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HomeMy WebLinkAboutNC0000272_Correspondence_20221219p of v° 175 Main Street Canton, NC 28716 828.646.2000 pactivevergin•mm VIA EMAIL —'NO HARDCOPY TO FOLLOW December 16,.2022 Mr. Landon Davidson Regional Supervisor Division of Water Resources —Asheville Regional•Office North Carolina Department of Environmental Quality 2090 US Hwy 70 Swannanoa, North Carolina 28778 Subject: Response to your questions related to Soap Blue Ridge Paper Products, Inc. dba Evergreen Packaging Canton Mill - Permit No. NC0000272 Dear Mr. Davidson: I am writing in response to your email, dated November 18, 2022. Below are the answers to your questions. Please let me know If you need anything else: A descriptive narrative of the following items as they pertain to soap: o Generation — Soap is the organic material left in the black liquor after it Is used In the chip digesting process. Black liquor Is heavier than soap and settles to the bottom of the tank. Soap is then collected, or skimmed, from black liquor tanks for use in the Trostol Oil Making process. o Storage — Soap is In 14 tanks in the facility. The amount of soap in each tank varies depending on multiple process variables. o Fate — See attached documents (Soap and Tall Oil Overview, Tall Oil Skimming Training) o Summary of recent introductions to WWTP — see the attached document "2022 BMP LMS Training.2022.05.18", specifically slides 27 — 31. • Inventory tracking: o Tanks that solely contain soap have level indicators that allow accurate real-time inventory tracking. o Tanks that contain a mixture of soap and other materials are monitored for total volume, but not by separate material. o During normal operations, a release of soap from containment would be discovered by visual inspections of process areas by operators, remote visual monitoring of areas that have cameras, and by WWTP operators monitoring the color of the primary influent to the WWTP. o During a shutdown situation, all of the above methods remain In place. Status of Corrective Actions: o Operator training and communication updates as they relate to avoiding discharge of soap in the WWTP. Complete. o Remote visual monitoring of the pine weak liquor storage area.:.Complete. .• o Improvement to communication of process changes which could indicate possible soap discharges. Complete. o Improved secondary containment to prevent discharge of soap. Complete. Please reach out to Tracy Willis if you have any further questions. Respectfully, John McCarthy Mill Manager Canton MITI John.McCarthv@oactIvevervreen.com Tracy Willis cc: Tim Heim Tracy Willis Wastewater Treatment Plant ORC Canton Mill — (828) 424-9955 Tracv.WiIIist pactIveverareen.com Canton Mill Page 2 of 2