AS-88489_96085_G_C_20221220_Email

From:Ramey, David E
To:Hunneke, William F
Cc:Macdonald, Janet K; Day, Collin
Subject:CHAMPION-PIGEON RIVER SEEP, NONCD0001473, Canton Paper Mill, Canton, NC, Haywood County
Date:Tuesday, December 20, 2022 4:09:39 PM
Attachments:image001.png
Bill,

Collin Day Teams Called me this morning to request that I prepare a site summary for the subject
site for you to share with Michael Scott and Elizabeth Biser. Here it is:

The reactivation of the seep was reported to NC DEQ on Friday, January 28, 2022. The seep had
stopped seeping again by Friday, February 11, 2022. The seep had seeped for less than two weeks.
The material which had seeped out of the riverbank and into the Pigeon River is black liquor, a
substance that is generated in the paper-making process when wood pulp is boiled. Black liquor is
present in the groundwater beneath the Canton Paper Mill owing to historical releases of black
liquor and possibly owing to ongoing releases of black liquor. The nature and extent of the black
liquor in groundwater beneath the Canton Paper Mill is unknown and is the subject of the
Groundwater Work Plan (GWWP) which will be submitted to me “early next year” according to Billy
Clarke, Outside Counsel for PactivEvergreen, the current owner/operator of the Canton Paper Mill.

The potentially responsible parties (PRPs), International Paper (IP) (who inherited the environmental
liability associated with Champion Paper) and PactivEvergreen spent much of 2022 arguing about
who is responsible for further assessing the seep. The Division of Water Resources (DWR) issued
Notices of Violation (NOVs) to IP (April 11, 2022) and PactivEvergreen (October 20, 2022). The
Inactive Hazardous Sites Branch (IHSB) sent a Notice of Regulatory Requirements (NORR) to IP (April
22, 2022).

By Tuesday, September 27, 2022 when we had a Teams Meeting regarding the site, IP and
PactivEvergreen had agreed to cooperate to assess and clean up the site. They also agreed to share
costs. I do not know exactly how they are dividing costs, but so long as the work gets done, that’s
between them.

On Wednesday, December 14, 2022, I participated in the riverbank reconnaissance of the Pigeon
River. The river was flowing high and fast enough that it was unclear whether we observed the seep
of black liquor or not. There is a #6 fuel oil release which according to PactivEvergreen General
Manager, John McCarthy, they have spent about $2 million addressing in the past month. When I
was onsite, I saw and photographed the booms deployed in the Pigeon River to capture the #6 fuel
oil release. I could see a little bit of a hydrocarbon sheen on the water between the riverbank and
the booms.

On the workweek beginning Monday, January 9, 2023, multiple media will be sampled including
surface water, seep, sediment, and groundwater from monitoring wells, RW-5 and RW-6. Toxicity
testing will be performed on the surface water samples. All the samples will also be analyzed for
many parameters by the labs. This sampling event will yield much data. I will probably receive that
data in report format more than a month after the sampling event.

Another thing that I am looking forward to “early next year” is the submittal of the GWWP. Arcadis
is the environmental consultant that will prepare it for their two clients, IP and PactivEvergreen. The
sampling that is performed on the samples collected on the workweek beginning Monday, January 9,
2023 is likely to result in few contaminants observed in the lab results owing especially to dilution of
the surface water samples. On the other hand, the sampling that is performed associated with the
GWWP is likely to reveal higher contaminant concentrations. Its focus will be the groundwater
beneath the Canton Paper Mill. Once we have the lab results from the groundwater assessment, IP,
PactivEvergreen, and Arcadis will be able to move on to answering the important question of what
they will do to address the groundwater contamination beneath the Canton Paper Mill.

In addition to this upcoming assessment work, in January, there will be a Teams Meeting to include
the multiple groups under the NC DEQ umbrella that are addressing aspects of the contamination at
the Canton Paper Mill. These will include at least the following: 1. IHSB, 2. DWR, 3. Underground
Storage Tank Section (USTS), 4. Division of Air Quality (DAQ), and 5. Hazardous Waste Section (HWS).

This is by no means an exhaustive addressing of the environmental assessment going on at the
Canton Paper Mill, but it should be enough to begin a conversation about it.

Please contact me with questions or comments.
Sincerely yours,
David

David Ramey
Hydrogeologist
North Carolina Department of Environmental Quality, Division of Waste Management, Superfund
Section, Inactive Hazardous Sites Branch
984.232.1127 Work Cell
[e-mail]
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.