NC0000272_EPA DWM Lead Relic Sewer Investigaiton_20230503

INTERIM WORK PLAN
WEST BANK SEWER INVESTIGATION
PACTIV EVERGREEN CANTON MILL
CANTON, NORTH CAROLINA
EnSafe Project Number
0888834351
Prepared for:
pactiv
-�
evergreen
Pactiv Evergreen
175 Main Street
Canton, North Carolina 28716
April 27, 2023
313 Wingo Way
Mount Pleasant, South Carolina 29464
843-884-0029 1 800-588-7962
www.ensafe.com
MSAFE
creative thinking. custom solutions.°

INTERIM WORK PLAN
WEST BANK SEWER INVESTIGATION
PACTIV EVERGREEN CANTON MILL
CANTON, NORTH CAROLINA
EnSafe Project Number
088834351
Prepared for:
pactiv
=
evergreen
Pactiv Evergreen
175 Main Street
Canton, North Carolina 28716
April 27, 2023
Prepared by: Reviewed by:
Travis Darden, PG Steven Hodskins, PE
Project Manager Project Engineer
313 Wingo Way
Mount Pleasant,South Carolina 29464
843-884-0029 1 800-588-7962
www.ensafe.com
MSAFE
creative thinking. custom solutions.

TABLE OF CONTENTS
1.0 INTRODUCTION..............................................................................................................1
2.0 KEY CONTACT INFORMATION .........................................................................................2
3.0 SITE DESCRIPTION AND HISTORY...................................................................................4
3.1 Incident Background Summary..............................................................................4
3.2 East Bank Abandoned Sewer Structures.................................................................5
3.3 West Bank Abandoned Sewer Structures................................................................5
3.4 Updated Conceptual Site Model.............................................................................6
4.0 PROPOSED FIELD ACTIVITIES.........................................................................................7
5.0 DATA COLLECTION/REPORTING......................................................................................9
6.0 PROJECT SCHEDULE ..................................................................................................... 10
7.0 REFERENCES ................................................................................................................ 11
FIGURES
Figure 1 Site Location Map
Figure 2 Site Map
Figure 3 Westbank Sewer Investigation
Figure 4 Westbank Abandoned Sewer Structures
Figure 5 Conceptual Site Model
Figure 6 Levee Cross Section Schematic
APPENDICES
Appendix A Photographic Log

Interim Work Plan— West Bank Sewer Investigation
���� Pactiv Evergreen—Canton Mill
Canton, North Carolina
April 27, 2023
1.0 INTRODUCTION
This Interim Work Plan describes additional assessment efforts tangentially associated with a release
of fuel oil at Pactiv Evergreen's (PTVE) Canton Mill (Site) at 175 Main Street in Canton, North Carolina
(location and site maps are included as Figures 1 and 2, respectively). The primary objective of this
scope of work is to close data gaps within the conceptual site model (CSM) regarding any
anthropogenic pathways that would facilitate the migration of fuel oil beneath the Pigeon River.
Field work activities will be conducted in the abandoned sewer structures along the west bank of the
Pigeon River in an attempt to confirm or dispel the existence of any abandoned sewer infrastructure
routed under the Pigeon River. Though no official documentation has been uncovered to date, it has
been suggested that the west bank sewer structures in question may have once been connected to
a portion of the City of Canton sewer system via piping routed beneath the river from the levee
manhole cistern (LMC) on the east bank of the river, as depicted on Figure 3. The abandoned lines
on the eastern side of the Pigeon River have been scoped from the LMC to an area near the riverbank
via a remote camera; however due to obstructions/collapse of the lines, the extent and route of the
piping remains unknown. Furthermore, an attempt was made from the river's west bank to trace the
abandoned sewer lines back towards the river with limited success. Activities described herein will
be performed in general accordance with industry standards and, if applicable, the North Carolina
Department of Environmental Quality Division of Waste Management's Underground Storage Tank
(UST) Section guidance.
This Interim Work Plan has been prepared in accordance with general industry standards, and is
organized as follows:
• Section 2: Identifies key project personnel
• Section 3: Provides an overview of the Site history
• Section 4: Describes proposed field activities
• Section 5: Summarizes data collection, reporting procedures, and quality assurance measures
• Section 6: Presents the tentative project schedule
• Section 7: Identifies references cited in this Interim Work Plan
Figures and supporting appendices are included at the conclusion of the text.
I

