In 2020, New-Indy Catawba began to convert its mill from manufacturing bleached white paper to unbleached containerboard. The white paper product historically manufactured by the facility was primarily used in advertisements, magazines, and other printed materials. Based on the steady decline in consumer demand for these products, New-Indy Catawba decided to convert its process to manufacture unbleached containerboard, which is used in boxes and other packages that are shipped through the mail. To complete the conversion process, major renovations and equipment upgrades at the facility were necessary. New-Indy Catawba hired a third-party contractor through an engineering, procurement and construction contract to oversee all aspects of the project. Once the project was completed, New-Indy Catawba reestablished its operations in February of 2021.

After restarting the manufacturing process, it was discovered that excess solids had been sent to the wastewater treatment system. This system had been minimally maintained by the mill’s prior owners, the extent of which did not become clear to New-Indy Catawba until after resuming manufacturing operations. This resulted in higher-than-normal hydrogen sulfide emissions from the wastewater treatment system.

March 1, 2021:
New-Indy Catawba (NIC) begins surface solids removal from the Aeration Stabilization Basin (ASB) and establishes a community service line for odor observations.

March 8, 2021:
Full mill odor survey is conducted by external consultant.

April 5, 2021:
NIC installs on-site hydrogen sulfide monitors for informational purposes.

April 16, 2021:
NIC submits a letter to South Carolina Department of Health and Environmental Control (S.C. DHEC) stating that it had retained a consultant to conduct an “expedited screening analysis” during the periods of March 16-18 and 23-25, 2021.

April 19, 2021:
NIC begins oxygen transfer supplementation in ASB.

May 3, 2021:
NIC brings foul condensate steam stripper back into service.

May 5, 2021:
NIC informs S.C. DHEC of steps taken to address the issues being discussed with S.C. DHEC.

May 24, 2021:
NIC installs on-site fence line hydrogen sulfide monitors in accordance with Environmental Protection Agency (EPA) regulations.

May 26, 2021:
NIC activates company landing page – newindycatawba.com.

June 7, 2021:
NIC installs Post Aeration Basin cover & carbon filter and activates two aerators and begins hydrogen peroxide treatment in the #1 Holding Pond. NIC also adds hydrogen peroxide and liquid oxygen to the ASB inlet.

June 14, 2021:
NIC adds ferric chloride to the #1 Holding Pond influent ditch.

June 28, 2021:
NIC and S.C. DHEC begin offsite hydrogen sulfide monitoring.

August 2021:
NIC conducts facility-wide air dispersion modeling analysis for total reduced sulfur, hydrogen sulfide and sulfur dioxide.

September 2, 2021:
Trim reflux condenser returned to service on the steam stripper.

September 13, 2021:
NIC initiates the use of a second dredge unit on the ASB to continue the removal of sub-surface solids.

September 17, 2021:
NIC received approval from S.C. DHEC for addition of hydrogen peroxide to the foul condensate hard pipe. Addition initiated on this date.

September 27, 2021:
NIC commences Equalization Stabilization Basin (EQ Basin) solids removal with an excavator.

October 8, 2021:
S.C. DHEC signs off on the final offsite Quality Assurance Protection Plan (QAPP) revisions. Both onsite and offsite QAPP’s are completed.

October 13-14, 2021:
NIC conducts sulfur dioxide testing on the two combination boilers.

October 26-29, 2021:
NIC conducts the fourth quarter 2021 Subpart S compliance demonstration testing.

November 5, 2021:
NIC Initiates operation of a hydrogen peroxide diffuser running the length of the #1 Holding Pond.

December 2, 2021:
S.C. DHEC approves the use of oxygen at the primary clarifier for hydrogen sulfide control at this unit.

December 6, 2021:
NIC expands the EQ Basin solids excavation activities with the use of three floating long-arm excavators.

December 21, 2021:
NIC submits pilot project requests to S.C. DHEC for the addition of ferric chloride to the primary clarifier underflow sludge stream and for the addition of oxygen to the #1 Holding Pond.

February 21, 2022:
Initiated oxygen addition to the ASB effluent.

