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Home My WebLink AboutNC0000272_Application_20240220BLACK LIQUOR INTERIM REMOVAL ACTION WORK PLAN PACTIV EVERGREEN CANTON MILL CANTON, NORTH CAROLINA EnSafe Project Number 0888834351 Prepared for: Pactiv Evergreen 175 Main Street Canton, North Carolina 28716 January 22, 2024 12402 N. 561h Street Tampa, Florida 33617 813-930-0669 1 800-588-7962 www.ensafe.com ENSAFE BLACK LIQUOR INTERIM REMOVAL ACTION Prepared by: -Z2�L�t Bernie Lauctes, PE Senior Project Manager/Engineer 12402 N. 561" Street Tampa, Florida 33617 813-930-0669 1 800-588-7962 www.ensafe.com &VSAFT WORK PLAN PACTIV EVERGREEN CANTON MILL CANTON, NORTH CAROLINA EnSafe Project Number 0888834351 Prepared for: pactiv evergreen Pactiv Evergreen 175 Main Street Canton, North Carolina 28716 Reviewed by: r Bridget S. orello, PE Principal January 22, 2024 TABLE OF CONTENTS 1.0 INTRODUCTION............................................................................................................1 1.1 Site Description..................................................................................................2 1.2 Regulatory History..............................................................................................3 2.0 PROJECT OBJECTIVES...................................................................................................8 2.1 Applicable or Relevant and Appropriate Requirements...........................................9 2.2 Community Relations........................................................................................10 3.0 CONCEPTUAL SITE MODEL AND BLACK LIQUOR AREAS OF CONCERN ............................. 12 3.1 Regional Geology and Site Hydrogeology............................................................ 12 3.2 Black Liquor Chemistry...................................................................................... 13 3.3 Conceptual Site Model....................................................................................... 14 3.4 Black Liquor Areas of Concern........................................................................... 15 3.5 Potential Receptors........................................................................................... 16 4.0 TIME CRITICAL REMOVAL ACTION PLAN...................................................................... 18 4.1 Evaluation of Removal Action Options................................................................. 18 4.2 Preferred Black Liquor Interim Removal Action .................................................... 19 4.2.1 Conceptual Design.................................................................................19 4.2.2 Data Gaps and WWTP Evaluation............................................................ 20 4.2.3 Permitting.............................................................................................22 4.2.4 Operation, Maintenance and Monitoring...................................................22 5.0 INTERIM REMOVAL ACTION IMPLEMENTATION............................................................ 23 5.1 Final Design and Work Plan Addendum............................................................... 23 5.2 Proposed Schedule........................................................................................... 23 6.0 REFERENCES.............................................................................................................. 25 TABLES Table 1 Timeline and Summary of Investigative and Remedial Activities by Other Parties .....4 Table 2 Regulatory Data Gap Inquiries and Relevant Action Items......................................6 Table 3 Lithology Description........................................................................................12 Table 4 Data Gaps Pre -IRA Design and Implementation................................................... 21 Table 5 Proposed Black Liquor IRA Implementation Schedule ........................................... 23 FIGURES Figure 1 Site Location Map Figure 2 Site Map Figure 3 Conceptualized Cross Section Along Pigeon River Figure 4 Black Liquor Conceptual Site Model Figure 5 Groundwater Potentiometric Map November 2023 Figure 6 NC2L Exceedances for Metals in Groundwater Figure 7 NC21- Exceedances for VOCs in Groundwater Figure 8 NC2L Exceedances for SVOCs in Groundwater Figure 9 NC21- Exceedances for Anions in Groundwater Figure 10 Groundwater pH Isocontour Map Figure 11 Groundwater Color Isocontour Map Figure 12 NC2B Exceedances in Surface Water and Seeps Figure 13 Screening of Retained Black Liquor IRA Options Figure 14 Conceptual Layout of Preferred Black Liquor IRA Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill MSA � Canton, North Carolina January 2024 INTRODUCTION This Black Liquor Interim Removal Action (BL IRA) Work Plan (Work Plan) was developed on behalf of Blue Ridge Paper Products LLC, d/b/a Evergreen Packaging (Pactiv Evergreen/ PTVE) in accordance with the Administrative Settlement Agreement and Order on Consent (AOC) for Removal Action Tasks and Deliverables (CERCLA-04-2024-7000, Effective Date: October 24, 2023) executed by the United States Environmental Protection Agency (U.S. EPA) and PTVE. This Work Plan outlines PTVE's approach to address the Time Critical Removal Action (TCRA) required per the AOC for black liquor in groundwater at the Canton Paper Mill (Mill/Site) located in Canton, North Carolina. This Work Plan supplements prior work plans and actions approved by U.S. EPA regarding assessment and remedial activities voluntarily undertaken by PTVE prior to execution of the AOC, as listed in Section 6 — References. The following prior submittals directly relate to the planned BL IRA activities outlined in this Work Plan: • Sampling and Analyses Plan (SAP) (EnSafe, April 2023) • Quality Assurance Project Plan (QAPP) (EnSafe, April 2023) • Health and Safety Plan (HASP) (EnSafe, November 2023) • Interim Work Plan Addendum — Comprehensive Sampling and Assessment of Black Liquor Impacts to Groundwater (EnSafe, June 2023) • Sampling and Evaluation Work Plan for Surface Water, Seep, and Sediment Sampling (TRC, October 2022) • Campground Branch Sampling Technical Memorandum (for Surface Water Sampling at two locations along Campground Branch) (EnSafe, September 2023) • Interim Work Plan Addendum Comprehensive Sampling and Assessment of Black Liquor Impacts to Groundwater (EnSafe, June 2023) • Implementation of Interim Work Plan Addendum to Address Vertical Delineation Data Gaps via Limited Subsurface Investigations (EnSafe, December 2023) Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill MSA � Canton, North Carolina January 2024 This Work Plan is organized as follows: • Section 1: Provides the Introduction, Site Description and Regulatory History • Section 2: Describes Project Objectives • Section 3: Provides the Conceptual Site Model and Black Liquor Areas of Concern • Section 4: Details the TCRA Plan • Section 5: Outlines the TCRA Monitoring and Reporting Plan • Section 6: Identifies References cited in this Work Plan Figures and supporting appendices are included at the conclusion of the text; tables are embedded with text. Activities described herein will be subject to review and approval by the lead agency for the TCRA, U.S. EPA, in consultation with the North Carolina Department of Environmental Quality (NCDEQ) Division of Waste Management's Superfund Section, Inactive Hazardous Sites Branch (IHSB) guidance, and in general accordance with the U.S. EPA Region 4, Laboratory Services and Applied Sciences Division (LSASD) (available at https://www.epa.gov/quality/quality-system-and- technical-procedures-Isasd-field-branches). 1.1 Site Description A paper mill operated at the location of this Site, 175 Main Street, Canton, Haywood County, North Carolina, from 1908 through June 2023. The location was likely originally selected due to its proximity to large tracts of timberland, an abundant water supply from the Pigeon River, and access to rail lines. Not long after production began, the Canton Mill was one of the largest paper -producing facilities in the world. The Site is bisected by the Pigeon River and surrounded by the town of Canton, North Carolina, as depicted in Figure 1. In June 2023, PTVE ceased production at the facility and began decommissioning activities. The Site occupies approximately 200 acres of Pigeon River bottomland situated within the city limits of Canton in Haywood County, North Carolina, and is bisected by the Pigeon River as depicted in Figure 1. The Pigeon River drains the high mountains to the south and flows north through the property. Former paper production infrastructure (i.e., former Mill operations) took place on the river's east bank, and the area along the river's west bank was used to store wood chips and is the location of the Wastewater Treatment Plant (WWTP) that also serves the Town of Canton. The Site Map is 2 ENSA lE Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill Canton, North Carolina January 2024 provided as Figure 2. PTVE has an agreement with the Town of Canton to operate the WWTP through March 2025, in accordance with a National Pollutant Discharge Elimination System (NPDES) Permit, NC0000272, issued by the State of North Carolina, effective May 1, 2022. Drinking water for the Town of Canton is supplied by the Canton Water and Sewer Department and is sourced from the Pigeon River via an intake located approximately 1 mile upstream of the Site. Pursuant to correspondence with county officials, there are no known water supply wells within a 0.5-mile radius of the Site. ..2 Regulatory History A release of black liquor into the Pigeon River was reported to the North Carolina Department of Environment and Natural Resources (NCDENR), now NCDEQ, in 1994 by Champion Paper (Champion) who owned the Mill at that time. A series of subsequent Comprehensive Site Assessments (CSAs) was conducted by Champion Paper to assess impacts to groundwater and included installation of the existing monitoring and recovery well network. Initial efforts to contain