AS-88489_96085_CA_RPTS_20230516_DraftInterimRemedialActionWP

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Mount Pleasant, South Carolina 29464
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INTERIM REMEDIAL ACTION WORK PLAN ADDENDUM
FOR REMOVAL OF PETROLEUM-IMPACTED SOILS

PACTIV EVERGREEN
CANTON MILL
CANTON, NORTH CAROLINA

EnSafe Project Number
0888834351

Prepared for:

Pactiv Evergreen
175 Main Street
Canton, North Carolina 28716

May 16, 2023

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TABLE OF CONTENTS

EXECUTIVE SUMMARY .............................................................................................................. ii
1.0 ZONE 1 — Aboveground Storage Tanks........................................................................... 1
1.1 Zone 1: Proposed Removal Action ....................................................................... 2
1.2 Zone 1: Area Preparation ................................................................................... 2
1.3 Zone 1: Excavation Activities .............................................................................. 3
1.4 Zone 1: Confirmation Sampling and Monitoring .................................................... 3
1.5 Zone 1: Restoration ........................................................................................... 3
2.0 Zone 2 — Abandoned Sewer Line and Levee Manhole Cistern Add text .............................. 4

3.0 Zone 3 — Impacted Soils from the Levee Manhole Cistern to the Seep .............................. 5
3.1 Zone 3: Proposed Removal Action ....................................................................... 5

4.0 Zone 4 — Riverbank Seep .............................................................................................. 7
4.1 Zone 4: Proposed Removal Action ....................................................................... 7
4.2 Zone 4: Area Preparation ................................................................................... 8 4.3 Zone 4: Excavation Activities .............................................................................. 8
4.4 Zone 4: Confirmation Sampling and Monitoring .................................................... 9
4.5 Zone 4: Restoration ........................................................................................... 9

5.0 Source Characterization — Multiple Zones ..................................................................... 10

6.0 Data Collection and Reporting ...................................................................................... 11
7.0 References ................................................................................................................. 12

FIGURES

Figure 1 Conceptual Site Model
Figure 2 AST Containment Bunker Cross-Section Schematic

TABLES

Table 1 Zone 1: Initial Work Plan Investigative Efforts vs Addendum Actions ....................... 1 Table 2 Data Zone 2: Initial Work Plan Investigative Efforts vs Addendum Actions ............... 4
Table 3 Zone 3: Initial Work Plan Investigative Efforts vs Addendum Actions ....................... 5
Table 4 Zone 4: Initial Work Plan Investigative Efforts vs Addendum Actions ....................... 7 Table 5 Source Characterization: Initial Work Plan Investigative Efforts vs Addendum Actions .......................................................... 10

APPENDICES

Appendix A Health and Safety Plan

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EXECUTIVE SUMMARY

EnSafe Inc., on behalf of Pactiv Evergreen (PTVE), has prepared this Interim Remedial Action Work
Plan Addendum (Work Plan Addendum) to expedite removal of petroleum-impacted soils in the
vicinity of the aboveground storage tanks (ASTs) and associated infrastructure at the Canton Mill
(Site) in Canton, North Carolina. This Work Plan Addendum is associated with the Fuel Oil
Investigation Work Plan (EnSafe, April 2023) which included a supporting Sampling and Analysis Plan
and Quality Assurance Project Plan. The document package was submitted to the United States
Environmental Protection Agency’s (U.S. EPA) and the North Carolina Department of Environmental
Quality (NCDEQ) on April 12, 2023, for comment. During a subsequent site visit with U.S. EPA and
Pactiv Evergreen on April 18, 2023, and additional correspondence with NCDEQ personnel from the
Underground Storage Tank (UST) Division on April 26, 2023, a consensus was reached expressing
interest in an accelerated timeline for the removal of petroleum-impacted soils at the Site.

This Work Plan Addendum summarizes relevant aspects of the Conceptual Site Model (CSM) based
on investigation activities to date and proposes a more aggressive approach to removal actions across
the specific zones described in the initial Work Plan (EnSafe, April 2023). A forthcoming site-specific
Health and Safety Plan (HASP) will be modified accordingly for the additional proposed work.
The removal action activities proposed within this Work Plan Addendum are presented for review
and approval and shall supersede the investigative efforts outlined in the initial Work Plan
(EnSafe, April 2023). Pending the results of the analytical data collected during this Scope of Work
and consultation with the appropriate agency(s), portions of the original Work Plan may be revised if
Site conditions warrant. This project will not commence until the U.S. EPA and NCDEQ approve the
additional recommended actions described herein.

