NC0000272_Analytical Fecal Coliform Date per Request_20180101 (14)

Investigative and Corrective Action Documentation
BMP Action Level Exceedance — Form E-2
Canton Mill
Date of Report: 3/22/2018
Investigative Action Required: x
Person Conducting Investi atg ion: Jacob Trantham
Corrective Action Required: x
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 (moo-st iinitiate Corrective Action alter I duty 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: 3/20 - 97,937lbs 1 3/21 74,8861-lbs.
Secondary effluent color 8/21 — 83,65 11 8/22 — 35,040
Corresponding Sewer Areas with Elevated Color: 4, 5BR
Operations Personnel Notified: All lower end foreman as well as area managers and lead
team members.
Day/Time: 3/20/18 0800 1 3/21 0800
Cause(s) for exceedance:
BMP related incident x
Primary Cause: Annual outage on #10 recovery furnace and hardwood pulp mill.
Non-BMP incident ❑
Test Method Interference ❑ New Method = Turbidity =
Secondary Effluent (with one day lag time) _
Outage x
Other ❑
Is problem ongoing? Outage is scheduled to continue thru 3/25/18
Revision 3, 10/1/08
Blue Ridge Paper Products Inc. dba Evergreen Packaging

Have efforts been made to mitigate the occurrence? Lower end is trying to ease back on
dumping and be mindful of flow and color going into the sewer in their areas.
Is corrective action recommended? Yes
Corrective Action Implemented: Lower end was instructed to cease dumping and control
all flow and color going into the sewers in their areas.
*Describe incident in detail including regulated substance (black liquor, turpentine, or
soap) that went to the Wastewater Treatment plant: A combination of outage related
washing, black liquor, fiber, and lime mud were dumped into the sewer throughout the
day causing very high flow and color in the influent stream to the WTP.
Describe any other necessary information:
WTP operators began adding our color reducing polymer Amerfloc 485 very early on
3/20 at the low lift, in the primary system and the secondary system. The decision was
made in the afternoon after still seeing a rise in influent color that the concentration of
CRP needed to be adjusted. A higher concentration of CRP was added into the process
and we began to see the effects within a few hours. The CRP was reducing the color
numbers significantly, so we continued with the higher dosage until lam on 3/21. At
IOpm on 3/20 influent flow was directed into the #1 clarifier to reduce flow just in case.
Secondary effluent color came in at 83,651 for the day, 20k below the limit. More
polymer was brought in by the vendor on 3/21, shipments are scheduled for 3/22 as well.
High color continued into 3/21. The lower end supervisors were notified of every color
over 300ppm. The outage continued to impact color throughout the day. CRP was added
throughout the day.
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
Canton Mill
Date of Report: 3/26/2018
Investigative Action Required: x
Person Conducting Investigation: J Trantham
Corrective Action Required: x
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 correspondingcolor:
olor:
Note: Investigative and/or Corrective Action must occur after 2 consecutive days at the
respective level. 3/24 — 94,371 Ibs 13/25 — 57,069 13/26 — 76,793
Corresponding Sewer Areas with Elevated Color: 2b, 4, 5BR, & 3
Operations Personnel Notified: All area supervision was notified.
Da.. /T� Supervision was notified of every hourly color grab over 300ppm.
Cause(s) for exceedance:
BMP related incident x '�
Primary Cause: Annual outage for # 10 recovery furnace and hardwood pulpmill
continues.
Non-BMP incident ❑
Test Method Interference ❑ New Method = Turbidity =
Secondary Effluent (with one day lag time) _
Outage x
Other ❑
Is problem ongoing? No, weak wash is no longer over flowing.
�.
Have efforts been made to mitii4ate the occurrence? Weak wash tank was overflowing
sending very high pH material to the WTP, tank level was pulled down.
Revision 3, 10/1/08
Blue Ridge Paper Products Inc. dba Evergreen Packaging
I

Is corrective action recommended? Lowering tank level was the corrective action in this
case.
Corrective Action Implemented: Yes
*Describe incident in detail including regulated substance (black liquor, turpentine, or
soap) that went to the Wastewater Treatment plant:
Ou'zage work hias delayed the startup of many of the j,,;roccsses in the rower end,
weak wash wlatgch is used to flute nine green liquor hn thie sr±ich dissolving ta±ilks isn't
being pulled down fast enough so the weak wash tank is over .lowing. Wear wash is
has a very nigh p1-1, this high pl1 material is ca3asing the bleach plant fAl thate to
abloom" arc: proc:uce high color. The 'hitigh pH also r edr ces the effects of oar color
reducing coagulant.
Weak was continued to over flow for 3 days until the level could finally he pulled
fi'€awn enough that it wasn't going into the sewer.
Secondary of uent colors were 3/25 — 61,712 18/26 — 71, 331 1 8/27 — 38,032.
Describe any other necessary information:
Return this form to the Environmental Manager for Record Keeping Requirements
Revision 3, 10/1/08
Blue Ridge Paper Products Inc. dba Evergreen Packaging