688 8/31/2012 26.39 35,875
Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color
MGD "Ib/dav" MGD "Ib/dav" MGD "IbmW
10/1/1012 26.98 41,627 11/1/2012 28.24 77,487 12/12012 25.93 47.576
10/2/2012 26.83 46,990 11/22012 29.08 76.639 11/2/2012 25.09 39.967
30/3/2012 25.08 42.879 11/3/2012 27.63 41.478 12/3/2012 25.24 37,890
30/4/2012 24.08 22.091 11/4/2012 27.61 43.060 12/4/2012 25.90 32,401
30/5/2012 24.00 23,619 11/5/2012 27.48 35,065 12/5/2012 26.31 36.425
10/6/2012 26.62 25,531 11/6/2012 27.92 34,695 12/6/2012 26.39 33,894
30/7/2012 28.93 35,709 11/7/2012 28.69 36.130 12/7/2012 26.02 31,465
30/8/2012 28.33 32.369 31/8/2012 25.65 45.137 12/8/2012 25.42 23,320
10/9/2012 28.34 33,562 11/9/2012 25.17 40.514 12/9/2012 26.26 21,901
10/10/2012 23.42 23,048 11/10/2012 25.01 32,122 12/10/2012 28.02 26.173
10/11/2012 28.85 32.001 11/11/2012 25.96 38,538 12/11/2012 26.63 24.430
10/12/2012 29.41 27,248 11/12/2012 27.44 39.362 12/12/2012 26.41 27.973
10/13/2012 27.59 28,993 11/13/2012 26.34 40.860 12/132012 26.38 31,021
10/14/2012 27.17 27,645 11/14/2012 26.40 44A76 12/14/2012 26.49 33,139
10/15/2012 29.23 28.278 11/15/2012 25.87 46,603 12/15/2012 27.85 36,234
10/16/2012 28.13 27,918 11/16/2012 24.70 41.818 12/16/2012 28.76 35.019
10/17/2012 27.36 32,402 11/172012 25.15 31.253 12/17/2012 28.29 28,313
10/18/2012 29.63 37.067 11/18/2012 25.53 42,158 12/18/2012 27.69 29,098
10/192012 27.92 19,094 11/19/2012 25.82 38,976 12/19/2012 26.23 33.689
10/202012 27.80 29,445 11/20/2012 25.26 57.512 22/20/2012 28.48 37.054
10/21/2012 27.57 34,260 1121/2012 24.90 27.620 1221/2012 28.26 25.926
10/22/2012 26.91 29.176 11/22/2012 24.91 28,669 12/22/2012 26.64 27,328
10/23/2012 27.73 31,452 1123/2012 25.58 38.827 12/23/2012 26.55 25,686
10/24/2012 27.59 23.930 11/24/2012 25.25 37,063 12/24/2012 27.85 22,995
10/25/2012 27.44 27.691 11/25/2012 25.04 36.755 1225/2012 27.34 22,346
10/26/2012 27.21 25,643 11/26/2012 25.26 36,024 12/26/2012 31.10 26,716
10/27/2012 27.07 23,931 11/27/2012 25.14 36.482 1227/2012 26.54 19,700
10/28/2012 27.27 25.017 11/28/2012 25.24 40,416 12/28/2012 27.07 21.222
10/29/2012 27.56 24,824 11/29/2012 23A6 40.305 12/29/2012 27.20 24.500
10/30/2012 28.19 30,328 11/30/2012 26.06 51,944 12/30/2012 26.31 25,892
10/31/2012 29.44 30,937 12/31/2012 26.55 27,014
Average Annual Flow: 26.77 MGD
Average Annual Color: 34,800 lbs/day

OF W ATF
\O� 9PG Michael F.F,asley,Governor
6) y William G.Ross Jr..Secretary
North Carolina Department of Environment and Natural Resources
—i
O Y CnlCen H.Sullins,Dirwor
Division Of Water Quality
February 12, 2008
Mr. David Green
Environmental Projects and Compliance Engineer
Blue Ridge Paper Products, P.O. Box 4000
Canton, North Carolina 28716
Subject: Tax Certification for Pollution Abatement Equipment
Real and Personal Property
NPDES Permit Number NC0000272
Tax Certification Number TCS-AV-103
Blue Ridge Paper Products
Haywood County
Dear Mr. Green:
As per your request, the staff of the Division of Water Quality have completed our review
of the Tax Certification Request for real and personal property that we received from your office
on October 26, 2007.
Please find attached a copy of Tax Certification Number TCS-AV-103 that has been
issued by this office to Blue Ridge Paper Products for the facility located in Haywood County.
A copy of this Certification is being sent to the Haywood County Tax Office along with a copy
of this letter. All item(s) listed on the application meet the established criteria to receive tax
certification. Please note that as part of this Tax Certification process the DENR staff did not
make any efforts to confirm either the cost of the item(s) certified or the year of acquisition.
If there is a need for any additional information or clarification, please do not hesitate to
contact either Tom S. Poe of our staff at ([e-mail]) or (919-7.15-6205) or me at
([e-mail]) or(919-715-6217).
Sincerely,
Mark L. Hubbard, P.E., Assistant Chief
Project Management Branch
Construction Grants and Loans Section
Attachment: North Carolina Division of Water Quality Tax Certification
cc: Ms.Judy Ballard, Haywood County Tax Assessor, 215 N. Main St, Waynesville,NC 28786
Construction Grants and Loans Section
SWPS Central Files
SWPS Regional Office Files
instruction Grants and Loans Section One
33 Mail Service Center Raleigh NC 27699-1633 North Carolina
one:919-733-6900/FAX:[phone]/Internet:www.nccgl.net

4.
r
l r
r� L
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
North Carolina Division of Water Quality
TAX CERTIFICATION NUMBER TCS-AV-103
In accordance with the provisions of the North Carolina Genera]Statutes G.S. 105-275.(8) this is to
certify that:
BLUE RIDGE PAPER PRODUCTS
175 MAIN STREET, PO BOX 4000
CANTON, NORTH CAROLINA 28716
HAYWOOD COUNTY
filed a request for tax certification for real and personal property covered under the
Division of Water Quality NPDES Permit Number NC0000272
Staff of the Division of Division of Water Qua]ity inspected these treatment units and/or equipment
on February 6,2008 and found based on the information supplied by the applicant that the facilities
and/or equipment listed on the attached application meet the following requirements for Tax
Certification:
f
1. The property has been, or will be, constructed or installed;
2. The property complies with, or if still under construction will comply with, the requirements of
the EMC;
3. The property is being effectively operated, or will when completed be required to operate, in S
accordance with the terms and conditions of approvals issued by the EMC; and
4. The property has, or when completed will have,as its primary rather than incidental purpose the
reduction of water pollution resulting from the discharge of sewage or waste.
Please note that as part of this Tax Certification process the DENR staff did not make any
efforts to confirm either the cost of the items certified or the year of their acquisition.
DATE TAX CERTIFICATION ISSUED: February 12,2008
Mark L. Hubbard, P.E., Assistant Chief
Project Management Branch
cc: Ms. Judy Ballard, Haywood County Tax Assessor, 215 N.Main St, Waynesville,NC 28786
Construction Grants and Loans Section
SWPS Central Files
SWPS Regional Office Files
06-01-07

�i11'wf
evergreen,* Canton Office i-rayU/
175 Main Street• Canton, NC 28716
packaging
JAG 27-12
Certified Mail
Return Receipt Requested
_ 7008 3230 0002 2591 1625
March 23, 2012
Mr. Tony Evans r�
North Carolina Division of Water Quality
Infrastructure Finance Section r l I !
1633 Mail Service Center J L j MAR 2 E 2012
Raleigh, NC 27699-1633 L
Subject: Evergreen Packaging—Canton Mill Facility r — _ - '-E
Request for Tax Certification
NPDES NC0000272,NCS000105
Dear Mr. Evans:
Thank you for your visit and tour of the Canton Mill Landfill Number 6 on 23 March 2012. We
appreciate you taking the time to review our tax certification request for the landfill leachate
system improvements associated with the construction of Area 6D South.
Per your request we have attached a summary of the three major project components, each
numbered for identification purposes, to supplement page 2 of the Division of Water Quality Tax
Certification &Exemption Application. The details of each are provided in the original
application for tax certification package submitted 15 August 2011.
Should you have any additional questions at this time please do not hesitate to ask.
Sincerely, t
James A. Grauque Paul Dickens
Waste Compliance&Landfill Supervisor Manager—Environmental Affairs
828-646-2028 Canton Mill—Waynesville Plant
iim.giaugueaa,eyerpack.com 828-646-6141
paul.dickens(a,everpack.com
file:6DS032312
Attachment
cc(letter only):
Jeff Menzel,NCDENR DWQ
Heidi Howard,Evergreen Packaging
Roger Edwards, Evergreen Packaging J /
\\everoack\w\EOHS\SHARE\Canton\Water\NPDES Permi[\Reeuest for Tax Certification ffQSh by C.jC;Slgli

..0 Canton Office
evergreen
1
packaging 5 Main slfeei- Canton, NC 28716
mssoo
n! NMM25-12
Certified Mail Return Receipt Requested
7008 3230 0002 2590 7444
13 March 2012
NPDES Permits Unit
Division of Water Quality r— _
1617 Mail Service Center I
Raleigh,NC 27699-1617 i
MAR 2 8 2012
Subject: 2012 NPDES General Permit Renewal Application
L
Evergreen Packaging --. --- �
Blue Ridge Paper Products, Inc. V v
Waynesville Plant --' ---
Attention: NPDES Permitting Official
Dear Sir or Madam:
This letter is to inform you of Blue Ridge Paper Products Inc.'s intent to renew the National
Pollution Discharge Elimination System (NPDES) General Permit NCG500151 for the Waynesville
Plant located in Haywood County, North Carolina. The current permit was issued on August 1,
2007 and will expire July 31,2012.
Prior to this submittal,we did not receive a notification letter that the permit was reaching
expiration and renewal was needed. We contacted both the Regional and State offices to confer
with NC Division of Water Quality(NC DWQ)staff. We were advised to submit this application with
the necessary documentation of changes to NC DWQ for renewal.
In addition to the renewal application,we have enclosed a check for the sum of$100.00 USD to be
applied to the facility's 2012 permit year. The NC DWQ staff advised that this payment was the only
payment needed for renewal and continued operations.
If you have any questions or comments please feel free to contact us at the numbers listed below.
Sincerely, =DENR-W
Nick McCrackenPaul Dickens
Water Compliance Coordi Manager,Environmental Affairs
828-64b-2874 828-646-6141
Nick [e-mail] Paul [e-mail]
ieverpackl cal EOHSiSHAREI Waynesville l Watery NPDES Permitl2012 Renewal

Attachments:
I- NPDES General Permit Renewal Application
II- Chemical Treatment Worksheet Form 101
III- MSDS for BSP Captor (Calcium thiosulfate) to accompany Attachment II
IV- Check for$100.00 USD for Permit Renewal/ 2012 Operating Year
Copy:
Mr. Chuck Cranford
DWQ Regional Supervisor,Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
cc: C File-2012 Waynesville Water
iieverpackicaiEONSiSILAREIWaynesvilleiWateriNPDES Permiti2012 Renewal

ATTACHMENT I
NPDES General Permit Renewal Application

I ..
FOR AGENCY USE ONLY
Dale Received
- Yeor Month Da
Division of Water Quality/Water Quality Section11
rYra��^aaaaaaaaaaaa� C.nscolc of Coma c
NCDENRNational Pollutant Discharge Elimination System Cl.W! Amolmt
Ywm GuvwnufMmrcw>-
FNraeonr�rtumNevu�bxna
NCG500000 Penn l Ass d to
NOTICE OF INTENT
National Pollutant Discharge Elimination System application for coverage under General Permit
NGG500000: Non-contact cooling water,boiler blowdown,cooling tower blowdown,condensate, and
similar point source discharges
(Please print or type)
1). Mailing address of owner/operator;
Company.Name Rlue 4idan Te er 'I�/Di�vcTS 'rne _ al,o Eyerarear `�aeku.cina
Owner.Name E,rerareew ri a-614;AA
Street Address S?�ZpDnt�ler Rv ik"ife SAi (obo
City hls State._ ZIP Code 38,II5
Telephone No. Aol kZl-5350 Fax:
`Address to which all permit correspondence will be mailed
2) Location of facility producing discharge:
Facility Name 'Eye '1 44'.`WZ 1'�wd"-Lc."dba �yer$ree�t�a��.�14f Tle-4
Facility Contact MIC.It��IceA�
Street Address iwt Howell Mill ?-aadt.
City ,l\InyrlPSytHt State 0f- ZIP Code 7-9'+TU
County alooc2
Teleph Fax: T2-V 4r- 22.
3) Physical location information:
Please provide a narrative description of how to get to the facility(use street names,state road numbers,
and distance and direction from aroadway intersection). UP c.AaoLp sic a J&F,+ a..r...li-
16�t�ecR• �
(A copy of a county map or USGS quad sheet with facility deafly located on the map is required to be submitted with this application)
4) This NPDES permit application applies to which of the following :
❑ New of Proposed
❑ Modification
/ Please describe the modification:
�J Renewal
Please specify existing permit number and original issue date: We-G75DO 151 i ssvea � 7�00't
5) Does this facility have any other NPDES permits?
❑0 No
N(Yes
If yes, list the permit numbers for all current NPDES permits for this facility: NCANJE-057ff
6) What is the nature of the business applying for thtspermitT Gx}rusieaCDAFcr.li -q
Page 1 of 4 04105

1
NCG500000 N.O.I,
7) Description of Discharge: /
a) Is the discharge directly to the receiving water? Ll Yes ❑ No
If no,submit a site map with the pathway to the potential receiving waters clearly marked.This
includes tracing the pathway of the storm sewer to the discharge point, if the storm sewer is the only
Viable means of discharge.
b) Number of discharge points(ditches, pipes,channels, etc.that convey wastewater from the
property): 00 eh bulfall
C) W at type of wastewat r is discharged? Indicate which discharge points, if more than one.
Zon-contact cooling water Discharge point(s)#: 001
❑ Boiler Blowdown Discharge point(s)#:
❑ Cooling Tower Blowdown Discharge point(s)#:
❑ Condensate Discharge point(s)#:
❑ Other Discharge point(s)M
(Please describe"Other")
d) Volume of discharge per each discharge point(in GPD):
y #1: tt FAO #2: 93: #4
e) Please describe the type of process(i.e., compressor,A/C unit,chiller, boiler,etc.)the wastewater is
i! being discharged from, per each separate discharge point(if applicable, use separate sheet):_
o a
8) Pleasecheck the type of chemical added to the wastewater for treatment, per each separate discharge
point(if applicable, use separate sheet):
❑ Blocides Name: Manuf.:
❑ Corrosion inhibitors Name: Manuf.:
❑ Chlorine Name: Manuf.:
❑ Algaecide Name: Manuf.:
Z Other Name: Manuf.:
❑ None
9) If any box in item(8)above,other than none,was checked,a completed Biocide 101 Form and
manufacturers'information on the additive is required to be submitted with the application for the
Division's review.
10) Is there any type of treatment being provided to the wastewater before discharge(i.e., retention ponds,
settling ponds, etc.)? ❑ Yes 2 No
If yes,please include design specifics (i.e., design volume,retention time, surface area, etc.)with
submittal package. Existing treatment facilities should be described in detail. Design criteria and
operational data(including calculations)should be provided to ensure that the facility can comply with the
requirements of the General Permit. The treatment shall be sufficient to meet the limits set by the
general permits.
Note: Construction of any wastewater treatment facilities requires submission of three(3)sets
of plans and specifications along with the application. Design of treatment facilities
must comply with the requirements of 15A NCAC 2H .0138. If construction applies to
this discharge,include the three sets of plans and specifications with this application.
Page 2 of 4 04105

I
NCG600000 N.O.I.
11) Discharge Frequency:
a) The discharge is: ❑ Continuous Intermittent ❑ Seasonalo
1) If the discharge is intermittent, describe when the discharge will occur: 60 CAAA tti
ii) If seasonal check the month(s)the discharge occurs: ❑ Jan. ❑ Feb. ❑ Mar. ❑ Apr.
❑ May ❑ Jun. ❑ Jul. ❑ Aug. ❑ Sept. ❑ Oct. ❑ Nov. ❑ Dec.
b) How many days per week is there a discharge? 'po &alAa?-
c) Please check the day dischar a occurs:
NJ Sat. Sun. 7Mon. �Tue. Rd Wed, f6Thu. dFN.
12) Pollutants:
Please list any known pollutants that are present in the discharge,per each separate discharge point(if
applicable,use separate sheet): Wovie-
13) Receiving waters:
a) What is the name of the body or bodies of water(creek,stream, river, lake,etc.)that the facility .
wastewater discharges end up in? If the site wastewater discharges to a separate storm sewer
system(4S),name the operator of the 4S (e.g. City of Raleigh). No CIAAAce
b) Stream Classification_ I
14) Alternatives to Direct Discharge:
Address the feasibility of implementing each'of the following non-discharge alternatives
a) Connection to a Municipal or Regional Sewer Collection System
b) Subsurface disposal(including nitrification field,infiltration gallery,injection wells,etc.)
c) Spray irrigation
The alternatives to discharge analysis should include boring logs and/or other information indicating that
a subsurface system is neither feasible nor practical as well as written confirmation indicating that
connection to a POTW is not an option. It should also include a present value of costs analysis as
outlined in the Division's"Guidance Forfhe Evaluation of Wastewater DisposalAltematives".
15) Additional Application Requirements:
For new or proposed discharges,the following information must be included in triplicate with this
application or it will be returned as incomplete.
a) 7.5 minute series USGS topographic map(or a photocopied portion thereof)with discharge location
clearly indicated.
b) Site map,if the discharge is not directly to a stream,the pathway to the receiving stream must be
clearly indicated. This includes tracing the pathway of a storm sewer to its discharge point.
c) If this application is being submitted by a consulting engineer(or engineering firm),include
documentation from the applicant showing that the engineer(Or firm)submitting the application has
been designated an authorized Representative of the applicant.
d) Final plans for the treatment system (if applicable). The plans must be signed and sealed by a North
Carolina registered Professional Engineer and stamped"Final Design-Not released for construction".
Page 3 of 04/05

NCG500000 N.O.I.
e) Final specifications for all major treatment components(if applicable). The specifications must be
signed and sealed by a North Carolina registered Professional Engineer and shall include a narrative
description of the treatment system to be constructed.
I certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information is true,complete,and accurate.
Printed ame of Person Signing: �aAr riswo�a
Title:
� !Z- 2olZ
(S' ature of Applicant) (Date Signed)
North Carolina General Statute 143.215.6 b(1) provides that:
Any person who knowingly makes any false statement, representation, or certification in any
application, record, report, plan or other document filed or required to be maintained under Article 21
or regulations of the Environmental Management Commission implementing that Article, or who
falsifies, tampers with or knowingly renders Inaccurate any recording or monitoring device or method
required to be operated or maintained under Article 21 or regulations of the Environmental
Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by
a fine not to exceed $2"60,.or by imprisonment not to exceed six months, or by both. (16 U.S.C.
Section 1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more
than 5 years,or both,for a similar offense.)
Notice of Intent must be accompanied by a check or money order for$100.00 made payable to:
NCDENR
Mail three(3)copies of the entire package to:
NPDES Permits Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Final Checklist
This application will be returned as Incomplete unless all of the following items have been
Included:
❑ Check for$100 made payable to NCDENR
113 copies of county map or USGS quad sheet with location of facility clearly marked on map
❑ 3 copies of this completed application and all supporting documents
❑ 3 sets of plans and specifications signed and sealed by a North Carolina P.E.
❑ Thorough responses to items 1-7 on this application
❑ Alternatives analysis including present value of costs for all alternatives
Note
The submission of this document does not guarantee the issuance of an NPDES permit
Page 4 of 4 04/05

I
ATTACHMENT II
Chemical Treatment Worksheet Form 101

BIOCIDE/CHEMICAL TREATMENT
WORKSHEET-FORM 101
The following calculations are to be performed on any biocidal products ultimately discharged to the surface waters of
North Carolina. This worksheet must be completed separately for each biocidal product in use.This worksheet is to be
returned with all appropriate data entered into the designated areas with calculations performed as indicated.
1. Facility Name: Blue Ridge Paper-Products Inc. dba Evergreen Packaging,Waynesville Plant
NPDES#NCG500151 Outfall#001
County: Haywood
Receiving Stream: Richland Creek 7Q10 19 (cfs)
(All above information supplied by the Division of Water Quality)
What is the Average Daily Discharge (A.D.D.) volume of the water handling systems to the receiving water body?
A.D.D.=0.0072 (in M.G.D.)
Please calculate the Instream Waste Concentration (IWC in percent) of this discharge using the data entered
above.
IWC = (A.D.D.) X 100 ( ) X 100 = 0.059%
(M10)(0.646) + (A.D.D) - ( )(0.646) + ( )
This value (IWC) represents the waste concentration to the receiving stream during low flow conditions.
II. What is the name of the whole product chemical treatment proposed for use in the discharge identified in Part I?
BSP Captor/Calcium Thiosulfate Solution (Dechlorination agent; decomposes to calcium sulfate upon
application)
Please list the active ingredients and percent composition:
Calcium Thiosulfate 30
What feed or dosage rate (D.R.) is used in this application?The units must be converted to maximum grams
of whole product used in a 24hr period.
D.R: 4709.76grams/24hr period
Please note,fluid ounces(a volume) must be converted to grams (a mass). The formula for this conversion is:
Grams of product= fluid oz. of product X 1 pal.water X 8.34 lbs. X specific gravity of product X 453.59p.
128 f1. oz. 1 gal.water 1 lb.

Facility Name: Blue Ridge Paper Products Inc. dba Evergreen Packaging, Waynesville Plant NPDES #:NCG500151
Estimate total volume of the water handling system between entry of biocidal product and NPDES discharge point.
On an attached sheet please provide justification for this estimate (system volume, average cycles per blowdown,
holding.lagoon size, etc.)
Volume= million gallons (N/A; product applied to non-contact cooling water at start of discharge
pipe)
What is the pH of the handling system prior to biocide addition? If unknown, enter N/A. N/A
What is the decay rate(D.K.) of the product? If unknown, assume no decay(D.K:0)and proceed to asterisk.
The degradation must be stated at pH level within 1/2 pH standard unit within handling system. Enter the half life
(Half Life is the time required for the initial product to degrade to half of its original concentration). Please provide
copies of the sources of this data.
H.L.= Days
The decay rate is equal to H�L X 0.69 = 0.00 =Decay Rate(D.K.)
Calculate degradation factor(D.F.). This is the first order loss coefficient.
* D.F. = A.D.D. D + 0.0072
+ .K.) _ ( ) =
(Volume) ( )
Calculate Steady State Discharge Concentration:
Dischg Conc. _ (D.F.)(Volume)(3785) _ ( )( ))(3785) = 172.82mg/I
Calculate concentration of biocide instream during low flow conditions.
(Receiving Stream Concentration)
(Dischq. Conc.) 1
x (IWC%) _ ) x
0 0 ( ) = 0.102mg/I
Receiving Stream Concentration
III. Calculate regulated limitation.
List all LC50 and EC50 data available for the whole product according to the following columns. (Note that units
should be in mg/1). Please provide copies of the sources of this data.
Organism Test Duration LC50/EC50 (mg/1)
No Aquatic Toxicity Data Available for
Calcium Thiosulfate or Thiosulfate
D.W.Q. Form 101 (62000) 2

Facility Name: Blue Ridge Paper Products Inc. dba Evergreen Packaging, Waynesville Plant NPDES#:NCG500151
Choose the lowest L•C50/EC50 listed above:
Enter the LC50/EC50:
If the half life (H.L.) is less than 4 days, perform the following calculation.
Regulated Limitation = 0.05 x LC50 ,= mg/1
If the half life (H.L.) is greater than or equal to 4 days or unknown, perform the following calculation.
Regulated Limitation = 0.01 . x LC50 .= mg/I
Choose the appropriate regulated limitation from the calculations immediately above and place in this blank:
N/A mg/liter
From Part II enter the receiving stream concentration:
0.102mg/Iiter
IV. Analysis.
If the receiving stream concentration is greater than the calculated regulated limitation,then this biocide is
unacceptable for use.
Person in Responsible Charge
Paul Dickens, Manager Environmental Affairs
Name (Print)
Signature Date
Person Completing This Worksheet(If different from above)
Nick McCracken, Water Compliance Coordinator
Name (Print)
Signature Date
Please submit to: Division of Water Quality
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, NC 27699-1621
Attn: Todd Christenson
D.W.Q. Form 101 (62000) 3

Facility Name: Blue Ridge Paper Products Inc. dba Evergreen Packaging, Waynesville Plant NPDES#:NCG500151
Supplemental Metals Analysis
If copper, zinc, or chromium are present in the proposed biocidal compound, complete this worksheet. A separate form
must be used for each metal and/or metal compound present in the biocide. List the metal, its chemical formula, molecular
weight (MW), formula weight (FW), and the concentration of the metal compound in the biocide (MCC). Complete a
separate form for every metal present in the biocide.
Metal Chemical Formula Molecular Weight of Metal Formula Weight Concentration in Biocide
EXAMPLE
Copper CuSO4 5H2O 63.546 g/mole 249.680 g/mole 0.2%
Dosage rate of Biocide(DR)(from page 1):
DR = grams/day
Average Daily Discharge(ADD)(from page 1):
ADD = million gallons/day
Discharge Concentration (DC)of Biocide:
DC = DR ( grams/day) rams/million gallons
ADD — ( million gallons/day) .= g g
Convert DC to micrograms/liter(ppb):
DC(pgA) = DC (grams/million gal) x 1 x 106 ug/q
3.785 x 106 liters/million gal. pg
Calculate the fraction of metal in the metal-containing compound(MF):
MF = MW _ ( grams/mole)
FW — ( grams/mole) _
Calculate the fraction of metal In the biocidal compound (BF):
0
BF = MF x 100 = x 100 /� _
Calculate the concentration of metal in the discharge(M):
M = DC x BF = pgA x = pg/I
Calculate the instream metal concentration (IMC)at low-flow conditions:
IMC = M x IWC %
100 _ NgA x 100 NgA
Regulated limitation of metal (from below): pg/I
NC General Statutes 15A NCAC 213.0211 define:
Copper-7 pgA water quality action level' Zinc-50 pg/I water quality action level*
Chromium-50 pgA water quality standard
(•Values which exceed action levels must be addressed directly by aquatic toxicity testing.)
D.W.Q. Form 101 (&2000) 4

ATTACHMENT III
MSW for BSP Captor (Calcium thiosulfate)

rr
MSDS SAFETY SHEET
BSP CAPTOR
Page I of 4
MATERIAL SAFETY DATA SHEET
Best Sulfur Products
A division of Ag Formulators Inc.
5427 E. Central Ave.
Fresno, CA 93725
For Emergency Information call Chemtree(800) 424-9300
For Technical Information call(800) 800-4854
Effective date: 05-16-05
Supersedes: 02-25-03
I. IDENTIFICATION
Product: BSP CAPTOR®
Chemical Name: Calcium Thiosulfate Solution
Formula: CaS203
Chemical Family: Inorganic Salt
H. COMPOSITION
Chemical CAS# Concentration Regulation
Calcium Thiosulfate L0124-41-1 30%w7v No
A solution of CaS203 in water
III. HAZARDOUS IDENTIFICATION
CERCLA Ratings (0-3): Health=0 Fire=0 Reactivity=0 Persistence=0
NFPA Ratings (0-4): Health=0 Fire=0 Reactivity=0
NSF International Standard 60 listed for use in drinking water. .
IV. EMERGENCY AND FIRST AID PROCEDURES
POTENTIAL SHORT-TERM HEALTH EFFECTS:
SKIN CONTACT: Immediately flush with large quantities of water,remove contaminated clothing
and shoes and wash product from skin.
EYE CONTACT: Immediately flush eyes with clean water, lifting upper and lower lids, for at lest
15-20 minutes. Obtain medical attention if irritation occurs or persist.
INGESTION: If vomiting occurs,keep head lower than hips to help prevent aspiration. Treat
symptomatically and supportively. Get medical attention if needed. .
INHALATION: Remove victim from contaminated area. If breathing is labored, administer
oxygen. If breathing has ceased, clear the airway and begin mouth to mouth.
LONG-TERM HEALTH EFFECTS: No information on long-term effects is available.

