NC0000272_NC WRC Comments 3-19-2021_20220401

North Carolina Wildlife Resources Commission LA
Cameron Ingram, Executive Director
March 19, 2021
Mr. Sergei Chernikov
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC, 27699
SUBJECT: Blue Ridge Paper Products Inc. dba Evergreen Packaging
NPDES Permit NC0000272 Renewal
Pigeon River, Haywood County
Dear Mr. Chernikov:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed
information concerning the proposed NPDES Permit renewal for Blue Ridge Paper Products'
paper mill discharge on the Pigeon River in Haywood County. This information included the
2014 "Canton Mill Balanced and Indigenous Species Study for the Pigeon River" (BISS), which
characterizes the river's biological community upstream and downstream of the discharge.
Comments from the NCWRC on the permit action are provided under provisions of the Clean
Water Act of 1977 (as amended), Fish and Wildlife Coordination Act (48 Stat. 401, as amended;
16 U.S.C. 661-667d), North Carolina General Statutes (G.S. 113-131 et seq.), and North
Carolina Administrative Code 15A NCAC 10I.0102.
The Blue Ridge Paper Products (BRPP) mill is an integrated elemental chlorine -free bleached
kraft pulp and paper mill with oxygen delignification and bleach filtrate recycle. In the early
1990s, BRPP's predecessor, Champion International, implemented a modernization project that
markedly improved water quality in the Pigeon River. NCWRC appreciates the commitments of
BRPP and the NC Division of Water Resources to this objective. Improvements in aquatic
habitat allowed reintroductions of some extirpated fishes in the watershed. The following
comments are based on information available to NCWRC. If there is additional data or
information, we would be happy to consider this as well.
The proposed permit renewal includes the following elements that are pertinent to our
comments:
• Continuance of a 316(a) variance for temperature, requiring that BRPP not exceed a monthly
average temperature of 32° C in the summer (July, August, and September) and 29° C in the
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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winter (October - June) at the Fiberville Bridge, which is 0.4 mi downstream of the mill
outfall. In addition, the monthly average temperature at this location must not exceed the
monthly average temperature of the upstream monitoring location by 8.5° C.
• Increase the flow limit from 29.9 to 34.0 mgd.
Biological Community
Upon review of the BISS and additional available data, NCWRC biologists recognize a disparity
in the native aquatic community upstream and downstream of the mill, and we continue to be
concerned about the role that thermal impacts play in this difference. The BISS concludes that
there are no adverse impacts from the mill's discharge and "a diverse and healthy community
persists in the Pigeon River below the Canton Mill." Although the BISS presents various metrics
and analyses to support this conclusion, a more focused review of the data in the BISS and other
data collected by state agencies demonstrates that the aquatic community downstream of the mill
is significantly different from the upstream community and extremely atypical of rivers of
western North Carolina. For example:
• The fish community downstream of the mill is very different from that upstream of the mill
in several ways. The BISS describes the Pigeon River below the mill as having high fish
diversity. However, a long reach of the river downstream the mill does not support key
species.
o The River Chub (Nocomis micropogon) is not found within the first 8 miles
downstream of the mill, but it is found less than a mile upstream of the mill's
discharge. This fish is considered a keystone species, which builds nests that are used
by numerous other species for spawning. There is no other species in the Pigeon
River that shapes habitat and creates spawning sites for other species as the River
Chub does.
o Although the BISS describes the Pigeon River as having a high number of shiner
species, many of these species are not found for a considerable distance below the
mill. Saffron Shiner (Notropis rubricroceus, a river chub nest associate) and Mirror
Shiner (N. spectrunculus) were found less than a mile upstream of the mill's
discharge but not downstream of the mill at any site. Warpaint Shiner (Luxilus
coccogenis) and Tennessee Shiner (Notropis leuciodus), both dependent on River
Chub nests and found less than a mile upstream of the mill through BISS or NCWRC
monitoring, were not found or were found in very limited abundance below the mill
for the first 8 miles downstream of the mill.
o Mottled Sculpin (Cottus bairdii), an important host fish species for Appalachian
Elktoe, was found in abundance less than a mile upstream of the mill but found only
at one downstream site, 11 miles downstream of the mill.
