NC0000272_NOV-2016-LV0524 and 0526 Response_20161018

evergree Canton Office
packaging I 175 Main Street . Canton, NC 28716
October 18, 2016 NMM 55-16
CERTIFIED MAIL
Return Receipt Requested
7099 3220 0007 0371 4781
Landon Davidson
Asheville Regional Supervisor
Division of Water Resources
North Carolina Department of Environmental Quality
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton,Haywood County,North Carolina
Notice of Violation: NOV-2016-LV-0524 &NOV-2016-LV-0526
NPDES Permit: NC0000272
Dear Mr. Davidson:
This letter serves as Evergreen Packaging's (EPI) formal response to two Notices of Violation
dated September 19,2016. Copies of the NOV's are attached. Thank you for granting EPI
additional time to respond to the NOV's and for speaking with me about this matter on October
7, 2016.
As you are aware, EPI treats all of the wastewater from the Town of Canton's collector sewer
system pursuant to contract (the "Contract").' EPI's waste stream includes little, if any,
biological waste. The Town of Canton is required to and does dose its wastewater with chlorine
prior to entering the EPI wastewater treatment plant("W WTP"). The Town has upgraded its
system over the years to an automatic chlorine injection system.2
There have been issues with fecal colifonn in EPI's effluent over the years and particularly
since early in 2015. EPI believes the fecal coliform exceedances in its effluent result from the
'The wastewater discharge from the Town of Canton is approximately nine hundred thousand gallons per day.
2 In 2007-08,the Town added the chlorine injection system,doubling its capacity to add chlorine and constructed a
flood wall to protect the system.
ft�.ah uy ;i.�si ;n f

NCDWR Page 2
failure of the Town to adequately treat its wastewater and from characteristics of the Town's
waste stream.
When issues with fecal coliform arose in May of this year, EPI consulted with experts at the
National Council for Air and Stream Improvement (NCASI) in an attempt to better characterize
any public health concern arising out of the exceedances of the daily maximum limit. EPI
collected samples and sent them off to a certified lab to characterize the E. coli present in the
fecal. The current Coliform test method screens for markers which may or may not be indicators
of good water quality. Accordingly, EPI asked for the E. coli analysis as a better measure of the
quality of the water being discharged.3
Multiple samples over different days were sent to Pace Analytical Laboratories. All results
showed the total E. coli count to be less than that which EPA recommends for E. coli (applied to
municipalities) which is 126 counts/100 mL monthly geometric mean and 410 counts/100mL
daily maximum. At the request of your office, additional Coliform tests were performed both
upstream and downstream of the mill and both were within the acceptable range.
Additional information that has not been sent to your office but was communicated to you on
October 7d'is as follows:
1. Upon receiving the first weekly fecal Coliform failure on May 27`s, an investigation into
the volume and make-up of flow through the town's chlorination system began.
2. Chlorine residuals were found to be depleted during two events, one when leachate was
being pumped while the other appeared to be a"random event".
3. Several meetings with the Canton Town Manager and their Collection System Manager
occurred discussing these findings. The Town insisted that the leachate was causing
depletion of the chlorine residual.
4. EPI evaluated the effects of leachate on chlorine residual and found that the leachate had
limited effect. Data was also captured that represents when no leachate is pumped and
when a"random event" occurs through the town's effluent which overwhelms the
existing chlorine treatment system and results in zero chlorine residuals.
5. All chlorine residuals data being captured moving forward,thus began to include the
"appearance"of the sample. The reason for this was during the "random events", the
effluent often appeared to be different in appearance versus typical high chlorine residual
effluent.
6. EPI,because we are the permit holder, has performed the following in an effort to
increase the chlorine residuals at the Wastewater Treatment Plant;
a. Installed a Hypochlorite pump feed system at the Landfill operations that is
designed to actuate and respond to when leachate is being pumped. EPI has the
hypo injection feed rate set at its maximum feed of—400gpd.
3 The nearest laboratory that could do this analysis is located in Eden,NC. Shipping time to the lab actually exceeds
the required hold time for samples, however,NCASI advised EPI the results would still be valid.
II
I

