NC0000272_Macroinvertebrate Assessment Pigeon River_20060914

Division of Water Quality
Biological Assessment Unit
14 September 2006
Memorandum
To: Jimmie Overton
Through: Trish MacPherson
From: Steven Beaty S
Re: July 2006 macroinvertebrate assessment of Pigeon River,Haywood County regarding Blue Ridge
Paper Products, Index nos.5-3-(6.5)and 5-(7).
Background
Blue Ridge Paper Products(BRPP)has applied for a NPDES permit renewal for it's mill in Canton, NC(current
permit no.NC0000272). Among the decisions under consideration with this permit renewal are whether to
continue variances from the temperature and color standards. Prior to this application,BRPP contracted biologists
at the University of Tennessee at Knoxville to conduct a balanced and indigenous species study report and a
temperature model for the Pigeon River(BRPP 2006). This study was required by NCDWQ in fulfillment of
BRPP's current permit. At the time,the Pigeon River was assessed to be impaired below the BRPP discharge by
the DWQ's Biological Assessment Unit and was on the State of North Carolina's 303(d)impaired streams list.
However,the 2002 basinwide sampling occurred in the midst of a severe statewide drought that likely negatively
affected the benthic community through low flows by effectively concentrating BRPP effluent. BRPP's balanced
and indigenous species study found that the Pigeon River benthic community was impacted only directly below the
mill as well as below the confluence of Richland Creek,which empties into the Pigeon River upstream of
Waynesville's municipal wastewater discharge. A request was made by BRPP to consider the 2005 data in use
assessment of the Pigeon during the BRPP NPDES permit renewal process. BAU biologists reviewed the report
and found that the BRPP study did not follow DWQ benthic collection protocols. Data,therefore,was not directly
comparable to DWQ data and was not considered(see BAU Memorandum 20060511 and 20060703).
Resampling by BAU biologists in July of 2006 was done as a special study to assess the Pigeon River during
normal flow.
Methods
BAU biologists sample using NC DWQ Benthic Macroinvertebrates standard operating procedures
(NCDWQ, 2006). All samples taken for this study were qualitative full-scale samples. A full-scale sample is
a composite of ten benthic collections:two riffle kicks,three sweeps,one leaf pack,two rockfiog washes,
one sand, and"visual"collections. All organisms were picked in the field.The complete stream environment
was analyzed for quality and quantity of instream habitat for invertebrate colonization, riparian integrity, and
bank stability. Habitat evaluations result in a composite score between 1 and 100 with a higher score
indicating a more favorable environment for stream biota. Water chemistry was measured for temperature,
dissolved oxygen (DO), conductivity, and pH. All sites sampled were classified using mountain criteria as
per NCDWQ SOP.
The purpose of these collections is to inventory the aquatic fauna and produce an indication of the relative
abundance of the benthic invertebrates. In the laboratory,organisms were identified to the lowest possible taxon,
enumerated and assigned an abundance rating:Rare(1-2 specimens),Common(3-9 specimens),or Abundant
(510 specimens). These values were used in conjunction with the organism's individual tolerance rating(0-10 with
10 being most tolerant)to produce several metrics that are then used to assess the impairment of the stream of
interest.

1
These metrics gage the relative tolerance of a system to stress. Pollutants,such as urban runoff,W WTP
discharge,sediments,or temperature variations,adversely affect aquatic biological communities. Streams thatare
impaired will usually have a lower invertebrate diversity and a lower proportion of intolerant species relative to
streams that are unimpaired. The diversity of the fauna is measured with taxa richness(a sum total of the number
of species present or total S)whereas the increasing tolerance of the community is assessed with a biotic index
values from 0-10,with higher numbers indicating more polluted conditions. The biotic index is the summation of
the tolerance values of all species present relative to their abundance in the community as a whole. The biotic
index used by DWQ biologists(the North Carolina Biotic Index or NCBI)is a specialized index developed over may
years by NC biologists to reflect the tolerances of invertebrates specific to North Carolina.
Another useful metric used by DWQ biologists in,assessing stream impairment is the total number of
Ephemeroptera(mayflies),Plecoptera(stoneflies),and Trichoptera(caddisflies). These three orders of aquatic
insects,as a group,are more sensitive to pollutions than other orders of insects. A high diversity of EPT(EPT S)
and abundance(EPT N)and a low biotic index generally indicates higher water quality.
The above metrics are used to assign bioclassification ratings to the stream being monitored. Bioclassifications are
Poor,Fair,Good-Fair,Good,and Excellent. A rating of Poor or Fair indicates an impaired stream.
Study Sites
On July 12 and 13,2006,benthic macroinvertebrates were collected from four Pigeon River sites and one site from
the East Fork Pigeon River. Three of the five locations sampled in this study,INC 215,SR 1642,SR 1338,and the
East Fork Pigeon River at US 276,are basinwide sampling sites and are scheduled to be sampled in the summer
of 2007. The NC 215 location was located one bridge closer to Canton opposite a city park about a quarter of a
mile downstream of the basinwide site. The Pigeon River at SR 1519 is a special site requested for this study.
These sites are summarized in Table 1 and indicated in Figure 1.
Table 1. Sampling sites on the East Fork Pigeon River and Pigeon River. Sites are organized from upstream to downstream.
BRPP study sites are measured in river-miles(RM)from the Pigeon River and French Broad River confluence in Tennessee.
Latitude and longitude are in degrees,minutes,and seconds.
Equivalent
BAU Sampling Site Location BRPP Site County Latitude Longitude
E.Irk Pigeon River US 276,Cruso — Haywood 35.24.39 82.48.36
Pigeon River NC 215,above Canton at park RM 59 Haywood 35.31.18 82.50.55
Pigeon River SR 1642,Clyde — Haywood 35.32.06 82.54.42
Pigeon River SR 1519,below Richland Cr. RM 54.5 Haywood 35.33.00 82.57.11
Pigeon River SR 1338,Hepoo RM 42.6 Haywood 35.39.58 82.59.39
The sampling site at SR 1519 was initially placed at SR 1625. However,a more suitable sampling site with better
habitat and easier access were available approximately 1 mile upstream. The sampling location was consequently
relocated to the present site at SR1519. A site from the East Fork Pigeon River was sampled to obtain a
community population that occurs in slightly colder water and that has few urban impacts and no permitted
dischargers. Pigeon River is farmed by the confluence of the East Fork and the West Fork Pigeon River and
therefore has access to the faunal pool that exists in both smaller streams. This is important in determining, in the
absence of stressors,the possible composition of the benthic community.
2

rt
Mn
SR 1519
Figure 1. Map of benthic sampling sites on the Pigeon River and the East Fork of the Pigeon River during
summer 2006 in Haywood County,NC. The Blue Ridge Paper Products mill in Canton is also indicated.
3

