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HomeMy WebLinkAboutNC0000272_All Jan - Apr 2021 Comments_Part 1 V2_20220401From: To: Subject: Date: Stacey W SVC DENR.publiccomments [External] Blue Ridge Paper Products, NC #0000272 Saturday, January 9, 2021 1:57:04 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Blue Ridge Paper Products, NC #0000272 THIS PERMIT IS UNACCEPTABLE • permit does not demonstrate the spirit of the Clean Water ACT NPDES (National Pollution Discharge Elimination System) permitting system in that it does not actually reduce pollution • • • • permit proposes an increase in the amount of chloroform permit calls for a 17% increase in water taken from the Pigeon permit calls for no changes and no reductions in pollution permit calls for removal of the color variance As a concerned citizen and lover of the Pigeon River, I feel it is in the best interest of the public (including both people and publicly held lands), the residential and commercial users of the river, and the natural ecosystems found in the Pigeon River and surrounding watershed areas to have the following addressed concerning Blue Ridge Paper Products, NC #0000272: Keep the color variance until water quality standards are met, and the water is as clear downstream as it is upstream from the paper mill Make no increases to chloroform, a carcinogenic chemical Don't take more water for the paper mill without an environmental assessment Water quality improvements should be made in every 5 year permitting cycle Sincerely, Stacey Whetstone From: To: Subject: Date: Roger Ford SVC DENR.publiccomments [External] Pigeon River Canton N.C. paper mill Saturday, January 9, 2021 9:38:16 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. We raised hell before to protect the Pigeon River and our 225,000 human rafting customers. We will fight this battle if forced to. This River is the livelihood of Hundreds of thousands people we will not stand for any Diminished water quality standards. So help me GOD. Roger Ford 3577 Grassy Fork Rd. Hartford, Tennessee. 37753 rogerfordgrassyfork@gmai 1. com From: To: Subject: Date: Anne McGinn Smith Gurney, Anna [External] No-- to the variance on NPDES RENEWAL NC0000272 Monday, January 11, 2021 6:01:35 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. No-- to the variance on Blue Ridge Paper Products. Anne M Smith From: To: Subject: Date: Steve Cox Gurney, Anna [External] NPDES RENEWAL NC0000272 Monday, January 11, 2021 6:07:31 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Please, No. No to the variance on Blue Ridge Paper Products. Our river is dirty and toxic enough as it is. Thank you. From: Bill Hale To: Gurney, Anna Subject: [External] NO to the Variance on NPDES Renewal NC 0000272 Date: Monday, January 11, 2021 6:50:03 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> NO to the variance on Blue Ridge Paper Products! Sent from my iPhone From: To: Subject: Date: William Woody Gurney Anna [External] No-- to the variance on NPDES RENEWAL NC0000272 Blue Ridge Paper Products Monday, January 11, 2021 7:18:37 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Mrs. Gurney, I am sending this email to offer my opinion on the variance requested by Blue Ridge Paper Products company. The variance needs to be denied. The river in Newport Tennessee still 30 years later is not clean. It's still far from the pristine river it once was. Has it improved, it has, I remember standing on the banks with my father and uncles as we fished watching gobs of white foam floating down past us the smell unimaginable. Yet today, the fish still aren't safe to eat. Dioxin signs are still posted. Mercury signs have recently been added and posted. The water still has a smell that makes it clear that it's not clean and pure. Too much damage was done...we cannot walk it back. We've watched it slowly...ever so slowly get to where it is today. Eagles nesting in the cliffs across from the courthouse in downtown Newport. More wildlife coming in year after year. Cranes, geese, ducks. More fish, larger fish. Why risk undoing that, for a little bit more money in the pocket of the company that destroyed the river to begin with. Choose what's right, Come down visit Newport and it's River Walk. See what an investment in the river does for communities. Don't let them destroy it again. William M. Woody Parrottsville, Tennessee From: To: Subject: Date: Cheryl Vaughn Gurney, Anna [External] Rivers -public comment notice. Monday, January 11, 2021 7:14:39 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. No- to the variance on NPDES RENEWAL NC0000272. No- to the variance on Blue Ridge Paper Products. From: couchx4 To: Gurney, Anna Subject: [External] Date: Monday, January 11, 2021 8:04:47 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. No-- to the variance on NPDES RENEWAL NC0000272. No-- to the variance on Blue Ridge Paper Products. Sent from my Verizon, Samsung Galaxy smartphone From: To: Subject: Date: pttenn@aol.com Gurney, Anna [External] Variance Monday, January 11, 2021 8:30:31 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. No-- to the variance on NPDES RENEWAL NC0000272. No-- to the variance on Blue Ridge Paper Products. Do your job and protect our environment, rivers and streams. Karen Timmerman 258 Co.Rd.227 Cullman, Al. 35057 From: To: Subject: Date: elaine stewart Gurney, Anna [External] NPDES renewal Monday, January 11, 2021 9:35:31 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. A resounding no to the NPDES renewal NC0000272. No to the variance on Blue Ridge paper products. From: JEFF LUSTER To: Gurney, Anna Subject: [External] No-- to the variance on NPDES RENEWAL NC0000272. No-- to the variance on Blue Ridge Paper Products. Date: Monday, January 11, 2021 9:05:30 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spam@nnc.gov> No-- to the variance on NPDES RENEWAL NC0000272. No-- to the variance on Blue Ridge Paper Products. From: melissa ottem To: Gurney Anna Subject: [External] NPDES renewal NC0000272 Date: Monday, January 11, 2021 9:59:35 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> No to the variance on Blue Ridge paper products Thank you, Meliss Sent from my iPhonc From: Mark Bourne To: Gurney, Anna Subject: [External] Blue Ridge Paper Products Date: Monday, January 11, 2021 10:27:40 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Ms. Gurney I am writing in objection to the variance on NPDES RENEWAL NC0000272. No-- to the variance on Blue Ridge Paper Products. Until this company can prove that dioxin does not contribute to the rise in cancer seen in the affected region, we should not be permitting this potential risk for purposes of private parties profit. Mark Bourne 1631 Sequoyah Dr Mooresburg, TN From: To: Subject: Date: Crustal Ottincier SVC DENR.oubliccomments; Smith, Danny; Pouoart, Jeff [External] BRPP"s Discharge Permit- Request to reschedule public hearing scheduled for 1/20/21 Wednesday, January 13, 2021 3:06:19 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. All, Please allow this email to serve as my request that you consider rescheduling the public hearing regarding the Blue Ridge Paper Product Discharge Permit that is currently set for January 20, 2021. As you are aware the proposed date conflicts with Inauguration Day and may not allow for public participation. We respectfully ask that you consider another date that does not conflict. Thank you, Cocke County Mayor 360 East Main Street Courthouse Annex Suite 146 Newport, TN 37821 Phone: 423-623-8791 Email: cottinger@cockecounty.net From: To: Subject: Date: stealthdf2@gmail.com SVC DENR.publiccomments [External] Blue Ridge Paper Products, NC #0000272 Tuesday, January 12, 2021 8:03:45 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Blue Ridge Paper Products, NC #0000272 THIS PERMIT IS UNACCEPTABLE • • • • • permit does not demonstrate the spirit of the Clean Water ACT NPDES (National Pollution Discharge Elimination System) permitting system in that it does not actually reduce pollution permit proposes an increase in the amount of chloroform permit calls for a 17% increase in water taken from the Pigeon permit calls for no changes and no reductions in pollution permit calls for removal of the color variance As a concerned citizen and lover of the Pigeon River, I/we feel it is in the best interest of the public (including both people and publicly held lands), the residential and commercial users of the river, and the natural ecosystems found in the Pigeon River and surrounding watershed areas to have the following addressed concerning Blue Ridge Paper Products, NC #0000272: Keep the color variance until water quality standards are met, and the water is as clear downstream as it is upstream from the paper mill Make no increases to chloroform, a carcinogenic chemical Don't take more water for the paper mill without an environmental assessment Water quality improvements should be made in every 5 year permitting cycle From: olparko©aol.com To: Gurney, Anna; SVC DENR.publiccomments; apharris40Ccagmail.com Subject: [External] Fwd: PUBLIC COMMENTS NC0000272 Date: Wednesday, January 13, 2021 5:10:59 PM Attachments: 2020 BenMaamar-etal Dioxin EnvResearch.pdf pone.0046249.pdf 2018 Nilsson-etal EnvEpig dvy016-1.pdf 2014 ScientificAmerican Article.pdf CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Jan. 13, 2021 TO WHOM IT MAY CONCERN: The emerging science on dioxin is telling us exactly what you have done to the residents of NC - but for my purposes, TN has had enough. History keeps repeating itself with this plant. Did NC DEQ decide that it would yield to political pressure? Shareholder pressure? What would make NC think removing a color variance would help TN? It doesn't. It does nothing at all for us. It just makes you look like you are helping a plant that has long outlived its life expectancy. Are you trying to make it look acceptable? Now we're not taking anymore of your colored water, anymore dioxin, or anymore smell on that river. Would you want to receive TN's deadly garbage for 113 years? Would you like to swap our nuclear water with your dioxin? I am dealing with the NIH on this, and Canton's days of looking good are over. Get it to the state line? And shove it down the river to TN? NO. We're not taking your garbage anymore. We're done. I have engaged a environmental attorney- for this is a bridge too far. I want all of my letters to Anna Gurney- to date- added to the Public Record. I have been here once, 2 decades ago, and I am saddened and stunned that we are here again. All of the downloads herein are to be added to the Public Record. I also request a 45 day extension as my secretary has had to quarantine due to Covid. I am behind schedule. Also in the 2007- Blue Ridge Paper Products Shareholder Annual Report, it says, "International Paper has also agreed to indemnify us for liabilities, including any remediation or additional capital expenditures required by the North Carolina Department of Health. Environment and Natural Resources, associated specifically with the seepage of dark colored materials from the Canton Mill into the northern banks of the Pigeon River that occurred prior to May 14, 1999. International Paper's indemnity for the liabilities associated with the seepage from the Canton Mill does not have a going -forward time limit and is not subject to any dollar amount threshold or aggregate dollar limit." Ding. Ding. Ding. Please tell me more. What is the seepage? Exactly? Has it been dealt with? If so, when? I do not find it in your , "ABTCP, HPD, PULP AND PAPER MINIMIZATION TECHNOLOGY REVIEW," dated 2002." Where would I find information on that "seepage?" Was the seepage dealt with? If so, who was the Engineering Firm that dealt with it? I will require those documents. Further, I note that per the 2020 shareholder report this company is not doing financially well. Did NC decide to help them further? I also bought some stock yesterday so that I might have are a real voice here. Money money money. Does NC really wish to continue this abuse on the backs of Tennesseans? We've had enough of that. And scientific studies are showing the abuse is stunning. See also Abstract I sent to Anna Gurney. I look forward to timely and meaningful answers to my questions. Most specifically - the "seepage." The environmental choices we make today determine the future of this planet and NC has had it's way with TN for far too long. New science shows the damage done. And that damage is irreparable. Ms. Park Overall 1374 Ripley Island Rd. Afton, TN 37616 All attachments above and this letter below from Dr. Skinner are to be added to the Public Record. Tue, Jan 12, 2021 3:40 pm Subject: Re: Dioxin help Dear Ms Overall Thanks for the email and information on your dioxin activity in Tennessee. I have enclosed in addition to our initial 2012 paper a recent paper to identify disease biomarkers after ancestral dioxin exposure. Also a review article on the epigenetic transgenerational inheritance impacts of toxicants like dioxin. I am a research scientist that specialized in a new non -genetic form of inheritance we have identified where environmental factors can impact your sperm or eggs to then pass on information to subsequent generations to increase disease susceptibility. So what your grandparents were exposed to will impact your disease, even know you have never seen the exposure, and you will pass this on to your great grandchildren. This is very different from the direct exposure toxicology we generally think of and test for by the states and EPA. A Scientific American review for this is enclosed as well for you reference. You can get more information at www.skinner.wsu.edu under public and press. In regards to your dioxin work, I am afraid most of the damage has been done and now we are determining what we can do about this for future generations. Stopping any further contamination will be critical. So testing the fish which if injected will be primary source of dioxin, as is found in the great lake populations. There the levels are high enough to have toxic effects after fish consumption. So one of the issue is you need to determine how good the testing has been in Tennessee to confirm negligible fish levels of dioxin. Multiple testing sources, not just EPA, would be suggested. In regards to industry contamination today, again the water levels need to be assessed accurately, and if present then you case is very strong. There are private testing firms that can help confirm or refute the EPA results as needed. Since humans are exposed to hundreds of different compounds and exposures daily, it is very difficult to clearly state a specific compound is the source of any disease or pathology within the population. So focusing