NCDWR Page 3
b. At the Wastewater Treatment Plant, EPI has the Hypochlorite feed at its
maximum feed rate of—400gpd.
Note: Even with the additional hypochlorite feed, data has shown that this max feed rate
still does not effectively and consistently maintain adequate chlorine residuals
when a"random event" occurs.
7. Once EPI identified the magnitude of the"random event", EPI began contacting some of
Canton's industrial users to try and identify any recent changes in discharges that may
have occurred. This resulted in no additional information.
8. EPI, more specifically, Brian Satterfield, EHS Business Unit Manager for the Canton
Mill,reached out to other Municipalities and compliance authorities to seek help to
address these "random event"issues.
9. EPI has most recently, upon discussing with various Wastewater Treatment experts,
begun the following:
a. Hourly Chlorine residual data collection (The reason behind this is because on
the week of September 16ei, EPI failed a weekly fecal Coliform. The chlorine
residual data showed dramatic decreases in residuals over time. Collecting
data every three hours does not reflect the potential of the effluent to achieve
zero within that timeframe.)
b. Investigating continuous Chlorine monitors. Current literature indicates that
placing these monitors in a pre-treatment set-up will give false positives and
would require frequent maintenance and cleaning.
c. Establish testing requirements, whereby if or when a`random event"takes
place which is seen via a sudden drop in the chlorine residuals, the sample will
undergo a series of additional tests to better understand the makeup of these
events.
10. EPI requested via a phone call to Mr. Davidson for assistance as to what, if anything else
may also be included as additional preventive and/or proactive measures to address the
ongoing "random events"that is being seen.
11. EPI has recently had follow-up meetings with the Town of Canton in regards to these on-
going issues and the Town has agreed to initiate a Request for Qualification (RFQ)
whereby an independent expert engineer will assess their system and provide
recommended corrective actions.
12. EPI has agreed to work with the Town of Canton on the RFQ to ensure that a feasible
solution to the ongoing fecal Coliform issue is addressed.
Given the complexity of the issue, the relationship with the Town of Canton, and the ongoing
study of this issue,.EPI requests that both NOV's be reconsidered and a Notice of Deficiency be
issued. EPI will continue to work with the Town of Canton to identify the cause(s) of this issue
and will update the Division of Water Resources on any information that is discovered.
Representatives of EPI will be happy to coordinate a meeting with representatives of the Town
and DWR.

NCDWR Page 4
Your cooperation and assistance in this matter are most appreciated. If you have any
questions or comments,please feel free to contact us at your earliest convenience.
Sincerely, (�
Nick McCracken
Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
[e-mail]
cc:
Mr. Tim Heim
Environmental Specialist,Asheville Regional Office
North Carolina Department of Environmental Quality
2090 U.S. Highway 70
Swannanoa,NC 28778
C. File—Water Notebook

PAT.IvICCRQR4'
Gmceracr
DONAI.D IV VAN DER VAART
Yk4fTer�eSPtlrre5
r iax+traraaawru dttxc rr S. JAY ZIMMFRMAN
Zlitaw
Certified Mail # 7014 0510 0000 4466 4897
Return Receipt Requested
September 19, 2016
Stephen J Hutchins, General Manager
Blue Ridge Paper Products Inc
175 Main St
Canton, NC 28716
SUBJECT: NOTICE OF VIOLATION &INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2016-LV-0524
Permit No. NC0000272
Canton Mill WWTP
Haywood County
DearPermittee:
A review of the May 2016 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated below:
Limit Ezceedance Violation(s):
Sample Limit Reported
Location Parameter Date Value Value Type of Violation
001 Effluent Coliform, Fecal MF, MFC Broth, 5/27/2016 400 2,420 Daily Maximum Exceeded
44.5 C(31616)
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's NPDES Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not
more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails
to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten (10) business des after receipt of this Notice.
A review of your response will be considered along with any information provided on the submitted Discharge
Monitoring Report(s). You will then be notified of any civil penalties that may be assessed regarding the
violations. If no response is received in this Office within the 10-day period, a civil penalty
assessment may be prepared.

Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
If you have any questions concerning this matter, please contact Janet Cantwell of the Asheville Regional
Office at 828-296-4500.
Sincerely,
G.TdonDavidson, P.G., Regional upervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Asheville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
Nick McCracken/ ORC
G:\WR\WQ\Haywood\WastewaMr\Indu ttragelue Ridge Paper 00272\NOV-NOI-2016-LV-0524.rtf

PAT MGCROR:Y
NC.
Df;NAL10 R: V Tf MR VAA1T
Senn
waterlfes4wrco
OAVWGI*C rn GWAIFTY S„JAY .Z.IMME.R.MAI
kirteMa
Certified Mail # 7014 0510 0000 4466 4903
Return Receipt Requested
September 19, 2016
Stephen J Hutchins, General Manager
Blue Ridge Paper Products Inc
175 Main St
Canton, NC 28716
SUBJECT: NOTICE OF VIOLATION &INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2016-LV-0526
Permit No. NC0000272
Canton Mill WWTP
Haywood County
DearPermittee:
A review of the June 2016 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated below:
Limit Exceedance Violation(s):
Sample Limit Reported
Location Parameter Date Value Value Type of Violation
001 Effluent Coliform, Fecal MF, MFC Broth, 6/2/2016 400 600 Daily Maximum Exceeded
44.5 C(31616)
001 Effluent Coliform, Fecal MF, MFC Broth, 6/9/2016 400 1,410 Daily Maximum Exceeded
44.5 C(31616)
001 Effluent Coliform, Fecal MF, MFC Broth, 6/16/2016 400 435 Daily Maximum Exceeded
44.5 C(31616)
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's NPDES Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not
more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails
to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
i
State of North Carolina I Environmental Quality I Water Resources
2090 U.S.70 Highway,Swannanoa,NC 28778
828-2964500

If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten 10) business days after receipt of this Notice.
A review of your response will be considered along with any information provided on the submitted Discharge
Monitoring Report(s). You will then be notified of any civil penalties that may be assessed regarding the
violations. If no response is received in this Office within the 10-day period, a civil penalty
assessment may be prepared.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
Please refer to the latest letter titled "Electronic Reporting Requirements"concerning registering to use the
Division's new a-DMR system for the completion and electronic submittal of monthly Discharge Monitoring Reports
DMRs .
Your facility will be required to report your Discharge Monitoring Reports electronically by December 21, 2016.
For more information, please visit the eDMR Website at the following address:
htti)://Dortal.ncdenr.org/web/wa/``admin/`­bog/ipu/edmr.
If you have any questions concerning this matter, please contact Janet Cantwell of the Asheville Regional
Office at 828-296-4500.
Sincerely,
i
G. Landon DavidsonZRegIgnal Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Asheville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
Nick McCracken/ ORC
G:\WR\WQ\Haywwd\WastewahxUPda b]\BNB Ridge Paper 00272\NOV-NOF2016-LV-0526.rtf

