NC0000272_NOV-2021-FK-0002 & NOV-2021-SS-0022 Response_20220203

pactiv
evergreen'
175 Main Street
Canton, NC 28716
828.646.2000
pactivevergreen.com
CERTIFIED MAIL— RETURN RECEIPT REQUESTED
70182290000178809897
February 3, 2022
Mr. Landon Davidson
Regional Supervisor
Division of Water Resources —Asheville Regional Office
North Carolina Department of Environmental Quality
2090 US Hwy 70
Swannanoa, North Carolina 28778
Subject: Response to NOV-2021-FK-0002 and NOV-2021-SS-0022
Blue Ridge Paper Products, Inc. dba Evergreen Packaging
Canton Mill - Permit No. NC0000272
Dear Mr. Davidson:
This document responds to NOV-2021-FK-0002 and NOV-2021-SS-0022 received on January 3, 2022.
As stated in the response to NOV-2022-LV-0002, Evergreen Packaging places paramount importance
upon permit compliance and water resource protection and regrets the issues that led to the upset of
the mill wastewater treatment plant and subsequent, apparent impacts to water quality in the Pigeon
River and aquatic life.
NOV-2022-LV-0002 cited three BOD daily limit exceedances and one monthly average limit exceedance
in November 2021. The Canton Mill has a significant history of NPDES wastewater permit limit
compliance, particularly regarding BOD limits. Two exceedances of BOD daily limits were identified
during review of the previous 15 years of discharge monitoring records: October 31, 2008 and May 17,
2012. Clearly, the recent BOD limit non-compliance was a rare event and effective treatment of
wastewater and discharge of compliant effluent should be expected.
As reported in the Noncompliance Report submitted to your office on December 6, 2021, wastewater
treatment processes and effluent quality were negatively impacted by soap, a byproduct of the kraft
pulping process, entering the mill sewer system, causing the exceedances of permit limits described in
NOV-2022-LV-0002.
Additional information regarding the investigation and actions taken by the mill since the above -
mentioned report was delivered is provided below; this information has been updated since submittal of
the NOV-2022-LV-0002 response on January 14, 2022.
Cause Investigation
Evergreen has continued efforts to analyze the cause(s) of the introduction of soap to the mill sewer
system, including reviewing mechanical components, system processes, communication/warning
systems, and operator actions and responses.

Response to NOV-2021-FK-0002 and NOV-2021-SS-0022
Page 2 of 4
As reported previously, two likely causes have been identified:
1. Discharge from the tall -oil -making process area
2. Overflow from the pine weak liquor storage tank
Corrective Action
After further investigation of the causes, the following items were identified that likely could have
prevented the loss of soap to the mill sewer:
• Updated training for operators of the extreme importance of containing soap in mill processes
and avoiding any discharge to the wastewater treatment plant (WTP), including more aggressive
action steps to eliminate and capture any discharges
• Updated training for operators of best management practices (BMPs)
• Expanded communications of pine weak liquor storage tank monitoring data to operators and
managers
• Remote visual monitoring of the pine weak liquor storage tank area
• Enhanced, timely communications of process condition changes that may indicate possible soap
overflows or discharges
• Increased secondary containment at the pine weak liquor storage tank to prevent discharge of
soap to the containment sump
Briefings and communications have been conducted with operators to emphasize the extreme
importance of containing soap in mill processes and avoiding any discharge to the WTP. Updated BMP
training is in the final stages of review and updates. Upon completion, the updated training module will
be released to appropriate mill personnel as required training, as soon as possible.
Best practices regarding the use and management of hoses within the tall -oil -making system has been
reviewed with department staff and the importance of maintaining effective secondary containment of
all products containing soap has been emphasized.
Communication of data collected from the overflow alarm on the pine weak liquor tank, an indication of
possible soap discharge from the tank, was modified to display in a second location for increased
visibility of process conditions for department managers. A text -enabled alarm to appropriate personnel
has also been initiated.
Remote visual monitoring was considered an enhancement to pine weak liquor tank area monitoring.
Installation of surveillance camera equipment has been completed. Monitoring of the visual feed from
the camera is now an assigned duty of operations personnel.
Intradepartmental and interdepartmental communications have been enhanced to create more
effective prevention and capture of soap discharges.
To further prevent the discharge of soap from the pine weak liquor tank to the mill sewer, temporary
measures have been implemented until permanent modifications can be completed: a sand bag wall has
been placed between the tank overflow pipe and drainage structures to contain any soap overflow. A
permanent, 4-foot containment wall with a drain valve will be constructed as soon as practicable. In the