black liquor and mitigate the seep included a pump and treat (P&T) system that proved to be ineffective. In 1999, Champion, who retained liability for the black liquor release, sold the Mill to Carolina Paper which later became Blue Ridge Paper Products. In 2000, Champion Paper was acquired by International Paper (IP). From 2007 to present, IP conducted semi-annual groundwater monitoring events targeting a limited analyte suite (AECOM various dates). In 2007, Evergreen Packaging (now PTVE) purchased the Canton Mill from Blue Ridge Paper Products, and operated the Mill from 2007 through June 2023. A new observation of the original black liquor seep was reported to NCDEQ on January 28, 2022. NCDEQ Division of Water Resources (DWR) issued a Notice of Violation (NOV) (dated April 11, 2022) to IP requiring IP to sample surface waters and sediments of the Pigeon River proximal to the black liquor seep, as well as to provide a summary of historical efforts to treat or contain impacted groundwater. The NCDEQ IHSB followed up with the issuance of a Notice of Regulatory Requirements (NORR) to IP (dated April 22, 2022), mandating a similar suite of assessment actions. NCDEQ DWR subsequently issued a NOV to PTVE on October 20, 2022, which mirrored the requirements of the NOV sent to IP in April 2022. In consultation with NCDEQ DWR prior to receiving the NOV, PTVE submitted a sampling plan on October 17, 2022, which was approved the following day by NCDEQ DWR, and outlined both riverbank reconnaissance and sampling of surface water, seep(s), and sediments (i.e., requirements 1 and 2 of the October 2022 NOV). PTVE implemented this work during the first quarter of 2023, and subsequent assessment of groundwater and surface water commenced in the third quarter of 2023 pursuant to the Interim Work Plan Addendum Comprehensive Sampling and Assessment of Black Liquor Impacts to Groundwater (EnSafe, June 2023). Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill MSA � Canton, North Carolina January 2024 The U.S. EPA began inquires at the Site on or around March 24, 2023, and published a Removal Site Evaluation (RSE) Pollution Report (POLREP) on July 6, 2023, regarding multiple observations of seeps of No. 6 Fuel Oil' and black liquor emanating from the Site to the Pigeon River. U.S. EPA published an Enforcement Action Memorandum (signed October 18, 2023) requesting an Enforcement -Lead TCRA at the Site, and U.S. EPA and PTVE then executed the AOC for the TCRA effective October 24, 2023. Prior to U.S. EPA's issuance of the RSE/POLREP, and in consultation with U.S. EPA and NCDEQ, PTVE voluntarily began to assess potential impacts to groundwater associated with historic releases of black liquor at the Site without the assistance of other potentially responsible parties. PTVE ceased all operations at the Mill in June 2023, and has since completed removal of all stored black liquor, interim removal action for No. 6 Fuel Oil pursuant to a separate work plan approved by U.S. EPA, and general cleanup of the Site. This Work Plan focuses on the black liquor interim removal action and associated activities per the AOC. Table 1 provides a summary of the investigative actions and remedial efforts conducted previously by other potentially responsible parties related to black liquor impacts at this Site, as documented in publicly available records. Table 1 Timeline and Summa of Investigative and Remedial Activities by Other Parties Key Site Document Summary of Assessment and Remedial Activities Site Assessment Plan (Roy F. Listed COPCs Weston Inc. December 1994 CSA (Roy F. Weston Inc. June 1995) Assessment Site Hydrogeology — surficial aquifer — MW network installed Lateral delineation of impacts Impacts to GW likely related to past activities Possible source areas SW monitoring Remedial RW-1 installed and operating beginning November 1994 RW-1 issues with submersible pump — pneumatic pump installed February 1995 RWs 2 thru 5 installed but not yet operational Champion to investigate infrastructure sewers sums and Ll-drains ' A Work Plan for assessment of the fuel oil release was separately submitted and approved by U.S. EPA under the AOC. 4 Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill �SA � Canton, North Carolina January 2024 Table 1 Timeline and Summa of Investigative and Remedial Activities by Other Parties Key Site Document Summary of Assessment and Remedial Activities CSA Addendum (Roy F. Weston Inc.) Assessment February 1996) Confirm Site Hydrogeology of surficial aquifer Confirm Lateral delineation of impacts to the south - additional MWs Assess Impacts to Bedrock Aquifer- installation of cased wells into bedrock Continued SW monitoring Remedial RW-1 installed and operating beginning November 1994 RW-6 & RW-7 installed CSA Phase III (Roy F. Weston Inc. Assessment July 1997) Confirm Site Hydrogeology of surficial aquifer Confirm Lateral delineation of impacts — additional MWs Confirm Minimal Impacts to Bedrock Aquifer Remedial Improvements to U-drains & sewers Entire RW network brought online July 1996 & treating 17,300 gallons of GW daily Scaling (calcium carbonate & perhaps silica) is a constant problem; RWs rehabilitated in April and May 1997 Monthly maintenance of pumps and well screens initiated Forthcoming CAP Agreement between Champion Remedial International (then owned by IP) and Blue Ridge Paper Products (November Sump and trench drain rehabilitation in Recovery Boiler 10 and 11 area, black liquor 2000 recovery building, digester area and Pine Mill Courtyard area Agenda from a meeting with IP and Agenda calls for IP's consultant to present information regarding in situ bench and pilot NC Agency Representatives at studies, groundwater modeling, and data trends Canton Mill (February 2003) Letter to NCDENR ARO (IP March 2006) Documented: • Severe scaling in wells and piping, resulting in reduced performance • Damage to RW pneumatic pumps and compressors by Pigeon River flooding • Recovery system ofFline since 2004 flood damage Infrastructure improvements to Mill piping and drain systems made in 2001 have mitigated impact to groundwater Bench and pilot scale findings summarized: • Bench scale studies for pH neutralization studies documented generation of a gelatinous precipitate, which could foul the aquifer. pH reduction was deemed not feasible. • Bench scale studies indicated color reduction may be feasible with strong oxidants. Two in -situ pilot studies were completed (the first with ozone in 2003, the second with sodium persulfate in 2005). Ozone treatment was unsuccessful; some success with sodium persulfate was noted, but implementation was noted to be limited due to injection methodology (DPT and need for direct contact) and infrastructure present onsite. Letter to NCDENR ARO SAP (Earth Tech SAP to NCDENR for review recommending plan to optimize long-term monitoring (limited November 2006) analyte list Letter from NCDENR ARO to SAP approval from NCDENR Champion/IP December 2006 NCDENR from IHSB to Champion/IP NCDENR realignment notification and REC Voluntary Cleanup Checklist received from (September 2007 IHSB Letter to NCDENR (IP October 2007) Voluntary Cleanup Checklist submitted to the IHSB. Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill �SA � Canton, North Carolina January 2024 Table 1 Timeline and Summay of Investigative and Remedial Activities by Other Parties Key Site Document Summary of Assessment and Remedial Activities Letter to NCDENR (IP May 2008) IP declines to enter REC program, and provides summary of response actions to date. Indicates that response actions (site monitoring) will continue in compliance with November 2006 SAP, noting that additional remedial actions will be planned as warranted. Limited GWS (]an 2023) Champion (IP) conducts GWS Event specific to RW-5 & RW- 6 for an expanded analyte suite 2008 to present - Semi-annual GW Champion (IP) continues Semi -Annual GWS Events for a limited analyte suite monitoring reports to IHSB Notes: More detailed correspondence (e.g., Underground Injection Control Permits, follow-up reports, and correspondence) have not been cited due to the volume of project records. COPCs = Constituents of Potential Concern CSA = Comprehensive Site Assessment SAP = Sampling and Analysis Plan MW = Monitoring well GW = Groundwater SW = Surface Water RW = Recovery Well IP = International Paper (Champion) NC = North Carolina NCDENR = North Carolina Department of Environment and Natural Resources now Department of Environmental Quality ARO = Asheville Regional Office of North Carolina Department of Environment and Natural Resources DPT = Direct Push Technology SAP = Sampling and Analysis Plan IHSB = Inactive Hazardous Sites Branch of NCDEQ REC = Registered Environmental Consultant — voluntary cleanup program GWS = Groundwater Sampling Table 2 below provides an overview of regulatory inquiries regarding data gaps and associated assessment activities completed or being addressed by PTVE pursuant to the NOV and AOC. Table 2 Regulatory Data Gap Inquiries and Relevant Action Items Data Gap Inquiry Action Item Identify contaminants of potential concern (COPCs) in Identified COPCs based on samples collected from groundwater related to historical black liquor production lines at the Site prior to Mill shut down in June use/release at the Mill 2023, and historic data derived from the CSA data sets associated with the 1994 CSA Work Plan. Summary of black composition and COPCs Consensus was outlined in the Black Li or Position Paper EnSafe, May 2023 Ensure adequate laboratory detection limits achievable "Trial Run" fieldwork, groundwater sampling event given complex sample matrix conducted June 2023 as documented in the Limited Groundwater Monitoring Report June 2023 Trial Run Event EnSafe, August 2023 Condition of existing monitoring wells network and Well Inventory Survey, Redevelopment and Rehabilitation, ability to obtain samples representative of current August 2023 aquifer conditions M. Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill MSA � Canton, North Carolina January 2024 Table 2 Regulatory Data Gap Inquiries and Relevant Action Items Data Gap Inquiry Action Item Accuracy of existing well location and elevation surveys Professional Survey of all wells conducted in September 2023 Comprehensive sitewide sampling completed in September/October 2023 per the approved Interim Work Plan Addendum Comprehensive Sampling and Assessment Comprehensive Baseline Data Set for Groundwater and of Black Liquor Impacts to Groundwater (EnSafe, June Surface Water 2023) Ongoing groundwater monitoring is performed by IP semi- annually in response to historical NOV and reported NCDEQ IHSB AECOM August 2023 is most recent report) Surface water and seep sampling was completed in September 2023 under low river flow/level conditions per the approved Interim Work Plan Addendum Comprehensive Sampling and Assessment of Black Liquor Impacts to Pigeon River water quality for various seasonal river Groundwater (EnSafe, June 2023) conditions Surface water sampling under high river flow/level conditions was completed by others in January 2023 (TRC, Jan 2023) along with toxicity sampling/analyses and sediment sampling in response to the NOV/NORR issued to IP in 2022 Camp Branch surface water sampling event and evaluation Campground Branch (Camp Branch) water quality of historical sewer installation in place of native feature; sampled upstream and outfall of Camp Branch stormwater sewer The Mill ceased operations in June 2023, and all stored Status of potential black liquor sources within the Site black liquor was removed from the Site as part of the decommissioning process Data gap filling to commence in January 2024 per the Vertical delineation of black liquor in the subsurface and approved Interim Work Plan Addendum to Address Vertical confirmation of Site lithology/hydrogeology Delineation Data Gaps via Limited Subsurface Investigations EnSafe December 2023 Notes: CSA = Comprehensive Site Assessment IP = International Paper (Champion) TRC = TRC Environmental Corporation NOV = Notice of Violation NCDEQ = North Carolina Department of Environmental Quality IHSB = Inactive Hazardous Sites Branch of NCDEQ NORR = Notice of Regulatory Requirements 7 Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill MSA � Canton, North Carolina January 2024 2.0 PROJECT OBJECTIVES As noted in Section 1.2, this Work Plan focuses on the U.S. EPA -lead TCRA for black liquor in groundwater discharging from the Site to the Pigeon River. The AOC and Enforcement Action Memorandum dictate the work to be performed at the Site by PTVE pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 U.S.C. §§ 9601-9675. The Site is not listed on the National Priorities List (NPL) of Superfund Sites, but all work pursuant to the AOC is being overseen by and is subject to approval of U.S. EPA's On -Scene Coordinator (OSC), in consultation with NCDEQ and other stakeholders, as applicable. The U.S. EPA's Enforcement Action Memorandum states, among other things that: 1) "The discharge of black liquor to the Pigeon River is a threat to public health and the environment." 2) "The Pigeon River is used for recreational purposes such as fishing and whitewater rafting and thus the black liquor seep could expose recreating populations." 3) "The black liquor contamination could be a result of one spill, several spills, poor housekeeping over a century of operation (legacy contaminant), or a combination of all of the above." This Work Plan satisfies Section 16.b of the AOC, which requires a "Black Liquor Removal Work Plan" within 90 days after the AOC effective date. Pursuant to the AOC and Enforcement Action Memorandum, this Work Plan presents the objectives and approach for the black liquor IRA which include: • Document the TCRA area of concern for black liquor in groundwater; • Summarize historical black liquor potential sources areas, assessment activities, and remedial measures; • Describe the community impact mitigation activities to be performed during the Site activities, working with U.S. EPA's OSC and Community Involvement Coordinator (CIC), as applicable; ME Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill Canton, North Carolina January 2024 • Identify data gaps and provide a plan to fill those gaps to supplement the IRA design basis; • Present an evaluation of interim removal action options to mitigate black liquor releases from groundwater to the Pigeon River; • Prepare a conceptual design for the selected black liquor IRA in a work plan for U.S. EPA review and approval; and • Provide a schedule for implementing: The approved Work Plan and prepare a Work Plan Addendum outlining the final IRA design once data gaps are filled and to address regulatory comments on the initial Work Plan, if any; and Implementing the black liquor IRA once the Work Plan Addendum is approved by U.S. EPA; and Submitting a final report summarizing black liquor IRA activities, as -built details, performance monitoring, and operation and maintenance. As noted in Section 1, PTVE has already implemented many aspects of the black liquor assessment and IRA design basis activities pursuant to prior submittals and work plans approved by U.S. EPA. PTVE is committed to meeting the objectives of the TCRA as required by the AOC, and will continue to work cooperatively with U.S. EPA, NCDEQ and other stakeholders. Applicable or Relevant and Appropriate Requirements Per Section V.D. of the AOC, Applicable or Relevant and Appropriate Requirements (ARARs) for the black liquor TCRA generally include: • NCDEQ Groundwater Quality Standards (GWQSs), Title 15A, North Carolina Administrative Code, Chapter 02, Subchapter L, Section .0202, dated April 2022 (hereafter NC2L or GWQS) • NCDEQ Surface Water Quality Standards (SWQSs) for Class C waterways, Title 15A, North Carolina Administrative Code, Subchapter 0213, Section .0211, dated September 2022 (hereafter NC213 or SWQS). 0 Applicable federal and state waste disposal requirements for any materials disposed offsite. Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill Canton, North Carolina January 2024 Other ARARs may be identified pending further assessment and final IRA design details, in consultation with U.S. EPA and NCDEQ. Community Relations PTVE will work with U.S. EPA's OSC and CIC to ensure the Canton community is aware of the TCRA for the Site and PTVE's activities to protect the public health, welfare, and environment. The Mill's history is synonymous with the Town of Canton's history, having operated from 1908 through June 2023. Many community residents were employed at the Mill or provided support services to Mill operations and staff. Although situated within the Canton City limits, the area surrounding the Mill has always been industrial/commercial focused. The nearest residential structure is over 1,000 feet from the black liquor area of concern. All of the black liquor IRA activities outlined in this Work Plan will take place on property owned by PTVE and therefore will not adversely impact the local residents, visitors, commuters, or businesses. PTVE is committed to ensuring site work does not pose any issues of concern for the community. The successful implementation of the Fuel Oil IRA work and Mill decommissioning work from June 2023 to date, without incident or concern from the community, demonstrates PTVE's focus on safety and protection of the general public. The U.S. EPA OSC or his designee will be the lead spokesperson to inform the community of TCRA activities, and will establish an Administrative Record for the TCRA, as applicable. Pursuant to Section 16.b of the AOC, PTVE will implement safety and other measures to ensure the following during implementation of this Work Plan: • Communicate regularly with the community via fact sheets, signage, community meetings, social media, local media, and other means as applicable; subject to coordination with the U.S. EPA OSC and CIC. • Follow appropriate local, state, and federal safety guidelines as well as PTVE's corporate safety protocols in accordance with the Site HASP, and update the HASP as applicable in the event new hazards or safety practices are identified during the work. M Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill �SA � Canton, North Carolina January 2024 • Implement best management practices (BMPs) to reduce impacts from IRA activities such as air emissions, dust, odor, traffic, and noise. PTVE will implement appropriate measures to alleviate the potential for exposure to Site COCs for the general public, nearby residents, pets, remaining Mill staff, and wildlife. • Consider and implement measures to avoid disruption, temporary relocation, and negative economic effects to residential areas, schools, playgrounds, healthcare facilities, or recreational public areas frequented by community members. • Conduct monitoring during IRA implementation as necessary to ensure public health, such as ambient air quality, noise, groundwater quality, and surface water quality, if applicable and required by U.S. EPA. Communicate results of any such monitoring to the community in a timely manner. • Adjust or implement additional measures or BMPs during the IRA activities as necessary to address community concerns and/or further reduce potentially negative impacts to the community. 11 Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill MSA � Canton, North Carolina January 2024 3.0 CONCEPTUAL SITE MODEL AND BLACK LIQUOR AREAS OF CONCERN Historic releases of black liquor at the Canton Mill have impacted the Site's groundwater quality. Assessment and remedial activities performed by PTVE and others have been reviewed and serve as the basis for the updated Conceptual Site Model (CSM) and black liquor areas of concern to be addressed per the TCRA AOC. The following sections provide a summary of regional and Site geology and hydrogeology, black liquor chemistry, CSM, black liquor areas of concern, and potential receptors. 