on known contamination sites and water or food sources that have contamination is best to get results to deter industry and reduce exposures. I hope that helps and good luck with your efforts. Let me know if you have questions. Michael Skinner Michael Skinner, PhD Eastlick Distinguished Professor Founding Director Center for Reproductive Biology School of Biological Sciences Washington State University Pullman WA 509-335-1524 www.skinner.wsu.edu From: "olparko@aol.com" <olparko@aol.com> Reply -To: "olparko@aol.com" <olparko@aol.com> Date: Tuesday, January 12, 2021 at 10:12 AM To: "Skinner, Michael K" <skinner@wsu.edu> Subject: Dioxin help Environmental Research 192 (2021) 110279 E (,T- TT T'n Contents lists available at ScienceDirect Environmental Research journal homepage: www.elsevier.com/locate/envres ri Transgenerational disease specific epigenetic sperm biomarkers after ancestral exposure to dioxin Millissia Ben Maamar, Eric Nilsson, Jennifer L.M. Thorson, Daniel Beck, Michael K. Skinner Center for Reproductive Biology, School of Biological Sciences, Washington State University, Pullman, WA, 99164-4236, USA ARTICLE INFO Keywords: EWAS Epigenetics Transgenerational DNA Methylation Sperm Dioxin TCDD Prostate Kidney Obesity Testis Pathology ABSTRACT Dioxin was historically one of the most common industrial contaminants with several major industry accidents, as well as governmental actions involving military service, having exposed large numbers of the worldwide population over the past century. Previous rat studies have demonstrated the ability of dioxin (2,3,7,8-tetra- chlorodibenzo-p-dioxin (TCDD)) exposure to promote the epigenetic transgenerational inheritance of disease susceptibility in subsequent generations. The types of disease previously observed include puberty abnormalities, testis, ovary, kidney, prostate and obesity pathologies. The current study was designed to use an epigenome-wide association study (EWAS) to identify potential sperm DNA methylation biomarkers for specific transgenerational diseases. Therefore, the transgenerational F3 generation dioxin lineage male rats with and without a specific disease were compared to identify differential DNA methylation regions (DMRs) as biomarkers for disease. The genomic features of the disease -specific DMRs were characterized. Observations demonstrate that disease - specific epimutation DMRs exist for the transgenerational dioxin lineage rats that can potentially be used as epigenetic biomarkers for testis, kidney, prostate and obesity diseases. These disease -specific DMRs were asso- ciated with genes that have previously been shown to be linked with the specific diseases. This EWAS for transgenerational disease identified potential epigenetic biomarkers and provides the proof of concept of the potential to develop similar biomarkers for humans to diagnose disease susceptibilities and facilitate preventa- tive medicine. 1. Introduction Agent Orange was an herbicide/defoliant sprayed across Vietnam and Southeast Asia by the US Air Force during the Vietnam War. The most toxic byproduct contaminant present in Agent Orange was dioxin — 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) (IOM, 2020; National Academies of Sciences, 2018). The soldiers handling this chemical were heavily exposed and thus at risk for exposure to TCDD. In addition, dioxin (TCDD) is a common pollutant from industry in most urban areas. Several major industrial accidents have occurred where the general populations were exposed (Eskenazi et al., 2004; Ni et al., 2010). Dioxins are extremely lipophilic and persist in both the exposed individuals and the environment. The half-life of TCDD in the human body has been estimated to range from 7 to 11 years (IOM, 2020; National Academies of Sciences, 2018). In rodents, TCDD has a half-life of weeks to years and can cause liver disease, weight loss, thymic atrophy and immune sup- pression (Birnbaum and Tuomisto, 2000; Grassman et al., 1998). In humans, direct exposure to TCDD can influence chronic diseases such as * Corresponding author. E-mail address: skinner@wsu.edu (M.K. Skinner). lymphomas and leukemias (Spaulding, 2011). Vietnam officials re- ported around 400,000 people killed or maimed, and 500,000 children born with birth defects after being exposed to Agent Orange (York and Mick, 2008). Prostate cancer, multiple myeloma, type II diabetes, and spina bifida in children were reported to be associated with Agent Or- ange exposure (M and Veterans and Agent 0, 2010). TCDD exposure happened not only in Vietnam. In the 1970s, Italy, China and Taiwan had industrial accidents that exposed populations to TCDD (Eskenazi et al., 2004; Ni et al., 2010; Guo et al., 2000). Various human exposures to TCDD have been documented and associated with a large number of different diseases (Igarashi et al., 2005; Resuehr et al., 2012; Bruner-- Tran and Osteen, 2010). The Developmental Origins of Health and Disease (DOHaD) paradigm is an expanding field of research focusing on the effects of chemical exposures such as dioxin on early -life develop- ment and the propagation of non -communicable disease into adulthood (Haugen et al., 2015). However, the majority of these epidemiology studies have focused on direct adult and fetal exposures (Carpenter, 2006). In the Seveso Italy population, health effects in the grandchildren https://doi.org/10.1016/j.envres.2020.110279 Received 31 July 2020; Received in revised form 24 September 2020; Accepted 25 September 2020 Available online 8 October 2020 0013-9351/© 2020 The Author(s). Published by Elsevier Inc. This is an open access article under the CC BY -NC -ND license miry:/ reanvecommom org/Nce.esNy-ncnd/4.Cq. M. Ben Maamar et aL Environmental Research 192 (2021) 110279 have been shown, even three decades after the dioxin exposure (Bac- carelli et al., 2008). In addition to health effects of direct parental ex- posures on the offspring, a number of studies have been conducted on the health consequences of ancestral exposures in future generations. The biological mechanism underlying these phenomena are epige- netic transgenerational inheritance processes, a form of non -genetic inheritance (Anway et al., 2005). Epigenetics is defined as molecular factors or processes around DNA that regulate genome activity, inde- pendent of DNA sequence, and are mitotically stable (Nilsson et al., 2018a). Epigenetic transgenerational inheritance involves the trans- mission of an altered epigenome and phenotypes through the germline across generations in the absence of continued direct environmental exposures (Anway et al., 2005; Skinner et al., 2010). During fetal development, the primordial germ cells (PGCs) undergo DNA deme- thylation and then upon gonadal sex determination a remethylation in a sex specific manner in order to generate the sperm or egg (Reik et al., 2001). Environmental exposures during this period of development can alter the reprogramming of germline epigenetics, and sometimes the altered DNA methylation appears to become permanently programmed, similar to the DNA methylation of an imprinted gene (Nilsson et al., 2018a; Guerrero-Bosagna et al., 2010). The epigenetic changes are propagated from the male and female germline to the zygote, and sub- sequently to the embryo stem cells and subsequently all somatic cells, which then will result in an altered epigenome and transcriptome in the subsequent generations (Nilsson et al., 2018a). Various environmental exposures such as nutrition, stress and chemical insults have been shown to promote the epigenetic transgenerational inheritance of adult onset disease in a wide variety of organisms from plants to humans (Nilsson et al., 2018a). These epigenetic changes could be used as potential biomarkers of exposure and disease (Manikkam et al., 2012a). Epige- netic molecular processes involve DNA methylation, histone modifica- tions, non -coding RNA, chromatin structure, and RNA methylation (Nilsson et al., 2018a). A variety of environmental exposures and toxi- cants have been shown to promote the epigenetic transgenerational inheritance of disease (Anway et al., 2005; Guerrero-Bosagna et al., 2010; McBirney et al., 2017; Anway and Skinner, 2008; Manikkam et al., 2012b, 2013). Recent studies have demonstrated that ancestral envi- ronmental exposures promote the concurrent alterations of three different epimutations in sperm involving differential DNA methylated regions (DMRs), differential histone retention sites (DHRs) and ncRNA (Ben Maamar et al., 2018; Skinner et al., 2018). The agricultural fungicide vinclozolin (Nilsson et al., 2018b; Stouder and Paoloni-Giacobino, 2010), pesticide DDT (dichloro-diphenyl-trichloro- ethane) (King et al., 2019; Skinner et al., 2013), herbicide atrazine (McBirney et al., 2017), and herbicide glyphosate (Ben Maamar et al., 2020) have all been shown to promote the epigenetic transgenerational inheritance of disease. In addition, the pathologies observed appear to be associated with unique epigenetic signatures of DMRs (McBirney et al., 2017; Nilsson et al., 2018b; King et al., 2019). The current study investigates DMRs in association with specific transgenerational diseases. In previous studies, we have shown that dioxin (i.e., TCDD) was able to promote epigenetic transgenerational inheritance of disease and DNA methylation epimutations in sperm (Manikkam et al., 2012c; Nilsson et al., 2012). When the Fl generation offspring directly exposed in utero were studied at one year of age, they were found to have a higher incidence of prostate disease in the males, primordial follicle loss in the females and polycystic ovarian disease compared to the control lineage (Manikkam et al., 2012c). The subsequent F3 generation great -grand offspring not directly exposed also appeared to have a significant in- crease in the frequency of male kidney disease, primordial follicle loss, polycystic ovarian disease, and female multiple disease compared to the control lineage (Manikkam et al., 2012c). As previously described, dioxin was found to promote major pathology through both direct exposure and ancestral exposure. These results are relevant to the human population since more data are accumulating on the health consequences of ancestral exposures to dioxin in future generations (Manikkam et al., 2012c; Nilsson et al., 2012; Bruner-Tran et al., 2014; Ding et al., 2018). Understanding the biological mechanisms underlying this toxicant exposure induced transgenerational epigenetic inheritance is further investigated in the current study. The potent and persistent environmental contaminants such as dioxins should be major environ- mental concerns today for human health (Contam et al., 2018). Dioxin -induced alterations have been shown to be transmitted to the subsequent generations through the male germline to influence pri- mordial germ cells reprogramming, which is a significant developmental window for disease susceptibility (Manikkam et al., 2012a, 2012c; Bruner-Tran et al., 2014, 2017; Pilsner et al., 2017). Individual animals were studied, and the specific pathologies in these transgenerational model systems were associated with specific epigenetic signatures (i.e., DMRs) for each toxicant exposure. Disease specific DMRs were identified for a number of these transgenerational pathologies, which shows that the establishment of an epigenetic biomarker for a specific disease and exposure is possible (McBirney et al., 2017; King et al., 2019; Ben Maamar et al., 2020). Although our previous study identified the ability of dioxin to promote the epigenetic transgenerational inheritance of pathologies and sperm epigenetic al- terations in the transgenerational F3 generation (Manikkam et al., 2012c), the potential that disease -specific epigenetic biomarkers exist has not been investigated. The current study provides evidence that these DMRs can be used as epigenetic disease specific biomarkers after an ancestral exposure to dioxin. 2. Results 2.1. Animal breeding As previously described (Manikkam et al., 2012c), FO generation outbred Sprague Dawley female rats were administered daily intraper- itoneal injections of dioxin (TCDD 100 ng/kg BW/day) or dimethyl sulfoxide (vehicle control) during embryonic days E8-E14 of gestation (Manikkam et al., 2012c). The lowest observable adverse effects level (LOAEL) is 160 ng/kg/BW (Greene et al., 2003). Therefore, the exposure used in the current study is a low exposure level. The intraperitoneal exposure was used to better control the exposure dose as compared to oral administration. The F3 generation is the first not directly exposed, thus called the transgenerational generation. All the animals were aged to 1 year and then euthanized by CO2 inhalation and cervical dislocation for pathology and sperm epigenetic analyses (Manikkam et al., 2012c). No sibling or cousin breeding was used to prevent any inbreeding arti- facts in the control or dioxin lineages. All protocols and studies were approved by the Washington State University Animal Care and Use Committee (protocol IACUC # 6252). 2.2. Pathology analysis The archived pathology slides from the previous study (Manikkam et al., 2012c) were used to reanalyze the pathology with more advanced digital pathology procedures. Images of the different pathology histol- ogies have been previously reported (Manikkam et al., 2012c). Pathol- ogy analysis was performed by analyzing digitally captured images of histology sections of testis, kidney, and prostate. Two individuals blin- ded to exposure evaluated each tissue image for abnormalities. If there was disagreement about disease status, then a third individual blinded to exposure evaluated the tissue, as described in the Supplemental Methods. The disease parameters were identified and quantified, as previously described (McBirney et al., 2017; Nilsson et al., 2018b; King et al., 2019; Kubsad et al., 2019). The various tissue histological pa- rameters used to identify pathology are outlined in the Methods, as well as other pathology conditions. For the F3 generation dioxin lineage male pathology, the individual animals are listed with a (+) that indicates presence of disease/pathology and a (—) that indicates the absence of 2 M. Ben Maamar et aL Environmental Research 192 (2021) 110279 disease (Table 1). To assess a statistical alteration in the dioxin lineage pathology, a comparison with the control lineage involving a vehicle exposure was analyzed for pathology as presented in Supplemental Table Sl. The control animal lineage had minimal disease. For a specific pathology, individuals were only selected for epigenetic analysis if they had that single pathology. Animals with multiple diseases (>>2) were identified, but only one animal had multiple disease, so no further analysis of this was performed. This strategy allows for a more accurate association with epimutations and eliminates the confounding presence of other diseases. The dioxin induced transgenerational dis- eases/pathologies that had sufficient numbers of animals was prostate disease (3 males), kidney disease (6 males), obesity (4 males), and testis disease (8 males), Table 1. These individuals were used to investigate the sperm disease epigenetic biomarkers. 