NC0000272_316a Study Plan_20120412

evergreen".I& Canton Off ice
packaging 175 Moire 51reer• Canton, NC 28716
PSD 29-12
12 April 2012
CERTIFIED MAIL
Tom Belnick RETURN RECEIPT REQUESTED
Supervisor, Complex NPDES Permitting Unit 7008 3230 0002 2591 1649
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Services Center
Raleigh,North Carolina 27699-1617
Subject: 316(a) Study Plan—Revised for DWQ ESS Comments
NPDES Permit NC0000272
Blue Ridge Paper Products Inc.
Canton Mill
Dear Mr. Belnick—
Enclosed are two copies of the 316(a) Study Plan required by Part I Condition A.(12.) of the subject
permit. This is a revised plan incorporating comments from the Division of Water Quality(DWQ),
Environmental Sciences Section(ESS)dated April 2,2012 and forwarded to us for evaluation.
Representatives of the ESS discussed their comments with the 316(a)Project Team during the March 20,
2012 laboratory certification visit to the University of Tennessee Department of Forestry,Wildlife and
Fisheries in Knoxville.
We understand that EPA Region IV on March 28,2012 provided an e-mail stating"no comments"on the
316(a) Study Plan submitted in February 2012. We request DWQ formal approval of this revised 316(a)
Study Plan dated April 2012. Field work is scheduled to begin this quarter.
Very truly yours,
BLUE RIDGE PAPER PRODUCTS INC.
DOING BUSINESS AS EVERGREEN PACKAGING
Paul Dickens Nick McCracken
Manager—Environmental Affairs Water Compliance Coordinator
828-646-6141 828-646-2874
paul.dickenskeve�ack.com nick.mccrackenkeve�ack.com
Enclosure: Revised 316(a) Study Plan—April 2012
cc(w/enclosure): DWQ ARO
316(a) Study Team
Internal Distribution fresh by design.
Doing Business in California as Evergreen Beverage Packaging

April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No. NC0000272
Part I A.(12.) of the May 2010 NPDES Permit (the Permit) is the special condition for review of
316(a) alternative thermal limits and states:
Blue Ridge Paper shall complete an analysis of temperature, including thermal modeling
and shall submit a balanced and indigenous species study, no later than 180 days prior
to permit expiration date. As part of this analysis, Blue Ridge Paper shall submit a
complete temperature variance report documenting the need for a continued temperature
variance. The temperature delta of 8.5 deg C can be adjusted based on the results of the
BIP[sic, balanced and indigenous population] thermal modeling.
The study shall be performed in accordance with the Division of Water Quality approved
plan. The temperature analysis and the balanced and indigenous study plan shall
conform to the specifications outlined in 40 CFR 125 Subpart Hand the EPA's Draft
316a Guidance Manual, dated 1977. The EPA shall be provided an opportunity to
review the plan prior to commencement of the study.
This document is the proposed 316(a) Study Plan. Blue Ridge Paper Products (Blue Ridge,
BRPP) dba Evergreen Packaging contracted with the University Of Tennessee, Knoxville
Department of Forestry, Wildlife and Fisheries (UTK) to prepare the Plan. Key project
personnel and consultants include Dr. Larry Wilson, Dr. Chuck Coutant, Dr. John Tyner and Dr.
David Etnier. UTK performed the May 2006 316(a) Demonstration submitted in support of the
application for the current Permit. They also manage the Pigeon River Restoration Project
(PRRP)—a nationally recognized, multi-agency and multi-state project restoring non-game fish
species in the Pigeon River. The success of the PRRP was made possible, in part, by the
improvements in water quality in the Pigeon River.
UTK will perform biological field sampling, thermal field monitoring, thermal modeling, and
data analysis for the 316(a) Demonstration due in December 2014 at the time the application to
renew the Permit is submitted. Field work for the 316(a) Demonstration is scheduled for the
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No. NC0000272
summer of 2012 with the summer of 2013 as contingency if river conditions in 2012 do not
allow safe access for field sampling. The 316(a) Study Plan addresses comments in the
February 22, 2010 EPA letter objecting to the November 2009 draft NPDES permit for the
Canton Mill issued by the North Carolina Division of Water Quality(DWQ). The Study Plan
also addresses the May 9, 2011 findings of the EPA Inspector General concerning EPA oversight
of 316(a) alternative effluent limits in permits issued by the DWQ.
The Study Plan builds on extensive knowledge of and experience with the Pigeon River
developed by BRPP, UTK and others during previous 316(a) field studies in 1995, 2000 and
2005 and in the 10-year history of the PRRP. Scientists with the DWQ Environmental Sciences
Section(ESS)were consulted for advice on reference streams, monitoring techniques and
laboratory certification during preparation of the Plan. Field sampling methods will match the
level of effort used in previous 316(a) study work to provide consistent trends and data
comparison between studies. UTK will also employ streamlined rapid bio-assessment methods
developed by the DWQ ESS for correlation with previous 316(s) studies and for benchmarking
against North Carolina metrics for biological integrity.
The overall goal of this 316(a) Study Plan is demonstration that existing thermal management
practices of the Canton Mill are protective of the aquatic environment in the Pigeon River.
Approval of this plan by the DWQ in consultation with EPA Region IV is requested no later than
May 2012 so that field work scheduled for summer of 2012 can proceed. The detailed plan
prepared by UTK follows.
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
Study Plan for Blue Ridge Paper Products'2014 316(a)Thermal Discharge Demonstration
OUTLINE:
Introduction
Section A: General Description
1.Temperature Measurement and Modeling
2. Biological Sampling and Analyses
3. BIP Demonstration
Section B: Detailed Study Plan
1.Temperature Measurement and Modeling
a. Data collection
b.Temperature model calibration and verification
c.Thermal plume characterization
2. Biological Sampling and Analyses
a. Fish
b. Macro-invertebrates/shellfish
c. Periphyton
d. Wildlife
Section C: Certification and Permitting
Figures
Project Team
References
Copy of Enclosure to February 22, 2010 EPA letter with requirements for 316(a) Study Plan
Copy of April 2, 2012 NC DWQ ESS memorandum with comments on Feb 2012 Study Plan
Introduction
An application for a renewed NPDES permit for the Blue Ridge Mill at Canton, North Carolina will
request alternative limits from otherwise applicable water quality standards for temperature for the
Pigeon River downstream of the mill. The request is made in accordance with Section 316(a) of the
Federal Water Pollution Control Act, as amended (Clean Water Act); its implementing regulations in 40
CFR Part 125, Subpart H; EPA's Guidance (Interagency 316(a) Technical Guidance Manual and Guide for
Thermal Effects Sections of Nuclear Facilities Environmental Impact Statements, 1977); and key
administrative and judicial precedents.
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
To obtain such alternative limits, Blue Ridge is required to demonstrate that the proposed limits will
"assure the projection [sic; protection] and propagation of a balanced, indigenous population ["BIP"] of
shellfish,fish, and wildlife in and on the body of water into which the discharge is to be made" (Section
316(a) Clean Water Act). Section 316(a) alternative thermal limits have been issued for the Blue Ridge
mill previously.This demonstration is for a renewal for an existing discharge.
As an existing discharger,the Blue Ridge Mill will follow a retrospective demonstration that is based on
"the absence of prior appreciable harm" in the recent past (125.73(c)(1)), augmented with data from
laboratory and field studies from the scientific literature that are normally used for predictive
demonstrations. Because the Pigeon River was historically affected by both point and non-point
pollution sources (largely chemical and sediment, but also thermal), the application will show that
"despite the occurrence of such previous harm, the desired alternative effluent limitations (or
appropriate modifications thereof)will nevertheless assure the protection and propagation of[the BIP]"
(125.73(c)(1)(ii). Historical studies of the river will be used to track the trend of improving biological
conditions under the prevailing effluent limitations (in accord with the importance of trends established
by the Environmental Appeals board decision in In Re:Dominion Energy Brayton Point, LLC, 12
Environmental Appeals Decision (E.A.D.)490(2006).
