NC0000272_Performance Summary_20220331

pactiv
evergreen
March 31, 2022
175 Main Street
Canton, NC 28716
828.646.2000
pactivevergreen.com
CBC 20-22
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7018 2290 0001 7880 9972
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 2021 Annual Report
Blue Ridge Paper Products LLC d/b/a Evergreen Packaging
Canton, NC
This letter report (two copies) is the 2021 summary of Best Management Practices (BMP) daily
monitoring for the Canton Mill. The report is required on or before March 31 st 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 2021
are as follows:
Effective Dates: 1 Jan 2021— 31 Dec 2021
Action Level
Total Influent (TI) Color
— daily monitoring result
Action Required
1-Day Upper Action
Level (UAL)
> 72,500 lbs/day for one day
Immediate investigation and
documented corrective action
2-day Upper Action
Level (UAL)
> 59,400 lbs/day for two
consecutive days
Investigation and documented corrective
action
2-day Lower Action
Level (LAL)
> 55,400 lbs/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.
The Canton Mill met all NPDES color permit limits during 2021.

Date(s)
Total Influent
(TI) Color
Action Level and Summary
17 — 18 February
79,946 lbs/day
1-day UAL / 2-day UAL — Immediate investigation
2021
77,294 lbs/day
and documented corrective action
Cause(s)
During normal operation on 2/17/2021, a tube leak
developed on #15 digester black liquor heater, causing
black liquor to enter the sewer. Additionally, a black
liquor mixture was found going to the sewer.
Corrective Action(s)
The digester liquor heater valve was taken out of service
for repairs. To terminate the sewering, the valves
around the drain were closed and black liquor valves at
the tie in points along the black liquor/mill water lines
were reseated to determine if black liquor was still
leaking into the water. Proactive, frequent checks of
area sewers and sump pumps occurred to detect any
other color losses when indicated. This was a two-day
event based on the timing of the beginning and end of
the event. There were no NPDES discharge limit color
exceedances due to this event.
18 — 19 March
97,660 lbs/day
1-day UAL/ 2-day UAL— Immediate investigation
2021
79,817 lbs/day
and documented corrective action
Cause(s)
In preparation for a planned cyclone wash, operators
were filling recovery boiler cyclones with condensate
when a crossover valve near the feed pump failed and
the cyclone filled with heavy black liquor that ran over
to the sewers.
Corrective Action(s)
The valve was identified and repairs were made
immediately. The high color material was captured in a
spare clarifier and was chemically treated in the WTP.
This was a two-day event based on the timing of the
beginning and end of the event. There were no NPDES
discharge limit color exceedances due to this event.

Date(s)
Total Influent
(TI) Color
Action Level and Summary
20 — 22 March
78,474 lbs/day
1-day UAL / 2-day UAL — Immediate investigation
2021
87,404 lbs/day
and documented corrective action
84,380 lbs/day
Cause(s)
Power failure caused a loss of control of the black
liquor containment sumps, which subsequently
overflowed to the sewer.
Corrective Action(s)
Repairs were made as soon as practicable, the
equipment was restarted, and normal operations
continued. The high color material was captured in a
spare clarifier and was chemically treated in the WTP.
This event spanned multiple days based on the timing of
the beginning and end of the event. There were no
NPDES discharge limit color exceedances due to this
event.
24 — 25 March
82,234 lbs/day
1-day UAL / 2-day UAL — Immediate investigation
2021
55,737 lbs/day
and documented corrective action
Cause(s)
The packing of the hardwood weak black liquor tank
pump was found to be leaking and the hardwood brown
knotter catch basin was partially plugged, causing color
material to run around the containment. Additionally, 11
hours of pine screen downtime and a 3-hour power
outage occurred.
Corrective Action(s)
The pump was re -packed, the packing water was
adjusted, and the partially plugged sump was cleared as
soon as practicable. The high color material was
chemically treated in the WTP. This event spanned
multiple days based on the timing of the beginning and
end of the event. There were no NPDES discharge limit
color exceedances due to this event.