Pigeon River, NC 215(Above Canton at park)
Date: 12 July 2006
Visible land use(%):50 residential,50 park
Width(m): 30
' Depth(m):Average:0.25 Max: 1.0
Canopy(%cover,type): 10,Deciduous
Substrate: Mostly cobble and gravel with some
bedrock
a Riparian quality:Wide riparian zone on right
(downstream)though with steep gradient. Little
r riparian on left(city park)
Instream habitat:Good riffle habitat but little
available snag habitat.Low substrate embeddedness.
- - Dissolved Oxygen(mg/L):8.3
Specific conductance(pmhos/cm):25
Figure 2.Pigeon River,Haywood County,NC at NC Temperature(°C):23.2
215 on 12 July 2006 looking downstream. pH:7.3
Habitat Score: 70
Pigeon River, SR 1642(Clyde)
Date: 13 July 2006
Visible land use(%):50 residential,50 commercial
Width(m): 30
Depth(m):Average:0.6 Max: 1.5
Canopy(%cover): 30, Deciduous
Substrate: Mostly gravel and sand with some
cobble
Riparian quality: Riparian narrow and restricted
to banks. Erosion areas present.
Instream habitat:Sparse riffle habitat and little
available snag habitat. Moderate substrate
embeddedness.
Dissolved Oxygen(mg/L):5.0
Specific conductance(pmhos/cm):638
Figure 3.Pigeon River,Haywood County,NC at SR Temperature(°C):27.9
1642 on 13 July 2006 looking downstream. pH: 7.8
Habitat Score: 51
Remarks: reach primarily deep run,fair amount of trash
4

Pigeon River, SR 1519(below Richland Creek)
t Date: 13 July 2006
S'6{a t Visible land use(%): 30 crop,30 pasture,20
forest,20 residential
Width(m): 30
Depth(m):Average:0.4 Max: 1.1
Canopy(%cover):20,Deciduous
Substrate: Mostly cobble with some boulder and
bedrock. Some sand and silt
Riparian quality:Wide riparian zone on right
(upstream),bank riparian on left no significant
erosion.
Instream habitat: Good riffle and root mat habitat
but little available snag habitat. Moderate substrate
embeddedness.
Figure 4.Pigeon River,Haywood County,NC at SR Dissolved Oxygen(mg/L): 6.9
1519 on 13 July 2006 looking upstream. Specific conductance(pmhos/cm):447
Temperature(°C):26.7
pH: 7.6
Habitat Score: 63
Remarks: Sewage smell present,siltation,trash
Pigeon River, SR 1338(Hepco, below Fines Creek)
Date: 13 July 2006
Visible land use(%):90 forest, 10 residential
Width(m): 50
Depth(m):Average:0.25 Max: 1.0
Canopy(%cover): 10,Deciduous
Substrate: Mostly cobble and boulder bedrock with
4, some sand.
Riparian quality:Wide riparian zone,no significant
erosion
aa' Instream habitat: Good riffle and root mat habitat
but little available snag habitat. Moderate substrate
embeddedness.
Dissolved Oxygen(mglL): 7.7
Figure 5.Rgeon River,Haywood County,NC at SR Specific conductance(pmhos/cm): 374
1338 on 13 July 2006 looking downstream. Temperature(°C):23
pH:6.9
Habitat Score:73
Remarks: Faint sewage smell
5

East Fork Pigeon River, US 276(near Cruso)
Date: 12 July 2006
Visible land use(%):90 forest, 10 residential
Width(m): 17
:+ (! Depth(m):Average:0.25 Max:0.75
Canopy(%cover,type):30, Deciduous
Substrate: Mostly cobble with some boulder,
gravel,and sand
Riparian quality:Wide riparian zone, no significant
z!
erosion
Instream habitat: Good riffle habitat but little
available snag habitat.Low embeddedness.
-- _. Dissolved Oxygen(mglL):7.3
- , Specific conductance(pmhosfcm): 13
Temperature(°C): 18.3
Figure 6.East Fork Pigeon River at US 276,Haywood pH: 6.3
County,NC on 12 July 2006 looking downstream. Habitat Score:82
Remarks:Trout farm upstream,root mats mostly out
of water
Note:All site data is summarized in Table 2 in Appendix 2.
Results and Discussion
Pigeon River, NC 215(Above Canton at city park)
This site was rated as Good after sampling in July 2006. This site had the highest EPT taxa richness(EPT S=34)
and lowest BI(4.61)of all the Pigeon River sites sampled in this study. Low specific conductance reflects the
absence of localized major dischargers in this segment of the Pigeon River. However,there is some urbanization
upstream of this site,primarily on the east side of the river,which may have a minor impact on stream biota
diversity. Since the site was sampled a week after the most recent rain, non-point sources of pollution had most
likely pulsed through the river. Though one minor NPDES permitted discharger,Silver Bluff Nursing Facility,exists
approximately 5 miles upstream,it seems likely that less than ideal habitat is a contributing factor to why this site
did not receive a better bioclassification.
Abundant intolerant and tolerant taxa that were found at the NC 215 location are noted in Table 3 in Appendix 2.
Very intolerant taxa are also noted independent of their abundance.
Historically,this location was sampled approximately one quarter of a mile further upstream than the current
location at a second bridge crossing. However,with no dischargers between the two bridges water quality should
not change. The basinwide site has received a Good or Excellent biodassificat on with the exception of the year
2002 where a Good-Fair classification was applied(Appendix 1,Figure 7). Differences in habitat were slight
between 2002(habitat score=69)and 2006 score=70). 2002 was a severe drought year though the river was
sampled during higher flow. The lower than usual EPT richness(EPT S=31)probably resulted from the
combination of long-term drought and scour from a spate event.
Pigeon River, SR 1642(Clyde)
A rating otE,�r_was applied to this segment of the Pigeon River for this sampling year. The number of
EPT taxa collected was 16. The biotic index was 6.38,significantly higher than the site above the mill
6