Renewal applications generally require "only such information described in paragraphs (a) and (b) of this
section"[125.72] and in 124.73(c)(1) "as the Director requests within 60 days after receipt of the permit
application" (Subpart H, 125.72(c)). We have taken the enclosure to the February 22, 2010 letter from
James G. Giattina, EPA Region 4,to Coleen H. Sullins, North Carolina Department of Environment and
Natural Resources, as direction for the content of the updated 316(a)study. That enclosure is
incorporated by reference and included at the end of this plan.
In preparing this study plan, Blue Ridge and UTK were cognizant of EPA's caution against overly
extensive field studies (EPA Guidance, Section 2.1.3):
The net result of this combination of situations is that[companies with thermal discharges]have often
embarked, without benefit of appropriate screening or pilot studies, on large-scale, expensive,
inappropriate studies which supply massive amounts of raw data but are not necessarily helpful to
regulatory agencies in decision-making.
The decision train suggested by this manual encourages the utility to conduct preliminary pilot or
screening procedures to determine how detailed the baseline biotic community studies should
be. (A]n emphasis has been placed upon identifying those types of information most relevant for
decision making and for deleting data requirements which have been found to be of little use in
past 316(a)decisions.
To meet the standards of proof established by the assessment guidelines and subsequent legal
interpretations,the assessments in this demonstration will seek to provide reasonable assurance of
their conclusions by using the best information reasonably attainable,the best methods reasonably
available (generally accepted practice, results of studies), and multiple lines of evidence.
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
This study plan describes the method by which Blue Ridge proposes to demonstrate that the otherwise
applicable thermal discharge effluent limitations are more stringent than necessary(ref. 40 CFR Part
125, Subpart H, 125.72(a) (2)). Section A below is a brief summary that provides the general information
required for early screening of applications (125.72(a)); Section B provides the "detailed study plan"
(125.72(b))for(1)thermal measurement and modeling, and (2) biological sampling.
Section A: General Description
The study and analyses will consist of three main components: (1)temperature measurement and
modeling that will characterize the temperature changes caused by the thermal discharge, (2) biological
sampling and analysis that will demonstrate the protectiveness of the proposed alternative limits, and
(3) the "Demonstration"that integrates the thermal and biological data with information from the
scientific literature in a manner that specifically addresses the criteria for a BIP that are itemized in 40
CFR 125.71(c), Subpart H; EPA's Guidance Manual; administrative and judicial precedents; and the
February 22, 2010 letter from J. G. Giattina of EPA referenced above. As stipulated in EPA's guidance
manual,the demonstration will be summarized in a "Master Rationale" supporting the alternative
effluent limitations.
The primary region of study is the Pigeon River from immediately upstream of Canton, North Carolina
(River Mile, PRM 64.5), to the upstream extent of the reservoir(Waterville Lake; PRM 42.6)formed by
Walters Dam (Figure 1; see Section B,Task 2 for list of biological sampling sites on Pigeon and
tributaries). This corresponds to the "primary study area" described in the EPA Guidance Manual
(Section 4, page 78). Heat balance of the reservoir obliterates the influence of the Canton Mill on
temperatures there and farther downstream (thus,there is no "far field study area"; EPA Guidance,
page 76). Additional sampling sites will be determined, including locations farther upstream on the
Pigeon River and its main tributaries, and also on a nearby 'reference' river of comparable basin
morphology, as suggested by EPA on the basis of the Brayton appeal decision (Giattina February 22,
2010 letter). The reference stream will be the Swannanoa River in the French Broad River Basin in
Buncombe County, North Carolina (Figure 2: Reference river temperature and biological sampling
stations).
1. Temperature measurement and modeling
Temperature monitors will be placed in the Pigeon River and its major tributaries upstream and
downstream of the Blue Ridge thermal discharge in periods representing summer and winter conditions;
they will be placed at similar locations as in the 2005 study (see list below). Monitors will also be placed
in a reference river comparable to the reach of the Pigeon River influenced by the mill. The Swannanoa
River in North Carolina has been designated as the reference river. The Swannanoa is in the French
Broad river basin, has similar headwater elevation and gradient characteristics as the Pigeon River, and
has a similar pattern of land use and development.
Thermal sampling locations on the Pigeon River(PRM) and the Swannanoa River(SRM) are as follows:
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
River Mile Location
PRM 64.5 Above Mill
PRM 63.3 Mill Outfall
PRM 63.2 Railroad Bridge below Outfall
PRM 63.15 Camp Creek-Tributary
PRM 63.0 Fiberville Bridge
PRM 62.9 Beaver Dam Creek-Tributary
PRM 62.5 Pump Station
PRM 61.0 DO Station -Thickety
PRM 59.0 Above Clyde
PRM 55.5 HyderMountain - Below Clyde
PRM 54.9 Richland Creek-Tributary
PRM 53.5 RiverView
PRM 49.8 Crabtree Creek-Tributary
PRM 46.0 Jonathan Creek -Tributary
PRM 45.1 Hepco Gage
PRM 42.7 Fines Creek -Tributary
PRM 42.6 Hepco Bridge
PRM 25.2 Waterville
PRM 22.0 Trail Hollow- Hartford
PRM19.3 Bluffton
SRM 11.3 Warren Wilson College
SRM 1.6 Exit 50 at 1-40
Hydrographic and meteorological data for the Pigeon River and vicinity will be obtained. The US
Geological Survey's flow monitoring stations, the Canton Mill meteorological station, and the National
Weather Service's regional weather monitoring stations will be used, as appropriate.
The measured temperatures, hydrographic data, and meteorological data will be used to update a one-
dimensional thermal model of the Pigeon River from upstream of the mill to Waterville Lake (aka
Walters Lake). The thermal model developed for the 2006 316(a) demonstration will be updated with
temperature and river flow data from 2005-2011, available from Blue Ridge NPDES permit monitoring in
the study reach, as well as the detailed temperature monitors deployed in 2012. The calibrated and
verified model will then be used to characterize the temperature profile downstream of the mill's
discharge at different river flows and without thermal additions by the mill (allowing calculation of the
difference in temperature with and without the mill, or the delta-T, at points downstream).
The physical size and shape of the thermal plume (mixing zone)from the mill's outfall will be
characterized between the discharge point and the established compliance monitoring station at the
Fiberville Bridge (0.4 mi downstream from the discharge). A grid pattern will be used to measure water
temperatures horizontally and vertically at representative river flows. Grids farther downstream may be
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
used, if needed,to characterize the thermal plume beyond Fiberville Bridge. The data will be used to
parameterize a thermal plume dispersion model, which would be applied at different river flows.
For detailed thermal study plans, see Section B.1.
2. Biological Sampling and Analyses
Biological sampling of all trophic levels will be conducted at representative sampling stations along the
length of the Pigeon River(Figure 1) and the Swannanoa River reference stream (Figure 2). The biotic
community of both rivers will be characterized to demonstrate "diversity, the capacity to sustain itself
through seasonal changes, presence of necessary food chain species, and ... a lack of domination by
pollution tolerant species" (Subpart H, 125.71(c)). The trophic levels include phytoplankton, periphyton,
zooplankton, benthic macro-invertebrates/shellfish,fish, and wildlife (encompassing the full "shellfish,
fish and wildlife" criteria of Section 316(a) of the Clean Water Act).
