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Home My WebLink AboutNC0000272_TN_NPDES_Comments_20010906 Summary of the Comments of the State of Tennessee on-the Draft.NPDES Permit for Blue Ridge Paper Products, Inc., Canton Mill Tennessee appreciates North Carolina's commitment to clean water in the Pigeon River, and recognizes the great improvement in water quality due to the process established by the 1998 settlement agreement. Though there has been . great progress,we have not yet achieved our clean water goals. Tennessee urges that the following improvements be made to the draft permit to ensure continued progress: • Tennessee's overriding concern has been and will always be protecting human health. For that reason, the new permit must maintain the requirements for monitoring for the full-range of dioxins and difurans. • The draft permit does not require Blue Ridge Paper Products to implement all three process improvements identified by the Technical Review Workgroup (TRW) as having the "highest certainty" of success. These include bleach filtrate recycle reliability, leak and spill collection and control and process optimization. The permit language should be revised to require implementation of all three of these improvements. • Tennessee asks that the required color reduction achieved by the above improvements be changed to a range of 6,000 to 8,000 pounds per day of true color, rather than a flat 6,000 pounds per day. We believe this better reflects the recommendations of the TRW. The 3,000 to 8,000 pounds per day range of true color reductions effective 2006 must be in addition to the color reductions required by the "highest certainty." process improvements described above. Blue Ridge Paper Products may achieve this second round of reductions through the technologies prescribed by the TRW or through other available technology that would result in the same level of improvement. • To ensure objectivity and accountability to all parties involved, the TRW must maintain its involvement in the implementation and review of new technologies. Any reconsideration of technology improvements must be guided and approved by the TRW. The TRW, involving pulp and paper industry experts as well as regulators from EPA, North Carolina and Tennessee, has delivered a wealth of technical experience to the mill as well as an independent point of view to the process. r q�'4 Egg TENNESSEE WILDLIFE RESOURCES AGENCY ELLINGTON AGRICULTURAL CENTER QOdOdOffN G1EMMMIN% P.O. BOX 40747 NASHVILLE,TENNESSEE 37204 gG�G�g6� eptem er , Mr. Forrest Westall Regional Water Quality Supervisor North Carolina Department of Environment & Natural Resources 59 Woodfin Place Asheville, NC 28801 re: NPDES Draft Permit No. NC0000272 Blue Ridge Paper Products Canton, NC Dear Mr. Westall: The Tennessee Wildlife Resources Agency (TWRA) provides the following comments and recommendations with regard to the August, 2001 Draft National Pollutant Discharge Elimination System (NPDES) industrial effluent permit for the Blue Ridge Paper Products discharge to the Pigeon River in Canton, North Carolina. We believe there is general consensus that tremendous progress has been made toward restoration of the Pigeon River and that substantial work remains. We look forward to working with all of our partners in conservation to reach our mutual goal of a fully restored Pigeon River. We recommend the following revisions to the Draft permit: • Require first found implementation of all three high certainty technologies as identified by the Technical Review Workgroup (TRW). • Require the first round Color reductions to be within the range of 6,000 to 8,000 pounds of color per day. The State of Tennessee AN FnuAI OPPORTUNITY EMPLOYER J • Require the second round color reductions of 3,000 to 8,000 pounds of color per day to be in addition to the first round reductions. • Require monitoring for the complete list of dioxins and difurans in mill effluent. • Insure the TRW remains fully involved in the technology evaluation process. We appreciate the commitment of all concerned parties to a fully restored Pigeon River. Sincerely, n Gary T. Myers Executive Director GTM/bjs cc: Tennessee Wildlife Resources Commission Milton Hamilton, Commission - TDEC Lisa McCarter - Tennessee Office of Attorney General and Reporter Beverly Bannister, EPA Region IV Telephone:615/781-6643 Fax:615:781-6667 E-mail dmckinney@mail.stale.tn.us £. STATE OF TENNESSEE - DON SUNDQUIST GOVERNOR September 6, 2001 Secretary William G. Ross, Jr. North Carolina Department of Environment and Natural Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Re: NPDES Draft Permit No.NC0000272 Blue Ridge Paper Products, Inc.,. - Dear Secretary.Ross: We have reviewed the draft