2.3. Sperm DNA methylation analysis The archived sperm samples maintained at —80 °C from the previous study (Manikkam et al., 2012c) were used to reanalyze the epigenetics with more advanced MeDIP-Seq technology than the tiling arrays pre- viously used (Manikkam et al., 2012c) on individual animals with spe- cific disease. Sperm samples were collected from the dioxin lineage F3 generation individual males for epigenetic analysis. Within the dioxin lineage, individual males with no disease were compared to individuals with a single specific disease (testis, prostate, kidney, or obesity) in order to determine the disease specific differential DNA methylation regions (DMRs) (Fig. 1A—D). This eliminates the confounding effects of multiple disease and allows disease specific biomarkers to be identified. The sperm samples were collected, then the DNA extracted, frag- mented and the methylated DNA immunoprecipitated (MeDIP) using a methyl -cytosine antibody (Ben Maamar et al., 2018; Skinner et al., Table 1 Dioxin transgenerational pathology. F3 generation dioxin lineage male rat pathology. The individual animals for the dioxin lineage males are listed and a (+) indicates presence of disease and (—) absence of disease. The animals with shaded (+) or (0) were used for the epigenetic analysis due to the presence of only one disease, except for the multiple (>2) disease or no disease (0). The n/a indicates not analyzed and the totals provide the ratio of diseased/total an- imals, and % disease. Molecular ID Late Puberty Testis Disease Prostate Disease Kidney Disease Obesity Tumor Multiple Disease Total Disease DX14 - - + + - - + 2 DX9 - - - - - - - 0 DX10 - - - - - - - 0 DX11 - -rmi - - - - - 1 DX12 - - - - - - - 0 DX13 - - - + - - - 1 DX1 - - - + - - - 1 DX2 + jill - - - - - - 1 DX4 - - - - - - 1 DX5 - - - - - - - 0 DX6 - - - - - - - 0 DX7 - - - - + - - 1 DX8 - - - - - - - 0 DX18 - - - - + - - 1 DX15 - 1 DX16 - 1 DX25 - - - - + - - 1 DX26 - - - - - - - 0 DX27 - - - - - - - 0 DX28 - - - - - - - 0 DX29 - - - 0 DX34 - - - 1 DX35 - - - - - - - 0 DX30 - - - - - - - 0 DX31 - - - - - - - 0 DX32 - - n/a - - - - n/a DX33 - - - - 1 DX - - - - - - 1 DX19 - - - - - - 1 DX20 - - - - - - - 0 DX22 - + - - - - - 1 DX23 - - + - - - - 1 DX24 - + - - - - - 1 DX41 - + - - - - - 1 DX42 - - - - - - 1 DX43 - - - - - - - 0 DX40 - - - + - - - 1 DX36 - - - - - - - 0 DX37 - - - - - - - 0 DX38 - - - - - - - 0 DX39 - 0 DX53 - - - 1 DX50 - - - - - - 1 DX51 - - - + - - - 1 DX52 - - - - - - - 0 DX44 - - - - - - - 0 DX45 - - - - - - - 0 DX46 + - - - - - - 1 DX47 - - - - - - - 0 DX48 - - - - - - - 0 DX49 - - + - - - - 1 Totals 2/51 = 4% 8/51 = 16% 5/50 = 10% 8/51 = 16% 4/51 = 8% 0/51 = 0% 1/51 = 2% 3 M. Ben Maamar et aL Environmental Research 192 (2021) 110279 DMR Identification A Prostate Disease DMR Biomarkers p-value 0.001 le-04 le-05 le-06 le-07 All Window 1211 177 19 6 0 Multiple Window 3 0 0 0 0 Significant windows (p<1 e-04) 1 Number of DMR 177 C Obesity Disease DMR Biomarkers p-value 0.001 le-04 le-05 le-06 le-07 All Window 1192 165 26 5 1 Multiple Window 2 0 0 0 0 Significant windows (p<1 e-04) 1 Number of DMR 165 B Kidney Disease DMR Biomarkers p-value All Window 0.001 1030 le-04 130 le-05 19 le-06 5 le-07 1 Multiple Window 1 0 0 0 0 Significant windows (p<1 e-04) 1 Number of DMR 130 D Testis Disease DMR Biomarkers p-value 0.001 le-04 le-05 le-06 le-07 All Window 959 123 15 3 2 Multiple Window 0 0 0 0 0 Significant windows (p<1 a-04) 1 Number of DMR 123 Fig. 1. DMR identification and numbers. The number of DMRs found using different p-value cutoff thresholds. The All Window column shows all DMRs. The Multiple Window column shows the number of DMRs containing at least two significant windows (1 kb each). The number of DMRs with the number of significant windows (1 kb per window) at a p-value threshold p < le-04 for DMR. (A) Prostate disease DMRs; (B) Kidney disease DMRs; (C) Obesity disease DMRs; and (D) Testis disease DMRs. 2018). The methylated DNA fragments were sequenced for an MeDIP-Seq analysis, as described in the Supplemental Methods section (Guerrero-Bosagna et al., 2010; Ben Maamar et al., 2018; Skinner et al., 2018). The DMR numbers are listed in Fig. 1 for different edgeR statis- tical p-value cutoff thresholds, and p < le-04 (diseased versus non -diseased) were selected as the threshold for all subsequent analyses. The total number of DMRs (All Windows) if present for each disease and multiple neighboring 1000 bp windows (Multiple Window) are shown (Fig. 1). In our previous study, the reported transgenerational F3 generation sperm dioxin versus control lineage DMRs used three pools of different animals to determine the dioxin induced sperm DNA epimutations with tiling arrays (Manikkam et al., 2012c). In the current study, individual animals were used to identify the transgenerational F3 generation dioxin induced disease sperm DMR epimutations with MeDIP-Seq. With an edgeR p < 1e-04, 177 DMRs were identified for the animals with pros- tate disease (Fig. 1A). The animals with kidney disease had 130 DMRs (Fig. 1B). The obesity disease group was found to have 165 DMRs (Fig. 1C). The animals showing testis disease had 123 DMRs (Fig. 1D). None of these different groups displayed any DMRs with multiple neighboring 1000 bp windows (Fig. 1A—D). In conclusion, the different diseases had altered DNA methylation in the F3 generation sperm at a p < 1e-04. The disease specific DMRs with an edgeR p < 1e-04 threshold are presented in Supplemental Tables S2—S5. The log -fold change in DNA methylation is presented and an increase in methylation was associated with 40% of the testis disease DMRs, 47% of the prostate disease DMRs, 42% of the kidney disease DMRs, and 35% of the obesity DMRs. The others all had a decrease in DNA methylation. The disease specific DMR chromosomal locations are presented in Fig. 2 where the DMR locations are represented by red arrowheads, and DMR clusters by black boxes. The prostate, kidney, obesity and testis disease biomarkers did not have any DMRs on the Y chromosome or the mitochondrial DNA (MT). Therefore, the DMRs were identified on nearly all chromosomes. DMR length and CpG density are shown in Fig. 3. The CpG density of the DMRs for all comparisons was 1-4 CpG per 100 bp being predominant, which is characteristic of a low -density CpG desert. These observations were similar to our past studies with other ancestral exposures (Manikkam et al., 2012c). The DMR lengths for each disease biomarker were 1-4 kb with 1 kb being predominant, Fig. 3. In general, the DMRs are 1 kb in size with around 10 CpGs, as previously reported (Skinner and Guerrero-Bosagna, 2014). The DMR genomic features and chromosomal locations are presented in Supplemental Tables S2—S5. For the different disease DMR biomarker comparisons with non -disease (prostate disease DMRs, kidney disease DMRs, obesity disease DMRs, and testis disease DMRs), a principal component analysis (PCA) demonstrates a clustered separation of the prostate, kidney, obesity, and testis disease samples compared to the non -disease based on read depth at DMR sites (Supplemental Fig. S1). The PCA on DMR sites was performed to assess the potential presence of any outlier samples, of which none were observed. Therefore, the disease samples were distinct from the non -disease samples for each of the pathologies when consid- ering read depth at DMR sites. To compare and identify overlapping DMRs for each disease (testis, prostate, kidney and obesity), a Venn diagram of chromosomal location overlaps at the p < le-04 threshold was used (Fig. 4A). Negligible overlap is observed at the p-value (p < le-04) threshold between the differential transgenerational DMR disease sites. This overlap analysis was further investigated with an extended overlap of the p < 1e-04 DMRs. The DMRs with p < 1 e-04 were compared to DMRs with p < 0.05 statistical threshold to allow for an increased potential to identify overlaps when a less stringent p-value was used. In all the comparisons, between 8 and 17% overlaps were observed for each comparison, Fig. 4B. An overlap of the disease -specific DMRs with a p < 0.05 is shown in Fig. 4C. The total number of DMRs is dramatically increased at this lower statistical threshold. Only 63 DMRs had an overlap with all diseases at p < 0.05, Fig. 4C. These 63 overlapping p < 0.05 DMRs were compared to the p < 1e-04 disease specific DMRs and few overlapping DMRs were identified, Fig. 4D. Therefore, no overlapping group of DMRs for all diseases was identified, but some overlap is observed be- tween comparisons of two diseases. Observations indicate that the DMRs identified are primarily specific to one disease/pathology, but approxi- mately 15-25 DMR overlapped at the reduced statistical threshold for 4 M. Ben Maamar et aL Environmental Research 192 (2021) 110279 DMR Chromosomal Locations A DMR Prostate Disease Biomarker Chromosome MT - Y - X 20 - 19 - 18 17 - 16 - 15 - 14 - 13 - 12 - 11 - 10 - 9- 8 - 7- 6 - 5 - 4 3 2 1 wwV T WWT•W T • • • TT •Tw T• w • • • T• • • T • • •T i• Tw W • • w• 7••• T w• • • • • wwTw w T • • w • T W T•• T •w w• • • • • •• w •• •T•w T •• • • •• • • • w • ••T• •T ••.. w• • • T!w • w •T •• 'CO N f0 0 O N `.2N Y N P. 2 N N .7n 2 N O �0 1� OD ' N N N N Chromosome length (Mb) C DMR Obesity Disease Biomarker Chromosome MT - Y - X 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 • W •TT ••• • w • Tw w T • •• • v r T• T • • • w • •• • •••••WW • w • • w • • •T••• • w • ••• • t• • • • •••• •T• w • TT • •T •• w w w T• T • T Tw. T•w •••• T •• • T • • ••• •• T • T • • • • • O c7 a d ro�pp OD W '1 lV O N On aD 2 c N v N c0 N V �0 Of N N N N N N Chromosome length (Mb) B DMR Kidney Disease Biomarker Chromosome MT - Y - X 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 v 3L_TV w • R ••• T• •T A T •• ♦ • • • • W T •.• ••• w• • • w • • •wT•• • • • • • T•• • • w• • •• • • T m • • • w • •• • • • • • •• •• •• • •• • w• • •• r• • • T • •• •• III I I I I I I I I I I I III I O a m N t0 P. O W N O 2 P (0 2 NN N O 4 N 4i �0 P. LO N N Chromosome length (Mb) D DMR Testis Disease Biomarker Chromosome MT - Y - X - 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 • • • • • • T • • • • • • • • T• • w • •T •• ••V1 TV • W w ••• ♦ •• • • ••• W • • •• •• w ww • •w • T • •• ••T • •• • • R N N TV • • • • w •TT, TTW • • •• T • w •w T O-. (.1 O cc! N N A M 1N V w 0 W 01 CO N 0 4 m N t0 O 01 tV W NNNN N O ,0 Chromosome length (Mb) W N N Fig. 2. DMR chromosomal locations. The DMR locations on the individual chromosomes is represented with an arrowhead and a cluster of DMRs with a black box. All DMRs containing at least one significant window at the selected p-value p < le-04 threshold are shown. The chromosome number and size of the chromosome (megabase) are presented. (A) Prostate disease DMRs; (B) Kidney disease DMRs; (C) Obesity disease DMRs; and (D) Testis disease DMRs. specific disease comparisons. 2.4. DMR gene associations Genes associated with the DMRs were identified for each disease specific DMR data set. The DMRs with a gene within 10 kb distance, in order to include promoters, were determined as well as the associated genes and gene functional categories (Supplemental Tables S2-S5). The DMRs with a p < 1e-04 were used for this analysis on the different diseases. For all the different disease specific DMRs approximately 50% had gene associations. The DMR associated gene categories demon- strated several relevant gene categories such as signaling, metabolism, transcription, receptor and cytoskeleton for all the different disease DMR signatures, Fig. 5A. A cellular KEGG pathway analysis was con- ducted to determine the associated genes for each DMR data set, as described in the Supplemental Methods. The top ten pathways with associated genes are presented, Fig. 5B. The cellular pathways identified also had signaling and critical cellular processes involved. Potential dioxin transgenerational disease specific DMR associated genes were analyzed for genes previously shown to associate with the 5 M. Ben Maamar et aL Environmental Research 192 (2021) 110279 DMR Genomic Features A Prostate Disease DMR CpG Density Number of DMR 0- O 1 I 1 0 2 3 4 5 6 7 8 9 210 Number of CpG sites per 100bp B Prostate Disease DMR Length N - O Q O 0 E z' o 2 3 4 5 6 7 6 9 210 DMR length (kb) D Kidney Disease DMR Length E Obesity Disease DMR CpG Density Number of DMR O' 2 3 4 6 6 7 6 9 210 DMR length (kb) G Testis Disease DMR CpG Density 0 2 3 4 6 6 7 6 9 210 Number of CpG sites per 100bp 0 2 3 4 5 6 7 8 9 210 Number of CpG sites per 100bp H Testis Disease DMR Length 0 2 3 4 5 6 7 8 9 210 DMR length (kb) C Kidney Disease DMR CpG Density cc g 2 O O E z i I I 0 2 3 4 6 6 7 6 9 210 Number of CpG sites per 100bp F Obesity Disease DMR Length 0 1 2 3 4 5 6 7 6 9 210 DMR length (kb) Fig. 3. DMR genomic features. The number of DMRs at different CpG densities. All DMRs at a p-value threshold of p < le-04 are shown. (A) Prostate disease DMR CpG density; (B) Prostate disease DMR length; (C) Kidney disease DMR CpG density; (D) Kidney disease DMR length; (E) Obesity disease DMR CpG density; (F) Obesity disease DMR length; (G) Testis disease DMR CpG density; (H) Testis disease DMR length. specific diseases, Figs. 6 and 7. The prostate disease DMR associated genes had a number of genes linked to prostate physiology and some linked to subfertility, Fig. 6A. The kidney disease DMR associated genes had a large number of genes linked to kidney physiology and disease and some linked to kidney hypocalciuria, Fig. 6B. The obesity DMR associ- ated genes had a number of genes linked to obesity and some associated with diabetes and insulin resistance, Fig. 7A. The testis disease DMR associated genes had a number of genes linked to testis physiology and male infertility, Fig. 7B. 3. Discussion Humans and other animals are exposed to a wide array of man-made toxicants. Many of them act as environmental toxicants or endocrine disruptors that can exhibit differential effects across the lifespan (Bru- ner-Tran et al., 2017). Various human exposures to dioxin (TCDD) have been documented and associated with a large number of different dis- eases and pathologies. However, the majority of these epidemiology studies have focused on direct adult and fetal exposures (Carpenter, 