Sampling protocols will include those used in previous 316(a) biological sampling and standardized
sampling techniques used by NC DENR and EPA. Use of multiple protocols will allow comparison
between monitoring by NC DENR and this study team. Protocols for surveying biotic groups not
sampled in the 2005 sampling (periphyton, phytoplankton, zooplankton, wildlife)will be developed in
consultation with NC DENR and recognized experts. Sampling will be guided by the known potential
impacts of added heat and elevated temperatures in rivers of comparable size to the Pigeon. In accord
with the EPA guidelines for small rivers,the phytoplankton, zooplankton, and wildlife biotic categories
will sampled and evaluated briefly as Low Potential Impact categories (see further discussion below).
Attention will be paid to collecting data that relate specifically to the criteria that define a balanced,
indigenous community and to other decision criteria specified in EPA Guidance and administrative and
judicial decisions. See Section 3, below.
Despite focus on "indigenous species", the community will necessarily contain "historically non-native
species introduced in connection with a program of wildlife management and species whose presence
or abundance results from substantial, irreversible environmental modifications." (Subpart H, 125.71(c)).
"Wildlife management" has included a major program of re-introduction of species common to similar
nearby rivers (to re-populate the reach historically affected by point and non-point sources) and
stocking of non-native game species. Some historically non-native species occur or are abundant due to
basin-wide agriculture, urbanization, and upstream impoundments. These will be identified in sampling
of the Pigeon River upstream of the mill. The community will be evaluated for"species whose presence
or abundance is attributed to the introduction of pollutants that will be eliminated by compliance" with
the Clean Water Act or"species whose presence or abundance is attributable to alternate effluent
limitations imposed pursuant to section 316(a)." (Subpart H, 125.71(c)). Such species will be identified
and included in the analyses.
Diversity of the aquatic community will be evaluated to ensure that all trophic levels present in the
unaffected portion of the river are present in the heat-affected portions. Diversity will be quantified by
use of several scientific diversity indices in common use in aquatic ecology at national and international
levels. Indices commonly used by NC DENR and EPA will be calculated.
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
The capacity to sustain itself through cyclical seasonal changes will be evaluated by conducting the
majority of sampling in late summer. This sampling time is currently favored (despite 1977 EPA
guidance to sample year-around) because it occurs at the end of the extreme warmest period when
community instability might be identified, and it allows identification of year-around survival and
reproduction by collecting juveniles of most species. Sampling through the year would be redundant
and constitute an unacceptable loss of aquatic life. Additionally, because of higher river flows during
winter and spring,field data collection in these periods is more difficult and can risk field personnel
safety.
The presence of necessary food chain species will be identified by sampling of periphyton, benthic
invertebrates/shellfish, and juvenile fish that make up much of the riverine food web. High species
diversity and abundance of known food items will be indicators of a healthy food web. EPA Guidance
specifically cautions against extremely detailed food chain analyses.
Dominance by any species especially tolerant of high temperatures will be looked for in all biological
community data. NC ratings of pollution tolerance and the scientific literature will be used as indicators.
Factors other than increased temperature that may cause changes in community assemblages in the
Pigeon River will be identified including impoundments, land use, stream habitat, other NPDES-
permitted discharges, non-point discharges, and sites of reproduction upstream of the thermal
discharge.
Although Representative Important Species (RIS) will be selected in consultation with NC DENR and EPA,
most of the biological sampling and community analyses will be comprehensive and include all species
amenable to sampling. Some special sampling will be undertaken to locate and evaluate RIS species, if
they are not adequately represented in the normal community-wide sampling protocols.
Statistical similarity analyses will be conducted between aquatic communities in the Pigeon River and
reference stream (Swannanoa River)to determine if the communities are significantly different (will
include indigenous and non-indigenous species).
For detailed biological sampling plans, see Section B.2.
3. BIP Demonstration
The Demonstration will briefly describe the regulatory history of the Blue Ridge Mill thermal discharge.
It will update the history presented in the 2006 permit application.
Renewal applications such as this one generally include specific consideration of any changes in
conditions from the previously granted alternative limits. The demonstration will discuss the criteria
commonly used to evaluate a Section 316(a) Permit renewal, as opposed to a new Demonstration,
which are:
• Whether the nature of the thermal discharge has changed from the previous Application;
• Whether the nature of the aquatic community has changed from the previous Application;
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
• Whether the best scientific methods to assess the effects of the thermal discharge have
changed from the previous Application;
• Whether the technical knowledge of stresses caused by the thermal discharge has changed; and,
• Whether the requirements of the current NPDES Permit have assured the protection and
propagation of a balanced indigenous population.
The alternative effluent limitations proposed by Blue Ridge will be presented in the Demonstration.
Because the study will be carried out under existing effluent limitations,the planned alternative (to
water quality standards) will be the limitations of the existing permit under which the temperature
regimes and biotic community have existed. These limits may be adjusted as result of the
Demonstration. The Demonstration will be a combined predictive and retrospective demonstration.
This is often referred to as an "Other Type III" demonstration as described in EPA Guidance (Section 3.7).
This is the most commonly used demonstration type for existing facilities.
The Demonstration will include both a listing and discussion of Representative Important Species (RIS).
The RIS, selected in coordination with the NCDWQ for previous 316(a)studies, were:
• Rock bass (pool-dwelling panfish important to anglers)
• Shiners (as a group; non-tolerant [intermediate or intolerant] pelagic to benthic insectivores)
• Redbreast sunfish (pool-dwelling panfish important to anglers; non-native)
• Central stoneroller(herbivore)
• Smallmouth bass (most common game fish important for anglers)
• Northern hog sucker(thermally sensitive bottom-feeding insectivore)
• Black redhorse (thermally sensitive bottom-feeding insectivore)
• Darters (as a group; diverse bottom-dwelling insectivores)
• Common carp (thermally tolerant and potential nuisance; non-native)
• River chub (pelagic omnivore; native)
• Mottled sculpin (bottom-dwelling insectivore; native)
• Banded sculpin (bottom-dwelling insectivore; native)
With this study plan, Blue Ridge requests NC DENR concurrence with this RIS list and comments on any
additions or deletions for the planned study.
The Demonstration will specifically address the elements in (1)the definition of a BIP in 40 CFR Part 125,
Subpart H; (2) EPA's Guidance(Interagency 316(a) Technical Guidance Manual and Guide for Thermal
Effects Sections of Nuclear Facilities Environmental Impact Statements, 1977); and (3) key administrative
and judicial precedents. These are:
• Trophic levels ("biotic categories" as per EPA guidance document), including plankton,
periphyton, macro-invertebrates/shellfish,fish, and wildlife.
• Diversity
• Capability to sustain itself through cyclical seasonal changes
• Presence of necessary food-chain species
• Lack of domination by pollutant-tolerant species.
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
• Indigenous species increase or decrease
• Threatened or endangered (T&E) species (federal and state) status, increase or decrease
• RIS,T&E, and other prominent species list,justification and detailed description, (historical and
current geographic distribution; history in the study area; thermal tolerance data (heat and cold
shock); temperatures for growth, development and reproduction; relative contribution to the
community; pollution tolerance; nuisance status)focused on demonstration that they will be
protected by the alternative thermal limits
• Critical function zones (resource zones)
• Habitat exclusion
• Thermal effects on "unique or rare habitat"
• Habitat former alterations
• Trends in the aquatic community since studies began in the 1980s, particularly the increasing
habitat suitability for reintroduced species under the current thermal limits
• Nuisance species abundance
• Zone of passage around the thermal plume under normal and worst-case conditions for fish,
zooplankton and invertebrates
• Change in commercial or sport fisheries
• Magnitude and duration of any identifiable thermal effect
• Sub-lethal or indirect impacts
• Interaction of the thermal discharge with other pollutants, using an inventory of NPDES permits
in the basin and general land use observations
• The degree to which the present community of the Pigeon River downstream of the thermal
discharge resembles the community that would have been there without the discharge.
