NC0000272_Correspondence_20240731 (4)

Baker, Caroline D
From: Boss, Daniel J
Sent: Wednesday, July 31, 2024 12:52 PM
To: Watkins, Tim; Chernikov, Sergei; Grzyb, Julie; Engard, Brett
Cc: Masemore, Sushma; Hennessy, John; Lane, Bill F; Moore, Andrew W; Scott, Michael;
Hunneke, William F; Damato, Victor a; Ulishney, Adam; Rogers, Richard E; Pjetraj,
Michael
Subject: RE: Canton WWT
Follow Up Flag: Follow up
Flag Status: Flagged
Hi Tim,
I sent your questions to Brett Laverty because he's following the groundwater remediation much closer than I am. Here
is the information he provided to me:
----------------------------------------------------------------------------------------------------------------------------------------------------------------
• Will the amount of wastewater generated by the Pactiv remediation impact the 4.9MGD capacity?
Ensafe (Pactiv's consultant) is currently working on the design for the recovery well field. An estimated yield or
discharge rate from the recovery well field has not been proposed at this time. Pactiv has scheduled a technical
meeting to discuss the black liquor remediation next Tuesday August 6. At that meeting, the Division may receive
updates on the recovery well field and remediation design.
Can the wastewater from the Pactiv remediation be treated with the existing WWTP operations/procedures or will
that wastewater stream require additional treatment (new/more chemicals, additional procedures, and/or pre-
treatment)?
Ensafe conducted a comprehensive groundwater site assessment in September/October 2023. Groundwater
samples were collected from 28 new and existing monitoring wells scattered across the site. Water samples were
analyzed for alkalinity, chloride, sulfate, sulfide, metals, volatile organic compounds (VOC), semi -volatile organic
compounds (SVOC), dioxins/furans, and PFAS/PFOA.
Heavy metal concentrations exceeding the 2L groundwater standards at one or more monitoring wells
include antimony, barium, beryllium, boron, chromium, cobalt, iron, lead, manganese, mercury, nickel, vanadium,
and zinc.
VOC and SVOC concentrations exceeding the 2L groundwater standards at one or more monitoring wells
include 2-hexanone, benzene, Trichloroethene, acenaphthene, bis(2-ethylhexyl)phthalate, naphthalene, and
phenol.
VOC and SVOC concentrations detected below the 2L groundwater standards or unregulated compounds at
one or more monitoring wells include 2-butanone (MEK), 4-methyl-2-pentanone (MIBK), acetone, cis-1,2-
dichloroethene, ethylbenzene, xylene, toluene, chloroform, isopropylbenzene, cyclohexane, carbon disulfide,
chlorobenzene, methylcyclohexane, trans-1,2-dichloroethene, styrene, 1,2,4-trichlorobenzene, 1,2-
dichlorobenzene, 1,3-dichlorobenzene, 1,4-dichlorobenzene, 3-methylphenol/4-methylphenol, biphenyl,
carbazole, dibenzofuran, fluoranthene, fluorene, phenanthrene, 2,4-dimethylphenol, 2-methylphenol (o-cresol),
2-methylnaphthalene, phenanthrene, and pyrene.

Unregulated dioxin/furan compounds detected atone or more monitoring wells include 1,2,3,4,6,7,8-HpCDF,
1,2,3,7,8,9-HxCDD, 2,3,4,7,8-PeCDF, 2378-TCDF, OCDD, OCDF, 1,2,3,6,7,8-HxCDF, and 1234678-HpCDD.
PFAS/PFOA compounds detected at one or more monitoring wells include Perfluorobutane sulfonic acid
(PFBS), Perfluorobutanoic acid (PFBA), Perfluoroheptanoic acid (PFHpA), Perfluorohexane sulfonic acid (PFHxS),
Perfluorohexanoic acid (PFHxA), Perfluorooctane sulfonic acid (PFOS), Perfluorooctanoic acid (PFOA),
Perfluoropentanoic acid (PFPeA), Perfluoro(3,5-dioxahexanoic) acid (PF02HxA), Nafion Byproduct 4 (PFESA BP4),
Perfluoro-2-(perfluoromethoxy)propanoic acid (PMPA), and Perfluorononanoic acid (PFNA).
Chloride and sulfate concentrations exceed the 2L groundwater standards at one or more monitoring wells.
pH and color concentrations exceed the 2L groundwater standards at one or more monitoring wells. pH values
range from 5.97 to 12.15 standard units. Color ranges from 5 to 16,000 color units.
Alkalinity concentrations range from 8.2 mg/l to 25,300 mg/l.
Brett Laverty (he/him/his)
Hydrogeologist —Asheville Regional Office
Water Quality Regional Operations
Division of Water Resources
North Carolina Department of Environmental Quality
Office: [phone] 1 Cell: [phone]
email: [e-mail]
---------------------------------------------
Daniel Boss
Assistant Supervisor- Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ- Division of Water Resources
Work Cell: 828-273-3991
[e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
�
, �: D_ E NORTH CAROLINA 7.4m Q
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Watkins, Tim <[e-mail]>
Sent: Wednesday, July 31, 2024 10:27 AM
To: Chernikov, Sergei <[e-mail]>; Boss, Daniel J <[e-mail]>; Grzyb, Julie
<[e-mail]>; Engard, Brett <[e-mail]>

