NC0000272_Correspondence_20161118

Charles C.Coutant,Ph.D. 120 Miramar Circle
Aquatic Ecologist Oak Ridge,TN 37830-8220
865-483-5976
e-mail: [e-mail]
November 18,2016
Nick McCracken
Water Supervisor
Evergreen Packaging—Canton Mill
175 Main Street
Canton,N.C.28716
Via email to Nick.McCrackenC'everpack.com
Dear Nick:
At William Clarke's request,I have examined thermal and biological information relevant to
Evergreen Packaging's Canton Mill not being able to meet its 8.5°C maximum monthly average
temperature rise during the current drought.At issue is an anticipated violation in November
based on river-temperature data taken through November 16,2016.
A table of daily temperatures for November 1-16 above the facility (Canton)and at several
stations downstream of the facility(Fiberville,Above Clyde,and HEPCO)shows an average
upstream temperature of 10.2°C and an average of 20.1°C at Fiberville,for an average
temperature rise due to the facility of 9.9°C and a Fiberville monthly maximum temperature of
22.8°C on November 1.Temperatures at Above Clyde and HEPCO show that the river is cooling
in November both going downstream(average 5 YC decline between Fiberville and Above
Clyde)and over time(Fiberville temperatures declined from 22.8°C on November 1 to 14.5°C on
November 16)as would be expected at this time of year.
The temperatures in the river would not be a problem at this time of year based on the biological
evidence from the years of sampling for permit renewals 1316(a) report of 2013,submitted to
DWQ in January 20141.Temperatures even at Fiberville are not only tolerable for the river biota,
but mostly are within the optimal range for warm-water stream organisms in summer.In this
cooling phase of the annual cycle,the temperatures at Above Clyde have declined in November
to levels that would be fine for even cold-water life such as trout.Even when the 8.5°C maximum
rise in the permit is exceeded at Fiberville it is clear that this would not constitute a rise into a
biologically detrimental temperature range.
It is generally accepted by biologists that the margin for temperature rise is the smallest in warm
ambient temperatures of summer(when the 8.5°C limit at the Canton mill is important)and is
larger when ambient temperatures are lower.See the attached figure,which illustrates the point
although it is from a different facility and species not from the Pigeon River. It is fortunate that
the drought with its extremely low flows in the Pigeon River is having its effect in the fall when
ambient temperatures are low and declining.
Thus,I support the company's request for a temporary waiver of the 8.5°C maximum monthly
temperature rise for the duration of the current drought this fall.
Sincerel ,
.:Charles C.Cout Ant, h 6D 'j
�
1

Figure:
An illustration of the larger margin of safety for aquatic organisms above ambient temperatures in
November than in summer(data for striped bass and white perch).
The graph is for water temperature(°F)over an annual cycle. The solid line is ambient
temperature of the water body in a year with historically average temperatures. The dotted line is
ambient temperature plus 12°F,which is the temperature elevation of the thermal discharge at the
facility(Salem Generating Station). The numbered squares, circles and triangles are
experimentally determined lethal temperatures placed at the calendar date corresponding to the
ambient(initial acclimation)temperature of fish in the tests (numbers refer to the literature
citations). Whereas the lethal temperatures are close to 12°F above ambient(the thermal-
discharge temperature)in summer,they are about 22°F above ambient temperature in November
(and about 10°F above the thermal-discharge temperature).
(a)upper Survival Data- Temperate Bass -Average Year
Primary Seasonal Distributlon
Upper SurrvivaI Data
so ®2 ,9...i.,..
1 2 2 e 2 2 .. 2 2�
80 2 2 4
` 2 2 Z
3 2 2
70
`m 2
Q
E 60 Maximum EOZ Exposure _
H
�,.• Primary Seasonal Dislribuiinn
50 Striped pass 1+&order
Striped pass o+
tttttt� White perch 1*&older Ambient Temperature
40 White perch 0+ [1 in 2 year]
30 week
1 5 9 13 1
7 21 25 29 33 31 41 45 49
Month
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
2