NC0000272_Response to 80/90 Rule_20160420

evergreen. Canton Office
packaging I 175 Main Street• Canton, NC 28716
April 20, 2016 NMM#25-16
Mr. Tim Heim
Environmental Engineer—Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ—Division of Water Resources
2090 U.S. Highway 70
Swannanoa,NC 28778
Re: NPDES NO. NC0000272
Email Request for 80/90 % Rule Explanation for Canton Mill
Blue Ridge Paper Products Inc. d/b/a Evergreen Packaging
Canton, NC
Thank you for your e-mail of Wednesday, April 20, 2016 regarding the 80/90 % Rule in 15A
NCAC 02T .0118. As you are aware, Subchapter 2T regulates waste not discharged to surface
waters. The first sentence of section .0118 reads, in part, "... no permits for sewer line
extensions shall be issued to wastewater treatment systems owned or operated by
municipalities, counties, sanitary districts or public utilities unless they meet the following
requirements. " Evergreen Packaging's wastewater treatment at the Canton Mill is not owned or
operated by the Town of Canton. It is Evergreen's position that 2T.0118 does not apply to the
Canton Mill Wastewater treatment plant.
Evergreen Packaging does treat waste from the Town of Canton,pursuant to contract. The
Canton Mill's wastewater treatment plant was originally designed for 60 MGD of effluent flow.
In the early 1990's, the mill underwent a modernization project that allowed us to upgrade the
facility and insert numerous internal recycling loops. This reduced the amount of flow to the
wastewater treatment plant by nearly half. The mill's current permitted monthly average
discharge limit is 29.9 MGD.
The Town of Canton discharges approximately 0.76 MGD (based on 2015 annual average)to the
Canton Mill's wastewater treatment plant on a daily basis. During periods of heavy flow or
storm events the treatment plant may see flows as high as 1.5 MGD. Using the Town flow value
versus an annual average mill discharge of 27.7 MGD for 2015 this would result in the Town
contributing^5.4% of the total discharge flow from the treatment plant.
Currently, the mill does not have plans to expand or increase the amount of discharge into the
Pigeon River. If anything, we continue to look for opportunities to decrease our usage and
amount discharged. The Town of Canton does own and operate the collector sewer system.
Blue Ridge Paper Products Inc. dba Evergreen Packaging —Canton Mill /
175 Main Street • PO Box 4000 ;rt
Canton, North Carolina 28716 • 828-646-2000
\\everpack\CTN\Shared\EOHS\Share\Water Files\Nick's Water Files\W WTP\DWR Correspondence\80 90 Rule Request&
Justification\Response to DWR Regarding 80-90 Rule 4-20-16.docW WTP\DWR Correspondence -

20 Apr 2016,Page 2
Evergreen Packaging is not aware of any plans by the Town of Canton to expand its collection
system.
If you have any further questions please feel free to contact me at your earliest convenience.
Please contact us if you have questions regarding this information.
Sincerely,
Nick McCracken
EHS Water Supervisor
Evergreen Packaging—Canton Mill
[e-mail]
Blue Ridge Paper Products Inc. dba Evergreen Packaging—Canton Mill
176 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
IleverpacklCTNISheredIEOHSISharelWater FilesUcks Water FilesIWWTPIDWR Correspondence180 90 Rule Request&
JustificationWesponse to DWR Regarding 80-90 Rule 4-20-16.doc