Rationale and Conceptual Site Model Summation
Historical and recent investigations (Law Engineering, February 1995; Roy F. Weston Inc, September
1995; EnSafe, March 2023) have indicated the presence of petroleum-impacted soils within specific
areas or zones at the Site as outlined in the CSM presented in the initial Fuel Oil Investigation Work
Plan (EnSafe, April 2023). Historically, No. 6 Fuel Oil was stored in 210,000- and 500,000-gallon
ASTs in a single containment bunker on the south side of the facility, on the east bank of the
Pigeon River. Evergreen has indicated that in 2018, No. 6 Fuel Oil was removed from the
500,000-gallon AST and replaced with No. 2 Fuel Oil (dyed diesel). Currently, No. 2 Fuel Oil continues
to be stored in the 500,000-gallon AST and No. 6 Fuel Oil is stored in the 210,000-gallon AST.
Plans are now in place to decommission and remove the ASTs and related infrastructure beginning
in early June 2023 to coincide with the closure of the Mill. The timely removal of the ASTs and
increased accessibility post Mill closure will allow for more immediate implementation of Removal
Actions. At this time, in lieu of the assessment activities outlined in the initial Work Plan,

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PTVE proposes to begin excavation and disposal of petroleum-impacted soils as soon as practical
pending the removal of the ASTs. Removal actions will initially focus in zones where impacted soils
are present based on previous investigations and the current CSM as depicted in Figure 1.

Pursuant to the current CSM, residual fuel oil is likely present in the soil matrix beneath the AST
containment bunker and proximal to PZ-16. It also appears that fuel oil and groundwater infiltrate
and migrate along an abandoned sewer line that extends northwest from the ASTs, parallel to the
protection levee, and terminates at the levee manhole cistern roughly 400 feet northwest. Mobile fuel
oil has not been identified in recovery wells RW-6 and RW-7, along the path of the abandoned sanitary
sewer line. The absence of mobile fuel oil in these recovery wells suggests that impacts due to
residual fuel oils are limited, and that the abandoned sewer line or immediate, adjacent fill is most
likely serving as a pathway for fuel oil migration. Further, this CSM presumes the migration of fuel
oil from the levee manhole cistern, beneath the access road and ultimately to the seep, likely occurred
within/along the abandoned lines emanating from the levee manhole cistern, and within the adjacent,
highly-permeable cobbles, as observed in pits dug along the access road.

Tables 1 through 5 in the following text were derived from the initial Work Plan and have been revised
to summarize the interim removal actions to be implemented in lieu of further investigative efforts
for each of the respective zones. Though many of the investigative efforts outlined in the initial
Work Plan (italicized in tables) will be superseded by removal actions, further monitoring may be
required pending results of confirmatory soil data. Any further actions deemed appropriate should
be consensus-driven among the applicable stakeholders.

Interim Remedial Action Work Plan Addendum for Removal of Petroleum-Impacted Soils
Pactiv Evergreen
Canton Mill Site — Canton, North Carolina
May 16, 2023

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1.0 ZONE 1 — ABOVEGROUND STORAGE TANKS
Hydrocarbon-impacted soils at the Site were first evaluated during assessment activities in the early
1990s. Prior reports document the presence of hydraulic oils in the soils proximal to the ASTs and
heavy fuel oil within the gravel base in the northeast corner of the containment bunker prior to
installation of a concrete floor (Law Engineering and Environmental Services, February 1995).
In 1995, monitoring well PZ-16 was installed just north of the AST containment bunker to gauge the
presence/absence of free product; no evidence of mobile fuel oil in soil or impacts to groundwater
were identified at that time (Weston, September 1995). An unknown petroleum hydrocarbon was
first identified in PZ-16 in 2013 as part of routine long-term monitoring for a separate black liquor
seep response action. The free product was reported to NCDEQ in a letter from PTVE to NCDEQ
(Evergreen, February 2013), and it was determined that this material was residual from a prior
release. The letter concluded that, based on the construction specifications of bin walls within the
levee structure that extend nearly 10 feet below the riverbed in that location, the potential for
migration to the river was low. Fuel oil was first observed in PZ-16 in 2018 during long-term,
semi-annual monitoring events associated with the black liquor response action, and on a continuous
basis since 2018 (AECOM reports, various dates). Furthermore, remote camera footage appeared to
show fuel oil infiltrating an abandoned sewer line that runs beneath the AST bunker and proximal to
PZ-16 during recent investigative efforts. A cross-section schematic from the AST containment
bunker to the Pigeon River is displayed as Figure 2. Table 1 below summarizes the revisions proposed
in Zone 1.

