NC0000272_Fact Sheet_20241021 (2)

Department of Environmental Quality
Division of Water Resources
Fact Sheet for NPDES Permit NC0000272
Facility Information
Applicant/Facility Name
Applicant Address:
Facility Address:
Permitted Flow:
Type of Waste:
Facility/Permit Status:
County:
Miscellaneous
Receiving Stream:
Stream Classification:
303(d) Listed?:
Subbasin:
Drainage Area (mi2): [calculated]
Summer 7Q10 (cfs):
Winter 7Q 10 (cfs):
30Q2
Average Flow (cfs):
IWC (%):
Primary SIC Code:
Regional Office:
USGS Topo Quad:
Permit Writer:
Date:
Background
TBD Utilities LLC (formerly Blue Ridge Paper)
P.O. Box 4000
175 Main Street
4.9 MGD
Industrial, domestic, groundwater remediation, stormwater, and
landfill leachate
Major Modification
Haywood
Pigeon River
C
Yes. Biological impairment.
04-03-05
130 mil
52 cfs at Canton and 120 cfs at Hepco
63 cfs at Canton and 183 cfs at Hepco
89.9 cfs at Canton
325 cfs at Canton and 677 cfs at Hepco
100% (See Text Below)
2621
Asheville
Canton (E7SE — State Grid)
Sergei Chernikov, Ph.D.
June 28, 2024
The Blue Ridge Paper was established in 1908 to produce pulp for the Champion paper mill in Hamilton,
Ohio. Blue Ridge paper acquired ownership of the mill in May of 1999 from Champion International. In
2007, the facility was purchased by the Rank Group and was operating as a subsidiary of Evergreen
Packaging. The company historically employed about 1,500 people in North Carolina. The facility was shut
down on May 24, 2023.
Currently the wastewater treatment plant primarily treats domestic wastewater from Canton (—I.1 MGD), the
other miscellaneous sources include groundwater remediation, landfill leachate, and stormwater. After
facility completed the cleanup of the equipment at the end of 2023, the average effluent volume was 1.88
MGD, with the highest flow of 7.98 MGD. Therefore, the permitted flow limit will be reduced to 4.9 MGD.
The facility is currently in escrow and the new owner will be TBD Utilities LLCnegotiating the sale of the
property to a redevelopment company. Upon completion of the sale, the new owner would have to submit
the Engineering Alternative Analysis to justify the requested flow limit.
The facility has been purchased by TBD Utilities LLC in 2024. In August 2024 the facility requested that
groundwater remediation was explicitly added to the permit since the decision has been made to conduct
groundwater remediation activities at the site and approximately 0.25 MGD will be added to treatment. The
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new RPA was conducted based on the new Form 2C submitted by the permittee, this Form 2C included
groundwater data.
Temperature
The facility first requested and received a 316 (a) variance (approved by EPA) for temperature on August 6,
1985. Since the facility no longer generates heated wastewater, the variance is no longer necessary and will
be removed from the permit.
Dioxins
Elevated levels of dioxins were found in fish tissue in the Pigeon River (around the late 1980s).
Subsequently, a fish consumption advisory was issued for sport fish, catfish, and carp. The Canton Mill has
not discharged any detectable levels of 2,3,7,8-TCDD to the Pigeon River (since 1989) and dioxin in fish
tissue continues to decline.
Most fish consumption advisories in North Carolina and Tennessee were removed in 1998 and 2002. The
last fish advisory for Common Carp in Waterville Lake was removed on January 7, 2007. There are no fish
advisories in the Pigeon River at this time.
The May 2010 NPDES Permit for the Blue Ridge Canton Mill required three (3) additional years of fish
tissue sampling and surveillance. During the sampling years between 2008-2013 the concentrations in fish
tissue fillets were below the NC DHHS 4 ppt TEQ [toxic equivalency] action level for fish consumption
advisory. In 2014, TEQ values were below detection for channel catfish for both sampling Stations;
however, in Common Carp, TEQ values were 9.619 ppt for Station 4A and 2.928 for Station 4B.