Interim Work Plan— West Bank Sewer Investigation
���� Pactiv Evergreen—Canton Mill
Canton, North Carolina
April 27, 2023
2.0 KEY CONTACT INFORMATION
Contact information for PTVE's designated personnel is as follows:
Ms. Alison Vincent
Regional Environmental Manager
[e-mail]
Mr. Charles Howell
Environmental Manager, Water and Waste Programs
[e-mail]
EnSafe Inc. will provide technical support and oversight for PTVE on this project. An EnSafe
project manager and project engineer will serve as the primary points-of-contact and provide
status updates if requested. The Site's safety and health officer/field manager will ensure tasks are
conducted in accordance with this Interim Work Plan and the Health and Safety Plan and will maintain
field documentation. Contact information for key EnSafe personnel is as follows:
Mr. Phil Coop
Senior Project Liaison
901-937-4229 (office)
901-833-3471 (mobile)
[e-mail]
Mr. Travis Darden, PG
Project Manager
843-884-0029 (office)
843-708-1601 (mobile)
[e-mail]
Mr. Steven Hodskins, PE
Project Engineer
843-884-0029 (office)
706-455-7556 (mobile)
[e-mail]
2

Interim Work Plan— West Bank Sewer Investigation
���� Pactiv Evergreen—Canton Mill
Canton, North Carolina
April 27, 2023
Mr. Jennings Kerr, PG
Site Safety and Health Officer
843-884-0029 (office)
843-568-8823 (mobile)
[e-mail]
Mr. Mark Love
Field Team Leader
843-884-0029 (office)
717-448-0434 (mobile)
[e-mail]
Ms. Savannah Craig
Data Specialist
843-884-0029 (office)
864-395-7175 (mobile)
[e-mail]

Interim Work Plan— West Bank Sewer Investigation
���� Pactiv Evergreen—Canton Mill
Canton, North Carolina
April 27, 2023
3.0 SITE DESCRIPTION AND HISTORY
The Canton Mill has been in operation at its current location since 1908. The mill was operated
by Champion International (now International Paper) from 1908 — 1999. In 1999, the mill was sold
to Carolina Paper, which later became Blue Ridge Paper Products. Evergreen Packaging purchased
the Canton Mill from Blue Ridge Paper Products in 2007. Evergreen Packaging and Pactiv merged to
become PTVE in September 2020. Fuel Oils stored at the Site are used to heat boilers and kilns as
part of the paper-making process and as an energy source for mill operations.
3.1 Incident Background Summary
No. 6 Fuel Oil has been stored in two aboveground storage tanks (ASTs) within a containment bunker
on the south side of the facility, on the east bank of the Pigeon River, since the late 1960's. In 2018,
No. 6 Fuel Oil was removed from the 500,000-gallon AST and replaced with No. 2 fuel oil
(dyed diesel). No. 2 fuel oil continues to be stored in the 500,000-gallon AST and No. 6 fuel oil is
stored in the 210,000-gallon AST. Steam was used to heat the No. 6 fuel oil in the tank. As the
temperature of the fuel oil increased, the viscosity decreased, allowing product to be pumped where
required around the Site. To keep the temperature of the fuel oil high enough for pumping,
steam lines were collocated with the fuel oil overhead delivery lines. Fuel oil has been observed in
monitoring well PZ-16, situated just north of the AST containment bunker, on a continuous basis
since 2018 as part of long-term, semi-annual monitoring events associated with the black liquor
response action (AECOM reports, various dates).
In June 2021, droplets/globules of petroleum and associated sheens were observed approximately
350 feet northwest of the AST containment bunker, along the east bank of the Pigeon River, as
depicted on Figure 3. The applicable regulatory agencies were notified of the release, and abatement
activities were immediately implemented by PTVE. Response activities continued until flooding
associated with Tropical Storm Fred severely eroded the riverbank at the Site in August 2021.
Booms were redeployed after the flood as weekly inspections noted trace amounts of residual oil
along the riverbank.
A second Notification of Discharge was submitted to North Carolina Department of
Environmental Quality on August 18, 2022, in response to what appeared to be a reactivation of the
seep when heavy oil was again identified at the base of the riverbank in the same general location
the 2021 seep. Additional booms were deployed for containment while emergency response and
recovery activities were implemented.
4