MSDS SAFETY SHEET
BSP CAPTOR
Page 2 of 4
V. FIRE AND EXPLOSION HAZARD
Negligible hazard when exposed to heat or flame
EXTINGUISHING MEDIA: Extinguish using agent suitable for type of surrounding fire.
FIRE FIGHTING: Move container from fire area if possible. Avoid breathing vapors. Keep upwind.
Use agents suitable for type of surrounding fire. Avoid breathing hazardous vapors. Keep upwind.
HAZARDOUS COMBUSTION PRODUCTS: Thermal decomposition products may include toxic
oxides of sulfur.
FLASH POINT : n/d
FLAMMABLE LIMITS IN AIR: n/d
AUTO IGNITION TEMPERATURE(degrees C (F)': n/d
EXTINGUISHING MEDIA: COZ,dry chemical foam,water spray
VI. ACCIDENTAL RELEASE MEASURES
Absorb small spills with sand, earth, sweeping compound or other inert absorbent. Dispose of in
accordance with all government regulations. Large spills should be diked to prevent entry of large
quantities of product into sewers or drains. Recover as much of solution as possible. On large spills,
land application could be possible as long as application rates are not exceeded,please check with the
local Ag Commissioner for permission. Dispose of in accordance with applicable local, county,state,
and federal regulations.
VH. HANDLING AND STORAGE
Do not heat drums with any welding equipment as explosion may occur. Avoid breathing gas. Do not
get in eyes, on skin, or on clothing. Store in a cool, dry place in properly designed vessels.
VHI. EXPOURE CONTROLS/PERSONAL PROTECTIONS
No occupational exposure limits have been established by OSHA,ACGIH, or NIOSH.
PROTECTIVE EQUIPMENT SHOULD BE USED DURING THE FOLLOWING PROCEDURES:
• Manufacture or formulation of this product
• Repair and maintenance of contaminated equipment.
• Clean up of leaks and spills
• Any other activity that may result in hazardous exposures.

r I
MSDS SAFETY SHEET
BSP CAPTOR
Page 3 of 4
RESPIRATORY PROTECTION:
None generally required. If conditions exist where excessive mist might be generated, a mist respirator
is recommended.
In case of emergency conditions such as.fire, high heat, and or contact with acids, use a NIOSH/MSHA
approved full-face respirator with S02 gas cartridge. Use positive pressure self-contained breathing
apparatus for emergency or other conditions requiring a higher level of protection.
CLOTHING: Rubber gloves and apron should be used for prolonged or repeated contact. Safety
glasses or chemical goggles are recommended to avoid eye contact. Do not wear contact lenses.
IX. PHYSICAL AND CHEMICAL PROPERTIES
DESCRIPTION: Clear colorless solution
Molecular Weight: 152.20
Water Solubility: Completely soluble in water
Molecular formula for active ingredient: CaS203
Solvent Solubility: dearly insoluble in alcohol
Specific Gravity: 1.245
pH: 6.5—7.5
Vapor pressure: (mm Hg) N/D
X. STABILITY AND REACTIVITY
Stable under normal conditions and pressures.
CONDITIONS TO AVOID: Avoid contact with acids. Sulfur dioxide could be released if
mixed with acids.
INCOMPATIBILITIES: Reacts with acid to form sulfur dioxide. Corrosive to brass and
copper.
XI. TOXICOLOGICAL INFORMATION:
LD 50 (rat): Anhydrous CaS203 : 374 mg/kg intravenous
LD 50 (rat): 573 mg/kg intraperitoneal
LD 50 (mouse): rat LD 50; 115 mg/kg intraperitoneal
CARCINOGEN STATUS: None
ACUTE TOXICITY LEVEL: Insufficient data.
TARGET EFFECTS: No data available.
SHIN CONTACT: May be irritating
EYE CONTACT: May be irritating.
INGESTION: Thiosulfate salts are poorly absorbed from the alimentary tract.
Ingestion may result in a cathartic effect.
CHRONIC EXPOSURE: No data available for any type of exposure.

MSDS SAFETY SHEET
BSP CAPTOR
Page 4 of 4
XIL DISPOSAL CONSIDERATIONS
Contaminated cleanup materials may be hazardous. Refer to Sections IV and Vul of this MSDS
sheet before handling. All contaminated materials should be placed in disposable containers and
buried in an approved dumping area. Follow all local rules governing waste disposal in your area.
XIH. TRANSPORTATION INFORMATION
Classification: NA
D.O.T. Proper Shipping Name: Not hazardous by D.O.T. Regulations
Other Requirements: NA
XIV. REGULATORY INFORMATION
REGULATORY INFORMATION
SARA TITLE III SECTION 313: NOT LISTED
RCRA HAZARDOUS WASTE:: NOT LISTED
CA Prop. 65: NOT LISTED
XV. OTHER INFORMATION
The information herein is given in good faith but no warranty, expressed or implied, is made.

ATTACHMENT IV
NPDES General Permit Renewal Fee

ENVIRONMENTNORTH CAROLINA DEPARTMENT OF
AND NATURAL RESOURCES
IIIIIIII III IIIIIIIII I IIIIIIIIIIIIIIillllllllllllllllllllll
2 0 1 2 P R 0 0 2 2 0 7
INVOICE
Annual Permit Fee
This annual fee is required by the North Carolina Administrative Code. It covers the administrative costs associated
with your permit. It is required of any person holding a permit for any time during the annual fee period, regardless of
the facility's operating status. Failure to pay the fee by the due date will subject the permit to revocation. Operating
without a valid permit is a violation and is subject to a $10,000 per day fine. If the permit is revoked and you later
decide a permit is needed, you must reapply,with the understanding the permit request may be denied due to changes
in environmental, regulatory, or modeling conditions.
Permit Number: NGG500151 Annual Fee Period: 2012-04-01 to 2013-03-31
Haywood County
Blue Ridge Paper Products Invoice Date: 03/06/12
Due Date: 04/05/12
Paul S. Dickens Annual Fee: $100.00
Blue Ridge Paper Products Inc
PO Box 4000
Canton, NC 28716
Notes:
1. A$25.00 processing fee will be charged for returned checks in accordance with the North Carolina General Statute 25-3-512
2. Non-Payment of this fee by the payment due date will initiate the permit revocation process. RECEIVED
3. Remit payment to: -
NCDENR -Division of Water Quality MAR 13 202
1617 Mail Service Center
Raleigh, NC 27699-1617 lNERGREEN PACKAGING
4. Should you have any questions regarding this invoice, please contact the Annual Administering&HIDWSnce Fee
Coordinator at 919-807-6321.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
(Return This Portion With Check)
ANNUAL PERMIT INVOICE III I 11111111 111111111111111
2 0 1 2 P R 0 0 2 2 0 7
Permit Number: NCG500151 Annual Fee Period: 2012-04-01 to 2013-03-31
Haywood County
Blue Ridge Paper Products Invoice Date: 03/06/12
Due Date: 04/05/12
Annual Fee: $100.00
Paul S. Dickens
Blue Ridge Paper Products Inc Check Number:
PO Box 4000
Canton,NC 28716

a
Blue Fudge Paper P14ducts Inc . dbaORvergreen PaWaging
PAYMENT SUMMARY Pagel
A VENDOR NO: 84906 PHONE NO: 1888) 883 0331 �;:
V VOUCHER NO: 3812006417 VOUCHER DATE: 03/08/2012
LOCATION INVOICE DATE DOCUMENT GROSS DISOUNT NET
AMOUNT AMOUNT AMOUNT
120 0 /O6/12CKR 03/07/2012 140 031957 100.00 0.00 100.00
-------- -------------- ----------- ----------- -------------- ---------- ------------
CHECK $100.00
AMOUNT
0
R
REMOVE DOCUMENT ALONG THIS PERFORATION
%evergreen' AP Shared Service Center CHECK DATE CHECK NUMBER g
oa •w••
P.O. Box 1549 03/08/2012 3812006417 g
Canton, NC 28716
y PAY: ONE HUNDRED DOLLARS AND 00 $*"****`w*`*100.00*
a
CENTS Blue Ridge Paper Products Inc.
BB To _ NORTH CAROLINA DEPT OF ENVIRON
THE & NAT RES DIV WATER QUALITY
ORDER 1617 MAIL SERVICE CENTER a•,e or a�k• - s
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Blue Ridge Paper Products Inc. - Canton Mill JAN 2 6 2012
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January 25, 2012 NMM#06-12 ." WATER OUALITv SECTION
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CERTIFIED MAIL
Return Receipt Requested """ "^" '^ - �•��-
7007 3020 0001 6119 7639
Chuck Cranford
Regional Supervisor
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Subject: NPDES NC0000272
2011 Annual Average Color
Evergreen Packaging
Canton, NC
Dear Mr. Cranford:
This letter and attachment document the 2011 average annual color discharge from Blue Ridge
Paper Products Canton Mill. Average secondary effluent color discharge for the period 1 Jan
2011 through 31 Dec 2011 was 35,254 Ibs/day and is compliant with the permit.
The attachment provides daily wastewater discharge flows and secondary effluent true color for
the mill during 2011.
Sincerely,
e 5��-
Nick McCracken Paul Dickens
Water Compliance Coordinator Manager,Environmental Affairs
Evergreen Packaging—Canton Mill Evergreen Packaging—Canton Mill
828-646-2874 828-646-6141
Attachment: Daily flow and color discharge for 2011
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Ileverpack1ca1E0HS0HAREI Water FileslNick's Water ReSMQIAnnual Reportsl2011 Annual Color Letter.doc

VFV
Canton Mill 2011 Average Annual Color and Wastewater Flow
Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color
MGD "Ib/day" MGD "Ib/day" MGD "Ib/day'
1/1/2011 26.77 48,448 2/1/2011 25.86 56,290 3/1/2011 24.60 32,416
1/2/2011 25.15 37,965 2/212011 26.16 42,544 3/2/2011 24.20 34,916
1/3/2011 24.50 38,823 2/3/2011 24.80 34.748 3/3/2011 23.48 31,723
1/4/2011 24.07 27,703 2/4/2011 26.05 32,371 3/4/2011 23.28 30,094
1/5/2011 23.73 31,665 2/5/2011 25.29 25,099 3/5/2011 24.25 27,910
1/6/2011 23.85 35,804 2/6/2011 24.37 25.406 3/6/201.1 26.88 35.869
1/7/2011 25.17 35,266 277/2011 25.17 23,091 3/7/2011 24.06 42,941
1/8/2011 24.27 29,957 218/2011 24.88 31,125 3/8/2011 24.00 49,640
1/9/2011 24.38 32,939 2/9/2011 24.78 41,126 3/9/2011 25.40 47,875
1/10/2011 23.47 35,037 2/10/2011 25.36 38,916 3/10/2011 26.00 46,404
1/11/2011 24.69 47,772 2/11/2011 25.14 29,144 3/11/2011 24.75 36,742
1/12/2011 23.91 37,888 2/12/2011 23.70 26,684 3/1212011 24.25 35,393
1/13/2011 23.39 37,844 2/13/2011 24.35 34,117 3/13/2011 25.15 38,594
1/14/2011 25.19 40,126 2/14/2011 25.78 34,831 3/14/2011 25.37 23,909
1/15/2011 26.00 39,465 2/15/2011 26.99 34,031 3/15/2011 25.91 30,901
1/16/2011 25.34 32,123 2/16/2011 24.95 44,322 3/16/2011 23.99 28,611
1/17/2011 27.21 34,494 2/17/2011 24.45 38,336 3/17/2011 24.68 23,876
1/18/2011 27.27 34,115 2/18/2011 23.21 33,875 3/18/2011 24.58 31,570
1/19/2011 25.14 33,547 2/19/2011 27.15 34,418 3/19/2011 24.03 34,471
1/20/2011 25.60 33,947 2/20/2011 25.00 35,445 3/20/2011 23.79 25,396
1/21/2011 25.26 36,024 2/21/2011 24.52 33,742 3/21/2011 23.69 25,882
1/22/2011 25.23 37,665 2/22/2011 24.27 36,232 3/22/2011 24.20 37,944
1/23/2011 25.97 33,355 2/23/2011 25.12 33,311 3/23/2011 25.12 34,358
1/24/2011 25.83 30,159 2/24/2011 24.75 32,201 3/24/2011 24.93 28,277
1/25/2011 25.15 27,687 2/25/2011 24.50 24.315 3/25/2011 24.62 44,967
1/26/2011 25.56 31,549 2/26/2011 23.93 34,527 3/26/2011 24.93 50,316
1/27/2011 24.15 29,809 2/27/2011 26.11 36.583 3/27/2011 23.73 49,873
1/28/2011 23.89 36,063 2/28/2011 26.44 33,958 3/28/2011 25.88 50,506
1/29/2011 23.13 47,647 3/29/2011 27.98 55,538
1/30/2011 22.68 43,694 3/30/2011 26.35 54,500
1/31/2011 23.62 47,081 3/31/2011 24.15 45,116

VpV
Canton Mill 2011 Average Annual Color and Wastewater Flow
Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color
MGD °Ib/day° MGD °Ib/day° MGD 'Ib/day°
4/1/2011 23.02 51,068 5/1/2011 24.43 34,229 6/1/2011 26.42 32.390
4/2/2011 23.48 41,123 5/2/2011 21.85 36.810 6/2/2011 24.54 34,997
4/3/2011 23.54 31,412 5/3/2011 3.29 4,088 6/3/2011 24.51 28,822
4/4/2011 25.64 37,849 5/4/2011 1.95 2.163 6/4/2011 24.91 36,564
4/5/2011 26.46 41,708 5/5/2011 1.10 1,208 6/5/2011 24.98 38,958
4/6/2011 25.52 45,547 5/6/2011 12.46 12,886 6/6/2011 26.59 39,030
4/7/2011 27.00 50,891 V712011 21.53 15.442 6/7/2011 25.85 35.141
4/8/2011 26.05 39,541 5/8/2011 24.27 20,848 6/8/2011 25.12 34,568
4/9/2011 25.86 37,958 5/9/2011 23.55 19,248 6/9/2011 25.95 43,501
4/10/2011 26.07 39,136 5/10/2011 23.84 19,683 6/10/2011 25.64 42,340
4/11/2011 26.09 32,203 5111/2011 25.00 21,476 6/11/2011 25.11 38.742
4/1212011 28.14 30,979 5/12/2011 24.22 29,491 6/12/2011 25.66 41,303
4/13/2011 26.28 29,369 5/13/2011 23.80 41,485 6/13/2011 25.52 41,290
4/14/2011 26.04 27,581 5/14/2011 25.40 41,096 6/14/2011 25.53 28,744
4/15/2011 26.09 39,166 5/15/2011 24.48 35,320 6/15/2011 27.00 40,307
4/16/2011 26.87 31,373 5/16/2011 24.83 30,441 6/16/2011 25.77 34.173
4/17/2011 24.98 22,708 5/17/2011 24.40 28,286 6/17/2011
24. ,53 36006
4/18/2011 25.90 29,809 5/18/2011 23.57 25.751
869
4/19/2011 25.81 29,705 5/19/2011 24.55 27,641 6/19/2011 25.03 39,245
4/20/2011 27.49 32,327 5/20/2011 26.90 39,036 6/20/2011 24.70 31,106
4/21/2011 27.49 29,346 5/21/2011 27.28 59,609 6/21/2011 26.47 43,269
4/22/2011 26.23 27,564 5/22/2011 27.71 51,767 6/22/2011 25.96 39,188
4/23/2011 26.30 36,630 5/23/2011 25.38 35,560 6/23/2011 25.04 36,128
4/24/2011 26.06 46,728 5/24/2011 25.95 37.008 6/24/2011 23.94 27,952
4/25/2011 25.05 26,324 5/25/2011 26.07 33,048 6/25/2011 23.90 28,504
4/26/2011 26.07 27,613 5/26/2011 25.51 32,764 6/26/2011 24.28 26.122
4/27/2011 24.34 22,939 5/27/2011 26.16 29,017 6/27/2011 23.55 24,944
4/28/2011 24.73 19,800 5/28/2011 25.92 29,616 6/28/2011 25.96 36,806
4/29/2011 24.24 23,249 5/29/2011 26.63 28,206 6/29/2011 23.54 26,700
4/30/2011 23.79 25,992 5/30/2011 27.33 25,984 6/30/2011 24.04 38,495
5/31/2011 28.01 42,516

PPFP�
Canton Mill 2011 Average Annual Color and Wastewater Flow
Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color
MGD °Ib/day" MGD 'Ib/day° MGD 'Ib/day
7/1/2011 24.48 37,770 811/201 226.70 38,301 9/1/2011 24.39 31,936
7/2/2011 25.53 28,318 8/2/2011 25.51 22,765 9/2/2011 25.10 35.168
7/3/2011 26.59 27,498 8/3/2011 24.48 18,987 9/3/2011 24.81 39,728
7/4/2011 25.57 31,775 8/4/2011 25.77 23,856 9/4/2011 24.36 35.553
7/5/2011 26.71 28,291 8/5/2011 24.19 31,270 9/5/2011 27.05 35,870
7l6/2011 28.07 24,113 8/6/2011 26.41 40,968 9/6/2011 27.06 30,693
7/7/2011 26.56 36,328 8/7/2011 25.97 29,240 917/2011 26.85 33,141
7/8/2011 27.52 52.559 8/8/2011 27.38 35,622 9/8/2011 27.32 29.620
7/9/2011 25.18 44,940 8/9/2011 26.59 27,942 9/9/2011 26.00 31,442
7/10/2011 25.09 34,945 8/10/2011 27.15 27.851 9/10/2011 25.06 33,858
7/11/2011 25.34 32,757 8/11/2011 26.19 22,716 9/11/2011 24.94 33.280
7/12/2011 24.73 25,369 8/12/2011 27.72 19,188 9/12/2011 25.51 30,636
7/13/2011 24.28 25,312 8/13/2011 26.16 20,945 9/13/2011 25.70 20.791
7/14/2011 26.37 42,446 8/14/2011 26.81 19,900 9/14/2011 25.12 27,445
7/15/2011 25.94 41,970 8/15/2011 26.85 24,184 9/15/2011 26.07 39,136
7/16/2011 25.32 31,464 8/16/2011 26.80 25,480 9/16/2011 26.07 35,658
7/17/2011 24.58 30,750 8/17/2011 25.77 20.632 9/17/2011 26.92 35,698
7/18/2011 25.70 29,579 8/18/2011 25.05 23,190 9/18/2011 26.71 32,746
7/19/2011 25.64 27,371 8/19/2011 26.42 20,712 9/19/2011 25.24 30,944
7/20/2011 25.18 30,660 8/20/2011 26.67 25,134 9/20/2011 26.72 30,307
7/21/2011 25.14 36,901 8/21/2011 27.47 28,179 9/21/2011 27.05 36,547
7/22/2011 25.02 16,902 8/22/2011 26.00 28,840 9/22/2011 25.80 30,985
7/23/2011 24.70 18,334 8/23/2011 25.35 28,542 9/23/2011 28.14 30.040
7/24/2011 24.80 33,714 8/24/2011 25.21 34.691 9/24/2011 25.82 26,702
7/25/2011 25.37 24,756 8/25/2011 26.77 36,838 9/25/2011 24.72 24,946
7/26/2011 25.18 32,550 8/26/2011 27.27 42,302 9/26/2011 24.84 26,724
7/27/2011 25.12 37,082 8/27/2011 25.47 36,324 9/27/2011 25.20 34,468
7/28/2011 23.91 32,703 8/28/2011 25.26 32,022 9/28/2011 26.06 41,729
7/29/2011 24.19 31,876 8/29/2011 26.69 30,941 9/29/2011 26.82 43,394
7/30/2011 25.51 39,147 8/30/2011 25.44 30,765 9/30/2011 26.77 35,945
7/31/2011 26.66 38,021 8/31/2011 25.63 39,758

ppppr,
Canton Mill 2011 Average Annual Color and Wastewater Flow
Date WTP Flow Sec Ell Color Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color
MGD 'Ib/day° MGD 'Ib/day' MGD 'Ib/day'
10/1/2011 26.02 36A23 11/1/2011 26.62 30,193 12/1/2011 26.01 32,755
10/2/2011 24.80 40,125 11/2/2011 26.72 38,552 12/2/2011 25.40 34,106
10/3/2011 26.08 46.329 11/3/2011 27.40 38,848 12/3/2011 26.19 37,351
10/4/2011 25.52 43,419 11/4/2011 27.44 28,835 12/4/2011 24.34 37,960
10/5/2011 26.92 45,352 11/5/2011 26.39 41.157 12/5/2011 24.91 60,663
10/6/2011 26.76 41,226 11/6/2011 26.18 35,371 12/6/2011 27.05 94,300
1017/2011 25.87 40,562 1 V7/2011 25.93 38.277 12r7/2011 28.63 95,748
10/8/2011 26.48 36.439 11/8/2011 25.91 35,871 12/8/2011 25.85 67,264
10/9/2011 28.11 60,250 11/9/2011 27.68 43.400 12/9/2011 25.46 52,235
10/10/2011 26.92 57,924 11/10/2011 27.93 52,877 12/10/2011 25.34 38,463
10/11/2011 27.89 62,337 11/11/2011 26.97 39.588 12/11/2011 26.12 44,004
10/12/2011 27.74 53,211 11/12/2011 26.28 34,411 12/12/2011 25.97 43,535
10/13/2011 27.25 42,726 11/13/2011 26.30 40,140 12/13/2011 26.01 37,311
10/14/2011 27.61 37,073 11/14/2011 25.74 31,557 12/14/2011 25.00 37,322
10/15/2011 24.58 47,764 11/15/2011 25.62 45,298 12/15/2011 26.74 48.617
10/16/2011 25.09 41,222 11/16/2011 31.16 59,251 12/16/2011 27.38 39,733
10/17/2011 28.12 35,882 11/17/2011 28.55 58,336 12/17/2011 25.62 40,170
10/18/2011 27.58 40,943 11/18/2011 25.17 39,045 12/18/2011 26.33 39,087
10/19/2011 29.72 45,111 11/19/2011 26.64 36,881 12/19/2011 26.17 35,576
10/20/2011 28.09 45,917 11/20/2011 26.07 38,701 12/20/2011 26.17 24.881
10/21/2011 27.19 37,189 11/21/2011 26.84 41,635 12/21/2011 26.72 34.318
10/22/2011 25.84 39,653 11/22/2011 26.87 36,304 12/22/2011 28.54 32.847
10/23/2011 25.94 37,859 11/23/2011 27.34 36,711 12/23/2011 28.91 31,103
10/24/2011 26.12 38,122 11/24/2011 26.70 18,482 12/24/2011 27.58 33,813
10/25/2011 26.41 30,396 11/25/2011 25.74 42,290 12/25/2011 27.37 34,925
10/26/2011 27.24 19,765 11/26/2011 26.25 42,471 12/26/2011 26.69 36,506
10/27/2011 27.94 23.069 11/27/2011 25.93 35,682 12/27/2011 27.51 43,363
10/28/2011 27.75 27,772 11/28/2011 29.66 33,147 12/28/2011 27.54 39,506
10/29/2011 27.02 27.492 11/29/2011 27.40 31.535 12/29/2011 26.06 41,077
10/30/2011 26.02 36,891 11/30/2011 25.74 38,641 12/30/2011 27.13 38,917
10/31/2011 27.23 32,475 12/31/2011 27.69 47,111
Average Annual Flow: 25.48 MGD
Average Annual Color: 35,254 Ibs/day

®�AA
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E.Skvada, III
Governor Secretary
October 15, 2014
Mr. Dane Griswold
Blue Ridge Paper Products Inc.
P.O. Box 4000
Canton NC 28716
Subject: Incident Closure
NOD-2014-PC-0105
Canton Mill
Permit No: NC0000272
Haywood County
Dear Mr. Griswold:
The Division of Water Resources has received the status report dated September 30, 2014, from
Blue Ridge Paper Products Inc. related to the Notice of Deficiency NOD-2014-PC-0105.
The written response and the change in sampling protocol have satisfactorily resolved the
deficiency noted in the subject NOD.
Your attention and cooperation is greatly appreciated. Should you have any questions regarding
this matter or other water quality issues or concerns,please contact me at(828) 296-4500 or
[e-mail].
Sincerely,
Jeff Menzel
Environmental Specialist
Water Quality Regional Operations
Asheville Regional Office
cc: John J Pryately, ORC
Chet Chiles/Manager: Environment, Health& Safety
Nick McCracken EHS&S Water Supervisor
MSC 1617-Central Files-Basement
Asheville Files
Water Quality Regional Operations—Asheville Regional Office
2090 U.S.Highway 70,Swannanoa,North Carolina 28778
Phone:[phone]\FAX:[phone]
Internet:http://portal.nodenr.org/webtwq
An Equal Opportunity 1 Afirmatve Acton Employer
GAWR\WQ\Hayvood\WastewateNndustrial\Blue Ridge Paper 002MNOD-2014-PC-0105 closure.doc

I L
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvada, III
Governor Director Secretary
January 13, 2014
Evergreen Packaging-Canton Office
175 Main Street
Canton, North Carolina 28716
Attn: Chet C. Chiles
Subject: Request to Rescind NOV-2013-LV-0677
NPDES Permit: NC0000272
Dear Mr. Chiles,
The Division of Water Resources received your letter requesting rescission of the subject NOV on
December 16, 2013.Your letter provided further clarity and detail regarding the probable cause of the
violation and the efforts undertaken by Evergreen and the Town of Canton to address the issues.We
appreciate the time and effort involved in meeting on November 141h and in preparing the subject letter.
After careful review and consideration of this information and the compliance record, the Division has
determined that the NOV was warranted and therefore has elected not to rescind the NOV.
The compliance history indicates four previous limit violations for fecal coliform where the Division
chose not to issue NOVs based on specific circumstances surrounding the violations.The Division has
considered the efforts undertaken by Evergreen and the Town of Canton, precipitation events,
construction efforts to remediate the cause of the violations, etc., and has chosen not to assess civil
penalties to date.
The Division appreciates your efforts and tenacity in addressing the fecal coliform exceedances and
ensuring compliance with the subject permit.
Please feel free to contact me at 828-296-4680 if you have any further questions regarding this matter.
Sincerel.
G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations
Asheville Regional Office
Water Quality Regional Operations-Asheville Regional Office
2090 U.S.Highway 70,Swannanoa,N.C. 28778
Phone[phone] FAX[phone]
http://portal..ncdenr.org nbhvgtwq
An Equal Opportunity/Affirmative Action Employer

Canton Office aMal of Waterlr Dp�
evergreen-.I* 175 Main Street• Canton, NC 28 16
packaging JAN 21 2014
January 15, 2014 WeterQ�relRgions
Asheville Regional Office
CERTIFIED MAIL
Return Receipt Requested
7099 3220 00027 0371 4378
Mrs. Laura Herbert
Land Quality Supervisor, Asheville Regional Office
North Carolina Department of Energy, Minerals
& Land Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill,Canton,Haywood County,North Carolina
Stormwater Release 5-day Submittal 1/11/2014
NPDES Permit: NCS000105
Dear Mrs. Herbert:
This is the 5-day written submission for the storm water release reported to NCDENR on
January 11, 2014. Due to freezing temperatures during the week of January 6, 2014, the mill
experienced a power outage and a subsequent unplanned cold mill shutdown. Upon start up, a
leak was discovered in the piping that feeds the North Oxidizer Tank. Black liquor material
sprayed from the piping striking an exterior wall attached to the outside of the containment.
Black liquor is primarily comprised of lignin, sodium hydroxide, water, and residual kraft pulp.
Inadvertently,during the leak some of the material ran down the wall and a small amount of
material pooled at the base of the containment. Upon contacting the ground, the material quickly
froze, thus making it difficult to estimate a quantity. Upon discovery,the leak was diverted
away from the wall and into the secondary containment.
Additionally, Evergreen personnel began preparations to resolve the active leak, sand bag the
affected area, and initiate cleanup of the spilled material. Unfortunately, prior to completing the
repairs and associated cleanup, it rained. Rainfall flowed over the spilled material and small
amount of the material entered the storm water drain. Once it was determined the dilute material
was entering the storm water drain, Evergreen personnel mobilized an on-site contractor to
vacuum up the residual material. During the rainfall event, flows within the Pigeon River were
in excess of 625 MGD; therefore, Evergreen is confident that material in the storm water drain
was further diluted and thus had a negligible impact on the river.
IleverpacklcMEOHSISHAROWater FilesWick's Water ResIDWO

NCDEMLR Page 2
A call was placed to NCDENR at approximately 3:18 PM on January 11, 2014. An additional
voicemail was left on Land Quality Supervisor Laura Herbert's phone during this time. A follow
up call from Janet Cantwell, Asheville Regional Office, was received that same day at
approximately 4:11 PM to discuss the release.
If you have any questions or comments, please feel free to contact me at your earliest
convenience.
Sincerely,
Nick McCracken
EHS&S Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCracken(a,everpack.com
cc:
Mr. Landon Davidson
Water Quality Supervisor, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
C. File—Water Notebook
Internal distribution -
D. Griswold
M. Ferguson
C. Chiles

evergr°een,. Canton Office
packaging
August 15, 2011 Certified Mail
Return Receipt Requested
7007 3020 0001 6119 7363
North Carolina Division of Water Quality
Construction Grants and Loans Section
1633 Mail Service Center
Raleigh, NC 27699-1633
Subject: Evergreen Packaging—Canton Mill Facility
Request for Tax Certification
NPDES NC0000272, NCS000105
The Evergreen Packaging Canton Mill hereby requests Tax Certification for the addition of
landfill leachate collection equipment. The sole purpose of the system is to reduce pollution.
Two copies of the North Carolina Division of Water Quality Application for Tax Certification
and Exemption (Form TC-WQ) are enclosed. Per Form TC-WQ instructions, a copy has also
been submitted to the Haywood Count Tax Administrator.
If you have any questions regarding this issue, do not hesitate to contact us.
Sincerely,
James A. Giauque Paul Dickens
Waste Compliance& Landfill Supervisor Manager—Environmental Affairs
828-646-2028 Canton Mill—Waynesville Plant
[e-mail] 828-646-6141
Paul.dickens @ eyerpack.COm
Enclosures
cc(letter only): /
Jeff Menzel, NCDENR DWQ" b" Y
Roger Edwards, NCDENR DWQ
Heidi Howard, Evergreen Packaging L,
Lori Cooper, Evergreen Packaging j — —
�� V� AIN 1 8 2011 �
Jf+L.ITY
TE'R

evergreensM ants i Ofifice
packaging
August 15, 2011 Certified Mail
Return Receipt Requested
7007 3020 0001 6119 7370
Ms. Judy Ballard
Haywood County Tax Assessor
215 N Main Street, Suite 220
Waynesville,NC 28786
Subject: Evergreen Packaging—Canton Mill Facility
Request for Tax Certification
NPDES NC0000272, NCS000105
Dear Ms. Ballard:
The Evergreen Packaging Canton Mill hereby requests Tax Certification for the addition of
landfill leachate collection equipment. The sole purpose of the system is to reduce pollution. A
copy of the North Carolina Division of Water Quality Application for Tax Certification and
Exemption(Form TC-WQ) is enclosed. Per Form TC-WQ instructions, two copies have also
been submitted to North Carolina Division of Water Quality, Construction Grants and Loans
Section in Raleigh.
If you have any questions regarding this issue, do not hesitate to contact us.
Sincerely,
4iauque James Paul Dickens
Waste Compliance&Landfill Supervisor Manager—Environmental Affairs
828-646-2028 Canton Mill—Waynesville Plant
[e-mail] 828-646-6141
[e-mail]
Enclosure
cc(letter only):
Roger Edwards, NCDENR DW
g
Jeff Menzel, NCDENR DWQ
Heidi Howard, Evergreen Packaging L AUG 1 8 2011
Lori Cooper, Evergreen Packaging
v Al c ri r r.