Table 1
Zone 1: Initial Work Plan Investigative Efforts vs Addendum Actions
Initial Work Plan vs Addendum Status of Initial Resolution vs Addendum
Zone 1:
Initial Work Plan
Data Gap: Extent of residual
product/impacted media proximal to ASTs
unknown.
Addendum Forego investigative soil borings and implement Removal Action of impacted soils
within and proximal to the footprint of the
former AST bunker. Delineation of impacted
soils will be based on field observations.
Omissions from Initial Work Plan Collect soil samples from five proposed boring locations to further delineate fuel oil and other hydrocarbon impacted soils near the AST
containment bunker and PZ-16.

These data will be used to gauge the potential for supplemental actions
in source/release areas. Sample intervals per Table 4-2 in the SAP • 4-5 feet bgs
• 9-10 feet bgs
• 14-15 feet bgs
Addendum
Collect confirmatory soil samples from each excavation wall and a representative sample from the base of each excavation.
Interim Remedial Action Work Plan Addendum for Removal of Petroleum-Impacted Soils
Pactiv Evergreen
Canton Mill Site — Canton, North Carolina
May 16, 2023

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Table 1 Zone 1: Initial Work Plan Investigative Efforts vs Addendum Actions
Initial Work Plan vs Addendum Status of Initial Resolution vs Addendum
If warranted, based on confirmatory sample data, install up to two
monitoring wells into the cobble layer in select locations to monitor
groundwater quality.

Soil and Groundwater Samples will be analyzed by U.S. EPA Method 8015 and MADEP EPH Methods pursuant to the QAPP.

Notes:
AST = aboveground storage tank SAP = Sampling and Analysis Plan bgs = below ground surface U.S. EPA = United States Environmental Protection Agency
QAPP = Quality Assurance Project Plan
NAPL = non-aqueous phase liquid
1.1 Zone 1: Proposed Removal Action
As noted above, fuel oil is present in the soils around and beneath the AST bunker to an unknown
extent. This residual fuel oil serves as the source of the seep via migration observed within
abandoned sewer structures. The recent announcement that the ASTs and other fuel oil-related
infrastructure was to be decommissioned and removed at the time of the Mill closure in June of 2023
was seen as opportunity to forgo some investigative efforts and focus on removal actions.
The proposed soil removal actions outlined below should commence once the AST and associated
equipment have been removed.

A HASP (included as Attachment A) has been developed and updated to address specific safety
protocols for each potential work zone during removal activities at the Site based on the anticipated
activities and the historical contaminant data documented during past investigations. Employees
working on the Site will be required to review and comply with the HASP along with any site-specific
requirements. The removal contractor will be required to be HAZWOPER Technician-certified.
Work zone-specific requirements will be added to the HASP as needed.

1.2 Zone 1: Area Preparation
Prior to implementation of removal actions in Zone 1, a safety meeting will be held to confirm that
conditions are suitable to begin the excavation of impacted soils and to determine operational areas
for the heavy equipment required for the excavation. It is anticipated that most heavy equipment
should avoid encroaching on the outer areas of the protection levee near the river where the two bin
walls are located. The HASP will be reviewed, and personnel will be briefed on the chemicals of
concern, emergency response actions, stop work authority, and the potential hazards present.
Interim Remedial Action Work Plan Addendum for Removal of Petroleum-Impacted Soils
Pactiv Evergreen
Canton Mill Site — Canton, North Carolina
May 16, 2023

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1.3 Zone 1: Excavation Activities
After Site preparations have been completed, a long-arm excavator and/or other suitable equipment
will be utilized to remove impacted soils from Zone 1. Given that the fuel oil at the Site is visible
within the soil matrix when present, and nearly immobile, removal efforts can be driven by field
observations. Collection of impacted soils will begin beneath the AST containment bunker and
continue laterally and vertically until residual fuel oil is no longer encountered or site conditions
warrant otherwise. Soils not visibly impacted (clean overburden) will be stockpiled nearby for use as
potential backfill. The excavator will likely be positioned in the area currently occupied by rail cars.
To assist the excavator, a compact track loader (or similar equipment) will be utilized in consolidating
material for removal by the excavator among other tasks. The long-arm excavator will remove
material from the excavation area and place it into a dump truck equipped with a sealed dump bed
gate. Impacted soils will be transported to a secure area onsite where it can be contained, staged
in piles, and potentially sorted. Larger materials (i.e.: boulders/cobbles) that exhibit staining may be
segregated from the impacted finer-grained material and repurposed. Precautions will be made to
ensure no material is lost between the removal area and staging areas. Any material collected at or
below the water table or otherwise saturated will be allowed to dewater in a suitable containment
vessel in the staging area. Water produced from dewatering activities will be collected within a sump
and removed accordingly.