Date(s)
Total Influent
(TI) Color
Action Level and Summary
27 March 2021
129,151 lbs/day
1-day UAL — Immediate investigation and
documented corrective action
Cause(s)
A leak in a soap transfer pump packing, created an
unplanned color diversion to the sewer.
Corrective Action(s)
Upon discovery of the packing leak, the pump was
taken out of service. The pump was re -packed on
3/29/2021. The residual soap was washed up to #11
Recovery Boiler sump, following inspection to ensure it
was working properly, and was processed through the
wash water tank by the evaporators. Color material was
captured in a spare clarifier and was chemically treated
in the WTP. There were no NPDES discharge limit
color exceedances due to this event.
4 April 2021
152,930 lbs/day
1-day UAL — Immediate investigation and
documented corrective action
Cause(s)
Color unexpectedly became elevated on 4/4/2021, and
upon investigation, the wash water tank was found to be
leaking. Black liquor reached the sewer.
Corrective Action(s)
The level in the tank was pulled below the location of
the leak and maintained until repairs could be made on
4/8/2021. The liquor was captured in a spare clarifier
and treated in the WTP. There were no NPDES
discharge limit color exceedances due to this event.

Date(s)
Total Influent
(TI) Color
Action Level and Summary
5 April 2021
77,105 lbs/day
2-day UAL — Investigation and documented
corrective action
Cause(s)
While boiling out the West GB evaporator set following
a mill -wide power failure on 4/3/2021, the sumps filled
with low conductivity material. The evaporator set
required a longer wash time than usual and the sumps
could not contain all of the color material and some was
discharged to the sewer.
Corrective Action(s)
The color material was captured in a spare clarifier and
treated in the WTP. There were no NPDES discharge
limit color exceedances due to this event.
21 — 23 August
114,937 lbs/day
1-day UAL / 2-day UAL — Immediate investigation
2021
77,390 lbs/day
and documented corrective action
64,294 lbs/day
Cause(s)
Due to significant flooding on 8/17/2021, the mill was
forced to shut down. When attempting to start up
around 23:00 on 8/20/2021, the pump packing retaining
ring began to leak, causing black liquor to enter the U-
drains. During other start-up events on 8/22/2021 and
8/23, the evaporators became air locked, causing black
liquor to be released to the sewer.
Corrective Action(s)
The east heavy black liquor pump was taken out of
service until the packing ring and retainer could be
repaired. The high color material on all 3 days was
received by the WTP and treated. This event spanned
multiple days based on the timing of the beginning and
end of the event. There were no NPDES discharge limit
color exceedances due to this event.

Date(s)
Total Influent
(TI) Color
Action Level and Summary
15 — 16
82,645 lbs/day
1-day UAL / 2-day UAL — Immediate investigation
September 2021
86,469 lbs/day
and documented corrective action
Cause(s)
East knotter feed pump was leaking black liquor to the
sewer. Cleaning of a separate compound contributed
additional color.
Corrective Action(s)
The east heavy black liquor compound valves were
closed. Repairs were planned for the east knotter feed
pump. The material was captured and treated in the
WTP. This event spanned two days before repairs could
be made to mitigate the elevated color. There were no
NPDES discharge limit color exceedances due to this
event.
21 — 23
58,390 lbs/day
1-day UAL / 2-day UAL — Immediate investigation
September 2021
84,476 lbs/day
and documented corrective action
75,172 lbs/day
Cause(s)
The pine fiberline experienced a filtrate (weak black
liquor) imbalance that caused a higher -than -normal
filtrate loss to the sewer.
Corrective Action(s)
The filtrate imbalance was stabilized and the color
diminished. The high color material on all 3 days was
received by the WTP and treated. There were no
NPDES discharge limit color exceedances due to this
event.