3.1 Regional Geology and Site Hydrogeology The Site is located in the Blue Ridge Physiographic Province of western North Carolina. According to online geologic mapping tools (interactive 1985 State of North Carolina Geologic Map), bedrock in the area consists of felsic rich biotite gneiss of Middle Proterozoic age. A more recent study by Carl E. Merschat and Leonard S. Wiener (North Carolina Geological Survey Bulletin 90, Geology of the Sandymush and Canton Quadrangles, North Carolina, 1988) refers to the rock sequence as either the Richard Russel (Biotite Gneiss) Formation or Earlies Gap Biotite Gneiss. Based on proxy data collected by others during earlier investigations at the Site, the soils overlaying the gneissic bedrock can be segregated into four distinct hydrogeologic horizons, as depicted and summarized in Table 3 below. SAPROLITE BEDROCK Depiction of Site Lithology Table 3 Lithology Description Litholo is Horizon Thickness and Description Surficial Fill Material 05-16 feet thick • Undifferentiated gravel, sand, silt, & clay -size fill, interspersed with layers of or anic material woodchi s • 6-20 feet thick Alluvium & Colluvium 0 Overbank river deposits and upslope material • Silty sand to sandy silt w/mica & gravel • 5-10 feet thick Cobble Layer 0 River channel deposits • Poorly graded sand ravel & cobble -sized sediments • 5-40 feet thick Saprolite (Regolith) In -situ weathered bedrock comprised primarily of clays and silts. • Minor sand and gravel fractions present within clay and silt dominated matrix. • Transition to competent/fractured bedrock can be abrupt. Biotite Gneiss Crystalline Bedrock 12 Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill MSA � Canton, North Carolina January 2024 Figure 3 illustrates the conceptualized cross section of the Site along the Pigeon River. Data from the existing well network indicate: • Depth to groundwater ranges 4.7 to 10.5 feet below ground surface (bgs); groundwater elevation across the Site ranges from around 2,582 feet above sea level (amsl) at PZ-21 to 2567 feet amsl at RW-1. • Groundwater flows in the general direction of the Pigeon River at an estimated rate of 7.7 feet per year based on a conductivity value of 0.3 feet per day and a gradient of 0.024 foot/foot (Weston 1995). • Assuming the 10-foot-thick cobble horizon is the most transmissive zone along the riverbank, approximately 560 gallons of groundwater are discharged into the Pigeon River daily. • Estimates for the average river flow range from 255 million gallons per day in the spring to 81 million gallons per day in the late summer months (USGS 034556991). 3.2 Black Liquor Chemistry Black liquor is the byproduct of the kraft process that separates cellulose from lignin and other compounds. Black liquor is an aqueous solution of lignin residues, hemicellulose, and inorganic chemicals comprised of 15% solids by weight, 85% water. The solids are comprised of a complex mixture of inorganic and organic constituents, 35-45% lignin. Lignin is insoluble at "normal" pH ranges and soluble at pH greater than 8.9. Based on actual sample testing at this Site, the specific gravity of observed black liquor is about 1.08. The black liquor impacting groundwater at this Site is likely weak black liquor resulting from a process step that separated the solids for use in boilers. Due to its chemical complexity, there is no single approved analytical methodology available to characterize the composition of spent pulping (black) liquor. EnSafe has identified laboratory methods most suitable for analyzing groundwater impacted with black liquor, but matrix interference continues to complicate analyses. During recent Mill operations, black liquor was concentrated before being burned in recovery boilers. Before the advent of the recovery boiler in the 1930s, spent black liquor may have been routed to a nearby waterway or discharged onsite (Academic Press 1993). Prior to its closing, black liquor and other spent process water at the Mill would have been conveyed through various subsurface piping and drains. As part of the decommissioning process of the Mill, all black liquor was removed from bulk storage vessels and transported offsite. Residual black liquor and any associated sludges were cleaned from storage areas and disposed of properly. 13 Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill MSA � Canton, North Carolina January 2024 3.3 Conceptual Site Model Based on available data the current CSM is depicted in Figure 4 and is as follows: • Lithology/Hydrogeology The soils overlaying the gneissic bedrock at the Site can be segregated into four distinct hydrogeologic horizons: surficial fill, alluvium/colluvium, cobble, and saprolite. The black liquor -impacted groundwater in the surficial aquifer flows at an estimated rate of 7.7 feet per year downgradient towards the Pigeon River. The volume of impacted groundwater discharging into the river is likely variable and dependent on head pressure differences between Site groundwater and river levels. A conservative estimate of groundwater seepage to the river is around 560 gallons per day through a highly transmissive cobble horizon. Depth to groundwater ranges 4.7 to 10.4 feet bgs. Figure 5 depicts the groundwater potentiometric surface based on data collected in November 2023. • Groundwater Impacts Contaminants of concern (COCs) in groundwater at levels above NCDEQ NC2L GWQSs include: o Color, pH, chloride, sulfate o Metals total and dissolved o Volatile organic compounds (VOCs): 2-hexanone, benzene, trichloroethene o Semi -volatile organic compounds (SVOCs): acenaphthene, bis(2-ethylhexyl)phthalate, naphthalene, phenol. Polyaromatic hydrocarbons (PAHs) which could stem from former Fuel Oil No. 6 releases at the Site are not COCs, and there does not appear to be any commingling of black liquor COCs and Fuel Oil components. 14 Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill MSA � Canton, North Carolina January 2024 COCs in groundwater are primarily within the shallow surficial aquifer, i.e., alluvium and cobble layers, at the Site. There is no evidence of groundwater communication between the surficial aquifer and bedrock aquifer. Figures 6 through 9 depict the exceedances of GWQSs. Figures 10 and 11 depict the iso-concentration contours for key COCs: pH, color. • Surface Water Impacts Sampling of surface water adjacent to the Site indicates surface water is not impacted at levels above NCDEQ NC213 SWQSs. Sampling of groundwater seeps to surface water; however, indicates exceedances of SWQSs for pH, copper, nickel, zinc, and lead; and results dissipate within feet of the seeps. Toxicity testing data (for water flea and minnows) do not indicate any adverse ecological impacts to the Pigeon River based on comparison of surface water quality data and sediment sample data to U.S. EPA Region 4 ecological screening values. Figure 12 depicts the exceedances of SWQSs. The CSM will continue to evolve as data gaps are resolved. 3.4 Black Liquor Areas of Concern The objective of the TCRA AOC is to mitigate the flux of black liquor -impacted groundwater to the Pigeon River. The primary area of concern includes the transmissive geologic horizon(s) facilitating groundwater discharge to the Pigeon River in the area generally along the east bank from the pipe bridge north to the railroad spur trestle, roughly 1,200 feet of riverbank. This area of concern is depicted on Figure 4. 15 Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill MSA � Canton, North Carolina January 2024 The black liquor area of concern is nearly inaccessible due to a substantial protection levee that parallels the river and a series of railroad tracks situated at the landward toe of the levee between the river and the Mill. A number of other potential black liquor source areas were identified and discussed as part of the Potential Source Areas (Weston 1995) • Former Rectifier Building • Former Hooker Cell Building • Former Woodyard and Caustic Evaporators • Caustic Storage and Liquor Tanks • Ash -Handling System • Digesters • Recovery Boilers original CSA (Weston 1995) were associated with the . Lime Kilns pulping process and are situated in the north central I • U-Drains and Sewers portion of the Site. The sewer system underlying the Site was also considered to be a potential source of black liquor to groundwater Many historical sewers were abandoned/sealed during various improvement projects and the current sewers were inspected as recently as 2020. Since the Mill closure in June 2023, and shut-off of water service to the Mill in November 2023, the flow in the Site sewer system to the WWTP has reduced from about 26 million gallons per day to only storm water runoff. Any assessment and remedial activities associated with these other potential areas of concern will be performed after implementation of this Work Plan, as applicable. Given the closure of the Mill in June 2023, there are no active continuing sources of black liquor to groundwater. 3.5 Potential Receptors Receptor surveys were conducted in the mid-1990s as part of Champion's CSA investigations noted the Pigeon River as a primary receptor. A follow-up receptor survey and consultation with Haywood County was conducted in 2023 to confirm prior findings regarding potential receptors for black liquor in Site groundwater. The findings of the original and recent receptor surveys and recent site -wide assessment of groundwater and surface water confirm that potential receptors are limited and the legacy releases of black liquor from the Site to the Pigeon River pose minimal current risk to potential receptors based on the following: • Groundwater beneath the Site is not a potable water source. • No private potable water wells are located within a 0.5-mile radius of the Site. • No industrial production wells are located at or in the vicinity of the Site. • Potable and industrial water is supplied to the area surrounding the Mill by the Canton Municipal Water Service. 