2006). Despite having thousands of man-made substances released into our environment each year, prospective risk assessment studies of these potentially harmful chemicals on human health are often not required by current regulations (Melnick et al., 2002). Human toxicant exposures have also been associated with military service. During the Vietnam War (1964-1975), thousands of pounds of Agent Orange, a highly toxic herbicide and defoliant, were sprayed by the U.S. military over large areas of dense jungles in south and central Vietnam to destroy the ground cover it provided to enemy troops (Lewis, 6 M. Ben Maamar et al. Environmental Research 192 (2021) 110279 A Venn Diagram of Specific Disease Overlapping Epimutations p<1 e-04 Kidney Disease DMRs Testis Disease DMRs Obesity DMRs Prostate Disease DMRs B Extended Overlap Disease DMRs p<0.05 p<1e-04 Dioxin Testis Dioxin Prostate Dioxin Kidney Dioxin Obesity Dioxin Testis 123 (100.0%) 17 (13.8%) 20 (16.3%) 15 (12.2%) Dioxin Prostate 15 (8.5%) 177 (100.0%) 25 (14.1%) 16 (9.0%) Dioxin Kidney 20 (15.4%) 19 (14.6%) 130 (100.0%) 18 (13.8%) Dioxin Obesity 21 (12.7%) 24 (14.5%) 29 (17.6%) 165 (100.0%) C Venn Overlap Disease DMRs p<0.05 Kidney Disease DMRs p<0.05 Testis Disease DMRs p<0.05 �31846 Obesity DMRs p<0.05 D Venn Overlap Disease DMRs p1e-04 versus p<0.05 All Disease Overlap Testis Disease p<1 e-04 Prostate Disease DMRs p<0.05 Prostate Diseas p<1e-04 \129 Kidney Disease p<1e-04 p<0.05 Overlaps (All Disease) Obesity p<1 e-04 Fig. 4. Overlap of disease DMRs. (A) Overlap of specific disease overlap epimutations p < le-04. Venn diagram overlap analysis for specific disease states. (B) An extended overlap of disease DMRs. The p-value data set at p < 1e-04 is compared to the p < 0.05 data to identify potential overlap between the different pathologies with DMR number and percentage of the total presented. The gray highlight is the expected 100% overlap. (C) Overlap of the different disease DMRs at p < 0.05. The Venn diagram identified 63 DMRs at p < 0.05 in common between the different diseases. (D) Venn diagram overlap of the different diseases DMRs at p < 1e-04 with the 63 common overlapping p < 0.05 DMRs. 2006). An estimated 1.5 million American servicemen are believed to have been exposed to dioxin as a consequence of Operation Ranch Hand. Some of these veterans reported skin rashes (chloracne), cancer, psy- chological symptoms, birth defects in their children, and other health issues (IOM, 2020). Agriculture crops and inhabited villages were also sprayed, resulting in the exposure of Vietnamese residents. Many of them continue to experience a wide range of health issues including high incidence of early pregnancy loss, congenital birth defects and serious health problems, such as cancers, in surviving children (Schecter et al., 2002a, 2002b; Anh et al., 2014; Nghi et al., 2015; Tai et al., 2013). Since transgenerational inheritance of these detrimental health ef- fects or diseases to subsequent generations can occur, the populations 7 M. Ben Maamar et al. Environmental Research 192 (2021) 110279 Disease DMR Associated Gene A DMR Associated Gene Categories Signaling Metabolism Transcription Receptor Unknown Cytoskeleton Transport Development Immune Epigenetic Growth Factors & Cytokines Extracellular Matrix Protease Apoptosis Translation Golgi Cell Junction Cell Cycle Binding Protein Protein Binding DNA Repair Proteolysis Hormone ■ dioxin.testes El dioxin.prostate O dioxin.kidney O dioxin.obesity I I I I 0 10 20 30 40 50 DMR Number Dioxin Prostate Disease p<le-04 rno05165 Human papillomavirus infection (9) rno05166 Human T-cell leukemia virus 1 infection (6) rno04144 Endocytosis (6) rno04218 Cellular senescence (5) rno04390 Hippo signaling pathway (5) rno04145 Phagosome (5) rno05170 Human immunodeficiency virus 1 infection (5) rno05169 Epstein -Barr virus infection (5) rno05203 Viral carcinogenesis (5) rno05163 Human cytomegalovirus infection (5) Dioxin Kidney Disease p<le-04 rno01100 Metabolic pathways (8) rno04810 Regulation of actin cytoskeleton (3) rno04080 Neuroactive ligand-receptor interaction (2) rno04970 Salivary secretion (2) rno05032 Morphine addiction (2) rno04742 Taste transduction (2) rno05166 Human T-cell leukemia virus 1 infection (2) rno04120 Ubiquitin mediated proteolysis (2) rno04727 GABAergic synapse (2) rno04360 Axon guidance (2) Dioxin Obesity p<le-04 rno01100 Metabolic pathways (11) rno04350 TGF-beta signaling pathway (3) rno04514 Cell adhesion molecules (CAMs) (3) rno05165 Human papillomavirus infection (2) rno05225 Hepatocellular carcinoma (2) rno05016 Huntington disease (2) rno04976 Bile secretion (2) rno04071 Sphingolipid signaling pathway (2) rno05206 MicroRNAs in cancer (2) rno04080 Neuroactive ligand-receptor interaction (2) Dioxin Testis Disease p<le-04 rno01100 Metabolic pathways (4) rno04151 PI3K-Akt signaling pathway (4) rno04015 Rap1 signaling pathway (4) rno04928 Parathyroid hormone synthesis, secretion and action (3) rno05200 Pathways in cancer (3) rno04072 Phospholipase D signaling pathway (3) rno04010 MAPK signaling pathway (3) rno04014 Ras signaling pathway (3) rno05218 Melanoma (2) rno04921 Oxytocin signaling pathway (2) Fig. 5. Disease DMR associated gene categories. (A) DMR associated gene categories. The different gene categories and number of DMRs in each category is pre- sented with a legend indicating the different disease DMR sets. (B) KEGG pathways for the different disease DMR associated genes. The top ten pathways with the number of associated genes in brackets are presented. present today that were ancestrally exposed to dioxin (TCDD) is of critical relevance. Dioxin exposure has been linked in the past to epigenetic modifications in rats (Manikkam et al., 2012a, 2012c; Nilsson et al., 2012; Ding et al., 2018; Bruner-Tran et al., 2017; Rowlands et al., 2006; Sanabria et al., 2016) and in humans (Chang et al., 2014; Chevrier et al., 2014; Ye et al., 2018; Ames et al., 2019). The present study shows DNA methylation alterations associated with ancestral exposure to di- oxins and disease -specific epimutation biomarkers for different pathologies identified. The pathologies studied include kidney disease, obesity, testis disease, and prostate disease. Kidney and prostate diseases are especially relevant to human populations since both are a major cause of disease and mortality among male humans (Pernar et al., 2018; Hill et al., 2016). According to the Centers of Disease Control (CDC), the prevalence of obesity in the USA was 42.4 million in 2017-2018 (Hales et al., 2017). The association of epigenetic biomarkers with these dis- eases could become particularly valuable indicators of disease 8 M. Ben Maamar et aL Environmental Research 192 (2021) 110279 A Prostate Disease DMR Associated Gene Correlations B Kidney Disease DMR Associated Gene Correlations Fig. 6. Disease DMR associated gene correlations. The disease DMR associated genes that correlate with the specific disease tissue functions and pathologies for each individual pathology are presented. Direct gene links to pathologies and physiologic processes are shown. (A) Prostate disease and (B) kidney disease. susceptibility in the human population. Genome-wide association studies (GWAS) have found specific genetic mutations associated with these human pathologies, however these genetic mutations typically appear in less than 1% of the diseased population. In contrast, epigenetic alterations called epimutations seem to have a higher frequency and appear in most individuals with the disease (McBirney et al., 2017; Nilsson et al., 2018b; King et al., 2019). The current study supports this observation where the number of differential DNA methylation regions (DMRs) in the transgenerational males is be- tween 100 and 200 at an edgeR p < 1e-04 threshold for each individual pathology (Fig. 1). A subpopulation of DMRs overlapping between the different individual disease pathologies was not identified (Fig. 4B). An overlap analysis of the disease -specific DMRs demonstrates some of the DMRs overlap between two different diseases, but none overlapped 9 M. Ben Maamar et aL Environmental Research 192 (2021) 110279 A Obesity Disease DMR Associated Gene Correlations B Testis Disease DMR Associated Gene Correlations Disease Organ Protein Protein (Protein phosphatase) Protein (Receptor) Protein (Transcription factor) Protein (Transporter) CellExpression GeneticChange QuantitativeChange > Regulation — - StateChange Fig. 7. Disease DMR associated gene correlations. The disease DMR associated genes that correlate with the specific disease tissue functions and pathologies for each individual pathology are presented. Direct gene links to pathologies and physiologic processes are shown. (A) obesity and (B) testis disease. between all four different diseases, Fig. 4. Therefore, an overlapping set of DMR associated with all general disease susceptibility was not observed. The DMR associated genes show that the most affected gene categories were signaling, metabolism, and transcription. In addition, a large number of previously identified disease -associated genes were present in the DMR associated gene list, Figs. 6 and 7. A limitation of the current study was the low numbers of animals with a specific individual disease. Although an edgeR p-value was used to identify and analyze the disease biomarker DMRs, analysis for multiple testing error for false discovery rate (FDR) provided p-values for the disease biomarkers of >0.1. Previous studies have demonstrated limitations in FDR analysis due to the presumptions in the multiple testing parameters (Devlin et al., 2003; Higdon et al., 2008; Yang and Churchill, 2007; Bretz et al., 2005; Jung, 2010; Nilsson et al., 2009). Therefore, the low sample number is a limitation in the current analysis. Potential higher variability in the data needs to be considered even though higher edgeR values were used, but this does not address mul- tiple testing corrections. Future studies will need to use higher n-values 10 M. Ben Maamar et aL Environmental Research 192 (2021) 110279 to reduce this analysis limitation (Devlin et al., 2003; Higdon et al., 2008; Yang and Churchill, 2007; Bretz et al., 2005; Jung, 2010; Nilsson et al., 2009). The current disease specific epimutation (i.e., DMRs) needs to be validated in future studies. Observations suggest dioxin induced transgenerational DMRs pre- sent in sperm appear associated with specific diseases. This indicates the existence of potential disease specific biomarkers could be used to assess transgenerational transmission of various pathology susceptibilities in the offspring. Such epigenetic biomarkers would also allow potential preventative therapeutics to be used or developed. Although more extensive studies in humans are required, the current study supports the concept that associated pathology DMRs could be utilized as epigenetic biomarkers. Further analysis is needed to determine if the use of these biomarkers is feasible for early detection of disease susceptibility, prior to the actual onset of diseases. Our first study examining the trans - generational endocrine disruptor atrazine showed epigenetic inheri- tance of disease and sperm epimutations, and also supports the concept that epigenetic biomarkers for disease can be identified and potentially employed for diagnosis (King et al., 2019). Subsequently, DDT and vinclozolin induced transgenerational DMRs were identified (Nilsson et al., 2018b; King et al., 2019). The current study showed dioxin in- duction of transgenerational disease and also suggests such environ- mental biomarkers can be identified and potentially become a diagnostic tool for disease susceptibility in the future. Epigenetic biomarkers have a high frequency of association with pathologies, and their incorporation into medical diagnostics will facilitate preventative medicine and dis- ease management. 4. Methods 4.1. Animal studies and breeding As previously described (Manikkam et al., 2012c), female and male rats of an outbred strain Hsd:Sprague Dawley SD (Harlan) at 70-100 days of age were fed ad lib with a standard rat diet and ad lib tap water. Timed -pregnant females on days 8 through 14 of gestation (Nilsson et al., 2008) were administered daily intraperitoneal injections of dioxin (TCDD 100 ng/kg BW/day) or dimethyl sulfoxide (DMSO), as previously described (Manikkam et al., 2012c). As previously described (Manikkam et al., 2012c), the gestating fe- male rats treated were designated as the FO generation. F1—F3 genera- tion control and dioxin lineages were housed in the same room and racks with lighting, food and water as previously described (Skinner et al., 2010; Manikkam et al., 2012a; Anway et al., 2006). All experimental protocols for the procedures with rats were pre -approved by the Washington State University Animal Care and Use Committee (protocol IACUC # 6252). All methods were performed in accordance with the relevant guidelines and regulations. The animal tissues and sperm samples from the previous study (Manikkam et al., 2012c) have been archived and were used for the current study. 