NC0000272_Evergreen Review of Draft Permit Comments_20220401

evergreen./
packaging
May 17, 2021
Via email and US Mail
Sergei Chernikov. P.E. Ph.D.
NPDES Permitting
North Carolina Department of Environmental Quality
217 W Jones St.
Raleigh, NC 27603
Canton Office
175 Main Street . Canton, NC 28716
Re: Draft NPDES Permit NC 0000272 Blue Ridge Paper Products LLC / Comments by
Tennessee Department of Environment and Conservation / April 27, 2021
Dear Dr. Chernikov,
Blue Ridge Paper Products LLC. ("Blue Ridge Paper"), d/b/a Evergreen Packaging, has
received and reviewed the Tennessee Department of Environment and Conservation's (TDEC)
comments on Draft NPDES Permit NC 000272 ("Draft Permit") dated April 27, 2021. Please
consider the following comments in response.
The Draft Permit reviewed by TDEC from December 2020 to February 2021 was
substantially the same as the current Draft Permit. Blue Ridge Paper would note, initially, that
TDEC, in its comments on the Draft Permit dated February 20, 2021, did not object to the removal
of the color variance, other than to express some concern about the methodology employed by
North Carolina Department of Environmental Quality ("DEQ").
Blue Ridge Paper agrees that there have been substantial improvements in the Pigeon
River since the late 1980's and that the improvements are continuing. Color in the Canton Mill
discharge has decreased by more than 90% since 1988. Dioxin has been non -detect in Mill effluent
since 1989. The Pigeon River Restoration Project, a partnership between the University of
Tennessee, TDEC and Blue Ridge Paper, has successfully restored extirpated fish species in the
Pigeon River in Tennessee and North Carolina. There is a thriving whitewater rafting industry in
the Pigeon River in Tennessee. Color in the river complies with North Carolina's narrative water
quality standard for color. True color concentration in the Pigeon River above the Canton Mill and
at the state line are indistinguishable to the human eye.

Today, and in recent times, the discharge from the Canton Mill has no adverse impact on
the Pigeon River in Tennessee. The distance from the Canton Mill discharge to the Tennessee
state line is approximately 39 river miles. At river mile 26, the Pigeon River in North Carolina is
impounded in the Waterville Reservoir. Water drawn from the bottom of the reservoir is pumped
through an approximately seven -mile pipe to the Duke Energy Hydroelectric plant where it goes
through the turbines and discharges to the river. Without the reservoir and the controlled releases,
there would be no rafting industry in the Pigeon River in Tennessee.
Color in the Pigeon River in Tennessee is only incrementally greater than color above the
Canton Mill. Blue Ridge Paper believes the color variance should be removed, and the draft permit
should be issued.
Section A. 8. Re( uirements for Color Ana I v pis and Com )liance Spiccial Conditions
The Current Permit requires Blue Ridge Paper to avoid major maintenance outages
during June, July and August. The Draft Permit, A. (8.) 6, on page 17, requires Blue Ridge Paper
to avoid major maintenance outages for the months of June through October. Extending this
limitation to September and October creates major operational issues for the Mill, including
creating a conflict with NCDOL's requirement that safety inspections for the Recovery boilers are
to be done during the window of September and October. Therefore, Blue Ridge Paper requests
that the period to avoid major maintenance outages remain June, July and August.
Section A. (94 Dioxin Monitoring, Special Condition
The Draft Permit requires Blue Ridge Paper to sample for dioxin in the second year of
the Permit. If any of the sample results exceed the NC DHHS 4 ppt TEQ action level, Blue Ridge
Paper has to conduct additional fish tissue analysis in the 4th year. EPA did intensive high volume
sampling for dioxin in the Pigeon River downstream of the Canton Mill in 2014. None of the
samples exceeded the North Carolina Water Quality standard for dioxin. Blue Ridge Paper
believes the dioxin provisions in the Permit are protective of the Pigeon River and should not be
changed.
Section A. (13.) Electronic Reporting of Discha r.e Monitorin4 Reports
BRPP respectfully requests that this requirement not be included in the NPDES permit.
The discharge monitoring reports are available on the DEQ website.
Technology Review Workgroup
Blue Ridge Paper believes the Technology Review Workgroup ("TRW") has served its
purpose. Color in the Pigeon River has been reduced by more than 90%. During the term of the
existing permit, Blue Ridge Paper evaluated the implementation of second stage oxygen
delignification and enhanced bleaching in the extraction stage. Neither of the technologies was
deemed to be technically or economically feasible. Reports of the evaluations were submitted to
DEQ, to EPA and to the TRW.

