NC0000272_Review of Balanced and Indigenous Population Assessment_20220401

Water Resources
Environmental Qualith
January 11, 2019
ROY COOPER
Governor
MICHAEL S. REGAN
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LINDA CULPEPPER
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Mr. Wallace McDonald, Manager
Evergreen Packaging
175 Main Street
Canton, NC 28716
Subject: Review of Evergreen Packaging (Canton Mill: NPDES Permit NC0000272) 316 (a)
Balanced and Indigenous Populations Assessment.
Dear Mr. Draovitch:
Water Sciences Section (WSS) staff has reviewed the aforementioned dataset. Although the Division
does not conduct fish bioasessments on the mainstem of the Pigeon River, a review of the fisheries
community, based on the data submitted, was conducted. Based on that review, we note that the
elevated temperatures allowed under the current permit do not seem to be significantly limiting fish
communities in the thermally influenced segment of the river. Moreover, the fish data provided
demonstrates good (and improving) diversity and abundance at most locations and species generally
considered thermally sensitive have maintained or increased populations since 1995. In addition, bottom
dwelling fish species (e.g., darters, sculpin, etc.), while limited in their natural ability to repopulate the
downstream reach of the river, have shown improvement since the start of the reintroduction efforts in
2006. In summary, with regard to the fish data provided, the Representative Important Species are
generally meeting the 316(a) standards of protection, propagation and sustainability. Overall, the fish
community data provided meets the definition of a Balanced and Indigenous Population.
Regarding the biological assessment of the invertebrate community, the data provided in this report on
the mainstem segment of the Pigeon River below the discharge (Figure 1) roughly correlates with the
Division's data for this segment over the same period (2012) with bioclassifications ranging from Fair to
Good -Fair (Table 3.1.1-2). However, there were exceptions. The Division's station at SR 1338 (below the
discharge) received a Good bioclassification (2012) whereas that segment in this study (PRM 45.3;
Figure 1) received a Good -Fair bioclassification. In addition, the data submitted in this report at the
Browns Bridge station (PRM 24.7, Figure 1) received a Good -Fair bioclassification whereas the Division's
2012 sample from this segment received an Excellent bioclassification. These discrepancies, particularly
the large, two (2) bioclassification difference observed from the Brown's Bridge segment are problematic.
Therefore, future overlap sampling should be arranged to assure consistent data collection. Please
contact Eric Fleek (eric.fleek(a�ncdenr.gov) to coordinate this effort.
Nevertheless, and although the data do suggest some impact on the benthos community as a result of
the thermal discharge, it can be argued that this impact is not significant enough to exceed the broad
definition of a Balanced and Indigenous Population.
In addition to the aforementioned sampling discrepancies on the Pigeon River, there are two additional
matters that need to be addressed in future surveys and subsequent reporting.
1) On Page 14, the following citation is used: "NCDENR 2001" (found under Section 2.1 "Habitat
Assessment"). On Page 10, there is reference to the use of "Standard Operating Procedures for
Benthic Macroinvertebrates (2003) and "Standard Operating Procedures for Biological Monitoring
of Stream Fish Community Assessment and Fish Tissue (2001). The data collected for use in this
document were collected in 2012. However, there was a 2006 version of the North Carolina
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State of North Carolina I Environmental Quality / Water Sciences Section
1621 Mail Service Center I Raleigh, North Carolina 27699-1621
919-743-8400

Department of Natural Resources (NCDENR) Standard Operating Procedure (SOP) available for
both Benthic Macroinvertebrates and Stream Fish Community Assessment and Fish Tissue and
the 2006 versions of these SOPs should have been used in this report. Therefore, the use and
citation of NCDENR 2001 is incorrect. It must be noted that future collections and analyses
should be conducted using the most current North Carolina Department of Environmental Quality
(NCDEQ) SOP. Please contact Eric Fleek (eric.fleek0.ncdenr.gov) for the most current
versions of the Benthos, Fish IBI, and Fish Tissue Standard Operating Procedures.
2) There are several errors noted in Table 3.1.1-1. For example, Allonarcys biloba is an outdated
genus designation having been synonymized with Pteronarcys in 1982 (Stark and Szczytko
1982). In addition, Seratella deficiens was changed to Telagonopsis deficiens in 2008 (Jacobus
and McCafferty 2008), Micrasema barksi is a non-existent species appellation and is an apparent
misspelling of Micrasema burksi. In addition, there are no know larval specimens (or keys to their
identification) for the larvae Cheumatopsyche pasella (Morse et al., 2017). Furthermore, there are
several semi -aquatic Hemiptera listed in Table 3.1.1-1 which are not collected and are not used in
the calculation of the North Carolina Biotic Index or in the assigning of bioclassifications in North
Carolina (NCDENR 2011). These taxa include the Gerrid Aquarius remigis, the Mesoveliid
Mesovelia mulsanti, and the Veliid Rhagovelia obesa. Given the semi -aquatic nature of these
taxa, they are not appropriate for use in water quality bioassessments (NCDENR 2011).
3) In the future, and to ensure that this office receives all germane biological and or
physical/chemical data for this facility, please either a) mail a copy directly to Eric Fleek (1621
Mail Service Center, Raleigh NC 27699-1621) OR b) email a scanned copy directly to
[e-mail].
If you have any questions about these issues, please do not hesitate to contact me.
Sincerely,
Cyndi Karoly
Chief, Water Sciences Section
cc: Landon Davidson, Asheville Regional Office
Julie Grzyb, NCDWR Complex Permitting Unit
Sergei Chernikov, NCDWR Complex Permitting Unit