Response to NOV-2021-FK-0002 and NOV-2021-SS-0022
Page 3 of 4
event of tank overflow, this addition will allow capture of overflowing materials prior to entry of the
materials to the sump, preventing any loss to the mill sewer.
Spent liquor, turpentine and soap containments, conductivity sensors and level transmitters have been
inspected to ensure all components are functional.
The following procedures and processes have been reviewed and will be modified as needed:
• BMP inspections
• Equipment repairs
• Sump, sewer and wastewater monitoring
• Spill response
Records
Per the request for electronic versions of records required by Section C. 2. of NPDES permit NC0000272:
• The current BMP Plan was provided to your office on December 15, 2021
• Attachment A provides daily BMP inspections records for the period of the subject event
(November 23, 24, and 25, 2021)
o Once a leak has been identified, a work request is entered into the mill computerized
maintenance management system (CMMS) and work order prepared
o Work histories on the equipment are maintained on CMMS
• Attachment B provides the BMP 2021 annual BMP training that was provided via the mill's
learning management system
o The event review portion was delivered without being updated, which will be rectified in
the updated training to be released imminently
• Attachment C provides the Best Management Practices 2020 Annual Report mailed to your
office on March 30, 2021—the 2021 report will be provided accordingly
• Attachment D provides records daily influent monitoring data (conductivity and color) for the
period of the subject event (November 23, 24, and 25, 2021)
We remain hopeful that consideration will be given to the long-term compliance history maintained by
the mill and corrective actions taken since the subject non-compliance event, as you review this matter.
Please contact Mr. Tracy Willis if we can provide any additional information that may be helpful.
Respectfully,
Tracy Wtllis
Wastewater Treatment Plant ORC
Canton Mill
tracy.willisPpactivevergreen.com
Phone: [phone] / Mobile: [phone]
A. 714---
John McCarthy
General Manager
Canton Mill
john.mccarthyPpactivevergreen.com
Phone: [phone]

Response to NOV-2021-FK-0002 and NOV-2021-SS-0022
Page 4 of 4
Attachments

ATTACHMENT A

#2 Fiberline BMP Daily Inspection for Black liquor Leaks
Please inspect systems fo leaks of Black liquor/Soap/Turpentine
Digester House
YES
NO
If yes please describe the Black Liquor leak in
detail
N
#7 Digester
.----'
GJJte--)C r (;rci-,, L cd m jea_e1
#8 Digester
—/
#9 Digester
#10 Digester
#11 Digester
./
#12 Digester
#14 Digester
#15 Digester
✓
' (ec f S)-- CA,,m /, ec;`J\
#16 Digester
Blow Tower
✓
djr^, i n de;' e ; -)
Turpentine System
Condenser
Decanter
Knotting and Brown Stock Washing
Primary knotter
Secondary Knotter and Accepts Tank
lst. Stage Pre-02 Washer System
2nd. Stage Pre-02 Washer System
3rd. Stage Pre-02 Washer System
Spill Collection System
West Sump Pump
East Sump Pump'
Brown Spill Collection Tank
Shift:
Crewleader
Ki ��d2lj Date: /T-02 3- 0

Recovery BMP Daily Inspection for Black Liquor Leaks
Please inspect systems for Teaks of Black Liquor/Soap /Turpentine*
Recovery Area
Y
N
If Yes please decribe the Black Liquor Leak in Detail
Red Liquor Storage Tank
#10 Recovery Boiler
#11 Recovery Boiler
#10 RB Sump Pump
L7,
#11 RB Sump Pump
Red Liquor Storage Tank
Sump Pump
Shift: / 1 9.4..FT
Room Runner:
Date:

Recovery BMP Daily Inspection for Black Liquor Leaks
Please inspect systems for Teaks of Black Liquor/Soap /Turpentine*
Recovery Area
Y
N
If Yes please decribe the Black Liquor Leak in Detail
Red Liquor Storage Tank
#10 Recovery Boiler
#11 Recovery Boiler
#10 RB Sump Pump
#11 RB Sump Pump
Red Liquor Storage Tank
Sump Pump
Shift: /I
Room Runner:
Date: 11— ay- 2001

#2 Fiberline BIM Daily Inspection for Black liquor Leaks
Please inspect systems fo leaks of Black liquor/Soap/Turpentine
Digester House
#7 Digester
#8 Digester
YES
NO
If yes please describe the Black Liquor leak in detail
fjtom LriG r k2
#9 Digester
#10 Digester
#11 Digester
#12 Digester
#14 Digester
#15 Digester
#16 Digester
4(),Y e c7L- 5' t'ecul-‘ 1e4 i
Blow Tower
Turpentine System
Condenser
Decanter
Knotting and Brown Stock Washi
Primary knotter
Secondary Knotter and Accepts Tank
1st. Stage Pre-02 Washer System
2nd. Stage Pre-02 Washer System
3rd. Stage Pre-02 Washer System
pill collection System
West Sump Pump
East Sump Pump '
Brown Spill Collection Tank
Shift:
Crewleader
Date: /I 2 / - Z

#2 Fiberline BMP Daily Inspection for Black liquor Leaks
Please inspect systems fo leaks of Black liquor/Soap/Turpentine
Digester House
YES
NO
#7 Digester
#8 Digester
#9 Digester
#10 Digester
#11 Digester
#12 Digester
#14 Digester
#15 Digester
#16 Digester
Blow Tower
Turpentine System
If yes please describe the Black Liquor leak in//detail
i del
L/4JevGc.
LA. L TI DrI2&z m ��V`,tgst esi
Condenser
Decanter
C./
Knotting and Brown Stock Washi
Primary knotter
,..---
Secondary Knotter and Accepts Tank
1st. Stage Pre-02 Washer System
2nd. Stage Pre-02 Washer System
(.,'''
SCeGG eCt n1n sala`-c)er'(,n, n>tkidrli e 1
3rd. Stage Pre 02 Washer System
&V
/ =,.,G e GG• ectel (j toA.t.)-eir) 2 e /<- 6111 $
pill c,oiiectton System
West Sump Pump
East Sump Pump '
Brown Spill Collection Tank
1,a (C- V -r8 4c) 6 71-40
01
64.,
Shift:
Crewleader
//- 2S �/
Date:
e/'‘
et, d

