NC0000272_Public Comments_20220401 (5)

Katie Hicks
263 Fairview Road
Asheville, NC 28803
NC Division of Water Resources
NPDES Wastewater Permitting
North Carolina Department of Environmental Quality
217 West Jones Street
Raleigh, NC 27603
April 30, 2021
Attn: Blue Ridge Paper Products
Draft Permit NC0000272
Dear Mr. Chernikov and NC DWR Team:
Growing up in Western North Carolina, I have observed the water and air pollution coming
from the Blue Ridge Paper Products mill in Canton, NC for my entire life. The Pigeon River is a
small mountain river and should have special protections compared to a larger water body with
a mill of similar size, yet permits allow the mill to discharge massive amounts of polluted
wastewater into the small river.
As a former staff member of Clean Water for NC (CWFNC), I began learning about the details
of the mill's wastewater discharges into the Pigeon River and the impacts on downstream
communities beginning with the 2010 permitting cycle. At that time, 11 years ago,
organizations such as CWFNC, Clean Water Expected in East Tennessee (CWEET), and others
were already having to pressure the Division to hold the mill accountable to make
improvements identified in the Settlement Agreement in the 1990s and the several technical
studies that followed. These studies proved that the mill could absolutely make changes to
create real progress in improving water quality in the Pigeon River, and yet, decades after the
studies took place, this permit continues to set low expectations, harming the livelihoods of
downstream users.
According to CWEET, whose members are largely raft guides and individuals who kayak, boat,
swim and fish in the Pigeon River downstream, "the color of the river is brown, dark and sweet
tea colored on many days. The river smells like the acrid papermill, all the way to Newport,
Tennessee. One can observe foam and often professional river guides deal with rashes and
reactions to the many chemicals that comprise the color pollution." (Source). Cocke County,
TN's economy and health has been adversely affected by the mill for over 100 years while

Haywood County, NC enjoys over 1000 high paying jobs and the tax revenue coming from the
mill's presence. In order to address the injustices caused by the mill's discharge, I offer the
following specific comments on the 2021 permit:
• Do not remove the color variance. Impacted residents and advocacy organizations have
had to fight against the removal of the color variance in numerous permitting cycles,
and the reasons for keeping it remain the same. The variance acknowledges that the
color in the river is not meeting the NC narrative standard, and to remove it would
indicate that the color in the river is acceptable, which is simply not the case.
• The instream color standard must be strengthened. The proposed standard is weaker
than the proposed EPI standard from back in the 1980s, which is unacceptable.
• Do not increase the limit for chloroform. This permit allows additional chloroform to be
released into the river compared to the previous permit, based on the total production
of the mill. Toxic releases should be decreasing, not increasing, over time, as set forth in
the creation of the Clean Water Act and NPDES permitting.
• Tighten the temperature variance and increase monitoring frequency for several key
parameters. This includes instream color, which should be sampled daily at the closest
downstream point (Fibreville). Enforcement should be based on these daily
measurements rather than monthly averages, which do not account for large spikes in
production. The summer temperature limit should be enforced daily, as well, and this
limit should be reduced to at least 30 degrees C.
The photo below was taken in 2010 on a flyover above the mill by my friend and Haywood
County resident Valerie Blanchette, who was a boater and firm advocate for cleaning up the
Pigeon River who had been involved in previous permitting cycles. She unfortunately passed
away in 2019. It is in memory of Valerie, and in hopes that her dream of a truly clean Pigeon
River and a paper mill that is truly held accountable by NC regulators, will become a reality.

Respectfully submitted,
Katie Hicks