16 Black Liquor Interim Removal Action Work Plan _ Pactiv Evergreen Canton Mill - Canton, North Carolina January 2024 • The only surface water bodies in proximity of the Site are the Pigeon River and the Campground Branch which was partially converted from a swale to a 72-inch concrete storm sewer as it crosses the eastern portion of the Site. Groundwater flows from the Site toward the Pigeon River. Stormwater collected from the Site flows either to the Campground Branch/storm sewer and discharges to the Pigeon River, or to the WWTP via other Site storm sewers. • Surface water data and toxicity testing demonstrate that the black liquor seeps have not degraded the Pigeon River water quality, and results meet NCDEQ's NC2B SWQSs. The black liquor IRA described in this Work Plan is intended to meet the objectives of the TCRA AOC and protect the public health, welfare, and environment. Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill MSA � Canton, North Carolina January 2024 4.0 TIME CRITICAL REMOVAL ACTION PLAN The basic assumptions for IRA options development and screening included: 1) The Remedial Acton Objective (RAO) for the TCRA is to control discharge of impacted groundwater into the Pigeon River to reduce/eliminate black liquor seeps. 2) Groundwater impacted with black liquor is not commingled with other contaminants related to the Fuel Oil IRA. 3) Long-term remedial support measures will continue regardless of the IRA option selected, including: groundwater, surface water, and seep monitoring, seep boom management and other best management practices (BMPs) as applicable. 4) The black liquor IRA will be implemented in a phased approach to prioritize hydraulic control along the Mill side of the Pigeon River levee to meet the RAO in the interim as other long- term remedies are evaluated for this area of concern and others at the Site. 5) The long-term or final remedy may use an in -situ groundwater remedy at the Pigeon River and/or interior Site source areas. Hydraulic control may be required during transition to a long-term remedy and possibly as part of the long-term remedy. 4.1 Evaluation of Removal Action Options The following IRA options were evaluated based on effectiveness, implementability, pros/cons, and costs: • Hydraulic Control/Pump and Treat (P&T) (using recovery wells or interceptor trench) • Containment Wall (e.g., sheet pile, funnel and gate, slurry wall) • In -Situ Treatment (e.g., bioremediation, chemical oxidation) • Phytoremediation The following IRA options were eliminated or screened -out: • Containment Wall (e.g., sheet pile, funnel and gate, slurry wall): Containment using sheet piles or slurry walls will still require groundwater recovery on the upstream side of the barrier with no added benefit over hydraulic control alone. A funnel and gate approach requires in -situ treatment or hydraulic recovery at the gate. Given the challenging black liquor chemistry and results of previous studies, time-consuming bench -scale and field testing would be required and delay implementation of the IRA. Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill MSA � Canton, North Carolina January 2024 • In -Situ Treatment (e.g., bioremediation, chemical oxidation): Given the challenging black liquor chemistry and results of previous in -situ studies at this Site, time-consuming bench -scale and field testing would be required and delay implementation of the IRA. However, in -situ treatment will be retained for potential consideration as a remedial enhancement in the IRA area or other black liquor source areas at the Site as final remedial options are evaluated. • Phytoremediation: Trees/vegetation can be employed to provide hydraulic control and uptake of contaminants, but this technology would be limited to addressing only shallow groundwater impacts, poses a lengthy period from construction (for growth/root development) to effective results, and Site features/use prevent effective placement and spacing of trees/vegetation. Current Site access near the levee is not ideal and future land use is not certain. The retained IRA option is hydraulic control/P&T using recovery wells or interceptor trenches. 4.2 Preferred Black Liquor Interim Removal Action Figure 13 provides a detailed evaluation of the selected hydraulic control/P&T IRA option using recovery wells or interceptor trenches with respect to effectiveness, implementability, pros/cons, and costs. Based on our evaluation, the preferred black liquor IRA is hydraulic control/P&T using recovery wells, i.e., a P&T System. This P&T System will accomplish the RAO for the black liquor TCRA by preventing black liquor -impacted groundwater from migrating to the Pigeon River. A P&T System with expansion capabilities also offers potential future remedial enhancement opportunities as additional recovery wells (or trenches) along the Mill side of the levee or in other interior source areas at the Site could supplement hydraulic control along the Pigeon River, and potentially reduce the flux of black -liquor impacted groundwater from the Site toward the river. P&T System expansion along with in -situ technologies will be considered as final remedial options are evaluated. A general description of the conceptual P&T System and other considerations are provided below. 4.2.1 Conceptual Design The P&T System conceptual design uses vertical groundwater recovery wells (RWs) installed along the same transect as the existing inactive RWs (RW-1 through RW-7), on the Mill side of the levee. The conceptual design includes: 19 Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill Canton, North Carolina January 2024 • Seven new RWs to be installed to approximately 30 feet bgs, constructed with 4-inch diameter, Schedule 40 PVC, 0.020-inch slotted screens, and equipped with down -hole pneumatic pumps, water level transducers, and completed in vaults flush with land surface. • The total P&T System design flow rate is estimated at 30 gallons per minute (gpm) based on historical RW performance and available hydraulic conductivity and other data. The actual number, construction, and flow rate for RWs will be determined after additional hydrogeological data gaps are filled as discussed in Section 4.2.2. • Recovered groundwater will be discharged, with no pretreatment, into the existing Mill sewer and conveyed to the WWTP located on the western bank of the Pigeon River. The P&T System discharge will flow through and receive treatment in the WWTP prior to discharge to the NPDES-permitted outfall to the Pigeon River located north of the Site. • The P&T System will consist of the RWs, subsurface piping (air, water, spares), subsurface conduit (transducers), air compressor stations, power drops, controls, and remote telemetry. • Based on previous P&T operations at the Site, a robust operation and maintenance program and scaling prevention protocol will be implemented to control well/piping fouling and maximize RW pumping efficiency. Figure 14 shows the Conceptual Layout of the P&T System. 4.2.2 Data Gaps and WWTP Evaluation The final P&T System design/layout and actual number, construction, and flow rate for RWs will be determined after additional hydrogeological data gaps are filled per the U.S. EPA -approved Implementation of Interim Work Plan Addendum to Address Vertical Delineation Data Gaps via Limited Subsurface Investigations (EnSafe, December 2023), and groundwater flow modeling is completed. This approach will ensure the final P&T System design provides effective hydraulic control of the black liquor plume to mitigate seeps. Table 4 provides a summary of the data gaps and proposed resolution. PTVE intends to commence data gap filling in January 2024 pursuant to the Work Plan Addendum approved by U.S. EPA. 20 Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill MSA � Canton, North Carolina January 2024 Table 4 Data Gaps Pre -IRA Design and Implementation Data Gap Proposed Resolution Confirm vertical and horizon extent of distinct site geologic horizons Collect continuous soil cores from up to ten locations and document the spatial extent of the distinct geologic horizons across the Site. Vertical extent of black liquor impacts Determine black liquor impacts to the distinct geologic horizons from the ten soil boring locations. The following methods will be utilized in the field to determine the presence of black liquor: • Color — visual observation — subjective • Color — apparent — Color disk/APHA Platinum -Cobalt Standard • pH • ORP Hydrogeologic Based on field measurements and observations from the borings, install up to three observation wells and one recovery well screened solely across the distinct geologic horizon(s) where black liquor is observed and perform aquifer testing to assess hydro eolo y in each stratum. Background Data Install one monitoring well at a location upgradient of any historic industrial/mill activities to serve as a baseline representative of background conditions. Notes: IRA = Interim Removal Action ORP = Oxidation -Reduction Potential Other data gaps may be identified based on observations and evaluation of the data collection outlined above and would need to be addressed prior to final IRA design. The aquifer testing results will be used to evaluate/determine the aquifer hydraulic properties, radius of influence, and water quality of recovered groundwater for more thorough evaluation of weighted average concentrations anticipated from full scale operation. All available hydraulic data and results of the data gap filling and aquifer testing will be used in a groundwater flow model to evaluate the capture zone and specify the RW pumping rates, screen intervals, and spacing. In addition, EnSafe is working with PTVE to fully understand the operation, monitoring and compliance reporting, and mass/flow balance for the WWTP. Further evaluation of this information and potential sampling/analyses and flow metering of various loadings (inputs) to the WWTP, including the estimated loading from the P&T System, will ensure that discharge of recovered groundwater to the WWTP will not adversely affect the unit processes or overall WWTP discharge compliance with NPDES permit limits. The current assumption, based on preliminary data evaluation, is that the recovered groundwater will be discharged, with no pretreatment, into the existing Mill sewer for treatment and final discharge at the WWTP. The existing sewer integrity will be confirmed, or new conveyance piping installed as applicable. If pre-treatment is deemed necessary in order to utilize the WWTP discharge permit/option, the final P&T System design will include details for such treatment. 