NC0000272_NOV-2019-LV-0014 Response_20190514

evergreen, Canton Office
packaging
May 14, 2019
Certified Mail: 7015 0640 0004 4331 7522
Return Receipt Requested
Mr. G. Landon Davidson, P.G., Regional Supervisor
North Carolina Department of Environmental Quality
Division of Water Resources — Water Quality Regional Operators Section
2090 US 70 Highway
Swannanoa, North Carolina 28778-8211
Subject: Notice of Violation — Formal Response
Tracking Number: NOV-2019-LV-0014
Permit Number: NC0000272
Blue Ridge Paper Products (d.b.a. Evergreen Packaging) — Canton Mill
Haywood County
Dear Mr. Davidson,
The facility provided information on this exceedance in the July, 2018 eDMR. A more detailed
response follows:
On July 24, 2018, Evergreen Packaging (EP) exceeded the secondary effluent fecal coliform
daily limit of 400 colonies per 100 ml, with a result of greater than 600 colonies per 100 ml. On
that day, the Town of Canton (TOC) effluent showed a fecal coliform of greater than 60,000
colonies per 100 ml. At the time of the exceedance, the TOC failed to properly disinfect the
influent that entered into the EP Waste Water Treatment Plant (WWTP). Additionally, EP
identified a source of fecal coliform within the contained mill chip system storm water collection
system.
The TOC maintains a chlorine injection system on the EP property that is designed to
completely disinfect the TOC effluent prior to its introduction into the EP WWTP. EP
employees check the TOC effluent hourly for chlorine residual. In the 24 hours preceding the
sample collection time the chlorine residual ranged from zero to ten mg/1, with zero residual
demonstrating insufficient disinfection. The current design of the TOC system does not provide
an adequate contact time to properly disinfect the TOC effluent. It has been expressed to the
TOC the need for a different chemical that requires a shorter contact time.

Following the exceedance on July 24, 2018 the investigation into the cause revealed higher
than normal levels of fecal coliform in the EP wood chip area storm water collection system. It
was determined that a sanitary sewer line that serves the chip system area had ruptured. This line
break allowed fecal matter to enter the waste water treatment system. The chip system sanitary
line was replaced. Following the replacement, no fecal coliform have been noted from the chip
system area.
In the weeks and months following this exceedance, there have been numerous conversations
and two meetings with the TOC in which proper disinfection of the influent is the central topic of
discussion. There is a plan in place for the TOC to run a trial of Peracetic Acid (PAA) as a
supplemental disinfection resource with hopes that the results will be such that the current
chlorine system can be replaced and PAA used as the sole means of TOC effluent disinfection.
One of the benefits of the PAA system is a shorter required contact time. The TOC has assured
EP that the PAA trial will be underway no later than June 1, 2019. EP strongly believes that
these efforts will eliminate fecal coliform exceedances in the future.
EP is dedicated to working with the TOC and the State of North Carolina to protect state water
resources and can assure you that all efforts are being made to avoid future fecal issues.
If I can answer further questions, please feel free to contact me.
Thank you,
Ali
Tracy Wi r1is
Waste Water Treatment Plant Operations Supervisor / ORC
NCWPCS Waste Water Grade 4 Certificate # 998768
tracy.willis(a)everpack. com
office: 828.646.2874
cell: 828.424.9955
CC:
Matthew Claypool — EPLLC
Michael Ferguson — EPLLC
Scott Bragg - EPLLC