NC0000272_Annual Progress Report on Color_20150731

Canton Office
evergree
pac ink 175 Main Street• Canton, NC 28716
NMM#58-15
July 31, 2015 CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 4705
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 2014 through June 2015).
Very truly yours,
BLUE RIDGE PAPER PRODUCTS INC.
DOING BUSINESS AS EVERGREEN PACKAGING
By:
Nick McCracken
EHS Water Supervisor
828-646-2874
nick.mccrackenAeyerpack.com
Enclosure: July 2015 Annual Progress Report on Color
cc: NC DWR—Complex NPDES Permitting Unit,Raleigh
Billy Clarke,Roberts and Stevens
EOHS\Share\Water\Color Reports 2010 Prmt

July 2015 — 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 2014
through June 2015, 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[Evergreen 2013]
o July 2014 Annual Progress Report on Color [Evergreen 2014]
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
Page 1

July 2015 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No. NC0000272
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
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 a current annual average (calendar year) true color limit of 36,000
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 I 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 2015 — 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, 1997 thru 2015
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70 62 -
0 60 — —
0 50 - - 48 . ..-----------
40 _40 39 37--35 36 38_3fi_35-35-..36- 38 36
0 30 - - - — - -
20 - - - — ... —
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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 2014 improved over the previous year's performance. The
increased outage schedule for the lower end of the mill continues to help with reliability.
Page 3

July 2015 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
This operational strategy and improvements to operating systems contributed to color
performance in 2014.
IV. Color Projects 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 2011 Color Progress Report [Evergreen 20111 documented significant Color
Team activities between May 2006 and May 2011. Significant activities since 2010 are
outlined in Tables 1 and 2. Capital projects in Table I are identified by Capital
Page 4

July 2015 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No.NC0000272
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 2015
exceeded $3.9 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*
2010
Replaced conductivity and level switches in East Heavy compound with
new, more reliable type. BMP improvement.
o Completed 3Q 2010, cnsd*
Page 5

July 2015 — 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
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 sprax bar on the 5 b 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 Dec 2010
o CIP—322435
o Cost—$724,000
Page 6

July 2015 — 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 cant'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 2015 — 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-—$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
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 2015 — 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 cant'
spill material directly to the Hardwood Spill Tank. This replacement
minimized losses to the mill sewer system.
o Completed Fall 2012, ensd*
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 II). 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 2015 — 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
tam, will reduce D 1 stage CIOz 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 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
Page 10

July 2015 — 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.
c Completed April 2014, csnd*
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 2015 — 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 Unoxidized and East
Unoxidized storage tanks. BMP sustaining measure.
o Completed June 2014, cnsd*
2015 Acid cleaning of the filtrate line from Pine Eo to Decker filtrate tank. This
allows operations to refine the filtrate balance cycle inside the bleach plant
preventing colored filtrate material from overflowing to the mill sewer
system.
o Completed April 2015
o Cost- $10,000
Installation of automatic valve on Pine Dl washer sewer drain. Remove
potential for colored filtrate losses to mill sewer. BMP sustaining measure.
o Completed May 2015
o Cost- $6,000
Pine D2 washer drum replacement. Old drum created a situation where the
Acid Sewer filtrates were being piped to the influent side of the W WTP. This
created opportunities for sewer generated color to occur. Once installed those
filtrates were then piped back to the effluent side of the clarifiers.
o Completed May 2015
o Cost- $225,000
Dome replacement for the fd effect on the West GB Evaporator set. BMP
sustaining measure.
o Completed May 2015
o Cost- $135,000
East Unoxidized Black Liquor storage tank repair&replacement items.
Replaced suction side spool coming out of tank, suction side isolation hand
valve, suction side expansion joint, suction side tee to pumps and replaced
hand valve on feed side to the tank. BMP sustaining measure.
o Completed July 2015
o Cost - $15,000
Page 12

July 2015 — 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
Green Liquor piping and hand valve replacement to the Causticizers. BMP
sustaining measure.
o Completed July 2015
o Cost- $8,000
*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 W WTP.
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. Existing batch treatment
of amine 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
Page 13

July 2015 — 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.
2014 Polymer study of the Acid Sewer stream at the W WTP. Polymer had the
ability to reduce the amount of color,however once introduced back into the
treatment system the sewer generated color phenomena occurred negating all
positive effects of the polymer addition. Trial deemed unsuccessful and was
not putinto use.
Since 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 mill targets
planned maintenance outages every eight weeks. This frequency of outages has been
proven successful and is maintained as a part of the color management strategy. This
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.
An increased focus for the mill fiberlines is around filtrate balancing and the bleached
filtrate cycle. This year's projects included efforts to minimize and reduce the potential
for color associated with bleach filtrates that enter the sewer. This included a periodic
system of jetting and acid cleaning specific filtrate lines to remove buildup. This excess
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July 2015 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No. NC0000272
build up reduces the amount of filtrate flow through the process and can lead to an
imbalance which may result in overflows to the mill sewer system.
V. TRW Recommendations
The Canton Mill continues to review the listed items under Section A.(8.)10. for
opportunities and refinements to our color management strategy. For this period that
includes refinements and sustaining measures to our BMP program and the evaluation of
polymers.
A new polymer study was conducted during the fall and spring months. The Acid Sewer
filtrate stream was evaluated for potential color savings prior to mixing with the alkaline
sewer and entering the primary clarifiers. The purpose was to see if color could be
reduced and prevented from returning once mixed with the incoming wastewater. The
results showed a reduction in color from the Acid Sewer stream,however all benefit
derived from the addition of polymer was soon negated as that sewer generated color
occurred after it came into contact with the influent. The trial was deemed unsuccessful
and the product abandoned.
BMP sustaining measures allow the mill to strengthen and enhance its color prevention
program. This year the mill replaced a Green Liquor feed line to the Causticizers along
with the hand valve. Other piping and valve replacement occurred at the East
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July 2015 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No. NC0000272
Unoxidized Black Liquor tank. Another project was the replacement of the dome on the
2nd effect of the West GB evaporators. These projects help prevent unwanted releases of
alkaline and elevated color sources to the mill sewers. The pine fiberline replaced an
automatic valve for the DIwasher sewer drain. This replacement will help to prevent any
potential losses due to fatigue.
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 16

July 2015 — 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.
Evergreen 2014 — 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 1,2014.
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.
Page 17

July 2015 — Annual Progress Report on Color
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No.NC0000272
NCASI 2006—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.
Page 18