4.2. Tissue harvest and histology processing As previously described (Manikkam et al., 2012c), at 12 months of age, rats were euthanized by CO2 inhalation and cervical dislocation for tissue harvest. Testis, prostate, and kidney were fixed in Bouin's solution (Sigma) followed by 70% ethanol, then processed for paraffin embed- ding and hematoxylin and eosin (H & E) staining by standard procedures for histopathological examination. Paraffin five micron sections were processed, stained, and processed by Nationwide Histology, Spokane WA, USA. 4.3. Histopathology examination and disease classification Archived histology slides or paraffin blocks from the previous study were stored in standard archive containers and organized files in the dark at room temperature 20-25 °C (Manikkam et al., 2012c) were used for a new histology analysis for the current study. The images of the various pathologies are presented in a previous study (Manikkam et al., 2012c). The tissue sections were reimaged and reanalyzed with a digital pathology procedure where an image of the tissue section is captured electronically and corrected for area for histopathology analysis. The oversight of the pathology analysis involved the co-author, Dr. Eric Nilsson, DVM/PhD, with over 20 years of pathology analysis experience in rats (McBirney et al., 2017; Anway and Skinner, 2008). The Wash- ington Animal Disease Diagnostic Laboratory (WADDL) at the Wash- ington State University College of Veterinary Medicine has board certified veterinary pathologists and assisted in initially establishing the criteria for the pathology analyses and identifying parameters to assess (Anway et al., 2006). The tissues evaluated histologically were selected from previous literature showing them to have pathology in trans - generational models (Anway et al., 2005, 2006; Guerrero-Bosagna et al., 2010; McBirney et al., 2017; Manikkam et al., 2012b, 2012c, 2013, 2014; Skinner et al., 2013; Tracey et al., 2013), with an emphasis on reproductive organs. Stained testis, prostate, and kidney slides were imaged through a microscope using 4x objective lenses (testis and prostate) or 10x objective lenses (kidney). Tiled images were captured using a digital camera. Tiled images for each tissue were photo -merged into a single image using Adobe Photoshop (ver. 21.1.2, Adobe, Inc.). The image area was captured in pixels and then converted into mm2. This allowed for correction of abnormality counts based on the size of the tissue sample. Images were evaluated and pathology features digi- tally marked using Photoshop software. Raw counts were then divided by the measured area for each sample. Histopathology readers were trained to recognize the specific abnormalities evaluated for this study in rat testis, ventral prostate and kidney. Two different pathology readers were used if they agreed and three different readers if they disagreed for each tissue that were blinded for the readers to the exposure lineage groups. A set of quality control (QC) slides were generated for each tissue and were read by each reader prior to evalu- ating any set of experimental slides. These QC slide results were moni- tored for reader accuracy and concordance. Previous studies by the laboratory help confirm and validate the pathology analysis (Anway et al., 2005, 2006; Guerrero-Bosagna et al., 2010; McBirney et al., 2017; Manikkam et al., 2012b, 2012c, 2013, 2014; Skinner et al., 2013; Tracey et al., 2013). As previously described (Nilsson et al., 2018a), testis histopathology criteria included the presence of vacuoles in the seminiferous tubules, azoospermic atretic seminiferous tubules, and `other' abnormalities including sloughed spermatogenic cells in the center of the tubule and a lack of a tubule lumen. As previously described (Anway and Skinner, 2008; Taylor et al., 2011), prostate histopathology criteria included the presence of vacuoles in the glandular epithelium, atrophic glandular epithelium and hyperplasia of prostatic gland epithelium. Kidney his- topathology criteria included reduced size of glomerulus, thickened Bowman's capsule, and the presence of proteinaceous fluid -filled cysts >50 µm in diameter. A cutoff was established to declare a tissue `diseased' based on the mean number of histopathological abnormalities plus 1.5 standard deviations from the mean of control group tissues, as assessed by each of the individual observers blinded to the treatment groups. This number (i.e., greater than 1.5 standard deviations) was used to classify rats into those with and without testis, prostate, or kidney disease in each lineage. Two individuals blinded to exposure evaluated each tissue image for abnormalities. If there was disagreement about disease status, then a third individual blinded to exposure eval- uated the tissue. Obesity was assessed with an increase in body mass and intra-abdominal adiposity and subcutaneous fat at the time of eutha- nasia, as previously described (Manikkam et al., 2012c). The results for pathology, as previously described (Manikkam et al., 2012c), were expressed as the proportion of affected animals that exceeded a pre- determined threshold (testis, prostate, kidney disease frequency, tumor frequency, obese frequency). Groups were analyzed for statistical 11 M. Ben Maamar et aL differences using Fisher's exact test. 4.4. Epididymal sperm collection and DNA isolation The protocol is described in detail in reference (Manikkam et al., 2012c). Briefly, the epididymis was dissected free of fat and connective tissue, then, after cutting open the cauda, placed into 6 ml of phosphate buffer saline (PBS) for 20 min at room temperature. Further incubation at 4 °C immobilized the sperm. The tissue was then minced, the released sperm pelleted at 4 °C 3000xg for 10 min, then resuspended in NIM buffer and stored at —80 °C for further processing. An appropriate amount of rat sperm suspension was used for DNA extraction. Previous studies have shown mammalian sperm heads are resistant to sonication unlike somatic cells (Huang and Yanagimachi, 1985; Calvin, 1976). Somatic cells and debris were therefore removed by brief sonication (Fisher Sonic Dismembrator, model 300, power 25), then centrifugation and washing 1-2 times in 1X PBS. The resulting pellet was resuspended in 820 µL DNA extraction buffer and 80 µl 0.1M DTT was added, then incubated at 65 °C for 15 min. 80 µl proteinase K (20 mg/ml) was added and the sample was incubated at 55 °C for 2-3 h under constant rotation. Proteins were removed by addition of protein precipitation solution (300 µl, Promega A795A), incubation for 15 min on ice, then centrifu- gation at 13,500 rpm for 30 min at 4 °C. One ml of the supernatant was precipitated with 2 µl of GlycoBlue (Invitrogen, AM9516) and 1 ml of cold 100% isopropanol. After incubation, the sample was spun at 13, 500 xg for 30 min at 4 °C, then washed with 70% cold ethanol. The pellet was air-dried for about 5 min then resuspended in 100 µl of nuclease free water. 4.5. Methylated DNA immunoprecipitation (MeDIP) The archived sperm samples were prepared from previously collected samples as described (Manikkam et al., 2012c). The protocol is described in detail in reference (Manikkam et al., 2012c). Genomic DNA was sonicated and run on 1.5% agarose gel for fragment size verifica- tion. The sonicated DNA was then diluted with 1X TE buffer to 400 µl, then heat -denatured for 10 min at 95 °C, and immediately cooled on ice for 10 min to create single -stranded DNA fragments. Then 100 µl of 5X IP buffer and 5 µg of antibody (monoclonal mouse anti 5-methyl cytidine; Diagenode #C15200006) were added, and the mixture was incubated overnight on a rotator at 4 °C. The following day, magnetic beads (Dynabeads M280 Sheep anti -Mouse IgG; Life Technologies 11201D) were pre -washed per manufacturer's instructions, and 50 1.11 of beads were added to the 500 µl of DNA -antibody mixture from the overnight incubation, then incubated for 2 h on a rotator at 4 °C. After this incu- bation, the samples were washed three times with 1X IP buffer using a magnetic rack. The washed samples were then resuspended in 250 µl digestion buffer (5 mM Tris pH 8, 10.mM EDTA, 0.5% SDS) with 3.5 µl Proteinase K (20 mg/ml), and incubated for 2-3 h on a rotator at 55 °C. DNA clean-up was performed using a Phenol-Chloroform-Isoamyl-Alcohol extraction, and the supernatant precipitated with 2 1.11 of GlycoBlue (20 mg/ml), 20 pi of 5M NaC1 and 500 1.t1 ethanol in —20 °C freezer for one to several hours. The DNA precipitate was pelleted, washed with 70% ethanol, then dried and resuspended in 20 µl H2O or 1X TE. DNA concentration was measured in Qubit (Life Technologies) with the ssDNA kit (Molecular Probes Q10212). 4.6. MeDIP-seq analysis As previously described (Ben Maamar et al., 2018), MeDIP DNA was used to create libraries for next generation sequencing (NGS) using the NEBNext Ultra RNA Library Prep Kit for Illumina (San Diego, CA) starting at step 1.4 of the manufacturer's protocol to generate double stranded DNA from the single -stranded DNA resulting from MeDIP. After this step, the manufacturer's protocol was followed indexing each Environmental Research 192 (2021) 110279 sample individually with NEBNext Multiplex Oligos for Illumina. The WSU Spokane Genomics Core sequenced the samples on the Illumina HiSeq 2500 at PE50, with a read size of approximately 50 bp and approximately 15-20 million reads per pool. 4.7. Statistics and bioinformatics The DMR identification and annotation methods follow those pre- sented in previous published papers (McBirney et al., 2017; Ben Maamar et al., 2018). Data quality was assessed using the FastQC program (htt ps://www.bioinformatics.babraham.ac.uk/projects/fastqc/), and reads were cleaned and filtered to remove adapters and low quality bases using Trimmomatic (28). The reads for each MeDIP were mapped to the Rnor 6.0 rat genome using Bowtie2 (Langmead and Salzberg, 2012) with default parameter options. The mapped read files were then converted to sorted BAM files using SAMtools (Li et al., 2009). The MEDIPS R package (Lienhard et al., 2014) was used to calculate differential coverage between control and exposure sample groups. The reference genome was split into 1000 bp windows. Windows with an average of at least 10 reads per sample were selected for differential analysis. The edgeR p-value (Robinson et al., 2010) was used to determine the relative difference between the two groups for each genomic window. Windows with an edgeR p-value less than an arbitrarily selected threshold were considered DMR. The site edges were extended until no genomic win- dow with an edgeR p-value less than 0.1 remained within 1000 bp of the DMR. The edgeR p-value was used to assess the significance of the DMR identified. Differential epimutation sites were annotated using the bio- maRt R package (Durinck et al., 2009) to access the Ensembl database (Cunningham et al., 2015). The DMR associated genes were then auto- matically sorted into functional groups using information provided by the DAVID (Huang da et al., 2009) and Panther (Mi et al., 2013) data- bases incorporated into an internal curated database (www.skinner.wsu. edu under genomic data). A Pathway Studio, Elsevier, database and network tool was used to assess physiological and disease process gene correlations. All molecular data has been deposited into the public database at NCBI (GEO # GSE157539) and R code computational tools available at GitHub (https://github.com/skinnerlab/MeDIP-seq) and www.skinner.wsu. edu. Funding sources This study was supported by John Templeton Foundation (50183 and 61174) (https://templeton.org/) grants to MKS and NIH (ES012974) (https://www.nih.gov/) grant to MKS. The funders had no role in study design, data collection and analysis, decision to publish, or preparation of the manuscript. Animal studies All experimental protocols for the procedures with rats were pre - approved by the Washington State University Animal Care and Use Committee (protocol IACUC # 6252), and all methods were performed in accordance with the relevant guidelines and regulations. Declaration of competing interest The authors declare that they have no known competing financial interests or personal relationships that could have appeared to influence the work reported in this paper. Acknowledgments We acknowledge Dr. Ingrid Sadler-Riggleman, Ms. Michelle Pappa- lardo, Mr. Ryan Thompson, Ms. Skylar Shea Davidson, Ms. Makena Horne, Ms. Emma Impala, and Ms. Rachel LaRosa for technical assis- tance. We acknowledge Ms. Amanda Quilty for editing and Ms. Heather 12 M. Ben Maamar et aL Environmental Research 192 (2021) 110279 Johnson for assistance in preparation of the manuscript. We thank the Genomics Core laboratory at WSU Spokane for sequencing data. This study was supported by John Templeton Foundation (50183 and 61174) (https://templeton.org/) grants to MKS and NIH (ES012974) (https://www.nih.gov/) grant to MKS. The funders had no role in study design, data collection and analysis, decision to publish, or preparation of the manuscript. Appendix A. 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Stouder, C., Paoloni-Giacobino, A., 2010. Transgenerational effects of the endocrine disruptor vinclozolin on the methylation pattern of imprinted genes in the mouse sperm. Reproduction 139 (2), 373-379. Tai, P.T., Nishijo, M., Anh, N.T., Maruzeni, S., Nakagawa, H., Van Luong, H., Anh, T.H., Honda, R., Kido, T., Nishijo, H., 2013. Dioxin exposure in breast milk and infant neurodevelopment in Vietnam. Occup. Environ. Med. 70 (9), 656-662. Taylor, J.A., Richter, C.A., Ruhlen, R.L., vom Saal, F.S., 2011. Estrogenic environmental chemicals and drugs: mechanisms for effects on the developing male urogenital system. J. Steroid Biochem. Mol. Biol. 127 (1-2), 83-95. Tracey, R., Manikkam, M., Guerrero-Bosagna, C., Skinner, M., 2013. Hydrocarbons (jet fuel JP-8) induce epigenetic transgenerational inheritance of obesity, reproductive disease and sperm epimutations. Reprod. Toxicol. 36, 104-116. Yang, H., Churchill, G., 2007. Estimating p-values in small microarray experiments. Bioinformatics 23 (1), 38-43. Ye, M., Warner, M., Mocarelli, P., Brambilla, P., Eskenazi, B., 2018. Prenatal exposure to TCDD and atopic conditions in the Seveso second generation: a prospective cohort study. Environ. Health 17 (1), 22. York, G., Mick, H., 2008. Last ghost of the Vietnam war. In: The Globe and Mail. Phillip Crawley, Toronto, ON Canada. 