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HomeMy WebLinkAboutNC0000272_Annual Progress Report_20160804 ever reen'.rI Canton Office g packaging 175 Main Street• Canton, NC 28716 NMM#37-16 July 26, 2016 CERTIFIED MAIL RETURN RECEIPT REQUESTED 7099 3220 0007 0371 4767 Landon Davidson Regional Supervisor Division of Water Resources North Carolina Department of Environmental Quality Asheville Regional Office 2090 U.S.Highway 70 RECEIVEDINCDEW R Swannanoa,North Carolina 28778 AUG ® 4 2016 Re: Annual Progress Report on Color tjYater Quality NPDES Permit No.NC0000272 Permitting vection 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 sixth year of the permit(July 2015 through June 2016). Very truly yours, BLUE RIDGE PAPER PRODUCTS INC. DOING BUSINESS AS EVERGREEN PACKAGING By: Nick McCracken EHS Water Supervisor 828-646-2874 nick.mccrackenneverpack.com Enclosure: July 2016 Annual Progress Report on Color cc: NC DWR—Complex NPDES Permitting Unit,Raleigh Billy Clarke,Roberts and Stevens fresh by designru Doing Business in California as Evergreen Beverage Packaging EOHS\Share\Water\NPDES\Permits\2010 NPDES Permit\Permit Reports\Color Reports 2010 Prmt July 2016 — 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 sixth year of the permit, July 2015 through June 2016, with emphasis on the mill's Best Management Practices (BMP) program refinements. Color-related reports previously submitted to the NC Division of Water Resources (DWR)under terms of the May 2010 NPDES permit include the following: 4 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] o July 2015 Annual Progress Report on Color [Evergreen 2015] 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 July 2016 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 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 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. 1 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). 1 The initial effluent limit was 38,020 lbs per day(annual average)Effective July 1,20014,and in accordance with Section A.(8.)paragraph 2.,the effluent limit for color was reduced to 36,000 lbs per day(annual average). July 2016 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 Figure 3 - Annual Average Effluent Color Blue Ridge Paper Canton Mill, 1997 thru 2016 80 y 70 2 BFR & Cluster Rule Color Improvement Projects 0 60 48 0 50 40 39 37 36 36 38 36 35 36 38 36 L 40 c 30 20 a 10 0 W A FO 0 0 ►� ti 3 D� h ro 1 0 0 0 ►� q, 3 D, h ro moo, moo, goo 00 00 00 00 00 00 00 00 00 00 0►. 0►. 0►. o� 0►. o� o� IV ti ti ti ti ti ti ti ti ti ti ti ti ti ti ti ti 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 an efficiency of 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 improved over the previous year's performance. The increased outage schedule for the lower end of the mill continues to improve process July 2016 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 reliability. This operational strategy with improvements to operating systems and control strategies contributed to color performance in 2015 &2016. IV. Color Proiects and Refinements to Best Management Practices The Canton Mill has a standing Color Team that meets regularly to review color performance. 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 2011] 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 1 are identified by Capital July 2016 — 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 2016 exceeded $3.95 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 CII'—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* July 2016 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 Table 1 Color Team Capital and Maintenance Projects 2010 - Forward Year Project Description and Cost Information for Capital Projects 2010 Replaced conductivity and level switches in East Heavy compound with new,more reliable type. BMP improvement. o Completed 3Q2010, 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 5a' effect of the Swenson evaporator set. Spray allows the 5a' 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 July 2016 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 Table 1 Color Team Capital and Maintenance Projects 2010 - Forward Year Project Description and Cost Information for Capital Projects 2011 Process lines to allow front-end boil out of West GB evaporator set. Allows more frequent, less intense evaporator cleaning. BMP improvement for process reliability to avoid carryover of color material into condensate systems. Reduces the volume of color material generated by evaporator boil out during outages. Color material carry over from evaporators into condensates is related to TRW Recommendations to prevent sewer-generated color. o Completed May 2011, cnsd* Repaired drain valves on No. 2 and 3 Primary Clarifiers. Allows reliable isolation of one of these larger volume clarifiers as the spare clarifier for high color material diversion during semi-annual outages. BMP sustaining measure. o Completed March 2011, cnsd* Pine Weak Liquor Tank shell replacement/repairs. BMP sustaining measure. o Completed May 2011 o CIP—331985 o Cost—$349,000 Installed soft start on motors for the hardwood weak black liquor transfer pumps and hardwood blow tower dilution pumps. Project reduces pump start water hammer in pipes containing black liquor and reduces risk of gasket failure,valve failure and/or pipe hanger failure from water hammer pipe movement. Project was identified by a water hammer valve failure in May 2011 that was contained within the process and did not reach the wastewater plant. o Completed May 2011 on hardwood blow tower dilution