The EPA Guidance provides for identification of certain biotic categories as "Low Potential Impact." For
example (EPA Guidance, Section 2.1.2):
In the course of the development of this draft, it became apparent to many working group
members that early screening procedures by industry or their consultants could sometimes
reveal those types of information which would not be necessary to gather in great detail at some
sites. If initial pilot field surveys and literature surveys revealed that the site was one of low
potential impact for phytoplankton,for example, it would be unnecessary to conduct detailed
studies to give the taxonomic identification of every species of phytoplankton in the vicinity.
Rivers, in particular, were cited by EPA Guidance as being low potential impact for phytoplankton (EPA
Guidance, Section 3.5.6.1):
Many water bodies, such as the majority of rivers and streams, can be classified as 'low potential
impact areas'for phytoplankton, and relatively little information is necessary for a 316(a)
demonstration. Nevertheless, more detailed information may be necessary in some instances if
phytoplankton is a substantial component of food chains supporting the balanced indigenous
population or if the thermal discharge is likely to cause a shift towards nuisance species.
The zooplankton biotic category of small rivers is generally "characterized by low concentrations of
commercially important species, rare and endangered species, and/or those forms that are important
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
components of the food web..." and is thus appropriately designated Low Potential Impact (EPA
Guidance Section 3.3.2.2). The Guidance states:
If preliminary 316(a)studies [of zooplankton] indicate that the area is one of low potential
impact, no further 316(a)studies are necessary. In this case, the applicant need provide only a
narrative discussion justifying the conclusion that the area is one of low potential impact.
Wildlife biotic category is also generally considered low potential impact (EPA Guidance Section
3.5.6.1.6):
Data will be required in relatively few cases in this biotic category. In those cases where data is
required, the type of data needed is decided by the applicant. The data selected should be the
least amount of data necessary to complete this section of the demonstration.
Further,the guidance provides examples of what did cause the regulatory agencies' concerns for the
wildlife biotic category, which include warm zones in "cold areas (such as North Central United States)
which would be predicted to attract ducks and geese, and encourage them to stay through the winter"
and "those few sites where the discharge might affect important (or threatened and endangered)
wildlife such as manatees." Western North Carolina is not on a migratory flyway and so migratory ducks
and geese are not abundant in the Pigeon River, including Waterville Lake. Threatened wildlife such as
the manatee is not found there.
It is anticipated, based on EPA guidance and previous studies of the Pigeon River,that phytoplankton,
zooplankton and wildlife will be presented and justified as low potential impact.
In accord with the recent Brayton Point Environmental Appeals Board decision (noted above),the
Demonstration will emphasize the increasing trend in habitat suitability for the indigenous species. The
Brayton Point decision made a strong point that the trend in community composition mattered in
establishing alternative thermal limitations on the discharge. At the Brayton Point Power Plant, the
trend for many native species was downward, with some of the downward trend attributed by EPA
Region 1 to the thermal discharge under its existing permit. In the Pigeon River, however, a notable
trend toward improvement (recovery) in native species under the existing thermal limits and permit is
evident in the biological data from previous BIP studies. Evidence for this continued improvement will
be collected and discussed.
A Master Rationale will integrate and summarize the thermal and biological information that supports
the proposed alternative effluent limitations.
Section B: Detailed Study Plans
Task 1 - Thermal: Update the Previously Developed Temperature Model and Low Flow Statistics
A temperature model was previously developed for the discharge of the Blue Ridge Paper Products
(BRPP) Canton Mill to the Pigeon River(Tyner, 2006). Model calibration was based upon data collected
by mill personnel for the 5-year period 2001-2005. Additional verification of the diel temperature range
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
was provided by the deployment of hourly recording thermographs at 22 Pigeon River locations during
the summer of 2005. As part of the 2012-2013 updated 316(a)Thermal Model Study,the temperature
model will be further verified by making comparisons between model predictions and more recent
temperature data collected by mill personnel and deployed thermographs.
Pigeon River temperature data collected by mill personnel since 2005 include daily values at Canton,
Fiberville and Clyde, and weekly values at HEPCO (Figure 1). Additional temperature data will be
obtained by deploying approximately 22 hourly recording thermographs (Hobo Pendant
Temperature/Light Data Logger Model 8K-UA-002-08), which will be deployed for a 4-6 week period
during July and August 2012, and also another 4-6 week period during the following January and
February 2013. The thermographs will be deployed at the same Pigeon River locations as sampled in the
2005 study;there will be at least two thermal sampling sites above the mill outfall added to the 2012-
2013 study. Most thermal sampling sites will coincide with the biological survey stations at specific
locations from PRM 69.5 (above the mill)to PRM 19.3 (below the mill); thermographs will also be
deployed during both thermal sampling periods at the mouth of contributing tributaries,the mill outfall,
and at selected sites on the reference river.
The model calculates at an hourly time step using meteorological data for surface heat exchange. Data
on air temperature, wind speed, relative humidity, solar radiation data and measured flow from the mill
outfall and the USGS gauging stations at Canton and HEPCO are used for calibration. The Pigeon River
temperature model will be re-calibrated as necessary using the high intensity summer 2012 thermal
data set. It will then be validated using the long-term (2005-2012) data collected by mill personnel. The
50th and 90th percentile of modeled temperature error will be calculated and presented.
The re-verified Pigeon River temperature model will be used in support of the 2014 316(a)
Demonstration. Year-long model run outputs can be summarized as daily/weekly mean temperatures
or other intervals of interest as a function of season. Worst-case mill discharge or receiving water
conditions can also be presented.
To investigate the mixing and dispersion of the heat plume exiting the mill outfall (PRM63.3),two
thermal cross-sections (at the railroad crossing just beneath the outfall (PRM 63.2) and at the Fiberville
bridge (PRM 63.0) will be collected on both a relatively low river flow day and a moderate river flow day.
The cross sections will be sampled approximately every 0.3 m by 0.3 m in a pattern shown by the figure
below. Results of the four cross sections (railroad low and moderate flow, and Fiberville bridge low and
moderate flow)will be contoured and the results will be discussed.
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
Task 2—Biological: Conduct Biological Surveys to Support a Continuation of the Mill's Thermal Variance
During May through September 2012, UTK will intensively survey fish and macro-invertebrates/shellfish
at 20 stations on the Pigeon River and in selected tributaries in North Carolina (18 stations) and
Tennessee (2 stations). At least two (2) sites on the Swannanoa River in North Carolina will be sampled
in the same manner as Pigeon River stations. Periphyton sampling will be conducted at all stations using
EPA rapid bio-assessment methods (Barbour et al. 1999). Phytoplankton, zooplankton, and wildlife will
be sampled less intensively to document low abundance. River mile (PRM) refers to distance upstream
of the confluence of the Pigeon River with the French Broad River in Tennessee; SRM refers to distance
upstream of the confluence of the Swannanoa with the French Broad River in North Carolina. New
stations added to the 2005 Pigeon River sample site list are indicated by an asterisk (*).