ATTACHMENT B

Trainin *
• Required
• When —Initial and Annual
• Who —operators, maintenance, supervision
• Includes:
— Overview of BMP plan requirements
— Previous year's event reports
— How and when to report
— How to initiate report
— Procedure on diversion (WWTP)

What are BMPs?
Best Management Practices
"The primary objective of the BMPs is to
prevent leaks, spills of spent pulping
liquors, soap and turpentine. The
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"

Whv must we have BMPs?
40 CFR 430.03
http://www.epa.gov/EPA-WATER/1998/April/Day-
15/w9556.htm
Cluster Rule
http://www.epa.gov/waterscience/guide/pulppaper/cluster.h
tml
NPDES
National Pollutant Discharge Elimination
System

NPDES Permit*
Issued by North Carolina
Canton Mill Operates under permit
#NC0000272
Must be renewed every 5 years
NPDES permit sets Secondary Effluent limits
Canton Mill has a permit limit of 36,000
ib s/day

3 Tiers of Protection
• Sumps
— Normally overflow to sewer but...
— Conductivity sensors & level detection
— Automatic and Manual sumps
• Offline Spare Clarifier (Usually No.1)
Communication is key!!
Released at a non -disruptive rate
Reactive control measure —
we MUST be proactive
Remember to follow our spill
reporting procedure!
• Stand-by aeration basin
— If lower basin cannot maintain DO, utilize upper basin
eve rg r a n
packaging

Canton Mill Sump System
HWD Knotter
Sump
East Digester
Sump
West Digester
Sump
Hardwood
Bleach
Pine West
Brownstock
Pine East
Brownstock
Pine Knotter
Sump
Fiberlines
HWD Brown
Spill Tank
1st Pre-02
Washer (HW)
HWD Bleach
Spill Tank
Pine Blow
Tower
Pine Brown
Spill Tank
HW Primary
Scrn Feed Tk
2nd Pre-02
Feed Tank (Pn)
Hardwood
BlowTower

Canton Mill Sump System - Recovery
Black Liquor
Evaporators
Sewer With
Operator Alarm
Sew er With
Operator Alarm
Heavy Black
Liquor
Evap. Wash
Water Tank
Evaporator Boil
Out Tank
Tall Oil Save All
Tank
East Heavy
Liquor
#10 Recovery
Boiler
#11 Recovery
Boiler
WGB Foul
Condensate
Swenson Foul
Condensate
Evap. Boil Out
Sump
Evaporator
Tank Farm
Evaporator
"U" North
Evaporator
"U" South
Stripper Sump
Camp Branch
Tank Farm
Tall Oil
Compound
CRP Sump

Canton Mill Sewers
Color, Conductivity, Flow and Fiber Loss
Overview - Mill Sewers
Hill Filt r P
CRP
10 R6
Re -
Cant
- Sump Iocaiion
- IMili011 65B
Smei Canduclivily
SII11YI1 Gol iiIL e1 w9ty
4G
Aid Sewer
5A
•
-4C
411
Depcly
Broke
4F
Erco
0.32 MGD
!l F!L
Bleach
Plant
Chemical Storage
0.40 MLbs Color Eo
4.82 Mlbs Color D-1
WEL
Evaps
Power
r - 7 #4
Boller
2A
Spste a j Ice
HW
Screen
Room
'4A
PI Color
54532 Ib sfd ay
#1 F$L
Brawn
Stock
Washing
t Time 5/1512009 1024143 NH
#19 PM FLOW 3.45 MGD
FIBEFL 8,51 Tons Fiber
0 FLOW 0.61 MGD
#20 PM FIBER: 1.05 Tons Fiber
Sewer Data
i!1 #2 #26 #31A #4 $15ri AS
FLOW OM* 4.23 NIA 0.43 1.91 NJA 1.73 3.03
coLOR iwt * 168.00 144.00
tnLort moo man Wyk 3.03 2.62 8.03 1.13 8.20
HIDER Itonsl: 5.61 NIA 0.04 0.33 NIA NIA 0.14
Power Boilers
WTP
10
162 PI Corot as pp1H
234 8Iu carnllasis of PI Cvlar
BM I
0-0
SE Color
42078 Ibsfday
SE TSS
[372 Ibslday
#14 PM Area
#12 PM
1111 PM
0 Color@ TN
7.92 D.D. F'vl
0 14.04Tons Fiber
30.614
0 No Data
2.9 Delta T
21.6 River Temperature
Sacorrdary FfllueI t D.A.,

TALL OIL AREA
BMP INSPECTION
BLUE RIDGE PAPER PRODUCTS, INC.
CANTON MILL
CANTON, NORTH CAROLINA
SA=28613
142.18$ gol
TANK LOCATIONS
23. SOAP COLLECTION
24. SOAP PUMP TANK
25. #I SOAP STORAGE
26. #2 SOAP STORAGE
27. TALL OIL COOK POT
U. TALL OIL LOADING
SUMP PUMP LOCATIONS
G. EAST HEAVY LIQUOR COMPOUND SUMP PUMP
J. TALL OIL/SOAP STORAGE COMPOUND SUMP PUMP
K. TALL OIL MAKING SUMP PUMP
I
18.
2
56.
ProJ. No:

NO. 2 FIBERLINE
BMP INSPECTION
BLUE RIDGE PAPER PRODUCTS, INC_
CANTON MILL
CANTON, NORTH CAROLINA
I
1
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10044
401014040
32.34.36
31 [A.B.
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39
30
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TANK
0
2_ DIGESTERS - PINE (9)
20. PINE TURPENTINE DECANTER
30. PINE BROWN SPILL TANK
31. PINE BROWNSTOCK WASHERS (3)
32_ PINE 1ST PRE 02 FILTRATE TANK
34_ PINE 2ND PRE 02 FILTRATE TANK
35. PINE 2ND PRE 02 MIX TANK
3G. PINE 3RD PRE 02 FILTRATE TANK
37_ PINE 3RD PRE 02 MIX TANK
38_ PINE BLOW TOWER
39. PINE PRIMARY KNOTTER
10. PINE SECONDARY KNOTTER
11. PINE SECONDARY KNOTTER ACCEPTS TANK
42. PINE SURGE TANK
a
YOL=
3917
aal.
SUMP PUMP LOCATIONS
E. EAST & WEST DIGESTER DOUBLE CHAMBERED SU
P. BROWN STOCK U-DRAIN WEST SUMP PUMP
O. BROWN STOCK U-DRAIN EAST SUMP PUMP
S. PINE KNOTTER SUMP PUMP
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— NCI- 1 FIB ERLINE
13 OAP INSPEC TIcN
BLIJ E RIDGE PAP ER PRODUCTS, INC .
CAN TON MILL
E ANT Q N. F•JDRTH CARDLINA
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21. HARDY/COD tLRPENTHE DECANTER
F!, HARDWOOD BROWN SPILL OI LLEC.TIM TANK
45, HAR CAN I}JO BR O W N 3TOCN WASHERS I4-
46.. H41rD 1ST PRE 02 FILTRATE TANK
47_ H W D 21'..0 RRE 02 FLT ATE TAM
4a_ H1'a 3Ra PRE 02 FLT ATE T4F•.;
49_ HWD 4TH PRE 02 FLTRATE TAIW
50_ HARDWOOD PRIMARY KNOTTER
51. H#RDY+O'D 9EcNaARV KNOTTER
52. SECONDARY *JOTTER ACCEPTS TANKS
53. HARD Wac'a SLOW TE+WER
43_ '1 FCIihI TANK
44-. '2 FC M TANK
SUMP PUMP Lcc ATKINS
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EVAPORATOR AREA
EIP INSPECTION
BLUE RIDE E PAPER Pf ODUCT5, INC.
CANTON MILL
WANTON, NORTH CAROLINAti .)\es
TANK EATKtIS
1. PIKE 'NEM 9Lh LIDUO R STORAGE
3 WEST GB FEED Tr41%IK
4. EkST C43 FEED TANK
5, SWENSQN FEED TALK
EVAF'0RAT 0 R OIL BUT TANK
F.. S'AE NSW EVAP0RAT0 R SKkl T'NK
NENSCN FOP 0RATOfR - F EELS
9 WEST o EVAPORATOR - 7 YEESELS
11. WEST GB EY eni9ATM SFFN TANK
1e. HARI:WOOD VIVI< BLACK LICILIOR STOKE
2!. WASH WATER TAW
56, HWD VIEW AZX UQUDR SOAP Tr41%IK
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O. E Y;FOR Alt "LP NORTH ELM' RAF
D. EVIPORATD 'V' 30IfTH BUMP PUMP
fR, HARDW000 WEAK UUUOR STORAGE C NTr41NIIENT

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AP
TANK LOCATIONS
14
-142.
16
22
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fikjiii
EA-44B
';41 B9 gal
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32.31.3E
1J . 61
F:E COVER( AR EA
IHP I NSPEZT ] ON
BLUE RIDGE PAPER PIRCOIJCT5, INC
CANTON MILL
CANTON, NORTH C IROL [ NA
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10, EAST HEAVY BLACK LIQUOR STORAGE TAW 40pp:•
12, NORTH OXIDIZER TANK
13_ CENTER OXIDIZER TANK
74-, SOUTH OXIDIZER TAIIK
15 EAST LI Irj:IDIzED ELACK LJQIJC STORAGE TAN
16_ WEST L Nm:IsIzED BLACK LIQUOR STORAGE TAIW
17. RED LIQUOR STCRAGE TANK
19_ TURPENTINE STORAGE TANK PUMP TANK
, wccIDIzED LIQUOR SOAP STAND PIPE
NO, 10 RECOVERY BOILER
NO, 11 RECOVERY HC1LER
sA=Ta1 i}
5•IJf' PUMP LOCATIONS
F, NO.II IRECO'EIRY BOILER 5UP.13 PUMP
H. FEED LIQUOR TANK FARM SUMP PUW
Ala
lg r- 411, SF

Insnections and Renair of Leaking Eciuinment
- Section (43O.O3(c(2*
• NPDES Permit Part A(6)
Section A(2)(i)
• Operating Areas
Performing Daily
Inspections:
— Tall Oil Making and
Finishing
— Recovery
— Evaporators
— Pine Fiberline
— Hardwood Fiberline
• Work Orders
— CODE "BMP"
4111110111iillildi
0 6 1 1 1 1 I I 1 1 1;:Sly°�tlllII '
GAF
QLLkCT Ilia

Inspections and Repair, cont.
• Must immediately repair leaking equipment items
• If repair not possible until next outage, temporary
means to mitigate (minimize) the leak must be
provided.
• Must track repairs and document for 3 years
(repairs made resulting from daily inspections)
• Must determine when it will be necessary to
curtail production (i.e., shutdown) to repair
leaking equipment items or prevent spills of black
liquor, soap or turpentine.