(NC 215). Flow was normal and the habitat score was slightly higher than in 2002(51 in 2006 versus 44 in 2002)
reflected in the substrate of mostly sand and gravel. However,the dissolved oxygen was lowest at this site,a direct
correlation to the increase in water temperature'seen. A snail that is tolerant of low dissolved oxygen, Physella sp.,
was abundant. Furthermore,the community was largely dominated by tolerant insects,though an intolerant
hydropsychid caddisfly occurred in high numbers as well(Table 3). No stoneflies were collected at this site. An
abundance of pollution tolerant midges(Chironomidae)and oligochaete worms provides further evidence of
impairment at this site. Other abundant taxa at the site are noted on Table 3 in Appendix 2.
SR 1642 in downtown Clyde has received Poor and Fair bioclassifications in the past. Most often since 1992(after
BRPP instituted major processing upgrades),this site has received a Fair. Two exceptions occurred,one in 1997
when the river at this site received a Good-Fair rating and 2002 when it received a Poor rating Appendix 1, Figure
8). The rating in 2002 was during low flow(approximately 2 months after the NC 215 site was sampled)when
there was less dilution of the mill effluent(specific conductance measured was 1,990 pmhos/cm)providing
evidence that BRPP discharge has a serious effect on waterqualityduring drought conditions. Additionally,data
from 2006 suggests that mill effluent still has a major effect on stream biota even during periods of normal flow.
Pigeon River,SR 1519(below Richland Creek)
This site was rated Fair after sampling in July of 2006. It had the lowest EPT taxa richness(EPT S=15)of any site
sampled on the Pigeon River as well as the highest BI(6.71). This site was added to capture the effects of
Waynesville's wastewater treatment effluent,which is discharged into the Pigeon River. Additionally,this site is
downstream of the BRPP mill effluent. It appears that a combined effect from the Canton paper mill and the
wastewater from Waynesville is occurring on the river.The stream had a sewage smell that was not apparent
upstream at SR 1642. The temperature was lower than at SR 1642 though significantly elevated compared to all
other sites. In addition,the biomass of organisms was significantly lower at this site than at SR 1642 providing
evidence of a compound effect from both major dischargers upstream. A pollution tolerant community was
dominant as evidenced by Table 3. No stoneflies were found at this site as well as no abundant intolerant taxa. An
abundance of midges tolerant to organic pollution(Dicrotendipes neomodestus and Polypedilum illinoense gr.)
presents evidence of organic enrichment at this site from Waynesville's W WTP.
The Pigeon River at SR 1519 has never been sampled,though a site approximately I mile downstream at SR 1625
was sampled in 1994. The site at SR 1625 received a Fair rating (15 EPT,BI=6.06)in 1994(Appendix 1,Figure
9). It had a similar community as the one collected this year though 3 stonefly taxa,Acroneuria abnormis,
Allocapnia sp.,and Paragnetina sp.(all Rare)were found in 1994.Abundant taxa at the site are noted on Table 3.
An additional site upstream of the W WTP effluent is advised to monitor the individual effect of the Canton mill at
this location. This site is recommended for future basinwide monitoring.
Pigeon River,SR 1338(Hepco,below Fines Creek)
This location was rated as Good-Fair after sampling in July 2006.Habitat at this site was adequate and flow was
normal. A slight smell of sewage existed at this site,in all probability a remnant of Waynesville's treated
wastewater. A distance of approximately 12 miles from the wastewater point source and the addition of water from
unimpaired tributaries,have apparently diluted the upstream pollutants.
The biological community has shifted from the tolerant community seen at SR1642 and SR 1519 to a balanced
community that is dominated by intolerant species. Four stonefly taxa not seen at the two sites upstream recur
(Table 3). A few toxic indicator species seen in 2002 are still present in the stream though in lower abundances
(Cdcotopus bicinctus from abundant to common and O.Euorthocladius sp.from abundant to rare in 2002 and
2006 respectively),evidence that pollutants are still affecting the water quality. Abundant taxa are noted on Table 3
in Appendix 2.
Since 1988,the Pigeon River at SR 1338 has received four Good-Fair ratings and one Fair rating in 1988
(Appendix 1, Figure 9). In 2002,a Good-Fair rating was given though the lowest number of EPT taxa
were collected(EPT S=19)compared to all other years sampled,with the exception of 1988(EPT
7

3=14)'. This may be attributable,in part,to the concentrated pollutants that occur from dischargers during drought
events.
East Fork Pigeon River,US 276(near Cruso)
This site is rated excellent from the July 2006 sampling. No permitted dischargers exist upstream and the major
land use is national forest. The excellent rating is based on BI of 3.05 and an EPT richness of 49. In the absence
point source pollution,the biological community is dominated by intolerant species. Taxa abundances are noted on
Table 4.
This site received an excellent rating in 1997 and 2002 and rated good in 1984. The argument that point source
effluent is concentrated during drought years is substantiated with the data from this site. In the absence of
pollutants,the habitat and water chemistry are suitable to support an intolerant biological community regardless of
reduced flows. Additionally,it is feasible that the fauna of the East Fork Pigeon River would colonize lower reaches
of the Pigeon River in the absence of biological stressors.
Summary
The rating of the Pigeon River at NC 215,Canton upstream of the BRPP mill received a bicclassification of Good
and has the lowest BI and highest EPT richness of all the Pigeon River sites. The rating given in 2002 for the
location one quarter mile upstream this site was Good-Fair,possible due to lower flows.
SR 1642 was given a rating of Fair due to a high BI and low number of EPT taxa. The community is dominated by
tolerant taxa. The rating is an improvement from 2002 when this site was rated as Poor,possibly due to
concentrated mill effluent and lack of habitat.
Downstream of Clyde at SR 1519 and below Waynesville's wastewater effluent,the Pigeon River rated a Fair. A
similar tolerant community to that found at SR 1642 exists here. The only other benthic collection made on this
segment of the Pigeon River was made during summer 1994 and resulted in a Fair bioclassification as well. This
site is recommended for future basinwide sampling.
The Pigeon River at SR 1338 is given a rating of Good-Fair. The benthic community has more intolerant taxa
though some tolerant taxa are still abundant. The same rating was applied in 2002. It appears that distance from
major dischargers and dilution of the Pigeon River by tributaries contributes to the higher classification than the two
upstream sites.
The East Fork Pigeon River,by all criteria used in this study, has the best water quality among the sites sampled
for this study. This location received an Excellent rating due to the very low BI and high number of EPT taxa. No
permitted dischargers.exist on this stream. This site received a classification of Excellent in 2002.
Based on the current data,it appears that the BRPP mill continues to have an effect on at least one segment of the
Pigeon River. This section,from below the mill discharge to the sampling location in Clyde at SR1642,is the only
section that has no major permitted dischargers other than the paper mill. It is not possible to say at this time
whether the mill has an impact at SR 1519. Waynesville's wastewater certainly has an additional effect on the
biota at that location. It is advisable to add a site above the Waynesville W WTP effluent to monitor the potential
impact between SR1519 and SR1692,though there may also be effects from the municipality of Clyde on the
Pigeon River at this point. It seems apparent however,that mill effects are discernible on the Pigeon River,
particularly when the communities from upstream of the mill(NC 215)and downstream of the mill(SR 1642)are
compared in the absence of other recognizable stressors
cc(via email):Serge!Chernikov(Point Source Branch),Roger Edwards(Asheville Regional Office),Keith Haynes
(Asheville Regional Office),Darlene Kucken(Basinwide Planning Unit),Matt Matthews(Point
Source Branch),, Bryn Tracy(Biological Assessment Unit),Susan Wilson(Point Source
Branch),Michelle Woolfolk(Modeling and TMDL Unit),
8

References
BRPP.2006.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 and 2005 biological
assessment, May 2006.Canton,NC Prepared by University of Tennessee,Institute of Agriculture,Department
of Forestry,Wildlife and Fisheries. J Larry Wilson,PhD.Principle Investigator.Knoxville,TN
NCDWQ,2006.Standard Operating Procedures for Benthic Macroinvertebrates.Biological Assessment Unit.
North Carolina Department of Environment and Natural Resources,Division of Water Quality,Water Quality
Section, Environmental Sciences Branch.Raleigh,NC.
9

APPENDIX 1
ra
45 44
m
40 38 37
F 34
F 35 33
W 31 H29
31
30
y
E 25
Z 20
15
10
984 986 1988 cov cow cos 997 2002 2006
Collection Year
'Figure 7.Pigeon River EPT taxa richness at NC 215(year 2006 at city
park),Haywood County,NC between 1984 and 2006.
30
25
25
20
F
W 9 9 9
O 9 fl
N
E 9
m io
7
Z 5
5 4
2
0
984 986 988 9R9 992 994 995 997 2002 2006
Collection Year
Figure S.Pigeon River EPT taxa dchness at SR 1642,Clyde,
Haywood County,NC between 1984 and 2006. `
i SR 1338
35 p SR 1625(1994).SR 1519(2006) 30
xm 30 27
F 25 22
20
45 b S g
O 15
13
E
Z 5
0
988 '994 997 2002 2006
Collection Year
Figure 9.Pigeon River EPT taxa richness at SR 1519,SR1625,and SR 1338,
Haywood County,NC between 1988 and 2006. '
10

