NC0000272_NOV-2022-SS-0007 International Paper response_20220708

Thomas C. Richardson 6400 Poplar Avenue
Remediation Project Manager Memphis, TN 38197
Environment, Health, & Safety
T 901 419 3878
F 901 214 9551
[e-mail]

July 8, 2022

Mr. G. Landon Davidson, P.G.
Regional Supervisor
Water Quality Reginal Operations
North Carolina Department of Environmental Quality
Division of Water Resources
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, North Carolina 28778

RE: Notice of Violation Data Evaluation
NOV-2022-SS-0007 (Incident No.: 202200160)
PactivEvergreen, LLC– Canton Mill (175 Main Street)
Haywood County, North Carolina

Dear Mr. Davidson:

This letter provides supporting information related to International Paper’s (“IP”) notice of violation (“NOV”)
response letter dated May 12, 2022. The April 11, 2022 NOV letter states that on January 28, 2022,
“PactivEvergreen reported the presence of material reported as black liquor visibly present in the streambed
substrate of the Pigeon River in the area of a documented groundwater seep.”

As stated in my E-mail to you of June 28, 2022, “[t]he [Canton] mill has been in the hands of Blue Ridge
for over 2 decades. Without access, and an appropriate investigation, it is impossible to know what
releases have taken place. This is a very old mill and it is likely that releases of black liquor have
occurred. In this regard, we intend to submit additional information which will include groundwater data
that suggests the source of the seep is not only historic, but likely ongoing, which would be the
responsibility of the facility owner/operator. Participation by Blue Ridge in the seep investigation and
access to the mill to determine the integrity of the mill infrastructure is essential.”

Thus, as noted above, PactivEvergreen has been the owner and operator of the mill for more than 20 years.
During that lengthy time period,IP has had no involvement in mill operations and maintenance, and
hasnoinformation on the potential source of the seep observed in January 2022. It must be kept in mind
that this was the first time in 20 years that a seep had been observed. Thus the focus should be on the
operator of the Canton Mill, not the long absent mill owner. Moreover, as certain evidence discussed below
demonstrates, there are indications that there have been black liquor releases over the last 20 years
Therefore PactivEvergreen is an essential participant in any investigation and any potential remediation of
groundwater seeps,

By way of background, IP is the successor by merger to Champion International Corporation
(“Champion”), which on May 14, 1999 sold assets associated with the Canton Mill to Blue Ridge Paper
Products (“Blue Ridge”). PactivEvergreen, which according to your NOV letter reported the presence of
the “black liquor,” is the successor to Blue Ridge. PactivEvergreen and its predecessors have operated
the Canton Mill over the last 20 years during which time IP has had no information regarding the mill
operation and maintenance. The mill is over 100 years old and the infrastructure is aging.

Mr. G. Landon Davidson, P.G.
July 8, 2022
Page 2

In the early 1990’s, black liquor was observed to be seeping into the Pigeon River. Champion conducted
major sewer repairs at the mill in the late 1990’s to prevent leaks of black liquor (and other sewage) to the
soil and groundwater at the mill, which was discharging to the Pigeon River through shallow groundwater
seepage. Much of the sewage in the mill system is extremely caustic and constant maintenance must be
conducted to prevent corrosion of components of the sewer system. IP has no knowledge of any
maintenance performed over the last 20 years, and to our understanding, no seeps have been observed
in the Pigeon River following the Champion sewer repairs until 2022.

Black liquor was reported to be visibly present in the streambed substrate of the Pigeon River. In the
absence of direct evidence of back liquor discharging into the Pigeon River at the observed location, it
remains possible that the black liquor was transported from an upstream location to the location where
the black liquor was observed. The black liquor observed in the Pigeon River was located between wells
RW-5 and RW-6 which are shown on the attached Figure 1.

Monitoring well PZ-7 is one of the most upgradient wells on the site. The attached February 2022
groundwater elevation contour map indicates radial flow from this location toward the Pigeon River
(Figure 2). The color and pH groundwater results from well PZ-7 indicate a potential black liquor release
to the environment in this upgradient area after the 1999 transfer of ownership of the Canton Mill to Blue
Ridge. Trend plots of test results from PZ-7 are attached.