Continuous Monitorin *
• Required by permit
• Continuous and automatic (conductivity & level)
— Conductivity set points will trigger sumps for
soap and black liquor losses
— Level alarms will be used to monitor turpentine
systems
• Practices separate from BMPs
— Operators —monitor levels in tanks for overflows
— WWTP & operators —monitor sewers for flow and
conductivity
— WWTP —monitors the Primary Influent

Containment*
• Required
• Canton Mill has 24 bulk
storage tanks
• Annual tank inspection
and integrity test
• Canton Mill uses curbing
and diversion structures to
sumps in lieu of secondary
containment

Containment Cont.
• Most Spent Liquor Bulk Storage Tanks are
curbed to a sump area and are part of the
mill's tank integrity testing program
• Camp Branch
• Bulk Turpentine Storage is fully contained
• Soap/Turp. Loading areas curbed to a sump
area

Color Action Levels
• Action Levels were developed for Primary Influent Color
• Lower Action Level = 55,400 lbs/day
• Upper Action Level = 59,400 lbs/day
• Out of Control Level = 72,500 lbs/day*
• Exceed LAL for 2 consecutive days = investigation.
• Exceed UAL for 2 consecutive days = investigation and
corrective action
* Requires immediate investigation

Shill Response and Renortin
• Must RESPOND to monitoring systems
immediately; spills identified must be reported
immediately (report to supervisor) or call ext.
6711.
• Always notify WWTP at 2480 or by
radio (Channel 6B) if black liquor, soap, or
turpentine has been spilled or intentionally
diverted to the sewer.
• Supervisor to report incident to EHS

Site Modification &
Construction*
• Team meeting prior to any construction activities
in the pulping and recovery areas that could
potentially effect BMP covered equipment
— e.g. — black liquor tanks, piping, sumps, etc.
• Purpose
— Prevent a release of a BMP related material
— Ensure all involved are aware of the importance of
preventing a release

Recordkeenin*
• Mill must maintain:
— Repair records (including tank integrity tests)
— Training records
— Records of all BMP reports
— Monitoring records
• For 3 years from date created.

Review of Past Events
What Hannened?
1) Unscheduled Outage /
Scheduled Outage
2) Equipment Malfunction

Scheduled Outage
• On Wednesday, 6/21/17, 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.
.

Scheduled Outage cont.
— 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.

EouiDment Malfunction
• At 3:30am 12-11-17
• High Color was first discovered in a grab sample, 596mg/1
• Both the Pulp Mill and Recovery Foreman were notified of the high
color.
• Nothing was found by either foreman.
• Color samples were then taken every 30 minutes ranging in value from
349-857, from 3:50am-7:00am
• 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.

Equipment Malfunction cont...
• The bark dam was reconstructed and the leak to #4 sewer was stopped
at 6:00am.
• The decision was made by recovery supervision to take the evaporator
down at 8 : 3 0.
• Once offline maintenance repaired the leaking transfer line on the 2nd
effect of the Swenson evaporators.
• Color numbers returned to normal with the 9:00am sample reading 275
and the 11:00am 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.

BMP Events the past 5 years
3.5
3
2.5
1.5
1
0.5
0
BMP Events
4 5

Take Home Notes
• Continue Daily
Inspections
• Communication with
WWTP (2480)
• Report any spill to
supervisor
• Fill out necessary
forms every time

ATTACHMENT C

evergreen
packaging
Canton Office
175 Main Street • Canton, NC 28716
March 30, 2021 CBC 17-21
CERTIFIED MAIL Return Receipt Requested
7020 0640 0000 4606 2258
North Carolina Department of Environmental Quality
Division of Water Resources
ATTENTION: Central Files
1611 Mail Service Center
Raleigh, NC 27699-1611
Re: NPDES NO. NC0000272
Best Management Practices 2020 Annual Report
Blue Ridge Paper Products Inc. d/b/a Evergreen Packaging
Canton, NC
This letter report (two copies) is the 2020 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 E.4 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 2020
are as follows:
Effective Dates: 1 Jan 2020 — 31 Dec 2020
Action Level
Total Influent (TI) Color —
daily monitoring result
Action Required
1-Day Upper Action
Level (UAL)
> 72,500 Ibs/day for one day
Immediate investigation and documented
corrective action
2-day Upper Action
Level (UAL)
> 59,400 Ibs/day for two
consecutive days
Investigation and documented corrective
action
2-day Lower Action
Level (LAL)
> 55,400 Ibs/day for two
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
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 E.4. The permit -required BMP
investigation reports are maintained at the mill.

