NC0000272_Compliance Report_20230317

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September 30, 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: Noncompliance Report
Blue Ridge Paper Products, Inc. dba Evergreen Packaging
Canton MITI - Permit No. NC0000272
Dear Mr. Davidson:
This document serves as the written submission requirement found in NPDES permit N00000272
Part il, Section E, 8. and 9.
The following represents the current findings of the Investigation and analysis of the
noncompliance event that was reported to your office on September 26, 2022. If and when
additional or corrected Information becomes available, subsequent reporting will be provided.
Note—all the following dates are 2022.
Descrtotion
On Friday, September 16, operators recorded an increase in secondary effluent TSS to 5,026
N/day, whereas the average Is about 2,500 *day. On Saturday, September 17, the secondary
effluent TSS was further elevated to 19,280 Wday. With no other indicators of upset Conditions
In the mill or the Waste Treatment Plant this condition appeared to be consistent with a Fall turn-
over. We have experienced such tumovers In the pest during the transition from warm summer
to cooler Fall. The changes In high and low outside temperature on any given day cause
inefliclencles as the bacteria find it difficult to adjust to temperature swings In bodies of water like
the secondary clarifier. These swings will cause the basins to turn over and cause heavy solids
cany�cver at the effluent weirs, accompanied by a foul smell often associated with hydrogen
sulfide gas. Operators Introduced flocculent polymer to the secondary and of the plant to assist
with poor settling. The next two days, September 181h and 1e. the secondary effluent TSS
dropped back to normal levels with the polymer addition to 2,577#/day and 2,577 lNday.
On Monday September 19, at approximately 12:00 pm, wastewater treatment plant (WTP)
operators noted an unusual decrease In dissolved oxygen at the effluent end of the aeration basin
and began Investigating the cause. There was no Indication of pulping liquor, foul condensate,
or soap loss at that time. Operators Introduced supplemental oxygen at the primary spiltter box
to increase the dissolved oxygen level In the aeration basin. Analysis showed that the decreased
dissolved oxygen levels were contained in the aeration basin by 5:00 pm on that day with

dissolved oxygen levels normal, at about 2 mgll upstream in the waste treatment plant. The next
morning the oxygen levels were still low In the aeration basin and Recovery and Utilities
Department personnel found no indication of chemical loss that would have contributed to
increased oxygen demand. Operators continued to feed supplemental oxygen throughout the day.
On Wednesday, September 21, the oxygen levels In the aeration basin showed a marked
Increase, and by 1:00 pm, levels were back to normal. SOD samples were collected and set for
the Flve-day incubation period and analysis. BODs that were collected on Monday, September
19 were within the normal range. BODs that were collected on Tuesday, September 20 were
analyzed on Sunday, September 25 and operators reported 16,187 # BOD in the secondary
effluent against a 10,897#/day limit. On September 26,the WTP Operator in Responsible Charge
(ORC) contacted Dan Boss (Division of Water Resources) in the Asheville Regional Office to
report the exoeedanoe.
Efforts are currently ongoing to identify the source of the BOD. Conditions In the serstlon basin
have remained within the normal range upon the rebound on September 21. The results for the
Five-day BOD samples that were collected and set for later analysis on September 25 are still
pending, and will be reported upon receipt. All other parmh4lmlted parameters have remained in
compliance during this period. In addition to normal sample collection rounds, river Inspections
were conducted by the ORC on a daily basis beginning September 19 through September 25.
Sample analysis and inspection findings confirmed water quality was within permit limits and no
Impacts to the fish population were noted.
Cause
At the time of this notification, mill personnel are investigating the source of the cause of the event.
All possible sources of oxygen demanding materials are being investigated. To date, there has
been no Indication of pulping liquors or soap to be the cause. Other potential secondary sources
Including the use of flocculent polymers as part of the Fall turnover are being investigated as we
have no definitive cause at this time.
Period
Effluent monitoring data results Indicated the 001 discharge was compliant with permit limits
throughout the event tlmefreme, except the BOD, which was not available for review, until
September 25. Effluent BOD Is the only parameter found to be greater than permit limits from the
event. Dissolved data indicated that the oondlflon began around noon on September 19 and
ceased on September 21 (at approximately 8:00 am0. Effluent BOD returned to compliance on
the samples that were collected on September 21 and submitted for analysis on September 26
and remain In compliance at the time of this notification.
Corrective Action
Upon communication from Wastewater Treatment Plant operators of an increase in secondary
effluent TSS, operators began introducing flocculent polymer to aid in settling. When operators
became aware of the decrease.In dissolved oxygen in the aeriation, supplemental oxygen was
Immediately Introduced to the system to reduce the impact, and all aerators were run on the
highest settings available. At the same time, the operators began their investigation.
Process personnel have increased Inspections, and evaluations of containments, sumps and
other equipment associated with liquor, foul condensate and soap handling.

Steps to Reduce. Eliminate and Prevent Reoccurrence
We will perform a review of the conditional changes during the transition from Summer to Fall to
better understand the process and to Investigate ways to mitigate upset conditions.
We will update your office as soon as possible with updates to the foregoing Information.
Respectfully,
Tracy iiils John McCarthy
Wastewater Treatment Plant ORC General Manager
Canton Mill Canton Mill
%r"lpactivevercreen.com iohn.mccarthvrizpactivevercreen com
Phone: [phone]/Mobile: 828-424gN5