NC0000272_Addendum Balanced Indigenous Species Study_20060701

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Addendum to
Canton Mill —
Balanced and Indigenous Species Study
for the Pigeon River
[Clean Water Act Section 316(a) Demonstration]
with Appendices including:
Pigeon River Temperature Model
2005 Biological Assessment
Prepared for Blue Ridge Paper Products Inc.
Canton, North Carolina
Prepared by:
University of Tennessee
Institute of Agriculture
Department of Forestry, Wildlife
and Fisheries
J. Larry Wilson, PhD—Principal Investigator
July 2006
The above report with appendices was submitted to the North Carolina Division of Water
Quality (DWQ) in May 2006. During June 2006, scientists with the Environmental Sciences
Section(ESS) of the DWQ reviewed and discussed the technical content of the report with Blue
Ridge Paper and with University of Tennessee scientists who prepared the report. This
addendum clarifies and corrects technical details in the report based on comments from the ESS.
The clarifications and revised /corrected report pages follow. The changes do not affect the
overall conclusions of the Clean Water Act Section 316a Demonstration.

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July 2006 Addendum to 316a Report-DRAFT
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361a Report-DWO ESS Comment/Concern
316a report, page 7, paragraph on Canton Mill history. A statement taken from EA Engineering
Science and Technology (EA) for previous 316a work is not technically correct. " By mid-80's,
aquatic life in the river was consistent with the expectations for Class C stream in North Carolina
(EA 1988)." The ESS concern is that are no standards or written "expectations" for biological
quality in Class C waters. There are water quality standards and criteria, but NC has never had
specific aquatic life criteria. See item 5 of the 2001 DWQ comments on the previous EA work.
Original Text of Concern in May 2006 316a Report:
The Canton Mill modernization in early 1990s,which reduced both chemical and thermal
loading, led to improvement in biological conditions in Pigeon River. The river habitat is well
recovered and restored from impacts prior to the mill modernization.Aquatic communities in the
Pigeon River have responded positively to the mill improvements.By the mid-80's, aquatic life
in the river was consistent with the expectations for a Class C stream in North Carolina (EA
1988). By the mid-90's, further improvements were documented based on greater faunal
diversity, improved biotic index scores, and reduced numbers of pollution tolerant organisms
(EA 1996).As discussed later in this report, further improvements were noted during the 2005
studies of the river(Appendix B). The improvements in the North Carolina portion of the river
have been accompanied by similar improvements in the Tennessee portion of the river(EA 1996;
J.Burr unpublished data).
University of Tennessee Response:
The current report has a statement that came from prior EA work that should be further
explained: `By the mid-80's, aquatic life in the river was consistent with the expectations for a
Class C stream in North Carolina(EA.1988)." The statement is correctly cited from the EA
1988 report. However, in a 2001 memo,B.H.Tracy of the NC DWQ commented that there were
no standards or written"expectations" for biological_quality in Class C waters (item 5 of the
2001 DWQ comments on the 2001 316(a) demonstration. There were water quality standards
and criteria, but NC has never had specific aquatic life criteria.Thus,the judgment by EA in
their 1988 report was misleading. The University of Tennessee acknowledges the confusion and
clarifies that we were simply reporting EA's published statement. We should have stated that the
aquatic life by 1988 had already shown improvement from prior conditions,without reference to
any formal biological expectations.
The statement concerning expectations for biological quality of Class C streams has been
removed.
A revised page 7 for the May 2006 316a report follows:

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July 2006 Addendum to 316a Report-DRAFT
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owner of the Canton Mill when employees,with the help from the KPS Special Situations Fund,
purchased the Mill from Champion.
The Canton Mill modernization in early 1990s,which reduced both chemical and thermal
loading, led to improvement in biological conditions in Pigeon River. The river habitat is well
recovered and restored from impacts prior to the mill modernization.Aquatic communities in the
Pigeon River have responded positively to the mill improvements. By the mid-90's, further
improvements were documented based on greater faunal diversity, improved biotic index scores,
and reduced numbers of pollution tolerant organisms (EA 1996). As discussed later in this report,
additional improvements were documented during the 2005 studies of the river(Appendix B).
The improvements in the North Carolina portion of the river have been accompanied by similar
improvements in the Tennessee portion of the river(EA 1996; J. Burr unpublished data).
1.3.2 Changes Since Current Permit(December 2001)
There were no significant process or operating changes affecting the thermal discharge at the
Canton Mill during the current NPDES permit term (December 2001 to present). The Mill
continued the OD I OOTM pulp bleaching process (oxygen delignification and 100 percent
elemental chlorine free bleaching)and improved the Bleach Filtrate RecyclingTm process for
bleach,plant color control. During 2001 and 2002,the Mill completed implementation of EPA
Cluster Rule requirements for pulp mill wastewater under 40 CFR 430. The Mill continued
pollution prevention initiatives for additional color reduction as outlined in Condition A (8)of
the December 2001 NPDES Permit. The Canton Mill wastewater effluent performance is among
the best of Kraft pulp and paper mills in the world (EKONO 2005).
The Mill's treated wastewater effluent is monitored quarterly for dioxin and related
compounds. Dioxin continues to be non-detect at the part-per-trillion(ppq) level. Fish tissue
samples from the Pigeon River downstream of the Canton Mill are collected analyzed for dioxin
compounds as part of long-term monitoring following the Canton Mill modernization. Based on
annual fish tissue sampling,the State of North Carolina lifted the dioxin in fish advisory for the
Pigeon River upstream of the Waterville Reservoir in August 2001. The State of Tennessee
lifted the dioxin in fish advisory for the Tennessee portion of the Pigeon River in January 2003.
The only fish advisory remaining is for carp in the Waterville Reservoir.
The Canton Mill experienced three floods in September 2004 when tropical storms Frances,
Ivan and Jeanne crossed the headwaters of the Pigeon River along the Blue Ridge Parkway,the
first two causing catastrophic flooding on the Pigeon River. The mill was down for a total of 21
days from 8 Sep 2004 to 29 Sep 2004.
Frances—7 & 8 September 2004—measured 17 inches of rain on East Fork of
Pigeon River—flood crest of 20.7 ft at Canton. Mill dikes, which protect to the 100-
July 2006 Addendum to 316a Report, Page 7

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July 2006 Addendum to 316a Report-DRAFT
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361a Report-DWO ESS Comment/Concern
316a report, page 32, simplification paragraph. ESS question-wasn't mottled scuplin
caught above the mill in 2005. Please check the data and correct.
Original Text of Concern in May 2006 316a Report:
Of the fish species historically found in the Pigeon River from the confluence of the East
Fork and West Fork to the Mill (as assembled by NC DWQ, unpublished; from several
record sources: EA 1988, 1996,2001; Carolina Power and Light Co. 2001;TVA 2000-
2002;NC WRC 1997-2003), only 4 have not been found since 1987 in the NC reach
between the Mill and Walters Dam(longear sunfish, Swannanoa darter,mottled sculpin,
and banded sculpin; none of these species was collected either above or below the Mill in
2005).
University of Tennessee Response:
The ESS is correct. Mottled scuplin were caught above the mill in 2005. The text should
read as follows:
Of the fish species historically found in the Pigeon River from the confluence of the East
Fork and West Fork to the Mill (as assembled by NC DWQ, unpublished, from several
record sources: EA 1988, 1996,2001; Carolina Power and Light Co.2001; TVA 2000-
2002;NC WRC 1997-2003), only 3 have not been found since 1987 in the NC reach
between the Mill and Walters Dam(longear sunfish, Swannanoa darter, fnett'n Win,
and banded sculpin; none of these species was collected either above or below the Mill in
2005).
A revised page 32 for the May 2006 316a report follows:

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Simplification Due to a Loss of Expected Species. Species richness of fish continues to be
higher in the warmest part of the river than in the cooler portions of the river both upstream and
farther downstream. In 2005,24 fish species were found at Thickety (RM 61) and 20 above
Clyde(RM 59) compared to 15 upstream of the Mill.None of the 15 species found above the
,Mill in 2005 were absent from downstream collections. Of the fish species historically found in
the Pigeon River from the confluence of the East Fork and West Fork to the Mill (as assembled
by NC DWQ, unpublished, from several record sources: EA 1988, 1996, 2001; Carolina Power
and Light Co. 2001; TVA 2000-2002;NC WRC 1997-2003), only 3 have not been found since
1987 in the NC reach between the Mill and Walters Dam(longear sunfish, Swannanoa darter,
and banded sculpin; none of these species was collected either above or below the Mill in 2005).
Seventeen species have been found since 1987 in the reach between the Mill and Walters Dam
that have not been found in the reach above the Mill (9 of them in 2005). Finding more species
downstream of the Mill than above it is the opposite of that expected if the thermal discharge
was causing simplification of the aquatic community.
A balanced macroinvertebrate community should have moderate to high taxa richness.
Although taxa richness at RM 63.0 was lower in the 2005 study than that found upstream of the
Mill at RM 64.5,virtually all of the major groups and several taxa found upstream were also
represented downstream and richness remained moderately high.
Community Dominated by Thermally Tolerant Species.The aquatic community downstream
of the Mill's thermal discharge is not dominated by tolerant species. Of the 45 fish species, only
four are rated as tolerant by the NC DENR(NC DENR 2001). With the exception of redbreast
sunfish, thermally tolerant fish species are rare (e.g., goldfish, not found in 2005), uncommon
(e.g., largemouth bass and channel catfish), or moderately common (e.g., carp).
Redbreast sunfish is common to abundant, but generally does not dominate the fish
community diversity (it is one of 15 species collected at the warmest station, comprising 21%of
the number of fish collected). It was one of 24 species at the next station downstream,
comprising 25% of the numbers.The intolerant smallmouth bass and rock bass were collected at
all stations,even the warmest. Intolerant darter species occurred at all but the warmest station.
Nonetheless,the fish community in the NC reach downstream of the Mill has more
characteristics of a warm-water fish community than does the river upstream of the Mill. This
shift is not inconsistent with a balanced, indigenous community based on EPA's 1979 decision
that it is frequently necessary to consider species "whose presence or abundance is attributable to
the introduction of thermal pollutants."(NPDES Appeal#78-6). Snails,aquatic worms and
some midges,the macroinvertebrates most likely to be thermally tolerant, have decreased in
relative abundance over the periods of biological studies. Of these three taxa,none was dominant
downstream of the mill during 2005.
July 2006 Addendum to 316a Report,Page 32

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361a Report-DWO ESS Comment/Concern
316a report,page 40, sculpin,there was a species identification mistake in the EA work that
appears to continue-mottled scuplin, not banded were found above the mill(EA 1996). See the
2001 DWQ comments.
Original Text of Concern in May 2006 316a Report:
Banded sculpin, Cottus carolinae
No thermal tolerance information was found for the banded sculpin,although the NC DENR
rated it as"intermediate" in general pollution tolerance. It occurred only in the Tennessee reach
of the Pigeon River in 2005,where it also was abundant in previous studies(EA 1988, 1995,
2001). It was found in the reach from the confluence of the East Fork and West Fork to the Mill
in only one study(EA 1996). Based on this limited thermal tolerance information and limited
occurrence, it is not a good species to be considered as an RIS.
University of Tennessee Response:
We defer to ESS on the past identification/miss-identification of sculpin species. The main
technical point for purposes of 316a demonstration is that sculpin are not good representative
important species. Corrected text is as follows.
No thermal tolerance information was found for the banded sculpin, although the NC DENR
rated it as"intermediate" in general pollution tolerance. It occurred only in the Tennessee reach
of the Pigeon River in 2005, where it also was abundant in previous studies (EA 1988, 1995,
2001).It was reported by EA (1996) to have been found in the reach from the confluence of
the East Fork and West Fork to the Mill in only one study, but we believe that this report was
a mis-identification of a mottled sculpin. There have been no reports of banded sculpin in the
river above the mill prior to or after the 1996 report. Based on this limited thermal tolerance
information and limited occurrence, it is not a good species to be considered as an RIS.
A revised page 32 for the May 2006 316a report follows:

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Mottled sculpin, Cottus bairdi
The mottled sculpin appears to be a cold-water species. Fish acclimated to 15°C had a CTM
of 30.9°C (Kowalski et al. 1978). The final preferendum has been reported to be 16.5°C (Coutant
1977) and 16.7°C (Wyman 1981).The optimum temperature for spawning is said to be 12.8°C
with a range of 5-16.1°C'and suitable hatching 7.8-17.3°C (Brown 1976). Scott and Crossman
(1973)report optimum spawning at 10°C.The NC DENR rated it as"intermediate" in general
pollution tolerance.
In 2005,the mottled sculpin was fairly abundant above the Mill, and occurred incidentally at
the next three stations downstream. It was missing from below Clyde to Waterville Reservoir
and only one specimen was found in Tennessee.
Banded sculpin, Cottus carolinae
No thermal tolerance information was found for the banded sculpin, although the NC DENR
rated it as"intermediate"in general pollution tolerance. It occurred only in the Tennessee reach
of the Pigeon River in 2005,where it also was abundant in previous studies (EA 1988, 1995,
2001). It was reported by EA(1996) to have been found in the reach from the confluence of the
East.Fork to the Mill in only one study, but we believe that this reporUwas a mis-identification of
a mottled sculpin. There have been no reports of banded sculpin in the river above the mill prior
to or after the 1996 report. Based on this limited thermal tolerance information and limited
occurrence, it is not a good species to be considered as an RIS.
RIS'Summary
In summary, several RIS (common carp and redbreast sunfish) will not be impacted even
during the worst-case thermal conditions because of their high thermal tolerances.Neither is
considered a nuisance species in the Pigeon River, and the common carp actually appears to be
in.decline.The abundance of tolerant redbreast sunfish may be restricting the rock bass
populations below the Mill, as these species commonly compete in similar habitats. The ratio of
redbreast sunfish to rock bass has declined over the years of studies. Several RIS will likely
avoid the near field area for a moderate period (perhaps a few weeks) under worst-case thermal
conditions and avoid it for short periods of the time (hours or days) during normal summer low-
flow periods.Avoidance during the summer is not a problem unless there is no alternative habitat
(thermal refuge), the period of avoidance is long, fish are forced to leave critical spawning areas,
or migratory movements are blocked.None of these conditions appear to be present. Although
some avoidance probably occurs, it has not detrimentally affected populations of most RIS or
caused "appreciable harm"to the aquatic communities downstream of the thermal discharge.
Among the RIS,the darters(as a group) are the only one conspicuously reduced downstream of
the Mill.As noted in previous study reports,the improvements to both water quality and the
biota should allow some missing darter species to recolonize the North Carolina reach
downstream of the Mill (EA 1996,2001).This seems to be occurring(Appendix B). It remains
likely that the somewhat more thermally tolerant
July 2006 Addendum to 316a Report, Page 40

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Appendix B—2005 Biological Assessment-DWO ESS Comment/Concern
Biological Report, Page 59, Question on Table 4.3-1 -Percent tolerant species in the TVA IBI
score,please clarify if this metric is based on number of tolerant species/total species or on
number of individual tolerant fish/total number of fish.
Biological Report, Page 61,Rounding error on Table 4.3-2- The calculated NC IBI score
should be rounded to the nearest even number.
University of Tennessee Response:
Corrected tables for pages 59 and 61 follow. Percent tolerant species for the TVA IBI score is
based on number of tolerant fish/total number of fish collected. Table 4.3-1 is modified to
clarify this metric. The NC IBI scores in Table 4.3-2 were calculated correctly in the May 2006
report, but final rounding to nearest even number was overlooked. This has been corrected.