packaging
August 15, 2011 Certified Mail
Return Receipt Requested
7007 3020 0001 6119 7370
Ms. Judy Ballard
Haywood County Tax Assessor
215 N Main Street, Suite 220
Waynesville, NC 28786
Subject: Evergreen Packaging—Canton Mill Facility
Request for Tax Certification
NPDES NC0000272, NCS000105
Dear Ms. Ballard:
The Evergreen Packaging Canton Mill hereby requests Tax Certification for the addition of
landfill leachate collection equipment. The sole purpose of the system is to reduce pollution. A
copy of the North Carolina Division of Water Quality Application for Tax Certification and
Exemption(Form TC-WQ) is enclosed. Per Form TC-WQ instructions, two copies have also
been submitted to North Carolina Division of Water Quality, Construction Grants and Loans
Section in Raleigh.
If you have any questions regarding this issue, do not hesitate to contact us.
Sincerely,
James &igauVque Paul Dickens
Waste Compliance& Landfill Supervisor Manager—Environmental Affairs
828-646-2028 Canton Mill—Waynesville Plant
[e-mail] 828-646-6141
[e-mail],
Enclosure '
cc (letter only): I I I
Roger Edwards, NCDENR DWQ
✓ J
Jeff Menzel, NCDENR DWQ AUG 8 2011
Heidi Howard, Evergreen Packaging
Lori Cooper, Evergreen Packaging

packer inc
August 15, 2011 Certified Mail
Return Receipt Requested
7007 3020 0001 6119 7363
North Carolina Division of Water Quality
Construction Grants and Loans Section
1633 Mail Service Center
Raleigh, NC 27699-1633
Subject: Evergreen Packaging—Canton Mill Facility
Request for Tax Certification
NPDES NC0000272, NCS000105
The Evergreen Packaging Canton Mill hereby requests Tax Certification for the addition of
landfill leachate collection equipment. The sole purpose of the system is to reduce pollution.
Two copies of the North Carolina Division of Water Quality Application for Tax Certification
and Exemption(Form TC-WQ) are enclosed. Per Form TC-WQ instructions, a copy has also
been submitted to the Haywood Count Tax Administrator.
If you have any questions regarding this issue, do not hesitate to contact us.
Sincerely,
9Janie"sfGiauque Paul Dickens
Waste Compliance& Landfill Supervisor Manager—Environmental Affairs
828-646-2028 Canton Mill—Waynesville Plant
[e-mail] 828-646-6141
[e-mail]
Enclosures
cc(letter only): _
Jeff Menzel,NCDENR DWQ
Roger Edwards, NCDENR DWQ/ p L
Heidi Howard, Evergreen Packaging
Lori Cooper, Evergreen Packaging frr11 I
J L AUG 1 8 2011 U
WATER QUALITY SECTION

A*A
NCDENR ` v
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
August 9, 2011
Mr. Dane Griswold, Plant Manager
Blue Ridge Paper Products Inc
PO Box 4000
Canton NC 28716
SUBJECT: Compliance Evaluation Inspection
Canton Mill
Permit No: NC0000272
Haywood County
Dear Mr. Griswold:
Enclosed please find a copy of the Compliance Evaluation Inspection conducted
on July 27, 2011. No violations of permit requirements or applicable regulations were
observed during this inspection.
Please refer to the enclosed inspection report for additional observations and
comments. If you or your staff have any questions, please call me at 828-2964500.
Sincerely,
Jeff Menzel
Environmental Specialist
Enclosure
cc: Paul Dickens, EHS Manager
John J Pryately, ORC
Central Files
Asheville Files
SURFACE WATER PROTECTION—ASHEVILLE REGIONAL OFFICE
Location:2090 U.S.Highway 70, Swannanoa, NC 28778111*11� NQnthCarolina
Phone:[phone]\FAX:[phone]\Customer Service: 1-877-623-6748 pt
Internet:www.ncwatercuaInv.oro Naturally
S:\SWP\Haywood\Wastewater\Industrial\Blue Ridge Paper 00272\00272 CEI JULY 2011.doc

United Stales Environmental Protection Agency Form Approved.
EPA Washington,D.C.204so OMB No.2040-0057
Water Compliance Inspection Report Approval expires 8-31-98
Section A: National Data System Coding (i.e.,PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 I rut 2 I S1 31 NC0000272 111 121 11/07/27 117 i61 rl 19l cl 201 I
LJ IJ Remarks IJ LJ IJ
2111IIIIII111111IIIIIIIIIIII1111111111IIIIIIIIIII6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 CA Reserved
671 1 69 701J 71I I 721 N 73�74 751 I I I I I 1 I e0
Section B: Facility Data 1J
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number)
Canton Mill 09:00 AM 11/07/27 10/07/01
175 Main St Exit Time/Date Permit Expiration Date
Canton NC 28716 01:00 PM 11/07/27 15/06/30
Name(s)of Onsite Representative(s)Ttles(s)/Phone and Fax Number(s) Other Facility Data
John J Pryately/ORC/828-646-6720/
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Carrie Brown,PO Box 4000 Canton NC 28716//828-646-2318/ No
Section C: Areas Evaluated During Inspection(Check only those areas evaluated)
Self-Monitoring Program E Effluent/Receiving Waters
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s)and Signature(s)of Inspectors Agency/Office/Phone and Fax Numbers Date
Jeff Menzel fin^ ARO WQ//828-296-4500/ 5/4/l/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers D to
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.
Page# 1

t
NPDES yr/mo/day Inspection Type 1
3I NC0000272' I11 12I 11/07/27 1
17 181_'
Section D: Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
The intent of this inspection was to observe plant personnel as they conducted the in-stream monitoring as
required by condition A.(5.) in permit NC0000272. Seven of the nine sampling sites were visited during the
inspection; DN3 and DN4 were not visited because the dissolved oxygen at DN1 and DN2 was above 5.0
mg/L. The facility is sampling as required by the permit. No violations of permit requirements or applicable
regulations were observed during this inspection.
Page# 2

- i
Permit: NC0000272 Owner-Facility: Canton Mill
InspectionDate; 07/27/2011 Inspection Type: Compliance Evaluation
Upstream/Downstream Sampling Yes No NA NE -
Is the facility sampling performed as required by the permit(frequency,sampling type,and sampling location)? ■ ❑ El 11
Comment:
Page# 3

*_
WDENR r' '!tE CC ,
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
July 19, 2011
Mr. Dane Griswold, Plant Manager
Blue Ridge Paper Products Inc
PO Box 4000
Canton NC 28716
SUBJECT: Compliance Evaluation Inspection
Canton Mill
Permit No: NC0000272
Haywood County
Dear Mr. Griswold:
Enclosed please find a copy of the Compliance Evaluation Inspection conducted
on June 27, 2011. No violations of permit requirements or applicable regulations were
observed during this inspection.
Please refer to the enclosed inspection report for additional observations and
comments. If you or your staff have any questions, please call me at 828-296-4500.
Sincerely,
Jeff Menzel
Environmental Specialist
Enclosure
cc: Paul Dickens, EHS Manager
Central Files
Asheville Files
SURFACE WATER PROTECTION—ASHEVILLE REGIONAL OFFICE
Location:2090 U.S. Highway 70,Swannanoa,NC 28778 $7�'`� No hCaTotlna
Phone: [phone]\FAX: [phone]\Customer Service: 1-877-623-6748
Internet:www.ncwateraualitv.orc S:\SWP\Haywood\Wastewater\lnduslriat\Blue Ridge Paper 00272\00272 CEI 2011.doc 'a 4r 11Y

United States Environmental Protection Agency Form Approved.
EPA Washington,D.C.20460 OMB No.2040-0057
Water Compliance Inspection Report Approval expires 8-31-98
Section A: National Data System Coding(i.e.,PCS)
Transaction Code NPDES yr/molday Inspection Type Inspector Fac Type
1 I N1 2 151 31 NC0000272 111 121 21/06/27 117 181 rl 191 cl 201 I
IJ LJ L Remarks LJ LJ LJ
21111111111111111111111111111111111111111111111116
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 CA Reserved
671 1 69 70(3( 71I I 72)N( 73I I I74 751 I I I 1 I 1 1 80
uu Section B: Facility Data
u t�
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also Include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number)
Canton Mill 09:30 AM 11/06/27 10/07/01
175 Main St Exit Time/Date Permit Expiration Date
Canton NC 28716 02:00 PM 11/06/27 15/06/30
Name(s)of Onsite Repmsentafwe(s)/I itles(s)/Phone and Fax Number(s) Other Facility Data
John J Pryately/ORC/828-646-6720/
Name,Address of Responsible OfticiaUritle/Phone and Fax Number
Contacted
Derric Brown,PO Box 4000 Canton NC 28716//828-646-2318/ No
Section C: Areas Evaluated During inspection(Check only those areas evaluated)
Permit 0 Flow Measurement operations&Maintenance Records/Reports
Self-Monitoring Program N Sludge Handling Disposal Facility Site Review Compliance Schedules
Storm Water
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s)and Stgnature(s)of Insp tor(s) Agency/OfficelPhone and Fax Numbers Date
Jeff Menzel ARO WQ//828-296-4500/ 7 VIf
Signature of Management Q A Reviewer Agency/OfBcelPhone and Fax Numbers DaI
Roger C Edwards �lti ARO WQ//828-296-4500/ 7 oII
PA Form 3560-3(Rev 9-94)Previous editions are obsolete.
Page# 1

NPDES yr/mo/day Inspection Type 1
3I NC0000272 I11 12I 11/06/2-1 I17 18u
Section D: Summary of Finding/Comments(Attach additional Ilssheets of narrative and checklists as necessary)
Currently the Mill is working on some internal modifications which may help to lower the temperature of the
waste water coming into the treatment plant. The facility has submitted a Low Flow Contingency Plan for
Color as required by the new permit.
The facility has not had any violations in the last 12 months.
No violations of permit requirements or applicable regulations were observed during this inspection.
Page# 2

Permit: NC0000272 Owner-Facility: Canton Mill
Inspection Date: 0 6/2 712 01 1 Inspection Type: Compliance Evaluation
Compliance Schedules Yes No NA NE
Is there a compliance schedule for this facility? ■ ❑ ❑ ❑
Is the facility compliant with the permit and conditions for the review period? ■ ❑ ❑ ❑
Comment:
Operations &Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑ ❑
Does the facility analyze process control parameters,for ex:MLSS,MCRT,Settleable Solids,pH, DO,Sludge ■ ❑ ❑ ❑
Judge,and other that are applicable?
Comment:
Permit Yes No NA NE ,
(If the present permit expires in 6 months or less). Has the permittee submitted a new application? ❑ ❑ ■ ❑
Is the facility as described in the permit? ■ ❑ ❑ ❑
#Are there any special conditions for the permit? ■ ❑ ❑ ❑
Is access to the plant site restricted to the general public? ■ ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? ■ ❑ ❑ ❑
Comment:
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit? ■ ❑ ❑ ❑
Is all required information readily available,complete and current? ■ ❑ ❑ ❑
Are all records maintained for 3 years(lab.reg. required 5 years)? ■ ❑ ❑ ❑
Are analytical results consistent with data reported on DMRs? ■ ❑ ❑ ❑
Is the chain-of-custody complete? ■ ❑ ❑ ❑
Dates,times and location of sampling ■
Name of individual performing the sampling ■
Results of analysis and calibration ■
Dates of analysis ■
Name of person performing analyses ■
Transported COCs ■
Are DMRs complete: do they include all permit parameters? ■ ❑ ❑ ❑
Has the facility submitted its annual compliance report to users and DWO? ■ ❑ ❑ ❑
(If the facility is=or>5 MGD permitted flow)Do they operate 2417 with a certified operator on each shift? 01300
Page# 3

Permit: NC0000272 Owner-Facility: Canton Mill
Inspection Date: 06272011 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Is the ORC visitation log available and current? ■ ❑ ❑ ❑
Is the ORC certified at grade equal to or higher than the facility classification? ■ ❑ Q ❑
Is the backup operator certified at one grade less or greater than the facility classification? ■ ❑ ❑ ❑
Is a copy of the current NPDES permit available on site? ■ ❑ ❑ ❑
Facility has copy of previous year's Annual Report on file for review? ■ Q Q Q
Comment:
Bar Screens Yes No NA NE
Type of bar screen
a.Manual ❑
b.Mechanical ■
Are the bars adequately screening debris? ■ ❑ ❑ ❑
Is the screen free of excessive debris? ■ 0011 .
Is disposal of screening in compliance? ■ ❑ Q ❑
Is the unit in good condition? ■ ❑ ❑ ❑
Comment: Currently the facility is rehabing an older bar screen and has plans to install
it as a back-up. Influent color is monitored every two hours or hourly if deemed
necessary.
Chemical Feed Yes No NA NE
Is containment adequate? ■ ❑ Q Q
Is storage adequate? ■ ❑ ❑ ❑
Are backup pumps available? ■ Q Q ❑
Is the site free of excessive leaking? ■ Q ❑ ❑
Comment:
Aeration Basins Yes No NA NE
Mode of operation
Type of aeration system Surface
Is the basin free of dead spots? ■ ❑ ❑ ❑
Are surface aerators and mixers operational? ■ ❑ ❑ Q
Are the diffusers operational? 110 ■ ❑
Is the foam the proper color for the treatment process? ■ Q ❑ ❑
Page# 4

Permit: NC0000272 Owner-Facility: Canton Mill
Inspection Date: 0 612 7/2 01 1 Inspection Type: Compliance Evaluation
Aeration Basins Yes No NA NE
Does the foam cover less than 25%of the basin's surface? ■ ❑ ❑ ❑
Is the DO level acceptable? ❑ ❑ ❑ ■
Is the DO level acceptable?(1.0 to 3.0 mgN) ❑ ❑ ❑ ■
Comment:
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? ■ ❑ ❑ ❑
Is the site free of excessive buildup of solids in center well of circular clarifier? ■ ❑ ❑ ❑
Are weirs level? ■ ❑ ❑ ❑
Is the site free of weir blockage? ■ ❑ ❑ ❑
Is the site free of evidence of short-circuiting? ■ ❑ ❑ ❑
Is scum removal adequate? ■ ❑ ❑ ❑
Is the site free of excessive floating sludge? ■ ❑ ❑ ❑
Is the drive unit operational? ■ ❑ ❑ ❑
Is the return rate acceptable(low turbulence)? ■ Q ❑ ❑
Is the overflow clear of excessive solids/pin floc? ■ ❑ ❑ ❑
Is the sludge blanket level acceptable?(Approximately%of the sidewall depth) ■ ❑ ❑ ❑
Comment: One of the secondary clarifiers was down for repairs at the time of
inspection. It did not appear to be hindering the facility's ability to treat waste water.
Standby Power Yes No NA NE
Is automatically activated standby power available? ■ ❑ ❑ ❑
Is the generator tested by interrupting primary power source? ■ ❑ ❑ ❑
Is the generator tested under load? ■ ❑ ❑ ❑
Was generator tested&operational during the inspection? ❑ ❑ ❑ ■
Do the generator(s)have adequate capacity to operate the entire wastewater site? ❑ ■ ❑ ❑
Is there an emergency agreement with a fuel vendor for extended run on back-up power? ■ ❑ ❑ ❑
Is the generator fuel level monitored? ■ ❑ ❑ ❑
Comment: The facility has three modes of receiving power: self-generated mill power,
CP&L, and a backup generator which can operate the influent pumps.
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional? ■ ❑ ❑ ❑
Page# 5

Permit: NC0000272 Owner-Facility: Canton Mill
Inspection Date: 06127/2011 Inspection Type: Compliance Evaluation
Effluent Sampling Yes No NA NE
Is sample collected below all treatment units? ■ ❑ ❑ ❑
Is proper volume collected? ■ ❑ ❑ ❑
Is the tubing clean? ■ ❑ ❑ ❑
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees Celsius)? ■ ❑ ❑ ❑
Is the facility sampling performed as required by the permit(frequency,sampling type representative)? ■ ❑ ❑ ❑
Comment: The facility is sampling as required by the permit. Flow meters are
calibrated quarterly. Continuous DO and pH monitoring is also conducted on the effluent.
Upstream/Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit(frequency,sampling type,and sampling location)? ■ ❑ ❑ ❑
Comment: The facility has several upstream and downstream monitoring points. The
facility has stations to add supplemental DO into the Pigeon River downstream of the
effluent outfall.
Page# 6

evergreen.40 Canton Office
packaging 75 Main Street• Canton, NC 28716
July 1, 2011 CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7007 3020 0001 6119 7769
Roger C.Edwards
Regional Supervisor
Division of Water Quality, Surface Water Protection
North Carolina Department of Environment and Natural Resources
Asheville Regional Office
2090 U.S.Highway 70
Swannanoa,North Carolina 28778
Re: Annual Progress Report on Color
NPDES Permit No. NC0000272
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill
Dear Mr.Edwards—
Enclosed is the Annual Progress Report on Color required by Part I A.(8.) item 8 of the May 26, 2010
NPDES permit.
I
Very truly yours,
I
BLUE RIDGE PAPER PRODUCTS INC.
DOING BUSINESS AS EVERGREEN PACKAGING
By.
• t
I
Nick McCracken Paul Dickens
Water Compliance Coordinator Manager Environment Health and Safety
Canton Mill Canton Mill Waynesville Plant
[e-mail] r)[e-mail]
828-646-2874 828-6461rWZZgua. �+
3
Enclosure: July 1, 2011 Annual Progress Report on Color D G E.
D
cc: Billy Clarke,Roberts and Stevens JUL — 5 2011 I
Internal distribution
f
WATER UALIT EETION
ASHEV4:LE,REGIONALQFFCZ-
-IV

-July 1, 2011 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
I. Introduction
Part I A.(8.) item 8 of the May 2010 NPDES Permit states — The facility will provide
annual progress reports to the Division on the color reduction efforts. This report fulfills
the requirements of Part I A.(8.) item 8. Specifically, the report documents projects and
best management practice (BMP) refinements completed by the Canton Mill Color Team
during the period May 2006 through May 2011. The Color Team continued work on
color performance improvement including several recommendations incorporated into the
final permit between the May 2006 application and May 2010 NPDES permit renewal.
II. Background
Levels of color in the wastewater effluent from the.Canton Mill are among the best of
Kraft pulp and paper mills in the world [EKONO August 2005, NCASI August 2006].
This high level of color performance is achieved by in-process controls and best
management practices. The mill will continue to operate the controls and practices
proven successful for color prevention. These controls and practices go well beyond the
requirements of the EPA Cluster Rule for Pulp and Paper (40 CFR 430, Subpart B).
Many, such as the Bleach Filtrate Recycling ProcessTM, are unique to the Canton Mill.
The May 2010 NPDES permit includes a daily maximum effluent true color limit of
105,250 lbs per day. The permit also specifies a monthly average true color limit of
52,000 lbs per day and an annual average (calendar year) true color limit of 38,020 lbs
Pagel

July 1, 2011 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
------------
per day. Compliance with these effluent limits requires significant management of mill
operations related to color. Prevention of wastewater effluent color is a priority for mill
operations every day.
III. Color Performance
Figure 1 illustrates the color performance of the Canton Mill since 1997. The mill has
sustained and continued the color reductions achieved under the 1997 and 2001 NPDES
permits. Annual average effluent true color in Figure 1 is presented in units of 1000 lbs
per day. The calculation of effluent color as a daily mass (lbs) is defined in Part I A.(8.)
items 2&3 of the permit: color (lbs/day) = effluent flow (mgd) x effluent true color
(platinum cobalt units) x 8.34. Effluent true color is measured using NCASI method
253 (1971).
Figure 1 - Annual Average Effluent Color
Blue Ridge Paper Canton Mill, 1997 thru 2010
70
62.2 BFR & Cluster Rule
60 ----------- Color Improvement
c 50 47.s .._.— �. - -----.__ --
0 43.4 42.7 44.6
41.1 41.2 39.7 39.1
.: 40 ------ ------ - —...- 37.1 36.1 36.5 37.9 35.9
0
c°� 30
Y
20 - -
r� Pb 0 ^0 rL0 f f (V rL0 f f ro
Page 2

July 1, 2( 1 — Annual Progress Repor`i on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
The best color performance of the Canton Mill occurs during normal, or full, production.
At normal production, the internal recycling and recovery of process filtrates, pulping
liquors and other process wastewaters are balanced. Color materials are contained within
the Kraft pulping process at efficiency greater than 99 percent. Color performance is
affected by process variability. Color materials can be lost during startup and shutdown
associated with a process upset, production curtailment or unplanned outage. Because of
both economic impact and adverse affect on color performance, the mill has strong
incentive to maintain process reliability and operate at normal production level.
Effluent color early in 2009 was affected by weak product demand related to the 2008
Financial Crisis and global recession that resulted in a lower overall rate of mill
production. Additionally, there was an unplanned pulp mill outage and color event in
September 2009 associated with a recovery furnace tube failure that required emergency,
life safety shutdown of the No. 10 Recovery Furnace. That single, unplanned outage
event added more than 1000 lbs per day to the 2009 annual average effluent color.
Effluent color at the end of 2009 and during the winter of 2010 was affected by extended
cold wet weather and regional wood supply shortages that resulted in lower than normal
rates of pulp production.
Page 3

July 1, 20 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
-------------
IV. Color Proiects and Refinements to Best Management Practices
The Canton Mill has a standing Color Team that routinely meets to review color
performance. The Color Team members include managers, supervisors and engineers
involved with production, maintenance, wastewater treatment and regulatory affairs. The
Color Team scope includes:
• Monitor color performance and the effectiveness of mill systems to prevent
effluent color
• Identify and track corrective actions related to Cluster Rule BMP color events
• Plan and review process trials related to effluent color
• Plan and review the effectiveness of capital and expense projects related to
effluent color
The Color Team is continuously evaluating projects, trials and process initiatives. Not all
of these are successful. Significant Color Team activities between 2001 and 2005 are
documented in the May 2006 Color Compliance Report [BRPPI May 2006]. Significant
activities from May 2006 through May 2011 are outlined in Tables 1 and 2. Capital
projects in Table 1 are identified by Capital Improvement Project (CIP) number. Other
projects were completed on operations and maintenance expense. Direct spending on
Color Team related projects, trials and initiatives identified in Tables 1 and 2 during the
period May 2006 through May 2011 exceed $ 3.0 MM capital and expense. These costs
are in addition to the on-going cost to operate and maintain color prevention systems at
the Canton Mill.
Page 4

July 1, 201 i — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
Table 1
Color Team Capital and Maintenance Projects
2006 - 2011
Year Project Description and Cost Information for Capital Projects
2006 Check valve installed in the#11 Recovery Boiler sump pump line. This
prevents collected color materials from being inadvertently pumped into the
CRP Feed Tank instead of the Wash Water Tank for processing through the
Evaporators. BMP improvement.
o Completed November 2006, cnsd*
2007 Continued 4th stage hardwood BSW shower replacement begun in 2005.
These shower bars were installed to improve washing and reduce carry-over
into the bleach plant. Liebergott Recommendation.
o Completed during 2007 Hwd semi-annual outage
o CEP - 230014
o Cost- $90,000
CRP sump installation and controls. This sump was installed to contain color
material event releases from the CRP system building. Also allows
collection of color material related to CRP maintenance boil out. BMP
improvement related to 2006 and 2007 color events.
o Completed December 2007
o CEP - 218675
o Cost- $164,000
Piping to collect Sarco Strainer washes directly to Wash Water Tank instead
of through sump area. Manual system of piping and valves. BMP
improvement.
o Completed in December 2007
o CIP - 232234
o Cost- $64,000
High level interlocks on CRP slurry tank. High-level indicator shuts the#11
Recovery Boiler sump gate and the CRP sewer gate exiting the building.
This allows material to be picked up in the sump if any overflows. BMP
improvement related to 2007 color event.
o Completed September 2007, cnsd*
Page 5

July 1, 20 1 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
Table 1
Color Team Capital and Maintenance Projects
2006 - 2011
Year Project Description and Cost Information for Capital Projects
2007 Mini-Hoods on No. 10 Smelt Dissolving Tank(SMDT). Allows substitution
of weak wash for clean water in SMDT demister creating more process
demand for weak wash and reducing high pH material discharged to sewer.
Related to TRW Recommendations regarding prevention of sewer-generated
color—high pH.
o Completed 2Q 2007, cnsd*
Created audible alarms for mill sewers in the DCS for WWTP. Allows
WWTP operators to locate potential elevated color streams in the mill sewers
and contact specific areas of the mill. BMP improvement.
o Completed 2007, cnsd*
2008 Dregs filter feed improvements to improve reliability and reduce frequency
of dregs sewering/overflow. Includes pipe separation, new lines and pump
upgrades. Related to TRW Recommendations regarding prevention of sewer
generated color—sulfide materials and high pH.
o Completed in 2Q of 2008
o CIP -232333
o Cost- $200,000
Creation of sample point inside CRP building to monitor color loading to
mill sewer. This point is being used to monitor operations, in regards to
color, within the CRP system. BMP improvement.
o Completed 2008, cnsd*
Determine CRP boil out strategy. Study included taking boil out water
samples at periodic intervals to determine color load to mill sewer. BMP
improvement possible with CRP recovery sump completed in 2007.
o Completed 2008, cnsd*
New set points for digester hog line conductivity probe. Better detection of
digester liquor heater leaks and better process data for monitoring-liquor
heater failures. BMP improvement.
o Completed March 2008, cnsd*
Page 6

July 1, 2011 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
------------------------------------------------------------
-------------------------------------------------------------
Table 1
Color Team Capital and Maintenance Projects
2006 - 2011
Year Project Description and Cost Information for Capital Projects
2009 Remote activation of shutoff valves on firewater quench to#11 Recovery
Boiler cyclones during Emergency Shutdown Procedure (ESP). This
mitigates potential volume of high color material from cyclone overflow
during an ESP. BMP improvement related to Sep 2009 color event.
o Identified in 4Q 2009
o Completed on No. 11 Recovery Furnace 3Q 2010, cnsd*
o Completed on No. 10 Recovery Furnace 2Q 2011, cnsd*
Curbing around East Camp Branch color material storage tank; pumps and
transfer piping. This is a proactive measure to segregate and prevent losses
of high color material to the#4 sewer. BMP improvement.
o Completed in 2009
o CIP - 239011
o Cost—portion of$128,000
Installation of separate sump and conductivity meter for East Camp Branch
tank,pumps and transfer piping. The sump and meter allow any losses from
the East Tank to be monitored and contained before entering the#4 sewer.
BMP improvement.
o Completed in 2009
o CEP - 239011
o Cost—portion of$128,000
Installation of 120 ft of concrete barrier around East Heavy Liquor Tank.
BMP improvement in the Recovery area. BMP improvement.
o Completed in 2009
o CIP—264956
o Cost- $20,000
Replacement of section(250 ft) of Wash Water line running from
evaporators to Wash Water Tank. This is a'proactive measure to prevent
losses from this transfer line. BMP improvement.
o Completed in 2009
o CIP—292829
o Cost—portion of$160,000
Page 7

July 1, 2011 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
Table 1
Color Team Capital and Maintenance Projects
2006 - 2011
Year Project Description and Cost Information for Capital Projects
2009 New flow meter at Evaporator area South Sump. Meter allows operators to
determine if the sump is picking up any losses from the Evaporator area.
BMP improvement.
o Completed March 2009, cnsd*
Level transmitter for Lime Kiln Sample Collection Tank put into DCS.
Allows an operator to monitor tank level to prevent overflows of high pH
material to the sewer and reduce the Sewer Generated Color phenomena.
Related to TRW Recommendations regarding prevention of sewer generated
color—high pH.
o Completed 2009, cnsd*
Manual back to Automatic on sumps. Sump indications now turn red and
alert operators that they are in manual mode on DCS screens. BMP
improvement related to color event.
o Completed January 2009, cnsd*
Replaced pump in the Evaporator area South Sump with a different style
pump for increased reliability. New pump is a submersible type. BMP
improvement related to color event.
o Completed 2009, cnsd*
Modified process lines and equipment on 51h effect of Swenson evaporators
to allow on-the-run cleaning. BMP improvement for process reliability to
avoid carryover of color material into condensate systems. Reduces the
volume of color material generated by evaporator boil out during outages.
Color material carry over from evaporators into condensates is related to
TRW Recommendations to prevent sewer-generated color.
o Completed 3Q 2009, cnsd*
Replaced slide rails and gates for isolating primary clarifiers at the Primary
Influent Headbox at the WWTP. New gates are faster and easier for WWTP
operators to divert high color material to the spare primary clarifier for
capture, batch treatment and attenuation. BMP sustaining measure and
improvement.
o Completed December 2009
o CIP—287478
o Cost—$265,000
Page 8

