NC0000272_Comments_20240912 (2)

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CANTON
NORTH CAROLINA RECEIVED
SEP 0 3 2024
Wastewater Permitting NCDEQ/DWR/NPDES
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
via email: publiccorrirnents((i)deq.nc.gov
Subject: Comments on Draft NPDES Major Modification
Canton Mill - Blue Ridge Paper Products (d/b/a Evergreen Packaging)
NPDES Permit NC0000272
Dear Sir or Madam,
The Town of Canton appreciates the opportunity to review and comment on the draft major modification
of NPDES Permit No NC0000272 that was issued for public comment by the North Carolina Department
of Environmental Quality (DEQ) on July 24, 2024.
The Town of Canton's understanding is the Pactiv Evergreen Canton Mill site where the wastewater
treatment plant (WWTP) is located, and other properties owned by Evergreen Packaging may be sold in the
next few months. At that time, the /Town of Canton assumes the new owner will be responsible for the
operation of the WWTP. This WWTP accepts and treats all wastewater from the Town of Canton. The
Town does not currently have another alternative for the treatment of wastewater from the Town.
The Town of Canton respectfully submits the following comments:.
Comment 1. In the "Supplement to the Permit Cover Sheet," (page 3 of 9), we request the following
revisions to the description in paragraph #1.
"Continue operation of a 4.9 MGD wastewater treatment plant for the treatment of wastewater
associated with the Blue Ridge Paper Products Inc. pulp and paper mill, landfill leachate, the Town
of Canton' s ehlai-in tee municipal wastewater, stornrwater runoff, and recovered
contaminated groundwater, black liquor, and fuel oil associated with the EPA Administrative
Settlement Agreement and Onder on Consent for Removal Action [AOC] (CERCLA Docket No.
CERCLA-04-2024-7000)."
The correct Ownership of the Canton Mill and WWTP should be clarified as a part of the final NPDES
permit modifications. The Town of Canton understands that "Blue Ridge Paper Products Inc" may not be
the correctly titled Owner.
The Town of Canton understands that the term "municipal" is a more accurate description of the Town of
Canton's wastewater than the term "chlorinated domestic."
The Town of Canton does not own the landfill. The Town of Canton understands that the leachate from the
landfill is currently treated by the WWTP and that this process will continue.

The Town of Canton understands that the WWTP is responsible for treating stormwater runoff from the
Canton Mill site. Said stormwater has the potential to be contaminated.
The Town of Canton understands that the WWTP will be responsible for treating the recovered liquids
described in the AOC.
Comment 2. The Town is in general agreement to reduce the flow limit to 4.90 MGD with the
understanding that the lower flow limit will allow operational cost savings to due to less staffing
requirements. However, a capacity analysis should be performed to confirm that the WWTP will adequately
service the Town of Canton's current flow of 1.0 to 1.2 MGD, allow for future growth of the Town, and be
sufficient to treat the other known inflows described in Comment 1.
Comment 3. The Town of Canton understands that the stormwater from the Canton Mill is currently being
treated by the WWTP and that this process will continue.
Comment 4. A provision should be added to Section A. (7.) Engineering Alternative Analysis (EAA) which
requires that the permittee also submit any EAA to the Town of Canton for review.
Comment 5. A provision should be added to Section A. (8.) Major Modification Application which requires
that the permittee also submit any Major Modification Application to the Town of Canton for review.
Comment 6. The Town of Canton request that the DEQ approve any change in ownership, operation, and
effluent limits to ensure protection of human health and the environment and that the Town of Canton be
notified of the request in change of Ownership upon receipt of an application for Ownership change by
DEQ.
Comment 7. The draft permit removes most requirements for instream sampling. The Town of Canton
request that applicable instream sampling, both upstream and downstream, be included in the revised
permit. This sampling will be critical to the Town of Canton, new Owners of the Canton Mill WWTP and
to DEQ to make informed scientific based decisions on future modifications of the WWTP as well as
options for the Town of Canton to provide treatment of wastewater generated and collected by the Town of
Canton.
We appreciate your attention to these comments. If you need additional information, please contact me at
828-648-2363 or lstinnet0cantonnc.com.
Respectful) .,
nMr
Li Stinnett
Town Manager
Town of Canton