14 OPEN 8 ACCESS Freely available online )PLOS I ONE Dioxin (TCDD) Induces Epigenetic Transgenerational Inheritance of Adult Onset Disease and Sperm Epimutations Mohan Manikkam, Rebecca Tracey, Carlos Guerrero-Bosagna, Michael K. Skinner* Center for Reproductive Biology, School of Biological Sciences, Washington State University, Pullman, Washington, United States of America Abstract Environmental compounds can promote epigenetic transgenerational inheritance of adult -onset disease in subsequent generations following ancestral exposure during fetal gonadal sex determination. The current study examined the ability of dioxin (2,3,7,8-tetrachlorodibenzo[pldioxin, TCDD) to promote epigenetic transgenerational inheritance of disease and DNA methylation epimutations in sperm. Gestating FO generation females were exposed to dioxin during fetal day 8 to 14 and adult -onset disease was evaluated in F1 and F3 generation rats. The incidences of total disease and multiple disease increased in F1 and F3 generations. Prostate disease, ovarian primordial follicle loss and polycystic ovary disease were increased in F1 generation dioxin lineage. Kidney disease in males, pubertal abnormalities in females, ovarian primordial follicle loss and polycystic ovary disease were increased in F3 generation dioxin lineage animals. Analysis of the F3 generation sperm epigenome identified 50 differentially DNA methylated regions (DMR) in gene promoters. These DMR provide potential epigenetic biomarkers for transgenerational disease and ancestral environmental exposures. Observations demonstrate dioxin exposure of a gestating female promotes epigenetic transgenerational inheritance of adult onset disease and sperm epimutations. Citation: Manikkam M, Tracey R, Guerrero-Bosagna C, Skinner MK (2012) Dioxin (TCDD) Induces Epigenetic Transgenerational Inheritance of Adult Onset Disease and Sperm Epimutations. PLoS ONE 7(9): e46249. doi:10.1371/journal.pone.0046249 Editor: Toshi Shioda, Massachusetts General Hospital, United States of America Received May 17, 2012; Accepted August 30, 2012; Published September 26, 2012 Copyright: © 2012 Manikkam et al. This is an open -access article distributed under the terms of the Creative Commons Attribution License, which permits unrestricted use, distribution, and reproduction in any medium, provided the original author and source are credited. Funding: Financial support of the USA Department of Defense (DOD) and NIH, NIEHS. The funders had no role in study design, data collection and analysis, decision to publish, or preparation of the manuscript. Competing Interests: The authors have declared that no competing interests exist. * E-mail: skinner@wsu.edu Introduction Epigenetic transgenerational inheritance involves the germline transmission of an altered epigenome and phenotypes across generations in the absence of direct environmental exposures [1,2]. The germline epigenome undergoes reprogramming during fetal gonadal development [3]. Environmentally induced germline epigenetic modifications can occur during this DNA demethyla- tion and remethylation period [1] and become permanently programmed similar to the DNA methylation of an imprinted gene [4]. The male germline propagates this epigenetic change after fertilization to all somatic cells resulting in an altered epigenome and transcriptome that can lead to adult onset disease in future generations. A number of environmental chemical exposures have been shown to promote epigenetic transgenera- tional inheritance of adult onset disease and the transgenerational epigenetic changes may be used as biomarkers of exposure and disease [5]. The current study was designed to investigate the potential that dioxin (2,3,7,8-tetrachlorodibenzo[p]dioxin, TCDD) promotes epigenetic transgenerational inheritance of adult onset disease. In rodents TCDD has a half-life of weeks and causes liver disease, weight loss, thymic atrophy and immune suppression. In humans direct dioxin exposure influences chronic diseases, lymphomas and leukemias [6]. The half-life of TCDD in humans varies to over 10 years with body mass index, age, sex and exposure concentration [7]. Agent Orange is one of the TCDD-contaminated herbicides used by the U.S. military during the Vietnam War from 1961 to 1971. Vietnam officials estimate 400,000 people were killed or maimed and 500,000 children born with birth defects resulting from exposure to Agent Orange [8]. The diseases associated with exposure to Agent Orange include: prostate cancer, respiratory cancers, multiple myeloma, type II diabetes, Hodgkin's disease, non -Hodgkin's lymphoma, soft tissue sarcoma, chloracne, por- phyria cutanea tarda, peripheral neuropathy, chronic lymphocytic leukemia, spina bifida in children, B cell leukemias (such as hairy cell leukemia), Parkinson's disease and ischemic heart disease [7]. Another example of a major human exposure to TCDD was the Anshu Seveso Italy industrial accident that occurred in 1976 [9]. Human exposure to dioxin from electronic waste in China has also been documented [10]. A Taiwan industrial accident and food contamination in 1979 was another major incidence of human exposure [11]. Therefore, a number of different human exposures to dioxin have been documented and associated with a large variety of different disease states. The majority of epidemiology studies have focused on direct adult and fetal exposures [12]. A study of the Seveso Italy population documented health effects in the grandchildren (F2 generation) of women that conceived as long as 25 years after the dioxin exposure [13]. No human studies have investigated transgenerational (F3 generation) effects of dioxin. Animal models have been used to study the toxicological effects of dioxin. Dioxin has been shown to produce cleft palates and kidney malformations in newborn mice [14]. Adverse effects in PLOS ONE I www.plosone.org 1 September 2012 I Volume 7 I Issue 9 I e46249 Dioxin Induced Transgenerational Disease animals include endometriosis, developmental neurobehavioral (cognitive) effects, developmental reproductive (sperm counts, female urogenital malformations) effects and immunotoxic effects [15]. A study on pregnant mice exposed to dioxin showed 50% pup mortality [16]. Previous studies with dioxin used high doses (0.2 to 3 µg/kg/BW) and only evaluated the direct exposure of adult and fetal (FO and F1) generations [17,18]. The current study used 0.1 % of oral LD50 dose for TCDD, such that no toxic effects of the exposure were anticipated. However, the current study was not designed as a risk assessment study, but to investigate the potential that dioxin may promote transgenerational disease. Since the exposure of a gestating FO generation female also directly exposes the F1 generation fetus and germ line that will generate the F2 generation, the current study investigated the F3 generation which is the first generation without direct exposure [19]. Environmental chemicals (fungicide vinclozolin and pesticide methoxychlor) were initially found to promote epigenetic transge- nerational inheritance of adult onset diseases following ancestral exposure [2]. Exposure of gestating females transiently to vinclozolin during the fetal gonadal sex determination period promoted epigenetic transgenerational inheritance of adult onset diseases in the F1-F4 generation rats. Subsequently a variety of environmental chemicals have been shown to promote epigenetic transgenerational inheritance of adult onset disease including the plasticizers bisphenol A (BPA) [5,20,21,22] and phthalates [5,20,22], pesticide permethrin and insect repellent DEET [5,22,23], and hydrocarbon mixture (jet fuel JP8) [5,22,24]. A number of other environmental factors such as nutrition (caloric restriction) have also been shown to promote transgenerational phenotypes [25]. Epigenetic transgenerational inheritance has now been shown to be present in plants [26], worms [27], flies [28], rats [5], mice [29] and humans [30]. The first observation that dioxin promotes transgenerational inheritance of adult onset disease demonstrated a decline in fertility in the F3 generation following dioxin exposure to FO generation gestating female mice [31]. Subsequently, dioxin exposure was found to promote pubertal abnormalities and ovarian disease in 120 day old F3 generation rats [5]. The current study was designed to extend these observations with dioxin to examine the epigenetic transgenerational inheritance of a variety of different disease states in 1 year old F1 (direct exposure) and F3 (transgenerational) generation rats. The epigenetic mechanisms involved in the transgenerational inheritance of disease have been previously reviewed [1]. Exposure of the fetus during gonadal sex determination alters the epigenetic (DNA methylation) programming of the germ line (e.g. sperm) that then transmits this altered epigenome in an imprinted -like manner between generations to promote adult onset disease transgener- ationally [4]. These sperm epimutations in the F3 generation dioxin lineage are unique and may be useful as biomarkers of dioxin exposure and adult -onset disease [5]. The current study further investigates the dioxin induced epimutations associated with the sperm epigenome. Results The epigenetic transgenerational action of dioxin administered to FO generation female rats transiently during days 8 to 14 of gestation was investigated. The F1 generation animals were bred to generate the F2 generation and the F2 generation bred to generate the F3 generation as previously described [5]. No sibling or cousin breedings were used to avoid any inbreeding artifacts. Control (vehicle dimethysulfoxide DMSO) exposure lineages and dioxin (TCDD) lineages were generated. The objective was to assess the potential transgenerational phenotype so the F3 generation was the focus with comparisons with the direct exposure F1 generation, while the F2 generation was not examined. The F1 and F3 generation rats of control and dioxin lineages were euthanized at 1 year of age. The testis, prostate, kidney and ovary histopathology was examined. To assess if there were any toxic effects from embryonic exposure to dioxin both the F1 and F3 generation body weights and organ weights were measured (Tables S1A and S1B). The body weight of the F1 generation dioxin lineage females was reduced, but the kidney, ovarian and uterine weights were unaltered. The body weight and the epididymal weight did not change in the F1 generation males. Testis weight in the F1 generation males was increased while the prostate and kidney weights were reduced. In the F3 generation dioxin lineage females the body weight, ovarian and uterine weights were unaltered but the kidney weight was reduced. Testis, epididymis and prostate weights did not change, but the kidney weight was lower in the F3 generation males of dioxin lineage. No effect on sex ratios in the F1, F2 or F3 generations were observed. No significant change in litter size were observed. In addition, serum sex steroid hormone concentrations were measured in the F3 generation to assess any endocrine alterations. Serum testosterone concentrations in the 1 year old F3 generation males increased. Serum estradiol concentrations in F3 generation females during proestrus-estrus phase or diestrus phase (Figure S1) were unaltered so no female F3 generation endocrine effects were detected. Observations indicate that there were no major F1 generation toxicological effects from the direct dioxin exposure. One of the major diseases/abnormalities observed in dioxin lineage males was kidney disease. Kidney disease was character- ized by the presence of an increased number of proteinaceous fluid filled cysts, reduction in size of glomeruli and thickening of Bowman's capsules (Figure 1). Previously, transgenerational kidney phenotypes have been shown to correlate with alterations in serum markers for kidney disease [32]. In the F1 generation an increase in kidney disease in males approached significance (P = 0.0672) and in the females there was no effect. There was a statistically significant increase in kidney disease in F3 generation males, but not in females (Figure 1). As previously reported [5], there was an increase in pubertal abnormalities in the F1 generation males of dioxin lineage, but not in F3 generation males (Figure 2). In the F1 generation 40% of males had pubertal abnormalities, with the majority being delayed pubertal onset. In the control lineage 18% of males had pubertal abnormalities, with the majority being delayed pubertal onset. In the F3 generation 5 % of dioxin lineage males had pubertal abnormalities, with all of them being delayed onset of puberty. In the F3 generation control lineage 8% of males had pubertal abnormalities, with the majority being early pubertal onset. The incidence of pubertal abnormalities in females did not change in the F1 generation, but was significantly altered in the F3 generation (Figure 2). In the F1 generation 13% of females had pubertal abnormalities, with half being delayed pubertal onset and the other half being early pubertal onset. In control lineage 7% of females had pubertal abnormalities, all being delayed pubertal onset. In the F3 generation 47 % of dioxin lineage females had pubertal abnormalities (Figure 2), all being early onset of puberty. In the F3 generation control lineage 6% of females had pubertal abnormalities, with the majority being early pubertal onset. As previously reported [5,22] there was an increase in the incidences of ovarian disease/abnormality including primordial follicle loss (Figure 2, panel C) and polycystic ovarian disease (Figure 2, panel D). These data were re -analyzed to determine PLOS ONE I www.plosone.org 2 September 2012 I Volume 7 I Issue 9 I e46249 Dioxin Induced Transgenerational Disease A Female Kidney Disease 50— a) 73 40- Y r a 30- 5as N CS p 20- c E 10- 0 3/18 1/7 6/34 5/39 1 Oo G N<C' C E G°��io\ • °l- Q`') (iCn) B D F 20 Male Kidney Disease ?, 50 40 Y vs 30 m Qf � 2 10 1/22 3/11 10/37 �* Q` { o`� o Goc% Oro}c` Figure 1. Dioxin and control lineage F1 and F3 generation adult -onset kidney disease. Percentages of females (panel A) and males (panel B) with kidney disease and number of diseased rats/total number of rats (*P<0.05). Micrographs (Scale bar=200 gm) show kidney disease in F3 generation dioxin lineage (panel E and F) compared to control (panel C and D) for female (panel C and E) and male (panel D and F). doi:10.1371 /journal.pone.0046249.g001 disease/abnormality incidence for the current study. The primor- dial follicle loss was shown by a reduction in the number of primordial follicles per ovary section and the polycystic ovarian histopathology was characterized by an increase in the number of small cysts. The F1 and F3 generation females showed an increase in the incidence of both primordial follicle loss and polycystic ovarian disease. The F1 and F3 generation rats did not present any change in the incidence of tumor development (Figure 2, panels E and F) or incidence of obesity (data not shown). Other sporadic disease PLOS ONE I www.plosone.org 3 September 2012 I Volume 7 I Issue 9 I e46249 Dioxin Induced Transgenerational Disease A 100 P 73 E 75- 0 c .0 < 50- lis a25- 2/30 2/15 6/101 • 0 i r • 40 Q (<'\ 45 0 Female Pubertal Abnormality *** 37/78 Primordial Follicle Loss C*** y y 0 t- 80- S f!7 - • 60- 0 O LL E • 40- iio- 20- a B D 100- I• 75.. Q 50- t 0 - 25- a • 0 0 100- ' 0 100- * 0 co 6 80- O 4/7 •a 60- ca c.) 40- rn 1/9 119 a 20- I O. 0/9 0/9 e ��o +,* ;io• �o 00 •.o 00�• o Goo o Goo 0' G ‘4", ‹)% Male Pubertal Abnormality 8/20 7/38 7/92 4/84 Q40 Q � 45 <5 0 7/7 6/9 E Female Tumor Development 25- 1 0 • 20- IH c L E • 15- t7. 