Historical Reference of Fecal Coliform based on Electronic records that were found.
Date Issue Cause/Resolution
01/28/03 NOV, Fecal Coliform The probable cause of the fecal coliform violation
was insufficient retention time in the Town of
Canton's chlorine contact chamber. Resolution-
Faulty valves requiring lengthy time for rebuilt,
the town will install a plug(s)that will allow the
chamber to operate normally as well as improve
the notification system to Mill when system is
not operating as designed.
06/26/12 Fecal Coliform Excursion Unable to determine Root Cause.
08/14/12 Fecal Coliform Excursion Unable to determine Root Cause.
11/20/12 Fecal Coliform Excursion The two breaks in the Town's chlorinated water
line were preventing the incoming waste stream
from getting the full necessary dose prior to
entering the low lift. Both breaks were repaired.
11/27/12 Fecal Coliform Excursion The two breaks in the chlorinated water line
were preventing the incoming waste stream from
getting the full necessary dose prior to entering
the low lift. Both breaks were repaired.
05/17/13 Fecal Coliform Excursion The construction progress on the Town's new
chlorine pretreatment feed system. Evergreen
continues to supplement the Town's feed at the
upper manhole via a gravity fed, sodium
hypochlorite tote. The feed rate of the tote has
since been increased along with adjustments to
the Town's chlorine feed system.
08/16/13 Fecal Coliform Excursion (NOV Canton area experienced a heavy rainfall event
Issued) resulting in over two inches of rain within a 35
minute period. Flow to the wastewater
treatment plant,from the town and mill, peaked
at approximately 50 million gallons. In order to
manage flow and protect plant operations the
plant's spare primary clarifier was partially filled.
After the event,flow normalized and the spare
clarifier was slowly drained back into the
treatment process over the next three days. This
material from the spare clarifier was from the
first flush of the rainfall event and believed to
hold the most concentrated waste.
2/20/14 Fecal Coliform Excursion Unable to determine Root Cause.
2/28/14 Fecal Coliform Excursion Unable to determine Root Cause.
06/05/14 Fecal Coliform Excursion It was believed that the Secondary Effluent and
Primary Effluent samples on 6/5 were swapped
and that the mill continued to be in compliance Y
with permit limits at that time.

12/30/14 Fecal Coliform Excursion The likely explanation is limited to a significant
rain event that occurred the previous day. This
event deposited—0.40"of rain, in the Canton
area, over a period of approximately 6 hours.
Historically, increased flow and fecal loading from
the Town,to the treatment plant, has been
observed during similar rainfall events.
5/27/16 Fecal Coliform Excursion (NOV- Investigation has revealed that there is an event
Pending) taking place during normal flows within the
town's system that is depleting the excessive use
of both hypo and chlorine treatment being used.
6/02/16 Fecal Coliform Excursion (NOV- Investigation has revealed that there is an event
Pending) taking place during normal flows within the
town's system that is depleting the excessive use
of both hypo and chlorine treatment being used.
6/09/16 Fecal Coliform Excursion (NOV- Investigation has revealed that there is an event
Pending) taking place during normal flows within the
town's system that is depleting the excessive use
of both hypo and chlorine treatment being used.
6/16/16 Fecal Coliform Excursion (NOV- Investigation has revealed that there is an event
Pending) taking place during normal flows within the
town's system that is depleting the excessive use
of both hypo and chlorine treatment being used.
9/16/16 Fecal Coliform Excursion Investigation has revealed that residuals dropped
to zero when leachate was pumped even when
additional hypo was added at the land fill. Time
was allotted to achieve 10 residuals again and
then samples were collected. Leachate pumping
was minimal. Still believe a slug event occurred
within the town's system that contributed to the
reading as all other Hypo systems was on full.

Town or C"tm_Grab Sa!nple Tam!Chlorine Residuals
Chtawim Appuranm of Punp Speed Ater DaM IleneReg" IAaafyU nrdad 1 rY20d6 ]2,`30 AM
LW AM
2:30AM
3:30 AM
q, No Leachate pumping over the
a30AM weekend. Chlorine residuals
713oAM dropped from 10 to 2.
$
pAM Measurements taken every hour.
IWW AM Color observed to change from
IIINAM "cloudy"to "Blackish". EPI cannot
123oPM confirm if residuals dropped below
1:3DPM �,
2,30PM " 2 without having a continuous real
3:30 PM R. time monitor. This is but one of
a3aw4 many examples EPI is experiencing
5:30 PM
6:30PM " in the current treatment of
1:30wA " incoming Town material.
a:3uPM ,•
t3aPM
PM
3190 pM
123DAIM
EM AM M
2010 AM
I
3;30AM ,r
f:30AM
S30AM
...-- -�..--. &WAM