July 1, 201-1 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
Table 1
Color Team Capital and Maintenance Projects
2006 - 2011
Year Project Description and Cost Information for Capital Projects
2010 East Heavy/Tall Oil Sump transfer line repair. This was a proactive measure
to prevent color material losses from this transfer line. BMP sustaining
measure.
o Completed August 2010, cnsd*
Replaced decant line from Turpentine loading to 4A manhole. This is a
proactive measure to prevent losses from this transfer line. BMP sustaining
measure.
o Completed 2010
o CIP—315223
o Cost- $275,000
Repair and recoating of west side of Camp Branch compound. Project to
maintain integrity of spill containment. BMP sustaining measure.
o Completed 2010
o CIP—315588
o Cost- $235,000
Several black liquor transfer line replacements including East Heavy storage
tank and West GB Discharge. BMP sustaining measure.
o Completed 2010, cnsd*
Replaced conductivity and level switches in East Heavy compound with
new, more reliable type. BMP improvement.
o Completed 3Q 2010, cnsd*
Relocation of sewer conductivity meter below Digester Area sumps. BMP
optimization in this area.
o Completed November 2010, cnsd*
Red Liquor Tank shell replacement/repairs. BMP sustaining measure.
o Completed May 2010
o CIP— 266446
o Cost—$265,000
Page 9

July 1, 20i i — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
--------------------------------------------------------------
--------------------------------------------------------------
Table 1
Color Team Capital and-Maintenance Projects
2006 - 2011
Year Project Description and Cost Information for Capital Projects
2010 Mini-Hoods on No. 11 Smelt Dissolving Tank (SMDT). Allows substitution
of weak wash for clean water in SMDT demister creating more process
demand for weak wash and reducing high pH material discharged to sewer.
Related to TRW Recommendations regarding prevention of sewer-generated
color—high pH.
o Completed 3Q 2010, .cnsd*
North White Liquor Tank shell replacement/repairs. BMP sustaining
measure and project related to TRW Recommendations regarding prevention
of sewer-generated color—high pH white liquor.
o Completed Dec 2010
o CIP—322435
o Cost—$724,000
2011 Process lines to allow front-end boil out of West GB Evaporator. Allows
more frequent, less intense evaporator cleaning. BMP improvement for
process reliability to avoid carryover of color material into condensate
systems. Reduces the volume of color material generated by evaporator boil
out during outages. Color material carry over from evaporators into
condensates is related to TRW Recommendations to prevent sewer-generated
color.
o Completed May 2011, cnsd*
Repaired drain valves on No. 2 and 3 Primary Clarifiers. Allows isolation of
one of these larger volume clarifiers as the spare clarifier for high color
material diversion during semi-annual outages. BMP sustaining measure.
o Completed March 2011, cnsd*
Pine Weak Liquor Tank shell replacement/repairs. BMP sustaining
measure.
o Completed May 2011
o CIP— 331985
o Cost—$349,000
*cnsd—cost not separately determined, completed on operations and
maintenance expense
Page 10

July 1, 20fi — Annual Progress Repo'n�on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
------------------------------------------
Table 2
Color Team BMP Refinements, Trials and Process Improvements
2006 - 2011
Year(s) Refinement,Trial and/or Improvement
2006 Liebergott Process Improvements
on-going o Improve performance of vacuum washers
o Evaluate the elimination of wash water bypass on 151 decker shower
o Evaluate the elimination of bypass of Eo filtrate to decker filtrate tank
o Improve performance of decker showers on Pine
2007 Metso Project and Training
o Shared savings program
o CLOZ use study to have a lower Kappa factor ,knowledge carried
forward
2007 Strategy change in Hardwood Pre-bleach on showers. Original strategy was
on-going to wash better with chance.of overflows. Now manage to prevent those
overflows.
2007 Thoroughly clean and jet lines and hardwood washer screens during each
on-going scheduled outage.
2007 More extensive jetting/cleaning in fiberlines during semi-annual outages.
on-going
2008 MRP improvements/time scheduled maintenance and operator rounds to
on-going increase reliability.
2008 CRP boil out strategy. Amount of time boil out material is picked up.
on-going Possible with CRP sump project completed in 2007.
2008 Use membrane caustic with lower chloride concentration. Helps overall
on-going efficiency of BFR system.
2009 Optimize use of polyamine for black liquor color in primary treatment during
on-going color events. Batch treatment, as well as short period continuous use when
influent is affected by black liquor.
2009 Swenson 5 effect spray bar strategy. Ability to clean evaporator on-the-run.
on-going Improves process reliability and reduces volume of color material to recover
during outages.
2010 Weak wash purge strategy to minimize potential sewer-generated color
on-going during process upset, outage or reduced pulp mill production when demand
for weak wash is out of balance with supply in causticizing.
2011 When both fiberlines are down, process contents of one of the spill tanks
through the evaporators to free up spill tank volume before starting up.
Page 11

July 1, 26 11 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
--------------
Table 2
Color Team BMP Refinements, Trials and Process Improvements
2006 - 2011
Year(s) Refinement,Trial and/or Improvement
2011 Alternative polymer study by Chemtreat at WWTP. Compared against
current polyamine polymer in use for batch treatment of black color
materials. No difference in color performance.
2011 West GB Evaporator partial boil out strategy. Ability to clean process during
on-going short outages as opportunities arise. Improves process reliability and
reduces volume of color material to recover during outages.
Several of the projects and process improvements listed in Tables 1 and 2 are related to
2006 Liebergott recommendations for existing process optimization [GL&V 2006].
These include projects for brown stock washing improvement and target pulp bleach
Kappa factor. Other projects and improvements are related to sewer-generated color and
polymer use optimization, which are Technology Review Workgroup (TRW) evaluation
recommendations in Part I A.(8.) item 10.13 of the May 2010 NPDES Permit. The
complete application to renew the NPDES permit was submitted by the Canton Mill in
May 2006. The permit renewal process including review by the TRW, public comment
and public hearings "was completed in May 2010. During this time, the Canton Mill
Color Team continued work on color performance improvement including several
recommendations incorporated into the final permit.
V. Summary
Of the many color improvement initiatives evaluated and,implemented at the Canton
Mill, the following are essential to current (2011) effluent color performance:
Page 12

July 1, 20 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
• OD 100TM process — oxygen delignification, elemental chlorine-free (ECF)
bleaching and enhanced fiberline brown stock washing
• Bleach Filtrate Recyclinim (BFR) with the Minerals Removal Process (MRP)
and the Chlorine Removal Process (CRP)
• Cluster Rule Best Management Practices (BMP) program with color as the BMP
monitoring parameter to detect process upsets and the loss of pulping liquors to
the mill sewer system
• Extensive sumps and systems to detect pulping liquor losses to capture and
recover color materials within the pulp mill process
• Spare primary clarifier maintained to capture, treat and attenuate high
concentration color materials that may exceed capacity of the in-process sump
and spill detection systems
• Mechanical seals on pumps in digester and knotter areas to minimize dilution of
color materials that prevents efficient recovery
• Interconnection of process spill sumps and equipment to increase the working
volume for recovery of color materials during process upsets and outages
• Segregation of black liquor from green and white liquor to avoid contamination
that prevents recovery of black liquor materials
• Segregation of bleach plant filtrates from high pH conditions in mill sewers to
reduce sewer-generated color
Page 13

July 1, 2011 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
• Management of high pH materials when process filtrates are out of balance due to
process upset or reduced pulp mill production
• Outage cleaning of pulp washers and evaporators to maintain performance and
reduce carry-over of. color materials into bleach plants and into condensate
systems
• Low Flow Contingency Plan for Color [Evergreen 20111 and priority given to
color management every day.
The Canton Mill will continue to utilize the processes and practices proven successful for
wastewater effluent color prevention. Prevention of effluent color is a priority for mill
operations every day.
References
EKONO — Environmental Performance, Regulations and Technologies in the Pulp and
Paper Industry, EKONO Inc, August 2005.
NCASI—Technical Bulletin No. 919 —Review of Color Control Technologies and Their
Applicability to Modern Kraft Pulp and Paper Mill, National Council for Air and Stream
Improvement, August 2006.
BRPPI — Color Compliance Report prepared to fulfill requirements of the December
2001 NPDES Permit for the Canton Mill, Blue Ridge Paper Products Inc., May 2006.
GL&V — Bleach Environmental Process Evaluation and Report prepared for Blue Ridge
Paper Products Inc., Canton Mill, Norman Liebergott and Lewis Shackford, July 2006.
Evergreen — Low Flow Contingency Plan for Color, submitted to NC DWQ on 26 May
2011 to meet requirements of Part I A.(8) item 12 of the May 2010 NPDES Permit, May
2011.
Page 14

Canton Office
evergr�ee agi� 175 Main Street• Canton, NC 2 D
ng
MAY 2 6 2011
I
WAT[R QUALITY SE
CTION
May 26,2011 CERT
RETURN RECEIPT REQUESTED
7007 3020 0001 6119 7226
Roger C. Edwards
Regional Supervisor
Division of Water Quality, Surface Water Protection
North Carolina Department of Environment and Natural Resources
Asheville Regional Office
2090 U.S.Highway 70
Swannanoa,North Carolina 28778
Re: Low Flow Contingency Plan for Color
NPDES Permit No. NC0000272
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill
Dear Mr.Edwards—
Enclosed is the Low Flow Contingency Plan for Color required by Part I A.(8.) item 12 of the May 26,
2010 NPDES permit.
Very truly yours,
BLUE RIDGE PAPER PRODUCTS INC.
DOING BUSINESS AS EVERGREEN PACKAGING
By:
yj'�k f4��� ._es�
Nick McCracken Paul Dickens
Water Compliance Coordinator Manager Environment Health and Safety
Canton Mill Canton Mill—Waynesville Plant
[e-mail] [e-mail]
828-646-2874 828-646-6141
Enclosure: May 26, 2011 Low Flow Contingency Plan for Color
cc: Billy Clarke,Roberts and Stevens
Internal distribution
fresh by design..
Doe,g Ba sz r C a tamia m Evergteen Beverage Pa kaghg

May 26, 2011 — Low Flow Contingency Plan for Color
Blue Ridge Paper Products Inc. dba Evergreen Pacn- ,
Canton, North Carolina
NPDES Permit No. NC0000272
- J L MAY 2 6 2011 J
----------------------
-----------------------
I. Introduction e - --1
-� -!- ICE
Part I A.(8.) item 12 of the May 2010 NPDES Permit states — The facility shall submit a .
low flow contingency plan for color control within the first year of permit issuance. This
plan fulfills the requirements of Part I A.(8.) item 12.
II. Backaround
Levels of color in the wastewater effluent from the Canton Mill are among the best of
Kraft pulp and paper mills in the world [EKONO August 2005, NCASI August 20061.
This high level of color performance is achieved by in-process controls and best
management practices. The mill will continue to operate the controls and practices
proven successful for color prevention. These controls and practices go well beyond the
requirements of the EPA Cluster Rule for Pulp and Paper (40 CFR 430, Subpart B).
Many, such as the Bleach Filtrate Recycling ProcessTM, are unique to the Canton Mill.
The May 2010 NPDES permit includes a daily maximum effluent true color limit of
105,250 lbs per day. The permit also specifics a monthly average true color limit of
52,000 lbs per day and an annual average (calendar year) true color limit of 38,020 lbs
per day. Compliance with these effluent limits requires careful management of mill
operations related to color. Prevention of wastewater effluent color is a priority for mill
operations every day.
Page 1

May 26, 2011 - Low Flow Contingency Plan
Blue Ridge Paper Products Inc. dba Evergreen P
Canton, North Carolina
NPDES Permit No. NC0000272 L ! p„ ;y 2 6 2011 �J
-J------------ ------------------
ON
III. Color Prevention During Lower River Flow and Highest Recreational Use
The best color performance of the Canton Mill occurs during normal production. At
normal production the internal recycling and recovery of process filtrates, pulping liquors
and other process wastewaters are balanced. Color materials are contained within the
Kraft pulping process at efficiency greater than 99 percent. Color materials can be lost
from the process during startup and shutdown associated with a major process outage.
To minimize potential color discharges during periods of lower river flow and highest
recreational use of the river, no major (semi-annual) outages are scheduled during the
months of June,July or August.
IV. Process Upset and Spill Containment
The Canton Mill maintains an extensive spill detection and containment system. The
system includes automatic sumps with conductivity metering and dedicated spill material
tanks to capture, contain and recover color materials within the Kraft pulping process.
The mill also maintains an empty spare primary clarifier to allow for the diversion and
capture of color materials.
The Canton Mill operates a large wastewater treatment plant that includes neutralization,
primary treatment, activated sludge secondary treatment and post aeration to meet limits
in the May 2010 NPDES permit. The mill wastewater treatment operators monitor color
Page 2

I
May 26, 2011 — Low Flow Contingency .Plan for Color__ .
Blue Ridge Paper Products Inc. dba Evergre ft-Packa&iq
Canton, North Carolina I I1
NPDES Permit No. NC0000272 J .
---------------------------------- --
rE
and conductivity in wastewater influent to the treatment plant in herder to detect a process
upset or spill. When a process upset or spill of color material is detected by monitoring
or reported by process operators in the mill, the wastewater operators divert the mill
wastewater flow to the spare clarifier to capture and hold this material. The captured
color material is batch treated with polyamine and discharged back into the wastewater
treatment plant at a rate that is non-disruptive to the treatment process. The result is
equalization and attenuation of color that was not contained within the Kraft pulping
process.
V. Summary
The Low Flow Contingency Plan for Color at the Canton Mill consists of five (5)
elements:
1.) Continue to operate the controls and practices proven successful for wastewater
effluent color prevention.
2.) Prevention of effluent color is a priority for mill operations every day.
3.) No major (semi-annual) outages are scheduled during the months of June, July or
August.
4.) Monitor influent wastewater for color to detect process upset or spill.
5.) When a process upset or spill occurs that exceeds the capacity of in-process
sumps and spill collection tanks, divert influent wastewater to a spare primary
clarifier for batch treatment and attenuation of color.
Page 3

May 26, 2011 =•Low Flow Contingency Plan for Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
-------------------------
References
EKONO — Environmental Performance, Regulations and Technologies in the Pulp and
Paper Industry, EKONO Inc, August 2005.
NCASI—Technical Bulletin No. 919 —Review of Color Control Technologies and Their
Applicability to Modern Kraft Pulp and Paper Mill, National Council for Air and Stream
Improvement, August 2006.
BRPPI — Color Compliance Report prepared to fulfill requirements of the December
2001 NPDES Permit for the Canton Mill, Blue Ridge Paper Products Inc., May 2006.
Page 4

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Land Resources
Land Quality Section
James D. Simons, PG, PE Beverly Eaves Perdue,Governor
Director and State Geologist Dee Freeman,Secretary
May 20, 2011 ((�� (�a
Blue Ridge Paper Products lnc. n LS `�
Canton Mill i D
Attn: Mr. Donald Messer MAY 2 5 2011
175 Main Street
Canton,North Carolina 28716
WATER QUALITY SECTION
RE: Lake Logan Dam ASh_�ILLE RE 310N.4L OrrICE
Haywood County
HAYWO-003
Dear Mr.Messer:
This is to acknowledge receipt of your Emergency Action Plan(EAP)dated May 13,2011 for the subject
dam. The EAP was received in our office on May 19,2011.
We appreciate your efforts toward developing an EAP for the subject dam. An accurate EAP will reduce
the likelihood for loss of life should the dam fail.Your EAP will be reviewed by this office along with
other Dam Safety applications in the order received,except that repairs to existing high hazard potential
dams with known safety issues will be given priority.
Please contact Ms.Janet Boyer,PE,Acting Regional Engineer,Land Quality Section,2090 U.S.
Highway 70, Swannanoa,North Carolina 28778,telephone number(828)2964500,or me at telephone
number(919) 733-4574 should you have any questions concerning this matter.
Sincerely,
Steven M. McEvJEni
State Dam Safety
Land Quality Section
SMM/rdk
cc: Ms.Janet Boyer,PE,Acting Land Quality Regional Engineer
Surface Water Protection Regional Supervisor
Filename:HAYWO-003_20110520_RECT-EAPU13date_LakeLoganDam
1612 Mail Service Center, Raleigh,North Carolina 27699-1612 • Telephone [phone] FAX:[phone]
512 North Salisbury Street, Raleigh, North Carolina,27604•Intemet:http:/Iwww.dlr.enr.state.nc.us/pagesAandqualitysection.html

packaging; '9
MAR 2 9 2011 11
;f I
Blue Ridge Paper Products Inc. - Canton Mill WATER QUALITY SECTION
r ' ASHEVILLE REGIONAL OFFICE `
March 28, 2011 FEDERAL EkFKESS�
TRACKING440M$ER .--'
7969 1780 5948
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
Water Quality Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDES NO.NC0000272
Best Management Practices 2010 Annual Report
Evergreen Packaging dba Blue Ridge Paper Products, Inc.
Canton,NC
This letter report (two copies) is the 2010 summary of Best Management Practices (BMP)daily
monitoring for the Canton Mill. The report is required on or before March 31"of each year by
Special Condition A.(6.)Best Management Practices, Section EA and Section F.1, of the miles
NPDES Permit No. NC0000272.
The BMP action levels established in accordance with permit requirements and in effect for 2010
are as follows:
Effective Dates: 1 Jan 2010—31 Dec 2010
Total Influent (TI) Color —
Action Level daily monitoring result Action Required
1-Day Upper Action > 72 Immediate investigation and documented
Level (UAL) ,5001bs/day for one day corrective action
2-day Upper Action > 59,400 Ibs/day for two Investigation and documented corrective
Level (UAL) consecutive days action
2-day Lower Action > 55,400 Ibs/day for two Investigation and documentation
Level (LAL) consecutive days
Daily records of total influent color are maintained at the mill. These daily color data are
compared to BMP action levels every morning. Total influent color exceeded BMP action levels
on the dates outlined in the following table. A brief summary of information for these dates is
Blue Ridge Paper Products Inc. dba Evergreen Packaging —Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

28 Mar 2011,Page 2
included as required by permit Condition A.(6.), Section EA. The permit-required BMP
investigation reports are maintained at the mill. None of the BMP action level days resulted in
disruption to the wastewater treatment plant. The Canton Mill met all NPDES annual average
effluent limits during 2010.
Total Influent
Date(s) (TI) Color Action Level and Summary
2 -5 Jan 2010 59,790 Ibs/day 2-day UAL— investigation and corrective action
81,278lbs/day
58,751 Ibs/day Cause and Corrective Action(s) — Steam shortage, freeze
60,560 Ibs/day and unplanned outage. Color was elevated by several
events including power boiler maintenance outages on 1/2
and a recovery furnace trip on 1/3 that resulted in a steam
shortage and unscheduled cold weather shutdown of the
pulp mill and paper machines.
Tank equalization and freezing lines while pulp mill was .
down caused loss of color materials to the mill sewer
system. The corrective action was to repair the power
boilers and bring the mill back online as soon as
operationally feasible. Upon start up of the mill, there were
liquor balance issues, which lead to additional losses.
8 & 9 Jan 2010 64,200 Ibs/day 2-day UAL—investigation and corrective action
59,635 Ibs/day
Cause and Corrective Action(s) — BMP event, freeze
related. Mill operations were slowed back and adversely
affected by cold weather and wood chip supply shortage.
On evening of 1/9, a level transmitter on the hardwood
weak black liquor tank froze resulting in false level
indication and overflow of the tank to the containment spill
sump. The level element was thawed with a portable
heater but failed again on 1/10. Some color material was
lost to the mill sewer system. Mill personnel manually
monitored level in the tank to prevent additional overflow.
The'level transmitter was replaced on 1/10.
Blue Ridge Paper Products Inc. dba Evergreen Packaging -Canton Mill
175 Main Street • PO Box 4000'
Canton, North Carolina 28716 • 828-646-2000

28 Mar 2011,Page 3
Total Influent
Date(s) (TI) Color Action Level and Summary
12 & 13 Jan 80,459 Ibs/day 1-day UAL— Investigation and corrective action
2010 66,614lbs/day
Cause and Corrective Action(s) — BMP event, freeze
related. Mill operations were slowed back and adversely
affected by cold weather and wood chip supply shortage.
At about midnight on 1/12, a liquor leak developed at the
No. 4 Digester drain valve that was not picked up by the
West Digester Sump. WTP personnel noted elevated
sewer color and notified the pulp mill,.which investigated
and stopped the leak. Polyamine.was added to the primary
clarifiers to treat the elevated color. Investigation
determined that because of cold weather and other
maintenance activity in.digester area, the digester sump
controls were in manual. The event was reviewed with the
pulp mill supervisors and crews.
24 &25 Jan 115,099 Ibs/day 1-day UAL— investigation and corrective action
2010 65,606lbs/day
Cause and Corrective Action(s) — BMP event, freeze
related. Mill operations were slowed back and adversely
affected by wood chip supply shortage. At about 3 pm on
1/24 a transfer pump drain line liquor leak occurred while
Recovery operators were transferring heavy black liquor
between tanks. The spill gates in the#11 RF area were up
and in manual to allow housekeeping clean up that was
underway by area operators. The release of color material
was detected, and the WTP operators diverted influent flow
to the spare clarifier for batch treatment with polyamine.
This material after batch treatment was metered back into
the treatment plant at a non-disruptive rate.
The drain line leak was freeze protection related. The
incident was reviewed with recovery and evaporator
operators and several procedural changes were
implemented including putting control of the liquor transfer
operation into the Evaporator DCS. The conductivity probe
for the#11 RF spills sump was replaced.
Blue Ridge Paper Products Inc. dba Evergreen Packaging —Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 . 828-646-2000

28 Mar 2011,Page 4
Total Influent
Date(s) (TI) Color Action Level and Summary
17-22 Mar 66,955 Ibs/day 2-day UAL— investigation and corrective action
2010 60,2681bs/day
56,468 Ibs/day Cause and Corrective Action(s)— No BMP event. Fiberline
66,335 Ibs/day bleach plant washing and filtrate balance issues resulted in
60,064 Ibs/day elevated mill sewer color. Pulp mill operations were
58,276 Ibs/day slowed back and adversely affected by wood chip supply
shortage. Specifically, the pine fiberline was up and down
and experiencing low closure. This increase in conductivity
was observed in the #3A & #4 sewers. During this same
period, the hardwood fiberline pre-bleach conductivity was
also elevated. The pH of the acid sewer was running lower
than typical operation at 2.1 because of balance issues with
the hardwood D1 washer. This increased amount of flow
through the acid sewer contributed to the elevated influent
color numbers. The corrective actions including restoring
closure to normal range on the pine fiberline and re-
balancing the hardwood Di washer filtrate.
14 & 15 May 78,071 Ibs/day 1-day UAL— immediate corrective action
2010 59,928lbs/day
Cause and Corrective Actions— No BMP event. Influent
color was elevated from activities associated with semi-
annual fiberline outage. Upon restart, there were washer
balance issues, and the #11 recovery boiler tripped and
was brought back online.
14 & 15 Oct 58,105 Ibs/day 2-day LAL— investigation required
2010 56,980lbs/day
Cause and Corrective Actions— No BMP event. Influent
color was elevated from activities associated with semi-
annual fiberline outage.
Blue Ridge Paper Products Inc. dba Evergreen Packaging —Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

28 Mar 2011,Page 5
Total Influent
Date(s) (TI) Color Action Level and Summary
17 Oct 2010 110,864 Ibs/day 1-day UAL—immediate corrective action
Cause and Corrective Actions— BMP event. Elevated
influent color caused by a process wreck at the West GB
evaporators that allowed black liquor color materials to
enter the contaminated condensate system, which then
overflowed to the mill sewer and created high sewer
generated color. Recovery operators notified the WTP
about the process wreck. The WTP operators monitored
influent color and diverted influent flow to the spare clarifier
for batch treatment with polyamine. This material after
batch treatment was metered back into the treatment plant
at a non-disruptive rate. The West GB evaporators were
repaired and placed back into service.
5 Nov 2010 73,899 Ibs/day 1-day UAL— immediate corrective action
Cause and Corrective Actions— No BMP event. Elevated
influent color was associated with turbidity and paper dye.
A small quantity of concentrated optical red dye
intermittently used in the process on the #19 paperboard
machine had collected in a mill sewer drain. An employee
washing down the area flushed a slug of the accumulated
dye into the mill sewer. The elevated influent color
numbers were associated with this dye and elevated fine
turbidity. The material was successfully treated. Dye
handling procedures at the#19 paperboard machine were
reviewed.
Blue Ridge Paper Products Inc. dba Evergreen Packaging —Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

• •
28 Mar 2011,Page 6
Total Influent
Date(s) (TI) Color Action Level and Summary
2 Dec 2010 77,503 Ibs/day 1-day UAL — immediate corrective action
Cause and Corrective Actions— BMP event. A process
upset in the #11 Recovery Furnace on the evening of 12/1
caused black liquor to overflow onto the second floor of the
furnace. Floor drains in the area would normally convey
this overflow and any wash water to the spill sump system.
However, a section of floor drain failed and allowed some
black liquor and water to enter an adjacent MCC room on
the first floor of the furnace where it shorted out power and
tripped off the furnace. Without power, the automatic spill
gate for the recovery furnace did not close.
Recovery operators notified the WTP about the power
failure and furnace trip. The WTP operators monitored
influent color and diverted influent flow to the spare clarifier
for batch treatment with polyamine. This material after
batch treatment was metered back into the treatment plant
at a non-disruptive rate.
The corrective actions included inspection of floor drains in
both recovery furnaces and the rerouting of the #11 drain
that could allow black liquor or wash water to enter an MCC
room if the drain failed.
Please contact us if you have questions regarding this information.
Sincerely,
tck cCrac cen Paul Dickens
Water Compliance Coordinator Manager, Environmental Health and Safety
Evergreen Packaging—Canton Mill Evergreen Packaging—Canton Mill
828-646-2874 828-646-6141
[e-mail] [e-mail]
cc:
W.Rogers Edwards ,
DWQ Regional Supervisor, Asheville Regional Office
Blue Ridge Paper Products Inc. dba Evergreen Packaging —Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

28 Mar 2011,Page 7
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
Internal Distribution: -
C. File—Water
BMP Notebook
Blue Ridge Paper Products Inc. dba Evergreen Packaging —Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

J 28 Mar 2011, Page 8 • •
Internal distribution
D. Griswold
M. Ferguson
L. Cooper
P. Dickens
N.McCracken
i
Blue Ridge Paper Products Inc. dba Evergreen Packaging —Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

evergreenTM �- '
Packaging
Blue Ridge Paper Products Inc. - Canton Mill a
23 March 2010 CERTIFIED MAIL,RETURN RECEIPT REQUESTED
7004 0750 0000 0865 7308
Roger C.Edwards
Regional Supervisor
Division of Water Quality—Surface Water Protection
North Carolina Department of Environment and
Natural Resources, Asheville Regional Office
2090 US Highway 70
Swannanoa,North Carolina 28778
Subject: Follow-Up to Chronic Toxicity Test Result December 2009
NPDES Permit No. NC0000272
Canton Mill
Dear Mr. Edwards—
This follows our 12/23/2009 notification of results from the December 2009 quarterly chronic toxicity
test result and the 2/25/2010 Notice of Violation from the Environmental Sciences Section, Aquatic
Toxicology Unit. The quarterly chronic toxicity test collected on 12/7-8 and 12110-1 t passed at 82
percent effluent concentration. The permit requires that we pass at 90 percent or greater effluent
concentration. In accordance with the permit, we completed chronic toxicity tests for each of the last
three months (Jan,Feb and Mar 2010). All these tests passed as normal for the mill. Copies are enclosed
and are reported in the respective monthly discharge monitoring reports.
It is rare for the mill to have a toxicity test that does not pass at 90 percent effluent concentration or
greater. We do not have an explanation for the December result. The mill was running well the week of
12/7. All conventional effluent parameters were in normal range. The water quality results and QA
controls associated with the toxicity test appear normal. A summary of aquatic toxicity testing results
since 2001 is enclosed. The history of aquatic toxicity testing for the Canton Mill is good. The
December 2009 results are an anomaly. Three subsequent monthly tests passed in normal range. We also
note that December 2009 was the wettest December on record for Western North Carolina. River flows
were elevated and effluent concentration was less than 10 percent of river flow. There were no adverse
aquatic effects associated with the December 2009 aquatic toxicity test result.
Sincerely—
Paul Dickens Nick McCracken
Manager, Environment Health and Safety Water Compliance Coordinator
828-646-6141 828-646-2874
Enclosures: Summary of Chronic Toxicity Testing Since 2001,Copies of Jan,Feb and Mar 2010
Toxicity Testing Reports,Copy of 2/25/2010 NOV
cc: Cindy Moore, DWQ Aquatic Toxicology Unit(w/enclosures)
C.File Water, John Pryately, Lori Cooper, Michael Ferguson
Blue Ridge Paper Products Inc. —Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

