NC0000272_Report_20211207

pactuv
evergreen
175 Main Street
Canton, NC 28716
828.646.2000
pactivevergreen.com
CERTIFIED MAIL —RETURN RECEIPT REQUESTED
70202450000035625795
December 6, 2021
Mr. Landon Davidson
Regional Supervisor
Division of Water Resources — Asheville Regional Office
North Carolina Department of Environmental Quality
2090 US Hwy 70
Swannanoa, North Carolina 28778
Subject: Noncompliance Report
Blue Ridge Paper Products, Inc. dba Evergreen Packaging
Canton Mill - Permit No. NC0000272
Dear Mr. Davidson:
This document serves as the written submission requirement found in NPDES permit NC0000272 Part II,
Section E, 6. And 9.
The following represents the current findings of the investigation and analysis of the noncompliance
event that was reported to your office on November 23 and 24, 2021. If and when additional or
corrected information becomes available, subsequent reporting will be provided. Note — all the
following dates are 2021.
Description
On November 23, at approximately 7:00 am, wastewater treatment plant (WTP) operators noted an
unusual, significant increase in influent color readings, identified soap in the flow, and began
investigating the cause with mill process personnel. At approximately 9:00 am, influent wastewater was
diverted to the spare clarifier to capture wastewater identified as problematic to prevent a possible
upset to the treatment process. Flow remained diverted until 90% spare clarifier capacity was reached.
Flow was then returned to normal operations. Effluent and process monitoring (Total suspended solids
[TSS], color, pH and dissolved oxygen [DO]) indicated wastewater effluent was below permit limits
(Table 1). BOD samples were set for the five-day incubation period and analysis (BOD5). Visual
observations conducted at approximately 7:30 am of the effluent discharge in the river, identified
elevated foam and turbid conditions. At 3:00 pm, the WTP Operator in Responsible Charge (ORC)
contacted Tim Heim (Division of Water Resources) in the Asheville Regional Office to report the change
in visual effluent conditions, including elevated foam in the discharge. Efforts continued to identify the
source of the soap and improve treatment of the wastewater to reduce foam and solids discharge,
which were slightly elevated above normal levels.
Effluent conditions remained relatively unchanged on the morning of November 24 (i.e., elevated solids
and foam) and within permit limits (Table 1). BOD5 samples were collected and set for later analysis.
Environmental technicians, conducting a periodic inspection, approximately two river -miles downstream
of the outfall 001 discharge, at a known dissolved -oxygen sag -point and oxygenation station (02

Noncompliance Report
Page 2 of 4
Station), observed two dead fish and several other fish in distress (Figure 1). DO monitoring on
November 24 indicated all locations within the range of 8.0 —10.7 mg/L (Table 1). The technicians
communicated the findings to mill EHS personnel. Additional river inspections were conducted at
multiple locations along the Pigeon River, as shown on Figure 1, where additional dead and distressed
fish were noted (Table 2). The ORC called Tim Heim to update him on the identification of the impacted
fish and conditions at the WTP, left a voicemail and provided a written report via email. Efforts
continued to confirm that no additional soap was entering the mill sewer system and improve treatment
of the wastewater to reduce foam and solids discharge, which continued to be slightly elevated above
normal levels.
River inspections were conducted on a daily basis through November 28. Inspection findings confirmed
water quality was steadily improving and no additional impacts to the fish population had occurred.
Tim Heim conducted an inspection of river locations with the ORC and others on November 29.
Cause
Two likely causes have been identified as contributors of soap to the mill WTP.
1. Tall -Oil -Making Process: The tall -oil -making process had been shut down on November 22 to
repair delivery pump and clogged delivery line from the east and west soap* collection tanks to
the saveall tank — part of the tall -oil -making compound. As part of the repair work, a valve on a
steam line adjacent to the soap collection tanks was opened to assist in clearing the delivery
line. A temporary hose, normally used for steam cleaning purposes, was attached to the same
steam line noted above within the tall -oil -making compound. The hose was left opened and the
end of the hose was left positioned outside of the secondary containment. Unknowingly,
contents of the east and west soap collection tanks (soap -laden black liquor) entered the steam
line, flowed through the temporary hose and was inadvertently discharged to the mill sewer
system.
The inadvertent discharge was identified at approximately 9:00 am on November 23 and
stopped. The discharge appeared to have lasted approximately two hours.
The amount of soap discharged to the wastewater treatment plant (WTP) is indeterminate at
this time. Attempts to quantify the amount are ongoing.
2. Pine Weak Liquor Storage Tank: Weak liquor from our pine washing system is collected in an
approximate 616,000-gallon tank with an overflow pipe from the top of the tank to the drainage
area on the ground. This tank sits in a BMP drainage area equipped with a recovery sump in the
event black liquor overfills the tank. The sump is designed such that if the conductivity is high,
indicating presence of black liquor then a pump will activate and move the contents to a spill
recovery tank.
Soap can occasionally build up in this tank and overflow. Soap in this sump can cause the
recovery pump to become air -bound and not actually pump; however, the controls will indicate
the pump is running. This tank does not normally have excessive soap and can be readily
managed. Due to recent soap recovery issues there was an unusual amount of soap in this tank.