30 Mar 2020, Page 2
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 2020.
Date(s)
Total Influent
(TI) Color
Action Level and Summary
6 — 8 January
102,256 Ibs/day
1-day UAL / 2-day UAL — Investigation and
2020
112,491 Ibs/day
documented corrective action
79,869 Ibs/day
Cause(s)
In association with a planned mill outage, color material
accumulated in the Recovery black liquor sumps. The
contents were diverted to the sewers. The waste
treatment plant received high color material, which was
treated with color reduction polymer.
Corrective Action(s)
Proactive, frequent checks of area sewers and sump
pumps occurred to ensure the gates were closed and
sumps were pumping to the proper location. One -hour
color sampling was done for the duration of the outage
and the use of a chemical color reduction agent
increased. There were no NPDES discharge limit color
exceedances due to this event.
4 March 2020
79,092 Ibs/day
1-day UAL — Immediate investigation and
documented corrective action
Cause(s)
During a planned Recovery outage, material contained in
the black liquor sumps was diverted to the waste
treatment plant for a period of 50 minutes.
Corrective Action(s)
This material was captured in a spill protection vessel (a
spare clarifier) and was metered back into the waste
treatment system for further physical and biological
treatment. Treatment efforts resulted in a 46.8%
reduction in color. More frequent checks of sump system
were implemented to ensure pick up of color material.
There were no NPDES discharge limit color exceedances
due to this event.
Blue Ridge Paper Products Inc. dba Evergreen Packaging — Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

30 Mar 2020, Page 3
Date(s)
Total Influent
(TI) Color
Action Level and Summary
6 — 7 March
2020
71,552 Ibs/day
58,215 Ibs/day
1-day UAL/ 2-day LAL— Investigation and
documented corrective action
Cause and Corrective Action(s)
During a planned Recovery outage, material contained in
the black liquor sumps was diverted to the Waste
Treatment plant.
Corrective Action(s)
The material was chemically and biologically treated prior
to reintroduction to the receiving stream, and more
frequent inspections of the sump system occurs to ensure
the pickup of color material. There were no NPDES
discharge limit color exceedances due to this event.
1 April 2020
75,113 Ibs/day
1-day UAL — Immediate investigation and
documented corrective action
Cause(s)
During a planned Recovery outage, high -color material
that accumulated in black liquor sumps was diverted to
waste treatment.
Corrective Action(s)
More frequent inspections of sumps and conductivity
meters occurred, and the material was treated with color
reduction agents. The secondary effluent color was
decreased using the activated sludge WTP and chemical
amendment. There were no NPDES discharge limit color
exceedances due to this event.
Blue Ridge Paper Products Inc. dba Evergreen Packaging — Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

30 Mar 2020, Page 4
Date(s)
Total Influent
(TI) Color
Action Level and Summary
13 April 2020
76,206 Ibs/day
1-day UAL — Immediate investigation and
documented corrective action
Cause(s)
During upset conditions in the pulp mill, the color became
elevated. The pulp mill experienced run -ability issues,
causing a diversion of black liquor to the sewers.
Corrective Action(s)
The material was treated with color reducing agents, and
the area was inspected frequently. The color event was
not ongoing. After the flash floods, the flow was close to
normal operation and the process was restarted to
decrease color. There were no NPDES discharge limit
color exceedances due to this event.
16 — 17 April
57,897 Ibs/day
2 Day LAL — Investigation and documented corrective
2020
60,664 Ibs/day
action
Cause(s)
The MRP was down for two days, so there was an
excess in pine bleach filtrate. Based on the filtrate
balance, the percent closure within the pine bleach plant
was affected, so the color material was sent to waste
treatment.
Corrective Action(s)
More frequent inspections of lines for cracks, fissures, or
indications of stress or wear were implemented, and the
material was treated with color reduction agents prior to
release to the effluent. Since no black liquor, soap, or
turpentine was released, this event qualifies as non-BMP,
but is included in the report to acknowledge that the 2-
day lower action limit was triggered and investigated.
However, there were no NPDES discharge limit color
exceedances due to this event.
Blue Ridge Paper Products Inc. dba Evergreen Packaging — Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

30 Mar 2020, Page 5
Date(s)
Total Influent
(TI) Color
Action Level and Summary
10 — 11 May
288,821 Ibs/day
1-day UAL / 2-day UAL — Investigation and
2020
80,979 Ibs/day
documented corrective action
Cause(s)
An electrical ground created an unexpected power
outage that caused #10 recovery boiler to go offline. Due
to the power outage, dilution water was added to the
cyclones as a safety mechanism, causing the material to
overflow. The next day, during a cyclone wash, black
liquor was sent to the sewers.
Corrective Action(s)
Material was treated with color reduction agents, with
most of the material captured in a spare clarifier/spill
protection vessel during both events. More frequent
scans of the conductivity meters and temperature gauges
were implemented, and an investigation into the cause of
the electrical ground occurred to prevent future issues.
There were no NPDES discharge limit color exceedances
due to this event.
1 June 2020
112,345 Ibs/day
1-day UAL — Investigation and documented corrective
action
Cause(s)
During an annual outage, the color material contained in
a #10 recovery boiler sump was unintentionally diverted
to the sewer, causing heightened color values.
Corrective Action(s)
Operations was advised to be diligent with
communications of color material to the waste treatment
staff. The color material was captured in a spare clarifier
for further treatment prior to slowly being metered back
into the system. Secondary effluent color was improved
prior to discharge. There were no NPDES discharge limit
color exceedances due to this event.
Blue Ridge Paper Products Inc. dba Evergreen Packaging — Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

