NC0000272_NOV-2021-DV-0254 Response_20210615

evergreen
packaging
G. Landon Davidson, P.G.
Regional Supervisor
NC Department of Environmental
Quality — Division of Water Quality
Sent VIA Electronic Mail
Re: Notice of Violation — 2021-DV-0254
Mr. Davidson,
Canton Office
175 Main Street . Canton, NC 28716
June 15, 2021
On May 3', an oil sheen was noticed by Canton Mill personnel along the east bank of the Pigeon River
adjacent to the wastewater collection system 4A manhole. The extent of the sheen was limited to an
eddy current just below the pipe which carried mill wastewater across the river.
The sheen, as required, was reported to the National Response Center which lead to an onsite
inspection on May 4th by Department of Environmental Quality, Division of Water Quality. An estimated
20 gallons of a wastewater containing turpentine may have been discharged to the ground in a shallow
depression next to the 4A manhole. A rain event just before the sheen was noticed seemed to have
washed the spilled material into the river.
It is believed the turpentine water mixture emitted from the partially open slide gate of the 4A manhole.
This slide gate is intended to be open for flood control measures instituted after the 2004 floods. The
turpentine decant system includes a dedicated pipe from the turpentine storage area to the 4A
manhole. The pipe extends from the top of the manhole to near the ordinary section of the wastewater
in the lower level of the manhole. A section of the pipe was found to be missing upon inspection on
May 4th. This allowed the turpentine and water mixture to spray along the side of the 30 foot tall
manhole structure splashing at a concrete ledge inside of the manhole.
The dedicated line is used approximately once a week to pump the decanted water from the bottom of
the turpentine tank as well as the stormwater which collects in the containment area.
A valve at the bottom of the tank is manually opened allowing decanted water to flow from the bottom
of the tank. As soon as product is seen, the valve is closed. It's this mix of water and turpentine which
we believe sprayed out of the side of the manhole slide gate on Saturday May 1st and found Monday
May 3rd
As soon as the leak was discovered the soil and debris around the slide gate were removed to minimize
the impact. Oil absorbing booms were also placed in the Pigeon River to absorb the material which was
seen in the eddy along the east side of the river. The bank of the river was walked both upstream and
downstream to confirm this was the only point of impact and additional cleanup material was not
needed elsewhere. We continue monitoring the riverbank. We believe the root cause has been
addressed with the installation of the pipe and this issue has been resolved.

Items to address:
1) Immediate cease all unpermitted discharges to surface waters of primary (i.e., tank and pipe)
and secondary sources (i.e., impacted spoils, stormwater conveyances, etc.).
Complete. The area immediately around the slide gate where the release occurred has been cleaned
of all impacted debris. An absorbent boom is still in the river to collect any remaining material which
may still be present.
2) Institute engineering, administrative and other necessary controls and training to reduce or
eliminate the reoccurrence of this event in the future.
Complete. The section of pipe from the top of the 4A manhole to the water surface has been
replaced. This will prevent the wastewater from splashing on the interior of the manhole.
3) Report to the Office assessing the cause, significance, and the extent of the industrial
wastewater released on May 3rd, 2021. The report is to include, but not limited to, the following
information:
a. Provide a detailed account of the cause of the release
Complete as noted above. We believe the turpentine water mix from a batch operation in the mill
splashed along the side of the 4A manhole due to a missing section of pipe. The splashing caused some
of the wastewater mix to exit the manhole structure through the slide gate.
b. Confirm the source and volume of material that entered the Pigeon River. Please include
documentation and/or sufficient detail supporting your estimate of the volume of
product released; and
Turpentine has a distinct pine odor which was present after the event. Looking at the sheen in the
water, it had a gray color and the patches somewhat hold together. All of these characteristics as well as
the missing pipe inside of the manhole lead us to the root cause of the turpentine decant water
splashed on the ground due to the missing pipe in the 4A manhole.
The amount is more difficult to quantify. Knowing the wastewater was being splashed on a ledge inside
of the 4A manhole and then exiting through a partially open slide gate is difficult to calculate. The
amount of sheen seen on the river is possible a quart or less and we have tried to capture as much as
possible with the absorbent booms.
c. Provide a summary of all emergency and remedial actions completed to date including
any site modifications (e.g. modification of the turpentine separation tanks and
associated conveyance to the WWTP, excavation of impacted Soil, ETC

The immediately impacted area around the slide gate has been cleared of saturated material. This
material was excavated the week of the incident and has been disposed. Absorbent booms have been
placed in the river to collect as much material as practical. These booms are being refreshed to make
sure they are still floating and capable of absorbing material. These booms are still being deployed to
collect residual material. The root cause was the missing pipe in the 4A manhole. A temporary pipe was
installed the following week after the event and a permanent pipe was installed the week of June 7tn
We believe this resolves this issue of the turpentine leak from the 4A manhole. Please contact me for
any additional information.
Respectfully submitted,
Paul T. Syslo
Environmental, Health and Safety Manager
Evergreen Packaging
Cell: 828-458-0244
Tracy Willis
Operator in Responsible Charge
Evergreen Packaging
Cell: 828-424-9955