Excavated soils will be sampled for waste characterization. Once analytical results have been
received, the impacted soils will be placed into lined dump trucks for offsite disposal at an approved
facility. If impacted material does not dewater as expected, the use of dewatering roll-off boxes may
be required.

1.4 Zone 1: Confirmation Sampling and Monitoring
Once removal actions are deemed complete by field teams, confirmatory soil samples will be collected
from each excavation sidewall and base for analysis. Analytical methods for soil samples are outlined
in the original QAPP (EnSafe, April 2023). Pending the results of the analytical data, if warranted,
portions of the original Work Plan may be enacted after consultation with the appropriate agency(s).

1.5 Zone 1: Restoration
Restoration plans for this Zone have yet to be finalized and will likely remain so until data indicates
remedial efforts are complete.
Interim Remedial Action Work Plan Addendum for Removal of Petroleum-Impacted Soils
Pactiv Evergreen
Canton Mill Site — Canton, North Carolina
May 16, 2023

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2.0 ZONE 2 — ABANDONED SEWER LINE AND LEVEE MANHOLE CISTERN
In accordance with the CSM, any residual fuel oil present in Zone 2 is likely confined to the soils
immediately adjacent to the abandoned sewer structures. The absence of product in recovery wells
RW-6 and RW-7 along the route of the abandoned sewer lines further suggests that significant
migration of product has not occurred in this locale and is consistent with the physical characteristics
of residual heavy fuel oils.

Extensive interim removal actions may not be warranted in Zone 2 unless excavations from
contiguous zones indicate recoverable quantities of impacted soils are present in this zone.

Should Zone 2 require immediate removal action, the protocols from sections 1.1 through 1.5 will be
followed; however, the excavator will need to be relocated accordingly. Table 2 below summarizes
the revisions proposed in Zone 2.

Table 2
Data Zone 2: Initial Work Plan Investigative Efforts vs Addendum Actions
Initial Data Gaps vs Proposed Action Status of Initial Resolution vs Addendum

ZONE 2:
Initial Work Plan Data Gap: Extent of residual product/impacted media proximal to
abandoned sewer line and levee manhole
cistern
Addendum Should excavations from contiguous zones
indicate recoverable quantities of impacted
soils are present in Zone 2, immediate
removal actions may be taken.
If Zone 2 requires immediate action, delineation and removal of impacted soils will
be based on field observations.

Omissions from Initial Work Plan Collect soil samples from up to three proposed boring locations to
further delineate fuel oil and other hydrocarbon-impacted soils along the
route of the abandoned sewer line.

Existing recovery wells RW-6 and RW-7 are positioned along the abandoned sewer and will serve as monitoring points for the evaluation of groundwater quality proximal to the abandoned sewer line.
Sample intervals per Table 4-2 in SAP
• 9-10 feet bgs
• 14-15 feet bgs
Addendum If warranted, collect confirmatory soil samples from each excavation wall and a representative sample from the base of each excavation.
Existing recovery wells RW-6 and RW-7 are positioned to allow for the
monitoring groundwater quality in Zone 2.

Soil and groundwater samples will be analyzed by U.S. EPA
Method 8015 and MADEP EPH Methods pursuant to the QAPP.

Notes:
SAP = Sampling and Analysis Plan
bgs = below ground surface U.S. EPA = United States Environmental Protection Agency QAPP = Quality Assurance Project Plan MADEP EPH = Method for the Determination of Extractable Petroleum Hydrocarbons
Interim Remedial Action Work Plan Addendum for Removal of Petroleum-Impacted Soils
Pactiv Evergreen
Canton Mill Site — Canton, North Carolina
May 16, 2023

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3.0 ZONE 3 — IMPACTED SOILS FROM THE LEVEE MANHOLE CISTERN TO THE SEEP
Oil was observed in three of the four test pits that were excavated in February 2023, along an access
road between the Pigeon River and the base of the protection levee utilizing a HydroVac system.
The presence of oil was noted in a cobble horizon in Pits 2, 3, and 4 at depths of around
3.5 feet below ground surface. The presence of fuel oil residuals in the alluvium (sands, gravels, and
cobbles) beneath the access road at the base of the levee appear to be associated with two
abandoned sewer lines emanating from the levee manhole cistern. The current CSM presumes that
any migration of heavy fuel oil that occurred from the levee manhole cistern toward the access road,
and ultimately the seep, likely occurred within or along the two abandoned pipes and/or within the
highly-permeable cobble horizon observed in the base of the test pits. The two sewer lines were
plugged by PTVE at the levee manhole cistern in August 2022. Table 3 below summarizes the
revisions proposed in Zone 3.