River Mile Location
WFPRM 6.6 Lake Logan*
WFPRM 3.6 West Fork Pigeon River*
EFPRM 3.5 East Fork Pigeon River*
PRM 69.5 Below confluence EFLR/WFLR*
PRM 64.5/64.9 Upstream of mill (expanded* from 2005)
PRM 63.0 Fiberville
PRM 61.0 D.O. augmentation station (Thickety)
PRM 59.0 Upstream of Clyde
PRM 57.7 Charles St Bridge/Clyde*
PRM 55.5 Downstream of Clyde
PRM Trib Richland Creek (PR confluence at PRM 54.9)
PRM 54.5 Downstream of Waynesville WWTP
PRM 52.3 Old Rt 209/Golf Course
PRM Trib Crabtree Creek (PR confluence at PRM 49.8)
PRM 48.2 Ferguson Bridge
PRM Trib Jonathan Creek(PR confluence at PRM 46.0)
PRM 45.3 HEPCO Gauging Station*
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
PRM Trib Fines Creek(PR confluence at PRM 42.7)
PRM 24.7 Waterville (TN)
PRM 19.3 Groundhog Creek-Bluffton (TN)
SRM 11.3 Warren Wilson College
SRM 1.6 Exit 50 at 1-40
Stream fish and macro-invertebrate sampling protocols at the above sampling stations will be
comparable to those used during the 2005 data collections and also will follow prescribed SOPS
consistent with NC DENR sampling guidelines (NCDENR 2006a, 2006b). Mussels/shellfish will also be
targeted species in the mainstem reaches. Special attention will be directed to the determination of the
presence of two Threatened and Endangered mussel species,Appalachian Elktoe (Alasmidonta
raveneliana) and the Wavyrayed Lampmussel (Lampsilis fasciola),which have been observed in the river
since the last 316(a) demonstration. Periphyton sampling will be conducted at all stations using EPA
rapid bioassessment methods (Barbour et al. 1999). The field-based rapid periphyton survey provides
semi-quantitative assessments of benthic algal biomass and coarse-level taxonomic composition (e.g.,
diatoms, filamentous green algae, blue-green algae) using a viewing bucket marked with a grid and
biomass scoring system. The primary advantage of using this technique is that it allows rapid
assessment of algal biomass over a large area. The attached riverweed Podestomum has been
demonstrated to be: (1) an important mechanism in the promotion of macro-invertebrate biomass,
abundance, and species richness, and (2) a positive influence on the abundance of several fish, including
the banded darter, Etheostoma zonale(Etnier and Starnes, 1993; Rohde et al., 2009). The distribution
and abundance of Podostemum in the Pigeon River upstream and downstream of the mill will be
surveyed and compared, including possible causes for any observed differential in location and/or
amount of vegetation present. The potamoplankton, i.e., unattached phytoplankton and zooplankton,
will be sampled less intensively to document low abundance. We will obtain information from NC
Wildlife personnel who work in the Pigeon River watershed, as well as Study Team observations,to
document wildlife abundance and river usage.
Detailed studies will be restricted to fish, macro-invertebrates/shellfish, and habitat evaluation and will
include measurements of routinely collected field physical/chemical parameters [i.e., temperature, DO,
conductivity, and water turbidity(NTUs)]. Follow-up sampling may be conducted in 2013, if necessary,
to fill any gaps in the data, or to repeat the sample if necessary.
Task 3—Prepare a 316(a) Demonstration Report(BIP Demonstration)
Based on the field data collected during Tasks 1 and 2,the results of the temperature model (Task 1), an
updated review of the thermal tolerance literature, and any other applicable data (e.g., NC DENR data,
Progress Energy data), UTK will prepare an updated 316(a) Demonstration Report (i.e., "Balanced
Indigenous" Report). This report will address the central question posed by§316(a) of the Clean Water
Act, i.e., does the existing thermal discharge allow for the maintenance or establishment of the balanced
indigenous population (community) of aquatic organisms that would have been there without the mill.
We will use the May 2006 successful 316(a) Demonstration as a template for the 2014 submittal.
Page 14

April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
Section C. Certification and Permitting
UTK has begun the process of securing "Certified Laboratory" status, which should be in place prior to
commencement of the field sampling (May 2012). The certification visit by the DWQ ESS occurred on
March 20, 2012. Required references for certification in 'fish' and 'benthic macro-invertebrates' have
been obtained for use during the project. The EPA Rapid Assessment Protocol (Barbour et al., 1999) has
been obtained and will be used for periphyton sampling and identification. North Carolina and
Tennessee collection permits for targeted species have been applied for from the North Carolina
Wildlife Resources Commission - Division of Inland Fisheries, and the Tennessee Wildlife Resources
Agency.
Page 15

April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
J. Larry Wilson, PhD
Fisheries Scientist and Professor
Dept of Forestry, Wildlife and Fisheries
Institute of Agriculture
University of Tennessee, Knoxville
865-974-7982
[e-mail]
Enclosures
Figures
Figure 1—Pigeon River Biological and Thermal Sampling Stations
Figure 2—Reference Stream (Swannanoa River) Biological and Thermal Sampling Stations
Project Team
References
Copy of Enclosure to February 22, 2010 EPA letter with requirements for 316(a) Study Plan
Copy of April 2, 2012 memorandum from the North Carolina Division of Water Quality, Environmental
Sciences Section (ESS) concerning review of the February 2012 316(a)Study Plan
The ESS concurred with the study plan offering four (4) comments. These comments were
discussed with UTK project team members during March 20, 2012 laboratory certification visit
by the ESS and are incorporated into this April 2012 Study Plan.
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No. NC0000272
-----------------------------------------------------
-----------------------------------------------------
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Figure 1— Pigeon River Biological and Thermal Sampling Stations
Page 17

April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
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Figure 2—Reference Stream (Swannanoa River) Biological and Thermal Sampling Stations
Page 18

April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton,North Carolina
NPDES Permit No. NC0000272
-----------------------------------------------------
-----------------------------------------------------
Team List: Pigeon River 316a Study Plan
UTK Proposal: 02/01/2012
Project Leader:
Dr.Larry Wilson,Professor,Fisheries/Aquatic Biology
Forestry,Wildlife and Fisheries,University of Tennessee,Knoxville (UTK)
Data Collection/Analysis Crew:
Joyce Coombs,Research Associate II
Phillip Harnage,M.S. candidate,Macro-invertebrate/fish sampling&monitoring
Justin Wolbert,M.S. candidate,stream collections/monitoring
TBD,M.S. candidate, stream collections/monitoring
Michael Gaugler,Ph.D. candidate,Habitat evaluation/assessment
Melinda Bousfield,Ph.D. candidate,Macro-invertebrate monitoring&assessment
Keith Garner,B.S.graduate, stream collections/equipment maintenance
Other UTK Personnel:
Dr.John Tyner,Associate Professor,Water Resources (thermal modeling,oxygen sag)
Biosystems Engineering and Soil Science
Dr.Ted Henry,Adjunct Assistant Professor,Environmental toxicology(tissue analysis and
tox screen),Center for Environmental Biotechnology/Forestry,Wildlife&Fisheries
Dr.Misty Huddleston,recent graduate (Dec 2011),AquAeTer,Inc.,Macro-invertebrate
taxonomy,data collection and analysis
Other Agency Personnel:
Dr.Ray Albright,Adjunct Professor,Water resource inventory/monitoring(oxygen model)
National Park Service (Adjunct with FWF)
Project Collaborators:
Dr. Chuck Coutant,Distinguished Research Ecologist (316a thermal studies)
Environmental Sciences Division,ORNL (retired)
Dr.David Etnier,Emeritus Professor,fish/invertebrate taxonomy and distribution (aquatic
resources inventory),Ecology and Evolutionary Biology(retired)
Mr. Steve Ahlstedt,mussel taxonomy and distribution,US Geological Service (retired)
Dr.John Wojtowicz,chironomid taxonomy/ID
Dr.DeeDee Kathman,TDOT Environmental Division,oligochaete taxonomy/ID
Dr.Todd Askegaard,TDOT Aquatic Resources Center,oligochaete taxonomy/ID
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
REFERENCES
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evaluation of fish condition in the field.Transactions American Fisheries Society 122:63-73.
Anderson, R.O., and S.J. Gutreuter. 1983.Length, weight, and associated structural indices.
Pages 283-300 in L. A. Nielsen and D. L.Johnson, editors. Fisheries techniques.American
Fisheries Society, Bethesda, MD.
Anderson, R.O., and R. M. Neumann. 1996. Length,weight, and associated structural indices.