21 ENSA aE NMW- Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill Canton, North Carolina January 2024 4.2.3 Permitting As provided in CERCLA and the National Contingency Plan, no federal, state, or local permit is required for any part of removal or remedial actions for work conducted entirely on the Site. Since all portions of the black liquor IRA will be performed at the Site, on property owned by PTVE, no offsite property access agreements or easements are needed. Well construction permits will be obtained from the NCDEQ DWR. The black liquor IRA P&T System will discharge recovered groundwater to the WWTP, which operates in accordance with its own NPDES Permit, and that permit is being updated to incorporate the P&T System loading to the WWTP; therefore, pending approval, no other discharge permits are required. 4.2.4 Operation, Maintenance and Monitoring Long-term operation and maintenance (O&M) will be performed to maintain the integrity of the P&T System components and ensure the system operates in accordance with the equipment specifications. Long-term 0&M will include, but may not be limited to, the following activities: • Routine inspection, maintenance, and repair of the system components • Routine/remote monitoring of system data including: RW pumping rates, drawdown, and discharge pressures - Total system flow rate and discharge pressure • Monitoring of groundwater quality at individual RWs and monitoring wells as applicable, and the combined system effluent (e.g., COCs, field parameters) Monitoring well water levels and river elevation Routine RW inspections and rehabilitation per a scaling control plan • Evaluate system performance and provide updates to U.S. EPA as part of ongoing progress reports per the AOC The performance monitoring will be designed to collect the necessary hydraulic and system operating data to ensure proper equipment operation, schedule preventative maintenance, implement the scale control plan, maximize system runtime, and assess and optimize overall system performance. Quarterly reporting of system 0&M details and monitoring results will be included in the quarterly progress reports required per the AOC. 22 Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill MSA � Canton, North Carolina January 2024 5.0 INTERIM REMOVAL ACTION IMPLEMENTATION The anticipated implementation of the selected IRA option to achieve the RAO for the TCRA is outlined in the following sections. 5.1 Final Design and Work Plan Addendum The final P&T System design will be documented in an addendum to this Work Plan. The Work Plan Addendum will document: • The results of the data gap filling, aquifer testing, and groundwater flow modeling, as well as further evaluation of the WWTP and pre-treatment needs. • The final P&T System design on a design/build level of detail to enable PTVE to obtain bids and secure construction subcontractors to implement the IRA. • Details regarding system construction sequence, system startup, and schedule. 5.2 Proposed Schedule The proposed black liquor IRA implementation schedule is summarized in Table 5 below. Table 5 Proposed Black Liquor IRA Implementation Schedule Q1 2024 — • Submit this Work Plan for U.S. EPA review and approval in consultation with NCDEQ • Commence data gap filling (in January) per the U.S. EPA -approved work plan and this Work Plan • Design and perform aquifer testing and confirm WWTP operational and compliance details (in February/March) • Coordinate with PTVE's public relations staff and Project Coordinator, and U.S. EPA's OSC and CIC regarding community notification of TCRA activities • Submit the Fuel Oil IRA Summary Report (in February) to document the completion of those activities per the AOC Q2 2024 — • Perform groundwater flow modeling to evaluate the P&T System capture zone • Prepare the final P&T System design • Submit the Black Liquor IRA Work Plan Addendum summarizing the data gap results, groundwater flow model conclusions and final P&T System design Q3 2024 — • Perform pre -construction activities, including obtaining well construction permits, preparing/updating the Site HASP, and pre -construction meetings/coordination • Pending approval of the Black Liquor IRA Work Plan Addendum: — Install the new RWs and any associated monitoring wells — Identify vendors and commence equipment procurement — Identify construction subcontractor and obtain submittals schedule, construction sequence 23 Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill �SA � Canton, North Carolina January 2024 Table 5 Proposed Black Liauor IRA Implementation Schedule Q4 2024 — • Complete procurement and initiate P&T System construction; the anticipated sequence of construction will include: — Utility mark -out — RW construction and wellhead completions, perform baseline hydraulic testing — Trenching, installation of subsurface piping (air, water, spares), backfilling, and restoration — Installation of equipment pads and power drops Installation of compressor stations, control panels, and remote telemetry Q1 2025 — • Complete P&T System construction and startup • Submit the following plans: — Construction Completion Report (with as -built drawings) — Operation, Maintenance, and Monitoring (OM&M) Plan (including the Scale Control Plan and Performance Monitoring and Reporting Plan Notes: IRA = Interim Removal Action U.S. EPA = United States Environmental Protection Agency NCDEQ = North Carolina Department of Environmental Quality WWTP = Wastewater Treatment Plant PTVEs = Pactiv Evergreen's OSC = On -Scene Coordinator CIC = Community Involvement Coordinator TCRA = Time -Critical Removal Action ACC = Agreement and Order on Consent P&T = Pump & treat HASP = Health and Safety Plan RW = Recovery Well 24 Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill MSA � Canton, North Carolina January 2024 6.0 REFERENCES AECOM/Earth Tech. Semi Annual Groundwater Sampling Reports, Pactiv Evergreen Site. Various Dates. — Groundwater Sampling Plan, to North Carolina Department of Environment and Natural Resources. 2006, November 28. Technical Memo — January 2023 Analytical Results for Wells RW-5 and RW-6, Pactiv Evergreen Site. 2023, February 22. EnSafe Inc. Technical Memorandum Summary of Response Actions Pactiv Evergreen Canton Mill, Canton, North Carolina. March 2023. — Work Plan FuelOi/Investigation (/.e., Initial Work Plan). Pactiv Evergreen Canton Mill, Canton, North Carolina. April 2023. Initial Quality Assurance Project Plan (/, e., Fuel 0// In vest/gation Qua//ty Assurance Project Plan). Pactiv Evergreen Canton Mill, Canton, North Carolina. April 2023. In/t/al Sampling and Analysis Plan (/, e., Fuel O/l In vest/gation Sampling and Analysis Plan). Pactiv Evergreen Canton Mill, Canton, North Carolina. April 2023. Initial Health and Safety Plan (i. e., Fuel O/l Investigation Health and Safety Plan). Pactiv Evergreen Canton Mill, Canton, North Carolina. April 2023. Position Paper — Assessment of Black Liquor Impacts to Groundwater. Pactiv Evergreen Canton Mill, Canton, North Carolina. May 2023. — Interim Work Plan Addendum Comprehensive Sampling and Assessment of Black Liquorlmpacts to Groundwater. Pactiv Evergreen Canton Mill, Canton, North Carolina. June 2023. Interim Removal Action Work Plan for Petroleum -Impacted Soils Pactiv Evergreen Canton Mill, Canton, North Carolina. August 2023. Limited Groundwater Mon/toring Report June 2023 Tr/a/ Run Event. Pactiv Evergreen Canton Mill, Canton, North Carolina. August 2023. 25 Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill MSA � Canton, North Carolina January 2024 Implementation of Interim Work Plan Addendum for Site -Wide Groundwater Sampling and Monitoring Well Rehabilitation and Redevelopment Protocols at the Pactiv Evergreen Corporation — Canton Mill, Pactiv Evergreen Canton Mill, Canton, North Carolina. August 17, 2023. Campground Branch Sampling Technical Memorandum (for Surface Water Sampling at two locations along Campground Branch), Pactiv Evergreen Canton Mill, Canton, North Carolina. September 19, 2023. — Health and Safety Plan, Revision 1. Pactiv Evergreen Canton Mill, Canton, North Carolina. November 2023. Implementation of Recovery of Submerged Off Pactiv Evergreen Canton Mill, Canton, North Carolina. November 2023. Implementation of Interim Work Plan Addendum to Address Vertical Delineation Data Gaps via Limited Subsurface Investigations Pactiv Evergreen Canton Mill, Canton, North Carolina. December 2023. Implementation of Interim Work Plan Addendum to Replace Monitoring Well PZ-16. Pactiv Evergreen Canton Mill, Canton, North Carolina. December 2023. International Paper. North Carolina Department of Environment and Natural Resources Meeting Agenda. 2003, February 20. — Path forward on the corrective action at the Blue Ridge Paper Products, Inc. Site, Canton Haywood County Letter from Mr. Thomas C. Richardson to Mr. Qu Qi, North Carolina Department of Environment and Natural Resources. 2006, March 27. Voluntary Cleanup Checklist for Blue Ridge Paper Products, Inc. Site, Canton Haywood County Letter from Mr. Thomas C. Richardson to Mr. Collin Day, North Carolina Department of Environment and Natural Resources. 2007, October 31. Response to Notice of Regulatory Requirements - Blue Ridge Paper Products, Inc. Site, Canton Haywood County, Groundwater Incident #12680 Letter from Mr. Thomas C. Richardson to Mr. Kim Caulk, North Carolina Department of Environment and Natural Resources. 2008, May 23. 26 Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill Canton, North Carolina January 2024 North Carolina Department of Environmental Quality (formerly Department of Environment and Natural Resources) Asheville Regional Office to IP Groundwater Sampling Plan — Approval. 