NC0000272_NOV-2019-LV-0264 Response_20190514

evergreen.�I
packaging
May 14, 2019
Canton Office
Certified Mail: 7015 0640 0004 4331 7539
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-0264
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 February, 2019 eDMR. A more
detailed response follows:
On February 4, 2019, 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
7272 colonies per 100 ml. A subsequent investigation into the fecal coliform exceedance found
that the TOC drained and cleaned a water treatment plant settling basin the evening before at a
rate much faster than is their standard practice.
The TOC employee who drained the basin at a higher rate was new to the position and did not
understand the impact that the speed at which he drained the vessel would have on the hydraulic
load and the introduction of fecal coliform to the EP Waste Water Treatment Plant (WWTP).
The material in this settling basin is mud and organic material that is settled from river water as it
is being processed into drinking water. The result of this rapid dumping caused a period of at
least two hours in which there was no chlorine residual measure in the TOC influent into the EP
WWTP.

It has been EP WWTP experience in the past that the material that is received when settling
basins are drained has a very high chlorine demand, and it is difficult to maintain a chlorine
residual without adding additional chlorine during the drain. The hydraulic timing of the TOC
zero chlorine residual and the secondary effluent fecal sample collection coincides with the
higher fecal test result.
In working with the TOC following this exceedance, a small batch water plant disinfection
procedure has since been instituted in which chlorine is added at the source with discharge
chlorine residual testing completed before release. Additionally, the TOC Water Department
employees now call to inform EP when they plan to discharge settling basin material so that EP
can discuss the procedure and make sure all steps are taken to provide proper disinfection of the
influent prior to introduction to the EP WWTP.
In the weeks following this exceedance, there have been 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 influent disinfection. The TOC has assured EP that the PAA trial will be
underway no later than June 1, 2019. 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 water
resources and can assure you that all efforts are being made to avoid future fecal issues.
If I can be of further assistance, please feel free to contact me.
Thank you,
Tracy Willis
Waste Water Treatment Plant Operations Supervisor / ORC
NCWPCS Waste Water Grade 4 — Certificate # 998768
office: 828.646.2874
cell: 828.424.9955

CC:
Matthew Claypool — EPLLC
Michael Ferguson — EPLLC
Scott Bragg - EPLLC