APPENDIX 2
Table 2.Site parameters and bioclassifications
River E.Fk.Pigeon Pigeon Pigeon Pigeon Pigeon
Location US 276 NC 215 SR 1642 SR 1519 SR 1338
BIMS Index no. 5-3-(6.5) 5-(7) 5-(7) 5-(7) 5-(7)
Collection Date 7/12/2006 7/12/2006 7M3/2006 7/13/2006 7/13/2006
Habitat
Width(meters) 17 30 40 30 50
Depth(meters) 0.25 0.25 0.6 0.4 0.3
Substrate(%)
Bedrock 10 5 0 20 20
Boulder 20 10 0 20 30
Rubble 40 45 - 25 30 30
Gravel 15 30 40 10 5
Sand 15 5 30 15 15
Silt 0 5 10 5 0
Habitat Score(0-100) 82 70 51 63 73
Physiochemical parameters
Temperature(°C) 18.3 23.2 27.9 26.7 23
Specific Conductance(pmhos/cm) 13 25 638 447 374
Dissolved Oxygen(mg/L) 7.3 8.3 5.0 6.9 7.7
pH 6.3 7.3 7.8 7.6 6.9
Total no. of taxa by order
Ephemeroptera 24 17 4 7 14
-Plecoptera 8 4 0 0 4
Trichoptera 17 13 12 8 12
Coleoptera 4 13 7 9 9
Odonata 4 7 9 7 8
Megaloptera 1 2 1 3 2
Diptera:Chironomidae 32 21 21 17 23
Misc Diptera 9 4 4 4 4
Hemiptera 0 0 0 2 0
Oligocheata 1 2 5 7 6
Crustacea 0 0 1 2 2
Pelycepoda 3 0 2 2 2
Gastropods 1 2 3 6 5
Othertaxa 1 1 2 4 3
Total Taxa Richness 104 86 71 78 94
EPT Taxa Richness 49 34 16 15 30
EPT Abundance 250 164 96 72 179
Biotic Index 3.05 4.61 6.38 6.71 5.43
BioClassification Excellent Good Fair Fair Good-Fair
11

Table 3.Taxa abundance at each site. Abundant taxa that are intolerant(tolerance value between 13)are noted with an'In. and
Very intolerant taxa(51)are noted with by'V.I"abundance value notwithstanding. Very tolerant taxa(>7)are denoted with a
"V.T.".
E.Fk.Pigeon R. Pigeon R. Pigeon R. Pigeon R. Pigeon R.
TAXON US 276 NC 215 SR 1642 SR 1519 SR 1336
Ephemeroptera
Amntml/a sp. A C A C A
Acerpenna pygmaea C
Baefis Navislripa A A A C A
Baetis intercalansv-'' A A A A
Baetis hicaudatus C
Caen/s sp. C C
Dannella lita vi C
Dannella simplex C
Dmnellaalleghenlensis yl C
Dmnella mmutella�' A
Omnella wayah A
Epeoms disparvi A
Epeoms mbidus�' C
EurNophella sp. C R
Eu to hpla minimella yi A
Eupdophella venwmdis R
Habmph/ebia vitimns R
Hepfagenia sp. C
Hepfagenia matginalfs A
Hetemdoeon cudosum C
lsonychia sp. A. A A
Leucmcuta sp. C R R
Neoephemere pulpurea R
Pamleptophleb/a sp.vl R R
Plauddos dub/us gr. R C A
P/auddus punctivenhis C
Pseudocloeon tmndale C
Pseudodoeon pmpinguum C
Stenonema itham 'C A R A
Stenonema medopundatum A A
Stenonema modestum C
Stenonema pudicum A
Sermfella camlina i A
Semafella deficlens R C C
Serrafella sermfa R
Sermtella semafo/des - C
Stenacmn pal/idum R R
Tdcoryfhodessp. R R
Plecoptera
Acroneuda abpomds°i A A R
Chlompedidae R
E=ptum xanthenes R
Isopede holoch/om R
Leucha sp. A C A
Pamgnetfna lmmarginata A C
Pedeste so. C C
Ptemnamys sp. R
Pfemnamys pmteus C
Tel/aped.sp.°i A
12

Table 3 continued.
E.Fk.Pigeon R. Pigeon R. Pigeon R. Pigeon R. Pigeon R.
TAXON US 276 NC 215 SR 1642 SR 1519 SR 1338
Trichoptera _
Beach t eraAppalachia�'� R
Bmchycenhus spine° C
CheumatapsYcp. p A q q
Dolophilodes sp.v1 - A
Glossosoma sp. R R
.Hydmpsyche deplda R
Hydmpsyche demom C
HydmAyche phalemta R
Hydmpsyche mnulads A A A A
Hydmpsychidae R C C
Hydmplila sp. R R
Lep/dostoma sp.°1 A A C A
Leurotrichia pictrpes R C R A
M/crosema mtm R C R C
Neophyax consimilis n A R
Neophylax mitWellvl R
Neophylax gligius R
Neumciipsis sp. A
Oeceu'ssp. R
Oewfispemimilis A A A A
Oligostomis pardalis C
Pplm C
Pslom Pycnopsyche sp.°i A
Rhyacophila Carolina yl R
Rhyacephila fuscula C
Rhyacophila vuphipes vi R
SymphiPopsyche alhedm C
Symphilopsyche momsa°t A C R A
Symphifopsyche slossonee y'�' A
Symphilopsyche spama A A A A
Tdaenodes ignitus R R
Coleoptera .
Amyx vadegatus R
Bemsus sp. R R
Dlneutus sp. R A A R
Elmidae R
Gydnus sp. R R C R
Helichus sp. A C C A
Hydmbius sp. R
Hydmpoms sp.V.T. R A A
Hydmphilidae R
Laccophilus sp. R
Macmnychus glabmNs A C C
MjCmGy"OOpUs PUW7/us R
Neopoms sp. C
Oph'oservus spp R
Optioservus oyalis R
Peltodytes sexmaculatus R
Pmmomsta sp. R R
Pmmomsia elegan C
13

