NC0000272_Correspondence_20241018

Report to Industrial Waste Permitting Regarding the Evergreen Packaging Wastewater Treatment Plant and 5 day Notification of Permit Limit Exceedance
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October 18, 2024

On Friday, September 27, 2024, our Wastewater Treatment Plant (WTP) experienced severe flooding, affecting most buildings and inundating some areas up to the ceilings. All open-top vessels
were submerged. This flooding rendered critical electrical equipment, including transformers, motors, switchgear, PLC, and DCS systems, inoperable due to water and mud damage. The flooding
also damaged the wastewater treatment plant laboratory and equipment.
Since the incident, we have undertaken extensive cleaning, replacement, and repair efforts across various electrical and mechanical systems within the plant. Most of the essential electrical
and mechanical equipment is now running. We will continue to address the remaining items.
As of the afternoon of October 8, 2024, we resumed the capture and treatment of the Town of Canton’s wastewater. Pactiv Evergreen is actively working on remaining repairs to ensure the
full integrity of both electrical and mechanical systems, including backup systems. We have had some issues with mud accumulated in vessels (clarifiers). Using skid-steer loaders we
have removed mud from one primary clarifier, and it is fully operational. Mud removal continues in the other clarifiers.
We believe the wastewater currently being treated and discharged to the Pigeon River is either in compliance or close to compliance with the limits in our NPDES Permit, as we make the
remaining repairs to the system. As noted previously herein, we await some analytical equipment necessary to confirm compliance.
We note that, prior to the arrival of Hurricane Helene, the Town of Canton was only intermittently and inadequately treating its wastewater with sodium hypochlorite before discharging
to the Pactiv system. The Town did provide sodium hypochlorite to Pactiv which Pactiv used to treat the waste prior to discharging to the river. It is our understanding that now even
the equipment the Town used to inject the sodium hypochlorite is unavailable,
due to the hurricane or otherwise. The Town has not replaced those systems or provided a timeline for doing so. Pre-treatment by the Town of its own wastewater is an important part of
the treatment process. These systems need to be immediately reinstalled and operated properly to ensure reliable operation and treatment of the system as a whole. Under current conditions,
wastewater from the Town of Canton’s collection system constitutes almost the entire flow through the plant.
As we reported this morning, October 17, 2024, the wastewater treatment plant exceeded its daily maximum limit for fecal coliform this week. The fecal count in the Town’s waste was greater
than 600,000 colonies. Because we treated the wastewater with sodium hypochlorite prior to discharge, we were able to reduce the count to 1968. That level was still in excess of the
limit of 400 and was solely caused by the Town’s refusal to pre-treat.
Importantly, no untreated wastewater has been discharged into the receiving stream since we resumed capture on October 8, 2024.

Tracy Willis
Evergreen Packaging WTP ORC
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