pumps o Completed Jul 2011 on hardwood weak black transfer pumps o 4 soft starts at$7540 each,project cost of$30,160 plus installation cost on maintenance expense July 2016 — 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 o 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 July 2016 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 Table 1 Color Team Capital and Maintenance Projects 2010 - Forward Year Project Description and Cost Information for Capital Projects 2012 Replacement of floor drain piping in Hardwood fiberline. Floor drains carry spill material directly to the Hardwood Spill Tank. This replacement minimized losses to the mill sewer system. o Completed Fall 2012, 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 CII' - 370243 o Cost- $581,442 July 2016 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 Table 1 Color Team Capital and Maintenance Projects 2010 - Forward Year Project Description and Cost Information for Capital Projects 2013 Installation of an additional u-drain located on the north side of the Hardwood Blow Tower. This drain will allow the capture and redirection of weak black liquor material from around the blow tower to the mill sump system. o Completed March 2013 o Cost- $36,641 West Green Liquor Clarifier shell replacement/repairs. BMP sustaining measure and project related to TRW Recommendations regarding prevention of sewer-generated color—high pH green liquor. o Completed March 2013 o CIP - 370243 o Cost- $122,000 Installation of new Oramac shower bars on the West Decker at the Hardwood Fiberline. These shower bars help improve washing efficiency and reduced carry-over of sodium compounds into the bleach plant, which in turn, will reduce D 1 stage C102 demand and effluent color from the bleach plant. o Completed April 2013 o Cost-—$40,000 West White Liquor Storage Tank shell replacement/repairs. BMP sustaining measure and project related to TRW Recommendations regarding prevention of sewer-generated color—high pH white liquor. o Completed April 2013 o Cost- $122,000 West GB 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 July 2016 — 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 3rd effect. BMP sustaining measure. o Completed April 2014, csnd* North Oxidizer feed piping upgrade to stainless steel. BMP sustaining measure. o 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* July 2016 — 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 D1 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 WWTP. 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 2nd 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 July 2016 — 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 2015 Green Liquor piping and hand valve replacement to the Causticizers. BMP sustaining measure. o Completed July 2015 o Cost- $8,000 Black liquor solids meter installation on Hardwood Brownstock fiberline. Assisted mill in developing operating strategy that minimizes color carryover to bleach plant stages that reach the sewer. o Completed September 2015 o Cost- $8,300 2016 White Liquor pump tank repairs. Reinforcement of outer shell to prevent leaks. BMP sustaining measure. o Completed April 2016 o Cost- $45,000 Improvement to Weak Wash overflow monitoring. Installation of temperature probe on overflow line and level cell in weir box to sewer. BMP measure designed to assist operators in monitoring Weak Wash releases to sewer. o Completed April 2016 o Cost- $10,600 *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. July 2016 — 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 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. 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. 2014 Polymer study of the Acid Sewer stream at the WWTP. 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 put into use. 2016 CRP purge reduction strategy to reduce color loading to the WWTP. White liquor is being tested for chloride content. Based on the results, if the chloride content is low the purge stream can be reduced resulting in less volume of color material to the mill sewer system. July 2016 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 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 to ten 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. V. TRW Recommendations The Canton Mill continues to review the listed items under Section A.(8.)l0. 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. BMP sustaining measures allow the mill to strengthen and enhance its color prevention program. This year further improvements to the mill's Weak Wash purge strategy included additions to the monitoring system already in place for the North Mud Washer. The temperature probe to the overflow line and level cell in the weir box will assist operators in identifying overflows sooner and also help to quantify the losses and their July 2016 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No. NC0000272 ------------------------------------------------------------ -------------------------------------------------------------- duration. With this information we can better understand the potential impact to sewer generated color at the wastewater treatment plant. YI. 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. July 2016 — 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. Evergreen 2015 — 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, 2015. July 2016 — Annual Progress Report on Color Blue Ridge Paper Products Inc. dba Evergreen Packaging Canton,North Carolina NPDES Permit No.NC0000272 NC OAH 2012 — 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.