Date(s)
Total Influent
(TI) Color
Action Level and Summary
11 — 12 October
73,086 lbs/day
1-day UAL / 2-day UAL — Immediate investigation
2021
100,661 lbs/day
and documented corrective action
Cause(s)
Multiple activities during shutdown for the #10
Recovery Boiler/Hardwood fiberline outage impacted
color levels.
Pulp Mill: on 10/10/2021, the hardwood 2nd stage
filtrate tank was emptied. WTP personnel added color
reduction polymer in order to offset known potential
color to the sewers. On 10/11/2021, there were multiple
tanks emptied in preparation for the outage, with some
material collection in the east hardwood secondary
knotter sump.
Recovery: In preparation for the outage, the liquor
system, cyclones, dissolving tank, and boiler were being
washed out. Some losses occurred from the liquor
system and cyclones. The dissolving tank did not
contain black liquor specifically, but the washed out
material did contain some color and turbidity.
Following shutdown procedure, the Swenson evaporator
set was boiled out and operators turned the product
liquor to the sewer at 5% solids, notifying the WTP.
Some soap got to the sewer, but the pump was shut off
when discovered.
Corrective Action(s)
Communication with the WTP to ensure the material
was captured and treated throughout the remainder of
the shutdown procedures/outage. Material was treated in
the WTP. There were no NPDES discharge limit color
exceedances due to this event.

Date(s)
Total Influent
(TI) Color
Action Level and Summary
18 — 19 October
111,436 lbs/day
1-day UAL / 2-day UAL — Immediate investigation
2021
93,978 lbs/day
and documented corrective action
Cause(s)
Multiple activities during startup from the #10 Recovery
Boiler/Hardwood fiberline annual outage impacted
color levels.
Pulp Mill: during start-up from the outage, there was
higher than usual filtrate loss to the sewers in areas
inaccessible to the sumps, impacting sewer color.
Recovery: when starting up from the outage, the
Swenson evaporator set outpaced the sump and some
black liquor was sent to the sewers.
Corrective Action(s)
Communication with the WTP to ensure the material
was captured and treated throughout start-up from the
outage. Material was treated in the WTP. There were
no NPDES discharge limit color exceedances due to this
event.
22 — 23 October
70,363 lbs/day
1-day UAL / 2-day UAL — Immediate investigation
2021
60,868 lbs/day
and documented corrective action
Cause(s)
During start-up from the annual hardwood fiberline
outage, there were higher than usual color samples
gathered at the 2B sewer sampler. The cause was
determined to be the result of upset conditions during
start-up.
Corrective Action(s)
Communication with the WTP to ensure the material
was captured and treated throughout start-up from the
outage. Material was treated in the WTP. There were
no NPDES discharge limit color exceedances due to this
event.

Date(s)
Total Influent
(TI) Color
Action Level and Summary
26 October 2021
75,944 lbs/day
1-day UAL — Immediate investigation and
documented corrective action
Cause(s)
East heavy black liquor storage north pump was taken
out of service to repack. During the lock -out tag -out
procedure, the suction valve would not hold, causing a
loss of black liquor into the compound. The level rose
and to protect the equipment and the safety of the
operators, the drain was opened to the compound.
Corrective Action(s)
When the level of black liquor was down to a safe
amount, the drain was closed. The material was
vacuumed out and discharged to the #11 Recovery
Boiler sump pump. Repairs were made following the
relocation of the material. The color material was
treated in the WTP. There were no NPDES discharge
limit color exceedances due to this event.
23 — 24
34,959 lbs/day
Soap Loss — Immediate investigation and
November 2021
33,237 lbs/day
documented corrective action
Cause(s)
Multiple factors were investigated as potential causes
for the loss of soap to the sewer, such as mechanical
components, system processes, communication/warning
systems, and operator actions/responses, but the most
likely causes were 1. discharge from the tall -oil -making
process area and 2. overflow from the pine weak liquor
storage tank.
Corrective Action(s)
The soap was treated by the WTP. However, in an
attempt to prevent future soap excursions, the following
corrective actions were identified and are in the process
of/have been implemented in the mill:
• Briefings/communications with operators to
emphasize the importance of containing soap in
mill processes/avoiding discharge to WTP;
• Updating BMP training (on -going);
• Inspection of spent liquor, turpentine and soap
containments, conductivity sensors, and level