Interim Work Plan— West Bank Sewer Investigation
���� Pactiv Evergreen—Canton Mill
Canton, North Carolina
April 27, 2023
3.2 East Bank Abandoned Sewer Structures
During subsequent assessment efforts in late August 2022, an abandoned sewer line was identified
running northwest-southeast beneath the AST containment bunker and the protection levee to the
LMC inland of the seep (Figure 3). Access into the buried pipe was made via two manholes situated
along the abandoned sewer line, one within the containment bunker and the other at the LMC.
An initial video inspection was conducted from the manhole within the AST containment bunker
(the presumed source area) and was performed to determine the integrity of the line and evaluate
the sewer pipe as a potential migration pathway for oily water observed in the LMC. The remote
camera inspection video and still images suggested oil may be entering the abandoned line near the
ASTs along seams and in places where the terracotta sewer pipe was compromised. Further video
inspection showed the line to be blocked at approximately 131 feet north (down river) of the AST
containment bunker manhole (Communications from Evergreen, January 2023).
An additional remote camera inspection was conducted from the LMC where contact water and oil
flowed within the abandoned line, parallel to the river, from the direction of the ASTs and into the
structure. Once in the LMC, the oily water would be rerouted 90 degrees through two pipes
positioned directly towards the river. Video inspection of these two pipes indicated the piping is
compromised in places and it is unclear if the piping continues beneath the riverbed to the west bank
of the Pigeon River (Communications from Evergreen, January 2023). To eliminate additional oil
from entering the abandoned pipes and to thwart further migration, the two lines were plugged from
within the LMC by PTVE in the fall of 2022. Details regarding prior field investigations along with the
subsequent findings are presented in a Technical Memorandum — Summary of Response Actions
(EnSafe, March 2023).
3.3 West Bank Abandoned Sewer Structures
After scoping the abandoned lines on the eastern bank failed to determine the extent of the lines in
the direction of the river, PTVE deemed it plausible that the lines, at some point, may have continued
beneath the river to the wastewater treatment plant (WWTP) on the opposite bank. Though there
is no known documentation of the existence of subaqueous piping from the LMC under the river to
the WWTP, as a precaution, PTVE, requested responders investigate whether the piping in question
could be located on the western side of the river and traced back under the river to the eastern bank.
During this phase of the investigation an abandoned sewer structure (manhole) was located on the
west bank of the river in line with the seep on the opposite bank. Responders were able to access
the manhole, remove the debris from the abandoned structure, and make entry into the
confined space. No piping was observed inbound from the direction of the river. Piping was,
however, noted running parallel to the river as depicted on Figure 4.
5

Interim Work Plan— West Bank Sewer Investigation
���� Pactiv Evergreen—Canton Mill
Canton, North Carolina
April 27, 2023
3.4 Updated Conceptual Site Model
Residual fuel oil near the AST containment bunker and PZ-16 appears to be migrating via an
abandoned sewer line that extends northwest, parallel to the protection levee, terminating at the
LMC. Mobile product has not been identified in recovery wells RW-6 and RW-7, along the path of
the abandoned sanitary sewer line. The absence of mobile product in these recovery wells suggests
that impacts due to residual fuel oils are limited, and that the abandoned sewer line or immediate,
adjacent fill is most likely serving as a pathway for fuel oil migration. The lack of significant migration
laterally from the sewer line is consistent with the physical characteristics of residual fuel oils.
As depicted on Figures 5 and 6, this CSM presumes migration has occurred primarily along the
abandoned sanitary sewer line, both within residual voids in the crushed line, and possibly in backfill
around the line.
Residual fuel oil is present in the northernmost portion of the abandoned sanitary sewer line,
specifically in the LMC, approximately 400 feet northwest of the AST containment bunker. This CSM
presumes that residual fuel oil inflow into the LMC now (and in the future) will be associated with
residuals that infiltrate the abandoned sewer line proximal to the ASTs.
The presence of fuel oil residuals in sands, gravels, and cobbles beneath the access road at the
base of the levee appear to be associated with abandoned sewer line segments emanating from
the LMC. This CSM presumes that any migration of fuel oil beneath the levee likely occurred within/
along the abandoned lines from the LMC and within the adjacent highly permeable cobbles observed
in the base of the test pits completed during the February 2023 investigation. To eliminate additional
oil from entering the abandoned pipes and to thwart further migration, the two lines were plugged
from within the LMC by Evergreen in the fall of 2022.
6