The TEQ results for Common Carp fillets in 2014 and 2007 could be anomalies, or could indicate that some
fish are present in the population with relatively higher TEQ values.
EPA conducted a High Volume dioxin sampling in the Pigeon River in 2014 and concluded that "the most
potent of congeners in the series, 2,3,7,8 — TCDD, was not detected in dissolved samples at the reporting
limit of 0.0012 parts per quadrillion at any station".
During the previous permit renewal all sampling results showed results below TEQ action level. Since the
fish dioxin concentration have been reduced steadily during the last several decades, the facility had no
dioxin detection in it's effluent since 1989, the production of pulp and paper has been eliminated, and based
on the EPA High Volume dioxin sampling results, the fish tissue sampling requirement in the permit will be
eliminated.
316(b)
Since the cessation of production, the facility withdraws less than 2.0 MGD from the Pigeon River and is not
subject to 316b rule.
Instream Monitoring
Historically, Blue Ridge Paper conducted extensive stream monitoring, including one upstream and seven
downstream monitoring stations. Since the facility was shut down in 2023, this regime is no longer necessary
and only one downstream monitoring station will remain in the permit to estimate impact from
miscellaneous waste streams such as landfill leachate.
Table 1. Instream Monitoring Requirements
Stream Mile Location Description Parameter Frequency
Desienation Marker
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DN1 62.9 Pigeon River at Fiberville Bridge Temperature Weekly
D.O. Weekly
Conductivity Weekly
Fecal Coliform Weekly
Color Weeklv
Compliance Summary
During the review period (05/2019 through 05/2023) the following NOVs (notices of violation) have been
issued: 4 - for violating whole effluent toxicity limit, 5 — for violating BOD limit, 6 — for violating Fecal
Coliform limit.
Permitting Rationale — Toxicants
The Division conducted EPA -recommended analyses to determine the reasonable potential for toxicants to be
discharged at levels exceeding water quality standards/EPA criteria by this facility. For the purposes of the
RPA, the background concentrations for all parameters were assumed to be below detection levels. The RPA
uses 95% probability level and 95% confidence basis in accordance with the EPA Guidance entitled "Technical
Support Document for Water Quality -based Toxics Control." The RPA included evaluation of dissolved
metals' standards, utilizing a default hardness value of 25 mg/L CaCO3 for hardness -dependent metals. The
RPA spreadsheets are attached to this Fact Sheet.
The calculations included: As, Be, Cd, Total Phenols, Cr, Cu, CN, F, Pb, Hg, Mo, Ni, Se, Ag, and Zn. The
new flow limit of 4.9 MGD was used for RPA. The discharge data on the EPA Form 2C and DMR reports was
used for the RPA. The analysis indicates no reasonable potential to violate the surface water quality standards
or EPA criteria.
The proposed permit requires that EPA methods 200.7 or 200.8 (or the most current versions) shall be used
for analyses of all metals except for total mercury.
Permitting Rationale — Oxygen Consuming Waste Pollutants
BOD
Limits for BOD have been converted to secondary treatment standards since the facility now primarily treats
domestic wastewater.
Ammonia monitoring requirements are retained in the draft permit to provide data concerning levels of
ammonia discharged to the Pigeon River (which may affect instream dissolved oxygen).
Effluent dissolved oxygen is limited at no less than 6 mg/L based on the above discussion.
Permitting Rationale — Nutrients
Total phosphorus and total nitrogen monitoring is required by 15A NCAC 2b .0500. Monthly monitoring
is required to assess the contribution of nutrients.
Permitting Rationale —Conventional Pollutants
The total suspended solids (TSS) limits have been converted to secondary treatment standards since the
facility now primarily treats domestic wastewater.
The temperature requirement is based on the State Rules per 15A NCAC 2B .0200.