Summary of Toxicity Data from March 2001 - March 2010
Results of 7-day Ceriodaphnia Survival and Reproduction
Chronic Values (ChV)
Canton Mill NC0000272
Sample Date Chronic Value Notes
ChV % Effluent
3/16/2001 > 100
6/15/2001 > 100
9/14/2001 > 100
12/14/2001 > 100
3/15/2002 > 100
6/15/2002 > 100
9/20/2002 92.5 NOEC= 90% LOEC= 95%
12/30/2002 > 100
3/21/2003 > 100
6/20/2003 > 100
9/5/2003 > 100
12/5/2003 > 100
3/5/2004 > 100
6/11/2004 > 100
10/22/2004 > 100 Due to historic floods, the Mill was unable to
collect a sample for the month of
September. Sample collected in October.
12/10/2004 > 100
3/18/2005 > 100
6/17/2005 > 100
9/9/2005 > 100
12/30/2005 92.5 NOEC= 90% LOEC= 95%
3/10/2006 > 100
QA problems with contract lab
NOEC<45% LOEC=45%
6/9/2006 <45 immediately retested and split sample
between two contract labs
Toxicity Data- Canton Mill Page 1 of 2 Printed 3/23/2010

I�
Summary of Toxicity Data from March 2001 - March 2010
Results of 7-day Ceriodaphnia Survival and Reproduction
Chronic Values(ChV)
Canton Mill NC0000272
Sample Date Chronic Value Notes
ChV %Effluent
Split sample between labs, both NOEC=
6/23/2006 > 100/> 100 100%
Split sample between labs, NOEC= 100%
7/20/2006 > 100/ 92.5 NOEC=90%, LOEC=95%
8/11/2006 > 100
9/8/2006 > 100
10/20/2006 > 100
12/15/2006 > 100
3/9/2007 > 100
6/8/2007 > 100
9/7/2007 > 100
12/7/2007 97.5 NOEC=95% LOEC= 100%
3/14/2008 > 100
6/6/2008 > 100
9/5/2008 97.5 NOEC= 95% LOEC=100%
1 211 2/2 0 0 8 > 100
3/6/2009 > 100
6/5/2009 97.5 NOEC=95% LOEC= 100%
9/11/2009 > 100
12/11/2009 82.5 NOEC=75% LOEC=90%
1/18/2010 > 100
2/8/2010 > 100
3/1/2010 97.5 NOEL=95% LOEC= 100%
Permit specifics that last month of each quarter is the normal toxicity testing month.
Permit requirement is chronic value (ChV) greater than or equal to 90 percent.
If quarterly toxicity test ChV is less than 90 percent,then follow-up tests next 2 months
are required.
Toxicity Data- Canton Mill Page 2 of 2 Printed 3/23/2010

•
• O iJ PO 7565
Asheville,NCo 28802
+� Phone: [phone]
.JFTS
Fax: [phone]
E-mail: [e-mail]
n
February 01, 2010
Ms. Lori Cooper
Blue Ridge Paper Products,Inc.
PO Box 4000
Canton,NC 28716
RE: ETS PROJECT NUMBER: 5921
Dear Ms.Cooper.
Enclosed are toxicity test results for samples from the Blue Ridge Paper Products,Inc.received by
Environmental Testing Solutions, Inc.January 19 and January 22 2010.
Parameter Test Procedure EPA Method Final Result
Code Number
North Carolina Phase II Chronic Whole
THP3B Effluent Toxicity Test Procedure— EPA-821-R-02-013 ChV>I00%
July 1991,Revised: February 1998
(Ceriodaphnia Full-range Toxicity Test)
Note: ChV=Chronic Value. A numeric value representing the geometric mean of the highest concentration
having no detectable impairment of survival or reproduction and the lowest concentration that does have a
detectable impairment of survival or reproduction.
If this test was performed as an NPDES requirement or by Administrative Letter,please enter the ChV
value>100% on the Effluent Discharge Monitoring Form(MR-1)for the collection date
January 18,2010 using the parameter code THP31B.
Additionally,please sign and submit the original DWQ Aquatic Toxicity Form(AT-3)by
February 28,2010.
If you have any questions concerning these results, please feel free to contact me.
(Sincerely,
JA' Sumner
Laboratory Director
This report should not be reproduced,except in its entirety,without the written consent of Environmental Testing Solutions,Inc.
The results in this report relate only to the samples submitted for analysis.
North Carolina Certificate Numbers: Biological Analyses: 37,Drinking Water: 37786,Wastewater: 600
South Carolina Certificate Number: Clean Water Act: 99053-001

iPO Box 7565
p Asheville,NC 28802
'9771;
Phone: [phone]
on Fax: [phone]
.3. Environmental Testing Solutions,Inc E-mail: [e-mail]
Effluent Aquatic Toxicity Report Form-Phase II Chronic Ceriodaphnia dubia Date: February Ol,2010
Facility: Blue Ridge Paper Products,Inc. NPDES#: NC.0000272 Pipe#: 001 County: Haywood
Laboratory Performing Test: Environmental Testing Solutions,Inc. Comments: .
Signature of Operator in Responsible Charge:
Signature of Laboratory Supervisor. C {4� f s e f Project: 5921
Samples: 100119.01,100122.03
Mail Original To:North Carolina Department of Environment and Natural Resources
DWQ/Environmental Sciences Branch
1621 Mail Service Center Standate: Enddatc Stan time: End time:
Raleigh,NC 27699-1621 01-20-10 01-27-10 1125 0758
Sample Information Sample I Sample 2 1 Control
Collection slant dare: 01-I8-10 01-21-10 't ,. Test Information san tt .at �2 Sun am 1 Ira 12
Grab: :� Treatment 100% 100% 100% Control Control I Control
Compositcciumrioo: 24-h 24-h 11114MM lnitialpH(SL9: 8.06 8.19 8.19 7.03 739 7.13
Alkalinity(mg(L CaCO,$): p�%2250133,1$6.159
Final pH(SU): 8.62 8.65 8.55 7.41 7.53 7.25
Hardness(mg/L CaCO3): +i� Initial DO(mg/L): 7.8 7.9 7.8 7.8 7.8 7.7
Conductivity(pmhos/an): 2250 Final DO(mga.): 7.9 8.0 7.7 7.8 7.9 7.6
Total residual chlorine(mg/L): <0.10 [aide[Temp.(C): 25.1 25.0 24.8 24.8 24.9 24.7
Sample Temp.a Receipt CQ: 3.9 Final Temp.(°C): 25.0 1 24.9 1 25.1 24.9 25.0 25.2
Organism Number
Control Organisms 1 2 3 4 5 6 7 8 9 10 man Chronic Test Results
N»mber of Young Produced 30 30 36 30 33 33 1 34131 1 321 30 131.9 Final Control Mortality(%): 0
Adult Survival: L)ive, Dead L L L L L I L I L I L I L I L K.Control with 3rd Brands: 100
Control Reproduction CV: 1 6.5
Effluent Percentage 45% 48 Hour Mortality
Treatment 2 Organisms 1 2 3 4 5 6 7 8 9 10 man CoatmC o of 10
umber of Young Produced 1 301361 38 1 371 351 361381331 361 35 35.4 twc: Io of 10
Adult Survival: L ive,(D)ead I L I L I L I L I L I L I L I L I L I L -11.0 Significam?. No
r�YLO® Final Mortality Significant et No Con.
Effluent Percentage 75%
Treatment 3 Organisms 1 2 3 4 5 6 7 8 9 10 manrrodmfim
production Anal ses
Number of Young Produced 38 35 40 351371 381381 33 37 36 36.7 OEC: >I00%
Adult Survival: L ive, D ead L L L L L L L L L L -15.0 NOEL: 100%
d: Damietta
Effluent Percentage 90% ution: Yes
Treatment 4 0 anisms 1 2 3 4 5 6 7 8 9 10 man Kolmo orov D
Numbat ofYoun Produced 39 38 35 32 34 37 35 34 38 37 35.9 0.946
Adult Survival: (L)ive,(D)ead I L I L I L I L L I L I L I L I L I L 1 -12.5 Critical Value: 1.035
x Equal Variances: Yes
Effluent Percentage 95% Method: Bardett's Test
Treatment 5 Organisms 1 2 3 4 5 6 7 8 9 10 man Statistic: 1.291
Number of Young Produced 1 381371 331 38 36 138 135 136 134 1 301 35.5 Critical Value: 15.086
Adult Survival: L ive, D ead I L I L I D I L L I L I L I L I L I L 1 -11.3 Non-Parametric Analysis(itapplicable)
Ma`�`a0n Method:
Effluent Percentage m0% Effluent% Rank Sim Critical Sam
Treatment 6 Organisms 1 2 3 4 5 6 7 8 9 10 man 45%
Number of Young Produced 1 28 133 1 321 33 134 133 128 126 130 132 1 30.9 75%
Adult Survival: L ive, D ead L D L L L L D L L L 3.1 90%
y aet°cow 95%
Overall Analysis: 100%
Result: PASS LOEC: >100% NOEC: 100% ChV: >100%
DWQformAT-3(8191)Rev. IL95

Page I of 5
OT TS
North Carolina Phase 11 Chronic Whole Effluent Toxicity Test
(EPA-821-R-02-013 Method 1002.0,NC Modification-February,1998)
Species: Cerlodaphnia dubla
fgEt_�� 41 1�&e_ PAP44 f"b-it_M Or-, I NPJDES N: NC
Facility: I I Outfall/Pipe: 001
County: AM1A00h I IWC: 1 90
Comments:
Test organism source information: Test information:
Organism age: I <24-hours old
Date and times organisms were born Randomizing template color. dr�dub
-10 0136 To 404S Incubator number and shelf
between: location: 2-61
Culture board: _jR
Replicate number,
1 4 1 5 1 6 1 7 1 9 1 9 1 ro YWr batch:
Culture board cup number., 17- 1 a 151 n I I I I I-LI jS rzo J*Lj I-LA 01.05-10
Transfer bowl information: I pH=-1.%40 SU TemPemtm= 114.01 *C Selenastrurn batch:
I 12-M-0i
%,;"' Dilution preparation information: Sam le collection in ormation:
Concenhation Sample I
Sample 2]
M Asl -(s '10 cis IGO
sample Va"aaehore '10 ISO too L'90 Zoo Collection start date: 01. _11_10
(010 0 1- 01. -LI-10
Diluejuvo
Collection end time: DOC)
(ML) 0 so _10 10 0 JOO() 1000
Total volume Grab/Composite 'Lq.140dot 't_ao,3
tg -&0 zoo 700 It() ZOO (duration): (A101ksit
Temperature('C)
upon receipt:
'.Z Physical YN Tpoi
characteristics:Sumelt r-to tLeAA
ltnUeS PALTV_Xn
ETS project number:
ETS sample number: fool i1t. 0 1 10 0 1 1,L-4y
Daily renewal information. -A SOL%M frk.00CULAOT HAIV-1 AL 516PJ i Fl CAfJV_%1
Day Date Test initiation, Control/Dilution Sample numbers Analyst L 0afttj. SMU
renewal,feeding,or water batch use used
termination time (Soft synthetic
tiafi....dF &. -M
0 01-20-10 bi 1 1USJ 0 1-1 t 10 10011q. 01 A-69OC JIVCD ul
-TI?S-V TIOq(LIL
I F�&mg 01-21-10 082-1 -Le-K&A-
2 W1 F-14k
3 Fftdws
4 171-2+10 pqy
Feeding
5 Ot-25-JO Renewal d Feeding
6 01_U.10 Reftg Olu
7 'on
Control information: Acceptance criteria Summary of test endvoints:
%of Male Adults: :520% 7-day LCsa >lot)1.
%Adults having 3'Broods: 100'/. 90% Lch
%Mortality: 20% LOE
-Mean Offs ring/Female: j Z:15.0 offspring(female ChV 5 loci'to
%CV: <40.0%
IC24
SOP AT13 Exhibit ATI 3.2,revision 04-01-09

t Page 2 of 5
< 5 • � � .
•�c
r�
Species: Ceriodanhnia dubia
p Date: 01-1-o•10
° Client: .6LV2. #-%n 2 Nked ..
a
w CONTROL Survival and Reproduction Data
1
Replicate number
o Day 1 2 3 4 5 6 7 8 9 10
i 2 Adult mortality
I' a,=live.D=dead
5 Numher 1
Youug fbroods
produced 13 1
`� 11 +`� Ilo l�l 1-1 +1 +y IS
`2t Adult mortality
(L=live,D=dead
6 or 7 Nmober 1 I 1 l young orbmoa, 1 l l l I 1
produced 1-1 Ilo Iq Ilo 1`1 lot In tt 1$ 15
Total young produced 30 30 3Ib 3b 53 35 &A 31 32. 3o
Final Adult Mortality ` >_
=live D=dead �!
w Xfor3` Broods X �( )4-
Control: -71
%Mortality: 'I,
Mean Offspring/Female: PjI.j
Concentration: S7+ Survival and Reproduction Data
r;
Replicate number
Da 1 2 3 4 5 6 7 8 9 10
F 2 Adult mortality
=live,D=dead L- L' L— �-- �— L
5 Young ofbmod, 7' L Z 1 Z i
produced 1 16 l� 1l0 16 16 I$ I S II 16
Adult mortality
=llMD.=dead)
R 6 or 7 Young L= 1 1 1 1 [ t 1 \ 1 i 9
!' produced Ito 7-0 19 21 1� Zp 20 18 1 q
Total young produced 30 36 3t3 31 35 36 3$ bM3 al. 3S
Final Adult Mortality l_
(L live,D=dead)
i
i
F
i Test Concentration:
i %Mortality: �.
Mean Offs rin emale: 5.
i %Reduction from Control: 4(61,
SOP AT13-Exhibit AT13.2,revision 04-01-09
E

Page 3 of 5
"j �rmLwmmhliungzdwouts
•y'i.
fi
Species: Ceriodanhnia dubia
�Lue 21 eae Pr�Pe�
Date: O1-20 I 0 Client:
r
: a.
3 '
[rt; Concentration: lj% Survival and Reproduction Data
t
Replicate number
1: Day 2 3 4 5 6 7 8 9 - 10
2 Adult mortality
_ =live,D=dead)
5 Young afb.ad, 7. '1- �• 2 2 2. 2 2 t
produced 6q Ito 1 11 11 {& 2.0 lip l8 l8
Adult mortality
=live,D=dead L— L 4�_ L L
6 or 7 Young fb.d, \ \ 1 \ l 1 \ 1 1
produced 18
Total young produced
.38 3S cI0 35 31 a8 38 3'6 3'1 3(.
Final Adult Mortality
=live.D=dead)
Test Concentration:
%Mortality:
Mean Offs rin emale:
%Reduction from Control:
Concentration: 407o Survival and Reproduction Data
Replicate number
Day 1 1 2 1 3 1 4 1 5 1 6 7 8 9 10
2 Adult li mortaty ` 1_( ,=live,Da dead
5 Number
Young afbmede Z 2 7. L -L '1, LL
produced 7.0 18 Iq 16 16 1s
Adult mortality
t =live,D=dead)
l' Number
6 or 7
I Young ofbm.da
} . produced 11 zo 16 Ib Ig l9 Ib {-1 Iq 19
r
s
Total young produced 38 35 31 3y 3 ► zz
3
Final Adult Mortality
y =live,D=dea L IL- 1_-
,:
i EX.Redouction
oncentration:
Mortality: v .
ff rin emale: 3. ,
e from Control:
SOP AT13—Exhibit AT13.2,revision 04-01-09

Page 4 of 5
Y
77�
_� a ViI Fmbenr�mYTaerq Sdutbny l,c.
r
Species: Ceriodaphnia dubia
Client: &2 '2tp(p pAf?1t_
Date: Q 1.7.0-10
Concentration: Survival and Reproduction Data
Replicate number
Day 3 4 5 6 7 1 8 9 10
2 Adult mortality
(L=live,D=dead)
5 Number
Young ofbmods 2.. 1
produced I'1 Ig 15 Ig Lot ?O 11 I$ Ib (SLL
Adult mortality
L=live,D=dead
Nmnbtt I 1 1 1 1 1 1 L I
6or7 young ofEroads 1
produced I� Ig 1& Ia1 11 1& Q
Total young produced 39 31 3b 3& 36
8& 35 36 3�{ 3p
' Final Adult Mortality
�.'. =live,D=dead)
a
Test Concentration:
%Mortality: I 7.
Mean Offs rid emale:
%Reduction from Control: 1.3
Concentration: /O07o Survival and Reproduction Data
Replicate number
Day 1 2 3 4 5 6 7 8 9 10
2 Adult mortality
=live,D=dead)
Nunbe i 1 2 i 2 2 Z
5 Young ofbmo
produced ly I (0 1 I1 1(0 1 g I�j 1'j I S I�{
Adult mortality 1•_. L �.-- L L L L L L
=live,D=dead
6 or 7 Young ens ae 1 I 1 1 1 1 ) 1 l 1
produced ly IliIS It 1$ I C'S 1` ( Is
Total young produced
Z8 33 31 33 3y 33 U Zf, 30 3Z
Final Adult Mortality ,
=live,D=dead)
L �-• ` L- L �--• .,
.v
Test Concentration: kill
Qw,4 e.. alOt gSt J I Ce 7 a/o Mortality:
Mean Offs rin emale: .9 71
%Reduction from Control: F
SOP AT13—Exhibit AT13.2,revision 04-01-09

1 o Page 5 of 5
� �FnWenm•nttlTu @q SolWowlx
5'
1{
Species: Cerioda�hnia dubia
Client: JQ IDEP HPCIL Date: 01.20-10
Daily Chemist
Da
Initiation Renewall. Renewal2
Analyst 1`7
Concentration Parameter
H S.U. -7•03
CONTROL DO m
Conductivity
mhos/cm i s3 15(p 1Sq
Alkalinity 3 3
ling CaCO3/L)
Hardness
(mg CaCO/L �1
Temperature('C) ILA-d 11Z Z 1S•O t 15.2
H S.U. 7, 5
DO m 0 I1.
Conductivity 113U 1000 1INO
mhos/cm)
Temperature('C) tS•O q 1S•O 't.S,O 1 LS•O
H S.U. -7. 1)4 9.43 £3,1`1 6•S•1 8.1 8•Y
DO m -I-Cl 1 •0
j&
Conductivity 1 IZ(� �'�� 1$00
( mhos/cm '1.
e Temperature('C) -Ls.-0 z�1•Q 15.0 _LS.0 1A."1 7S •L
H S.U.) 8.15 .Sa
DO m 'L,q -1•$ �•�
Conductivity q'70 �+OBU Z100
Tem erature °C) Zs•0 l Q•8 �.U %S.•L L 2S. 2
H S.U. 017 R.la 8.6b R. 17 SZ
E DO m g 6.0
4i IS7 conductivity Z NO ^ 2l'lO
mhos/cm O�ILl Q
Temperature(°C) IS. K•0 °IS•O 1S. 0 —L 7S,
H S.U.
Conductivity
1. mhos/cm
Temperature(°C
H S.U. O(o . G 8.b5 8• I9 SS
100% DO(mg/L) 1. -1.9 & .0 7.
Conductivity -Z Z�0 aa.00 17-SO
mhos/cm
TR chlorine <6 10 4 0. 10
m
Temperature(°C) 1$•I 2 2 ,O LI1.11 1 1. 2S• 1
Initial Final Initial Final Initial Final
SOP AT13-Exhibit AT13.2,revision 04-01-09

•
0 _ =_ _
3^1 Environmental Testin
g Solutions,Inc.
Ceriodaphnia Survival and Reproduction Test-Reproduction
Start Date: I202010 Test ID: CdFRCRNC Sample ID: Blue Ridge Paper Products,Inc.
End Date: 1272010 Lab ID: ETS-Envir.Testing Sol. Sample Type: DMR-Discharge Monitoring Report
Sample Date: Protocol: FWCHR-EPA-821-R-02-013 Test Species: CD-Ceriodaphnia dubia
Comments:
Cone-% 1 2 3 4 _ 5 6 7 8 9 10
D-Control 30.000 30.000 36.000 30.000 33.000 33.000 34.000 31.000 32.000 30.000 =,
45 30.000 36.000 38.000 37.000 35.000 36.000 38.000 33.000 36.000 35.000
75 38.000 35.000 40.000 35.000 37.000 38.000 38.000 33.000 37.000 36.000
90 39.000 38.000 35.000 32.000 34.000 37.000 35.000 34.000 38.000 37.000
95 38.000 37.000 33.000 38.000 36.000 38.000 35.000 36.000 34.000 30.000
I00 28.000 33.000 32.000 33.000 34.000 33.000 28.000 26.000 30.000 32.000
Transform:Untransformed I-Tailed Isotonic
Cone-% Mean N-Mean Mean Min Max CV% N t-Scat Critical MSD Mean N-Mean
D-Control 31.900 1.0000 31.900 30.000 36.000 6.517 10 35.080 1.0000
45 35.400 1.1097 35.400 30.000 38.000 6.816 10 -3.322 2.287 2.409 35.080 1.0000
75 36.700 1.1505 36.700 33.000 40.000 5.457 10 4.556 2.287 2.409 35.080 1.0000
90 35.900 1.1254 35.900 32.000 39.000 6.222 10 -3.797 2.287 2.409 35.080 1.0000
95 35.500 1.1129 35.500 30.000 38.000 7.303 10 -3.417 2.287 2.409 35.080 1.0000
I00 30.900 0.9687 30.900 26.000 34.000 8.823 10 0.949 2.287 2.409 30.900 0.8808
Auxiliary Tests Statistic Critical Skew Kurt
Kohnogorov D Test indicates normal distribution(p>0.01) 0.94603854 1.035 -0.5552021 -0.2369768
Bartletes Test indicates equal variances(p=0.94) 1.29115987 15 0862722
Hypothesis Test(1-tad,0.05) NOEC LOEC ChV TU MSDu MSDp MSB MSE F-Prob df
Dunnett's Test 100 >100 1 2.40915279 0.07552203 56.4966667 5.55 6.6E-07 5,54
Treatments vs D-Control
Linear Interpolation(200 Resamples)
Point % SD 95%CL Skew
IC05 97.098 0.607 95.728 98.317 0.1796
IC10 99.196
IC15 >100
IC20 >100
IC25 >100
IC40 >100 Blue_Ridge_Paper 01-20-10
IC50 >100

• Ceriodaphnia dubia Chronic Whole Effluent Toxicity Test
EPA-821-R-02-013,Method 1000.0 -North Carolina Modification
'i 4 Quality Control
Verification of Data Entry, Calculations, and Statistical Analyses
13 Environmental Testing Solutions,Inc. Client:_Blue Ridge Paper Products,Inc.
Test dates: January 20-27,2010
Project number: 5921
Reveiwed by: &,,,� -
Concentration Day Re Ecate number Survive] Average cotmcieol or Percent reduction from
1 2 1 3 4 5 1 6 7 8 9 1 10 % re roduction rnrind'm (%) control(•A)
5 13 14 1 17 14 16 1 14 17 17 14 1 15
Control 7 17 16 1 19 16 17 19 17 14 18 15 100 31.9 6.5 Not applicable
Total 30 30 36 30 33 33 34 31 32 30
5 14 16 19 16 16 16 18 15 17 16
45% 7 16 20 19 21 19 20 20 18 19 19 100 35.4 6.8 -11.0
Total 30 36 38 37 35 36 38 33 36 35
5 19 16 19 1 17 17 18 20 16 18 18
75% 7 19 19 21 18 20 20 18 17 19 18 100 36.7 5.5 -15.0
Total 38 35 40 35 37 38 38 33 37 36
5 20 18 19 16 16 1 18 19 17 19 l8
90% 7 19 20 16 16 18 1 19 16 17 19 19 too 35.9 6.2 -12.5
Total 39 38 35 32 1 34 1 37 35 34 38 37
5 19 18 15 19 19 20 17 18 18 15
95% 7 19 _ 19 18 19 17 18 18 18 16 15 90 35.5 7.3 -11.3
Total 38 37 33 38 36 38 35 36 34 30
16 17 17 16 18 15 15 IS 17
100% 7 14 17 15 16 18 l5 13 I1 l5 15 80 30.9 8.8 3.1
Total 28 33 32 33 34 33 28 26 30 32'
Dunnen's MSD value: 2.409 MSD= Minimum Significant Difference
PMSD: 7.6 PMSD= Percent Minimum Significant Difference
PMSD is a measure of test precision. The PMSD is the minimum percent difference between the control and treatment that can be declared
statistically significant in a whole effluent toxicity test.
Lower PMSD bound determined by USEPA(]0ib percentile) =13%.
Upper PMSD bound determined by USEPA(9&percentile)=47%.
Lower and upper PMSD bounds were determined from the loth and 90th percentile,respectively,of PMSD data from EPA's WET
Interlabomtory Variability Study(USEPA,2001a;USEPA,2001b).
USEPA. 2001a,2001b.Final Report: Interlaboratory Variability Study of EPA Short-term Chronic and Acute Whole Effluent Toxicity Test Methods,Volumes 1 and 2-Appendix EPA-821-131-0I-004 and EPA-82I-B-01-005.US
Environmental Protection Agency,Cincinnati,OH.
Blue Ridge_Paper_01-20-10

C� O py
� PO Box 7565
T1111
Asheville,NC 28802
Phone: [phone]
-_ Fax: [phone]
E-mail: [e-mail]
Environmental Testing Solutions,Inc
February 19, 2010
Ms. Lori Cooper
Blue Ridge Paper Products, Inc.
PO Box 4000
Canton,NC 28716
RE: ETS PROJECT NUMBER: 5945
Dear Ms. Cooper:
Enclosed are toxicity test results for samples from the Blue Ridge Paper Products,Inc. received by
Environmental Testing Solutions, Inc. February 02 and February 05,2010.
Parameter Test Procedure EPA Method Final Result
Code Number
North Carolina Phase 11 Chronic Whole
THP3B Effluent Toxicity Test Procedure— EPA-821-R-02-013 ChV>100%
July 1991,Revised: February 1998
(Ceriodaphnia Full-range Toxicity Test)
Note: ChV=Chronic Value. A numeric value representing the geometric mean of the highest concentration
having no detectable impairment of survival or reproduction and the lowest concentration that does have a
detectable impairment of survival or reproduction.
If this test was performed as an NPDES requirement or by Administrative Letter, please enter the ChV
value>100%on the Effluent Discharge Monitoring Form(MR-1)for the collection date
February 01,2010 using the parameter code THP3B.
Additionally,please sign and submit the original DWQ Aquatic Toxicity Form(AT-3)by
March 31,2010.
If you have any questions concerning these results, please feel free to contact me.
Sincerely,
'7im Sumner
Laboratory Director
This report should not be reproduced,except in its entirety,without the written consent of Environmental Testing Solutions,Inc.
The results in this report relate only to the samples submitted for analysis.
North Carolina Certificate Numbers: Biological Analyses: 37,Drinking Water: 37786,Wastewater: 600
South Carolina Certificate Number: Clean Water Act: 99053-001

•® � PO Box 7565
® :, 7 71;
Asheville,NC 28802
Phone: [phone]
C�J Fax: [phone]
',) Environmental Testing Solutions,Inc E-mail: [e-mail]
Effluent Aquatic Toxicity Report Form-Phase II Chronic Ceriodaphnia dubia Date: February 19,2010
Facility: Blue Ridge Paper Products,Inc. NPDES#: NC-0000272 Pipe#: 001 County: Haywood
Laboratory Performing Test: Environmental Testing Solutions,Inc. Comments: .
Signal=of Operator in Responsible Charge:
Signature of laboratory Supervisor: project: 5945
Samples: 100202.07.100205.03
Mail Original To:North Carolina Department of Environment and Natural Resources
DWQ/Environmental Sciences Branch
162I Mail Service Center Start date: End date: Start time: Endtimr.
Raleigh,NC 27699-1621 02-03-10 02-10-10 1531 0746
Sample Information Samples Somple2 Control
Collection smrt date: 02-01-10 02-04-10 d Test Information sun nag 1 nm 121 sun g 11 anu 2
Crab: Treatmem: 100% 100% 100% Control Control Control
Composite duration: 24-h 24-h Initial pH(SU): 8.25 8.25 8.14 7.14 7.29 7.39
Alkalinity(mg/L CaCOs): s'' 33,34 Final pH(SU): 8.47 8.52 8.52 7.13 7.30 7.22
Hardness(mg(L C8CO3): ' 44,42 Instal DO(mg/L): 7.8 7.6 8.0 7.8 8.0 8.0
Conductivity(µ nhos/cm): 2020 2220 rst,iaq isa Final DO(mg/L): 7.7 8.0 8.0 7.6 8.0 7.9
Total residual chlorine(mg/L): 1 2"0 1 <0.10 steA;wwtya initial Temp.CQ: 25.2 24.9 25.0 24.8 24.7 24.7
Sample Temp.at Receipt CQ: 1.4 0.8 Final Temp.CC): 1 25.0 1 24.7 1 25.0 1 24.9 1 25.1 1 25.2
Organism Number
Control Organisms I 2 3 4 5 6 7 8 9 10 mmo Chronic Test Results
Number of Young Produced 1 301 32 1 28 129 128 127 1 321291271 301 29 2 Final Comrsel Monality(%): 0
Adult Survival: ive, Dead L L L L L L L L L L %Control with 3rd Broods: too
Control Reproducdon CV: 6.2
Effluent Percentage 45% 48 How Mortality
Treatment 2 Organisms 1 2 3 4 5 6 7 8 9 10 m. Control: 0 of 10
Number of Young Produced 36 33 32 33 30 35 32 32 35 33 33.1 Iwc: o of to
Adult Survival: L ive, Dead L L L L L L L L L L -13.4 Significant?: No
%R' _10 Final Monatity Significant at: No Conc
Effluent Percentage 75%
Treatment 3 Organisms 1 2 3 4 5 6 7 8 9 10 Reproduction Analyses
Number of Young Produced 136133133 1 351 311 32 34 133 134 1 341 33.5 ReproductionLOEC: >100%
Adult Survival: ive, Dead I L I L I L I L I L I L L I L I L I L 1 -14.7 1 Reproduction NOEC: 100%
%M.d® OverA Method: Dunnetrs
Effluent Percentage[E] Normal Distribution: Yes
Treatment 4 Organisms I 2 3 4 5 6 7 8 9 10 m. Method: KolmogmovD
Number of Young Produced 1 371381 31 1 371 341371 351 321 351 331 34.9 statistic: 0.518
Adult Survival: (L)ive,(D)ead L L L L L L L L L L -195 Critical Value: 1.035
%RW. Equal Variances: Yes
Effluent Percentage 95% Method: Burdens Test
Treatment 5 Organisms I 2 3 4 5 6 7 8 9 10 mua Smdstic: 4.344
Namber of Young Produced 31 1371381 36 321301 35 35133 33 34.0 Critical Value: 15.086
Adult Survival: L ive Dead I L I L I L I L I L I L I L I L I L I L 1 -16.4 Non-Pammemic Analysis(if applicable)
%M.d® Method:
Effluent Percentage 300% Effluent% Rank Sum Critical Sum
Treatment 6 Organisms I 2 3 4 5 6 7 8 9 10 m. 45%
Nlunber of Yam Produced 39 351311 341361321321331361351 34.3 75%
Adult 5luvival: L ive, (D)gad L L L L L L L L L L -17.5 90%
xaa ® 95%
Overall Analysis: 100%
Result: PASS LOEC: >100% NOEC: 100% ChV: >100%
DWQformAT-3(891)Rem.IL195

