NC0000272_Public Comments 4-30-2021_20220401

April 30, 2021
Comments submitted electronically to: [e-mail]
Re: Blue Ridge Paper Products Permit
To Whom It May Concern,
I am submitting the following comments on behalf of Foothills Paddling Club (FPC) to oppose
renewal of National Pollutant Discharge Elimination System (NPDES) discharge permit
NC0000272 for Blue Ridge Paper Products Inc. for wastewater discharge to the Pigeon River.
FPC is based in Greenville, South Carolina and has a membership that extends throughout the
region, including Western North Carolina, Northeast Georgia, East Tennessee, and throughout
South Carolina. FPC promotes the safe enjoyment of both whitewater and flat water and supports
the local paddling community through events, trips, classes, clinics, and online resources. Many
FPC members paddle the Pigeon River. FPC supports protecting the health of our southeast
rivers to ensure that existing uses and the water quality needed to protect those uses is
maintained.
The water quality of the Pigeon River has improved significantly in recent decades thanks to
pressure from federal, state, and local governments, the public, and operational changes at the
Canton Mill. Recreational use of the river has also increased, helping to boost the local economy.
However, there is still much that needs to be done to reduce pollution in the river coming from
the Mill's wastewater discharge. The proposed permit includes no new requirements for water
quality improvements to address water quality impairments downstream of the discharge, and
therefore is inconsistent with antidegradation policy and anti -backsliding provisions of the Clean
Water Act. The goal of the Clean Water Act is to prevent, reduce, and eliminate pollution in the
Nation's waters in order to restore and maintain their chemical, physical, and biological integrity.
Anti -backsliding provisions prohibit the renewal, reissuance, or modification of an existing
NPDES permit that contains effluent limitations, permit conditions, or standards less stringent
than those established in the previous permit.
The renewal of the NPDES discharge permit is long overdue, as are needed water quality
improvements. The new permit should therefore include requirements that would improve and
protect water quality and stream health/aquatic life, not allow more pollution. The following
comments are offered to detail our opposition to the proposed permit.
• The requested change of water usage from 29 to 34 MGD (17% increase) to
accommodate changes to industrial process, increased landfill leachate, and growth from
the Town of Canton effectively increases pollutant loading to an already impaired section
of the Pigeon River. More stringent permit limits/conditions/standards are therefore
needed to mitigate additional impacts to water quality from the increased discharge and
increased pollutant load. NC DEQ should require the mill to submit updated information
stating what pollutant levels they will be discharging under the increased flow.