Pages 447-481 in B. R. Murphy and D. W. Willis, editors. Fisheries techniques. 2nd edition.
American Fisheries Society, Bethesda, MD.
Barbour, M.T.,J. Gerritsen, B.D. Snyder, and J.B. Stribling. 1999. Rapid Bioassessment Protocols for Use
in Streams and Wadeable Rivers: Periphyton, Benthic Macro-invertebrates, and Fish, Second
Edition. EPA 841-B-99-002. US Environmental Protection Agency, Office of Water,Washington,
DC.
Beaty, S.R.Taxonomy Document with Standard Taxonomic Effort Levels for Ephemeroptera of North
Carolina. NCDENR, DWQ, Biological Assessment Unit. November 2010.
Beaty, S.R.Taxonomy Document with Standard Taxonomic Effort Levels for Plecoptera of North
Carolina. NCDENR, DWQ, Biological Assessment Unit. November 2010.
Beaty, S.R.Taxonomy Document with Standard Taxonomic Effort Levels for Trichoptera of North
Carolina. NCDENR, DWQ, Biological Assessment Unit. November 2010.
Beaty, S.R.Taxonomy Document with Standard Taxonomic Effort Levels for Coleoptera of North
Carolina. NCDENR, DWQ, Biological Assessment Unit. November 2010.
Coutant, C. C., and D. L. DeAngelis. 1983. Comparative temperature-dependent growth rates of
largemouth and smallmouth bass.Transactions of the American Fisheries Society 112:416-423.
Coutant, C. C. 1977. Compilation of temperature preference data.Journal Fisheries Research Board of
Canada 34:739-745.
Dahlberg, Michael D. 1975. Guide to Coastal Fishes of Georgia and Nearby States. University of Georgia
Press. Athens, GA. 187 pp.
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
EA Engineering, Science, and Technology, Inc. 1988.Synoptic survey of physical and biological condition
of the Pigeon River in the vicinity of Champion International's Canton Mill. EA Engineering,
Science, and Technology, Inc. Sparks, MD.
EA Engineering, Science, and Technology, Inc. 1996.A study of the aquatic resources and water quality
of the Pigeon River. EA Engineering, Science and Technology, Inc. Deerfield, IL.
EA Engineering, Science, and Technology, Inc. 2000. Results of the 1999 biological survey of the Pigeon
River. EA Engineering, Science, and Technology, Inc. Deerfield, IL.
EA Engineering, Science, and Technology, Inc. 2001. A study of the aquatic resources of the Pigeon River
during 2000. EA Engineering, Science, and Technology, Inc. Deerfield, IL.
Eaton,J.G.,J. McCormick, B. Goodno, G. O'Brien, H. Stefany, M. Hondzo, and R. Scheller. 1995. A field
information-based system for estimating fish temperature tolerances. Fisheries 20(4):10-18.
Etnier D. A., and W.C. Starnes. 2001.The Fishes of Tennessee.The University of Tennessee Press,
Knoxville,TN. 689 pp.
Fore, L.S. and J.B. Karr. 1994. Statistical properties of an Index of Biotic Integrity used to evaluate water
resources. Canadian Journal of Aquatic Science 5:1077-1087.
Goede, R.W., and B.A. Barton. 1990. Organism indices and an autopsy-based assessment as indicators
of health and condition of fish. American Fisheries Society Symposium 8:93-108.
Hutchens,J.J.,JR., and J.B. Wallace. 2004. Role of Podostemum ceratophyllum Michx in structuring
benthic macro-invertebrate assemblage in a southern Appalachian river.Journal of the North
American Benthological Society 23(4): 697-708.
Jenkins, R., and N. Burkhead. 1994. Freshwater fishes of Virginia. American Fisheries Society,
Bethesda, MD.
Karr,J.R. 1981.Assessment of biotic integrity using fish communities. Fisheries 6(6): 21-27.
Karr,J.R., K.D. Fausch, P.L. Angermeier, P.R. Yant, and I.J. Schlosser. 1986.Assessing biological integrity
in running water: a method and its rationale. Illinois Natural History Survey Special Publication
Number 5, Champaign, IL.
Kathman, R.D., and R.O. Brinkhurst. 1998. Guide to the Freshwater Oligochaetes of North America.
Aquatic Resources Center, College Grove,TN. 264 pp.
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
Lenat, D.R. 1988. Water quality assessment of streams using a qualitative collection method for benthic
macro-invertebrates.Journal of the North American Benthological Society 7:222-233.
Lenat, D.R. 1993.A biotic index for the southeastern United States: Derivation and list of tolerance
values, with criteria for assigning water quality ratings.Journal of the North American
Benthological Society 7:270-290.
Menhinick, E. F. 1991.The freshwater fishes of North Carolina. North Carolina Wildlife Resources
Commission. Raleigh, NC. 227 pp.
Minshall, G.W. 1984. Aquatic insect-substratum relationships. Pages 358-400 in V.H. Resh and D.M.
Rosenberg (editors). The ecology of aquatic insects. Praeger Publishers, New York.
Murphy, B.R., and D.W. Willis, editors. 1996. Fisheries Techniques, 2nd edition. American
Fisheries Society, Bethesda, MD.
North Carolina Department of Environment, Health and Natural Resources (DEHNR). 1997.
Standard operating procedure for biological monitoring.January 1997. Division of
Environmental Management, Water Quality Section, Raleigh, NC.
North Carolina Department of Environment and Natural Resources. 2005. Post Hurricane
Frances, Ivan, and Jeanne Biological Monitoring (French Broad and Watauga River Basins) and
Biological Sampling, November 30-December 2, 2004.Technical memorandum dated April 4,
2005. Biological Assessment Unit, Division of Water Quality, Environmental Sciences Section,
Raleigh, NC.
North Carolina Department of Environment and Natural Resources (NCDENR). 2011. Standard
operating procedures for collection and analysis of benthic macro-invertebrates (Version 3.0).
December 1, 2011. Biological Assessment Unit, Division of Water Quality, Environmental
Sciences Section, Raleigh, NC.
North Carolina Department of Environment and Natural Resources (NCDENR). 2006b. Standard
operating procedure, Stream fish community assessment program. August 1, 2006. Biological
Assessment Unit, Division of Water Quality, Environmental Sciences Section, Raleigh, NC.
North Carolina Department of Environment and Natural Resources (NCDENR). 2009. Habitat
assessment field data sheet Mountain/Piedmont streams. Revision 7. March 2009. Biological
Assessment Unit, Division of Water Quality, Environmental Sciences Section, Raleigh, NC.
Ohio Environmental Protection Agency(Ohio EPA). 1989. Biological criteria for the protection of aquatic
life: Volume III. Standardized field and laboratory methods for assessing fish and macro-
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
invertebrate communities. Division Water Quality Planning and Assessment, Ecological
Assessment Section, Columbus, OH.
Progress Energy. 2005. 2004 Water Quality and Biotic Indices Study of the Pigeon River at the Walters
Hydroelectric Plant.Appendix A Requirements. Environmental Services Section, Progress Energy
Service Company, Raleigh, NC.
Reynolds, W.W., and M.E. Casterlin. 1976.Thermal preferenda and behavioral thermoregulation in
three centrarchid fishes. Pages 185-190 in G.W. Esch and R. W. McFarlane, editors.Thermal
ecology II. Dept. of Energy Symposium Series (CONF-75025), Nat.Tech. Info. Serv., Springfield,
VA.
Rohde, F.C.,J.W. Foltz, and J.M.Quattro. 2009. Freshwater fishes of South Carolina. University of South
Carolina Press, Columbia, SC. 430 pp.
Saylor, C.F.,A. McKinney, and W. Schacher. 1993. Case study of the Pigeon River in the Tennessee River
drainage. TVA Biological Report 19.Tennessee Valley Authority, Norris,TN.