Table 3 continued.
E. Fk.Pigeon R. Pigeon R. Pigeon R. Pigeon R. Pigeon R.
TAXON US 276 NC 215 SR 1642 SR 1519 SR 1338
Coleoptera cont.
Psephenus herricki R
SDemhopsis fesseflatusvI C R R
Stenelmis sp. R C
Stene/mis cmnata C R
Odonata
Argla sp.vT R A A
eoyena vinosa C A A A C
Calopteryx sp. A C
Calopteryx maculafa C
Enallagma sp. C
Gomphus sp. C
Hagenius bmvisty/us R
Hefaedna sp. R A
Hetaenna amerimna A
Ischnum sp. R
Lanthus sp. R _
Lanthus pamulas C
Mamma sp. R C A C
NeurocorduLa sp. C C A A
Neumcordulia obsoleta R R
Ophiogomphus sp. R R
Stylogomphus alb!sMus R R R
Megaloptera
Corydalus comutus R R R A
Nigmnia senfcomis C R R C
Sialis sp. R
Diptera:Chironomidae
Ablabesmyiamallochiv'T C R A A C
Apsectmianypusjohnsoni" R
Bnllla sp. R
Bmndmlella eumorpha R
Cjgtopus bicincfus:do spi R R R C
Onhodadlus obumbmtus gr d0 sp10 R
O.(euorfhodadius)type fir.do sp13 C
Onhwladus(ewrthodaOW I No sp20 R
Onhodadius(ewrfhodadius):do sp3 R
Cdwtopus nr fiamandus:do sp31 R
Cdcotopus vienensis gr do sp46 C
Cdcotopus in(uscatus gr do sp5 R C C
Cardlocladius sp. C R C C
Chimnomus sp. R C R
Conchapelopia group C C C
Copponeum sp. R
Corynoneam sp c epler R
Caa nonema sp h epler C
Cryptochimnomus sp. C R C C C
Oicm_tendipes sp. R
Dicmtendipes�neomodestus �' R A A C
Eukieflenella pseudomontana qr. R
EukieHeriella demnica qr. R
14

Table 3 continued.
E.Fk.Pigeon R. Pigeon R. Pigeon R. Pigeon R. PigeomR.
TAXON US276 NC 215 SR 1642 SR 1519 SR 1336
Diptera:Chironomidae cont.
Labmndima pifose/fa R
Lopesdadiussp. R
Meropelopia sp. A
Micmpsecba sp1°1 C
Micmpsecua sp5a R
Micmfendipesspl C
Nanocladius sp. R R
Nanodadius sp5 C
Nilothaums sp. R
Pamdadopelma undine R
Pammefnocnemus lundbecki C C
Pentaneum sp. R C
Phaenopsedra sp. R
Phaenops— edra0avipes�' q
Polypedifum sp. R R
Polypedilum avimps R C
Polypedifum laflax C
PZeddum flavum C
Polypedilum✓linoense pr.'m'�' C R A
Polypedifum scalaenum C C C
Polthasba lonpimanus R
Pmdadius sp. C R R
Pmdlamesa oWacea R
Rheocrimtopus mbacki '' A q C
Rheocdcotopus tuberadatus C
Rheopefopia acm A
Rheofanytamus sp. C C C
Saafheda Vus R
Stenochlronomus sp. R
Sublehea wffmani R
Synodhmladius sp. A R C C R
Tanytamus sp. C R A
Tanytamus sp2b R
Tanytamus sp3 C C
TanNarsus sp.u A
Thienemaniella xena R R R C C
Tdbefos sp. R
Xylotopus par R
Misc.Diptera
Anfocha sp. R C R R C
Afhenx sp. C
Palpomyia ;flex C
Dicrenota sp.vx A R
Dixa sp. R
Dixella Indiana R
Empididae C R R R
Hexatoma sp. A
Simulium sp. C A C C C
Tipula sp. R R R R
Hemiptera
Hydmmeha sp. R
Ranatra sp. R
15

Table 3 continued.
E.Fk.Pigeon R. Pigeon R. Pigeon R. Pigeon R. Pigeon R.
TAXON US 276 NC 215 SR 1642 SR 1519 SR1338
l)ligochaeta
Ilyodd/us templePoN C R
Llmnodit.sp.�'�' A
L imnoddlus hoflmeistedv'T' A
Lumbdculidae V.I. C 4 R R C A
Megaddle o/igochaete R R R
Nais sp•v.�. C A
Nais vadabtiis - C
Ophidonals se_ryentlne R
Pdstinella sP.v'r' A C
Ripistes pamslta R C
Tubifiddae C
Crustacea ,
Ceeddotea sp. A C
Cmngonyxsp. R A
Gammams sp. R
Pelecypoda
Corbicula fluminea A A A
MUSCU ipm sp. R
Asidium sp. C C C
Maedum sp. R I "
Gastropoda
Ellmla_sp. 1 C C
Feuissia sp. C C R R
Fossada sp. C
Hellsoma anceps A C
mlommenetus dystatus. R c
Physella sp,v" C A A A
Pseudosucmtnea columella C" R
Othertaxa
Erpobdellalmooreobdella C
Helobtlella Wsedalis�C R A'
Hydmcadna R C^ C C
Moomobdella melanbstoma A _
Myzobdefla lu ubds C
Pmstoma gmecens - R
Pyralidae R
16

pppppp—
DIV OF WATER QUALITY Fax:[phone] Mar 29 2006 11:16 P. 01
s°'SGt¢y
�a
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Director's Office
• FAX TRANSMITTAL COVER .
To: Roger Edwards.ARO _
Company: DWQ
Fax#: [phone] Phone#: [phone] ..
From: Alan Klimek
pate: 3129106 Number of pages(including uover'sheet): 3
RFJ4ARKS:
RE: Blue Ridge Paper—For contereuce call on Friday.
Nadine Address Street Address Phone:(919,733-7015
1617 Mail Service Center 912 N.Salisbury St. Fax: [phone]
Raleigh,NC 27699-1617 Rakig),NC 276N u
MAR 2 9 2W6
�.{�� WATER QUALITY SECTION -
�§`�" ASHEVILI_E REGIONAL OFFICE

� a
s
cl
Ov
N d

DIV OF WATER QUALITY Fox:9197332496 Mar 29 2006 11:19 P. 02
03-26^08 - 05+16a+ FrcwrWA Standgrdc. FlonttnnnQ 8 TWIL Branch [phone] T-9d2 P 001/002 F-1 BB
----_---------' -a--:
YIhIITED STATES ENVIRONME pX TKA0SB91TTA . °"^°a`n• "t
Atlanta Fedc �� r�
c 61 Fors)Rlt S asw oi.a
Atlanta,GpOrg a �V.ju 31U4
March 28 2006
Alan Klimek,Dixector
Division of Water Quality (d !�° 1�5 ; Lt (�y
NCDENR
1611 Mail Service Center
Raleigh,NC 27699-1617
U y rr4E (�
Pau]B.1)avis.Director �a!
Division of Water Pollution Control P1
6mF7oorL&CAnnex i /i1 f$!
401 Church Street
Nashville,TN 37423-1534 � r�'ir✓
Re: Ecological Assessment of Me Pigeon River vv
Dcat Alan and Paul:
As you are aware,a numbed of years ago a settlement agreement wa$established to
address the NPDES permitted dlscirarge by Champion International(now Blue Rictae Paper)into
the Pigeon giver- Paragraph 33 of dte settlement agreement directed EPA,in . gperatitm with
the states of North Carolina and T"assee,to make a determination whethOr ccoiggical or health
risks remain in the wateibody aft improvements in the gnality of the dischiuge.li As part of that
determination,EPA,was to conven, a scientific panel to evaluate existing data;identify data
needed and,if necessary,conduct a risk assessment. EPA contracted with Tetia T&ch,Inc.to
review Sara to bolp accomplish th4e tasks. A report of their wvrkhas heert:prepaied. EPA's
intends that this report be used as z{resource to assist with comple4on of the regtuiemem of
Paragraph 33. A copy of that repot[is enclosed.
i
The next steps in the p i ess will be to hold a conference call with i pmseutatives from
Tentlessee and North Carohna to Osc=the current status of the issue$nd 5e&W csvelopiug a
coordinated course of action Torcgmpleting the requirements of this provision of the Settlement
Agreement. This call has been s6eduled for March 31,2006. Dunn.-this call we anticipate
asking for representatives from eavth slate to serve on a wodtgroup to iderdi�y nevi ssary tasks nttd
develop timeline to complete therrxinre^i ted tasks.
\Nn \
0,.c