Table 3 Zone 3: Initial Work Plan Investigative Efforts vs Addendum Actions
Initial Data Gaps vs Proposed Action Status of Initial Resolution vs Addendum
ZONE 3:
Initial Work Plan Data Gap: Extent of residual product/impacted
media between LMC and seep not fully defined. Addendum
Forego investigative soil borings and implement Removal Action of impacted soils proximal to the access road pit locations between the LMC and the
seep. Delineation of impacted soils will be based on
field observations.
Omissions from Initial Work Plan Collect soil samples at three proposed boring locations to further delineate fuel oil-impacted soils between the levee manhole cistern and the seep.
Assessments may also be performed using test pits/trenches to gauge recovery options along the access road.
If warranted, based on soil borings and samples, one monitoring well may be installed downgradient in Zone 3 into the cobble layer. This well allows for
monitoring of any product migration between the levee manhole cistern and the seep.
Sample intervals per Table 4-2 in SAP
• 4-5 feet bgs • 9-10 feet bgs
Addendum Collect confirmatory soil samples from each excavation wall and a representative
sample from the base of each excavation. If warranted, based on confirmatory sample data, install up to two monitoring
wells into the cobble layer in select locations to monitor groundwater quality. Soil and Groundwater Samples will be analyzed by U.S. EPA Method 8015 and
MADEP EPH Methods pursuant to the QAPP. Soil and groundwater samples will be analyzed by U.S. EPA Method 8015 and MADEP EPH Methods pursuant to the QAPP.

Notes: SAP = Sampling and Analysis Plan bgs = below ground surface
U.S. EPA = United States Environmental Protection Agency QAPP = Quality Assurance Project Plan LMC = Levee Manhole Cistern
MADEP EPH = Method for the Determination of Extractable Petroleum Hydrocarbons 3.1 Zone 3: Proposed Removal Action
Interim Remedial Action Work Plan Addendum for Removal of Petroleum-Impacted Soils
Pactiv Evergreen
Canton Mill Site — Canton, North Carolina
May 16, 2023

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As discussed above, fuel oil is present in a highly-permeable cobble-laden soil horizon. The presence
of heavy fuel oils within the highly-permeable strata is likely acting as the immediate source for the
seep along the riverbank. Though the vertical and horizonal extent of the impacted soils is unknown
at this time, it is proposed that removal actions begin in this zone in a timely manner once Mill
operations cease.

Except for excavator repositioning, removal actions in Zone 3 will mirror the protocols set forth in
sections 1.1 through 1.5 above.

Interim Remedial Action Work Plan Addendum for Removal of Petroleum-Impacted Soils
Pactiv Evergreen
Canton Mill Site — Canton, North Carolina
May 16, 2023

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4.0 ZONE 4 — RIVERBANK SEEP
No. 6 Fuel Oil was first observed seeping from the east bank of the Pigeon River on June 3, 2021,
approximately 350 feet to the northwest of the AST containment bunker. Initial abatement activities
were implemented from June through August 2021, including deployment of oil containment booms,
free product recovery, and inspections of the seep area conducted multiple times per week.
Flash flooding along the Pigeon River associated with Tropical Storm Fred in August 2021 all but
eliminated any residual product along the riverbank. Free product was again identified along the
riverbank on August 18, 2022, in roughly the same location as the previous seep in 2021. Unintrusive
abatement activities were implemented and have continued as needed. Table 4 below summarizes
the revisions proposed in Zone 4.

Table 4 Zone 4: Initial Work Plan Investigative Efforts vs Addendum Actions
Initial Data Gaps vs Proposed Action Status of Initial Resolution vs Addendum
ZONE 4: Initial Work Plan
Data Gap: Extent of residual
product/impacted media and continued
assessment of risks associated with the seep
along the east bank of the Pigeon River. Addendum Forego investigative soil borings and
implement Removal Action of impacted soils
proximal to the seep. Delineation of impacted
soils will be based on field observations
Initial Work Plan – no omissions

Per Initial Work Plan
Further testing of soil/sediment and surface water will be conducted at 3 collocated locations shown on Figure 7 (1 upstream, 1 downstream, and 1 at the seep) to aid in determining and implementing appropriate toxicity testing methods given NAPL presence and exposure scenario.