0 to > 10- ra a, Eo • 5- 0 2/20 0/9 4/69 3/41 0 F 25- la E �20- . E15- °10- o _0 cv 2 5- 0 0 Polycystic Ovary Disease *** 9/9 Male Tumor Development 0/22 1/13 2/56 1/45 • C'oo`�o� ,o•c Goc�to� 'S�•`o O ▪ `o ��'oc�yo, `o+moo ocio\ • 04S � <5 �,�0 415 k Figure 2. Dioxin and control lineage F1 and F3 generation pubertal abnormality and ovarian disease. Percentages of females (panel A) and males (panel B) with pubertal abnormality, or primordial follicle loss (panel C), or polycystic ovary disease (panel D), or those with tumor development (panels E and F). The number of diseased rats/total number of rats in each lineage are presented (*P<0.05; ***P<0.001). doi:10.1371/journal.pone.0046249.g002 PLOS ONE I www.plosone.org 4 September 2012 I Volume 7 I Issue 9 I e46249 Dioxin Induced Transgenerational Disease predominantly observed in the dioxin lineage animals included abscesses, eye discharges, colon impaction, missing testis, rudi- mentary epididymis, fat necrosis, lung abnormalities, and active mammary gland (milk presence) unrelated to pregnancy. The incidences of testis and prostate diseases in the dioxin lineage are presented in Figure 3. Testis disease/abnormality was characterized by the presence of histopathology including azoospermic and atretic seminiferous tubules, presence of vacuoles in basal regions of seminiferous tubules, sloughed cells in center of seminiferous tubules and lack of seminiferous tubule lumen (Figure 3). There was no increase in testis disease in either F1 or F3 generation rats. To further study testis disease the number of apoptotic spermatogenic cells was examined by TUNEL analysis. The number of apoptotic spermatogenic cells declined in the F1 generation and did not change in the F3 generation rats (Supplemental Figure S 1 D). Therefore spermatogenic defects that were present in vinclozolin lineage F3 generation rats [2,32] were not observed in dioxin lineage F3 generation rats. Also there was no alteration in sperm numbers or sperm motility in F1 and F3 generations (data not shown). Prostate disease/abnormality was characterized by atrophic prostatic duct epithelium (Figure 3). Only the F1 generation dioxin lineage rats showed an increase in prostate histopathology. Observations indicate ancestors exposed to dioxin transgener- ationally transmitted kidney disease, pubertal abnormalities and ovarian disease/abnormality to their unexposed F3 generation descendants. These findings are an example of environmentally induced epigenetic transgenerational inheritance of adult -onset disease. The incidence of diseases/abnormalities in individual rats from control and dioxin lineages are presented in Tables S2A (F1 generation females), S2B (F1 generation males), S3A (F3 generation females) and S3B (F3 generation males). The total number of animals is indicated for each disease/abnormality assessment in Tables S2 and S3. The number of animals per litter (litter representation) mean ± SEM used for the control versus dioxin lineage comparison was found not to be statistically different (p>0.05) for each individual disease/abnormality, such that no litter bias was detected. The incidence of total disease/ abnormality per rat increased in both F1 and F3 generation females of dioxin lineage (Figure 4, panel A). The incidence of rats with multiple diseases/abnormalities also increased in both F1 and F3 generation females of dioxin lineage (Figure 4, panel C). The incidence of total disease/abnormality per rat increased in F1 and in F3 generation males (Figure 4, panel B). The incidence of multiple diseases/abnormalities per rat increased in F1 generation but not in F3 generation males. Exposure of F0 generation females to dioxin increased the overall incidence of adult onset histopa- thology in both F1 and F3 generation males and females. As previously described, the transgenerational effects of dioxin on the sperm epigenome are unique [5]. The transgenerational F3 generation control and dioxin lineage sperm epigenomes were analyzed. This analysis identified 50 statistically significant differentially DNA methylated regions (DMR) in promoters, Table 1. A methylated DNA immunoprecipitation (MeDIP) followed by PCR was used to confirm the MeDIP-Chip analysis for selected DMR due to their high connectivity in the gene network below. The MeDIP-PCR for Hdac3 and Npc2 were found to confirm the MeDIP-Chip identification with >10 fold changes that were statistically different (p<0.0001). The DMR are on average 800 bp in size. The chromosomal locations of these DMR are presented in Figure 5. The majority of the autosomes contained dioxin induced epimutations. The functional gene categories of the gene promoters containing the DMR are shown in Figure 6. Signaling and transcription were the two most predominant functional gene categories. Signaling pathway and cellular process enrichment for the list of dioxin lineage genes having DMR in F3 generation sperm was examined. The top 20 pathways enriched in genes having DMR in their promoters are presented (Table S4). There were four pathways each with three genes affected. They include ribosome pathway, chemokine signaling pathway and natural killer cell mediated cytotoxicity. Additionally 16 pathways had two genes affected in each. Therefore, dioxin induced a transgenerational alteration in the sperm epigenome and the DMR epimutations were not predom- inant in specific cellular pathways. A gene network analysis of the DMR associated genes did not identify a direct gene connection gene network, but did identify connections with general cellular process, Figure 7. Discussion The current study demonstrates that dioxin (TCDD), an environmental toxicant and contaminant present in herbicides such as Agent Orange, can promote epigenetic transgenerational inheritance of diseases in unexposed progeny of the FO generation females exposed during gestation. These observations extend previous studies in mice [31] and rats [5] by examining a variety of different disease states in 1-year-old rats. In addition, the epigenetic mechanism of transmission of this adult -onset disease was further examined by characterizing the transgenerational epigenetic changes in the F3 generation sperm. Epigenetic alterations in sperm DNA methylation (termed epimutations) in the F3 generation were observed after dioxin exposure of the FO generation gestating female ancestors. This transgenerational transmission of adult onset diseases has implications of disease risk for not only the current exposed human and animal populations, but also for future generations [1]. For example, Vietnam War Veterans exposed to the Agent Orange descendants may currently be experiencing an increased incidence of disease [7]. The toxic effects of direct exposure to dioxin include acute liver damage, weight loss, thymic atrophy, immune suppression and chronic diseases, as well as lymphomas and leukemias in humans [6]. The list of diseases seen following exposure of war veterans to Agent Orange (herbicide contaminated with dioxin) during the Vietnam era is growing [7]. Similar observations have been made with the Taiwan [11], Seveso Italy [9], China [10] and Japan exposures [33]. Due to the bioaccumulation of dioxin and up to decade long half-life in humans, any woman becoming pregnant even 20 years after dioxin exposure runs the risk of transmitting dioxin effects to her fetus and later generations. A generational study in the Seveso Italy exposed population supports this concept demonstrating health effects in progeny born 25 years following the exposure [13]. Few studies have addressed this transgenerational aspect of dioxin exposure. The first animal study demonstrated transgenera- tional actions of dioxin on mouse fertility [31]. Subsequently dioxin effects on F3 generation 120 day old rat disease was demonstrated [5]. The current study investigated the adult onset disease in 1 year old F3 generation offspring of FO generation ancestors exposed to dioxin. This study did not use toxic doses of dioxin, but used only pharmacological doses based on 0.1 % of the oral LD50 dose for dioxin. Therefore, no major toxic effects of dioxin were observed. However, the dose and route of administration used in the current study does not allow risk assessment of dioxin exposure. The objective of the study was to investigate if exposure to TCDD could promote epigenetic transgenerational inheritance of disease/ abnormality phenotypes, and not to assess environmental risk of PLOS ONE I www.plosone.org 5 September 2012 I Volume 7 I Issue 9 I e46249 Dioxin Induced Transgenerational Disease A 100- 0 C E 4/19 Testis Disease 5/11 O• o 8/36 6/47 Go*��o� �'b B D F 4/43 1/36 100- m O 75- Cr. a) t m cn To 25- 2 " 50- Prostate Disease 5/22 *** 9/12 • �• o % '' < Figure 3. Dioxin and control lineage F1 and F3 generation adult -onset transgenerational testis or prostate disease. Percentages of males with testis (panel A) or prostate disease (panel B) and number of diseased rats/total number of rats (*"P<0.001). Micrographs (Scale bar=200 gm) show testis and prostate disease in F3 generation dioxin lineage (panels D and F) compared to control (panels C and E). doi:10.1371/journal.pone.0046249.g003 exposure to dioxin. These observations can now be used in future studies with appropriate modes of administration and doses to design more effective risk assessment analysis. However, the current study demonstrates the potential of dioxin to promote epigenetic transgenerational inheritance of disease. In the current study, the transgenerational diseases/abnormal- ities observed includes kidney disease, ovary disease/abnormality, and pubertal abnormalities. Kidney disease incidence was higher in the transgenerational F3 generation dioxin lineage males. Chronic kidney disease in humans is correlated with high dioxin PLOS ONE www.plosone.org 6 September 2012 Volume 7 Issue 9 e46249 Dioxin Induced Transgenerational Disease A Total Female Disease Incidence 100- a) U aa) 75- U C 50- ea a) a 25- 7/20 7/9 32/41 • • Oo 12. �G • k 13/69 o�.o` • c)41 kb k�0 C Incidence of Female Multiple Disease 100 0 25- 1/20 5/9 o ' , 0 O�.s `"*4� k^G k: *** 13/41 2/69 "� \ O• \O*`i` k kn' B Total Male Disease Incidence 100- a) U w 75- 0 50- m ca a 25— a 100— m V w 75— a 2 ** 13/13 11/22 19145 17/56 11111111111111111 I ocd `+,• � 0 ^G k�0 Q <S 0 Incidence of Male Multiple Disease * 6/13 3/22 1 I O�'yO\ 4 00 �G k^ k 3/56 3/45 I • 3Go4e. O�o k� Figure 4. Dioxin and control lineage F1 and F3 generation adult -onset diseases in rats. Incidences of total female disease (panel A), total male disease (panel B), female multiple disease (panel C) and male multiple disease (panel D) and number of diseased rats/total number of rats (*P<0.05; **P<0.01; ***P<0.001). doi:10.1371/journal.pone.0046249.g004 levels [34]. Prenatal TCDD exposure has been shown to augment renal immune complex deposition, glomerulonephritis, and mesangial proliferation [35]. Male rats exposed to TCDD have manifested nephrotoxicity shown by increases in serum creatinine and blood urea nitrogen levels, altered kidney histopathology, and renal oxidative stress [36]. Lactational exposure of mice to TCDD caused hydronephrotic kidney [37]. The current study is the first to report a transgenerational kidney histopathology in unexposed F3 generation male descendents of F0 generation gestating females exposed to dioxin. As previously observed [22], the ovarian disease/abnormality identified included primordial follicle loss and polycystic ovarian disease in F3 generation dioxin lineage females. Currently the world's human female population is facing an increased incidence of primary ovarian insufficiency, characterized by primordial follicle reserve loss, and an increased incidence of polycystic ovarian disease, characterized by the presence of anovulatory cysts [38,39]. Similar to kidney disease, ovary disease phenotypes in the current study also appear to be the outcome of epigenetic transgenerational inheritance mechanisms. In animal studies, effects of dioxin exposure on ovarian function and steroid levels have been demonstrated. Dioxin exposure affects ovarian function [40,41,42] and results in reduced ovarian weight and reduced numbers of corpora lutea and follicles [43,44,45]. Further, dioxin causes reduced ovulation rate, failure of follicular rupture, morphologic changes in the ovary, and abnormal cyclicity with disruption of the estrous cycle [41,46,47,48,49,50,51,52,53]. Dioxin slows follicular maturation [51,52,54]. Ovarian tumors were induced by chronic TCDD exposures [55]. A nonmonotonic dioxin dose -related association was found with risk of earlier menopause (loss of primordial follicle pool reserve) in a population of women residing near Seveso, Italy, in 1976, at the time of a PLOS ONE I www.plosone.org 7 September 2012 I Volume 7 I Issue 9 I e46249 Dioxin Induced Transgenerational Disease Table 1. Sperm differential methylation regions (DMR) in F3 generation dioxin lineage. Gene Symbol Chr Start Stop Gene ID min p-value Gene Title Cytoskeleton-ECM Flg 2 186309317 186310200 24641 8.5E-15 Filaggrin Development Npc2 6 108814526 108815306 286898 3.6E-15 Niemann-Pick disease, type C2 Sema3b 8 112851422 112852727 363142 3.9E-11 sema domain, immunoglobulin domain (Ig), short basic domain, secreted, (semaphorin) 3B Epigenetics Jmjd8 10 15093529 15094314 360498 6.1E-07 jumonji domain containing 8 Hdac3 18 30875498 30876873 84578 1.9E-08 histone deacetylase 3 Golgi Apparatus B4galt2 5 138346044 138347049 313536 1.5E-13 UDP-Gal:betaGlcNAc beta 1,4- galactosyltransferase, polypeptide 2 Growth Factors Tgfbi 17 13934717 13935412 116487 5.9E-10 transforming growth factor, beta induced Hormone LHB 1 95892653 95894255 25329 1.4E-07 luteinizing hormone beta Immune Response Irgc1 1 79680291 79680891 308428 8.4E-07 immunity -related GTPase family, cinema 1 Siglec5 1 93734203 93734913 292843 1.4E-09 sialic acid binding Ig-like lectin 5 Fcgr2a 13 86914892 86915576 116591 3.1E-11 Fc fragment of IgG, low affinity Ila, receptor (CD32) Cd99l2 15 5672856 5673836 171485 9.1E-09 CD99 molecule -like 2 Metabolism & Transport Syt3 1 94866199 94867099 25731 3.2E-07 synaptotagmin III Ca2 2 88092498 88093184 54231 2.1E-24 carbonic anhydrase II LoxI3 4 117244180 117245277 312478 4.2E-11 lysyl oxidase-like 3 CIcn2 11 82429579 82430269 29232 2.7E-08 chloride channel 2 Aldh7al 18 52310889 52311983 291450 4.9E-17 aldehyde dehydrogenase 7 family, member Al Proteolysis DPP3 3 138285960 138287265 114591 8.4E-13 dipeptidylpeptidase 3 Pi16 20 7642807 7643887 294312 2.9E-11 peptidase inhibitor 16 Receptors & Binding Proteins 01r60 1 160632243 160632843 405017 1.1E-10 olfactory receptor 60 Chrm3 17 71070835 71071435 24260 9.1E-22 cholinergic receptor, muscarinic 3 Signaling Ppp1 r14a 1 84421173 84422179 114004 8.6E-12 protein phosphatase 1, regulatory (inhibitor) subunit 14A Ffar2 1 85881877 85882477 292794 4.3E-14 free fatty acid receptor 2 Bcar3 2 219075668 219076268 310838 1.1E-14 breast cancer anti -estrogen resistance 3 Dok1 4 117244180 117245277 312477 4.2E-11 docking protein 1 Akap6 6 73042917 73043604 64553 9.5E-85 A kinase (PRKA) anchor protein 6 CSNK1G2 7 10588530 10589932 65278 7.4E-12 casein kinase 1, gamma 2 Shc2 7 11584014 11584614 314612 3.5E-12 SHC (Src homology 2 domain containing) transforming protein 2 Rasal3 7 12968011 12968901 314596 4.2E-11 RAS protein activator like 3 Hspdl 9 53896237 53896837 63868 4.7E-10 heat shock protein 1 (chaperonin) Grid2ip 12 11553996 11554716 288484 2.4E-08 glutamate receptor, ionotropic, delta 2 (Grid2) interacting protein Grk6 17 15237197 15237797 59076 1.7E-13 G protein -coupled receptor kinase 6 Transcription Fes 1 136208036 136209136 361597 4.3E-08 feline sarcoma oncogene Nras 2 198291944 