Noncompliance Report
Page 3 of 4
Although recorded data is not currently available, it is believed that this tank overflowed for
some period of time, discharging soap to the mill sewer system. Data gathering and analysis will
continue for better understanding of what transpired in the pine weak liquor storage tank
compound.
Other possible sources of soap are being evaluated as part of the response to the event. Best
management practices require soap to be contained within mill processes and prevented from entering
the sewer system. Other secondary possible sources are being investigated.
*[Soap (rosin soap) — a byproduct of the kraft process; utilized in tall oil production; normally rises to the
surface of the black liquor and is skimmed off for making tall oil]
Period
Influent wastewater color data indicated soap likely started entering the WTP at approximately 7:00 am
on November 23 and ceased on November 23 at approximately 10:00 am. Due to the nature of
recycling biomass in an activated sludge treatment plant, the material remained in the plant for several
days. Effluent monitoring data results (Table 1), indicated the 001 discharge was compliant with permit
limits throughout the event timeframe, except the BODssamples, which were not available for review
until November 29. The BOD5 samples from November 23, 24 and 25, which were available on
November 29, 30 and December 1, indicated exceedances of our daily maximum pound per day BOD5
limit (14,778 Ibs/day, 17,931 lbs/day, 16,791 Ibs/day versus a daily maximum of 10,897 Ibs/day). The
BOD5 effluent results were significantly high enough that our monthly BOD5 average was 3370 Ibs/day,
exceeding the monthly limit of 3205 Ibs/day. The BOD5 results available on December 2 and 3 were back
in compliance with our daily maximum permit limit (6,879 Ibs/day and 2,645 Ibs/day). Effluent BOD5was
the only parameter found to be greater than permit limits from the event.
Corrective Action
Upon communication from wastewater operators of a significant increase in influent color, operations
personnel began investigating the possible cause. At approximately 10:00 am, the discharge from the
steam line was identified and stopped.
As stated above, at approximately 9:00 am WTP personnel diverted the soap -laden wastewater to the
empty, backup clarifier to prevent further introduction of the problematic materials to the treatment
process.
WTP operators increased polymer injection and defoamer addition in attempts to improve wastewater
treatment, lower total suspended solids (TSS) and reduce possible effects on the river. Process sampling
was increased to evaluate treatment effectiveness in efforts to reduce TSS and foam in the discharge.
Process personnel increased inspections, and evaluations of containments, sumps and other equipment
associated with soap handling.
On November 30, following indications that the majority of the soap discharged to the WTP had been
processed and treated, reducing ongoing negative impacts on the microbial population in the
wastewater system, augmentation of the treatment system with additional microorganisms and food
began to assist the plant fully recover from the upset.