Addendum
If feasible, collect confirmatory soil samples from each excavation wall
and a representative sample from the base of each excavation. Sediment and surface water samples will be analyzed by U.S. EPA Method 8015 and MADEP EPH Methods pursuant to the QAPP

Notes:
SAP = Sampling and Analysis Plan
bgs = below ground surface U.S. EPA = United States Environmental Protection Agency QAPP = Quality Assurance Project Plan NAPL = non-aqueous phase liquid
MADEP EPH = Method for the Determination of Extractable Petroleum Hydrocarbons

4.1 Zone 4: Proposed Removal Action
As noted above, fuel oil was observed seeping from the east bank of the Pigeon River and likely
derived from free product escaping the levee manhole cistern via two abandoned lines that have
since been plugged. The proposed soil removal actions outlined below could commence once the
integrity of the current pneumatic piping plugs in place is confirmed or a permanent seal of the lines
within the levee manhole cistern is completed. The subsurface extent of the residual fuel oil proximal
to the seep is currently unknown; however, excavations within Zone 3, along the levee, and access
Interim Remedial Action Work Plan Addendum for Removal of Petroleum-Impacted Soils
Pactiv Evergreen
Canton Mill Site — Canton, North Carolina
May 16, 2023

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road may provide insight to the volume of impacted media requiring removal from the riverbank.

A HASP has been developed and updated to address specific safety protocols for each potential work
zone during removal activities at the Site based on the anticipated activities and the historical
contaminant data documented during past investigations. Employees working on the Site will be
required to review and comply with the HASP along with any site-specific requirements. The removal
contractor will be required to be HAZWOPER Technician-certified. Work zone-specific requirements
will be added to the HASP as needed.

4.2 Zone 4: Area Preparation
Prior to removal actions along the riverbank, additional containment and sorbent boom will be
deployed to capture any product or sheen that may be liberated during excavation activities.
A response team will be in place to recover any product or sheen observed during removal efforts.
Removal efforts within Zone 4 will likely require acceptable, near base-flow, river levels to safely
complete this Scope of Work. Silt fencing may be utilized to mitigate the release of unacceptable
amounts of fine-grained material into the river, if warranted. Safety meetings will be held prior to
the implementation of removal actions to confirm that conditions are suitable to begin the excavation
of impacted soils and to determine the limits of operational areas.

Notification from the Federal On-Scene Coordinator to the United States Army Corp of Engineers of
the removal actions may be required pursuant to the Nationwide Permit 20 as follows:
“Activities conducted in response to a discharge or release of oil or hazardous substances that are
subject to the National Oil and Hazardous Substances Pollution Contingency Plan (40 CFR part 300)
including containment, cleanup, and mitigation efforts, provided that the activities are done under
either: (1) the Spill Control and Countermeasure Plan required by 40 CFR 112.3; (2) the direction or
oversight of the federal on-scene coordinator designated by 40 CFR part 300; or (3) any approved
existing state, regional or local contingency plan provided that the Regional Response Team (if one
exists in the area) concurs with the proposed response efforts.”

Courtesy notification of the proposed removal actions and this Work Plan will also be made to
NCDEQ — Water Quality Division, and other applicable stakeholders.

4.3 Zone 4: Excavation Activities
After site preparations have been completed, a long-arm excavator and/or other suitable equipment
will be utilized to temporarily relocate and stage riprap boulders allowing access to the impacted soils
Interim Remedial Action Work Plan Addendum for Removal of Petroleum-Impacted Soils
Pactiv Evergreen
Canton Mill Site — Canton, North Carolina
May 16, 2023

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along the riverbank slated for removal. As with excavations in other zones, removal efforts will be
driven by field observations. Collection of impacted soils will begin at the seep and continue laterally
and vertically until residual fuel oil is no longer encountered or site conditions warrant otherwise.
Soils not visibly impacted (clean overburden) will be stockpiled nearby for use as potential backfill.
The excavator will likely be positioned on the access road that runs parallel to the riverbank.
A compact track loader (or similar equipment) may be utilized to assist the excavator in removing
material among other tasks. The long-arm excavator will remove material from the excavation area
and place it into a dump truck equipped with a sealed dump bed gate. Impacted soils will be
transported to a secure area onsite where it can be contained, staged in piles, and potentially sorted.
Larger materials (i.e.: boulders/cobbles) that exhibit staining may be segregated from the impacted
finer-grained material and repurposed. Precautions will be made to ensure no material is lost
between the removal area and staging areas. Any material collected at or below the water table or
otherwise saturated will be allowed to dewater in a suitable containment vessel in the staging area.
Water produced from dewatering activities will be collected within a sump and removed via
vacuum truck.

Excavated soils will be sampled for waste characterization. Once analytical results have been
received, the impacted soils will be placed into lined dump trucks for offsite disposal at an approved
facility. If impacted material does not dewater as expected, the use of dewatering roll-off boxes may
be required.

4.4 Zone 4: Confirmation Sampling and Monitoring
Once removal actions are deemed complete by field teams, confirmatory soil samples will be collected
from each excavation sidewall and base for analysis. Analytical methods for soil samples are outlined
in the original QAPP (EnSafe, April 2023). Pending the results of the analytical data, if warranted,
portions of the original Work Plan may be revisited after consultation with the appropriate agency(s).