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Limitations for fecal coliform are based on the contribution of domestic wastewater from the Town of
Canton and the requirements of 15A NCAC 2B .0200.
Conductivity monitoring is required based on 15A NCAC 2B .0500 and remain unchanged until the new
owner determines the type of wastewater that will be treated.
Limitations for pH 6.0 —9.0 are based on 15A NCAC 2B .0200.
Toxicity Testing
(15A NCAC 2B.0200 and 15A NCAC 2B.0500)
Current Requirement: Outfall 001 — Chronic P/F @ 90% using Ceriodaphnia Dubia
Recommended Requirement: Outfall 001 — Chronic P/F @ 12.7% using Ceriodaphnia Dubia.
This facility failed 4 toxicity tests in 2023. However, the subsequent tests passed, please see attached. All tests
conducted in 2020, 2021, 2022, and 2024 passed.
For the purposes of the permitting, the permitted flow was used in conjunction with the 7Q 10 summer flow to
calculate the percent effluent concentrations to be used for WET tests for each facility.
PROPOSED PERMIT CHANGES
1) The following changes have been made due to the cessation of all manufacturing processes:
a) The limits and/or monitoring for the following compounds at Outfall 001 have been eliminated:
2,3,7,8-Tetrachloro-dibenzo-p-dioxin, Trichlorophenol, Pentachlorophenol, Adsorbable Organic
Halides, Chemical Oxygen Demand, Total Copper, and Total Zinc.
b) Mass color limits and instream color limits have been eliminated.
c) The flow limit was reduced to 4.9 MGD.
d) Instream Waste Concentration for toxicity test was reduced to 12.7%.
e) Internal Outfall 002 and Internal Outfall 003 have been eliminated.
f) Instream Sampling at the following locations has been eliminated: UP (upstream), DN2
(Downstream 2), DN3, DN4, DN6, BC, DN7.
g) Frequency of instream sampling at DN1 has been reduced to weekly for the following
parameters: Temperature, DO, Conductivity, and Color.
h) Dioxin Monitoring Special Condition has been eliminated.
i) Clean Water Act Section 316(a) Thermal Variance Special Condition has been eliminated.
j) Best Management Practices Special Condition has been eliminated.
k) Effluent Guideline Sampling Plan Special Condition has been eliminated.
1) The requirement for Color Analysis and Compliance Special Condition has been eliminated.
m) Dissolved Oxygen Special Condition has been eliminated.
n) Limits for BOD and TSS have been converted to secondary treatment standards since the facility
now primarily treats domestic wastewater.
2) Engineering Alternative Analysis Special Condition was added to the permit to assure that the new
owner has a justification for the permitted flow volume in accordance with the state rules.
3) Major Modification Application Special Condition was added to the permit to assure that the
potential new waste streams comply with the state rules.
Public Notice
Permit to Public Notice: 07/23/2024
Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the Director
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within the 30-day comment period indicating the interest of the party filing such request and the reasons why
a hearing is warranted.
State Contact
If you have any questions on any of the above information or on the attached permit, please contact Sergei
Chernikov at [phone] or sergei.chernikov(&deq.nc.gov.
Changes in the Final Permit
• The permittee name was changed to reflect the recent transition of the facility's ownership.
• The requirement to complete EPA Form 2C within 180 days from the permit effective date was added
to the permit to conduct secondary evaluation of treated groundwater addition to the facility's effluent.
This change was made in response to the comment from the SELC.
• The wastewater description was updated in response to the comment from the Town of Canton.
• The recovered treated groundwater was added to the list of authorized waste stream in response to the
request from the permit holder and after a new statistical evaluation of the effluent.
• The upstream sampling for fecal coliforms and DO was restored in the permit in response to the
comment from the Town of Canton.
• The influent sampling for fecal coliforms was added to the permit to determine the cause of fecal
coliform violations.
• Semi-annual PFAS monitoring was added to Outfall 001 based on the EPA Guidance.
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