NC0000272_TN Wildlief Resources Color Reduction Position_20120921

%E SS,
�� TENNESSEE WILDLIFE RESOURCES AGENCY
WILDUF RESOURCES ELLINGTON AGRICULTURAL CENTER
+t P. O. BOX 40747
NASHVILLE, TENNESSEE 37204
gC�NO�t
September 21, 2012
Dr. Sergei Chernikov, Ph.D.
Division of Water Quality
North Carolina Department of Environment and National Resources
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
Re: Blue Ridge Paper—Pigeon River
Color Reduction
Canton, North Carolina
Dear Dr. Chernikov:
The Tennessee Wildlife Resources Agency has had the opportunity to review the color reduction
pilot project(s) and feasibility report as submitted by Blue Ridge Paper, Inc. under the current
National Pollution Discharge Elimination System (NPDES)permit. Just prior to the release of
this report, we had an opportunity to meet with representatives of the Blue Ridge Paper, Inc. mill
from Canton, North Carolina, representatives from Evergreen's corporate office in Memphis,
Tennessee, and their lobbying firm from Nashville, Tennessee.
In both the report and the meeting the message from Blue Ridge and Evergreen is consistent. The
current status of color reduction can be summarized as follows:
• 2012 represents at least the fourth consecutive year without significant reduction of color
loading to the Pigeon River. Total color loading in the range of 38,000 pounds per day
has not improved during this period.
• 2012 represents at least the third consecutive year without significant progress in
controlling process color spikes and variability resulting in color loading to the Pigeon
River.
• Blue Ridge Paper has abandoned the effort to reduce color loading to the Pigeon River to
the 32,000 pounds per day goal established for this NPDES permit.
• Blue Ridge Paper has concluded the long range goal of reduction of total color loading to
the mid-twenty thousand pounds per day, a loading factor at which color would cease to
be an issue in the Pigeon River, is not feasible and is no longer necessary.
All parties entered into the incremental color reduction strategy with the full understanding that
progress would become increasingly difficult as the mill approached the mid-twenty thousand
The State of Tennessee

pounds per day for total color loading. Our commitment to an incremental color reduction
strategy has always had two basic components. (1) We expect a fully restored Pigeon River and
(2) that failure of technology cannot result in an entitlement to pollute the Pigeon River in
Tennessee.
At least three options are and have been available to resolve this issue:
• Make a product that incorporates color.
• Ship black-liquor off site for treatment.
• Bring pulp to the mill from another facility.
If it is the case that Blue Ridge has come to the conclusion that no technology is available to
reach color reduction goals, then it is time to consider use of alternative methodology. It
continues to be our experience that the periodic presence of characteristic paper mill odor in the
water significantly effects how the public using the Pigeon River in Tennessee for recreation
regards color, water contact recreation, and whether or not fish should be consumed.
As always, your time and attention to this important matter is greatly appreciated. We request
that North Carolina take those actions necessary to require Blue Ridge Paper to reconsider the
decision to abandon further color reduction and the goal of a fully restored Pigeon River.
Sincerely,
76�
Aubrey D. McKinney
Chief, Division of Environmental Services
ADM/ds
cc: Jonathon Burr, WPC/TDEC, Knoxville
Ed Carter, Director, TWRA