2006, December 21. — North Carolina Department of Environmental Quality IHSB Letter to International Paper RE; Requirements for Containment Assessment and Cleanup (Agency Restructuring & Voluntary Cleanup/RECProgram). 2007, September 21. — Notice of Regulatory Requirements to International Paper. 2008, March 17. Notice of Regulatory Requirements to International Paper. 2022, April 22. Notice of Violation to International Paper. 2022, November 11. — Notice of Violation to Pactiv Evergreen. 2022, October 20. TRC Environmental Corp. Sampling and Evaluation Work Plan - Surface Water, Seep, and Sediment Sampling, October 27, 2022. Surface Water, Seep, and Sediment Sampling Report. 2023, March Roy. F. Weston, Inc. Groundwater Assessment at the Canton Pulp and Paper Mill. 1994, December 15. Comprehensive Site Assessment Report Canton Pulp and Paper Mill, Canton North Carolina. 1995, June 1. Comprehensive Site Assessment Addendum Report Canton Pulp and Paper Mill, Canton North Carolina. 1996, January 18. — Comprehensive Site Assessment Phase III Report Canton Pulp and Paper Mill, Canton North Carolina. 1997, July 10. United States Environmental Protection Agency. Quality System and Technical Procedures for LSASD Field Branches. https://www.epa.gov/quality/quality-system-and-technical- procedures-Isasd-field-branches. Last Update 2022, February 7. Black Liquor Interim Removal Action Work Plan Pactiv Evergreen Canton Mill MSA � Canton, North Carolina January 2024 — Pollution/Situation Report Evergreen Packaging Site Removal Site Evaluation (POLREP) Canton North Carolina. 2023, July 06. — Enforcement Action Memorandum - Evergreen Packaging Site, Canton North Carolina. 2023, October 18. Administrative Settlement Agreement and Order on Consent for Removal Action - Evergreen Packaging Site, Canton North Carolina. 2023, October 24. E. Sjostrom. Wood Chemistry. Fundamentals and Applications 1993 Academic Press. 28 Figures lti ( `-` N V --North Canton a 11 is Corn Unity Cem El d N CAIV1 pry RD 74 I \ ' ryl EDGAR Lry 1 r 215 SERVICE 1104 d 61r7 wo $ 9�p� N Lj 800 S '9 01fS W ENv ` a P •��ERDbiN4r 0 c�Pr S � � sh ��`' ♦2y 4�Tr .J ♦ F sT sr Fibreville r. aL RECL'COV�RD l P v� pS� �a DpVIS PULL RD OLDCLYpE.r. RD ++'� Cemet Smathe es �..i7t � � MiHGUS NILL'p4 d �♦,P � P¢Q, o� 19 23 S C S SPRING s ELLS PENNSYCYANIA AVE ti 04ST �p>r�' �I f t J ENGLAHD RD �O r Htt7 - �G- ibs 2� �9 ST O�� 4 JOyNSOIy.DR >b SOBSrAr1ON:Rp� yT ST 1 LAKEVIEH . L4q ST 90 �PISGAH.SCHOOL RD yq DR j OOp p C2800 A vim• . R� 1 ... RHOpA Sr- AL'LEN 09' ` A?I CORI �zry09 �t h i , o 3: 1 . 111 a gRTI \ gp �y = FIGURE 1 4.P 215 �$ o 170 �• .. SITE LOCATION MAP IT PACTIV EVERGREEN CANTON MILL °,� CANTON, NORTH CAROLINA - g o ` NAD 1983 STATE PLANE REQUESTED BY: TD MSAILT NORTH CAROLINA FEET LEGEND DRAWN BY: NR 0 1,000 2,000 '2 r--j APPROXIMATE SUBJECT PROPERTY BOUNDARY DATE: 11/27/2023 creative thinking. custom solutions. SCALE IN FEET PROJECT: 0888834351 800-588.79621—ensafe.com K Source: U.S. Geological Survey. Canton Quadrangle, North Carolina[Map]. Photorevised 2022. 1:24,000. 7.5 Minute Series. Source: Google Earth Pro Imagery - 04/2022 ' may,!"-.R d1 - ' - - ' - - _ _ ' �_ }. _ - _ _ T _ - sfq��--- -7.._ __ •}v - r tic+ -� ��. }L 5f rf. � - ✓' - - ••'�L - L � F '- - � _ � -_ _ _ - s � �� ILL RM -t;'x , Yf,�}'4:�• '� r _ e �ii_ - -�-'�_ _ - ♦♦ a `^' . - '� { o 0 A t - O M ♦ O ... S. S -77VV FORMER AST CONTAINMENT BUNKER W PZ- W- ' • •a + • P -2 -5 1 Z- RW-4 9P PZ-2 \ RW-3 Z-6 PZ-1 PZ-14R RW-2 i JfffJI4 sgAR� F � �RW-1 MONITORING/RECOVERY WELL RIVER FLOW DIRECTION GROUNDWATER FLOW DIRECTION RESIDUAL OIL IN SOILS (OIL EXTENT IN SOIL IS CURRENTLY UNKNOWN. SHADED AREAS ARE INFERRED FROM 2023 DATA SET) APPROXIMATE EXTENT OF BLACK LIQUOR SEEP (OBSERVED AT LOW RIVER CONDITIONS) AREA OF CONCERN FOR BLACK LIQUOR TCRA FIGURE 4 BLACK LIQUOR CONCEPTUAL SITE MODEL UNDERGROUND UTILITIES PACTIV EVERGREEN CANTON MILL CANTON, NORTH CAROLINA OLD SEWER LINE REQUESTED BY: TD DATE: 01/15/2024 CURRENT SEWER LINE DRAWN BY: KPB PROJECT #: 0888834351 Source: Google Earth Pro Imagery - 04/2022 4 r BRA Chromium - 0.32 Chromium (Dissolved) - 0.22 ''R - Cobalt - 0.019 J Cobalt (Dissolved) - 0.021 J Manganese - 9.8 Manganese (Dissolved) - 11.7 Nickel - 0.55 '. ram_ Nickel (Dissolved) - 0.4 f _v T PZ-7 RW-1 Vanadium - 0.0095 J Arsenic - 0.021 J Manganese - 1.57 Arsenic (Dissolved) - 0.013 J Manganese (Dissolved) - 1.32 Beryllium - 0.0078 J Vanadium - 0.0115 PZ'6 Beryllium (Dissolved) - 0.0057 J Cobalt - 0.0019 J Chromium - 0.22 .t Cobalt (Dissolved) - 0.0018 J [ Manganese - 3.2 Chromium (Dissolved) - 0.2 Cobalt - 0.014 J s• Manganese (Dissolved) - 2.8 Cobalt (Dissolved) - 0.01 J Iron - 22.7 ' PZ-14R BR-3 Iron (Dissolved) -18.1 Manganese - 0.25 Cobalt - 0.0017 J Lead - 0.039 J Manganese (Dissolved) - 0.25 Cobalt (Dissolved) - 0.0022 J Lead Dissolved) - 0.033 Manganese - 0.097 Manganese - 0.12 ti Vanadium - 0.11 Manganese (Dissolved) - 0.086 BR-2 r Vanadium (Dissolved) - 0.1 Nickel - 0.15 Antimony - 0.0071 J Nickel (Dissolved) - 0.12 Chromium - 0.0912 Vanadium - 0.96 PZ-2 Vanadium (Dissolved) - 0.8 Cobalt - 0.0081 J Arsenic - 0.025 J Manganese - 0.216 PZ-1 Arsenic (Dissolved) - 0.016 •- Vanadium - 0.0273 Manganese - 3.6 Chromium - 0.04 Manganese (Dissolved) - 3.1 ti Chromium (Dissolved) - 0.029 F Vanadium - 0.0463 Cobalt - 0.0086 J PZ 9 ' Vanadium (Dissolved) - 0.0356 Cobalt (Dissolved) - 0.006 J Cobalt - 0.0013 J = Iron -15.4r ._._ RW-2 Iron (Dissolved) -10.1 Chromium - 0.0424 PZ-3 Manganese - 0.13 Chromium (Dissolved) - 0.0135 Chromium - 0.0175 4r r Cobalt - 0.0248 J Chromium (Dissolved) - 0.0146 Manganese (Dissolved) - 0.089 Cobalt (Dissolved) - 0.0158 Cobalt - 0.0025 J Nickel - 0.19 PZ-21 Vanadium - 0.556 Cobalt (Dissolved) - 0.0017 J Nickel (Dissolved) - 0.14 PZ-8 Cobalt - 0.0012 J 2 Manganese - 1.39 Vanadium - 0.55 Chromium - 0.0108 Manganese - 0.833 Zinc - 2.86 Manganese (Dissolved) - 1.21 Vanadium (Dissolved) - 0.4 Cobalt - 0.0031 J Manganese (Dissolved) - 0.648 Vanadium (Dissolved) - 0.423 Cobalt (Dissolved) - 0.0012 J Zinc (Dissolved) - 2 Vanadium - 0.227 Vanadium - 0.0389 Vanadium (Dissolved) - 0.174 PZ 13 Vanadium (Dissolved) - 0.0238 Cobalt - 0.01 Cobalt (Dissolved) - 0.0078 J s Manganese - 0.26 - Manganese (Dissolved) - 0.25 qq PZ-20 RW-3 Cobalt - 0.0027 J PZ-4 •� ddd RW-4 Antimony (Dissolved) - 0.0179 Vanadium-0.0977 Manganese-0.799 � t, Arsenic - 0.0303 Arsenic - 0.254' Vanadium (Dissolved) - 0.0577 Manganese (Dissolved) -0.824 Arsenic (Dissolved) - 0.0296 Vanadium - 0.0178 Arsenic (Dissolved) - 0.297 " Chromium - 0.0499 Vanadium (Dissolved) - 0.0094 J Chromium - 0.118 Chromium (Dissolved) - 0.0334 Chromium (Dissolved) - 0.115 Cobalt - 0.0037 J - Cobalt - 0.0036 J i . ' =a+• Cobalt (Dissolved) - 0.0017 J Cobalt (Dissolved) - 0.004 J Manganese - 0.161 }' Iron - 5.09 Manganese (Dissolved) - 0.0725 Iron (Dissolved) - 3.55 y Vanadium - 0.493 ti Manganese - 0.0823 47 Vanadium (Dissolved) - 0.322 Mercury-0.0032 r' f Mercury (Dissolved) - 0.0036 R r Nickel - 0.117 Vanadium - 1.32 RW-5 i • Vanadium (Dissolved) - 1.34 _ 1. a Arsenic - 0.286 J = , Arsenic (Dissolved) - 0.613 Boron - 2.37 J r �' ■y� �- PZ-11 ,t,# Boron (Dissolved) - 4.42 r' K* Arsenic - 0.046 J Chromium - 0.191 J s Arsenic (Dissolved) - 0.06 of Chromium (Dissolved) - 0.219 J Barium - 0.72 _ - Iron - 3.86 Chromium - 0.17 Lead - 0.278 J y + Chromium (Dissolved) - 0.15 fsY Manganese - 0.137 J1 Cobalt (Dissolved) - 0.0052 J '�_ +T r Nickel - 0.146 J - Manganese - 0.23 Nickel (Dissolved) - 0.257 i . Manganese (Dissolved) - 0.18 Vanadium - 1.24 RW 6 Vanadium - 0.84 Vanadium (Dissolved) - 1.91 Cobalt (Dissolved) - 0.0012 J Vanadium (Dissolved) - 0.73 .� Zinc - 1.78 Manganese - 0.673 PZ-12 8 _ Arsenic - 0.042�` ~ � , '_�. Manganese (Dissolved) - 0.687 N Arsenic (Dissolved) - 0.042 Cobalt-0.0016 J ,. Chromium - 0.17 y Cobalt (Dissolved) - 0.0033 J Chromium (Dissolved) -0.15 Manganese - 0.63 Cobalt - 0.0035 J =. Manganese (Dissolved) - 0.61 i Cobalt (Dissolved) - 0.003 J ! �� Manganese - 0.18 Manganese (Dissolved) - 0.15 -r �fc ' Vanadium - 0.96 •� Vanadium (Dissolved) - 0.81 49 F •` �� r` ;'try d Cobalt (Dissolved) - 0.0012 J ■" _ Manganese - 0.453 Manganese (Dissolved) - 0.508i n i ► { Manganese - 2.43 ..r �• - Manganese (Dissolved) - 2.07 rr ; ` - - , 1, ly�L. w •- _ � r.: :.: � _ :. • v �' . 4 1 M55 FIGURE 6 #' NC2L EXCEEDANCES FOR METALS IN GROUNDWATER • Y'.r- PACTIV EVERGREEN CANTON MILL CANTON, NORTH CAROLINA NOTES NAD 1983 STATE PLANE REQUESTED BY: TD MSA� UNITS ARE IN MILLIGRAMS PER LITER (mg/L) NORTH CAROLINA FEET LEGEND J = ESTIMATED VALUE DRAWN BY: RC 4) WELL LOCATION BR-2 INSUFFICIENT SAMPLE VOLUME FOR DISSOLVED METALS 0 75 150 DATE: 1/8/2024 creative thinking. custom solutions. NC21- = NORTH CAROLINA GROUNDWATER QUALITY STANDARDS SCALE IN FEET PROJECT: 0888834351 800.588.7962 1 -ensafe.com Source: Google Earth Pro Imagery- 04/2022 •� - ' P {y 1 5:`xkl I ,* I :e _- ! jp �• i am -. i� PZ-9 PZ-21 PZ-13 RW-3 ti {w- _ PZ-3 •- j' f` y ''A: �s RW-4 Benzene - 1.3 J *. _ PF 3. r _ .+rr. PZ-11 . }v r . RW-8a�-� Benzene - 1 A J • - . _ ` .� 4 �r<' � - -�/ - 'k '� �' .,try _. ■' 41 y ,�~ _b FIGURE 7 " z r NC2LEXCEEDANCESFOR VOCS ' IN GROUNDWATER �►. PACTIV EVERGREEN CANTON MILL ' .. CANTON, NORTH CAROLINA NOTES UNITS ARE IN MICROGRAMS PER LITER (Ng/L) NAD 1983 STATE PLANE REQUESTED BY: TD iMSAILT 3 LEGEND - VOC = VOLATILE ORGANIC COMPOUND NORTH CAROLINA FEET DRAWN BY: RC C WELL LOCATION =ESTIMATED VALUE 0 75 150 DATE: 12/18/2023 creative thinking. custom solutions. NC2L = NORTH CAROLINA GROUNDWATER QUALITY STANDARDS SCALE IN FEET PROJECT: 0888834351 800.58U9621 www.ensafe.com Source: Google Earth Pro Imagery - 04/2022 N +i, 1 t SCH, 5 � RW-1 PZ-6 +• _ r F/BERVLLLERD STATf RD3643 y BR 1 PZ-14R 'rrr Naphthalene - 13.2 f •- - - - • - r y PZ-7 BR-2 - BR-3•'� •`- RW-2 _ a if - PZ-2 Phenol - 49.1 J PZ-9 t PZ-1Aft • ,� �, � - PZ-21 Naphthalene -15.1 5. - RW-4 Naphthalene - 130 i;';_• ` 1�- y:r x PZ-4 k :Q Naphthalene - 225 y K _ ti •� o- r�� +,F_ - PZ-11 J•• - 'f P 4 � r Ff' ,•• r . RW-6 Nth '' , PZ-18 , PZ-12 Acenaphthene - 87.7 Naphthalene - 108 ti l G� • R ''Ord 1 • �_ � fi 'a: P y i PZ-17 bis(2-Ethylhexyl)phthalate 4.4 J y _ •, _- '.