• Although multiple species of salamanders, including the Eastern Hellbender
(Cryptobranchus alleganiensis, US Federal Species of Concern, NC Special Concern), are
found in the Pigeon River at numerous locations upstream of the mill according to both
NCWRC surveys and a 2009 longitudinal salamander survey described in the BISS, no
salamander species were found in the 15 miles surveyed downstream of the mill according to
the 2009 study.
• Data available express a significant difference in the mussel fauna of Pigeon river upstream
and downstream of the BRPP. Here is a summary of our data assessment.

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o 2012 survey efforts for the BISS found no mussels either upstream or downstream of
the mill. NCWRC staff and others have consistently found listed native mussels
within a mile upstream of the mill, namely the Appalachian Elktoe (Alasmidonta
raveneliana, US and NC Endangered) and Wavyrayed Lampmussel (Lampsilis
fasciola, US Federal Species of Concern, NC Special Concern), with Appalachian
Elktoe most recently found in 2020. However, these mussels have not been found
downstream of the mill in the Pigeon River at any location upstream of Crabtree
Creek, nearly 14 miles.
o The BISS maintains that conditions in the river would support native mussels if they
occurred, describing the results of a multi -year mussel silo study, in which young
Wavyrayed Lampmussels placed in silos demonstrated survival and growth.
However, this silo study cannot be used to assume long-term mussel survival and
successful reproduction. Mussel reproduction and juvenile development depend on a
complex set of factors, including appropriate temperature, dissolved oxygen, low
salinity, and low levels of pollutants (e.g., ammonia, potassium), and presence and
stability of appropriate fish host species. In addition, the closest silo to the mill was
in Clyde, approximately 5 miles downstream of the mill's outfall, so it is unclear how
well young mussels would fare in the reach between the mill and Clyde.
• Viability of crayfish upstream and downstream of the BRPP is notably different. No crayfish
have been found within the first 11 miles of river downstream of the mill, although they are
found in tributaries to the downstream reach of the Pigeon River and within the Pigeon River
upstream of the mill, with most recent records just upstream of the mill from 2020. It is also
notable that the crayfish species found 11 miles downstream of the mill is the non-native
White River Crayfish (Procambarus acutus). Given its tolerance to high water temperatures
and presence in Beaverdam Creek, a tributary to the river just downstream of the mill, and
within the Pigeon River less than a mile upstream of the mill, this species would be expected
in the Pigeon River just downstream of the mill. It is absent in the 11-mile reach downstream
of the mill, suggesting that high temperatures may not be the only issue impacting crayfish in
that reach.
Water Quality and Flow Issues
Given that effluent chronic (7-day exposure) toxicity testing has not demonstrated toxicity, it is
likely that consistent or acute high temperatures caused by mill effluent are a key factor affecting
the biological community in the Pigeon River downstream of the mill.
BRPP effluent conductivity is measured but not subjected to a permit limit. Analysis of recent
daily monitoring report data (January -November 2020) from upstream and downstream
Fiberville bridge monitoring locations shows a mean rise in conductivity of 277 µs/cm, with a
maximum increase of 1,358 µs/cm. For comparison, mean conductivity upstream of the mill was
27 µs/cm. Given these high levels of conductivity and indications that there may be water
quality factors besides temperature affecting the aquatic community, NCWRC believes that
additional analysis of constituents causing these high conductivity levels is merited.
The proposed increase in discharge flow from 29.9 to 34.0 mgd will likely exacerbate
temperature and other possible water quality impacts from the mill, as the discharge flow already
accounts for most of the flow in the river at various times during the year. Blue Ridge Paper

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withdraws its process water from the Pigeon River and returns flow as processed wastewater 0.3
mi downstream. When BRPP staff anticipate that Pigeon River flows will be inadequate for mill
operations, they release flows upstream from Lake Logan on the West Fork of the Pigeon River
to increase downstream flows.