Interim Work Plan— West Bank Sewer Investigation
���� Pactiv Evergreen—Canton Mill
Canton, North Carolina
April 27, 2023
4.0 PROPOSED FIELD ACTIVITIES
As previously stated, the current CSM presumes that any migration of heavy fuel oil that occurred
from the LMC, beneath the access road, and ultimately to the seep, would likely have occurred within
or along the two abandoned pipes. The purpose of the proposed field activities, as described herein,
is to close data gaps within the CSM regarding the presence and extent of any existing anthropogenic
features (abandoned sewer lines) that could allow for fuel oil to pass beneath the Pigeon River and
potentially impact the riverbed and areas along the western bank. Table 1 summarizes the data gaps,
action items implemented to date, and the subsequent findings or additional measures needed to
resolve any perceived CSM deficiencies.
Table 1
Data Gaps,Action Items,and Findings
Existence and Possible Route of An Abandoned Sewer Line Beneath the Pigeon River
Data Gap Action Items Findings
Lines were compromised in placed and
The lateral extent of two of the Removed oil and oily debris from LMC. ultimately completely collapsed blocking
abandoned sewer lines between the LMC CSE made in LMC. the camera from advancing.
and the eastern riverbank Lines scoped with remote camera. Unable to determine if lines continued
under river.
Unable to locate any pipes coming from
river.
Located an abandoned sewer structure Located abandoned pipes running,
(manhole)on the west bank in line north/south,parallel to the river that
The existence/location of the sewer lines with seep on the opposite bank. may lead to other abandoned sewer
on the west bank of the river Removed debris from sewer structure. structure and lines immediately upriver
CSE made in abandoned sewer to the north.
structure on the west bank. The location of the sewer structure and
schematic based on observations from
the CSE can be found on Figure 4.
Locate potential additional access
points based on earlier west bank
sewer investigations.
Presence or absence of piping from Remove any debris from sewer beneath the river toward the abandoned structure to allow for access.prepare for CSE into relevant TBD
sewer structures along the west bank
abandoned sewer structures.
During CSE utilize a remote camera to
scope any additional sewer lines that
may cross beneath the Pigeon River.
Notes:
LMC = levee manhole cistern
CSE = confined space entry
TBD = to be determined
Further Assessment of West Bank Sewer Structures
As discussed in Section 3.3 and depicted on Figure 4, in the fall of 2022, responders entered an
abandoned sewer structure along the west bank of the Pigeon River with the intent to trace any
sewer lines running in the direction of the river back towards the seep area on the opposite bank.
No such lines were observed; however, lines were noted running in a general north/south direction,
7

Interim Work Plan— West Bank Sewer Investigation
���� Pactiv Evergreen—Canton Mill
Canton, North Carolina
April 27, 2023
parallel to the river. This Scope of Work will focus on the removal of debris, accessing and subsequent
confined space entry, and exploration of a newly identified structure just north of the structure
inspected in the fall of 2022. Further investigative efforts via remote camera scoping may facilitate
refinement of the CSM as to the presence or absence of piping beneath the river. A photo log has
been included as Appendix A to serve as a visual reference to the ongoing abandoned
sewer investigations.
It should be noted that drawings from 1941 indicate that sewer lines from the town of Canton to the
east and lines from the opposite bank empty directly into the river along their respective sides.
A WWTP for the mill was brought online in 1959. It wasn't until 1964, after the mill expanded the
treatment facility, that the town entered into an agreement for the treatment of its sewage. It is
believed that the town constructed a new sewer line to the WWTP, crossing over the river along the
Park Street bridge. To date, definitive evidence of sewer lines crossing beneath the Pigeon River has
yet to be discovered.
8