Scott, W.B., and E.J. Crossman. 1973. Freshwater fishes of Canada. Fisheries Research Board Canada
Bulletin 184:1-966.
Simon,T.P., and J. Lyons. 1995. Application of the index of biotic integrity to evaluate water
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editors. Biological assessment and criteria:Tools for water resource planning and
decision making. Lewis Publishers, Boca Raton, FL.
Surber, E.W. 1970. Smallmouth bass stream investigations.Virginia Commission of Game and Inland
Fisheries, Federal Aid in Sport Fish Restoration, Project F-14-R,Job 2-Shenandoah River study,
January 1, 1964-June 30, 1969. Final Report, Richmond.
Tennessee Valley Authority. 2004.TVA Protocol for Conducting an Index of Biotic Integrity
Biological Assessment.Technical Memorandum. 15 pp.
Trembley, F.J. 1960. Research project on effects of condenser discharge water on aquatic life. Progress
Report 1960. Institute of Research, Lehigh Univ., Bethlehem, PA.
Tyner,J.S. 2006. Pigeon River Temperature Model: 2001-2005. Appendix A in Wilson,J.L. 2006. Canton
Mill—Balanced and Indigenous Species Study for the Pigeon River. [Clean Water Act Section
316(a) Demonstration]. Blue Ridge Paper Products Inc., Canton, NC.
US EPA(US Environmental Protection Agency). 1974. 316(a)Technical Guidance—Thermal
Discharges Draft. Water Planning Division, Washington, DC.
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April 2012 — 316(a) Study Plan
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton, North Carolina
NPDES Permit No. NC0000272
US EPA(US Environmental Protection Agency). 1977. Interagency 316(a)technical guidance manual and
guide for thermal effects sections of nuclear facilities environmental impact statements. Office
of Water Enforcement, Permits Division, Industrial Permits Branch, Washington, DC.
Wege, G.J., and R.O. Anderson. 1978. Relative weight (Wr): a new index of condition for largemouth
bass. Page 79-91 in G.D. Novinger and J.G. Dillard, editors. New approaches to the management
of small impoundments. American Fisheries Society, North Central Division, Special Publication
5, Bethesda, MD.
Wilson,J. Larry. 2006. Canton Mill—Balanced and Indigenous Species Study for the Pigeon River. [Clean
Water Act Section 316(a) Demonstration]. Blue Ridge Paper Products Inc., Canton, NC.
Wrenn, W. B. 1980. Effects of elevated temperatures on growth and survival of smallmouth bass.
Transactions of the American Fisheries Society 109:617-625.
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the sustainability and biological integrity of water resource quality using fish communities. CRC
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Copy of Enclosure to the February 22, 2010 EPA Letter:
Section 316(a)Report and the Study Plan for the Subsequent Permit
and
Copy of April 2, 2012 North Carolina Division of Water Quality, Environmental Sciences Section
memorandum:
Review of Evergreen Packaging(Canton Mill)NPDES Permit NC0000272 "316(a)Study Plan:February
20,2012"
Both documents follow in order cited.
Page 24

Enclosure
Section 316(a) Report and the Study Plan for the Subsequent Permit
Blue Ridge may use existing data in completing its study and may incorporate the
existence of such data into the monitoring program plan design; however, the existing data needs
to be evaluated and presented in the context of a BIP definition that the existing record does not
adequately provide.
Section 316(a) of the CWA contains the term"BIP" but does not define it. However, 40
CFR §125.71(c) defines the term "balanced, indigenous community"I as:
"A biotic community typically characterized by diversity, the capacity to sustain itself
through cyclic seasonal changes,presence of necessary food chain species and by a lack
of domination by pollution tolerant species. Such a community may include historically
non-native species introduced in connection with a program of wildlife management and
species whose presence or abundance results from substantial, irreversible environmental
modifications. Normally, however, such a community will not include species whose
presence is attributable to the introduction of pollutants that will be eliminated by
compliance by all sources with section 301(b)(2) of the Act: and may not include species
whose presence or abundance is attributable to alternative effluent limitations imposed
pursuant to section 316(a)."
The Environmental Appeals Board stated in its decision in In Re Dominion Energy
Brayton Point, LLC, 12 Environmental Appeals Decision (E.A.D.)490 (2006)("Brayton Point"),
"this definition clearly envisions a consideration of more than the population of organisms
currently inhabiting the water body. In this vein, although it permits inclusion of certain
`historically non-native species' that are currently present, it explicitly excludes certain currently
present species whose presence or abundance is attributable to avoidable pollution or previously-
granted section 316(a) variances."
Page 557 of the Brayton Point E.A.D. goes on to further state that a BIP "can be the
indigenous population that existed prior to the impacts of pollutants, not solely the current
populations of organisms."
To the question of how a permittee should identify a BIP in an area that has been altered
by impacts from an existing thermal discharge, the Brayton Point E.A.D. points out that it may
be appropriate to use a nearby water body unaffected by the existing thermal discharge as a
reference area. Examination of an appropriate reference area may be applicable in this case.
The definition of"balanced, indigenous community" at 40 CFR § 125.71(c) contains
several key elements. To be consistent with the regulations, each of these key elements should
be specifically addressed in the demonstration, and the Pigeon River Section 316(a) monitoring
plan for the next permit cycle should be designed to generate information relevant to these
elements. Those elements include: (1) "a population typically characterized by diversity at all
' "Balanced, indigenous community"and BIP are equivalent terms.

trophic levels;" (2) "the capacity to sustain itself through cyclic seasonal changes;" (3) "presence
of necessary food chain species;" (4) "non-domination of pollution-tolerant species;" and(5)
"indigenous." Each of these elements is discussed in more detail below:
1. "A population typically characterized by diversity at all trophic levels" means that all of the
major trophic levels present in the unaffected portion of the water body should be present in the
heat affected portions. EPA recognizes that community structure differences will occur,
however, the number of species represented in each trophic level in the unaffected portions
should be reasonably similar in the heat-affected portions of the water body. Sampling and
analysis of fish and invertebrate communities should be done such that the major trophic levels
are identified and represented by reasonably similar species distributions. Also, the study plan
should be expanded to include some observations of wildlife (i.e., water fowl, mammals,
amphibians, etc.) both upstream and immediately downstream of the discharge point that may be
impacted by the thermal discharge.
2. "The capacity to sustain itself through cyclic seasonal changes ' means that any additional
thermal stress will not cause significant community instability during times of natural extremes
in environmental conditions. Community data should be collected during normal seasonal
extremes as well as during optimal seasonal conditions. Data should be compared between heat
affected and unaffected portions of the receiving water body to account for normal community
changes corresponding with a change in season.
3. "Presence of necessary food chain species ' means that the necessary food webs remain intact
so that communities will be sustaining. We believe that exhaustive food web studies are not
necessary provided that invertebrate, fish and wildlife communities are otherwise healthy, i.e.,
represented by sufficiently.high species diversity and abundance (appropriate for that portion of
the receiving water body) for the identified trophic levels and sustaining through normal seasonal
changes.
4. "Non-domination of pollution-tolerant species" means that in the case of a thermal effluent,
community assemblages in heat affected portions of the lake dominated by heat tolerant species
do not constitute a BIP. EPA recognizes that because all species have varying levels of thermal
tolerance, communities in the heat affected portions of the water body may possess altered
assemblages in terms of species present and abundance. All community data should be
collected, analyzed and presented to clearly demonstrate that affected communities have not
shifted to primarily heat tolerant assemblages.