Date(s)
Total Influent
(TI) Color
Action Level and Summary
transmitters were all inspected to ensure
functionality;
• 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, along with a
text -enabled alarm;
• Installation of surveillance camera
equipment/monitoring of visible feed by
operators;
• Additional containment to capture possible soap
overflows was provided by construction of a 4-
foot containment wall with a drain valve.
Three daily maximum and one monthly average BOD5
permit limit exceedances were recorded during this
event.
18 — 20
61,543 lbs/day
2-day UAL — Investigation and documented
December 2021
64,784 lbs/day
corrective action
57,167 lbs/day
Cause(s)
The solution transfer pump in the Chloride Removal
Process (CRP) was shut down due to pump failure. At
the time, the Recovery area began sending dark filtrate
from the CRP system to the sewer since CRP was down.
Following replacement of the pump on 12/20, it was
found the discharge line was plugged on startup. During
this time, dark filtrate was still flowing to the sewer,
elevating color. Investigation revealed that the cause of
the elevated color was filtrate.
Corrective Action(s)
The solution transfer pump was replaced on
12/20/2021, but plugged upon start up. The plugged line
was cleared and color dropped. The color material was
treated in WTP. There were no NPDES discharge limit
color exceedances due to this event.

23 December
2021
84,689 lbs/day
1-day UAL — Immediate investigation and
documented corrective action
Cause(s)
The Pine Primary Knotter began flushing at 05:56. The
operator attempted to pull back on the load from the
blow tower and cut knotter dilution to decrease the
pressure; this proceeded to cause the secondary knotter
accepts tank to overflow. A manual flush of the
secondary knotter was completed and when checking
the purge from the A and B valves, the B valve was
found partially open, causing black liquor to flow out.
The black liquor was flowing into a U-drain that lead to
the east sump. However, the sump was not pumping.
The level was high and rich with content from the
secondary knotter accepts tank. Pulp had accumulated
in the sump, filling it up.
Corrective Action(s)
When the issue was first identified, the operator
attempted to pull back load from the blow tower and cut
back on knotter dilution to decrease pressure and stop
the flushing. This caused the secondary knotter accepts
tank to overflow, so the operator then tried to increase
rejects from primary screen in an attempt to flush the
primary knotter.
The crew leader performed a manual flush of the
secondary knotter to prevent plugging. Once completed,
the crew leader went to check purge through the A and
B valves and identified the leak. Upon identifying the
leak, the operator went through the TCC to try bringing
load back on. The A and B valve area was flushed two
more times, and the B valve finally closed.
Once this was closed, a round was made to determine
where the black liquor was flowing to. When it was
discovered that the east sump, where the color material
was accumulating, was not pumping, it was flushed and
the pump was switched to manual. The pump was
primed and all of the material was placed in a spill
containment area. Once the load was increased, the
secondary knotter accepts tank stopped overflowing and
the issue was resolved.
The material was treated in the WTP. There were no

Date(s)
Total Influent
(TI) Color
Action Level and Summary
NPDES discharge limit color exceedances due to this
event.
Please contact us if you have questions regarding this information.
Sincerely,
Tracy' Willis
WWTP ORC
Canton Mill
[e-mail]
Phone: [phone]
cc:
John McCarthy
General Manager
Canton Mill
[e-mail]
Phone: [phone]
Mr. Landon Davidson
DWR Regional Supervisor, Asheville Regional Office
North Carolina Department of Environmental Quality
2090 U.S. Highway 70
Swannanoa, NC 28778
Certified Mail 7018 2290 0001 7880 9989
C. File — 405 — Wastewater