NC0000272_Request to Rescind NOV-2013-LV-0677_20131213

Canton Office
evergreen
packaging 175 Main Street• Canton, NC 28716
December 13,2013 NMM#101-13
Certified Mail-Return Receipt Requested
7011 3500 0001 8863 8003
Landon Davidson
Asheville Regional Supervisor
Division of Water Quality
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
Request to Rescind NOV;NOV-2013-LV-0677
NPDES Permit:NC0000272
Dear Mr.Davidson:
On November 5,2013 we received a Notice of Violation(NOV)in regards to a daily maximum value for fecal
coliform. We respectfully request that the NOV be rescinded.
After a formal discussion,at the regional office on November 14t,you requested additional information
about the circumstances surrounding the prior and most recent test values. Please see below for an
explanation of the events that occurred for elevated fecal coliform test results in 2012 and 2013.
On June 26,2012 an elevated fecal coliform test value was reported. Laboratory results showed a geometric
mean of 477 colonies/100ml. We were unable to determine the cause of the elevated value. A complete
walk through of the treatment system was conducted. The Town of Canton owns and operates a
pretreatment chlorination system.This system is owned and operated as part of an agreement between the
Town and Mill. This system was checked and appeared to be functioning as designed.
On August 14,2012 the Mill received an elevated fecal coliform value of 600 colonies/100m1. At the time of
discovery,we were unable to determine a cause for the elevated value. A complete walk through of the
treatment system was conducted. The Town of Canton,once again,checked the pretreatment chlorination
system,and it appeared to be functioning as designed without any downtime in operation. After review,it
was determined the results were a laboratory anomaly.
On November 20,2012 and November 27,2012 two additional test results showed values of 600 colonies/
100ml and 6000 colonies/100ml,respectively. During this time,a construction upgrade of the Champion
Drive force main and Bridges pump station was occurring. Construction crews were onsite installing the
force main working towards the W WTP low lift. The last section of the new piping occurs at the tie-in to the
South force main before entering the head of the plant This is also the location of the Town of Canton's
pretreatment piping. As crews excavated,they discovered that the chlorinated water line that pretreats the
Town of Canton's wastewater had broken in three sections underground. The HDPE pipe was installed in
fresh by design .
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sections with each new section welded to the other. It appeared the pipe had contracted,pulling these welds
apart Along with our notification,we submitted a letter from the Town of Canton explaining the breaks in
the line and also their repair. With this discovery,we determined the Town's chlorinated water line had
been broken for some time which resulted in the elevated fecal coliform results in June and August that are
discussed above.
In consultation with the Town of Canton and their consultants,we collectively decided to improve the
current pretreatment design of the system. A single run of HDPE piping would be used to prevent past
failures from recurring. Additionally,there would be two points of entry for the chlorinated water and a new
distribution system within the manhole to evenly dose the incoming wastewater. These design
improvements required additional funding from the Town prior to installation.
On May 17,2013 the Mill received a fecal coliform test result of 600 colonies/100ml. Upgrades to the
Town's pretreatment system were not complete at this time. The Mill was continuing to supplement the feed
of chlorinated water from the Town with a sodium hypochlorite tote at the upper manhole. This practice
continued until construction was completed during the month of June.
On August 16,2013 the Mill experienced a heavy rainfall event resulting in over two inches of rainfall within
35 minutes. This act of God resulted in flow to the treatment plant from the Town of Canton and Mill peaking
at approximately 50 million gallons. In order to manage this abnormal 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.
Based on these events and our findings,we request that the NOV issued on November 5,2013 be rescinded.
If you have any questions or comments,please feel free to contact us at your earliest convenience.
Sincerely,
Chet C.Chiles
EHS&S Manager
Canton&Waynesville
828-646-2381
[e-mail]
NMM\
cc: Chuck Cranford,Asheville Regional Office
Jeff Menzel,Asheville Regional Office