DIV OF WATER QUALITY Fax:[phone] Mar 29 2006 11:19 P. 03
03-26-86,� 85';6po Frar6PA standards, Mamtorrna a TM➢L Branch [phone] T-842 'g P MAR F•108
/I
if you need further inbunat'n of have any questions,please contact Me W 1'404-562-
9479,or David Melgaad of my stdf at 404-562-9265. Thank you for your adsistaatx in this
effort.
i
sincerely,
Andrew Bartlett,Chief !_
Standards,Monitoring,and TMDL Branch
Enclostmc '
I
i
�i

pppwver Ecological Assessment Conference call]
Subject: [Fwd: Pigeon River Ecological Assessment Conference call]
From: Sergei Chernikov<[e-mail]>
Date: Fri,,31 Mar 2006 10:02:20 -0500
To:Roger Edwards<[e-mail]>
-------- Original Message--------
Subject:Pigeon River Ecological Assessment Conference call
Date:Wed, 29 Mar 2006 17:04:54 -0500
From:Me]gaard.Davidpepamail.epa.gov
To:Paul.Estill.Davispstate.tn.us, sergei.chernikovQncmail.net,[e-mail]
Mitchell.Gailpepamail.epa.gov,Bartlett.Andrewpepamail.epa.gov,
Melville.Williampepamail.epa.gov, Godfrey.Anniepepamail.epa.gov,
Hyatt.Marshallp,epamail.epa.gov
Date: March 31, 2006
Time: 2:00 PM EST
Call in number: 866-299-3188 Conference code: 4045629243 followed by
the # key
Agenda:
1. Discussion of provisions of Paragraph 33 of the Settlement
Agreement
2. Activities completed to date
A. USEPA activities B. State activities
C. Other information (Blue Ridge Paper, Progress Energy, others)
3. Discussion regarding future activities necessary to complete the
requirements of Paragraph 33 (actual language included below)
Thank you again for your assistance.
David Melgaard
U.S. EPA/Water Management Division
61 Forsyth St. , SW
Atlanta, GA 30303
Phone: [phone] -
Fax: [phone]
email: [e-mail]
FYI this is the language of Paragraph 33 .
V. ECOLOGICAL ASSESSMENT OF THE PIGEON RIVER
SYSTEM AND THE WATERVILLE RESERVOIR
33. Over the years, a number of studies have been conducted by
1 of 2 3/31/2006 11:08 AM

PPPIver Ecological Assessment Conference call]
p—various entities on the health of the aquatic biological community in
the Pigeon River and, in particular, analysis of fish flesh
contamination. However, EPA believes that a more current evaluation of
the level of contaminants remaining in the system and the overall health
of the river and of the Waterville Reservoir should be undertaken. EPA
will lead, in cooperation with North Carolina and Tennessee, an
independent evaluation of current information on the Pigeon River. The
evaluation will include convening a group of scientists to evaluate
existing data, to identify additional data needed, and, if necessary, to
conduct an ecological assessment. EPA agrees to take the lead in
convening the scientific panel. The information gathered from such an
assessment would be used to determine whether any significant ecological
or health risks exist, and, if so, what, if any, steps could and should
be taken to address those risks.
Sergei Chernikov, Ph.D.
Environmental Engineer
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
phone: [phone] ext. 594
fax: [phone]
2 of 3/31/2006 11:08 AM

0�WATF9p Pw� Michael F. Easley
�O G Governor
r ©DENR William G. Ross,Jr.,Secretary
North Carolina Department of Environment and Natural Resources
O Y Alan W.Klimek,P.E., Director
Division of Water Quality
March 6, 2006
DRAFT
James D. Giattina, Director
Water Management Division
EPA Region IV, Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Subject: Response to EPA Scientific
Panel Study of Pigeon River
Dear Mr. Giattina:
The North Carolina Division of Water Quality(DWQ, Division)has received the report from EPA
Region IV entitled"Pigeon River Science Panel Data Review and Recommendations". The Division has
a number of serious objections and comments that we would like to bring to your attention.
The report was written to satisfy Paragraph 33 of the Settlement Agreement between EPA,North
Carolina(NC), Tennessee (TN) and several government and non-profit organizations. The Settlement
Agreement, which called for this study, was the result of a challenge by TN and third parties to a 1996
NPDES permit issued for Champion International paper mill (currently Blue Ridge Paper)by the
Division. Paragraph 33 of the Agreement states that"EPA will lead in cooperation with North Carolina
and Tennessee an independent evaluation of current information on the Pigeon River". Despite
requirements of the agreement,NC was not involved in the development of the report and was not
provided an opportunity to comment. The Division has been provided the stated Final Report apparently
as a courtesy.
It appears from reading the report that TN had a role in developing this report. The Division believes
that the presented study is inaccurate, as it contains what we believe are numerous errors and false
statements. For example, there are claims throughout the report that benthic and discharge monitoring
data were not available, when in fact these data are available,but the authors to our knowledge never
requested the data. The authors have instead chosen a"limited"number of parameters to evaluate, have
completed the report under a severe time constraint of three weeks, and fell short of developing a
complete evaluation by not utilizing all the available information. The detailed evaluation of the report,
as well as Divisions' questions and comments are contained in the Appendix to this letter.
Based on the failure of the report to properly address the provisions of the Settlement, the tardiness in
meeting the objectives of the Settlement (all other provisions of the Agreement were met long ago with
the exception of this "Final Report") and the overall limited scope of this effort, we believe EPA should
retract this report as fulfillment of Paragraph 33 of the Settlement Agreement. While NC sees no basis
N.C.Division of Water Quality I NPDES Unit Phone:[phone]
1617 Mail Service Center,Raleigh,NC 27699-1617 fax:[phone]
Internet:www.ncwaterquality.org DENR Customer Service Center:1 800 623-7748

PPP
Letter to James D. Giattina -2-
for developing this report at this late date, any effort to proceed should follow the provisions, as stated in
Paragraph 33 of the Settlement Agreement, of including all parties in its development. If EPA will
undertake this inclusive effort,we expect EPA to establish a detailed list of activities and a time line for
report development in accordance with the Settlement Agreement. These activities and objectives should_
be supported by all parties before any effort can move forward.
Again, based on the above we strongly object to the report as it stands now and request that EPA retract
this Final Report. Should EPA choose to develop an inclusive report,we request that your staff contact
us to allow full NC and TNparticipation in this process. The Division cannot support the current
recommended activities in the report as we do not consider it complete and accurate. Division staff hope
to have a conference call with EPA Region IV staff in the near future.
Sincerely,
Alan W. Klimek,P.E.,Director
Division of Water Quality
cc: David Melgaard,EPA, Region IV
Marshall Hyatt,EPA,Region IV
NPDES Files(Permit#NC0000272)
Asheville Regional Office,Surface Water Protection
Environmental Sciences Section,Biological Assessment Unit
Dan Oakley, DENR