Cc: Masemore, Sushma <[e-mail]>; Hennessy, John <john.hen [e-mail]>; Lane, Bill F
<[e-mail]>; Moore, Andrew W <[e-mail]>; Scott, Michael
<[e-mail]>; Hunneke, William F <[e-mail]>; Damato, Victor a
<[e-mail]>; Ulishney, Adam <[e-mail]>; Rogers, Richard E
<[e-mail]>; Pjetraj, Michael <[e-mail]>
Subject: Canton WWT
Hello everyone,
I participated in a call with DOJ yesterday afternoon regarding settlement negotiations with Pactiv. Providing WWT to
the Town of Canton is a central part of the settlement, thus understanding the estimated value/cost of providing WWT
to the Town is important. Pactiv has stated the cost to operate the WWTP are $400K per month (about $5M annually).
This seems high, but likely reflects Pactiv's historical cost of operation of the WWTP including 24/7 labor costs. A few
months ago, at the request of Canton, I reached out to our DWI colleagues, and they did an analysis comparing WWT
costs with towns of similar size which estimated costs for Canton at about $1M to $1.3M annually, assuming a design
capacity of 1.2MGD (Vic Damato is copied on this message). Daniel and I had a brief discussion about this yesterday
afternoon, and I wanted to follow up with my understanding of a few key issues and also to get your thoughts on a few
questions.
First, please let me know if any of the statements below are not correct and/or inaccurate.
Permit WWT 4.9MGD Capacity
o The draft permit is for 4.9MGD capacity, which is a monthly average.
o The typical MGD in Canton has ranged from 1 to 3 MGD recently, but the higher capacity in the draft
permit allows for daily fluctuations that could include significant rain events.
o A capacity of less than SMGD, allows staffing for the operation of the WWTP to be less than 24/7.
EPA Removal Action/Pactiv Remediation
o The draft permit does not currently account for accepting wastewater associated with the EPA removal
actions for black liquor.
o The permit will require a modification before the WWTP accepts wastewater from the Pactiv
remediation activities.
• Permit Ownership
o DEQwill have to approve a change in ownership of the WWT permit (e.g., if Pactiv transfers ownership
of the WWTP to either the Town or a new site owner).
Second, please let me know your thoughts on the following relating to the Pactiv remediation activities, which I realize
that we may not be able to fully answer at this point in time.
• Will the amount of wastewater generated by the Pactiv remediation impact the 4.9MGD capacity?
• Can the wastewater from the Pactiv remediation be treated with the existing WWTP operations/procedures or
will that wastewater stream require additional treatment (new/more chemicals, additional procedures, and/or
pre-treatment)?
I am happy to talk directly with anyone or set up a quick call, if that is easier than responding via email.
Thank you!
Tim Watkins
Chief Deputy Secretary
North Carolina Department of Environmental Quality
[e-mail]
217 W Jones Street
Raleigh NC 27603

[phone] (Cell)
[phone] (Office)
M1lC�¢IHCxia(kJNA ��D..
6epy7rnpnl �1 En4lrgnmpn4l Q�Ii7Y
"Providing science -based environmental stewardship for the health and prosperity of all North Carolinians"
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.