Analysis of flow data from the US Geological Survey's (USGS) upstream gauge (USGS
03456991) for the period of 1985 to 2020 demonstrates that the proposed withdrawal of 34 mgd
will exceed flows available in the Pigeon River 6% of the time for September, the lowest flow
month of the year. 7Q10 flows are often used as a bare minimum of what can sustain some
biological function within a river; these are not required within the 0.3 mile reach between
BRPP's intake and outflow, but it is useful to see how often these minimal flows would be
absent with the increase in withdrawal/discharge. The USGS gauge data indicate that there
would be inadequate streamflow to provide the proposed withdrawal of 34.0 mgd and maintain
the 7Q10 flow (approximately 27 mgd, per USGS calculation) in the bypass between the intake
and outfall for more than 25% of the time from July through November.
Recommendations
Given concerns about temperature and the significantly altered aquatic community downstream
versus upstream of the mill, NCWRC requests that the permit conditions include the following
elements:
• Temperature should be monitored on a continuous 15-minute interval basis at the upstream
monitoring location and two downstream locations — DN-1 (Fiberville bridge), and DN-2
(above Clyde, RM 57.7) — so that temperature fluctuations can be better described. The data
should be summarized on daily basis as minimum, maximum, mean, and median. The entire
dataset should be retained and made available for outside analysis. We recommend that
BRPP use the upstream USGS station as their upstream control for flow and temperature.
• Presumably, the 8.5° C exceedance is not in addition to the 29° C and 32° C thresholds (i.e.,
allowing up to 37.5° C and 40.5° C), but is aimed at limiting even more extreme temperature
rises during winter months. Clarification of how these two thermal limits interact within the
permit is needed.
• It is unclear why the draft permit specifies that temperature limits be met on a monthly basis,
when temperature limits are to be met on a weekly basis, according to the April 24, 2012
partial settlement agreement 10 EHR 4341 (Cocke Co. TN v DENR, DWQ, and Blue Ridge
Paper Products) and 10 EHR 4982 (Cocke Co. TN v EMC, NPDES Committee, and Blue
Ridge Paper Products).
• Based on aquatic species concerns, we believe there would be a significant benefit of
temperature limits being met on a daily average instead of a weekly average at the Fiberville
Bridge so that large fluctuations in water temperature are kept to a minimum.
• We request that the permit require analysis of individual constituents that are responsible for
the high conductivity levels in the mill's effluent, such as salinity, potassium, sodium,
chlorides, nitrites, and sulfates. If the permit does not specify this analysis, we ask that the
NC Division of Water Resources perform its own analysis of mill effluent so that a better
characterization of the discharge is available upon which to base permit conditions and
potential mill process changes.
• We recommend that a BISS technical team be established that includes the NCWRC. This
technical team would provide input on survey locations and the methods utilized for the next

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BISS, as well as be allowed the opportunity to review the BISS before it is submitted to
NCDWR and the US Environmental Protection Agency. Long-term, detailed data should be
used to properly interpret the BISS. NCWRC sees value in the next BISS including more
robust biological and water quality monitoring, and offers the following specific
recommendations:
o Taxa-specific surveys for fish, mussels, and crayfish upstream and downstream of the
mill should be performed, with a minimum of three surveys per site, one per season
(spring, summer, and fall). The number of upstream and downstream sites and
tributary sites can be reduced to accommodate this increase in effort.
o Reference sites that are more analogous to the Pigeon River should be incorporated;
instead of the Swannanoa River, we recommend the upper French Broad River as a
reference.
o Salinity be measured at each site.
All these factors could be further discussed and planned during meetings of the technical
team.
Most importantly, we ask that solutions for the effluent's contribution to the river's biological
impairment be evaluated and implemented during this permit cycle. These solutions should
include technical and possible operational changes and appropriate thermal limits that reduce the
chronic effects of elevated temperature on the aquatic community.
Thank you for the opportunity to review and comment further on this permit action. Please
contact Andrea Leslie at [phone] if there are any questions about these comments.
David R. Cox, Supervisor
Habitat Conservation Division
ec: Luke Etchison, Chris Goudreau, TR Russ, Powell Wheeler, NCWRC
Byron Hamstead, USFWS