NC0000272_Comments on Draft Permit and Fact Sheet_20220401

April 22, 2021
Submittal of Comments Relative to the Following Project:
Draft NPDES Wastewater Discharge Permit #NC0000272 for Blue Ridge Pulp Mill, Canton, NC,
with proposed removal of color variance and continuing use of Temperature Variance.
Comments:
NCDEC Fact Sheet for Draft Permit
INSTREAM MONTORING, Page 4. Figure 1. I find this map very difficult to read for many
reasons. The symbols for the USGS sites and NPDES dischargers are difficult to see. The one
label that is different than the rest has the text cut off. Indicating downstream direction would be
useful. It would also be useful to mark where the water treatment and paper mill locations are
themselves, maybe in its own zoomed in section of the map.
Draft Permit
Part I
A1-A3. Pages 4-9. Effluent Limitations and Monitoring Requirements
There looks to be 5 locations for monitoring: influent; effluent; the Pigeon River; and two other
effluents of wastewater before entering the wastewater treatment plants. This does not seem to
be enough locations, and ,in some cases, not enough sampling frequency. What is the
justification for those that are only tested quarterly and annually?
A5. Page 11. Instream Monitoring Special Condition
There are more sampling sites within Pigeon River for the special condition, what is the special
condition? Is it relevant to Dioxin Monitoring?
A8. Pages 16,17. Requirements for Color Analysis and Compliance Special Condition
The pounds of true color are calculated for this permit only. Is there no standard otherwise? I
believe 39 FR 430.11 is incorrectly referenced.
A9. Page 17. Dioxin Monitoring Special Condition
Dioxin has historically been an issue in this watershed. What is the justification for only annual
monitoring? What are the monitoring requirements should other permit condition indices (e.g.,
fish tissue TCDD levels) exceed permit limits?
A10. Page 18. Dissolved Oxygen Special Condition
Are the oxygen injection facilities already in use, and do they help with maintaining a good
dissolved oxygen level? It is suggested that DO be measured closer to the facility and
downstream past milemark 57.7. It is recommended that DO be measured in more than two

locations so as to more complete data relative to the plant's impacts on the Pigeon River
dissolved oxygen levels.
A11. Page 18. Town of Canton Inflow and Infiltration Special Condition
What efforts are being done to decrease the amount of inflow/infiltration into the Town of
Canton? Should specific metrics be required to meet this condition?
A. (12.) Page 18. Clean Water Act Section 316(a) Thermal Variance
The renewed permit will continue the temperature variances approved for the 2010 Permit.
During the last permit renewal, the variance requirements were changed and the temperature
difference between upstream and downstream monitoring locations (LT) was reduced from
13.9°C to 8.5°C . What was the scientific reason for allowing this anthropogenic temperature
increase.? The biological diversity and overall health of the Pigeon River has significantly
improved over the last 10 years. It is proposed that the LT Permit Variance be further
decreased so as to provide steam conditions even more satisfactory to further support
macroinvertebrate and fish species that appear to be recovering.
Thank you for considering our comments on this draft permit.
Regards,
Mary Plauche, MSc.
Gary D. Kollman
Environmental Review, Inc.