IH1473_20240415_Q1 2024 Progress Report

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April 15, 2024

Mr. Kenneth B. Rhame via email: [e-mail]
United States Environmental Protection Agency — Region 4
61 Forsyth Street S.W. #9 Atlanta, Georgia 30303

Re: Project Progress Report for First Quarter 2024 Pactiv Evergreen — Canton Mill, Canton, North Carolina

Dear Mr. Rhame:
This progress report provides a summary of Time Critical Removal Action (TCRA) activities undertaken
by or on behalf of Pactiv Evergreen (PTVE) at the former Canton Mill (the Site) in Canton, North Carolina.
This report complies with the requirements of Section VIII.25 of the Administrative Settlement
Agreement and Order on Consent for Removal Action (AOC), CERCLA-04-2024-7000, effective
October 24, 2023. This report covers the first quarter (Q1) of 2024.

DESCRIPTION OF WORK COMPLETED
A detailed Action Tracker (log) of TCRA activities is provided on the project-specific SharePoint site.
The following TCRA field activities were performed during Q1 2024 (corresponding documents are listed
below in Submittals/Deliverables as applicable):

1. Submitted various reports/submittals as noted below.
2. Initiated data gap filling for the Black Liquor TCRA pursuant to the Implementation of Interim
Work Plan Addendum to Address Vertical Delineation Data Gaps via Limited Subsurface
Investigations (dated December 11, 2023, and approved by United States Environmental
Protection Agency (U.S. EPA) December 27, 2023).
3. Completed installation of replacement monitoring well PZ-16R pursuant to the Implementation
of Interim Work Plan Addendum to Replace Monitoring Well PZ-16 (dated December 14, 2023,
approved by U.S. EPA January 24, 2024).
4. Removed fuel oil collection berms and sorbent boom from Pigeon River in February 2024
pursuant to U.S. EPA approval dated February 9, 2024. PTVE will continue visual inspections for
fuel oil sheen and redeploy booms if deemed necessary.

SUBMITTALS/DELIVERABLES
1. The following correspondence was issued or received by or on behalf of PTVE in Q1 2024:
a. Submitted the financial assurance mechanism (surety bond) to U.S. EPA on January 16, 2024 per the Section X.35-38 of the AOC; and received U.S. EPA approved via email
dated February 7, 2024.
b. Submitted the Black Liquor Interim Removal Action Work Plan to U.S. EPA on January
22, 2024; received U.S. EPA approval via email dated February 9, 2024.
Mr. Kenneth Rhame April 15, 2024
Page 2

c. Received U.S. EPA approval on January 24, 2024, of the Implementation of Interim Work
Plan Addendum to Replace Monitoring Well PZ-16 (dated December 14, 2023).
d. Submitted the Project Progress Report for Q4 2023 to U.S. EPA via email dated January
31, 2024.
e. Received U.S. EPA approval on February 9, 2024, to remove the absorbent and hard-
skirted oil booms from the Pigeon River.
f. Submitted the GW-1 Well Construction Records to NCDEQ (via email dated March 4,
2024) for the two new recovery wells constructed in February 2024, in accordance with
Permit WR0100064.
g. Submitted the draft Technical Memorandum – Summary of Interim Removal Action of
Petroleum-Impacted Soils to U.S. EPA review via email dated March 25, 2024.

SUMMARY OF SAMPLING RESULTS/TESTS
1. Initiated data gap filling pursuant to the Implementation of Interim Work Plan Addendum to
Address Vertical Delineation Data Gaps via Limited Subsurface Investigations (dated December
11, 2023, and approved by United States Environmental Protection Agency (U.S. EPA) December
27, 2023) including:
a. Installed 10 borings (SB-1 through SB-10) to evaluate vertical black liquor impacts and
lithology in January 2024
b. Installed six observation wells (OW-1 through OW-6), two boundary wells near RW-1
(OW-7 and OW-8), and two groundwater recovery wells (RW-8 and RW-9) in February
2024. A map illustrating the new well locations is attached.
c. Performed aquifer slug testing in February 2024
d. Performed aquifer step testing at RW-8 and RW-9 in March 2024
e. Collected baseline groundwater samples at RW-8 and RW-9 for laboratory analysis of
site contaminants of concern
f. Performed 24-hour constant rate aquifer testing at RW-8 and RW-9
g. Collected groundwater samples at RW-8 and RW-9 during aquifer pump testing (at
approximately the 22-hour mark of the test) for laboratory analysis of site contaminants
of concern representative of pumping conditions.
h. Coordinated characterization sampling and profiling for off-site disposal of investigation
derived waste (IDW) in March 2024
i. Re-sampled PZ-12 for laboratory analysis to determine if September 2023 results were
anomalous/outliers.
j. A summary of this work will be provided after the data gap filling results evaluation and
modeling is complete, likely May/June 2024.

ISSUES/RESOLUTIONS
None. However, the planned background well was not installed upgradient of the site due to logistical
and schedule constraints, and will be completed during a subsequent drilling event.

COMMUNITY RELATIONS
None.
Mr. Kenneth Rhame April 15, 2024
Page 3

WORK ANTICIPATED IN FOLLOWING QUARTER
The following TCRA activities are planned for the second quarter of 2024 (April - June):

1. Continue implementing work and deliverables as required per the AOC.
2. Continue implementing the U.S. EPA approved Black Liquor Interim Removal Action Work Plan.
3. Continue evaluation and modeling of results from data gap filling activities to refine the black
liquor interim removal action design basis, per the U.S. EPA approved Implementation of Interim
Work Plan Addendum to Address Vertical Delineation Data Gaps via Limited Subsurface
Investigations (EnSafe, December 2023).
4. Finalize the draft Technical Memorandum – Summary of Interim Removal Action of Petroleum-
Impacted Soils once U.S. EPA responds, and submit as final.
5. Participate in periodic status calls/meetings with stakeholders.
6. Support U.S. EPA’s community relations and outreach as applicable.

If you have questions or need additional information, please contact me at 813-734-7985.

Sincerely,

EnSafe Inc.

By: Bridget Morello, PE
Principal

cc: Alison Vincent, Project Coordinator, PTVE
Project-specific SharePoint site

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FIGURE 1NEW RECOVERY WELLS AND
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