F
7 Page 1 of 5
1 �Fm4minnWTUWq$dNWiele ,
North Carolina Phase II Chronic Whole Effluent Toxicity Test
(EPA-821-R-02-013 Method 1002.0,NC Modification-February,1998)
f Species: Ceriodaohnia dubia
Client: ! G NPDE : C 0000 92
t Facility: Out
WPiS# e:N 061
County: ]VC: 90
Comments:
' Test organism source information: Test information:
Organism a <24-hours old Randomizing template color.
Date and times organisms were bon OY-ob-lO Ob50-m 1N 0 q incubator number and shelf
between: location: ZC
Culture board: •.1
! Replicate number: t 1 2 a 1a 1 s 1 s 1 2 1 e 1 s 1 10 ywT batch:
Culture board cup number. I 'Lit) 1'-p Z$ O (M-US-ID
;'_;.. Transfer bowl informations I pH= -1.14 SU Tem erature= -ljtA.4j °C Selemstrum batch: 01.29.10
Dilution preparation information: Sam le collection in ormation:
t' ��oj e0�on CIS j 0 °!S 166 Sample 1 Sample 2
f sample volume Collection start date:
mI 90 /yU I80 150 ?do [7z 0L10 02 o4-to
Imment vulume 10 b Collection end time: IOOo
3: MI. Ilu W '10 1000
Tot volume �� �Od � Zt1d 2 Grab/Composite �y-1'p&w -L4.1 OJ2
b l ) (duration): LbOv2scD 6
i .
Temperature(eC)
upon receipt: I.4'L G•¢ O•
Physical ORFtk6o- TAa
chameterisOcs: C.t.2A(L s�.vA%A
PA2TlClLS PARi1
�i E[S project number:
+. EPS sample number: ((1Q 01.0� /b010'a.63
Daily renewal information:
F Day Date Test initiation, Control/Dilution Sample numbers Analyst
renewal,feeding,or water batch used used
termination time (Soft s nthetic
° O3.63d0 lettiafieaenciFeeding 1Sb% Os-01-10
files
A•
i 0A.04.10 Feeding 08bZ ��k
2 01-015•10 aea"M l and Feeding 01-01-Ib 100202.09
I,
b' 3 0=•04./0 Feed ng
6A5U l'ka-
4 Fe Svg
5 oy(>o.lo Renewil2eM Feeding
11 Os-o�i-Il7 l00 S-n
f, 6 Feeding
U2•u9.lu 1.10
err k- 7 01. 0. 6 re�mrian vl�IO
r
` Control information: Acceptance criteria I Summary of test endpoints:
%of Male Adults: s20% 7-day LCso >1601•
%Adults having 3 Broods: I z80% NOEC I Oo' .
%Mortality: O'(, s 20% LOEC
Mean Offs rin emale: a 15.0 offspring(female Chv
%CV: (aZ <40.0% IC25.
r
SOP AT13—Exhibit AT13.2,revision 04-01-09

Page 2 of 5
Janwvmmmnamsmwsnaus
i
7
Species: Ceriodanhnia dubia
Client: nn Date: DA-63.I0
�� /�t�yL� I'4�N1
CONTROL Survival and Reproduction Data
Replicate number
Day 1 2 3 4 5 6 7 8 9 10
2 Adult mortality
=live,D=dead
Numbv
5 Young ofbroods �' 1• �' Z' Z
produced l3 11 1, 13 15 IZ- IS IS
Adult mortality
=live,D=dead)
6 or 7 Young ofbrooesls l 1 \ \ \ i \ I
produced 1, 15 I Ib lJ 15 1, ly t� l(o
Total young produced
' 30 3z Z9 2& Z.1 3 Z 29. 30
Final Adult Mortality L l L L L
=Iive,D=dead
X for 3 Broods x
1 Control:
Mortality:
Mean Offspring/Female: Gt,
• H Survival and Reproduction Data
Concentration. 5�• P
Replicate number
Day 3 4 5 6 1 7 8 9 10
2 Adult mortality -L L L
=live,D=dead
5 Numher 7.. 1 Z. -L 'L
Young ofbroods
4 produced l8' 15 Ib l$ 1 l� I—I I 18 I&
Adult mortality
=live,D=dead
6 or 7 Young oPronds \ \ \ l \ l l L
produced 18 18 I la I S I to tq I s ►� I"I I S
Total young produced 36 3'3 37- 33 30 35 3Z 3Z. 3 S 33
Final Adult Mortality L L L L
- =live,D=dead)
Test Concentration:
a
/o Mortality:
Mean Offs rin emale: 3.
°/a Reduction from Control: - y.
SOP AT13-Exhibit AT13.2,revision 04-01-09
�1

Ix==1+ Page 3 of 5
r .,.
'1Ff 5 IFTS
*':� �,fm4mmmWT.Ni95dWmiNc
{•t
Species: Ceriodauhnia dubia
/ n Oa•63. 10
Client: ,d SUP Qt 0 j ` 4020 Date:
n.
IConcentration: 1151• Survival and Reproduction Data
¢ Replicate number
I Day 1 2 3 4 5 6 7 8 9 10
2 Adult mortality L
=live,D=dead)
I Number
5 Young oFbraods 1 l Z 1 2.
produced IS tS is lF( ll0 1 Ilp 1"1 �5 1
Adult mortality '
=live,D=dead)
6 or 7 Young orbraom-.Number 1 1 l .1 L I l 1 l
produced 71 I$ Ltf 11 I�j 1 l8 L b 101 1.�
Total young produced 3y 33 33 35 31 3Z 3q 33 3`A
Final Adult Mortality l— %-- L L L t_
=live,D=dead)
ITest Concentration:
%Mortality: 0.
I Mean Offs tin emale: 33.s
%Reduction from Control:
IConcentration:90 Survival and Reproduction Data
a
S° Replicate number
IDay 1 2 3 4 5 6 7 8 9 10
2 Adult mortality
.(L=live,D=dead
I Z
5 Young Numha Z
oCbmods 7 Z- l 2
produced (e
Adult mortality L L 1✓ L
i =live,D=dead
6 or 7 Young o e, I 1 1 1 1 1 1 l 1 1
produced Ig Zl 1"J I� Ig 20 I$ IS 19 lg
ITotal young produced 3� 3k 31 31 3y 3"1 35 3'L 35 33
Final Adult Mortality L L L ` 1✓ L
=live,D=dead)
Test Concentration:
( %Mortality:
Mean Offs rin emale:
i
%Reduction from Control: ,-1 ,
C;
I' SOP AT13—Exhibit AT13.2,revision 04-01-09
ii

a r=
n • Page 4 of 5
•
O75
'..�s' •�FnW®m,nWhRM19FdWmadc
Species: Ceriodaphnia dubia
Date: 02.O3. 10
Client: U-a k to Gt tanti
4?.
' Concentration: S•�- Survival and Reproduction Data
Replicate number
Day 1 2 3 4 5 6 7 8 9 10
i' 2 Adult mortality
y$, =live,D=dead)
Number
5 Young afb.ds
produced 1 1�S Ig l Igo IS ZO 1& lg
Adult mortality L. L
=live,D=dea
6 or 7 Young °fbroods.Number % L l 1 1 1 1 1 1 1 i8 l
produced ll0 1 g ZO 11 lb - IS %S
Total young produced 38 310 3-L 3b 35 35 33 33
Final Adult Mortality
(L=live,D=dead)
Test Concentration:
%Mortality: p'!.
Mean Offs rin emale: 134.0
%Reduction from Control:
Concentration: 1601. Survival and Reproduction Data
I Replicate number
Day I 1 1 2 1 3 4 1 5 6 7 8 9 10
2 Adultmortality L-
f•- =live,D=dead
L 5 Number z Z L z s
Young ofb-.df
r produced ic} lq l b 1�{ 20 LS t$ ZO 19 19
E Adult mortality L L L L. L L L_ L_
4-� =live,D=dead)
6 or 7 Young eb e l l 1 l I \ \ L� \ 1
produced Z.o I to 15 1 to l 11 1.3 1 1i0
Total young produced 3aL 35 31 &A 36 3'L b•L 33 56 3S
Final Adult Mortality L L L, l_ L L. L- l_ %--
(L=live,D=d
' DyPHNIR Ptteseral'. fteMcde.4 t3`J
Fe7TC- ?KICK TO Test Concentration:
1W%-AobUCrldtJ OF C. boidi %Mortali : 0
' I Mean Offspring/Female: INS
Reduction from Control: I —1 S-•
ISOP AT13—Exhibit AT13.2,revision 04-01-09

j Page 5 of 5
o r•=
fl '
Species: Cerioda hnia du is
Client Date: 02.66 1O
Daily Chemistrw
Da
' Initiation Renewall Renewal2
I.
I Anal st 11 mskj I MwU L
_-K Concentration Parameter
H S.U. I 2 �7 71 oL
CONTROL DO m g Ip o S.O v
Conductivityos/c mhm \S, IloO ��
Alkalinity 33 34
m CaCO/L
Hardness qq 2 m CaCO/L
Temperature C2L U. $ VA.°I 'W"1 LS.I 'L .
j x S.U.
DO m 1.Q to �•7 t3•b
��•�. Conductivity
mhos/cm L°`10 I oLl 1110
J Temperature(Q 1-1.8 `LS•Z .'1 �. .4 1�1•l. tS.O
i x s.u. 8.1"1 .3 l I 0.•f0
DO m in 1
Conductivity Isso 110ib 1�30
mhos/cm
Temperature °C) "LS-O
fifiF. H S.U. 6.2 L f3.43 8 22 2
L DO m 1. ao 9.1 O
Conductivity Id—IO
mhos/om lee)n U30
I Temperature(°C) "LS•O 1`I•d 'L •1 "ZAA I vA
li H S.U.
8-1S B.45 -SL .12
p s% DO m -I.-A t3.
-1 Conductivity 1�30
mhos/cm IC160 5LI30
Temperature °C -LS .O Z5.a 1 •ts.0 "Lll. 1.1
H S.U.
DO m
Conductivity
(gmhostc '
Temperature C
H S.U. 2S d as 0. I 9.52.
100% DO(mg/L) 1,g '�•� �.(p 9.O �,ci 0.0
•J'
Conductivity 2020 A01 0 a,ac►0
mhos/cm
TR chlorine t 0•lQ t0 10
Lm erature C) •0 2S.0
Initial Fioal Initial Final Initial Final
LJ
SOP AT13—Exhibit ATI3.2,revision 04-01-09

Environmental Testing Solutions,Inc.
Ceriodaphnia Survival and Reproduction Test-Reproduction
Start Date: 2/3/2010 Test ID: CdFRCRNC Sample ID: Blue Ridge Paper Products,Inc.
End Date: 2/10/2010 Lab ID: ETS-Envir.Testing Sol. Sample Type: DMR-Discharge Monitoring Report
Sample Date: Protocol: FWCHR-EPA-821-R-02-013 Test Species: CD-Ceriodaphnia dubia
Comments:
Cone-% 1 2 3 4 5 6 7 8 9 10
D-Control 30.000 32.000 28.000 29.000 28.000 27.000 32.000 29.000 27.000 30.000
45 36.000 33.000 32.000 33.000 30.000 35.000 32.000 32.000 35.000 33.000
75 36.000 33.000 33.000 35.000 31.000 32.000 34.000 33.000 34.000 34.000
90 37.000 38.000 31.000 37.000 34.000 37.000 35.000 32.000 35.000 33.000
95 31.000 37.000 38.000 36.000 32.000 30.000 35.000 35.000 33.000 33.000
100 39.000 35.000 31.000 34.000 36.000 32.000 32.000 33.000 36.000 35.000
Transform:Untransformed I-Tailed Isotonic
Cone-% Mean N-Mean Mean Min Max CV% N t-Stat Critical MSD Mean N-Mean
D-Control 29.200 1.0000 29.200 27.000 32.000 6.211 10 33.167 1.0000
45 33.100 1.1336 33.100 30.000 36.000 5.414 10 4.119 2.287 2.165 33.167 1.0000
75 33.500 1.1473 33.500 31.000 36.000 4.280 10 4.542 2.287 2.165 33.167 1.0000
90 34.900 1.1952 34.900 31.000 38.000 6.814 10 -6.021 2.287 2.165 33.167 1.0000
95 34.000 1.1644 34.000 30.000 38.000 7.720 10 -5.070 2.287 2.165 33.167 1.0000
100 34.300 1.1747 34.300 31.000 39.000 7.015 10 -5.387 2.287 2.165 33.167 1.0000
Auxiliary Tests Statistic Critical Skew Kurt
Kolmogorov D Test indicates normal distribution(p>0.05 0.51815635 I.035 0.08991576 -0.5757789
Bartlett's Test indicates equal variances(p=0.50) 4.34398222 15 0862722
Hypothesis Test(1-tad,0.05) NOEC LOEC C11V TU MSDu MSDp MSB MSE F-Prob df
Dunnetes Test 100 >I00 1 2.16485421 0.07413884 41.6666667 4.48148148 2.0E-06 5,54
Treatments vs D-Control
Linear Interpolation(200 Resamples)
Point % SD 95%CL Skew
IC05 >100
IC10 >100
IC15 >100
IC20 >100
IC25 >100 Blue_Ridge_Paper 02-03-10
IC40 >100
IC50 >100

• Y 6. Ceriodaphnia dubia Chronic Whole Effluent Toxicity Test
EPA-821-R-02-013,Method 1000.0 -North Carolina Modification
Quality Control
Verification of Data Entry, Calculations, and Statistical Analyses
Environmental Testing Solutions,Inc. Client: Blue Ridge Paper Products,Inc.
Test dates: February 03- 10,2010
Project number: 5945
Reveiwed by:
Concentration Day Replicate number I Survival Avenge coefficient or Percent reduction from
1 2 3 4 5 6 7 8 9 10 % reproduction variation(%) control(%)
5 13 17 13 13 15 12 IS 15 13 14
Control 7 17 15 15 16 13 15 17 14 14 16 100 29.2 6.2 Not applicable
Total 30 32 28 29 28 27 32 29 27 30
5 18 15 16 18 14 16 17 15 18 18
45% -7 18 18 16 15 16 19 15 17 17 15 100 33.1 5.4 -13.4
Total 36 33 32 33 30 35 32 32 35 33
5 15 15 15 IS 16 14 16 17 15 17
75% 7 21 18 18 17 15 18 18 16 19 17 100 33.5 43 -14.7
Total 36 33 33 35 31 32 34 33 34 34
5 19 17 14 18 15 17 17 17 16 14
90% 7 18 21 17 19 19 20 18 15 19 19 100 34.9 6.8 -19.5
Total 37 38 31 37 34 37 35 32 35 33
5 15 18 - 18 19 16 15 20 18 18 15
95% 7 16 19 20 17 16 15 15 17 - 15 18 100 34.0 7.7 -16.4
Total 31 37 38 36 32 30. 35 35 33 33
5 19 l9 16 19 20 18 15 20 19 19
100% 7 20 l6 15 15 16 14 17 13 17 16 100 343 7.0 -17.5
Total 1 39 1 35 1 31 134 36. 1 32 32 33 36 35
Dunnett's MSD value: 2.165 MSD= Minimum Significant Difference
PMSD: 7A PMSD= Percent Minimum Significant Difference
PMSD is a measure of test precision. The PMSD is the minimum percent difference between the control and treatment that can be declared
statistically significant in a whole effluent toxicity test.
Lower PMSD bound determined by USEPA(I&percentile) =13%.
Upper PMSD bound determined by USEPA(906 percentile)=47°/a.
Lower and upper PMSD bounds were determined from the 101h and 90th percentile,respectively,of PMSD data from EPA's WET
Interlabomtory Variability Study(USEPA,2001a;USEPA,2001b).
USEPA 2001a,2001b.Final Report: Interlabomtory Variability Study of EPA Short-term Chronic and Acute Whole Effluent Toxicity Test Methods,Volumes I and 2-Appendix.EPA-821-B-0I-004 and EPA-821-B-0I-005.US
Environmental Protection Agency,Cincinnati,OIL
Blue_Ridge_Paper_02-03-10

O • 351 Depot Street
® Asheville,NC 28801
Phone: [phone]
Fax: [phone]
Environmental Testing Solutions,Inc.
Whole Effluent Toxicity Chain-of-Custody Form
Facility: Blue Ridge Paper Products,Inc. NPDES#: NCO000272 Pipe#: 001 County: Haywood
Purchase order: 389150
Species: Ceriodaphnia dubia Effluent dilution: 45,75,90,95,100%
Test type: Phase H Chronic Parameter code: THP3B
Sample information: (to be completed by sample collector), t
Composite sample: Sample location: 5 C6 c.1 1i.R:zy lAftJ
Start date: L2 —I — I O Time: W00 R0\ Volume collected for testing: q\\O T.
End date: 'a—& — Jb Time: 1 0:00 jDt , Number of containers filled for testing:
Number of samples per hour: 5 Method of transport to laboratory: (?Aa Q\S 2L
Chilled during collection? O (✓ Comments:
If chilled,specify temperature: 14 OC-1
Triple rinse sample container with sample before filling. Completely fill the sample container with no air space.
Pack the sample container completely in ice. The sample must be<6.0°C upon receipt at the laboratory.
An additional fee of$50.00 per sample will be charged for samples collected before 8:00 AM.
Sample custody: (to be completed by sample collector and facility personnel)
Sample collected by:
Food 11 19, hwWoo, DatnandNm
Relinquished by: 'Received by:
o P zlio lLvs ollw a a is
Pwl $ignam�e Damavd4� Privt $i�lwe Datcavd 4ma
Relinquished by: Received by:
UA/ qua a D I3•
Prva Sigwwe D eand unm RiN Signnum Date and wro
Sample receipt information: (to be completed by ETS personnel)
Relinquished to ETS by: Received at ETS by:
OIL-tne-10
ETSmijen " 1IazS
Pint sjg Dueaod m Pont sw000e Dam end ume
Custody seals intact?: Ea r--1 r--1 Sample temperature upon receipt at ETS(°C):
Y. No Nuvmd 1• 1
Samples received in good condition?:
Y. No Total residual chlorine upon receipt at ETS: =
-1 (DPD Presence/Abseme Indicator,Iv1DL-0.10 mg/L) A^
Tracking number: r 14 �i;
Project number:v'lu5 Sample number {002(20-
Comments•

® • 351 Depot Street
® Asheville,NC 28801
�` Y. Phone: [phone]
F _.... Fax: [phone]
Environmental Testing Solutions,Inc.
Whole Effluent Toxicity Chain-of-Custody Form
Facility: Blue Ridge Paper Products,Inc. NPDES#: NC0000272 Pipe#: 001 County: Haywood
Purchase order: 389150
Species: Ceriodaphuia dubia Effluent dilution: 45,75,90,95, 100%
Test type: Phase H Chronic Parameter code: THP3B
Sample information: (to be completed by sample collector)
Composite sample: Samplelocation: C ,Vt:�t.tcl♦ g;e SLZ(t4 t
Start date: a-4 —k-C> Time: Sb-0 b A Volume collected for testing: I J&A\kt'0
End date: %— 5 —1 a Time: j b =00 A Th Number of containers filled for testing:
Number of samples per hour: S Method ofttansport to laboratory:
Chilled during collection? 14 0C. V`LS Comments:
If chilled,specify temperature: 1*°t✓
Triple rinse sample container with sample.before filling. Completely fill the sample container with no air space.
Pack the sample container completely in ice. The sample must be<6.0°C upon receipt at the laboratory.
An additional fee of$50.00 per sample will be charged for samples collected before 8:00 AM.
Sample custody: (to be completed by sample collector and facility personnel)
Sample collected by:
Ai
Pnm Sir Dazemdc
Relinquished by: Received by:
a-S-10 v
5 W�� to as gar- /PARR �EEiV,91,
Pnnt Signwte Dare avdeme tiet 'D=— Daremdome
Relinquished by: Received by:
Pont Signaum Danmdaena Peiot Si®atum Dmemd ntrc
Sample receipt information: (to be completed by ETS personnel)
Relinquished to ETS by: Received at ETS by:
r^NRQ ��1 o2`S•l0 o'L•OC•lo
EEVfW ; OO�vY %MoHtael� I100
wt - Dazeaednme Pnnt Sigumm - DmeaodW
Custody seals intact?: r7 Sample temperature upon receipt at ETS(°C): f
Y. No Nttu �.�•�+
Samples received in good condition?:
Ye No Total residual chlorine upon receipt at ETS:
(DPD Presence/Absense indicator,MDL-0.10 mg(L)
Tracking Dumber. fJA
Project n,umber: gq-5 Samplenumber. IM0205•03
Comments:

® rF 1 Ceriodaphnia dubia
z` Chronic Reference Toxicant Control Chart
0 Precision of Endpoint Measurements
Environmental Testing Solutions,Inc.
40
d35 — _ .....�.........�.................... — — — .....
b8 30 ............................................. ............................................
a25
C
w 20
q o
o
Minimum Acceptance Criteria(> 15.0 offspring per surviving female)
q40 _.._.._.._.._.._.._. _.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._..
o North Carolina Acceptance Limit(<40.0%)
o "
o
Kentucky Acceptance Limit(<30.0%)
0 0 20
e~ U 10 .................................................
.. ............. .... .....
U
50
USEPA Upper PMSD Hound(906'percentile<47.0%)
40
30
A
rn
a 20
10
0 ob�q 3 oq 1AAq,o oq,A�q oS oq o5 oq oq oq oq oq,$oq A��q o8,oq oA oq%9-,5 vo.oq ob oq, -,vAA9,oA9 oti,o oa p9 oSAO tiAO
off' op
oti' %V o 05" 05" O6" ob" ob" o� oa� oa. No. titi, off.
Test date
• Control Reproduction, Coefficient of Variation (CV), or Percent Minimum Significant Difference
(PMSD) PMSD is the minimum significant difference between the control and treatment that can be
declared statistically significant.
— — Central Tendency (mean Control Reproduction, CV, or PMSD)
••••••••• Control Limits (mean Control Reproduction, CV, or PMSD f 2 Standard Deviations)

= h,, Ceriodaphnia dubia
Chronic Reference Toxicant Control Chart
Environmental Testing Solutlons,Inc
1.14 USEPA Control Limits (f 2 Standard Deviations)
1.12
1.10 ............
1.08
1.06
....................................................
1.04 ..
1.02
2.5
U USEPA Warning and Control Limits (75th and 90`h Percentile CYs)
eQ 2.0
z ..........................................................................................
1.5 —..—..—..—..—..—..—..—..—..—..—..—..—..—..—..—..—..—..—..—..—..—..
U • ��- • • • • • • •—• • • • • • • •
1.0
�-1
.p 0.5 .........................................................................................
t`
1.4
1.3 Laboratory Warning and Control Limits (10rh and 25th Percentile CYs)
..............................................................0...........................
1.2
On
1.1
1.0 —..—..—..—..—..—..—..—..—..—..—..—..—..—..—..—..—..—..—..—..—..—..—..—..
0.9 ..........................................................................................
0.8 09 09 09 09 CH CB 09 09 09 09 09 09 o 09 09 09 009 ♦p 1p
Ovq* p103' a Or O"S" Qo" ' Ow05& 0G.p9" %0 *X 'P-z p&p� o8"OM p9.1y ,p-* -OWvk -.11a NT & ZN& a
Test date
• 7-day IC25=25%inhibition concentration. An estimation of the concentration of sodium chloride
that would cause a 25%reduction in Ceriodaphnia reproduction for the test population.
— — - Central Tendency (mean IC25)
-- —••- Warning Limits (mean IC25 f SAI, or SA.75)
........• Control Limits (mean IC25:L SA-251 SA.901 or 2 Standard Deviations)

• CCU p�
• PO Box 7565
Asheville,NC 28802
® Phone: [phone]
Fax: [phone]
FTS E-mail: JimSumner®aol.com
Environmental Testing Solutions,Inc.
March 15,2010
Ms.Lori Cooper
Blue Ridge Paper Products,Inc.
PO Box 4000
Canton,NC 28716
RE: ETS PROJECT NUMBER: 6009
Dear Ms. Cooper:
Enclosed are toxicity test results for samples from the Blue Ridge Paper Products,Inc.received by
Environmental Testing Solutions,Inc.March 02 and March 05 2010.
Parameter Test Procedure EPA Method Final Result
Code Number
North Carolina Phase II Chronic Whole
THP3B Effluent Toxicity Test Procedure— EPA-821-R-02-013 ChV =97.5%
July 1991,Revised:February 1998
(Ceriodaphnia Full-range Toxicity Test)
Note: ChV=Chronic Value. A numeric value representing the geometric mean of the highest concentration
having no detectable impairment of survival or reproduction and the lowest concentration that does have a
detectable impairment of survival or reproduction.
If this test was performed as an NPDES requirement or by Administrative Letter,please enter the ChV
value 97.5%on the Effluent Discharge Monitoring Form(MR-1)for the collection date
March 01,2010 using the parameter code TBP3B.
Additionally,please sign and submit the original DWQ Aquatic Toxicity Form(AT-3)by
April 30,2010.
If you have any questions concerning these results,please feel free to contact me.
Sincerely,
tyr.w��
i
' m umner
Laboratory Director
i
1
i
This report should not be reproduced,except in its entirety,without the written consent of Environmental Testing Solutions,Inc.
The results in this report relate only to the samples submitted for analysis.
North Carolina Certificate Numbers: Biological Analyses: 37,Drinking Water: 37786,Wastewater: 600
South Carolina Certificate Number: Clean Water Act: 99053-001

