NC0000272_Report_20240313

ENSAFE
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January 31, 2024
Mr. Kenneth B. Rhame via email: [e-mail]
United States Environmental Protection Agency — Region 4
61 Forsyth Street S.W. #9
Atlanta, Georgia 30303
Re: Project Progress Report for Fourth Quarter 2023
Pactiv Evergreen — Canton Mill, Canton, North Carolina
Dear Mr. Rhame:
This progress report provides a summary of Time Critical Removal Action (TCRA) activities undertaken
by or on behalf of Pactiv Evergreen (PTVE) at the former Canton Mill (the Site) in Canton, North Carolina.
This report complies with the requirements of Section VIII.25 of the Administrative Settlement
Agreement and Order on Consent for Removal Action (AOC), CERCLA-04-2024-7000, effective
October 24, 2023. This report covers the fourth quarter (Q4) of 2023.
DESCRIPTION OF WORK COMPLETED
A detailed Action Tracker (log) of TCRA activities is provided on the project -specific SharePoint site.
The following TCRA field activities were performed during Q4 2023 (corresponding documents are listed
below in Submittals/Deliverables):
1. Completed a one-time, site -wide comprehensive groundwater and surface water sampling event
performed in September and October 2023, pursuant to the United States Environmental
Protection Agency (U.S. EPA) approved Interim Work Plan Addendum — Comprehensive
Sampling and Assessment of Black Liquor Impacts to Groundwater(EnSafe Inc., June 2023), to
assess impacts to groundwater and surrounding surface water bodies as a baseline for the black
liquor interim removal action required by the AOC.
2. Completed surface water sampling at the Campground Branch on October 2, 2023, per the
approved work plan.
3. Completed removal of submerged fuel oil from the Pigeon River per the approved work plan.
4. Completed the Fuel Oil Area Interim Removal Action per the U.S. EPA approved Interim Removal
Action Work Plan for Petroleum -Impacted Soils (EnSafe, August 14, 2023), including
aboveground storage tank (AST) removal, soil excavation and disposal, dewatering/treatment
and disposal, confirmatory soil sampling, grouting of sewer line in former AST bunker to the
levee manhole, grouting of the levee manhole, and restoration of work areas.
SUBMITTALS/DELIVERABLES
1. The following correspondence was issued or received by or on behalf of PTVE in Q4 2023:
a. Received the executed Administrative Settlement Agreement and AOC for
Removal Action, CERCLA-04-2024-7000, effective October 24, 2023.
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Mr. Kenneth Rhame
January 31, 2024
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b. Submitted the Implementation of Recovery of Submerged Oil Plan dated
November 1, 2023); U.S. EPA approved the submittal via email dated November 2, 2023.
C. Submitted the Health and Safety Plan, Revision 1 dated November 14, 2023, pursuant
to the AOC.
d. Submitted the Implementation of Interim Work Plan Addendum to Address Vertical
Delineation Data Gaps via Limited Subsurface Investigations dated December 11, 2023;
U.S. EPA approved the submittal via email dated December 27, 2023.
e. Submitted the Implementation of Interim Work Plan Addendum to Replace Monitoring
Well PZ-16 dated December 14, 2023; U.S. EPA approved the submittal January 24,
2024.
SUMMARY OF SAMPLING RESULTS/TESTS
1. Attachment 1 provides the Technical Memorandum — Summary of 2023 Groundwater and
Surface Water Sampling (EnSafe, January 2024) documenting the work and results from the
site -wide sampling and Campground Branch surface water sampling efforts in September and
October 2023. Key takeaways include:
a. Groundwater, seep, and surface water contaminants of potential concern have been
resolved, and future monitoring (scope to be determined when applicable) can focus on
the known contaminants of concern (COCs) in groundwater and seeps; no COCs were
identified in surface water and toxicity testing indicates no adverse ecological impacts to
the Pigeon River.
b. Historical thinking regarding groundwater COCs have been disproved as follows: dioxins
and furans typically related to pulp/paper mills are not a concern in site groundwater;
and volatile organic compounds and semi -volatile organic compounds are not prevalent
in site groundwater and only a few of each are considered COCs.
C. Groundwater impacts are primarily within the shallow unconsolidated aquiferat the Site.
There is no evidence of groundwater communication between the surficial aquifer and
bedrock aquifer.
2. Confirmatory soil sampling results from the former Fuel Oil AST bunker area will be documented
in the Fuel Oil Area Interim Removal Summary Report scheduled for submittal in February 2024.
Only one of 23 confirmatory samples exhibited results above soil screening levels (and that
location could not be further excavated due to bunker wall/obstacle).
WORK ANTICIPATED IN FOLLOWING QUARTER
The following TCRA activities are planned for the first quarter of 2024 (January — March):
1. Continue implementing work and deliverables as required per the AOC.
2. Submit the Black Liquor Interim RemovalAction Work Plan per Section VIII.16.b of the AOC.
3. Commence data gap filling activities to refine the black liquor interim removal action design
basis, 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).
This includes soil borings to assess vertical lithology, determine which hydrogeologic formation
ENSAFE

Mr. Kenneth Rhame
January 31, 2024
Paqe 3
exhibit black liquor residuals in groundwater, collection of specific hydrogeologic data, and
installation of wells for aquifer testing.
4. Replace monitoring well PZ-16 per the U.S. EPA approved Implementation oflnterim WorkP/an
Addendum to Replace Monitoring Well PZ-16 (EnSafe, December 2023).
5. Implement the Black Liquor Interim Removal Action Work Plan once approved by U.S. EPA in
consultation with the North Carolina Department of Environmental Quality.
6. Participate in periodic status calls/meetings with stakeholders.
7. Support U.S. EPA's community relations and outreach as applicable.
ISSUES/RESOLUTIONS
None.
COMMUNITY RELATIONS
Provided data and information as applicable to support U.S. EPA and North Carolina Department of
Environmental Quality in response to community inquiries.
If you have questions or need additional information, please contact me at 813-734-7985.
Sincerely,
EnSafe Inc.
�ti1 C�
By: Bridget Morello, PE
Principal
Attachments:
Attachment 1 — Technical Memorandum — Summary of2023 Groundwater and Surface Water
Sampling (EnSafe, January 2024)
cc: Alison Vincent, Project Coordinator, PTVE
Project -specific SharePoint site
ENSAFE