} z r' - m: FIGURE 8 " NC2L EXCEEDANCES FOR SVOCS j IN GROUNDWATER PACTIV EVERGREEN CANTON MILL ' .. CANTON, NORTH CAROLINA NAD 1983 STATE PLANE NOTES UNITS ARE IN MICROGRAMS PER LITER (Ng/L) NORTH CAROLINA FEET REQUESTED BY: TD iMSAILT LEGEND SVOC = SEMI -VOLATILE ORGANIC COMPOUND DRAWN BY: RC C WELL LOCATION 3 = ESTIMATED VALUE 0 75 150 DATE: 12/18/2023 creative thinking. custom solutions. NC2L = NORTH CAROLINA GROUNDWATER QUALITY STANDARD SCALE IN FEET PR03ECT: 0888834351 800S88.79621 www.ensafe.com Source: Google Earth Pro Imagery - 04/2022 -' N fin•- - 57 S NIGH' / PZ-579 • i^ y��.{. SCHOO S( T. • r FIBERVILLE RD STATERD3643 _ c - y BR-1� l Chloride - 15,900 Sulfate - 540 PZ-14R 5 E � to BR-3 Chloride - 8,910 h' - BR-2 F f w Sulfate -500 '.'•'�, PZ-2 r• -: PZ-1 Chloride - 1 , 3601 !F{PZ-9� -_ Chloride - 282 y rr t � PZ-21 r '�+ PZ-8 , _ Chloride - 2,670 (E300)r PZ-13 r RW-3 Sulfate - 490 r / PZ-3 .� 7• 1 kk PZ-20 ,r RW-4 Sulfate t Chloride - 4,960 - qp y Sulfate - 824 r r �► If %.T 4 ST PZ-11 -' r r , , yy RW-6 s� - PZ.18 PZ-12 Chloride - 1,53 0 - Sulfate - 630 Ir pk R ■ - _ *r� i. PZ-17 - •'-" +�" . , •-'"'.,s� FIGURE 9 NC2L EXCEEDANCES OF ANIONS �- IN GROUNDWATER PACTIV EVERGREEN CANTON MILL _ CANTON, NORTH CAROLINA - NOTES NAD 1983 STATE PLANE REQUESTED BY: TD MSAI:r - UNITS ARE IN MILLIGRAMS PER LITER (mg/L) LEGEND - PZ-8 AND PZ-9 ANALYSIS METHOD E300 ALL OTHERS SW 9056 NORTH CAROLINA FEET DRAWN BY: RC WELL LOCATION - BR-2 AND RW-5 WERE NOT ANALYZED FOR ANIONS 0 75 150 DATE: 1/8/2024 creative thinking. custom solutions. - NC2L = NORTH CAROLINA GROUNDWATER QUALITY STANDARDS SCALE IN FEET PROJECT: 0888834351 800.588.79621 www.ensafe.com K Source: Google Earth Pro Imagery - 04/2022 Source: Google Earth Pro Imagery - 04/2022 PZ-14R 10. 's. 10 9 ♦ BR-1 50 100 BR-2 . C 50 F /15 PZ-13' \115 1 l ' 1 PZ-20 1 250 500 228.5 1000 5000 -432 Z-9 . ;► PZ-21 pZ_g 5 C 5U:4 M1 ` C PAV 350 J+ 1 ♦ ♦♦ 1 . PZ-11 1 1 9000 1 -224.5 I I PZ-18 / 500 / K- -89.7 / / i i i PZ 17 FIGURE 11 GROUNDWATER COLOR ISOCONTOUR MAP NOTES RANI = ORP IN MEGAVOLTS (mV) T )y6,,.` SEPTEMBER 2023 _ J =ESTIMATED CONCENTRATION PACTIV EVERGREEN CANTON MILL U = NOT DETECTED AT THE CANTON, NORTH CAROLINA NUMERICAL DETECTION LIMIT r LEGEND NAD 1983 STATE PLANE REQUESTED BY: TD o C WELL LOCATION Q SEEP COLOR CONTOURS, DASHED WHERE INFERRED NORTH CAROLINA FEET DRAWN BY: NR MSAM 6 COLOR BY SM212OB-2011 COLOR IN PLATINUM COBALT UNITS 0 100 200 DATE: 12/8/2023 creative thinking. custom solutions. - 15 SO 100 500 1000 5000 10000 SCALE IN FEET PROJECT: 0888834351 800-588.79621—ensafe.com Source: Google Earth Pro Imagery - 04/2022 D • 5. •'S � �.. � '•ems � � � :+� �-:• � /, r. Camp Branch Outfall (CBOF) Lead - 2.2 (0.54 n nc SEEP-02 x PH - 9.3 J (6-9) Copper - 4.2 J (2.7) , RW,1... , PZ-6 ` PZ-14 R O PZ-7 BR-2 BR-3 RW-2 �J PZ-2 CHAMPION DR Camp B�r ;h.; PZ-1::. i:..- �e . 0 .. _ . . Upstream b PZ-9 PZ-21 near x + , f Y ; (CBUS) 1: G PZ-8411 f PZ-13'. RW-3 SW-02 PZ-20 RW-4 PZ-4 SEEP-01 L:iy �s; pH - 10.2 J (6-9) RW=5 Copper- 3.7 J (2.7) SW 01 �•� PZ-11 Zinc - 50.7 (36) q PZ-12 s RW=7 r: PZ117 n FIGURE 12 s LEGEND NOTES - DISSOLVED METALS IN MICROGRAMS PER LITER J = ESTIMATED VALUE NC2B EXCEEDANCES IN SURFACE SURFACE WATER PIGEON RIVER SAMPLES COLLECTED 9/20/23 WATER AND SEEPS O SAMPLE LOCATION PACTIV EVERGREEN CANTON MILL CAMP BRANCH SAMPLES COLLECTED 10/02/23 0 0 CANTON, NORTH CAROLINA SEEP SAMPLE LOCATION NC2B = NORTH CAROLINA SURFACE WATER • PIEZOMETER QUALITY STANDARDS pH IN STANDARD UNITS NAD 1983 STATE PLANE REQUESTED BY: TD �� RECOVERY WELL (XX) = NC2B SW STANDARD NORTH CAROLINA FEET DRAWN BY: RC BEDROCK MONITORING WELL 0 200 40o DATE: 12/20/2023 e. creative thinkin custom solutions. w RIVER FLOW DIRECTION SCALE IN FEET PROJECT: 0888834351 800.588.7962 1 —ensafe.com Source: Google Earth Pro Imagery - 04/2022 Figure 13 Screening of Retained Black Liquor IRA Options Pactive Evergreen Canton Mill Canton, North Carolina TCRA Objective Description Effectiveness Implementability Pros Cons Comments Cost Estir Annual O&M IRA OPTION 1= P&T System Using Recovery Wells IRA OPTION 2 = P&T System Using Interceptor Trench Provide downgradient hydraulic control of shallow groundwater to minimize black liquor discharge into the Pigeon River. Install new hydraulic containment system along the same transect as the Install new hydraulic containment system along the same transect as the existing RWs, on the Mill -side of the levee using vertical groundwater existing RWs, on the Mill -side of the levee using —1,200 feet of a recovery wells (RWs) with pneumatic pumps. The recovered groundwater groundwater interceptor trench with sumps. will be discharged to the WWTP through existng sewer discharge line Key the trench into the Saprolite at —40 feet bgs. Install recovery sumps without pretreatment. Existing RW screens are 20-40 feet long between 9 with pneumatic pumps every 200 feet to collect groundwater from and 49 feet bgs (across Fill, A/C, COB, and SAP. New RWs are proposed to perforated laterals w/filter socks in the trench. The trench will be lined with be screened —10-40 feet bgs across Fill, A/C, COB, and SAP), not bedrock. geotextile prior to backfilling to limit fines migration. The recovered Final screen intervals will be based on vertical COC delineation (data gap). groundwater will be discharged to the WWTP through the existing sewer discharge line, but pretreatment (filtration) may be needed to reduce fines. Actual trench depth would depend on vertical COC delineation (data gap). High. Very effective at minimizing black liquor discharge into the Pigeon High. Very effective at minimizing black liquor discharge into the Pigeon River. System reliability/maintainability will be maximized through a River. System reliability/maintainability will be maximized through a preventative maintenance program. Pneumatic pumps will be used, with preventative maintenance program. Pneumatic sump pumps will be used, equipment/controls situated above flood level. with equipment/controls situated above flood level. Cleanouts will be installed in the laterals; however, the depth of the laterals/filter sock will complicate routine rehabilitation for scaling control. • System installation is easily implementable for RWs, air lines, discharge • Trench installation to a depth of —40 feet bgs is complex and pricey. piping, air compressor station, and power drop. • Recovery system installation is easily implementable for the recovery • Well screen intervals can be easily adjusted prior to installation if sumps, air lines, discharge piping, air compressor station, and power drop. necessary based on the vertical COC delineation (data gap). Expansion using • Trenches are difficult to modify or expand after installation if site additional RWs is feasible and spare piping/fittings can be incorporated in conditions warrant. the original system for ease of expansion. • Provides immediate hydraulic capture along RW-line, capture zone will • Provides immediate hydraulic capture along trench, capture zone may extend downgradient to the river side of levee but not to the river; extend to river side of levee, but residual black liquor in that area will therefore, residual black liquor under the levee not within the capture zone continue to move to the river. will continue to move to the river. • Not readily expandable with regard to trenches, but can install expansion • P&T was previously implemented at the site and if properly maintained recovery components/spare piping. can be effective over a longer period of operation. • Provides interim black liquor remedy while other remedy options are • Moderately easy to modify system/add wells, can install expansion evaluated. components/spare piping on initial install to accommodate more RWs. • Discharge to the WWTP but likely requires pretreatment to reduce fines. • Provides interim black liquor remedy while other remedy options are evaluated. • Discharge to the WWTP without pretreatment. • Higher than average O&M effort is needed to maintain pumping • Higher than average O&M effort is needed to maintain laterals/sump efficiency due to scaling. pump efficiency due to scaling. Cleaning effectiveness has limitations, • Other discharge options may be required in the future (NPDES) pending cannot clean geotextile once it is fouled and there is no recourse. Note that WWTP upgrades/replacement. if the trench geotextile becomes plugged due to scaling or BL solids accumulation, there is no feasible method to rehabilitate. • Slope stability control during installation to —40 feet bgs may require 5-10 feet on each side of the trench for benching. • Installation cost is higher than RWs, and is most feasible if shorter trench segments and shallow depths are used. • Other discharge options may be required in the future (NPDES) pending WWTP upgrades/replacement. Requires well efficiency monitoring to determine frequency of well Requires lateral/sump rehabilitation due to calcium carbonate fouling. rehabilitation due to calcium carbonate fouling. Well rehabilitation will be Lateral rehabilitation will be challenging due to access. Intermediate -term performed when baseline well efficiency declines by 30-50%due to plugging of trench geotextile/lateral pipe socks is likely and rehabilitation increased drawdown, decreased yield, and decreased specific capacity. will be challenging at best. Conventional mechanical and chemical well rehabilitation methods will be used. A downhole camera will document pre- and post -rehabilitation well screen conditions, and post cleaning specific capacity testing will be performed to confirm effectiveness of process. nate $790,000 $1,100,000 $280,000 $340,000 OPTION 1= SELECTED OPTION OPTION 2 = Retained for possible future use if/where applicable Notes: bgs - below ground surface A/C - alluvium/colluvium COB - cobble layer SAP - saprolite BR - bedrock Page 1 of 1 Source: Google Earth Pro Imagery- 04/2022