• FT PO Box 7565
Asheville,NC 28802
Phone: [phone]
® m ;, Fax: [phone]
E-mail: [e-mail]
Environmental Testing solutions,Ina
Effluent Aquatic Toxicity Report Form-Phase II Chronic Cerlodaphnia dubla Date: March 15,2010
Facility:Blue Ridge Paper Products,Inc. NPDES#: NC-0000272 Pipe#: 001 County: Haywood
Laboratory Performing Test: Environmental Testing Solutions,Inc. Comments: .
Signature of Operator in Responsible Charge:
Signature of Laboratory Supervisor: x Project 6009
Samples: 100302.07.100305.02
Mail Original To:North Carolina Department of Enviromnent and Natural Resources
DWQ1 Environmental Sciences Branch
1621 Mail Service Center I Stan date: I End data; 1 Stautime: 1 End time:
Raleigb,NC 27699-1621 1 03-03.10 1 03-10-10 1 1324 1 0737
Sample Information I Sample I Sample2 I Control
Collation area date: 03-01.10 03-04-10 Test Information am Rmaetr R 21 son nor 1 nau.ar
Grab: Treatmeat: t00% t00% t00% Control Control Central
Composite duration 24-h 24-h - Initial PH(St): 8.52 8.54 8A3 7.77 7.81 7.80
AlWi-ry(my/LC,CO3): 35 FinalpH(su): 8.85 8.83 8.73 7.73 7.94 7.61
Hmdaess(m8/L Cn(305): 42 Initial DO(mg/L): 8.0 7.8 7.7 7.9 8.0 7.9
ConduchM(µmhodon): 3290 2930 165.170.149 Rod DO(mg/L): 7.7 7.6 8.1 7.8 7.9 7.6
.Towlr6idual chimme(mg/L): -0.10 <0.10 Initial Temp.CC): 25.1 249 252 24.9 24.7 24.6
Sample Temp.at Receipt(Q: 2.7 0.7 FWdTempa('C): 25.0 24.9 24.7 24.9 24.7 24.8
Organism Nmaba
Control Organisms 1 2 3 4 5 6 7 8 9 10 m® Chronic Test Results
Number of Young Produced 31 31 30 28 31 133 132 30 130 31 3077 Find Control Mortality(%: 0
AduitSurvival: ive ead L L L L L L L I. L L %Conhoiwith3rd13mods: TO
t
Caatrol uctiw CV: 4.4
Effluent Percentage 45% 48 HomM
Treatment 2 Organisms 1 2 3 4 5 6 7 8 9 10 roan trot: r of 10
N, a ofYoimg Produced 136 131134 135 138 134 33 35 135 30 34.1 twc: 0 of 10
Adult Survival: ive ead I L I L I L I L I L I L L L L L -11.1 siloafficeA No
xaa4vn® final Mortahtysigni5cantat No Cone
Effluent Percentage 75%
Treatment Organisms 1 2 3 4 5 6 7 8 9 10 m®o Reproduction Analyses
.Number of Young Produced 135 132 31 36 34 133 135 134132 135 1 33.7 'anLoEc: tor%
Adult Survival: ive ad L L L L L L L L L L .9.8 'ortNOEC: 93%
% Overall Method: Steels may
i Effluent Percentage 90% Normal Dombmion: Yes
Treatment 4Organisms 1 2 3 4 5 6 7 8 9 10 MonoMethod: xolmo orevD
NmnberofYoun Produced 1291321321311271321281321291301 30.2 Statisic: 0.820
( Adult Survival: (L)ive,(D)eadj L I L I Ll Ll Ll L ILI Ll Ll Ll 1.6 1 Cedcal Value: 1.035
56am
Equal Variances: No
Effluent Percentage 9sY. Method. 13ardenTest
Treatment 5 Organism 1 2 3 4 5 6 7 8 9 10 m® Statistic: 31259
Number of Young Produced 125 128 122 124 125 126 124 128 127 126 25.5 Critical Value: 15.096
Adult Survival: ive (D)cad I L I L I L I L I L I L I L I L I L I L 1 16.9 Non-Pammehic Ambns it liable)
x Method: Steels harry One
Effluent Percentage lOo% E®n.-A Rank Sum Critical gum
Treatment 6 0 eaisms 12 3 4 5 6 7 8 9 10 moo 45% 143.0 75.0
I Number ofYoon Produced 1 191281201 Ill 121121 9 1 17120111 15.9 75% 1473 75.0
+f Adult Survival: ive ead I L I L I L I L I L I L I L I L I L IL 48.2 W% 100.0 75.0
56Fod� 95°/a 56.0 75.0
Overall Analysis: 100% 55.5 7s.o
# Result: PASS LOEC: 100% NOEC: 95% ChV: 97.5%
j DWQjormAT-3(8/91)Rev.11/95

Page 1 of 5
O* E75
North Carolina Phase lI Chronic Whole Effluent Toxicity Test
I (EPA-821-R-02-013 Method 1002.0,NC Modification-February,1998)
Species: Cerlodaohnia dubla
Client: 1 BLU ff these pkpmNPDES#: NC 1,'I
I 2—
Facility: OutleWPi e: opt
County: IWC
Comments:
I
Test organism source information: Test In ormaHon:
IOrganism <24-hours old Randomizin tem late coIrbal-
Date and times organisms were bom OS-01 tO' 0"1 TO [3eb Incubator number and sh
between: location:Cultum board: QL• -10Replicate number: z 2 a s a r e s m Ywr batch:
Culture board cu number. 1 7- 5 -1 11 IL t Ib 1 Transfer bowl information: H- 1 3 SU Tem erature= 2 °C Selenastrum batch:.
I Dilation aratian information: Sam le collection Information.
Concentration C�e �0 9S 106 Sample Sample
Y
Sample vobone 90 � 1eo 'vo zoo Collection start date:• 03-01•!0 Ob-01.10
Dluem volume Collection end time:
M 11D (7U 20 10 O 1000 1000
T�volume � � Z� Grab/Camposite 1,q-14odQ 'LAOAOUL
( ) duration• L MPOS
i Temperature CC) . 2-�.C-
0.-1•C
u on meet t: A- a
Physical IM13 �IP.u.Ow
characteristics: T L100L�ErS project numETS sample numb /O030S.QL_
Daily renewal information:
Day Date Test initiation, Control/Dilution Sample numbers Analyst
I ` renewal,feeding,or water batch used used
f termination time Softs thetic
0 03pal0 towwoeenaiasas O•L•23•tD OIJ*40 •61
1 03.0$•►0 ;R--il
0 12 C�O$ Fmreg LbO Ion3 O3.010.LO4 p3o�j.l0 '11Oa►5 aSt� l00-1 Orl.-TS-10 t06bOs•01.-
0 �StY,l1O 1101
7 CfsID1u r�.,pn .
I Control information: Acceptance criteria summary of test endpoints.,
%of Male Adults: s 20% 7-dav LCsoN-1091.
%Adults having 3 Broods: Inowl. t 80% NOEC
%Mortality: iJ 520% LOEC 1t7O'
Mean Offspring/Female: __3Ckt j Z 15.0 offsprinp/female ChV
%CV: LIM <40.0% IC25
4 SOP AT13—Exhibit AT13.2,revision 04-01-09

eta ;5 Page 2 of 5
ini0mv,jdTeMGSoWbnilw
Species: Ceriodaphnia dubia
Date: OB-n•►O
Client: l��ae 2lect PAeee
Y;
CONTROL Survival and Reproduction Data
Replicate number
Day 1 2 3 4 1 5 1 6 7 8 9 10
2 Adult mortality' L L
=liveive Ddead
5 Nmb,r t
Young °fbmeds
produced %-1 1$ 1a I'A It 18 15 11 1%4 1p
e5 - Adult mortality
_ -live,D=de
6 Nimbef 1 1 1 1 l ► 1 1 1 Young orbm°de 1
produced iw . 16 1q 114 13 IS 11 13 11. Ilo
Total young produced 3 30 3�
at) 24 31 33 3Z 3b
Final Adult Mortality
'! =live D=dc4
X for 3 Broods
' Control:
rI %Mortality: OY.
Mean Offs rin emale:
c
qq
Concentration: 5 76 Survival and Reproduction Data
Replicate number
Day 1 2 3 4 5 6 7 8 9 10
e ;> 2 Adultmortaaly L
=liv D=dead)
5 Young oe6�w; I- 1 ZLi.. 2
produced 11, 19 Id} 1$
Adult mortality ` �• 1_ L° L t_
=Iive,D=dead
6 or 7 Young dbmabe 1 1 1 1 1 1 l 1 \ \
produced 1-1 1(0 1 18 ZO lip 11 1.6 16 15
Total young produced al. '3\ 3`4 35 3$ IM 33 35 JS 30
Final Adult Mortality L L ti✓ L L !` >✓
=live,D=dead)
Test Concentration:
%Mortality: 0 .
Mean O rin emale: ' 1
%Reduction from Control:
SOP AT13—Exhibit AT13.2,revision 04-01-09
j

+_. • y Page 3 of 5
0 T
a=: �wbwmmmroe•sam=a�.
ea
Species: Ceriodaphnia dubia
Date: 6i-tS3.1 O
Client: 6Lu2 A%tke PAmt
Il . Concentration: IS7o Survival and Reproduction Data
Replicate number
Day 4 5 1 6 7 'S 9 10
2 Adult mortality L L L
=live,D-dea
LL
xmnber L
5 Young ofb.ds s �. �'
produced 1$ 1 1 ZO IIo 1 01 1& 1 IS 1 g
Adult mortality°. =live D=dea
I` 6 or 7 Young ofrouar 1 1 1 1 1 1 1 1 I 1
�{ produced 11 Is lip 16 Ice 14 11 IS I t(.
Total young produced
35 32. 31 36 34 3b 35 3t•I 3Z 35
Final Adult Mortality L L L l L L L L L
-live,D=d
(' Test Concentration:
%Mortality: 'le
Mean Offsp emale:
%Reduction from Control:
a"
Concentration: a07• Survival and Reproduction Data
Replicate number
Day 1 1 2 1 3 4 5 6 7 S 9 10
2 Adult mortality L- I— L
=live,D=dea
5 Young Mbmo xmbmde 2. 7. IL 121 1 2
produced lq Ito Ile is 1 1/ IS '1'j 1S 1(to
Adult mortality L L I. L
' -live,D-den
6 or 7 Young oPbmo�df ! I =1 1 1 I 1 ► I 1
produced 16 'to 16 I to 113 1s 13 17 1 y I'{
Total young produced ZS 32 3Z 31 27 3Z 28 37 2�1 3O
Final Adult Mortality L L L L l L L L L
=live,D=dead)
Test Coneentratlan:
%Mortality: orl.
Mean Offs rin emale: 30.
%Reduction from Control:
SOP AT13-Exhibit AT13.2,revision 04-01-09

TS
Page 4 of 5
e
f..
fy1 r.wom.mumv�rdmaiume
Species: Ceriodaphnia dubia
Client: 8we 91ba Oma Date: tt3-03-lO
Concentration: aS7. Survival and Reproduction Data
Replicate number
} Day 4 5 6 7 8 9 10
r . 2 Adult mortality � L.— � L— L— L I-- L-- L �
=Gve,D=d
5 Young oProb odf 1
produced 1 1 t-L IS 1Z 1`'{ 1 13 1`+
Adult mortality
=live,D=dcad)
6 or 7 Young. afb�ioodA¢ 1 1 1 1 1 1 1 1 7 1
produced q 13 1 10) 114 1 q I L
Total young produced 2S Z� ZZ 7� 2yS Z(o 2c( ZII 7-1 7-6
Final Adult Mortality
i, (L—fim D=dead)
Test Concentration:
%Mortality:
O%•
Mean Offspring/Female: $
%Reduction from Controb Ib '
A.:
i.
Concentration: l Qpya Survival and Reproduction Data
Replicate number
#" Day 1 2 '3 4 5 6 7 8 9 10
2 Adult mortality
=live,D=dead)
' Number
5 Young dbread. 1 l . 1 1 1 ,1 1 7 t
produced l 13 I Q "l B �' I Z 13 S
AdultmurtWlty L L �. L L L it, L L.
=live D=dcad)
6 or 7 Young Number 1 1 I 1 1 1 5 1 , 1 S 1 l
produced 5 1 10
Total.you ng produced 1of 7-T Z,O I 1?- 12_ q 11 20 I
Final Adult Mortality L L L t_ L L L L L
=liv D=dead)
Test Concentration:
%Mortalit3r, 001.
Mean Offs rin emale:
%Reduction from Control: 64455-2'
SOP AT13—Exhibit AT13.2,revision 04-01-09

U TTS�: Page 5 of 5
w ai_
Species: Ceriodanhnia dnbia
' Client: $W0 P-maL Pwle2 Date: O'3-M,10
Daily Chemistry:
Da
Initiation Ran ewalI Renewal
Analyst
Concentration Parameter
H S.U. ( ® ?Jd
_ CONTROL DO m
Conductivity lb$ LID
(pmhos/cm
Alkalinity
(mg CaCO
al:? Hardness ,1
m (8Ct) '1Z+
Temperature C) 14-11 :q ta.9 `l. .6 L`1•&
H S.U. too 9+6► .37 6.y
t: .t DO m .O -7. 9.7..
5. Conductivity /
p mhos/cm b Ito '" ZU
tl Temperature '1 A V{ •(1 1.1
H S.U. 9-L41 11l0$
DO m
1S('a Conductivity
mhos/cm) C)
Temperature C 75. 1S. 1q.Q O lA.8 U1•b
H S. b.(- cl
DO m 9.0 0•
�olu Conductivity 1�Z-Ls-tu)
3o2Z) 2&&
mhos/cm
k^ Temperature C tS•OZq•b 7.114 b5.0 Its•1
H S.u. 5 53 - v
DO m 8.0 •8 7.7 7 O
g57a Conductivity '
mhos/cm 1b0a24 Z 7 7 0
Temperature C LS. 2 7. . 15.D ,6
H S.U.
D
Conductivity �I
mhos/cm "rT�CJ"
Temperature C)
H S.U. SZ ;Final
100% DO(my/L)Conductivity 3t8Umhos/cm TRchlorine 010mTem erature 1S.1 t IS.7— lvi%q
InitialInitial Final Initial -Final
SOP AT13—Exhibit AT13.2,revision 04-01-09

•
O F
Environmental Testing Solutions,lnc
Ceriodaphnia Survival and Reproduction Test-Reproduction
Stoll Date: 3/32010 Test ID: CdFRCRNC Sample ID: Blue Ridge Paper Products,Inc.
End Date: 3/I02010 Lab M: ETS-Envir.Testing Sol. Sample Type: DMR-Discharge Monitoring Report
Sample Date: Protocol: FWCHR-EPA-821-R02-013 Test Species: CD-Ceriodapbmadubia
Comments:
Conc% 1 2 3 4 5 -6 7 8 9 10
D-Control 31.000 31.000 30.000 28.000 31.000 33.000 32.000 30.000 - 30.000 31.000 {'
45 36.000 31.000 34.000 35.000 38.000 34.000 33.000 35.000 35.000 30.000
75 35.000 32.000 31.000 36.000 34.000 33.000 35.000 34.000 32.000 35.000
90 29.000 32.000 32.000 31.000 27.000 32.000 28.000 32.000 29.000 30.000
95 25.000 28.000 22.000 24.000 25.000 26.000 24.000 28.000 27.000 26.000
100 19.000 28.000 20.000 11.000 12.000 12.000 9.000 17.000 20.000 11.000
Transform:Untransformed Rank I-Tailed Isotonic
Conc"/o Mean N-Mesa Mean Min Max CV% N Sum Critical Mean N-Mean
D-Control 30.700 1.0000 30.700 28.000 33.000 4.357 10 32.833 1.0000
45 34.100 1.1107 34.100 30.000 38.000 6.836 10 143.00 75.00 32.833 1.0000
75 33.700 1.0977 33.700 31.000 36.000 4.856 10 147.50 75.00 32.833 1.0000
90 30.200 0.9837 30200 27.000 32.000 6.205 10 100.00 75.00 30.200 0.9198
•95 25.500 0.8306 25.500 22.000 28.000 7.452 10 56,00 75.00 25500 0.7766
•100 15.900 0.5179 15.900 9.000 28.000 37.320 10 5550 75.00 15.900 0.4843
Auxiliary Tests Statistic Critical Skew Kurt
Kohnogorov D Test indicates normal distribution(p>0.01) 0.82039492 1.035 0.91295727 4.88340348
Bartlett's Test indicates unequal variances(p=833E-06) 31.2592087 15.0862722
Hypothesis Test(1-tail,0.05) NOEC LOEC ChV TU
Steers Many-One Rank Test 90 95 92.46621 1.1 1111111
Treatments vs D-Control
Linear Interpolation(200 Resamples)
Point % SD 95%CL Skew
IC05 84.351 2.145 81.410 90.043 0.7982
IC10 90.691 0.947 87.820 91.713 -1.8817
IC15 92.438 0.532 91.297 93A68 -0.0982
IC20 94.184 0.559 93.112 95.118 -0.1078
IC25 95.456 0.336 94.676 96.094 -0.4959
IC40 98.021 Blue Ridge Paper 03-03-10
IC50 99.731

Q F
<>+
Environmental Testing Solution's,Inc.
PMSD Calculation Only, Ceriodaphnia Survival and Reproduction Test-Reproduction
Start Date: 3/32010 Test ID: CdFRCRNC Sample ID: Blue Ridge Paper Products,Inc.
End Date: 3/102010 Lab ID: ETS-Envir.Testing Sol. Sample Type: DMR-Discharge Monitoring Report
Sample Date: Protocol: FWCHR-EPA-821-R-02-013 Test Species: CD-Ceriodaplmiadubia
Comments:
Conc°/a 1 2 3 4 5 6 7 8 9 10
D-Control 31.000 31.000 30.000 28.000 31.000 33.000 32.000 30.000 30.000 31.000
45 36.000 31.000 34.000 35.000 38.000 34.000 33.000 35.000 35.000 30.000
75 35.000 32.000 31.000 36.000 34.000 33.000 35.000 34.000 32.000 35.000
90 29.000 32.000 32.000 31.000 27.000 32.000 28.000 32.000 29.000 30.000
95 25.000 28.000 22.000 24.000 25.000 26.000 24.000 28.000 27.000 26.000
100 19.000 28.000 20.000 11.000 12.000 I2.000 9.000 17.000 20.000 11.000
Transform:Untransformed 1-Tailed Isotonic
Conc-% Mean N-Mean Mean Min Max CV% N t-Stat Critical MSD Mean N-Mean
D-Control 30.700 1.0000 30.700 28.000 33.000 4357 10 32.833 1.0000
45 34.100 I.1107 34.100 30.000 38.000 6.836 10 -2.577 2.287 3.017 32.833 1.0000
75 33.700 1.0977 33.700 31.000 36.000 4.856 10 -2.274 2.287 3.017 32.833 1.0000
90 30.200 0.9837 30.200 27.000 32.000 6.205 10 0.379 2.287 3.017 30.200 0.9198
•95 25.500 0.8306 25.500 22.000 28.000 7.452 10 3.941 2.287 3.017 25.500 0.7766
•100 15.900 0.5179 15.900 9.000 28.000 37320 10 11.216 2.287 3.017 15.900 0.4943
Auxiliary Tests Statistic Critical Skew Kurt
Kolmogorov D Test indicates normal distribution(p>0.01) 0.82038492 1.035 0.91295727 4.88340348
Bar0etfs Test indicates unequal variances(p=8.33E-06) 31.2592087 15.0862722
Hypothesis Test(1-tail,0.05) NOEC LOEC C11V TU MSDu MSDp MSB MSE F-Prob df
Darmetrs Test 90 95 92.46621 1.11111111 3.01728336 0.09828285 467.51 8.70555556 9.6E-20 5,54
Treatments vs D-Control
Linear Interpolation(200 Resamples)
Point % SD 95%CL Skew
IC05 84.351 2.366 81.031 90.187 0.6408
ICIO 90.691 I.035 87.240 91.653 -2.I095
IC15 92.438 0.556 91.214 93.453 -0.2323 .
IC20 94.184 0.574 93.218 95.227 0.0863
IC25 95.456 0.343 94.744 96.072 0.2214
IC40 98.021 B1ue Ridge Pape?j3-03-10
IC50 99.731

• -,, sa(�,.� +;'''•' , ""+:;s;a Ceriodaphnia dubia Chronic Whole Effluent Toxicity Test
• EPA-821-R-02-013,Method 1000.0-North Carolina Modification
Quality Control
Verification of Data Entry, Calculations,and Statistical Analyses
Environmental Testing Solutions,Inc. Client: Blue Ridge Paper Products,Inc.
Test dates: March 03-10,2010
Project number: 6009
Revelwedby: -
1
Concentration Day Re Bute number Survival Average caemnr^M or Per®rreaaioo Gore --
1 2 3 4 5 6 7 8 9 10 % reproduction vrtLtlon(%) WOW(u).
5 17 15 16 14 18 18 15 17 14 15
Control 7 14 16 14 14 13 15 17 13 16 16 100 30.7 4.4 Not applicable
Total 31 31 30 28 31 33 32 30 30 31
5 19 " 15 19 17 18 18 16 19 19 15
45% 7 17 16 15 1s 20 16 17 16 16 15 100 34.1 6.8 -11.1
Total 36 31 34 35 38 34 - 33 35 35 30
5 18 17 15 20 16 19 19 19 15 19
75% 7 17 15 16 16 18 14 17 15 17 16 100 33.7 4.9 -9.8
Total 35 32 31 36 34 1 33 35 34 32 35
5 19 16 16 11 14 17 15 15 15 16
90% 7 to 16 16 16 13 IS 13 17 14 14 100 30.2 6.2 1.6
Total 29 32 32 31 27 32 28 32 29 30
5 17 15 12 15 12 14 14 14 13 14
95% 7 8 13 10 9 13 12 10 14 14 12 100 255 75 16.9
Total 25 28 22 24 25 26 24 28 27 26
5 14 13 10 4 8 4 4 12 13 5
100% 7 51 15 1 10 1 7 4 8 5 5 7 6 100 15.9 373 48.2 _
Total 1 19 1 28 1 20 1 11 12 12 9 17 20 11 11
Ounnett's MSD valve: 3.017 MSD= Minimum Significant Difi'erence
PMSD: 9.8 PMSD= Percent Minimum Significant DiD'ereace
PMSD is a measure of test precision. The PMSD is the minimum percent differrace between the control and treatment that can be declared
statistically significant in a whole effluent toxicity test
Lower PMSD bound determined by USEPA(10"percentile) —13o/a
Upper PMSD bond determined by USEPA(90m percentile)=47%.
Lower and upper PMSD bonds were determined from the loth and 90th percentile,respectively,of PMSD data from EPA's WEr
mteriaboramry Variability Study(USEPA,2001a;USEPA,2001b).
USEPA. 2001a,2001b.Final Report mterlabomtory Variability Study of EPA Short-tern Chronic and Acute Whole Effluent Toxicity Test Methods,Volumes I and 2-Appendix.EPA-821-B-01-004 and EPA-821-B-0I-005.US
Environmental Protection Agency,Cinciunaty OIL
Blue Ridge Poper_03-03-10

351 Depot Street
• Asheville,NC 28801
® Phone: [phone]
,: Fax: [phone]
® Environmental Testing solutions,Inc.
Whole Effluent Toxicity Chain-of-Custody Form
Facility: Blue Ridge Paper Products,Inc. NPDES#: NC0000272 Pipe#: 001 County: Haywood
Purchase order: 389150
Species: Ceriodaphnia dabia Effluent dilution: 45,75,90,95,100%
Test type: Phase H Chronic Parameter code: THP3B
Sample information: (to be completed by sample collector) _t_
Composite sample: Samplelocadon: szgcOtJkAM-mil 2LOx 11KV,
Start date: 1 O Time: 1 00{il`\ Volume collected for testing: e,PM(i U
End date: 3/a/ l o Time: L O'00% Number of containers filled for testing: 1
Number of samples per hour: Jr Method of transport to laboratory: e u2 9-t? P-
Chilled during collection? yL 5 Comments:
If chilled,specify temperature: I130l'
Triple rinse sample container with sample before filling. Completely fill the sample container with no air space.
Pack the sample container completely in ice. The sample must be<6.OeC upon receipt at the laboratory.
An additional fee of$50.00 per sample will be charged for samples collected before 8:00 AM.
Sample custody: (m be completed by sample collector and facility personnel)
Sample collected by:
/tfli
P S' a Da:amdtlme
Relinquished by: Received by: .
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Relinquished by: Received by:
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Sample receipt information: (to be completed by ETS personnel)
Reliuqulshed to Irl'S by: Reeved at ETS by:
nSJM*gl4 Ob•vL•t0
= {y t
Ma bwo Dab W fima
Custody seals intact?: M M Sample temperature upon receipt at ETS CC): �
Samples received in good condition?: ED M �•
Y. N. Total residual chlorine upon receipt at ETS:
(DPD Presence/Absense Indicator,NML-0.10 mg/L) ,T
Tracking number. [JR
III Project number.WQ1 Samplenumber.
j Comments:
I
1

• 351 Depot Street
• Asheville,NC 28801
0 Phone: [phone]
n.;r _.,,: Fax: [phone]
Environmental Testing Solutions,Inc.
Whole Effluent Toxicity Chain-of-Custody Form
Facility: Blue Ridge Paper Products,Inc. NPDES#: NC0000272 Pipe#: 001 County: Haywood
Purchase order: 389150
Species: Ceriodaphnia dubia Effluent dilation: 45,75,90,95,100%
Test type: Phase H Chronic Parameter code: TEIP3B
Sample information: (to be completed by sample collector)
Composite sample: Sample location:
Start date: 3 W A a Time: Q R M_ Volume collected for testing: NJ Gm\O 0
End date: T110 Time: (0 -AM Number of containers filled for testing: k
Number of samples per hour: S Method of transport to laboratory: C),�Lgm\ f P-
Chilled during collection? y Comments:
If chilled,specify temperature: 2'[
Triple rinse sample container with sample before rdling. Completely fill the sample container with no air space.
Pack the sample container completely in ice. The sample must be<6.0aC upon receipt at the laboratory.
An additional fee of$50.00 per sample will be charged for samples collected before 8:00 AA
Sample custody: (to be completed by sample collector and facility personnel)
Sample collected by:
Riv[ b OrteavEtlm
Relinquished by: Received by:
W£if�FR 3(5��'f5i4 EA p S
Prat Si®uave Oak avdeue Rut Signuvn nakaoatimo
Relinquished by: Received by:
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PnR bibo aueeadome Prat 55qukrt Uaa==
Sample receipt information: (to be completed by ETS personnel)
Relinquished to ETS by: Received at ETS by:
I�1FX�enart '�1 O�lzzz
P�iu Siswova DuamEome P�iN bl4^auR OakmEome
Custody seats Intact?—M r--I M Sample temperature upon receipt at ETS CQ: f}
Y. No Na a oa 7 Z•
Samples received in good condition?:
Y. N. Total residual chlorine upon receipt at ETS:
(DPD Presence/Absense indicator.WL-0.10 mg/L) P""t i1 M
Tmcldng number: ?4A
Project number Sample number.
Comments:

s
Ceriodaphuia dubia
® Chronic Reference Toxicant Control Chart
(*DFTS Precision of Endpoint Measurements
Environmental Testing Solutions,Inc.
40
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20
Minimum Acceptance Criteria(>15.0 offspring per surviving female)
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Test date
i
t Control Reproduction,Coefficient of Variation(CV),or Percent Minimum Significant Difference
(PMSD) PMSD is the minimum significant difference between-the control and treatment that can be
declared statistically significant.
—— Central Tendency(mean Control Reproduction, CV, or PMSD)
......... Control Limits (mean Control Reproduction,CV,or PMSD t 2 Standard Deviations)
i

•
• Ceriodaphnia dubia
F �: Chronic Reference Toxicant Control Chart
T
Environmental Testing Solu[lons,lna
1.14 USEPA Control Limits (f 2 Standard Deviations)
1.12
1.10 •..............
1.08
1.06
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1.04 ................................
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2.5
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C: 2.0
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..........................................................................................
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1.1
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Test date
7-day IC25=25%inhibition concentration. An estimation of the concentration of sodium chloride
that would cause a 25%reduction in Ceriodaphnia reproduction for the test population.
—— • Central Tendency (mean ICZs)
—••—••- Warning Limits(mean ICZs}SA.10 or Snas)
I ......... Control Limits (mean IC25 f Sa 29 Sa901 or 2 Standard Deviations)

ISevergreeff
packaging
Blue Ridge Paper Products Inc. - Canton Mill / Waynesville Plant
19 March 2010 CERTIFIED MAIL,RETURN RECEIPT REQUESTED
7004 0750 0000 0865 7285
Roger EdwardsLE
Regional Supervisor
Division of Water Quality
North Carolina Department of Environment J L MAR Z 2 2010
and Natural Resources ' l
2090 US Highway 70 v r,c [TY iota
Swannanoa,North Carolina 28778 r =. `ice
Subject: Utility Contractor Damage to Canton Mill Landfill Leachate Force Main 3-16-2010
Unanticipated By-pass, NPDES NC0000272
Dear Mr. Edwards—
This is the 5-day report required by permit following our telephone report to Keith Haynes on 3/17
concerning an environmental release associated with utility contractor damage to the force main that
conveys leachate from our No. 6 landfill to the Town of Canton sewer system. Pike Construction -a
contractor working for Progress Energy - was installing temporary power poles for line work along
Champion Drive on the north side of the Pigeon River at Fiberville in Canton. At about 5:20 pm on 3/16,
the contractor angered into the mill's leachate force main which is at a depth of 5 feet in the right of way
along the side of Champion Drive. The contractor immediately notified the Town of Canton who notified
the mill. The landfill leachate pumps were stopped at 6:41 pm,and the Town isolated the discharge end
of the force main from the Town's Fiberville pump station at 8:35 pm. The landfill pumps were then
locked, and the force main remained isolated from the Town's Fiberville pump station awaiting repair.
Repairs to the damaged force main were completed on 3/17. The leachate pumping system was restored
to normal operation about 3 pm on 3/17. Town of Canton personnel assisted with verifying the integrity
of the repair before the excavation for repair was closed.
When the force main was broken, some landfill leachate ran down the gutter of Champion Drive and
entered a Town storm drain that discharges to the Pigeon River at Fiberville. We estimate that 5800
gallons of landfill leachate and 650 gallons of Town sewage were lost.The force main was broken near a
low point and this estimate includes material that drained by gravity and backflow from the Town's pump
station. We visually inspected the river at Fiberville in daylight on the morning of 3/17 and found no
ex dence of any aquatic damage. River Flow is above season norm at about 312 mgd. The notice required.
by NC Statutes, Article 21,Chapter 143.215.0 will be completed today.
Regards—
Paul S.Dickens 5JamesA. Giauque
Manager,Environmental Health and Safety Landfill Supervisor
828-646-6141 828-646-2028
cc: Town of Canton,Progress Energy
Blue Ridge Paper Products Inc. dba Evergreen Packaging—Canton Mill/Waynesville Plant
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
February 25,2010
CERTIFIED MAIL:7006 2760 0001 9282 0600
RETURN RECEIPT REQUESTED
Mr.Robert M.Shanahan
Blue Ridge Paper Products,Inc.
175 Main Street
P.O.Box 4000
Canton,North Carolina28716
Subject: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No.NC0000272
Blue Ridge Paper Products,Inc.—Canton Mill
Haywood County
Dear Mr.Shanahan:
This is to inform you that a review of your toxicity self-monitoring report form for the month of December 2009 indicates a violation of the
toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent toxicity violation(s). You efforts
may include conducting a Toxicity Reduction Evaluation(TRE),a site-specific study designed to identify the causative agents of effluent toxicity,
isolate the sources of toxicity,evaluate the effectiveness of toxicity control options,and confirm reductions in effluent toxicity. Please be aware that
North Carolina General Statutes provide for assessment of civil penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity Monitoring and Reporting
Requirements. Please note appropriate mailing addresses for submitting your Discharge Monitoring Reports (DMRs) and Aquatic Toxicity (AT)
Test Forms. We encourage you to review this information; if it would be helpful to discuss this situation or possible solutions to resolve effluent
toxicity noncompliance,please contact Mr.John Giorgino with this office at(919)743-8441.
Sincerely,
Cindy A.Moore a
Supervisor,Aquatic Toxicabgy,•Uni[ -- - -
cc: Roger Edwards/Asheville Regional Office EIMAR
? II 4'�
Jeff Menzel/Asheville Regional Office t�U Aquatic Toxicology UnitCentral Files - 3 2010
UALITY SECTION
REGIONAL OFFICE
Environmental Sciences Section -'
1621 Mail Servioe Center,Raleigh,North Carolina 27699-1621 „.,,.,,;,..�_,.._,,.......-.One---- - --
Location:4401 Reedy Creek Road,Raleigh.North Carolina 27607 NorthCarolina
Phone:[phone] FAX:[phone] Customer Service:1-877-623-6748 Intemet http:llh2o.enr.state.nc.us/mb/ Nisn tura/lil
An Equal Oppor unity 1 Affirmative Action Employer i/