• More than 6 miles of the Pigeon River below the Canton Mill discharge are currently
listed as impaired by NC DEQ for not adequately supporting aquatic life and an
additional 7.8 miles downstream are proposed to be listed as impaired (in a reach that was
previously listed), also because they do not fully support aquatic life. The fish community
below the Mill is more characteristic of a warm water system compared to upstream of
the Mill. The 2014 Canton Mill Balanced and Indigenous Species Study for the Pigeon
River found that the most common fish species collected downstream of the Mill
discharge was redbreast sunfish, which is nonindigenous to cold mountain waters and is
thermally tolerant. Similarly, carp is also common in the thermally affected reach below
the Mill. No salamanders were found in samples collected in the Pigeon River below the
mill discharge, although they were found upstream and in tributaries. A 2009-2010
baseline survey of crayfish in the Pigeon watershed with 1,320 crayfish specimens
represented found crayfish in nine tributaries, in the mainstem of the Pigeon River
upstream of the Mill, in the bypass reach downstream of Walters Dam, and in reaches in
Tennessee. No crayfish were found at three stations in the river downstream of the Mill
above Waterville Lake. The 2014 species study found no native crayfish species and only
one non-native crayfish species in the river downstream of the Mill. Federally
endangered freshwater mussels and mussel species of concern in North Carolina have
been found in the Pigeon River upstream of the Canton Mill discharge, while it has been
reported that the only bivalve found in the lower portion of the river below the Mill dam
is the exotic invasive Corbicula. (Note: Fish experts from the N.C. Museum of Natural
Sciences, N.C. Wildlife Resources Commission, University of Tennessee and other
groups estimated that 40 species of native mussels and 95 species of native fishes once
inhabited the river.) North Carolina Biotic Index scores for macroinvertebrates declined
from a Good rating upstream of the discharge to a Fair rating downstream of the
discharge. Blue-green algae were reported as dominating the periphyton community
below the discharge. The aquatic plant indicator species Podostemum ceratophyllum was
present in reference and upstream sites and further downstream, but was not present at all
in the thermally affected reach below the Mill. While it is recognized that there has been
an overall positive trend towards improvement of conditions more conducive to healthy
indigenous aquatic life, thermally affected reaches remain impaired and therefore
measures are needed to improve the water quality of the Canton Mill discharge
sufficient to adequately support aquatic life.
• NC DEQ should eliminate the thermal variance for the mill discharge. The aquatic
community below the discharge is not balanced or indigenous, which is a requirement for
a thermal variance under Section 316(a) of the Clean Water Act. Therefore, NC DEQ
should not grant furtherance of the thermal variance. Permit requirements and conditions
are needed to continue to reduce thermal impacts to the river from the wastewater
discharge at the Canton Mill. The heated waste discharge alters the Pigeon River aquatic
community and impairs downstream water quality and in -stream habitat conditions.
Measures are needed to decrease the temperature difference and to minimize extreme
changes in temperature as measured on a daily time scale. Therefore, daily temperature
limits are needed for the new permit. The 2007 fish kill during low flow conditions and
high temperatures underscores this need. Replacing weekly average temperature
standards with monthly average standards is backsliding and will likely have the effect of
allowing increased temperatures below the mill. Therefore, tighter standards (daily limits)

for temperature are needed for the new permit, along with elimination of the thermal
variance.
• Although there have been significant improvements, the color of the Pigeon River
remains unacceptable. The water color is inconsistent with that of other rivers in the area,
particularly during low flow periods, and looks like that of a slow -moving coastal black
water river high in tannins. The unnatural color of the mill discharge adversely affects the
aesthetic quality of the river and negatively affects the quality of recreational experiences
in reaches downstream of the discharge. The darker color of the Pigeon River below the
mill discharge along with elevated specific conductance levels indicates a high level of
dissolved constituents in the water column that are likely contributing to the impairment
of aquatic life. Furthermore, the Pigeon River across the state line in Tennessee is
currently not meeting all its designated uses and remains on the Tennessee 303(d) list for
impaired rivers due to color pollution, foam, taste, and smell from the Canton Mill
discharge. Therefore, the color variance must not be removed until the river below the
discharge is meeting its designated uses and is no longer significantly and unnaturally
discolored.
• Dioxin testing in fish should continue until none is detected. Relaxing dioxin testing
requirements is not warranted for the new permit.
• There have been multiple violations of water quality standards for fecal coliform, which
directly impacts recreational use. The new permit should include required measures to
prevent fecal coliform violations in the future.
• Paper mills using polyfluoroalkyl substances (PFAS) may be a significant source of
contamination to water. NC DEQ should require a complete disclosure of all PFAS used
now or historically at the Canton Mill and ensure the best available technologies are used
to remove these pollutants before water is returned to the river. Additional sampling
should be required to detect the presence and concentration of PFAS in the wastewater
discharge.
In summary, the draft NPDES discharge permit NC0000272 for Blue Ridge Paper Products Inc.
for wastewater discharge to the Pigeon River permit fails to adequately protect aquatic health and
recreational use, allows for increased pollutant loading, and is inconsistent with the goals of the
Clean Water Act for the continued reduction and elimination of pollution. The draft permit is a
step backwards for the continued recovery of the Pigeon River from ongoing significant and
impactful wastewater discharges from the Mill and therefore should not be approved.
Sincerely,
Adam Mobley, Vice President
Foothills Padding Club