Interim Work Plan— West Bank Sewer Investigation
���� Pactiv Evergreen—Canton Mill
Canton, North Carolina
April 27, 2023
5.0 DATA COLLECTION/REPORTING
During field activities, EnSafe will collect pertinent information and observations for each phase
of work. Such information may include sample location coordinates (+/- 3-meter accuracy,
if applicable), photographs, field note logs, and other information deemed relevant.
At the completion of each phase of work or task, EnSafe will provide updates via the SharePoint Site
with all relevant data. Due to the nature of the unknowns associated with subsurface investigation
and assessment efforts, this Interim Work Plan and Health and Safety Plan may be amended to
address field conditions.
9

Interim Work Plan— West Bank Sewer Investigation
���� Pactiv Evergreen—Canton Mill
Canton, North Carolina
April 27, 2023
6.0 PROJECT SCHEDULE
Field activities related to this scope of work will commence as soon as practical, pending approval.
Field activities are anticipated to last roughly 2 days. The project schedule is subject to change based
on access limitations and/or unfavorable weather conditions.
10

Interim Work Plan— West Bank Sewer Investigation
���� Pactiv Evergreen—Canton Mill
Canton, North Carolina
April 27, 2023
7.0 REFERENCES
AECOM. Semi Annual Groundwater Sampling Reports, Pactiv-Evergreen Site. Various Dates.
Champion Paper. Topographic Map for Flood Control. 1941, May 22.
— Agreement for Wastewater Treatment Contract. 1964, February 28.
EnSafe Inc. Technical Memorandum Summary of Response Actions. Pactiv Evergreen Canton Mill,
Canton, North Carolina. March 2023.
— Fuel O// Investigation Health and Safety Plan. Pactiv Evergreen Canton Mill,
Canton, North Carolina. April 2023.
Evergreen Packaging. Notification of Discharge(Form UST-62). 2021, June 8.
— Notification of Discharge (Form UST-62). 2022, August 18.
— Communications re: abandoned sewer inspections January 2023.
North Carolina Department of Environmental Quality. UST Section Assessment Guidelines,
Petroleum and Hazardous Substance UST Releases, Petroleum Non-UST Releases.
2021, January 19.
— Comprehensive Tab/es for Corrective Action Guidelines, Petroleum and Hazardous
Substance UST Releases, Petroleum Non-UST Releases 2021, January 19.
— Guidelines for Site Checks, Tank Closure, and Initial Response and Abatement,
Petroleum and Hazardous Substance UST Releases, Petroleum Non-UST Releases.
2021, May 17.
11

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Source:Google Earth Pro Imagery-04/2022

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UNDERGROUND UTILITIES
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POSSIBLE ROUTE OF SEWER LINE BENEATH RIVER DATE: 4/6/2023 creative thinking.Customsolubons.
SCALE IN FEET PROJECT: 0888834351 800.188.7962 Iwvaw.ensafe.com
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Source:Google Earth Pro Imagery-04/2022;Contours-derived from LIDAR point clouds from https://apps.nationalmap.gov/

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SCALE IN FEET PROJECT: 0888834351 800.188.7962 Iwvaw.ensafe.com
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Source:Google Earth Pro Imagery-04/2022;Contours-derived from LIDAR point clouds from https://apps.nationalmap.gov/

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a
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INFERRED SANITARY SEWER DRAWN BY: KPB PROJECT #: 0888834351