Noncompliance Report
Page 4 of 4
Steps to Reduce, Eliminate and Prevent Reoccurrence
Preventing the discharge of soap to the mill sewer system and WTP is a critical component of
established best management practices (BMP) and a primary component of the mill's BMP Plan.
Although soap was not expected to be in the steam line, had the hose been in the containment, the
release would have been contained and identified.
Monitoring system and sump pump components that should have identified and contained a soap
discharge to the pine weak liquor storage tank sump are being evaluated for efficacy and will be
modified as appropriate. Action steps to be taken by operators and condition thresholds (e.g., tank
levels, conductivity, pump performance) that indicate that soap may be discharging from tanks and
other process system components are being reviewed and also will be modified as appropriate.
In addition to the above immediate actions, the following is either underway or will be conducted to
further prevent possible reoccurrence of similar spills:
• Inspection of all spent liquor, turpentine and soap containments, conductivity sensors and level
transmitters to ensure the all components are functional as outlined in the BMP Plan
• Additional, BMP refresher training for appropriate mill personnel
• Review of the following procedures and processes:
o BMP inspections
o Equipment repairs
o Sump, sewer and wastewater monitoring
o Spill response
• Review of historical monitoring data and BMP event reports to discuss or spill events and
identify trends
We will update your office as soon as possible with any changes in this information.
Respectfully,
Tracy Mllis
Wastewater Treatment Plant ORC
Canton Mill
[e-mail]
Phone: [phone] / Mobile: [phone]
'-(ze/QcL T-
Fred Perrett
Interim General Manager
Canton Mill
[e-mail]
Phone: [phone]

1
Ryder Mountain and
Richland Creek
(7.3)
• Aerial photography from Google Earth (downloaded 12/29/2021)
• River miles calculated via Google Earth measuring tool
Clyde Lift Station
(5.7)
Above Clyde
(5.2)
Clyde Park
4.6
Evergreen Packaging - Canton Mill
Noncompliance Report
Figure 1
Pigeon
River
Legend
02 Station
(2.0)
Fiberville
Bridge
0.3
Monitoring/Observation Location
(River miles from Outfall 001)

Evergreen Packaging - Canton Mill
Noncompliance Report
Table 1
Monitoring Location
Outfall 001
Canton
Fiberville
Bridge
Above
Clyde
Canton
Fiberville
Bridge
Above Clyde
Parameter
Flow
TSS
BOD5
Color
DO
pH
Fecal Coliform
DO
pH
Units
MGD
lb/day
lb/day
lb/day
mg/I
pH
Colonies/100mL
mg/I
mg/I
mg/I
pH
pH
pH
Permit Limit (Daily
maximum unless
otherwise noted )
Monthly
average
29.9
49560
10897
105250
Monthly
average not
Tess than 6.0
6.0 - 9.0
400/100mL
-
-
-
-
-
-
11/17/2021
26.9
3139
1560
28919
9.3
7.5
10.8
10.5
9.6
7.2
7.6
7.6
11/18/2021
27.7
3920
2015
35974
9.0
7.4
9.7
9.8
9.4
7.1
7.6
7.7
11/19/2021
26.1
3702
3216
37672
9.6
7.4
10.2
10.5
10.6
7.6
7.7
7.9
11/20/2021
26.4
3085
3158
33933
9.3
7.6
10.6
10.9
10.2
7.4
7.7
7.8
11/21/2021
26.2
2188
1835
30626
9.8
7.5
10.9
11.1
11.0
7.6
7.6
7.9
11/22/2021
27.1
2261
1816
35045
9.7
7.6
<1
10.1
10.8
10.9
7.6
7.6
7.9
11/23/2021
29.8
4967
14778
35765
8.2
7.1
10.9
11.0
10.9
7.3
7.5
7.7
11/24/2021
30.1
16050
17931
47147
8.0
7.2
10.6
10.7
9.1
6.8
7.3
7.3
11/25/2021
28.7
12216
16719 1
43114
12.1
7.4
10.6
11.3
8.1
7.3
7.4
7.4
11/26/2021
27.8
6258
6879
43804
13.1
7.5
9.5
11.0
9.0
7.5
7.6
7.6
11/27/2021
27.5
3435
2645
50155
16.8
7.4
10.8
10.6
9.4
7.5
7.6
7.7
11/28/2021
28.9
3858
2295
49186
14.3
7.6
10.3
11.1
9.2
7.3
7.6
7.7
11/29/2021
28.1
2341
1814
52673
14.2
7.6
10.8
11.6 1
9.6
7.1
7.5
7.7
11/30/2021
27.2
1816
1648
45857
12.9
7.7
7
10.9
11.5
9.6
7.2
7.6
7.7
Bold numbers indicate data greater than permit limit
001- Outfall 001 permitted discharge
BOD5 - biological oxygen demand with five-day incubation period
C - celcius
deg - degrees
DO - dissolved oxygen
lb/day - pounds per day
mg/I - milligrams per liter
MGD - million gallons per day