In the three monitoring events performed from 1995 to 2002, the color in platinum-cobalt color units (CU)
ranged from 36 to 2,270 CU. The color result from September 2005 increased to 3,800 CU and in
February 2007 increased further to 100,000 CU. The color at this location after twenty-nine additional
monitoring events remains the highest on the site at 35,000 CU in February 2022.

In the three monitoring events performed from 1995 to 2002, the pH in standard units (SU) in PZ-7
ranged from 6.50 to 8.80 SU. The pH result from September 2005 increased to 11.22 SU and in
February 2007 increased further to 13.34 SU. The pH at this location after twenty-nine additional
monitoring events remains higher than the 1995 to 2002 levels.

Monitoring well PZ-20 is located upgradient from wells RW-5 and RW-6 which are adjacent to the location
of the black liquor visibly present in the Pigeon River. The pH from the 2002 monitoring event was 6.25
SU. The pH from monitoring well PZ-20 has increased since 2002 to the all-time high of 9.66 SU in the
most recent February 2022 event. Trend plots of test results from PZ-20 are attached.

It has been over 20 years since Champion completed the source control work for the seep. Since then,
IP is not aware of any releases to the Pigeon River associated with the Canton Mill that have been
reported. From the trend plots attached, it appears that releases related to increases in color and pH in
groundwater occurred several years after sewer renovations were completed. IP requests that North
Carolina Department of Environmental Quality (NCDEQ) add PactivEvergreen as a party to the NCDEQ
NOV letter so that it can participate and address its contribution to the event that is the basis for the NOV.

If you have any questions or comments, please contact me at [phone].

Sincerely,

Tom Richardson

cc: Steve Ginski/IP
John Cermak/Cermak & Inglin
Mark Hartford/AECOM
Mr. G. Landon Davidson, P.G.
July 8, 2022
Page 3

Collin Day, NC DWM IHSB

Attachment

FIGURES

TREND PLOTS

P
i
g
e
o
n

R
i
v
e
r
Champion Dr.BR-1
BR-2 BR-3
PZ-1
PZ-2
PZ-3
PZ-4
PZ-5
PZ-6
PZ-7
PZ-8
PZ-9
PZ-11
PZ-12
PZ-13
PZ-14R
PZ-16
PZ-17
PZ-18
PZ-20
PZ-21
RW-1
RW-2
RW-3
RW-4
RW-5
RW-6
RW-7
Scale (feet)
0 200 400
Legend
Well LocationRW-4
P
i
g
e
o
n

R
i
v
e
r
Champion Dr.
2571
2
5
7
3
2573
2575
2
5
7
5
2577
2
5
7
7
2
5
7
9
2579
2
5
8
1
BR-1
BR-2 BR-3
PZ-1
PZ-2
PZ-3
PZ-4
PZ-5
PZ-6
PZ-7
PZ-8
PZ-9
PZ-11
PZ-12
PZ-13
PZ-14R
PZ-16
PZ-17
PZ-18
PZ-20
PZ-21
RW-1
RW-2
RW-3
RW-4
RW-5
RW-6
RW-7
2561.33
NM 2573.57
2570.01
NM
2573.36
2577.49
2574.54
2571.62
2579.89
2578.38
2577.75
2577.40
2575.40
2579.53
NM
NM
2574.72
2576.40
2579.47
2582.23
2570.14
2570.03
2569.68
2571.71
2573.31
2573.00
2574.40
Scale (feet)
0 200 400
PZ-3
0
200,000
400,000
600,000
800,000
1,000,000
1,200,000
0
10000
20000
30000
40000
50000
60000
Co
l
o
r
-

P
l
a
t
-
C
o
b

U
n
i
t
s
TD
S

m
g
/
L
PZ-7
TDS Color
4
6
8
10
12
14
16
0
1
2
3
4
5
6
pH

-

S
U
mg
/
L
PZ-7
Chromium Nickel pH
0
50
100
150
200
250
300
350
400
450
500
0
1,000
2,000
3,000
4,000
5,000
6,000
7,000
8,000
9,000
10,000
Co
l
o
r
-

P
l
a
t
-
C
o
b

U
n
i
t
s
TD
S

m
g
/
L
PZ-20
TDS Color
4
5
6
7
8
9
10
11
12
0
0.05
0.1
0.15
0.2
0.25
0.3
pH

-

S
U
mg
/
L
PZ-20
Chromium Nickel pH