The Draft Permit requires Blue Ridge Paper to conduct a technical review of color
removal technologies and submit a report to DEQ with the permit renewal application. See A. (8.)
7 in the Draft Permit (page 17).
North Carolina Water Quality Standard for Color
North Carolina has a narrative water quality standard for color. The standard
consists of multiple components: public health, secondary recreation, aquatic life and wildlife,
palatability of fish, impairment of designated uses and aesthetic quality. There is no argument that
the water in the Pigeon River in NC complies with all components of the standard, except
aesthetics. In the 1980's, EPA determined that the aesthetic component of the standard could be
met by compliance with a 50 platinum cobalt unit (milligrams per liter) standard. EPA
"interpreted" the aesthetic component of North Carolina's standard to be 50 platinum cobalt units
or 50 mg/liter).
The 50-unit standard has never been formally promulgated as a water quality
standard by EPA or North Carolina. However, because of the history of 50 in the Pigeon River,
Blue Ridge Paper asked AquAeTer to analyze color concentrations in the Pigeon River based on
samples taken since 2010. AquAeTer also analyzed monthly flows in the Pigeon River in North
Carolina using USGS data for approximately the last 100 years. Based on its analysis, AquAeTer
determined that true color concentrations in the Pigeon River, at flows greater than or equal to 129
cubic feet per second, averaged less than 50 true color units more than 90% of the time.
Evergreen submitted the AquAeTer report to DEQ in January 2018. AquAeTer
updated the report in 2019 and in 2021 and the updates were submitted to DEQ. The report(s)
include a thorough analysis and discussion of the basis for using the monthly 30Q2 flow. In fact,
AquAeTer calculated the actual monthly 30Q2 for each month. However, DEQ chose to use the
lowest monthly 30Q2 flow, 129 cfs.
TDEC also argues that North Carolina should apply its color standard at all flows.
However, for aesthetic pollutants such as color, Title 15A North Carolina Administrative Code,
2B.0206 requires compliance only at all flows equal to or greater than 30Q2.1 The daily, monthly
and annual effluent limits for color apply at all flows.
The Tennessee Color Standard
Tennessee also has a narrative water quality standard for color. For recreational waters, the
standard requires "...no turbidity or color in such amounts as will result in any "objectionable"
appearance." Objectionable is not defined. 2 TDEC argues that even if the NC color standard is
' 129 cubic feet per second is the lowest 30Q2 monthly flow calculated for the Pigeon River.
2 Tennessee suggests that it has a different criterion or interpretation of its standard for `Blue Ridge Waters," however,
it cites no specific regulation.

being met, the standard in Tennessee is not, although TDEC offers no data to support its position
other than stating that it has "a different criterion" for interpretation of color in a Blue Ridge
Stream.
Tennessee also argues that the color standard in the Pigeon River in Tennessee is not being
met because the first five miles of the Pigeon River are listed as impaired for color on EPA's
303(d) list. There is simply no data to support this listing of impaired. Blue Ridge Paper has
objected, on multiple occasions, to the listing of the first five miles of the Pigeon River as being
impaired in Tennessee and the attribution of the impairment to "large industrial discharger in North
Carolina", without success.
Removal of the Color Variance
TDEC objects to removal of the color variance. Most of its "objections" question North
Carolina's methodology for determining compliance with North Carolina's narrative color
standard and the use of a monthly rather than annual 30Q2. TDEC also disagrees with the
averaging of color and suggests that color has an impact on aquatic life. TDEC further asserts that
"exceedances of our narrative standard are not continuous but occur for the most part during low
river flows." TDEC makes reference to color measurements in the 30 to 40 color unit range.
Finally, TDEC argues that "objectionable color" is an instantaneous perception by the public and
requests that color limits be based upon individual monthly averages with the application of an
instantaneous daily maximum limit
None of TDEC's arguments are based on actual data. Satisfying an "instantaneous
perception by the public standard" is impossible and wholly unrealistic. So is complying with an
instantaneous daily maximum limit.
Blue Ridge Paper believes, based on years of instream data, that color in the Pigeon River
complies with the North Carolina water quality standard for color. The color variance should be
removed.
Blue Ridge Paper appreciates the opportunity to respond to these comments. Please let me
know if you have questions.
Very Truly Yours,
Tracy Willis Fred J. Perrett
Operations Supervisor / ORC Mill Manager