Evergreen Packaging - Canton Mill
Noncompliance Report
Table 2
River Observations
Monitoring Location
Fiberville
02 Station
Clyde Park
Above Clyde
Clyde Lift Station
Hyder Mountain
and Richland Creek
Riverside Drive
River miles below
Outfal 1001
0.3
2.0
4.6
5.2
5.7
7.3
9.2
Observations
11/23/2021
• No dead fish
• No fish in distress
• 3 dead fish
• Multiple fish in
distress
• < 10 dead fish
• Multiple fish in
distress
• No dead fish
• No fish in distress
NO
• No dead fish
• No fish in distress
• No dead fish
• No fish in distress
11/24/2021
• No dead fish
• No fish in distress
• 3 dead fish
• Multiple fish in
distress
• < 10 dead fish
• Multiple fish in
distress
• No dead fish
• No fish in distress
• 3 dead fish
• No fish in distress
• No dead fish
• Several fish in
distress
• No dead fish
• No fish in distress
11/25/2021
• No dead fish
• No fish in distress
• 3 dead fish
• Multiple fish in
distress
• < 10 dead fish
• Multiple fish in
distress
• No dead fish
• No fish in distress
• 3 dead fish
• No fish in distress
• No dead fish
• Several fish in
distress
• No dead fish
• No fish in distress
11/26/2021
• No dead fish
• No fish in distress
• 3 dead fish
• No fish in distress
• 18 dead fish
• No fish in distress
• 2 dead fish
• No fish in distress
• 3 dead fish
• No fish in distress
• No dead fish
• No fish in distress
• No dead fish
• No fish in distress
11/27/2021
• No dead fish
• No fish in distress
• No dead fish
• No fish in distress
• 10 dead fish
• No fish in distress
• No dead fish
• No fish in distress
• No dead fish
• Several fish in
distress
• No dead fish
• Several fish in
distress
• No dead fish
• No fish in distress
11/28/2021
• No dead fish
• No fish in distress
• No dead fish
• No fish in distress
• 10 dead fish
• No fish in distress
• No dead fish
• No fish in distress
• No dead fish
• Several fish in
distress
• No dead fish
• Several fish in
distress
• No dead fish
• No fish in distress
11/29/2021
• No dead fish
• No fish in distress
• No dead fish
• No fish in distress
• 10 dead fish
• No fish in distress
• No dead fish
• No fish in distress
• No dead fish
• No fish in distress
• No dead fish
• Several fish in
distress
• No dead fish
• No fish in distress
11/30/2021
• No dead fish
• No fish in distress
• No dead fish
• No fish in distress
• <10 dead fish
• No fish in distress
• No dead fish
• No fish in distress
• No dead fish
• Several fish in
distress
• No dead fish
• Several fish in
distress
• No dead fish
• No fish in distress
NO - Not observed