March 27, 2022:
Initiated oxygen addition to the primary clarifier.

April 11, 2022:
Initiated ferric chloride addition to the primary clarifier underflow.

June 20, 2022:
Began operating a turbulator in the ASB, a device that adds oxygen to the water.

June 27, 2022:
Installed permanent PAB cover and filter system, which operates aerators continuously to ensure an adequate level of dissolved oxygen is present before effluent reaches the Catawba River.

Sludge from the EQ Basin is mechanically removed and transported to the #4 Sludge Pond where it is offloaded and leveled for drying. Subsurface sludge removed from the ASB is pumped into geotubes, which aid in the drying process. Once dried, the material is added to the #4 Sludge Pond surface. The sludge is managed per terms of the #4 Sludge Pond closure plan and section 10 of New-Indy Catawba’s wastewater treatment manual.

New-Indy Catawba uses a foul condensate steam stripper to strip methanol from such condensate generated during the manufacturing process. The methanol stripping process simultaneously removes hydrogen sulfide and other sulfurous compounds. The stripped methanol, hydrogen sulfide, and other sulfurous compounds are then burned in one of the combustion boilers at the mill. To decrease the potential for hydrogen sulfide emissions, New-Indy Catawba restarted the stripper and added a reflux condenser. New-Indy Catawba has continued its efforts to make this process more effective. Efforts include the installation of a peroxide injection and oxidation reduction potential (ORP) measurement and feedback control system, which improves oxygen levels in the wastewater treatment process.

In the spring of 2021, incident to the conversion of the facility from manufacturing bleached white paper to unbleached containerboard, a crust formed on the surface of the ASB. To break-up and remove this crust, and improve the function of the ASB, New Indy Catawba:

1. Deployed a barge to dredge and push the crust toward the edge of the ASB;
2. Utilized subsurface dredging equipment to remove non-floating sludge solids.

Once the surface crust was removed, New-Indy Catawba began the process to remove fiber and other solids that that were floating on the ASB surface. These steps allowed the ASB to function as intended. New-Indy Catawba continues to perform these activities to maintain the effectiveness of the ASB.

New-Indy Catawba intends to remove more solids from the ASB to further improve and maximize its effectiveness in the treatment process. The historical contamination of the sludge at the bottom of the ASB makes this a complicated process however, and New-Indy Catawba plans to remove this material safely. Once this step of the process is complete, New-Indy Catawba plans to continue dredging solids from the ASB in accordance with industry standards.

Additional plans are being developed for a system that will remove solids prior to introduction to the primary clarifier to make the wastewater treatment process more efficient.

New-Indy Catawba has worked to improve communication with the community surrounding the facility over the last several months. A Community Engagement Group (CEG) was started in June 2021 so that New-Indy Catawba could hear directly from members of the public about the impact of its operations and to provide the community with updates on operations at the facility, which may impact their neighborhoods. New-Indy Catawba management is directly engaged with the CEG on a regular basis to convey facility operations updates, which the CEG can pass on to their neighbors. In addition to regular monthly meetings, New-Indy Catawba management advises the CEG about any production issues and of planned activity at the facility. This proactive approach in engaging with the community has served both sides well.

June 28, 2021:
Initial New-Indy Catawba Community Engagement Group (CEG) meeting takes place.

August 9, 2021:
Second CEG meeting takes place at the facility which includes tour of the mill for CEG members.

September 3, 2021:
Virtual CEG meeting to discuss elevated emissions from the mill.

September 13, 2021:
Third CEG meeting takes place with presentations from toxicologist and wastewater treatment expert.

October 18, 2021:
Fourth CEG meeting takes place with presentations on air dispersion modeling and community outreach.

November 15, 2021:
Fifth CEG meeting takes place with presentation on New-Indy Catawba’s Voluntary Cleanup Contract (VCC) and the environmental assessment New-Indy Catawba made just prior to its acquisition of the Catawba mill.

December 13, 2021:
Sixth CEG meeting takes place with a follow-up tour of the mill to exhibit and explain site progress.