PLetter to James D. Giattina -3 -
Appendix
I.Issues within the Report as it Exists Today
Considering the comments already made, it is important to at least look at the Report, as it exists to get
some consideration of the evaluation it offers.
In looking at the reason this report was being done—paragraph 33 of the December, 1997 Settlement
Agreement—the charge was "EPA will lead, in cooperation with North Carolina and Tennessee, an
independent evaluation of current information on the Pigeon River". The evaluation was to include a
convened group of scientists to:
1) evaluate existing data
2) identify additional data needed
3) and, if necessary, conduct an ecological assessment
Contrary to the charge, instead of a collaborative evaluation, it appears EPA assigned this task to a
group of three scientists,with perhaps some input from Tennessee and no input from North Carolina. It
appears the Panel tried to complete task 1) for data through 2004, made some recommendations that
attempted to address task 2) (possible data that could be collected in the future for conducting an
ecological assessment), and for task 3) failed to do an ecological assessment.
In relation to the data review, the report doesn't seem to incorporate significant data sources that are -
available through NC and other agencies/groups, particularly the electronic databases within NC DWQ's
Environmental Sciences Section and the effluent and in stream monitoring data collected under the
NPDES permit. The staff at DWQ could have been extremely helpful in providing this information and
to providing the"Panel"with insight on the data and the extensive history of study within this
watershed. Some of the recommendations made by the "panel"clearly show a lack of knowledge about
the work that has been done on the river.
A significant amount of work has been performed during 2005 to document ecological improvements in
the river and to develop essential information for the 2006 permit renewal. Considering the report has
already been delayed for nearly ten years, it would seem prudent at this time to at least incorporate
recent data which would provide a better understanding of the river's ecological health today.
By limiting the data review process and by excluding the NC agency personnel with extensive
knowledge of the Pigeon and this ecosystem, this process failed to get at true and accurate look at the
issues, as they exist today.
The Panel findings utilizing data from 1983 to 2004 seem to be:
1) Lack of continuity—data was not gathered continuously and consistently over the two decades
2) Sampling and methods of calculating benthic communities differ between NC and TN
3) Significant improvements in water quality occurred during the early 1990's
4) Substantial improvements to the benthic and fish communities have clearly occurred over time
5) Downstream fish communities show an increasing diversity of native species—suggesting
substantial improvement in the ecological condition of the Lower Pigeon River

PLetter to James D. Giattina -4-
6) Dioxin concentrations iri fish has decreased substantially such that consumption advisories
have been eliminated in TN and rescinded to include only common carp in Waterville
Reservoir in NC
From those findings, there is no conclusion that the Pigeon River presents any ecological health risk and
the only human health risk appears to be for those people who may eat common carp from Waterville
Reservoir(this is a very low risk indeed). In looking at the data for dioxin and understanding the
changes at the mill, it is clear that dioxin is steadily decreasing in fish and should soon be at levels
where the last consumption advisory can be removed.
Although there was no stated reason or logical argument provided to conclude that a future ecological
assessment needed to be performed, the Panel recommended activities that could be done,presumably
by state agencies, in the future. They include:
1) Centralized banking of data
2) Periodic synoptic benthic surveys
3) Continuous DO, temperature, and conductivity monitoring at three places on the Pigeon River
and some unidentified number of major tributaries.
4) Reduce dioxin sampling of bottom feeding fish in Waterville Reservoir to once every five
years—all that is needed to confirm that dioxin will remain below levels of health concern.
Perhaps monitor dioxin in sediments and other biota.
5) Perform sediment transport modeling
6) A general list of ecological information about pollutant levels, stressors, organism responses,
predators, etc.
These recommendations are clearly beyond any scope of the intention of Paragraph 33 and would
represent an unsupportable portion of either NC water quality monitoring budgets for the entire state.
Should EPA choose to fund the type of ongoing data collection on the Pigeon River,NC will be happy
to participate. These conclusions represent a"research project"view of this system rather than a
realistic review of the extensive database available on this system and the dramatic improvement in
environmental quality over the last few years. The"panel" failed to establish any basis for needing this
kind of unprecedented assessment. The Pigeon River system is well on its way to full recovery and is
currently.meeting State and Federal standards in these regards.
II. Specific Questions and Comments
1. Did the Science Panel make a site visit to the mill,the watershed, Walters Lake,the Pigeon
River, etc.? If so, we request at this time all reports and data obtained or generated as a result of
those visit(s).
2. Did the three authors constitute the entire "Science Panel"? If not,please describe the panel
makeup.
3. p. i. Why has the panel conducted a short-term intensive review of the data? Who imposed the
three-week time constraint and why was it done? The volume of existing data is substantial and
we feel that a three-week time constraint may have prevented the panel from developing a
complete and thorough report.
4. p ii. The Division disagrees with statement that benthic community patterns suggest responses to
spatial differences in habitat and possibly to other inputs when the plant discharge makes up 90%

PLetter to James D. Giattina -5-
of the river at low flow, that discharge is the primary influence until it is comparable to what
comes in the intake.
5. p. ii. The mill's dissolved oxygen monitoring record is extensive as are its DMRs.
6. p. iii. Synoptic surveys covering many points on the river is not feasible because much of the
river is not wadeable and we feel that EMAP Wadeable Streams sampling protocols should never
be used.
7. p. iii. The sediment transport modeling was performed already by CP&L in 1991 -- refer to
Lawler, J. P. and B. H. Tracy. 1995. Environmental issues in relicensing hearings for Carolina
Power and Light Company's Walters Hydroelectric Plant on the Pigeon River, NC. Proc.
Internat. Conf. Hydropower. J. J. Cassidy(ed.). Waterpower '95. San Francisco, CA. pp. 301 -
310. Was this peer-reviewed paper read by the"Science Panel"?
8. p. 1. Class A trout waters -- this classification is not used by DWQ nor by the NC Wildlife
Resources Commission.
9. p. 2. Walters Dam was not built in 1930. The hydroelectric plant became fully operational on
October 29, 1929. -
10. p. 3. and p. 5. The data have been collected from the Pigeon River since at least 1940 and
possibly as early as 1908.
11. p. 4. All DWQ, BRP, and Progress Energy data are traceable to methods, SOPS, site descriptions,
reports, fish species analyzed for contaminants, QA/QC, etc.
12. p. 4. The Division disagrees with statement that that there is "lack of any commonality in
application ofstation mmnes". All sites are known by all researchers and are all geo-referenced.
13. p. 4. The RM 39 is not"near the reservoir dam", it's one mile from the dam.
14. p. 4. (and throughout the report) The Division would like to strongly stress that benthic data was
never asked for. We supply our data electronically to anyone and everyone who asks for it. We
were never asked for the data. Significant amount of data are available on the web and all are
available electronically or in hard copy.
15.p. 5. Wrong names were used for DWQ and DENR.
16. p. 5. Why the did the"Panel"review only a limited number of parameters?How can an unbiased
report be prepared if all parameters are not reviewed?
17. p. 7. Blue Ridge Paper (BRP) and DWQ have many "fixed stations" along the Pigeon River that
are sampled at minimum monthly and some hourly, daily or weekly.
18.p. 8. The report does not mention BRP or DWQ discharge monitoring reports (DMR) and
ambient monitoring data; no mention of Progress Energy's 2004 data.
19. p. 9. and 10. DWQ benthic macroinvertebrate data have been collected following a consistent
SOP for nearly 20 years.
20. p. 10. The NC benthic program has the NCBI which is a Biotic Index not Biotic Integrity, and
the Tennessee IBI is.a fishery index, not a benthic one.