4.5 Zone 4: Restoration
Restoration of the riverbank to its prior state will commence immediately upon completion of removal
activities. Excavations will be backfilled with a similar material and the riprap boulders will then be
returned to their original locations to the extent practical.
Interim Remedial Action Work Plan Addendum for Removal of Petroleum-Impacted Soils
Pactiv Evergreen
Canton Mill Site — Canton, North Carolina
May 16, 2023

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5.0 SOURCE CHARACTERIZATION — MULTIPLE ZONES
Source characterization does not deviate from the initial Work Plan and is summarized in
Table 5 below.

Table 5 Source Characterization: Initial Work Plan Investigative Efforts vs Addendum Actions
Initial Data Gaps vs Proposed Action Status of Initial Resolution vs Addendum
Source characterization
MULTIPLE ZONES:

Addendum does not deviate from the Initial Work Plan

Per the SAP: Samples of residual product from proposed locations will
be analyzed (fingerprinted) to determine the hydrocarbon fingerprint proximal to the inferred source (Zone 1) and to document any changes in fuel fingerprint along the migration pathway (Zones 2, 3 and 4).
Fingerprint data will be useful in gauging whether there is a difference
in distribution/mobile fraction to be considered in the remedial
approach.
Recommended analysis per the QAPP: Gas Chromatography-Flame Ionization Detection or Gas Chromatography/Mass Spectrometer in full-scan mode.

Notes:
SAP = Sampling and Analysis Plan
QAPP = Quality Assurance Project Plan
Interim Remedial Action Work Plan Addendum for Removal of Petroleum-Impacted Soils
Pactiv Evergreen
Canton Mill Site — Canton, North Carolina
May 16, 2023

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6.0 DATA COLLECTION AND REPORTING
During field activities, EnSafe will use the ArcGIS Field Maps application with Global Positioning
System to collect pertinent information and observations for each sampling point. Such information
will include location coordinates (sub-meter accuracy, to the extent practicable), photographs, sample
and analysis data, field note logs, excavation extents, and other pertinent information.

At the completion of each phase of work or task, EnSafe will provide updates via the SharePoint Site
with all relevant data. Given the unknowns associated with our current understanding of volume and
extent of impacted subsurface media, this Interim Remedial Action Work Plan serves as an addendum
to the initial Fuel Oil Investigation Work Plan and accompanying Sampling and Analysis Plan,
Quality Assurance Project Plan, and Health and Safety Plan, and may require additional amendments
to address changing field conditions.

Interim Remedial Action Work Plan Addendum for Removal of Petroleum-Impacted Soils
Pactiv Evergreen
Canton Mill Site — Canton, North Carolina
May 16, 2023

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7.0 REFERENCES
AECOM. Semi-Annual Groundwater Sampling Reports, Pactiv Evergreen Site. Various Dates.

EnSafe Inc. Technical Memorandum Summary of Response Actions. Pactiv Evergreen Canton Mill,
Canton, North Carolina. March 2023.

— Initial Work Plan (i.e., Fuel Oil Investigation Work Plan. Pactiv Evergreen Canton Mill,
Canton, North Carolina. April 2023.

— Fuel Oil Investigation Quality Assurance Project Plan. Pactiv Evergreen Canton Mill,
Canton, North Carolina. April 2023.

— Fuel Oil Investigation Sampling and Analysis Plan. Pactiv Evergreen Canton Mill,
Canton, North Carolina. April 2023.

— Fuel Oil Investigation Health and Safety Plan. Pactiv Evergreen Canton Mill,
Canton, North Carolina. April 2023.

Evergreen Packaging. Letter from James A. Giauque to Caroline La Fond, North Carolina Department
of Environment and Natural Resources. 2013, February 1.

— Letter from James A. Giauque to Caroline La Fond, North Carolina Department of
Environment and Natural Resources. 2013, September 10.

— Notification of Discharge (Form UST-62). 2021, June 8.

— Technical Memorandum, Incident Number 96085, No. 6 Fuel Oil Release Status
Update, 2021, November 9.

— Technical Memorandum, Incident Number 96085, No. 6 Fuel Oil Release Status
Update, 2022, June 6.

— Notification of Discharge (Form UST-62). 2022, August 18.

— Communications re: abandoned sewer inspections. January 2023.