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Table 4.3-1. Measured values and associated TVA IBI scores (in parentheses) for the Pigeon
River main stem sampling locations, 2005.
Main stem Sampling Locations (River Mile
64.5 63 61 59 55.5 54.5 52.3 48.2 1 42.6 24.9 19.3
Metric:
Total#native fish 14 13 21 18 11 15 15 13 8 19 18
species (3) (3) (5) (3) (3) (3) (3) (3) (1) (3) (3)
#of darter species 4 1 4 2 2 2 2 1 1 3 3
5 1 5 3 3 1 1 1 (1) (3 3
#of sunfish species 1 1 4 1 1 3 2 1 2 0 1
3 3 5 3 3 5 5 3 5 1 3
#of sucker species 2 2 2 2 2 1 3 2 2 5 3
(3) (3 3 3 3 I 3 (3) 3 5 3
#intolerant species 2 2 2 1 1 1 2 2 2 3 2
3 3 3 1 1 1 (3) (3) (3 5 3
% of fish as tolerant 0 0.4 0.7 0.7 0.9 2.2 0.5 0.5 0 0.4 0.3
species* (5) (5) (5) (5) (5) (5) (5) (5) (5) (5) (5)
% 43 55 37 52 41 67 29 33 0 12 53
omnivores/stonerollers (1) (1) (1) (1) (1) (1) (I) (1) (5) (3) (1)
% specialized 33 16 18 10 7 3 11 27 9 24 17
insectivores (3) (1) (1) (1) (1) (1) (1) (3) (1) (1) (1)
%piscivores 10 3 7 4 6 7 4.3 9 30 13 8
5 3 5 3 5 5 5 5 1) 5 5
Catch rate 28 34 16 16 15 27 11 11 3 16 17
5 5 3 3 3 5 3 (3) (I 5 5
%hybrids 0 0 0 0 0 0 0 0 0 0.4 0
5 5 5 5 5 5 5 5 5 3) 5
%diseased 0.4 0 0 0.3 2.7 1.1 1 0 43 0 0.6
5 5 5 5 3 5 5 5 1 5 5
IBI Score 46 38 46 36 36 38 40 40 32 44 42
*The total number of individuals in each tolerant species is summed and divided by the total
number of fish collected to obtain the percentage of tolerant fish.
July 2006 Addendum to 316a Report, Appendix B Biological Report Page 59

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Table 4.3-2. Comparison of IBI scores for Pigeon River main stem and tributary locations, 1995, 2000, 2005.
1995 2000 2005 Data Converted to 2000 2005
NC IBI Method NC IBI Method NC IBI score for comparison TVA IBI Method
purposes
River Mile
64.5 54 55 48 46
63 46 51 38 38
61 52 44 46
59 44 45 38 36
55.5 52 42 40 36
54.5 42 42 38 38
52.3 46 44 46 40
48.2 48 46 44 40
42.6 42 46 32 32
24.9 48 47 50 44
19.3 54 55 40 42
Tributaries
Richland Creek 42 44 44 44
Jonathans Creek 52 51 44 46
Fines Creek 40 44 36 36
July 2006 Addendum to 316a Report, Appendix B Biological Report Page 61