Letter to James D. Giattina -6 -
21. p. 11. Benthic data collected by DWQ, BRP, and Progress Energy have always been readily
available.
22.p. 11. -- It is true that DWQ fisheries data are available only for tributaries to the Pigeon River.
We are not staffed to sample large rivers. Data are available electronically and in hard copy,but
it was never requested by the"Panel".
23.p. 11. The report did not mention that DWQ has been a participant and one of the initial
members on the Re-introduction Project for the NC portion of the river.
24. p. 11. 2004 and 2005 data are available on reintroduction numbers.
25. p. 11. To the best of our knowledge, the DWQ staff has never put biological data into STORET,
therefore we don't know what data was extracted and why it contains so many errors.
26. p. 12. The report did not consider BRP data from 2005 or 2000 or from earlier years.
27. p. 12. The Division was not contacted for fisheries data.
28. p. 12.NCDENR, 2004 is not in the references.
29. p. 13. The Division would like to note that TVA generally does not sample tributaries, they tend
to sample mainstem reaches of river while DWQ samples the tributaries.
30. p. 14. DWQ does not monitor for dioxins and furans, BRP and Progress Energy are required to
by NPDES permit and FERC License requirements.
31. p. 15. The Division needs clarification on"all other types of toxicant data".
32. p. 15. The Division disagrees with the statement that"no data were provided on the fish species
sampled". All fish tissue contaminant data collected by BRP,DWQ, and Progress Energy are
tracked by species and have been since the mid-1980s.
33. p. 15. The statement that WWTP discharge monitoring data were not available to the"Panel" is
false. The "Panel"has never contacted DWQ to request the data.
34. p. 16. The report did not consider dioxin in sediment data collected by CP&L in 1991.
35. p. 18. 3rd paragraph. There are no "macrophyte beds" in the river. Their presence in 2002 was
due to an exceptional,prolonged drought and such beds were not seen before or since then. The
mats do not settle out in the reservoir and contribute to the organic loading of the reservoir.
36. p. 20. The "prolific weed growths"was a one time event not seen previously or since then.
37. p. 20. The Division disagrees with the statement that habitat data are not reported, since 1998
every NC biological sample has a habitat form filled out at the time of sampling.
38. p. 21. The Division would like to emphasize that the Tennessee portion of the river is in a
different ecoregion than the upstream portion and is also of much larger size.
39. p. 21. The report mentions green darter, we are unaware of this species, did the"Panel"mean
greenside darter?

PPP
Letter to James D. Giattina 7-
40.p. 21. One would not expect gizzard shad in high gradient, cool waters as are found in much of
the NC portion of the river.
41.p. 21. In the absence of the mill,it could be possible to predict what the fish community would
be like. There are other rivers the size of the Pigeon River in western NC from which such
comparisons could be made.
42. p. 26. Figure 3 should be Figure 23.
43. p. 26. Are fish found at depths of 30 - 35 m near the dam? What are the dissolved oxygen levels
in the hypolimnetic waters? Do common carp inhabit such depths?
44. p. 27. There are few depositional areas above the reservoir, which is why common carp still tend
to pick up a low dose of dioxins in the reservoir.
45. p. 27. Were temporal reservoir level fluctuations examined?
46. p. 27. The bypass reach of the Pigeon River is a very atypical reach in terms of flow and its fish
communities.
47. p. 28. The DMR data from BRP has always been readily available.
48. p. 28. The flow monitoring data are available at nine sites within the Pigeon River watershed in
NC.
49. p. 29. Why does the "Panel'believe that dissolved oxygen is a problem at the base of the
bypassed reach? It has never been identified as a problem in that reach of the river.
50. p. 30. Comments already provided for the I&M of Data.
51. p. 30. The fate and transport of dioxins in sediment and fish are known.
52. p. 31. Did the"Panel'review Lawler and Tracy(1995) or any of the FERC documents and
testimony of expert witnesses related to the issue of contaminated sediments?
53. p. 31. Is there any evidence of risk from bioaccumulation of toxins in higher predators (e.g., river
otters) in the Pigeon River system?
54. p. 31. Does the "Panel'understand that any future release of water from the dam will not be
from the hypolimnion and will not be transporting sediments from the reservoir to the bypass
reach?
55. p. 31. The database for fish tissue contaminants now includes more than 15 years worth of data,
probably one of the longest continuous monitoring of dioxins in the country. Therefore,
statement- "limited fish tissue contaminant concentrations" is highly inaccurate.
56. p. 31. As stated previously, the macrophytes growths was a one-time, limited event.
57. p. 31. Due to the gradient of the river, the only zone for contaminant deposition is in the
reservoir.
58. p. 31. Southeastern Fishes Council, 2003 is not listed in the References.

Letter to James.D. Giattina -8-
59. p. 32. What are the diets of river otters and great blue herons, ospreys or other birds of prey?
These species typically do not consuming 5-10+year old common carp. The number of common
carp may actually be decreasing in the reservoir.
60. p. 35. The meeting on January 19, 2005 was not attended by anyone from the"Panel'nor by
anyone from US EPA.
61. p. 37. The map is very difficult to read.
62. p. 41. The report does not mention 2003 and 2004 data.

[Fwd:Pigeon River Ecological Assessment Conference Call]
Subject: [Fwd: Pigeon River Ecological Assessment Conference Call]
From: Sergei Chernikov<[e-mail]>
Date: Fri, 24 Mar 2006 09:07:59 -0500
To: Bryn Tracy<[e-mail]>, Roger Edwards<[e-mail]>, Trish
MacPherson<[e-mail]>
-------- Original Message --------
Subject:Pigeon River Ecological Assessment Conference Call
Date-Thu, 23 Mar 2006 15:56:30-0500
From:[e-mail]
To:Paul.Estill.Davis cr,state.tn.us, dave.mckinney(cDstate.tn.us, sergei.chemikov6E�ncmail.net
CC:Mitchell.Gail oepamail.epa.gov, Bartlett.Andrew cr,epamail.epa.gov,
Melville.William(,epamail.epa.gov, Hyatt.Marshallna,epamail.epa.gov
To all:
This message is to provide the conference call number for our call next
week regarding the Pigeon River ecological assessment task.
Date: March 31, 2006
Time: 2:00 PM EST
Call in number: 866-299-3188; you will be asked to key in the
conference code
Conference call code: 4045629243
I am still working on the agenda and will send it out next week.
Thank you for your cooperation.
David Melgaard-
U.S. EPA/Water Management Division
61 Forsyth St. , SW
Atlanta, GA 30303
Phone: [phone]
Fax: [phone]
email: melgaard.davideepa.gov
Sergei Chernikov, Ph.D.
Environmental Engineer
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
phone: [phone] ext. 594
fax: [phone]
1 of 1 3/24/2006 9:33 AM