30 Mar 2020, Page 6
Date(s)
Total Influent
(TI) Color
Action Level and Summary
17 July 2020
83,106 Ibs/day
1-day UAL— Investigation and documented corrective
action
Cause(s)
While #10 recovery boiler was down for a cyclone wash,
the boiler sump lost prime twice, allowing a large amount
of wash water material from the black liquor cyclones to
enter the main mill sewer.
Corrective Action(s)
The sump pump internal flapper was changed and the
discharge check valve was cleaned to reduce the
possibility of the pump losing prime again. The material
was biologically treated. There were no NPDES
discharge limit color exceedances due to this event.
12 — 14
177,701 Ibs/day
1-day UAL i 2-day UAL — Investigation and
September
128,859 Ibs/day
documented corrective action
2020
55,837 Ibs/day
Cause and
An unexpected power outage caused all mill systems to
go offline/inoperable. The black liquor sumps, green
liquor, and weak wash all over -ran to the sewer.
Corrective Action(s)
Color material was captured in a spare clarifier and was
chemically treated prior to reintroduction to the system.
Lower color material was treated with color reduction
agents. There were no NPDES discharge limit color
exceedances due to this event.
Blue Ridge Paper Products Inc. dba Evergreen Packaging — Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

30 Mar 2020, Page 7
Date(s)
Total Influent
(TI) Color
Action Level and Summary
17 — 18
105,121 Ibs/day
1 day UAL / 2-day UAL — Investigation and
September
79,698 Ibs/day
documented corrective action
2020
Cause(s)
During a planned outage, the Recovery, Utilities, and
Pulp Mill departments were unable to contain all color
material in the sumps. Most tanks and vessels needed to
be drained prior to the extended outage.
Corrective Action(s)
Plans were in place to chemically treat any color releases
and capture flow if necessary. The material was treated
with color reduction agents and most of the high color
material captured in a spare clarifier. There were no
NPDES discharge limit color exceedances due to this
event.
29 September
100,483 Ibs/day
1-day UAL — Immediate investigation and
2020
documented corrective action
Cause(s)
Following a planned outage, an unplanned power outage
prevented the Recovery, Utilities, and Pulp Mill
departments from being able to contain all color material
in the sumps.
Corrective Action(s)
Plans were created to mitigate color and effectively
prevented color exceptions in the secondary effluent.
Flow was captured and color material was chemically
treated. There were no NPDES discharge limit color
exceedances due to this event.
Blue Ridge Paper Products Inc. dba Evergreen Packaging — Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

30 Mar 2020, Page 8
Date(s)
Total Influent
(TI) Color
Action Level and Summary
11 — 12
79,180 Ibs/day
1 day UAL / 2-day UAL — Investigation and
October 2020
59,379 Ibs/day
documented corrective action
Cause(s)
Following start up from a planned Recovery outage, the
black liquor sumps were unable to contain all color
material. Additionally, the conductivity probe in the area
was reading incorrectly.
Corrective Action(s)
Repairs were made to the affected areas while normal
color mitigation plans were in place; maintained regular
communication with the areas discharging color to the
sewers, maintained the ability to chemically treat material
and divert the flow of material to a spare catch clarifier for
treatment. There were no NPDES discharge limit color
exceedances due to this event.
9 — 10
112,157 Ibs/day
1 day UAL / 2-day UAL — Investigation and
November
62,892 Ibs/day
documented corrective action
2020
Cause(s)
During normal operations, a power outage caused a
failure of the #11 recovery boiler sump pump. During this
period of inoperability, the pump became plugged and the
contained black liquor overflowed to the sewers.
Corrective Action(s)
Repairs were made within 4.5-5 hours, however the color
material remained in the primary influent system for a
period exceeding 24 hours. One million gallons of
material was captured in spare clarifier before additional
biological treatment. There were no NPDES discharge
limit color exceedances due to this event.
Blue Ridge Paper Products Inc. dba Evergreen Packaging — Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

30 Mar 2020, Page 9
Date(s)
Total Influent
(TI) Color
Action Level and Summary
10 — 14
73,971 Ibs/day
1 day UAL / 2-day UAL — Investigation and
December
53,102 Ibs/day
documented corrective action
2020
60,094 lbs/day
62,393 Ibs/day
Cause(s)
57,800 Ibs/day
During the start-up phase after a planned outage, several
black liquor pumps within the hardwood pulp mill became
plugged, causing liquor to be diverted to the sewer.
Corrective Action(s)
Waste treatment operators were notified in a timely
manner, and high color material was captured in a spill
containment clarifier. The sumps were cleared and
repaired. During the next three days, color continued to
be elevated, but was chemically and biologically treated
and monitored hourly. There were no NPDES discharge
limit color exceedances due to this event.
Please contact us if you have questions regarding this information.
Sincerely,
Chuck Cranford
Environmental Manager — Waste and Water Programs
Evergreen Packaging — Canton Mill
[e-mail]
cc:
Mr. Landon Davidson
DWR Regional Supervisor, Asheville Regional Office
North Carolina Department of Environmental Quality
2090 U.S. Highway 70
Swannanoa, NC 28778
C. File — Wastewater
Tracy Willis
Operations Supervisor/ORC - WWTP
Evergreen Packaging — Canton Mill
[e-mail]
Blue Ridge Paper Products Inc. dba Evergreen Packaging — Canton Mill
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000

ATTACHMENT D

WTP Influent Conductivity
PI Trend
11/23—11/25, 2021
Ad -Hoc Trend
11/26/2021 12:00-00