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and reporting
information.Please take time to review this information.The items below do not address or include all the toxicity testing and reporting
requirements contained in your NPDES permit. If you should have any questions about your toxicity testing requirement,please contact Mr.
John Giorgino with the Aquatic Toxicology Unit at(919)743-8401 or,another Unit representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that toxicity report forms are
appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered(with the appropriate
parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center -
Raleigh,NC 27699-1617
IN ADDITION
Toxicity test data(original"AT"form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Section _
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting period
leg,January test result is due by the end of February).
➢ Toxicity test condition language contained in yourNPDES permit may require use of multiple concentration toxicity testing upon failure of any
single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the permit limit,then at least two multiple
concentration toxicity tests(one per month)will be conducted over the following two months. As many analyses as can be completed will be
accepted. If your NPDES permit does not require use of multiple concentration toxicity testing upon failure of any single quarterly test, you
may choose to conduct either single concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement
initiatives.effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit,except for NPDES Permits which contain episodic toxicity monitoring
requirements(eg,if the testing months specified in your NPDES permit are March,June,September,and December,then toxicity testing must
be conducted during these months).
➢ If your NPDES Permit specifies episodic monitoring and your facility does nothave a discharge from January I-June 30,then you must provide
written notification to the Environmertal Sciences Section by June 30 that a discharge did not occur during the first six months of thecalendar
year.
➢ If you receive notification from your contract laboratory that a test was invalidated,you should immediately notify the Environmental Sciences
Section at(919)743-8401 and provide written documentation indicating why the test was invalidated and the date when follow-up testing.will
occur.
➢ If your facility is required to conduct toxicity testing during amonth in which no discharge occurs,you should complete the information block
located at the top of the AT form indicating the facility name,permit number,pipe number,county and the month/year of the subject report.
You should also write"No Flow"on the AT form,sign the form and submit following normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC)except for facilities which have not
received a facility classification. In these cases,a duly authorized facility representative must sign the AT form. The AT form must also be
signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality,you may consider submitting your toxicity test
results certified mail,return receipt requested to the Environmental Sciences Section.
Environmental Sciences Section
1621 Mail Service Center,Raleigh,North Carolina 27699-1621
Location:4401 Reedy Creek Road,Raleigh,North Carolina 27607Phone: NOttI'th CflTOlIri1
Internethftp:42o.eOstate.ncuslesb65171 Customer Service:l-677-623-6748 Natu quit
An Equal Opportunity 1 ARanative Acton Employer s

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
February 25,2010
CERTIFIED MAIL:7006 2760 0001 9282 0600 (�" l
RETURN RECEIPT REQUESTED PD
' MAR 9 2010
Mr.Robert M.Shanahan
Blue Ridge Paper Products,Inc. =
175 Main Street
BLUE RIDGE PAPER PRODUCTS il,C
P.O.Box 4000 �
BIIS DEPARTMENT
Canton,North Carolina 28716
Subject: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No.NCO000272
Blue Ridge Paper Products,Inc.—Canton Mill
..Haywood County
Dear Mr.Shanahan:
This is to inform you that a review of your toxicity self-monitoring report form for the month of December 2009 indicates a violation of the
toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent toxicity violation(s). Your efforts
may include conducting a Toxicity Reduction Evaluation(TRE),a site-specific study designed to identify the causative agents of effluent toxicity,
isolate the sources of toxicity,evaluate the effectiveness of toxicity control options,and confirm reductions in effluent toxicity. Please be aware that
North Carolina General Statutes provide for assessment of civil penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity Monitoring and Reporting
Requirements. Please note appropriate mailing addresses for submitting your Discharge Monitoring Reports (D)dRs) and Aquatic Toxicity (AT)
Test Forms. We encourage you to review this information; if it would be helpful to discuss this situation or possible solutions to resolve effluent
toxicity noncompliance,please contact Mr.John Giorgino with this office at(919)743-8441.
Sincerely,
C— uv t
Cindy A.Moore
Supervisor,Aquatic Toxicology Unit
cc: Roger Edwards/Asheville Regional Office
Jeff Menzel/Asheville Regional Office
Aquatic Toxicology Unit
Central Files
Environmental Sciences Section
1621 Mail Service Center,Ralegh,North Carolina 27699-1621
Location:4401 Reedy Creek Road,Raleigh,North Carolina 27607 Iv0 e Carolina
Phone:[phone] FAX:[phone] Custaner Service:1-877-623-6748 //
Internet http:ith2o.enr.state.nc.us/esW atzmally
An Equal Opportunity 1 Affirmative Action Employer

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and reporting
information. Please take time to review this information.The items below do not address or include all the toxicity testing and reporting
requirements contained in your NPDES permit. If you should have any questions about your toxicity testing requirement,please contact Mr.
John Giorgino with the Aquatic Toxicology Unit at(919)743-8401 or another Unit representative at the same number.
➢ The mermittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that toxicity report forms are
appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered(with the appropriate
parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
IN ADDITION
Toxicity test data(original"AT"form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
➢ Toxicity test results shall be tiled with the Environmental Sciences Section no later than 30 days after the end of the reporting period
(eg,January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing upon failure of any
single quarterly toxicity test If the initial pass/fail test fails or if the chronic value is lower than the permit limit,then at least two multiple
concentration toxicity tests(one per month)will be conducted over the following two months. As many analyses as can be completed will be
accepted. If your NPDES permit does not require use of multiple concentration toxicity testing upon failure of any single quarterly test, you
may choose to conduct either single concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement
initiatives effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit,except for NPDES Permits which contain episodic toxicity monitoring
requirements(eg,if the testing months specified in your NPDES permit are March,June,September,and December,then toxicity testing must
be conducted during these months).
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30,then you must provide
written notification to the Environmental Sciences Section by June 30 thara discharge did not occur during the first six months of the calendar
year.
➢ If you receive notification from your contract laboratory that a test was invalidated,you should immediately notify the Environmental Sciences
Section at(919)743-8401 and provide written documentation indicating why the test was invalidated and the date when follow-up testing will
occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs,you should complete the information block
located at the top of the AT form indicating the facility name,permit number,pipe number,county and the month/year of the subject report.
You should also write"No Flow"on the AT form,sign the form and submit following normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC)except for facilities which have not
received a facility classification. In these cases,a duly authorized facility representative must sign the AT form. The AT form must also be
signed by the performing lab supervisor.
➢ ,To determine if your AT test forms were received on time by'the Division of Water Quality,you may consider submitting your toxicity test
results certified mail return receipt requested to the Environmental Sciences Section.
Environmental Sciences Section
1621 Mail Service Center,Raleigh,North Carolina 27699-1621 One
Location:4401 Reedy Creek Road,Raleigh,North Carolina 27607 NorthCarohna
Phone:[phone] FAX:[phone] Customer Service:l-877-623-6748 �s �f
Internet http:llh2o.enustale.nc.uslesbl Natltrally
An Equal Opportunity 1 Afirrnabve Action Employer

• CEO p�
R. . �tf` packaging
Blue Ridge Paper Products Inc. - Canton Mill
February 19, 2010 CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7007 0710 0003'731 i"4139`
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
Water Quality Section
ATTENTION: Central Files '
1617 Mail Service Center i
Raleigh, NC 27699-1617 •.
riJ,FA
Co
Re: NPDES NO.NC0000272 r m
Best Management Practices 2009 Annual Report r`
Evergreen Packaging dba Blue Ridge Paper Product Postage $ �S
Canton, NC
Ln ceNfied Fee
Postmark
This letter report(two copies) is the 2009 summary of Best 10 (End tee'",eR reat
10 He•e
monitoring for the Canton Mill. The report is required on or o (E!= dst
Special Condition A.(6.) Best Management Practices, Sectio c3
NPDES Permit No. NC0000272. T° 'r Keith Haynes —
SentDWQThe BMP action levels established in accordance with permit M Er villegional Officeare as follows: US Highway 70nnanoa,NC 28778
Effective Dates: 1 Jan 2009— 31 Dec 2009
Total Influent (TI) Color —
Action Level daily monitoring result Action Required
1-Day Upper Action > 72 Immediate investigation and documented
Level UAL ,500 Ibs/day for one day corrective action
2-day Upper Action > 59,400 Ibs/day for two Investigation and documented corrective
Level UAL consecutive days action
2-day Lower Action > 55,400 Ibs/day for two Investigation and documentation
Level (LAL) consecutive days
Daily records of total influent color are maintained at the mill. These daily color data are
compared to BMP action levels every morning. Total influent color exceeded BMP action levels
on the dates outlined in the following table. A brief summary of information for these dates is
included as required by permit Condition A.(6.), Section EA. The permit-required BMP
investigation reports are maintained at the mill. None of the BMP action level days resulted in
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Division of Evergreen Packaging

• Page 2
disruption to the wastewater treatment plant. The Canton Mill met all NPDES annual average
effluent limits during 2009.
Total Influent
Date(s TI) Color Action Level and Summary
31 Jan 2009 56,564 Ibs/day 2-day LAL—investigation required
1 Feb 2009 67,507 Ibs/day
Cause and Corrective Actions—During the period 1/31 &
2/1, the hardwood Eo consistency meter began reading
above its normal range. This resulted in an increase of
shower water used in the washers. This increase in flow
was seen in the mill sewer system and also added to the
elevated TI color. The hardwood Eo consistency meter was
replaced.
20 &21 Feb 61,504 Ibs/day 2-day LAL— investigation required
2009 57,639lbs/day
Cause and Corrective Actions — Elevated low lift color
numbers were observed for 2/20 &2/21. After extensive
investigation and analysis of our continuous monitoring
systems we were unable to determine the cause of the
elevated low lift color numbers for those two days. The
secondary effluent for the period was normal. No corrective
action was taken.
16 Sep 2009 647,755 Ibs/day 1-day UAL— immediate corrective action
18 Sep 2009 75,901 Ibs/day
Cause and Corrective Actions —On 9/16, at approximately
4:30 am, a process condition occurred that required an
emergency shutdown of one of the mill's two (2) recovery
furnaces. The condition was caused by a sudden and
unexpected mechanical failure.
One of the automatic safety controls that activates during a
recovery furnace emergency shutdown is a firewater
quench to cool the recovery furnace cyclones. A
consequence of the emergency quench is that some black
liquor solids fuel containing lignin color materials is washed
out of furnace cyclones and into the mill's recovery sumps
and sewers. Since the recovery furnace operators
evacuate during an emergency shutdown, operation of fire
systems and other furnace controls has to be accomplished
remotely.
In the specific circumstances that occurred on 9/16, the mill
was able to divert and hold about one-half of the black
liquor solids that entered the mill sewer. All of the available
capacity to divert and hold color materials was utilized. The
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
, Division of Evergreen Packaging

Page 3
Total Influent
Dates) (TI) Color Action Level and Summary
balance of the black liquor solids material was treated in the
mill's wastewater plant. The mill followed established
procedures for this type of event and began adding
additional polymer and defoamer to the wastewater
treatment process. Additional clarifier and aeration basin
capacity were also brought into use. Color from lignin in
the mill's treated wastewater on 9/17 &18 was increased
above normal operating levels by the 9/16 recovery furnace
emergency shutdown. There was no foam discharged from
this event, and there was no visible foam on the river in
Canton below the mill's treated wastewater outfall.
7 & 8 Nov 63,056 Ibs/day 2-day UAL— investigation and corrective action
2009 58,743lbs/day
Cause and Corrective Actions—On 11/9, physical damage
was found on the hydrometer used for pine washing
baume' readings. The process trends reviewed in this
investigation indicate the initial damage occurred around
10/31. The incorrect baume' readings lead to a pulp
washing upset and filtrate imbalance affecting color
performance. The hydrometer was discarded and a new
hydrometer put into service.
27 &28 Dec 59,963 Ibs/day 2-day UAL— investigation and corrective action
2009 69,295lbs/day
Cause and Corrective Actions—On 12/26, the hardwood
fiberline took an unscheduled outage. The combination of
filtrate balance issues within the hardwood fiberline,
equalization of tank levels and the oscillation of operations
during start-up lead to the sewer generated color
phenomena at the WWTP.
Please call us if you have any questions regarding this information.
Sincerely,
Nick McCracken Paul Dickens
Water Compliance Coordinator Manager, Environmental Affairs
Evergreen Packaging—Canton Mill Evergreen Packaging—Canton Mill
828-646-2874 828-646-6141
[e-mail] [e-mail]
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Division of Evergreen Packaging

Page 4
cc:
Mr. D. Keith Haynes
Environmental Specialist
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778
Internal Distribution:
C. File—Water
BMP Notebook
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Division of Evergreen Packaging

7
Page 5
Internal distribution D. Griswold
M. Ferguson
L. Cooper
P. Dickens
N.McCracken
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street • PC Box 4000
Canton, North Carolina 28716 • 828-646-2000
Division of Evergreen Packaging

%evirergreeff ® �
packaging k ._ �, VI
APO 16 2010 u
Blue Ridge Paper Products Inc. - Canton Mill l
VIIATER QUALITY SECTION
February 19,2010 CERTIFIED MAIL°'iEYIL E,REGIONAL OFFICE
E
RETURN RECEIPT REQUESTED
7007 0716,D003 731 1 4139°' `
North Carolina Department of Environment ( +«, '1 _
and Natural Resources Lc INU ! Dpp
Division of Water Quality d U
Water Quality Section ffLN
B 252010
ATTENTION: Central Files
1617 Mail Service Center -WATER QUAt rlY
Raleigh, NC 27699-1617 POINT SOURCE BRANCH
Re: NPDES NO. NC0000272
Best Management Practices 2009 Annual Report
Evergreen Packaging dba Blue Ridge Paper Products, Inc.
Canton,NC
This letter report(two copies) is the 2009 summary of Best Management Practices (BMP)daily
monitoring for the Canton Mill. The report is required on or before March 3I51 of each year by
Special Condition A.(6.) Best Management Practices, Section EA and Section F.1, of the mill's
NPDES Permit No. NC0000272.
The BMP action levels established in accordance with permit requirements and in effect for 2009
are as follows:
Effective Dates: 1 Jan 2009-31 Dec 2009
Total Influent (TI) Color -
Action Level daily monitoring result Action Required
1-Day Upper Action > 72,500 Ibs/day for one day Immediate investigation and documented
Level UAL corrective action
2-day Upper Action > 59,4 00 Ibs/day for two Investigation and documented corrective
Level UAL consecutive days action
2-day Lower Action > 55,400 Ibs/day for two Investigation and documentation
Level (LAL) consecutive days
Daily records of total influent color are maintained at the mill. These daily color data are
compared to BMP action levels every morning. Total influent color exceeded BMP action levels
on the dates outlined in the following table. A brief summary of information for these dates is
included as required by permit Condition A.(6.), Section E.4. The permit-required BMP
investigation reports are maintained at the mill. None of the BMP action level days resulted in
Blue Ridge Paper Products Inc.-Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Division of Evergreen Packaging

Page 2
disruption to the wastewater treatment plant. The Canton Mill met all NPDES annual average
effluent limits during 2009.
Total Influent
Dates TI Color Action Level and Summary
31 Jan 2009 56,564 Ibs/day 2-day LAL—investigation required
1 Feb 2009 67,507 Ibs/day
Cause and Corrective Actions—During the period 1/31 &
2/1, the hardwood Eo consistency meter began reading
above its normal range. This resulted in an increase of
shower water used in the washers. This increase in flow
was seen in the mill sewer system and also added to the
elevated TI color. The hardwood Eo consistency meter was
replaced.
20 &21 Feb 61,504 Ibs/day 2-day LAL—investigation required
2009 57,639lbs/day
Cause and Corrective Actions— Elevated low lift color
numbers were observed for 2/20 &2/21. After extensive
investigation and analysis of our continuous monitoring
systems we were unable to determine the cause of the
elevated low lift color numbers for those two days. The
secondary effluent for the period was normal. No corrective
action was taken.
16 Sep 2009 647,755 Ibs/day 1-day UAL—immediate corrective action
18 Sep 2009 75,901 Ibs/day
Cause and Corrective Actions—On 9/16, at approximately
4:30 am, a process condition occurred that required an
emergency shutdown of one of the mill's two (2) recovery
furnaces. The condition was caused by a sudden and
unexpected mechanical failure.
One of the automatic safety controls.that activates during a
recovery furnace emergency shutdown is a firewater
quench to cool the recovery furnace cyclones. A
consequence of the emergency quench is that some black
liquor solids fuel containing lignin color materials iswashed
out of furnace cyclones and into the mill's recovery sumps
and sewers. Since the recovery furnace operators
evacuate during an emergency shutdown, operation of fire
systems and other furnace controls has to be accomplished
remotely.
In the specific circumstances that occurred on 9/16,the mill
was able to divert and hold about one-half of the black
liquor solids that entered the mill sewer. All of the available
nqnmrifif to divert and hold color materials was utilized. The
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Division of Evergreen Packaging

Page 3
Total Influent
Dates (TI) Color Action Level and Summary
balance of the black liquor solids material was treated in the
mill's wastewater plant. The mill followed established
procedures for this type of event and began adding
additional polymer and defoamer to the wastewater
treatment process. Additional clarifier and aeration basin
capacity were also brought into use. Color from lignin in
the mill's treated wastewater on 9/17 &18 was increased
above normal operating levels by the 9/16 recovery furnace
emergency shutdown. There was no foam discharged from
this event, and there was no visible foam on the river in
Canton below the mill's treated wastewater outfall.
7 &8 Nov 63,056 Ibs/day 2-day UAL—investigation and corrective action
2009 58,743lbs/day
Cause and Corrective Actions—On 11/9, physical damage
was found on the hydrometer used for pine washing
baume' readings. The process trends reviewed in this
investigation indicate the initial damage occurred around
10/31. The incorrect baume' readings lead to a pulp
washing upset and filtrate imbalance affecting color
performance. The hydrometer was discarded and a new
hydrometer put into service.
27 & 28 Dec 59,963 Ibs/day 2-day UAL—investigation and corrective action
2009 69,295lbs/day
Cause and Corrective Actions—On 12/26, the hardwood
fiberline took an unscheduled outage. The combination of
filtrate balance issues within the hardwood fiberline,
equalization of tank levels and the oscillation of operations
during start-up lead to the sewer generated color
phenomena at the WWTP.
Please call us if you have any questions regarding this information.
Sincerely,
Nick McCracken Paul Dickens
Water Compliance Coordinator Manager,Environmental Affairs
Evergreen Packaging—Canton Mill Evergreen Packaging—Canton Mill
828-646-2874 828-646-6141
[e-mail] [e-mail]
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street * PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Division of Evergreen Packaging

Page 4
cc:
Mr. D. Keith Haynes
Environmental Specialist
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
Internal Distribution:
C. File—Water
BMP Notebook
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Division of Evergreen Packaging

Page 5 -'
Internal distribution
D. Griswold
M. Ferguson
L. Cooper
P. Dickens
N.McCracken
Blue Ridge Paper Products Inc.—Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Division of Evergreen Packaging

olevergreeff
packaging
Blue Ridge Paper Products Inc. - Canton Mill
January 13, 2010 CERTIFIED MAIL
Return Receipt Requested
D. Keith Haynes 7009 0820 0000 5161 7338
Environmental Specialist
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
2090 US Highway 70
Swannanoa, NC 28778
Subject: NPDES NC0000272
2009 Annual Average Color
Evergreen Packaging
Canton, NC
Dear Mr. Haynes:
This letter and attachment document the 2009 average annual color discharge from Blue Ridge
Paper Products Canton Mill. Average secondary effluent color discharge for the period I Jan
2009 through 31 Dec 2009 was 37,931 Ibs/day. This represents a slight increase in effluent color
performance from the previous 3 years. The increase is attributed, in part, to production
curtailments during the first half of 2009 due to economic conditions and an Emergency
Shutdown Procedure of the#11 Recovery Furnace in September. As we have discussed in the
past, color performance is optimal when the Mill is at full production with no unplanned outages.
The attachment provides daily wastewater discharge flows and secondary effluent true color for
the mill during 2009.
Sincer
Nick McCracken Paul Dickens
Water Compliance Coordinator Manager, Environmental Affairs
Evergreen Packaging—Canton Mill Evergreen Packaging—Canton Mill
828-646-2874 828-646-6141 .
Y:
Attachment: Daily flow and color discharge for 2009 n C L Q q
I ; D
Blue Ridge Paper Products Inc.—Canton Mill �{1N 4 �jO ,
175 Main Street • PO Box 4000 fI
Canton, North Carolina 28716 • 828-646-2000 t
WATER QUALITY SECTION
Division of Evergreen Packaging =`_ Le Pec cNA_Q=FI E :a
Y

Canton Mill 2009 Average Annual Color and Wastewater Flow
Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color Date WTP Flow Sec Eff Color
MGD 'Ib/day MGD 'Ib/dayl MGD .1blday'
1/1/2009 23.36 31,756 2/1/2009 26.28 50,191 3/1/2009 27.52 40,624
1/2/2009 24.42 31,568 2/2/2009 26.36 49,684 3/2/2009 26.23 40,033
1/3/2009 29.98 35,755 2/3/2009 25.35 45,244 3/3/2009 26.28 39,013
1/4/2D09 25.43 31,813 2/4/2009 26.00 42,717 3/4/2009 26.81 38.906
1/5/2009 25.66 30,603 2/5/2009 26.29 41,878 3/5/2009 25.68 33,411
1/6/2009 29.69 31,942 2/6/2009 26.96 44,969 3/6/2009 26.40 33,026
1/7/2009 27.80 33,387 2!7/2009 26.65 43,621 37/2009 25.17 29,388
1/8/2009 25.57 38,172 2/8/2009 26.44 40,574 3/8/2009 26.45 33,751
1/9/2009 25.23 35,561 2/9/2009 25.27 36,882 3/9/2009 25.92 37,614
1/10/2009 25.59 45,672 2/10/2009 25.06 35,321 3/10/2009 25.42 39,433
1/11/2009 25.33 48,377 2/11/2009 26.03 44,286 3111/2009 24.98 46,042
1/12/2009 26.91 45,559 2/12/2009 25.17 41,774 3/12/2009 27.51 48,181
1/13/2009 27.56 42,752 2/13/2009 25.29 39,653 3/13/2009 26.03 48,628
1/14/2009 25.98 47,085 2/14/2009 25.73 W480 3/14Y2009 25.82 49,313
1/15/2009 25.42 42,613 2/15/2009 25.47 34,412 31IW2009 26.08 61,555
1/16/2009 25.42 40,705 2/16/2009 25.76 35,448 3/16/2009 27.20 52,856
1/17/2009 27.29 51,892 2/17/2009 24.33 34,901 3/17/2009 27.98 39.203
1/18/2009 27.16 47.568 2/18/2009 27.08 32,070 3/18/2009 27.27 37,071
1/19/2009 24.57 40,573 2/19/2009 26.23 36,095 3/19/2009 25.39 31,339
1/20/2009 24.04 42,506 2/20/2009 25.61 33,747 3/20/2009 26.61 30,182
1/21/2009 23.93 39,716 2/21/2009 26.09 33,944 3/21/2009 27.55 32,627
1/22/2009 23.92 45,484 2/22/2009 25.85 33,632 W22/2009 27.03 37,647
1/23/2009 23.03 48,594 2123/2009 25.91 39,544 3123✓2009 26.04 36,485
1/24/2009 24.74 47,663 2/24/2009 25.81 42,190 3/24/2009 23.74 29,897
i/25/2009 23.62 39,398 2/2W2009 26.00 35,345 3r25/2009 25.04 54,714
1/26/2009 25.26 45,926 2/26/2009 26.40 37,764 3/26/2009 26.35 44,831
1/27/2009 26.48 45,935 2/27/2009 26.96 41,372 3/27/2009 25.06 35,112
1/28/2009 25.14 37,321 2/28/2009 28.19 38,792 3/28/2009 25.89 42,105
1/29/2009 24.87 33,601 3/29/2009 26.45 45,883
1/30/2009 24.90 38,834 3r30/2009 27.01 44,827
1/31/2009 25.19 39,496 3/31/2009 26.73 37,675
I' I
JAN 14 2010
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Canton Mill 2009 Average Annual Color and Wastewater Flow
Date WTP Flow Sec Etl Color Date WTP Flow Sec Ell Color Date WTP Flow Sao Eff Color
MGD 'Ib/day MGD 'Ib/day MGD -lb/day'
10/1/2009 26.60 34,830 11/1/2009 28.20 40,452 12/1/2009 24.75 29,311
10/2/2009 26,05 38,672 11/2/2009 27.68 33,243 12/2/2009 27.10 38,422
10/3/2009 25.19 34,454 11/3/2009 28.46 31,806 12/3/2009 26.61 30,848
10/4/2009 25.59 30,946 11/4/2009 26.87 33,614 12/4/2009 25.54 36,637
10/5/2009 27.63 29,618 11/5/2009 27.39 34,493 12/5/2009 24.81 30,417
10/6r2009 26.39 28,392 11/6/2009 26.15 44,709 12/6/2009 25.35 34,038
10/7/2009 25.84 36,420 11/7/2009 26.48 54,327 12/7/2009 25.59 36,068
10/8r2009 26.45 37,060 11/8/2009 25.05 62,466 12/8/2009 26.61 37.506
10/9/2009 26.90 23,108 11/9/2009 25.06 63,536 12/9/2009 28.46 41,537
10/10/2009 26.88 27,574 11/10/2009 27.83 55,240 12/10/2009 25.03 38,028
10/11/2009 26.27 30,673 11/11/2009 28.71 36,635 12/11/2009 24.79 34,320
10/12/2009 26A8 39,301 11/12/2009 25.87 40,562 12/12/2009 24.40 36,833
10113t2D09 26.W 32,526 11/13/2009 25.56 44,766 12/1312009 24.75 36,742
10/14/2009 27.28 53,694 11/14/2009 25.02 42,905 12/14/2W9 24.69 32,535
10/15/2009 26.38 40,042 11/15/2009 24.57 43,442 12/15/2009 24.74 34,664
10/16/2W9 25.67 34,468 11/16/2009 25.19 36,345 12/16/2009 23.25 31,607
10/17/2009 26.83 33,564 11/17/2009 27.05 43,991 12/17/2009 24.32 35,901
10/18/2009 26.78 33,502 11/18/2009 27.77 47,942 12/18/2009 26.49 49,488
10/19/2009 25.81 26,476 11/19/2009 25.89 59,163 12/19/2009 26.53 54,430
10/20/2009 26.76 31,022 11/20/2009 24.75 54,906 12J20/2009 26.34 50,306
10/21/2009 26.37 31,669 11/21/2009 25.14 40,466 12/21/2009 25.82 54,696
10/22/2009 26.76 31,915 11/22/2009 26.00 50,307 12/22/2009 24.85 50,154
10/23/2009 26.95 26,522 11/23/2009 25.76 45,975 12/23/2009 26.04 40,611
10/24/2009 25.91 27,443 11/24/2009 26.12 36,597 12/24/2W9 26.10 35,263
10/26/2009 25.51 28,509 11/25/2009 25.21 32,799 12/25/2W9 30.60 37,005
10/26/2009 25.55 33,881 11/26/2009 25.29 38,598 12/26/2009 26.24 22.322
10/27/2009 27.47 30,699 11/27/2009 24.89 34,666 12/27/2W9 24.57 36,270
10/28/2009 25.15 31,043 11/28/2009 24.35 34,727 12/28/2009 25.71 46,958
10/29/2009 26.50 28,289 11/29/2009 24.54 38,477 12IM2009 25.71 37,953
10/3012D09 26.84 46,560 11/30/2009 25.28 34,155 12/30/2009 25.30 30,595
10/31/2009 27.37 45,653 12/31/2009 26.98 34,652
Average Annual Flow: 26.32 MGD
Average Annual Color: 37,931 Ibs/day
- I
14 2010
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