CROSS SECTION OF PROTECTION LEVEE CROSS SECTION ACROSS LEVEE FROM
ALONG ABANDONED SEWER LINE FROM ASTs TO RW-6 LEVEE MANHOLE CISTERN TO SEEP
DOWN RIVER UP RIVER
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RIVER BANK OILED SEDIMENTS— '
I —
2570 L J INFERRED ♦ ♦��---
SEWER LINES OIL IN 2570
PZ-16 SEEP
APPROXIMATE APPROXIMATE
256 RIVER RIVER ELEVATION ABANDONED
256 INBOUND LINE
ELEVATION
FROM AST AREA
2565 FUEL OIL
2565
2560
2560
3
O
FIGURE 6
LEVEE CROSS SECTIONS SCHEMATIC
PACTIV EVERGREEN CANTON MILL
CANTON, NORTH CAROLINA
LEGEND NOTE REQUESTED BY: TD msmr
G MONITORING/RECOVERY WATER TABLE(INFERRED) RESIDUAL FUEL OIL(INFERRED FROM 2023 DATA SET) AST ABOVEGROUND STORAGE TANK ALL ELEVATIONS ARE APPROXIMATE DRAWN BY: KMB
WELL SCREEN �� OIL WATER MIXTURE MIGRATES THROUGH — — — REFER TO FIGURE 3 FOR GENERAL LOCATION AND DATE: 3/31/2023 Creative thinking.Custom solutions.
5
ABANDONED SEWER LINE — — —IABANDONED SANITARY SEWER LINE ORIENTATION OF CROSS SECTION SCHEMATICS PROJECT: 0888834351 800.588.7962 www.ensafe.com

Appendix A
Photographic Log

Appendix A— Photographic Log ����
Pactiv Evergreen Canton Mill
Canton, North Carolina
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PHOTO NO. 1 View from the chip bridge across the Pigeon River looking south(upriver). Seep area is at left
DESCRIPTION: along the eastern bank. Levee Manhole Cistern is out of the image at middle left. The location of
any subterranean cross river piping would likely be proximal to the upriver collection boom set.
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PHOTO NO. 2 View from the west bank looking east along the likely route of inferred piping. Chip bridge is at left,
DESCRIPTION: containment boom has been deployed around the seep on the east bank.

Appendix A— Photographic Log ����
Pactiv Evergreen Canton Mill
Canton, North Carolina
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PHOTO NO. 3 Looking north(downriver). The Levee Manhole Cistern (LMC)is located on the landward base of
DESCRIPTION: the protection levee.
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PHOTO NO. 4 Oily water is being recovered from the LMC along the river's eastern bank.
DESCRIPTION:

Appendix A— Photographic Log ����
Pactiv Evergreen Canton Mill
Canton, North Carolina
PHOTO NO. 5 View from the seep area on the east bank looking across the river towards the wastewater
DESCRIPTION: treatment plant.
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PHOTO NO. 6 T
w from the seep area looking east at the protection levee in line with the location of the LMC.
DESCRIPTION:

Appendix A— Photographic Log ����
Pactiv Evergreen Canton Mill
Canton, North Carolina
1
PHOTO NO. 7 Responders preparing for confined space entry into an abandoned sewer structure along the river's
DESCRIPTION: west bank in the fall of 2022. Further investigations will be attempted in a newly identified sewer
access near the brick retaining wall in the far middle right of this image.
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PHOTO NO. 8 View inside the abandoned west bank sewer. No lines were observed running in the direction of
DESCRIPTION: the river and seep. Lines were noted running parallel to the river. This Interim Work Plan details
efforts to investigate an additional sewer structure immediately upriver along the referenced lines.

Appendix A— Photographic Log ����
Pactiv Evergreen Canton Mill
Canton, North Carolina
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PHOTO NO. 9 View of the potential sewer structure to be the focus of this scope of work. The abandoned sewer
DESCRIPTION: structure from the 2022 investigation can be seen in the extreme upper left of this image.
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PHOTO NO. 10 Attempts were made to locate a manhole cover within the inferred sewer structure to no avail.
DESCRIPTION: Investigations undertaken during this scope of work will likely require HyroVac excavations to allow
for access via CSE and subsequent remote camera scoping of any abandoned lines that may exist.