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HomeMy WebLinkAboutNC0000272_Balanced and Indigenous Population_20190307Water Resources Environrnerml Quality January 11, 2019 ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director Mr.VVallaceMcDonald, Manager Evergreen Packaging 175 Main Street Canton, NC 28716 Subject: Review of Evergreen Packaging (Canton Mill: NPDES Permit NC%0000272) 316 (a) Balanced and Indigenous Populations Assessment. Dear Mr. Draovitch: Water Sciences Section (VVSS) staff has reviewed the aforementioned dataset. Although the Division does not conduct fish bioasessments on the mainstem of the Pigeon River, a revie�D v, of the fisheries community, based on the data submitted, was conducted. Based on that review, `^we note that the elevated temperatures allowed under the current permit do not seem to be significantly limiting fish communities in the thermally influenced segment of the river. Moreover, the fish dzata provided demonstrates good (and improving) diversity and abundance at most locations anal species generally considered thermally sensitive have maintained or increased populations since 19695. In addition, bottom dwelling fish species (e.g., darters, sculpin, etc.), while limited in their natural abilitty to repopulate the downstream reach of the river, have shown improvement since the start of the reir-Itroduction efforts in 2006. In summary, with regard to the fish data provided, the Representative Important Species are generally meeting the 316(a) standards of protection, propagation and sustainabillity, Overall, the fish community data provided meets the definition of a Balanced and Indigenous Population. Regarding the biological assessment of the invertebrate community, the data provided in this report on the mainstem segment of the Pigeon River below the discharge (Figure 1) roughly correlates with the Division's data for this segment over the same period (2012) with bioclassification% ranging from Fair to Good -Fair (Table 3.1.1-2). However, there were exceptions. The Division's station at SR 1338 (below the discharge) received a Good bioclassification (2012) whereas that segment in this Study-(PRM-46.3; -- -- ----- Figure 1) received a Good -Fair bioclassification. In addition, the data submitted in this report at the Browns Bridge station (PRM 24.7, Figure 1) received a Good -Fair bioclassificationi whereas the Division's 2012 sample from this segment received an Excellent bioclassification. These discrepancies, particularly the large, two (2) bioclassification difference observed from the Brown's Bridge segment are problematic. Therefore, future overlap sampling should be arranged to assure consistent data Collection. Please contact Eric Reek (eric.fleek(dricdenr.nov) to coordinate this effort. Nevertheless, and although the data do suggest some impact on the benthos community as a result of the thermal discharge, it can be argued that this impact is not significant enough to exceed the broad definition of a Balanced and Indigenous Population. In addition to the aforementioned sampling discrepancies on the Pigeon River, there are two additional matters that need to be addressed in future surveys and subsequent reporting. 1) On Page 14, the following citation is used: "NCDENR 2001" (found under Section 2.1 "Habitat Assessment"). On Page 10, there is reference to the use of "Standard Operating Procedures for Benthic Macroinvertebrates (2003) and "Standard Operating Procedures for Biological Monitoring. of Stream Fish Community Assessment and Fish Tissue (2001). The data collected for use in this document were collected in 2012. However, there was a 2006 version of the North Carolina -^/ Iothtng Compares:. State of North Carolina I Environmental Quality / Water Sciences Section 1621 Mail Service Center I Raleigb, North Carolina 27699-1621 919-743-8400 Department of Natural Resources (NCDENR) Standard Operating Procedure (SOP) available for both Benthic Macroinvertebrates and Stream Fish Community Assessment and Fish Tissue and the 2006 versions of these SOPs should have been used in this report. Therefore, the use and citation of NCDENR 2001 is incorrect. It must be noted that future collections and analyses should be conducted using the most current North Carolina Department of Environmental Quality (NCDEQ) SOP. Please contact Eric Reek (eric.fleek(rDncdenr.nov) for the most current versions of the Benthos, Fish IBI, and Fish Tissue Standard Operating Procedures. 2) There are several errors noted in Table 3.1.1-1. For example, Allonarcys biloba is an outdated genus designation having been synonymized with Pteronarcys in 1982 (Stark and Szczytko 1982). In addition, Seratella deficiens was changed to Telagoncpsis deficiens in 2008 (Jacobus and McCafferty 2008), Micrasema barksi is a non-existent species appellation and is an apparent misspelling of Micrasema burksi. In addition, there are no know larval specimens (or keys to their identification) for the larvae Cheumatopsyche pasella (Morse et al., 2017). Furthermore, there are several semi -aquatic Hemiptera listed in Table 3.1.1-1 which are not collected and are not used in the calculation of the North Carolina Biotic Index or in the assigning of bioclassifications in North Carolina (NCDENR 2011). These taxa include the Gerrid Aquarius remigis, the Mesoveliid Mesovelia mulsanti, and the Veliid Rhagovelia obesa. Given the semi -aquatic nature of these taxa, they are not appropriate for use in water quality bioassessments (NCDENR 2011). 3) In the future, and to ensure that this office receives all germane biological and or physical/chemical data for this facility, please either a) mail a copy directly to Eric Fleek (1621 Mail Service Center, Raleigh NC 27699-1621) OR b) email a scanned copy directly to eric.fleek@ncdenr.com. If you have any questions about these issues, please do not hesitate to contact me. Sincerely, 4�. /" Cyndi Karoly Chief, Water Sciences Section cc: Landon Davidson, Asheville Regional Office Julie Grzyb, NCDWR Complex Permitting Unit Sergei Chernikov, NCDWR Complex Permitting Unit References Cited Jacobus, L.M and McCafferty, W.P. 2008. Revision of Ephemerellidae genera (Ephemeroptera). Transactions of the American Entomological Society, pp.185-274. Morse, J. C., W. P. McCafferty, B. P. Stark, and L.M. Jacobus, eds. 2017. Larvae of the Southeastern USA Mayfly, Stonefly, and Caddisfly Species (Ephemeroptera, Plecoptera, and Trichoptera). Biota of South Carolina. Vol. 9. Clemson University Public Service and Agriculture, Clemson University, Clemson, South Carolina, USA. 482 pp. North Carolina Department of Environmental and Natural Resource (NCDENR). 2011. Standard Operating Procedures for the Collection and Analysis of Benthic Macroinvertebrates. Division of Water Resources. Raleigh, North Carolina. December 1, 2011. Stark, B.P. and Szczytko, W.P. 1982. Egg Morphology and Phylogeny in Pteronarcyidae (Plecoptera). Annals of the Entomological Society of America, Volume 75, Issue 5, PP 519-529.