Color & Fiber Monitoring Sheet
Notify Pulp Mill and Recovery Supervisors by radio if color exceeds 400 ppm.
During Outage, notify Pulp Mill and Recovery Supervisors of each color.
Observe the amount of fiber on the pad after each HR color.
Enter Low, Med, or High into Excel.
Non -Outage Color capture set point is 500 ppm - divert to empty clarifier.
Outage color capture set point is 900 ppm - divert to empty clarifier.
Pulp Mill: 1AJ1 B
Recovery: 5C
11/12PM: 11A
20PM: 11B
19PM: 11C
Indicate Channel If No Answer
Record all color diversions, color removal polymer addition times, & clarifier drain times at bottom of sheet.
Date LL Color,
//-2 a
Composite
12:00 AM
1:00 AM ll
2:00 AM
3:00AM
4:00AM
5:00 AM __._...70_
6:00 AM
7:00 AM -71
8:00 AM .�_
9:00 AM 1,
10:00 AM
Fiber
(Circle)
LMH
LM
LMH
LM
LMH
L
LMH
L M©
LMH
L
LMH
m
Grab @Time
11:00 AM 7 5 I L-1
12:00 PM
1:OOPM g Z
2:00 PM el
pp L M H
3:00PM __.l.__.!___-.
4:00 PM L M H
5:00 PM 9 / L M�
6:00 PM L M H
8:00 PM L M H
9:00 PM /3 7 LCI-1
10:OOPM LMH
11:00 PM 2 /q
8-hr
Color
7L/
8-hr
Color
67
8-hr
Color
Ni
Date
LL Color, ppm
Composite Fiber
l�—a3 (Circle)
12:00 AM L M H
Grab @Time
1:00AM 36,0 LM it
2:OOAM LMH
3 00 AM A,3 L
4:00AM LMH
6:00AM LMH r4/4 ?"168
7:00 AM 97J L0H fiA464j1/ J43
8:00 AM LMH -v3S
9:00 AM 701 L M H
10:00 AM L M H
11:00 AM 350 L M H
12:00 PM L M H
1:00 PM /0 6 LMH _ -
2:00 PM L M H
3:00 PM tt LMH 111,
4:OOPM LMH
5:OOPM /) LMH
6:OOPM LMH
7:O0PM // LMH
8:00PM LMH
91
9:00PM 6,2s LMH 170:15: y 150,,,9e
10:00 PM LMH
11:OOPM 73 LMH
8-hr
Color
� -rl
8-hr
Color
a1_3
8-hr
Color
A /6
NOTE: If 24-hr influent composite sample is 30% higher than the average of the 3-8hr samples a rerun of the influent sample
needs to be made. This result will need to be averaged with the initial reading and documented accordingly.
Color Removal Polyamine Addition
Date
Color Event Capture
Start Time
Stop Time
S • litter Box or . #1 Clarifier
Clarifier Drain
Date
Start Time
Stop Time
X:\Room Runner Sheets\Color Monitoring Sheet.docx

Color & Fiber Monitoring Sheet
Notify Pulp Mill and Recovery Supervisors by radio if color exceeds 400 ppm.
During Outage, notify Pulp Mill and Recovery Supervisors of each color.
Observe the amount of fiber on the pad after each HR color.
Enter Low, Med, or High into Excel.
Non -Outage Color capture set point is 500 ppm - divert to empty clarifier.
Pulp Mill: 1A/1B
Recovery: 5C
11/12PM: 11A
20PM: 11B
19PM: 11C
Outage color capture set point is 900 ppm - divert to empty clarifier. Indicate Channel If No Answer
Record all color diversions, color removal polymer addition times, & clarifier drain times at bottom of sheet.
LL Color, ppm
Date
LL Color, ppm
12:00 AM
1: OO AM
2:00 AM
3:00 AM
4:00 AM
5:00 AM
6:00 AM
7:00 AM
8:00 AM
9:00 AM
10:00 AM
11 T00AM
12:00 PM
1:00 PM
2:00 PM
3.00PM
4:00 PM
5:00 PM
6:00 PM
7:00 PM
8:00 PM
_..-9:00 PM
10:00 PM
11:00 PM
Composite
321.
13
Fiber
(Circle)
LMH
LM(6)
LMMHH
LMH
Grab @Time
LMH
LMH .ri4.'.
LMH
LM
LM�
LMH
l�iA H
LMH
L®H-..
LMH
LM®
LMH
L(1H
LMH
LMH
i
8-hr
Color
aS
8-hr
Color
8-h r
Color
Date
I tbC
12:00 AM
1:00 AM
2:00 AM
3:00AM
4:00 AM
5:00 AM
......_._.........
6:00AM
7:00 AM
8:00 AM
9:00 AM
10:00 AM
11:00AM
12:00 PM
1:00 PM
2:00 PM
3:00 PM
4:00 PM
5:OOPM
6:00 PM
7 :00 PM
8:00 PM
9:00 PM
10:00 PM
11:00 PM
Composite
Q(7
Fiber
(Circle)
LMH
Grab @Time
L M)
LMH
L
LMH
LMCRJ�
LMH
LM
LMH
L H
LMH
Lt,PH
LMH
Lc H
LMH
Li
LMH
L_..
LMH
................ ............
LM�
LMH
L M�
LMH
L V�1H
8-h r
Color
log
8-hr
Color
8-hr
Color
/;J
NOTE: If 24-hr influent composite sample is 30% higher than the average of the 3-8hr samples a rerun of the influent samp e
needs to be made. This result will need to be averaged with the initial reading and documented accordingly.
Color Removal Polyamine Addition
Color Event Capture
Date
Start Time
Stop Time
Slitter Box or . #1 Clarifier
Clarifier Drain
Date
Start Time
Stop Time
X:\Room Runner Sheets\Color Monitoring Sheet.docx