NC0000272_Annual Progress Color Report_20130701

evergreen,Mr/ Canton Office
packaging
1 75 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 2012 through June 2013).
Very truly yours,
BLUE RIDGE PAPER PRODUCTS INC.
DOING BUSINESS AS EVERGREEN PACKAGING
By:
Nick McCracken
Water Compliance Coordinator
828-646-2874
nick.mccrackenkeverpack.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 Doing Business in California 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. BacklZround
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 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
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 62.2
�60
ca
-0 55
c 50 47.8
44.6
45 .
41.1 41.2
O 40 39.137.9
5 37.1 36.1 36.5 35.9
35.3 34.8
035
M 30
W 111411 '�9g6 1�999 `ZJpO Zip" 'Ozrl Zdp'3 2SjpDl 101116
2011
6 10111 Zdp6 2Sjp0 �0 2O11 I-PN2
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 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.
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 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 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 5th effect of the Swenson evaporator set.
Spray allows the 5th 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*
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 201 Ion hardwood blow tower dilution pumps
o Completed Jul 2011 on hardwood weak black transfer pumps
o 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
o 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 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
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, 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
Installation of an additional a-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 2nd 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
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. 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#513
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 Study on the PilZeon 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
---------------------------------------------------------------
VII. 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 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.
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 Modern Kraft Pulp and Paper Mill, National Council for Air and
Stream Improvement, August 2006.
Page 18