Appvion Responds to Accusation of Spill

Appvion has responded to a charge from the Pa. Dept. of Environmental Protection (DEP) that its Spring Mill plant killed fish in the Frankstown Branch of the Juniata River with a release of a chemical on Aug. 20 and 21, 2020.

In a letter dated Sept. 17, 2020, the DEP stated, “On August 27, 2020 the [DEP] responded to a report of a fish kill in the Frankstown Branch of the Juniata River. During an investigation of the incident, dead fish were observed over a 4.5 mile stretch of the river that extended upstream to an area approximately 500 feet below the Appvion industrial wastewater treatment plant outfall pipe.”

Appvion, as required by DEP, issued a “Notice of Violation Response” letter dated Oct. 2, 2020. Appvion’s response denies that it was responsible for killing fish via a chemical release. The letter also outlines Appvion’s account of the chemical overflow incident and the Spring Mill plant response.

The incident

The response letter from Appvion states that there was an unplanned movement of Chlorostain, a security paper dye, within the Spring Mill plant in Roaring Spring on Aug. 19, 2020.

Appvion states in its letter that on Aug. 19, 2020, at approximately 5 p.m., the loss of approximately 4,300 gallons of Chlorostain was discovered following a tank inspection by the Chlorostain vendor, who notified Appvion’s technical department.

Appvion states that “immediately following the discovery, an investigation and records review indicated that the Chlorostain tank drained between 10 a.m. and 12:30 p.m. through an open valve into the No. 3 Paper Machine half tank, which retained approximately 600 gallons of the chemical.”

The rest of the Chlorostain, according to Appvion, overflowed the half-tank and “entered the mill’s sump system and was then pumped to the primary clarifiers, and was dispersed into Lagoon No. 2.”

Appvion’s response states that at approximately 5:15 p.m., Appvion’s Technical Department director notified Appvion’s Environmental Department to begin monitoring the “upstream waste flow and influent” for ammonia and chemical oxygen demand, which could indicate a chemical release.

Over the next few hours, the Appvion departments evaluated the “loss threat” and “concluded the data did not indicate any conditions requiring immediate response” from the plant.

Appvion’s response letter, written by Robert Stasik, staff environmental engineer, stated that “reporting from the second shift operator at 9:36 p.m. [Aug. 19] revealed no wastewater quality anomalies.”

Cause

Appvion stated in its letter that the “cause of the loss” was human error. An employee was “retrieving Chlorostain when an alarm in the plant triggered and the employee responded to the alarm and failed to close the release valve on the tank holding the Chlorostain,” Stasik reported.

Remedies

Appvion’s letter stated several “corrective actions” taken to “ensure no repeat of this incident will occur,” including

• A tank level-monitoring alarm was installed, providing both visual and audible alarms

• Removal and blanking of unnecessary tank outlets.

• Installation of an automatic supply/cutoff valve on the main tank outlet to automatically isolate the tank based on high use or tank level drop.

• Installation of “dead man” switches on local supply valves.

• Administrative modifications regarding chemical safety.

Reason for no initial report

Appvion also addressed DEP’s statement that the plant did not immediately report the chemical release incident, as required under the plant’s federal pollutant discharge permit.

The letter from Stasik states that

the Chlorostain was “contained completely within our facility and funneled through our wastewater treatment system [...] no other data pointed to any exceedences and the Chlorostain [official data sheet] does not indicate any aquatic toxicity indicators.”

The letter further states that Appvion contacted its supplier of Chlorostain and requested information about the chemical’s effects on aquatic life. The response from the manufacturer stated that there is no aquatic toxicity associated with Chlorostain because there is “no aquatic toxicity concern associated with any of its main components.”

“We believe this information is important since any conclusion that this incident cause the fish kills observed by you and others seems to be contradicted by this information from the Chlorostain supplier,” Stasik wrote.

The DEP’s initial investigation report notes that chemical’s official description sheet states that the substance is toxic to humans but does not indicate its effects if spilled into an aquatic environment.

Appvion produces thermal, carbonless and security papers at the Spring Mill plant. The company’s headquarters is in Appleton, Wisc.

Appvion’s permit

The DEP investigation stated that “Appvion failed to immediately report a spill of approximately 3,700 gallons of the chemical chlorostain to their wastewater treatment process in violation of [the company’s] NPDES permit.”

NPDES stands for “National Pollutant Discharge Elimination System.”

According to the U.S. Environmental Protection Agency (EPA), a NPDES permit is issued under the The Clean Water Act, which prohibits discharging “pollutants” into a “water of the United States” without a NPDES permit.

A NPDES permit sets limits on what can be discharged, monitoring and reporting requirements, and other provisions to ensure that the discharge does not hurt water quality or people's health.

Appvion did not return calls from the Herald requesting comment.