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Home My WebLink AboutNC0000752_NOV-2024-PC-0578 Response to Notice_20241012Smurfit Westrock Address line 1, Address line 2 Country, Post/zip-code Tel: +1 770-123-4567, Fax: +1 770-123-4567 info@smu rfitwestrock. com Kevin Fowler, Environmental Specialist Division of Water Quality Raleigh Regional Office, NCDEQ 3800 Barrett Drive, Suite 101 Raleigh, NC 27609 Dear Mr. Fowler: Subject: Notice of Violation, Tracking No. NOV-2024-PC-0332 C� S Smurfit c Westrock This letter is in response to the Notice of Violation (NOV), Tracking Number: NOV-2024- PC-0332, received at our post office box on October 22, 2024. The initial report call was made to Mr. Donald Smith at 11:55 AM on 9/12/2024, reporting the incident that occurred on 9/11/2024 from 5:00 to 5:50 PM. A five-day written report was emailed to Donald Smith on 9/16/2024 as required. It is important to note that the overflow did not reach surface water, nor did it contain sanitary wastewater. Part II Section 4.(c) of the mill's NPDES permit NC000752 is cited in the letter as the basis for the NOV. Part a. of that very Section states: "The Permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the provisions of Paragraphs b. and c. of this Section." As discussed below, no effluent limitations were exceeded and maintenance on the lift pumps was essential in order to return them to proper operation. The information below addresses the items requested in the NOV including, a system description, a description of the incident, the mill's immediate response and preventative actions that were taken. System Description The largest portion of the paper machine effluent flows to a sump where three lift pumps discharge to the mill sewer system which flows by gravity to the main sewer and ultimately to the primary clarifier. When there is an excess of paper machine effluent, the sump overflow is designed to flow into downstream drop inlets and ultimately to an underground pipe to a second lift station that has two additional lift pumps which in turn discharge to the main sewer. This station also collects some of the storm water in the area between the paper machines and the Utility trailer. Three pumps at the primary clarifier then lift the comprehensive main sewer flow to the main clarifier. Clarified effluent flows by gravity to the waste treatment ponds and discharges to the Roanoke River. Smurfit Westrock Address line 1, Address line 2 Country, Post/zip-code Tel: +1 770-123-4567, Fax: +1 770-123-4567 info@smurfitwestrock.com smurfitwestrock.com The Incident Smurfit Westrock The lift pumps for the paper machine sump failed due to a malfunction in the #3 paper machine dry end pulper break pump starter that was repaired the same day. This allowed the dry end pulper to overflow with pieces of paper. The paper clogged up the intake to the lift pumps in the beforementioned sump, which overflowed to the second lift station and the volume exceeded the capacity of those back up pumps. This caused the underground pipe to back up and overflow across a gravel trailer yard toward the mill's storm sewer. Immediate Response Maintenance began by safely locking out the pumps and cleaned the paper from the intake to the pumps. As soon as the first pump began operation, the sump overflow stopped. A diesel sump pump was concurrently used to pump the overflow process water and recover it to the mill main sewer system. When the second pump began operation, the accumulated water dried up and the overflows from both systems receded. While these activities were in progress, the Emergency Response Team began covering the storm sewer manholes to limit the amount of water entering the storm sewer. Another crew placed more sandbags into the surrounding storm sewer at the nearest culvert under some railroad tracks preventing passage downstream to the river. The next day, a vacuum truck was brought in, and the storm sewer was vacuumed, and the process water was returned to the mill waste treatment system. Preventative Actions Repairs were made to the PM3 dry end pulper break pump starter. A procedure was written and communicated on the proper handling of repulper malfunctions and protection against lift pump pluggage. An Eradicator was installed in the pump suction of the north lift pump to evaluate its effectiveness on preventing pump pluggage. This equipment will be installed on the two other lift pumps upon a successful evaluation. Sump level control system improvements have been made with alarms for early warning of upsets. Smurfit Westrock is very open to further correspondence for clarity or perhaps a face-to- face meeting would be advantageous to discuss the applicability and potential rescinding of the NOV. Paper I Packaging I Solutions Smurfit Westrock Address line 1, Address line 2 Country, Post/zip-code Tel: +1 770-123-4567, Fax: +1 770-123-4567 info@smurfitwestrock.com smurfitwestrock.com CDSmurfit Westrock We regret this incident occurred, but also reiterate no wastewater escaped to the river, no effluent limitations were exceeded, process water was returned to the waste treatment system, maintenance was required, and process equipment was restored to proper operation safely and efficiently within a very reasonable timeframe. If you have any questions or desire further information, please don't hesitate to contact our Environmental Manager, Mike Knudson at 252-326-5288 or mike.knudson@westrock.com Sincerely, Benjamrh P. White General Manager cc: Mike Knudson, Environmental Manager Jim Taylor, Manager Environmental Affairs Paper I Packaging I Solutions