— Communications re: decommissioning and removal of ASTs. April 2023.
Interim Remedial Action Work Plan Addendum for Removal of Petroleum-Impacted Soils
Pactiv Evergreen
Canton Mill Site — Canton, North Carolina
May 16, 2023

13
Interstate Technology & Regulatory Council. 2015. Integrated DNAPL Site Characterization and
Tools Selection (ISC-1). Washington, D.C.: Interstate Technology & Regulatory Council,
DNAPL Site Characterization Team. www.itrcweb.org/DNAPL-ISC_ tools-selection.

— Interstate Technology & Regulatory Council. 2018. Light Non-Aqueous Phase Liquid
(LNAPL) Site Management: LCSM Evolution, Decision Process, and Remedial
Technologies. LNAPL-3. Washington, D.C. https://lnapl-3.itrcweb.org.

Law Engineering and Environmental Services. Report of Environmental Assessment, Petroleum
Contacted Soil at Sites 1-12, Champion International Corporation, Canton, North Carolina Mill.
1995, February 15.

North Carolina Department of Environmental Quality. UST Section Assessment Guidelines,
Petroleum and Hazardous Substance UST Releases, Petroleum Non-UST Releases. 2021,
January 19.

— Comprehensive Tables for Corrective Action Guidelines, Petroleum and Hazardous
Substance UST Releases, Petroleum Non-UST Releases. 2021, January 19.

— Guidelines for Site Checks, Tank Closure, and Initial Response and Abatement,
Petroleum and Hazardous Substance UST Releases, Petroleum Non-UST Releases.
2021, May 17.

— North Carolina Department of Environmental Quality. 15A NCAC 02C.0108.
Effective 2019, September 1.

Roy. F. Weston, Inc. Investigation and Remediation at Seven Petroleum Sites, Canton Pulp and
Paper Mill, Canton, North Carolina. 1995, September 28.

United States Army Corps of Engineers. Nationwide Permit 20 - Response Operations for Oil or
Hazardous Substances Effective Date: February 25, 2022; Expiration Date: March 14, 2026
(NWP Final Notice, 86 FR 73522).

United States Environmental Protection Agency. Quality System and Technical Procedures for LSASD
Field Branches. https://www.epa.gov/quality/quality-system-and-technical-procedures-lsasd-
field-branches. Last Update 2022, February 7.
Figures
FIGURE 1
CONCEPTUAL SITE MODEL
PACTIV EVERGREEN CANTON MILL
CANTON, NORTH CAROLINA
//esgis1/Xdrive/EvergreenPackaging/CSM/Evergreen_Canton_NC/Figure1_EvergreenCantonMill_opt2_LeveeUNDERGROUND UTILITIES
FUEL OIL DELIVERY LINE FOR ABOVEGROUND STORAGE TANKS
ABANDONED SANITARY SEWER (INTEGRITY COMPROMISED IN PLACES)
INFERRED SANITARY SEWER DRAWN BY:
REQUESTED BY: DATE:
PROJECT #:
TB
KPB
04/26/2023
0888834351NS
S
MONITORING/RECOVERY WELL
ABANDONED SANITARY SEWER MANHOLE
RIVER FLOW DIRECTION
FUEL OIL MIGRATION WITHIN ABANDONED SEWER LINE
RESIDUAL OIL IN SOILS
(OIL EXTENT IN SOIL IS CURRENTLY UNKNOWN. SHADED
AREAS ARE INFERRED FROM 2023 DATA SET)
PZ-12
RW-7
RW-6
PZ-16
CONTAINMENT BUNKER
LEVEE MANHOLE
CISTERN
LEVEE LOCATION
PIGEON RIVER
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SEWER LINE INTEGRITY IS
COMPROMISED IN PLACES
ZONE 1
ZONE 4
APPROXIMATE
LOCATION
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ZONE 3
ZONE 2
S
CONTAINMENT BUNKER MANHOLE
BIN WALLS EXTEND BELOW RIVERBED
25902585258025752570256725652560||||||RAILROAD TRACKS 2584'2579.7'2572.7'2570.7'2572.7'2575.7'BIN WALL2589'7' TOP OFWATERRIVERRIVER BOTTOMCONTAINMENTWALL2565'2561'12" OLD SEWER2570.70'ASTBIN WALLFILLI:\CAD PROJECTS\Evergreen Packaging\34351\Plans\33451_B002_AST_EVERGREEN PACKAGING.dwg
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.com Creative thinking.Custom solutions.REQUESTED BY:DRAWN BY:DATE:PROJECT:FIGURE 2CROSS SECTION SCHEMATIC ASTCONTAINMENT BUNKER TOPIGEON RIVER0888834351KMBTD 4/28/2023LEGENDWATER TABLE (INFERRED)NOTE- ALL ELEVATIONS ARE APPROXIMATEASTABOVEGROUND STORAGE TANKGROUND SURFACE
Attachment A
Health and Safety Plan