NC0000272_NOV-2022-LV-0002 Response_20220114

p►activ
evergreen.
175 Main Street
Canton, NC 28716
828.646.2000
pactivevergreen.com
CERTIFIED MAIL— RETURN RECEIPT REQUESTED
70200640000046061718
January 14, 2022
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: Response to NOV-2022-LV-0002
Blue Ridge Paper Products, Inc. dba Evergreen Packaging
Canton Mill - Permit No. N00000272
Dear Mr. Davidson:
This document responds to NOV-2022-LV-0002 received on January 4, 2022.
Firstly, Evergreen Packaging places paramount importance upon permit compliance and water resource
protection and regrets the issues that led to the upset of the mill wastewater treatment plant.
The facility has a significant history of NPDES wastewater permit limit compliance, particularly regarding
BOD limits. Two exceedances of BOD daily limits were identified during review of the previous 15 years
of discharge monitoring records: October 31, 2008 and May 17, 2012. Clearly, the recent BOD limit non-
compliance was a rare event and effective treatment of wastewater and discharge of compliant effluent
should be expected.
As reported in the Noncompliance Report submitted to your office on December 6, 2021, wastewater
treatment processes and effluent quality were negatively impacted by soap entering the mill sewer
system, causing the exceedances of permit limits described in the subject NOV.
Additional information regarding the investigation and actions taken by the mill since the above -
mentioned report was delivered is provided below.
Cause Investigation
Evergreen has continued efforts to identify the cause(s) of the introduction of soap to the mill sewer
system, including reviewing mechanical components, system processes, communication/warning
systems, and operator actions and responses.
As reported previously, two likely causes have been identified:
1. Discharge from the tall -oil -making process
2. Overflow from the pine weak liquor storage tank

Response to NOV-2022-LV-0002
Page 2 of 3
Corrective Action
After further investigation of the causes, the following items were identified that likely could have
prevented the loss of soap to the mill sewer:
• Updated training for operators of the extreme importance of containing soap in mill processes
and avoiding any discharge to the wastewater treatment plant (WTP), including more aggressive
action steps to eliminate and capture any discharges
• Updated training for operators of best management practices (BMPs)
• Expanded communications of pine weak liquor storage tank monitoring data to operators and
managers
• Remote visual monitoring of the pine weak liquor storage tank area
• Enhanced, timely communications of process condition changes that may indicate possible soap
overflows or discharges
• Increased secondary containment at the pine weak liquor storage tank to prevent discharge of
soap to the containment sump
Briefings and communications have been conducted with operators to emphasize the extreme
importance of containing soap in mill processes and avoiding any discharge to the wastewater
treatment plant (WTP). BMP training will be updated and enhanced for release to mill personnel as soon
as possible in 2022.
Best practices regarding the use and management of hoses within the tall -oil -making system has been
reviewed with department staff and the importance of maintaining effective secondary containment of
all products containing soap has been emphasized.
Communication of data collected from the overflow alarm on the pine weak liquor tank, an indication of
possible soap discharge from the tank, was modified to display in a second location for increased
visibility of process conditions for department managers. A text -enabled alarm to appropriate personnel
has also been initiated.
Remote visual monitoring was considered an enhancement to pine weak liquor tank area monitoring.
Installation of surveillance camera equipment is planned. Until camera installation is completed, mill
personnel are inspecting the pine weak liquor tank area every 30 minutes.
Intradepartmental and interdepartmental communications have been enhanced to create more
effective prevention and capture of soap discharges.
To further prevent the discharge of soap from the pine weak liquor tank to the mill sewer, secondary
containment is being modified to provide additional storage capacity. Temporary measures have been
implemented until permanent modifications can be completed.
Spent liquor, turpentine and soap containments, conductivity sensors and level transmitters have been
inspected to ensure all components are functional.
The following procedures and processes have been reviewed and will be modified as needed:
• BMP inspections

Response to NOV-2022-LV-0002
Page 3 of 3
• Equipment repairs
• Sump, sewer and wastewater monitoring
• Spill response
We are hopeful consideration will be given to the long-term compliance history maintained by the mill
and corrective actions taken since the subject non-compliance event, as you review this matter.
Please contact Mr. Tracy Willis if we can provide any additional information that may be helpful.
Respectfully,
‘lize
Tracy'Willis
Wastewater Treatment Plant ORC
Canton Mill
[e-mail]
Phone: [phone] / Mobile: [phone]
John McCarthy
General Manager
Canton Mill
[e-mail]
Phone: [phone]