December 30, 2021:
Virtual CEG meeting to explain the consent decree agreed upon between New-Indy Catawba and the EPA.

January 28, 2022:
Seventh CEG meeting takes place with members of the local media invited for a tour of the facility and a presentation of the mill’s remediation efforts over the past year. U.S. Congressman Ralph Norman and S.C. State Senator Mike Fanning were also in attendance.

February 28, 2022:
CEG meeting with a presentation on misconceptions vs. reality.

February-April 2022:
Hosted more than 70 local elected officials for mill tours to familiarize them with the facility and exhibit mill’s remediation process and upgrades.

April 4, 2022:
CEG meeting with NALCO employees presenting a corporate overview and explain its odor control program and other technologies being utilized at the mill that are saving water, fiber, and energy.

May 16, 2022:
CEG meeting with presentation from an environmental engineer on Subpart S and New-Indy Catawba’s regulatory compliance over the last two years.

June 27, 2022:
CEG meeting with presentation from a toxicologist provided on New-Indy Catawba’s summa cannister testing, which included analysis for methyl mercaptan.

August 22, 2022:
CEG meeting with a presentation on industrial black liquor, a byproduct of the kraft process of turning wood into pulp.

October 17, 2022:
A programs director from York Technical College delivered a presentation on the school’s apprenticeship program and partnership with New-Indy.

November 13, 2022:
The CEG recognized the ancestry and traditions of the Catawba Indian Nation with a presentation by a member of the local tribe at its monthly meeting.

December 12, 2022:
A representative from the North Carolina Forestry Association conducted a presentation on how properly managed forestry practices promote efficient carbon sequestration and help combat climate change.

Mill records indicate that the mill does not and never has used 1,1-dichloromethane (carbon tetrachloride).  That compound, 1,1-dichloromethane (carbon tetrachloride), is however generated as a byproduct of the bleaching and pulping process.  In 2020, emissions of 1,1-dichloromethane (carbon tetrachloride) from the Catawba mill were 1,100 pounds.  Those were fugitive emissions from mill processes into the atmosphere.  We will determine the 2021 emissions no later than 3/31/22.  For reference, the reporting threshold under the US EPA Toxic Chemicals Reporting program is 10,000 pounds per year for any entity that generates 1,1-dichloromethane (carbon tetrachloride).  Because the New-Indy Catawba mill generates considerably less (both historically and currently, especially with having shut down the bleaching process), New-Indy Catawba is not required to report or take any other measure with respect to this compound.

In 2017, the prior owner of the Catawba mill discovered the presence of a different chemical compound, 1,1-dichloroethane (ethylidene dichloride) and properly notified DHEC of this.  That compound is not 1,1-dichloromethane (carbon tetrachloride).  1,1-dichloroethane (ethylidene dichloride) is primarily used in the manufacture of other chemicals such as vinyl chloride, and to manufacture high vacuum rubber. Ethylidene dichloride has limited use as a solvent for plastics, oils, and fats. In the past, ethylidene dichloride was used as an anesthetic, but that use has been discontinued. The prior owner of the Catawba mill investigated possible uses in the mill and could not determine any potential sources for this contamination.  With DHEC approval, the prior owner of the Catawba mill installed new monitoring wells to track that plume.  Based on groundwater modeling results conducted in 2017, the prior owner of the mill and DHEC expected that such plume would naturally attenuate, and DHEC did not require any additional remedial action.  The prior owner installed those monitoring wells.  New-Indy Catawba monitors those wells and reports that information to DHEC.  Those reports indicate that the plume is indeed naturally attenuating and that it is leaving the New-Indy Catawba property.

Because 1,1-dichloroethane (ethylidene dichloride) has only been detected in groundwater, we conclude that such compound is not the source of any sweet odor detected in or around the New-Indy Catawba mill.  Further, because the Catawba mill emits a relatively small amount of 1,1-dichloromethane (carbon tetrachloride) and because that amount has decreased with the cessation of bleaching operations, we think that it is highly unlikely that 1,1-dichlromethane (carbon tetrachloride) is the source of any sweet odor currently being detected in or around the New-Indy Catawba mill.