NPDES permit for Blue Ridge Paper Products, Inc. on the Pigeon River. We appreciate your agency's commitment over the past five years to improve water quality in the Pigeon River, and your support of the process that has resulted in this draft permit. The process to which we agreed in the 1998 settlement to improve water quality in the Pigeon River has functioned well. The Pigeon River improvement process is setting the standard for the pulp and paper industry nationwide. Today, the river is cleaner. Aquatic life is more diverse and abundant. Thousands of people now come to east Tennessee and western North Carolina every summer to enjoy whitewater recreation. The Tennessee Wildlife Resources Commission has designated the Tennessee portion of the Pigeon River as a trophysmallrnouth bass fishing stream. This progress has happened even with the low flows of recent years. While we are pleased with this progress, we have not yet achieved our goal. Our position remains unchanged: Tennesseans deserve clean water. We will not be satisfied until the process we embarked on in 1998 successfully runs it course, and the Pigeon River runs clean and clear. In support of that goal,we request that the following changes be made to the draft permit: • Our overriding concern has been and will always be protecting human health. For that reason, the new permit must maintain the requirements for monitoring for the full-range of dioxins and difurans. State Capitol, Nashville, Tennessee 37243-0001 Telephone No. (615) 741-2001 Conaams of Justin P.Wilson,State of Tennessee NPDES Draft Permit No.NC0000272 Page 2 • The draft permit does not require Blue Ridge Paper Products to implement all three process improvements identified by the Technical Review Workgroup (TRW) as having the "highest certainty"of success. These include bleach filtrate recycle reliability, leak and spill collection and control and process optimization. The permit language should be revised to require implementation of all three of these improvements. • We ask that the required color reduction achieved by the above improvements be changed to a range of 6,000 to 8,000 pounds per day of true color, rather than a flat 6,000 pounds per - day. We believe this better reflects the recommendations of the TRW. • The 3,000 to 8,000 pounds per day range of true color reductions effective 2006 must be in addition to the color reductions required by the "highest certainty" process improvements described above. Blue Ridge Paper Products may achieve this second round of reductions through the technologies prescribed by the TRW or through other available technology that would result in the same level of improvement. • To ensure objectivity and accountability to all parties involved, the TRW must maintain its involvement in the implementation and review of new technologies. Any reconsideration of technology improvements must be guided and approved by the TRW. We appreciate your commitment to this issue and your willingness to work with the state of Tennessee, local citizens and the TRW. We have faith in the partnership that has been forged between our two states, and believe that partnership is the key to the future of this river._This permit represents a milestone, but not the finish line. Let us now carry on, and finish what we started. incerely, -, J stin P. Wilson : Commissioner Milton H. Hamilton, Jr., TN Department of Environment and Conservation Director Gary Myers, TN Wildlife Resources Agency Beverly H. Banister, U.S. Environmental Protection Agency; Region 4 Mayor Roland Dykes, City of Newport Charles Lewis Moore, Cocke County Executive Jerry Wilde, Dead Pigeon River Council David Jenkins, American Canoe Association Will Calloway, Tennessee Environmental Council Brad Davis, USA Raft Bob Williams, Blue Ridge Paper Products, Inc. BLUE RIDGE PAPER PRODUCTS INC. May 29,2001 Mr.Forrest Westall Regional Water Quality Supervisor North Carolina Department of Environment and Natural Resources 59 Woodfin Place Asheville,NC 28801 RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products,Inc. Canton Mill June 1,2001 Required Reports Dear Mr.Westall: Attached are the June 1, 2001 Comparative Evaluation Report and the June 1, 2001 Color Performance Statistical Evaluation. These reports are submitted to fulfill part of the requirements stated in Part III,Paragraph E 14 of the modified 1997 NPDES Permit. Please call me at(828) 646-2033 or Derric Brown at(828) 646-2318 if you have any questions or concerns regarding these reports. Sincere' Bob Williams Director-Environmental,Health and Safety Attachment. _ 175 Main Street • P.O. Box 4000 Canton, North Carolina 28716 • Phone: 828-646-2000 Raising Your Expectations Xc: Keith Haynes Dave Goodrich Mike Myers