NC0000272_Monitoring Report Section E6a_20170104

evergreen.'Fa Wanton Office
packagi Street Canton, NC 28716
January 4,2017
CERTEFIED MAIL
Return Receirni Rcouested
Landon Davidson
Asheville Regional Supervisor
Division of Water Resources
North Carolina Department of Environment
and Natural Resources
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
Daily Maximum Fecal Coliform 12/22/2017 & 12/29/2017
NPDES Permit:NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: b(a). The secondary effluent fecal coliform sample was taken on
December 22d at approximately 8:30 am and was picked up and delivered by laboratory courier.
Proper sampling procedures were followed by plant personnel. The result of the analysis showed
a value of 24200 MPN per 100 ml. The fecal coliform excursion on December 221 was limited
to that sample parameter and day. A phone call was placed to the NCDEQ regional office on
December 28h to discuss the results once discovery had been made.
After the value from the laboratory was observed, all systems in the treatment facility were
inspected. They were found to be operating correctly leading up to and during the time of
sample.
Leading up to December 221d Fecal Coliform(FC) exceedance,EPI had been further
investigating on-going but varied data reported back from our certified laboratory Pace
Analytical Services dating back to the week of November 19'. The reason for the investigation
was due to a reported FC exceedance of the daily maximum for December 15e EPI submitted to
DWR a letter on December I Vh that outlined its investigation into the alleged exceedance. On
December 81h after conducting an investigation into the December 1'exceedance,EPI received
the FC compliance lab results from Pace. The results indicated the following: Town of Canton,
4.1 MPN/ 100 ml;Upstream, 95 CFU/100ml and the Secondary EfIIuen% 1300 MPN/100ml.
EPI questioned this data given the historical data collected from each source coupled with the
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fact that no changes operationally have occurred. When EPI presented this information to Pace,
Pace reviewed their internal procedures and EPI was informed that Pace believes that the
samples had switched during the evaluation of the data. Pace then sent EPI a revised Laboratory
Analysis report which then reflected the values of the Town of Canton(TOC) and the Secondary
Effluent to now be switched(4.1 MPN/100m1 for the Secondary Effluent and 1300 MPN/l 00ml
for the TOC.
Given the now questionable reliability of Pace,EPI felt the need to explore other
laboratories that could test for FC. In speaking with Jason Smith from DWR, EPI was presented
a list of laboratories in the region who could perform the Colilert 18 method. After analysis of
our options, EPI identified only one other lab alternative, Statesville Analytical. As part of the
FC study with the TOC and working with FISS environmental,the proposal within the scope of
work was if any exceedance were to occur,then have the sample analyzed via Membrane
filtration or sent to another lab and have an e.coli speciation performed. To date,EPI has not
sent any samples off for e.coli speciation testing but is considering this a probable next step.
Back in 2016 when a series of weekly exceedances occurred, EPI did send off at that time
samples to the Eden,NC lab for e.coh determination. It was determined at that time to not be of
any human or animal origins but rather plant based. This echoed the information EPI obtained
from NCASI when informed of the on-going issues.
EPI wanted to determine the ability or differences in running the Cohlert 18 versus the
membrane filter test for FC. The reason for this analysis was to determine if this was a
contributing cause to the varying data that has been received for the multiple sampling
conditions. The week of December 18&, EPI began to split the samples to be analyzed into four;
two samples going to Pace and two samples going to Statesville Analytical(SA)with each lab
being requested to test for FC using both the Colilert 18 and the Membrane Filter methods. The
FC results for the week showed that Pace labs had major differences in FC counts given the two
methods while the SA lab had very similar results between the two methods. Furthermore,the
FC counts from Pace were on average 3-10 times higher than those from SA. Not knowing the
aforementioned information, EPI performed the normal compliance test on December 22'and
only had the Colilert 18 method performed.
On December 27a', EPI received the laboratory analysis report from PACE which
indicated that the compliance test performed on December 22"d was 24,200 MPNII00ml. EPI
contacted Pace to question the results to determine if the results obtained were switched at the
laboratory. At that time, the Pace representative, spearing on behalf of their Microbiologist,
indicated that given the recent samples EPI has submitted to run both Colilert 18 and Membrane
Filtration,Pace has identified other non-fecal bacteria in large concentrations that in their words
was most likely causing interferences in obtaining accurate counts via both test methods. On
December 28',EPI contacted the DWR and informed them of the results and EPI's steps to
investigate the issue. EPI requested from DWR that a formal conference call be had between the
two to discuss the facts and investigational findings. The meeting was scheduled for January 31d.
EPI contacted SA and had discussions around the general observations of the EPI samples and if

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there was any difficulties in running the samples and to obtain accurate data from those samples.
SA responded that they observed non-fecal bacteria present but the samples provided were not
such that accurate results could not be obtained.
Given the information obtained from the discussions from both labs,the decision was
then to have SA perform the analysis. However, the week of December 25a', SA did not have a
currier to pick up samples and as such,EPI sent the weekly routine samples again to Pace with
the December 291 compliance sample split to run both the Colilert-18 and the Membrane Filter
test. The results for the December 291 test was received on January 21 and indicated a wide
difference between both test procedures(2910 MPNA00m1 for the Colilert-18 versus 610
MPN/100m1) for membrane filtration. EPI investigated its operations and found no change in its
operations. EPI then formulated the sampling scheduled to have SA run both FC tests on the
TOC and#4 flume on January 3'd and the same on January 41 but also include the secondary
effluent. For the week of January P,the following sampling schedule has been developed:
January 9a': Pace—TOC and#4 Flume with both FC test procedures.
SA—TOC,Upstream,#4 Flume and Secondary Effluent with both FC test
procedures. An additional split sample of the Secondary Effluent will be collected
to have a heterotrophic classification test performed.
January 10th: SA-TOC and#4 Flume with both FC test procedures. An additional split sample
of the#4 Flume will be collected to have a heterotrophic classification test
performed.
January l lm: Pace—TOC and#4 Flume with both FC test procedures.
SA—TOC,Upstream,#4 Flume and Secondary Effluent with both FC test
procedures. An additional split sample of the Secondary Effluent will be collected
to have a heterotrophic classification test performed.
The reason for the additional testing, switching the testing to another certified laboratory
and to obtain heterotrophic classifications of the material present in the discharge samples is
because EPI believes the current laboratory data acquired from Pace is not accurate nor is it
representative of the effectiveness of the treatment abilities conducted at EPI.
EPI had a formal conference call with the DWR on January 3'd to discuss the
investigative approach and DWR has requested to split samples on January 91 and 11*and have
the results tested in their laboratory. DWR also requested to witness the entire preparation,
capture, collection and preparation of the samples. EPI requests to the DRW that enforcement
discretion be given pending the outcome of the sampling results submitted to the certified lab SA
and also the results obtained through DWR's split sampling and internal testing.

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If you have any questions or comments,please feel free to contact us at your earliest
convenience.
Sincerely,
Brian Satterfield
EHS Manager
Evergreen Packaging—Canton Mill
828-646-2381
UJL.LQU.saLLrfield(i,,I�Mack.com
cc:
Mr. Tim Heim
Environmental Engineer,Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778