NC0000272_Correspondence_20180518

Doing Business in California as Evergreen Beverage Packaging

\\everpack\ca\EOHS\SHARE\Water Files\Nick's Water Files\DEQ

May 18, 2018

Landon Davidson
Asheville Regional Supervisor
Division of Water Resources
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778

Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton, Haywood County, North Carolina
Daily Max Fecal Coliform Exceedance, 04/24/2018.
NPDES Permit: NC0000272

On April 24, 2018, Evergreen Packaging collected a permitted weekly fecal coliform sample
from our secondary effluent flume. Additionally, samples were taken from the Town of
Canton’s Influent as well as the Up-stream location as an indicator of river conditions leading
into the Mill. The samples were processed and sent to ETS for analysis. On April 25th, 2018
Evergreen Packaging received a preliminary analysis via email from ETS which indicated >600
col/100ml at the permitted secondary effluent sampling location. The results also indicated that
the upstream river conditions also contained the same fecal coliform concentrations at >600
col/100ml while the Town of Canton’s Influent results showed 20 col/100ml.

An investigation in the cause of the exceedance was initiated and two issues were identified.
One that was believed to be the most plausible was high river levels. The Mill experienced
nearly three inches of rain fall and river levels were elevated more than average and as such, the
mill’s intake pumps increase their back flushing rate. All back flushing waters goes directly into
the 4A sewer. The 4A sewer goes directly into the low lift. Essentially the river water used for
back flushing goes untreated directly into the low lift. As stated previously, the river conditions
demonstrated fecal coliform levels of >600 col/100 ml which was identical to what Evergreen’s
secondary compliance sample was >600 col/100 ml. Evergreen collected a sample on April 26,
2018 at the 4A manhole once the river levels had subsided to evaluate the fecal coliform readings
and sent them to Statesville Analytical. The results for fecal coliform was <1 CFU/100ml.
Moving forward, Evergreen Packaging will ensure that a representative sample of its operation
will be collected within the allowable timeframe to collect the sample.

As part of the actionable items working with the Town of Canton in the identification of possible
Fecal/coliform sources internal to the Mill, an evaluation of Mill sewer lines as well as sump
areas have been initiated. Upon initial notification by ETS of our Fecal/Coliform exceedance,
the WTP management team further continued the efforts to examine any influent lines coming
NCDWR Page 2
into the WTP that may or may not carry a fecal/coliform source. A sewer line was identified in
our records many years ago (2012) as having a breach that required a repair/replacement in the
line. The WTP management inspected the general area where the line resides and found no
evidence of line disruption. Due to the excess rain, while performing the analysis, the WTP
management identified the storm water runoff basin had water in it that comes from around the
pine chip pile. This basin flows directly into the #3 clarifier and so the WTP Management team
collected a sample on April 26, 2018 to test for fecal/coliform. The results showed >6000
CFU/100ml. Upon review of historical records, it was found that during elevated rain events,
Champion/Blue Ridge Paper would add chlorine tablets in a bucket with holes in it to allow for a
slow dissolve just at the discharge of the basin and before it could be sent to the #3 clarifier. The
WTP management applied this method of treatment to the basin and resampled on April 27,
2018. The results showed <1 CFU/100ml.

It should be further noted that on April 24, 2018, Evergreen Packaging at the compliance
location performed a E.coli analysis as well and the results indicated as follows: S.A. E. coli
(10) 100ml mpn. Evergreen Packaging is working with BCN to establish a process to delineate
the E.coli species but this process is taking a longer to get worked out than anticipated.
Evergreen is working with local certified laboratories to determine if they can perform this
testing and meet the hold time for future needs and will keep the Regional office informed of the
progress. Any additional observations found during the identification/evaluation of sources as
outlined in the FISS Environmental RFQ between the Town of Canton and Evergreen Packaging
through the partnership of DWR Regional Office will be submitted in writing as part of the
continuing effort to seek resolution of the fecal/coliform issues.

Evergreen Packaging received the official results of the Fecal/Coliform tests on May 4, 2018 and
on May 8, 2018, the Regional Office of DWQ was informed of the information contained in this
letter. Should additional information be request, please contact me.

Sincerely,

Jacob Trantham
WWTP Supervisor
Evergreen Packaging – Canton Mill
828-646-2365
[e-mail]