5. "Indigenous"has been further clarified in the regulations: "Such a community may include
historically non-native species introduced in connection with a program of wildlife management
and species whose presence or abundance results from substantial, irreversible environmental
modifications. Normally, however, such a community will not include species whose presence is
attributable to the introduction of pollutants that will be eliminated by compliance by all sources
with section 301(b)(2) of the Act: and may not include species whose presence or abundance is
attributable to alternative effluent limitations imposed pursuant to section 316(a)." EPA
recognizes that non-indigenous species are present in most aquatic systems in the United States.
All community data should be analyzed and presented to demonstrate that community
2

assemblages in the heat affected portions of the receiving water body are not significantly
different from non-affected communities with regard to the number of non-indigenous species in
the assemblages.
In addition to the foregoing components of the BIP definition, the study plan should also
include provisions for the identification of RIS (e.g., a list of threatened, endangered, thermally
sensitive, or commercially or recreationally valuable species up- and downstream of the study
area), as contemplated in 40 CFR §125.72(b). 40 CFR §125.71(b) defines RIS as "species which
are representative, in terms of their biological needs, of a balanced, indigenous community of
shellfish, fish and wildlife in the body of water into which a discharge of heat is made."
The following EPA comments should be specifically addressed in the study plan prior to
Blue Ridge commencing sampling during the term of the next NPDES permit. The plan should:
a) include available information on wildlife in the lake areas based on
communications with North Carolina's Wildlife Management Agency. See
item 1 above.
b) include a diagram depicting the thermal plume under the worst case scenario
and address the presence or absence of a zone of passage for which fish can
travel around the thermal plume.
e) provide information of which fish collected are either heat-sensitive or
nuisance species. See item 4 above.
d) provide a list of any lake species that are endangered or threaten in accordance with
federal and state regulations.
e) analyze and present data to clearly demonstrate that affected communities
have not shifted to primarily heat tolerant assemblages.
f) include recent data or information on benthic macroinvertebrates. See item 1 above.
g) analyze and present all data to demonstrate that community assemblages in the heat-
affected portions of the receiving water body are not significantly different from non-
affected communities with regard to the number of non-indigenous species in the
assemblages; and
h) include a thermal modeling study based on historical effluent temperatures and
operating conditions to determine appropriate permit limits for temperature.
In order to ensure that Blue Ridge's future study plan for the Pigeon River is adequate to
demonstrate that the Canton Mill should have its Section 316(a) variance renewed during the
term of its next NPDES permit, EPA requests the opportunity to review a draft Section 316(a)
plan prior to Blue Ridge commencing the study.
3

ALIT
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Governor Director Secretary
April 2, 2012
MEMORANDUM
To: Tom Belnick
Through: Jay Sauber
From: Eric Fleek
Subject: Review of Evergreen Packaging (Canton Mill) NPDES Permit NC0000272 "316(a) Study Plan:
February, 20, 2012".
Environmental Sciences Section (ESS) staff has reviewed the subject document. Specifically Bryn Tracy
reviewed the fisheries portion of the study plan while Eric Fleek reviewed the benthic macroinvertebrate
portion of the plan. ESS does not have the expertise to evaluate the thermal plume dispersion model,
hydrographic or meteorological data. Therefore, these aspects of the study will not be addressed in this
document.
In summary, we concur with the proposed summer sampling plan for biological communities and agree
with all aspects of the proposed biological study plan including the trophic levels being assessed, the
various assessment methodologies specific to each community and we further concur with the selection
of the Swannanoa River as a reference waterbody. In addition we also agree with the Representative
Important Species (RIS) and Threatened and Endangered (T&E) list(except as noted below in items No.
1 and No. 2). In addition, on March 201h, 2012 Eric Fleek, Bryn Tracy and Lance Ferrell participated in a
Biological Lab Certification inspection of the University of Tennessee's biological lab. The final
certification of this facility to conduct fish community and benthic macroinvertebrate assessments is still
pending but will likely be resolved (pending the successful completion of the benthic macroinvertebrate
QA sample) on or near April 17th
Based upon a review of the study plan, the following items require attention:
1. The study plan should discuss the two Threatened and Endangered (T&E)species that have
been found in the Pigeon River since the last 316(a) demonstration. These species include the
Appalachian Elktoe (Alasmidonta raveneliana) and the Wavyrayed Lampmussel (Lampsilis
fasciola).
2. On page 9 of the study plan, it is noted that the River Chub is an "insectivore". This should be
corrected to "omnivore".
3. The study plan should discuss the longitudinal distribution of Podostemum in the Pigeon River.
Podostemum meets the criteria of a "Habitat Former" as defined in the 1977 EPA Interagency
316(a)Technical Guidance Manual. For example, Podostemum has been repeatedly
demonstrated to be an important mechanism in the promotion of benthic macroinvertebrate
biomass, abundance and species richness (Glime and Clemmons 1972, Minshall 1984, Lee and
Environmental Sciences Section
1621 Mail Service Center, Raleigh,North Carolina 27699-1621
Location:4401 Reedy Creek Road, Raleigh,North Carolina 27607
Phone:[phone]\FAX:[phone] One
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Addressee
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Page 2 of 2
Hershey 200, Hutchens and Wallace 2004). In addition, Podostemum and has been shown to
positively influence the abundance of several fish, including the Banded darter(Etheostoma
zonate; Etnier and Starnes 1993, Rohde et al. 2009)which despite efforts of reintroduction, fails
to recruit in the Pigeon River below the Mill. As a result, Podostemum distribution should be
studied to determine if it's observed reduction in distribution downstream from the mill (NCDWQ,
Unpublished Data) as compared to upstream of the mill is due to light-limitation, substrate, or
some other factor. This survey could easily be incorporated into the current proposed
assessment of periphyton cover.
4. The study plan notes (on Page 7)that: "In accord with the EPA guidelines for small rivers, the
phytoplankton, zooplankton, and wildlife biotic categories will be sampled and evaluated briefly as
Low Potential Impact categories" and (on Page 10)that"The EPA Guidance provides for
identification of certain biotic categories as "Low Potential Impact(EPA Guidance, Section 2.1.2):
If initial pilot field surveys and literature surveys revealed that the site was one of low potential
impact for phytoplankton, for example, it would be unnecessary to conduct detailed studies to
give the taxonomic identification of every species of phytoplankton in the vicinity'. Conversely, on
Page 14 the study plan notes: "Detailed studies will be restricted to fish, macro-
invertebrates/shellfish, periphyton, and habitat evaluation...". The study plan requires clarification
in terms of the methodology to be used in the periphyton study and whether or not the periphyton
study will include taxonomic identifications or only presence/absence assessments.
References Cited
Etnier, D. A. and W. C. Starnes. 1993. The fishes of Tennessee. The University of Tennessee Press,
Knoxville, TN.
Glime, J.M. and R.N. Clemons. 1972. Species diversity of stream insects on Fontinalis spp. compared to
diversity on artificial substrates. Ecology 53:458-464.
Hutchens, J.J., Jr. and J. B. Wallace. 2004. Role of Podostemum ceratophyllum Michx. in structuring
benthic macroinvertebrate assemblage in a southern Appalachian river. Journal of the North
American Benthological Society 23(4):713-727.
Lee, J.O. and A.E. Hershey. 2000. Effects of aquatic bryophytes and long-term fertilization of artic stream
insects. Journal of the North American Benthological Society 19:697-708.
Minshall, G.W. 1984. Aquatic insect-substratum relationships. Pages 358-400 in V.H. Resh and D. M.
Rosenberg (editors). The ecology of aquatic insects. Praeger Publishers, New Your.
Rohde, F. C., Foltz, J. W., and J. M Quattro. 2009. Freshwater fishes of South Carolina. University of
South Carolina Press, Columbia, SC.
cc: Chuck Cranford, Asheville Regional Office
Jeff Poupart, Surface Water Protection Section
Sergei Chernikov, Surface Water Protection Section
Bryn H. Tracy, Environmental Sciences Section