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Appendix B'—2005,Biological Assessment-DWO ESS Comment/Concern
Biological Report, Page 64„ Question on Section 4.4- Was there some text left out? There is a
discontinuity in the discussion.
University of Tennessee Response:
Two sentences were left out. Editing mistake while producing the final 'report. Revised pages 62
and 63 follow.
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Table 4.3-3. TVA IBI scores for the Pigeon River tributary sampling locations,2005.
Trib tary Sam lin Locations
Richland Jonathans Fines
Creek Creek Creek
Metric:
Total#fish species 14 3 9 3 9 3
# of darterspecies 3 3 2 3 1 1
# of sunfish species 2 5 2 5 1 3
# of suckerspecies 2 5 3 5 2 5
#intolerant species 2 (3) 1 1) 0 (1)
%tolerant species 0 5 0.3 5 0.8 (5)
%omnivores/stonerollers 51 1 23 3 41 (1)
•specialized insectivores 11 1 72 5 31 3
• iscivores 8 5 0 (1) 1 1
Catch rate 13 3 45 5 19 3
•hybrids 0 (5) O S 0 5
•diseased 0 5 0 5 0 (5
IBI Score 44 46 136
4.4 LIFE STAGES AND SPAWNING ACTIVITY
The structure of the Pigeon River fish community was examined further by determining the
reproductive status and lifestage of all fish collected. Lifestage information was used as an
indicator of reproductive success(presence of young- of-the-year) as well as overall community
health (representation by a range/variety of life-stages). Because the study was conducted in July
and August, most fish were not in breeding condition and indicators of breeding condition(e.g.,
tubercules in males, gravid females,breeding colors)were essentially absent. Thus, assessment
of reproductive success was based on the presence of YOY(young-of-the-year) fish and-a wide
range of sizes for a particular species (indicative of successful spawning and recruitment in
previous years).Reproductive life-stages of fishes were classified as follows: YOYs were
spawned during the current calendar year,juveniles were not mature enough to reproduce, and
adults were sexually mature and capable of reproduction.
Length distributions for the more common sport and larger non-sport fishes collected in the
Pigeon River are presented in Appendix B4. Examination of these tables indicates that eight of
the nine species shown were represented by a broad range of sizes. Common carp was.
represented only by medium and large individuals which is typical of the size distribution of this
species, for which YOYs and small juveniles are rarely collected. In the entire reach of the river
(NC and TN), the size distribution of the remaining eight species at various sample sites
indicated the presence of YOYs, including northern hog sucker, redbreast sunfish, smallmouth
bass,rock bass, and largemouth bass. Conversely, YOY largemouth bass were somewhat less
common downstream of the Progress Energy Hydro Plant. These differences in YOY
representation downstream of the Hydro Plant may be related to fluctuations in water levels that
occur due to operation of the Hydro Plant. The fact that the YOYs were seen at most of the sites
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on the main stem indicates that that reproduction by some of the species was not significantly
disrupted by the floods.
Among the tributaries, reduced numbers of YOYs of several species including northern hog
sucker(all 3 tributaries), white sucker(Jonathans),redbreast sunfish (Richland and Jonathans),
rainbow trout(Jonathans and Fines),brown trout(Jonathans and Fines), rock bass (Richland),
and largemouth bass Richland)were observed, indicating substantial reproduction.
4.5 HABITAT ASSESSMENT
Habitat Assessment
An evaluation of the quality of the aquatic habitat and surrounding lands is important to any
assessment of aquatic ecological integrity.A high quality habitat functions as a refuge for
organisms, meets their needs throughout their life cycle,moderates runoff influences,provides
living space and food, and tempers alteration to channel morphology, erosion, and deposition.
Therefore,the biological condition of indigenous communities is determined by the natural
characteristics of the whole system. The potential of aquatic communities is dependent on the
habitat quality as a primary component of their ecological requirements.
The riverine habitat was assessed using the methodologies established by NC DENR(2001)
using the Habitat Assessment Field Data Sheet for Mountain and Piedmont Streams (Revision 6).
The habitat characteristics which were recorded were channel modification, in-stream habitat,
bottom substrate,pool variety,riffle habitat, bank stability and vegetation, light penetration, and
riparian vegetation zone'width. The maximum score possible using all metrics was 100. In
addition to habitat assessment,physicochemical data (temperature, dissolved oxygen, and pH)
were also recorded at each sampling location. Habitat field data sheets are presented in Appendix
B4.5-1 and Appendix B4.5-2.
Among the main stem locations,habitat scores (Table 4.5-1)ranged from 34-83 and tributary
scores ranged from 72-88. Main stream scores were higher at RM 24.9 (83),RM 59 (80), and
RM 61 (79), and lower at RM 64.5 (57),RM 63 (40), and RM 55.5 (34). The highest score,
Jonathans Creek(88),was the result of instream habitat and riffle habitat scores. The lowest
score at RM 55.5 was the result of poor instream habitat, substrate quality, bank stability,
canopy, and riparian zone width.
July 2006 Addendum to 316a Report, Appendix B Biological Report Page 63