198293429 24605 9.9E-13 neuroblastoma ras oncogene PLOS ONE I www.plosone.org 8 September 2012 I Volume 7 I Issue 9 I e46249 Dioxin Induced Transgenerational Disease Table 1. Cont. Gene Symbol Chr Start Stop Gene ID min p-value Gene Title Pole3 Tceb1 RGD1563216 No110 5 79520269 5 1975423 6 108814526 6 41121100 79520987 298098 5.3E-24 polymerase (DNA directed), epsilon 3 (p17 subunit) 1976200 64525 7.7E-35 transcription elongation factor B (SIII), polypeptide 1 108815306 500694 3.6E-15 similar to HESB like domain containing 1 41121700 313981 3.1E-12 nucleolar protein 10 Translation & Protein Modification Rpl8 7 114953948 114955044 26962 2.3E-09 ribosomal protein L8 Syncrip 8 93822110 93822710 363113 1.1E-10 synaptotagmin binding, cytoplasmic RNA interacting protein Padi4 Rp136 Arl6ip4 Rp135 Miscellaneous & Unknown RGD1307797 RGD1560846 NSCAN pred chr14.352.a NSCAN pred chr14.357.a Fam129c NSCAN pred chr17.082.a 5 Un 12 3 159616539 159617242 29512 3.6E-16 peptidyl arginine deiminase, type IV 25163917 25164597 58927 6.0E-20 ribosomal protein L36 33604987 33605992 65105 2.2E-07 ADP-ribosylation-like factor 6 interacting protein 4 18794594 18795299 296709 8.2E-50 ribosomal protein L35 1 12 14 14 16 17 85716944 6095843 49589568 49806934 18796064 12540665 85717628 6096542 49590168 49807635 18796973 12541742 361547 8.9E-08 LOC361547 498133 1.5E-11 similar to hypothetical protein MGC40178 4.2E-12 3.5E-10 498604 8.8E-09 3.6E-13 family with sequence similarity 129, member C doi:10.1371 /jou rnal.pone.0046249.t001 chemical plant explosion [56]. In the current study, the diseases of primordial follicle loss and polycystic ovarian disease found in the F3 generation support two previous reports [5,22] of transgenera- tional ovarian diseases following ancestral exposure to dioxin. It is important to note that the polycystic ovarian disease was observed at an increased frequency in the transgenerational (F3) generation [22]. Therefore, ancestral exposure of a gestating female to dioxin promotes an altered fetal gonadal development and epigenetic reprogramming of the male germline that then transmits the altered epigenome to subsequent generations to contribute to the development of these ovarian diseases transgenerationally. All cell types and tissues derived from the altered sperm epigenome have cell specific alterations in transcriptomes and epigenomes. Previous observations showed a transgenerational alteration in both the transcriptome and the epigenome of the ovarian granulosa cells from F3 generation rats of the vinclozolin lineage [22]. Epigenetic mechanisms underlie the development of polycystic ovary syndrome in women [57] and prenatally androgenized rhesus monkeys [58]. These observations suggest an additional epigenetic paradigm be considered for the etiology of primary ovarian insufficiency and polycystic ovarian disease in women. Pubertal abnormalities were increased only in female F3 generation animals of dioxin lineage. In an earlier study [5] it was shown that F3 dioxin lineage females had an alteration of the time of pubertal onset (number of days to pubertal onset reduced). The current study assessed the number of animals with pubertal abnormalities using a time of puberty cutoff of mean of control lineage ±2 standard deviations and reports an increased percent incidence of pubertal abnormalities in F3 generation dioxin lineage females. The current study investigated pubertal abnor- malities in part due to the dramatic increase in pubertal abnormalities over the past decades in humans [59]. The early and delayed onset of puberty are forerunners to different adult health consequences. For example, early onset of puberty results in accelerated bone mineralization and reduced adult height in girls, as well as susceptibility to breast tumors [60]. The delayed onset of puberty leads to reduced bone mineralization, psychological stress and metabolic problems [60]. In the current study, equal proportions of F1 generation females of dioxin lineage had early and delayed pubertal onset, while males had increased proportion of delayed pubertal onset, indicating sexually dimorphic and different direct -exposure effects. Previously, perinatal exposure to a low dose of dioxin induced only precocious puberty that included early maturation of the hypothalamic -pituitary axis, the gonads and genitals, in female Long -Evans hooded rats [61]. In the current study, the affected F3 generation dioxin lineage females had early onset of puberty, while the affected males showed delayed onset of puberty, indicating sex -specific and different transgenerational effects. In this study pubertal onset in dioxin lineage rats is an example where direct and transgenera- tional effects are very different. Previously, early onset of puberty in girls has been suggested to be due to environmental exposures to endocrine disruptors [62]. Dioxin exposure is suggested to cause early onset of menarche in girls [63,64]. Early onset of puberty in girls disrupts brain development, endocrine organ systems and growth leading to susceptibility to disease. It is interesting to note that puberty onset (an early developmental milestone) in this study is associated with epigenetic transgenerational adult onset ovarian disease in F3 generation females. The molecular mechanism of epigenetic transgenerational inheritance of phenotypes involves the reprogramming of the germline epigenome during male gonadal sex determination [1,65]. The modified sperm epigenome (DNA methylation) appears to be permanently reprogrammed similar to an imprint- ed -like site and is protected from DNA demethylation and reprogramming after fertilization and in the following generations. This allows transgenerational transmission of the modified sperm PLOS ONE I www.plosone.org 9 September 2012 I Volume 7 I Issue 9 I e46249 Dioxin Induced Transgenerational Disease Chromosome 20 - 19- 18- 17- 16- 15- 14- 13- 12- 11 - 10- 9- 8- 7- 6- 5 4- 3- 2- ■ ■ ■ VW ■ ■ ■ ■■ ■ ■ ■ ► ■ ► ► ► i ■ ► ► ► 2 0 2 CM r n N 0 ■ ► I■ a o0 0 0, o m .o 0 ► ■ ■ ■ ■ ■ ■ 2 0) 2 0 ► ■ ► . .a 2 0, o o N N n h N 0 0 N Figure 5. Dioxin promoted F3 generation sperm epimutations. Chromosomal locations for transgenerational differential DNA methylation regions (DMR) (arrowheads). There were 50 DMR in sperm DNA from dioxin lineage rats compared to control lineage rats. doi:10.1371/journal.pone.0046249.g005 epimutations to then modify all somatic cell and tissue epigenomes and transcriptomes to promote epigenetic transgenerational inheritance of disease phenotypes. The current study further analyzed the altered sperm epigenome and epimutations induced by ancestral dioxin exposure. Transgenerational alterations in an F3 generation sperm epigenome were initially identified following developmental exposure to vinclozolin [2,4]. A recent study demonstrated a variety of different environmental toxicants induce 12 10 6 E z 4 2 0 nn APO°Q ��P 4 ;\ \�(J p Q.°k- C§ 6' CR \� • Figure 6. Dioxin induced DMR and functional gene categories. Number of DMR associated with various gene categories. doi:10.1371/journal.pone.0046249.g006 exposure specific differentially DNA methylated regions (DMR), defined as epimutations and epigenetic biomarkers, which included dioxin lineage F3 generation sperm epimutations [5]. The list of DMR associated genes from F3 generation sperm dioxin lineage is presented in Table S4. Therefore, the sperm epimutations correlated with the epigenetic transgenerational inheritance of the disease phenotypes documented. Transgenerational diseases are promoted by many environ- mental compounds [5]. Vinclozolin exposure resulted in F3 generation testis disease, prostate disease, kidney disease, immune system abnormalities, tumors, uterine hemorrhage during preg- nancy and polycystic ovarian disease [2,29,32,66]. Further, changes in the methylation patterns of imprinted genes in sperm of F3 generation male mice were found following vinclozolin exposure [67]. Exposure of FO generation gestating rats to Bisphenol-A caused decreased fertility in F3 generation males [21]. Environmental factors such as nutrition [25] also can promote epigenetic transgenerational inheritance of disease phenotypes. Demonstration of epigenetic transgenerational inher- itance in worms [27], flies [28], plants [26] and mammals [30,68,69] suggest this phenomenon will likely be critical in biology and disease etiology [1]. Together these observations demonstrate that exposure of gestating females to dioxin during gonadal sex determination promotes epigenetic transgenerational inheritance of adult -onset disease including kidney disease, ovary disease/abnormality and pubertal onset abnormalities. The overall increase in total and multiple diseases/abnormalities in F3 generation are also considerable. Associated with the occurrence of these transgenerational diseases are the epigenetic changes in rat sperm DNA. These epimutations may be useful as early stage PLOS ONE I www.plosone.org 10 September 2012 I Volume 7 I Issue 9 I e46249 Dioxin Induced Transgenerational Disease tit 4444444 4 4 44 40 041 Il441i Ulu �l4 44 r 441(44444444 � 1 Ilff� '1f..tMi11iiliQiil11a.4a11.111411 014.,s"!t r. 0 1 ;ii tieI I1 ep5helml cell profrfereton Infertility C4GL_ li Figure 7. Gene network of DMR associated genes. The DMR associated genes with connections to various cellular processes and associated cellular localization. doi:10.1371 /journal.pone.0046249.g007 biomarkers of compound exposure and adult onset disease. Although not designed for risk assessment, these results have implications for the human populations that are exposed to dioxin and are experiencing declines in fertility and increases in adult onset disease, with a potential to transmit them to later generations. Materials and Methods Animal Studies and Breeding All experimental protocols for the procedures with rats were pre -approved by the Washington State University Animal Care and Use Committee (IACUC approval # 02568-026). Female and male rats of an outbred strain Hsd:Sprague Dawley®TMSD®TM (Harlan) at about 70 and 100 days of age were fed ad lib with a standard rat diet and ad lib tap water for drinking. To obtain time - pregnant females, the female rats in proestrus were pair -mated with male rats. The sperm -positive (day 0) rats were monitored for diestrus and body weight. On days 8 through 14 of gestation [66], the females were administered daily intraperitoneal injections of dioxin (TCDD 100 ng/kg BW/day) or dimethyl sulfoxide (vehicle control). Treatment lineages are designated `control' and `dioxin' (TCDD) lineages. The gestating female rats treated were designated as the FO generation. The offspring of the FO generation rats were the F1 generation. Non-littermate females and males aged 70-90 days from F1 generation of control or dioxin lineages were randomly selected and bred to obtain F2 generation offspring. The F2 generation rats were bred to obtain F3 generation offspring. The F1- F3 generation offspring were not directly treated with the dioxin. No sibling or cousin breeding was used to avoid any inbreeding artifacts. The number of animals used is indicated in Tables S2 and S3, for each histopathology examined. The control lineage population was larger than the dioxin lineage due to the lower incidence of disease in the control lineage. The increased number of control lineage animals allowed for an increased ability to detect disease in the control lineage that then allowed for more accurate statistical comparison of the control versus dioxin lineage populations. No alterations in litter size or sex ratios were identified in the F1, F2 or F3 generations for the control or dioxin lineage animals. PLOS ONE I www.plosone.org 11 September 2012 I Volume 7 I Issue 9 I e46249 Dioxin Induced Transgenerational Disease Tissue Harvest and Histology Processing Rats at 1-year of age were euthanized by CO2 inhalation for tissue harvest. Body and organ weights were measured at dissection time. Testis, epididymis, prostate, seminal vesicle, ovaries, uterus and kidney were fixed in Bouin's solution (Sigma) and 70% ethanol, then processed for paraffin embedding by standard procedures for histopathology examination. Five -micrometer tissue sections were made and were either unstained and used for TUNEL analysis or stained with H & E stain and examined for histopathology. Blood samples were collected at the time of dissection, allowed to clot, centrifuged and serum samples stored for steroid hormone assays. Testicular Apoptotic Cells by TUNEL Testis sections were examined by Terminal deoxynucleotidyl transferase-mediated dUTP nick end labeling (TUNEL) assay (In situ cell death detection kit, Fluorescein, Roche Diagnostics, Mannheim, Germany). Sections were deparaffmized and rehy- drated through an alcohol series. They were deproteinized by Proteinase K (20 mg/ml; Invitrogen, Carlsbad, CA), washed with PBS and then 25 µl of the enzyme -label solution mix was applied and incubated at 37°C for 90 min. After PBS washes, slides were mounted and kept at 4°C until examination in a fluorescent microscope in dark field. Both testis sections of each slide were microscopically examined to identify and to count apoptotic germ cells by the bright fluorescence. Histopathology Examination and Disease Classification All histopathology was examined in randomly selected animals by three independent observers. Testis histopathology criteria included the presence of a vacuole, azoospermic atretic seminif- erous tubule and `other' abnormalities including sloughed spermatogenic cells in center of the tubule and a lack of a tubule lumen. Prostate histopathology criteria included the presence of vacuoles, atrophic epithelial layer of ducts and hyperplasia of prostatic duct epithelium. Kidney histopathology criteria included reduced size of glomerulus, thickened Bowman's capsule and the presence of proteinaceous fluid -filled cysts. A cut-off was established to declare a tissue `diseased' based on the mean number of histopathological abnormalities plus two standard deviations from the mean of control tissues by each of the three individual observers. This number was used to classify rats into those with and without testis, prostate or kidney disease/ abnormality in each lineage. A rat tissue section was finally declared `diseased' only when at least two of the three observers marked the same tissue section `diseased'. The proportion of rats with obesity or tumor development was obtained by accounting those that had these conditions out of all the animals evaluated. The number of animals per litter (litter representation) mean ± SEM used for the control versus dioxin lineage comparisons for each specific disease/abnormality was found not to be statistically different (p>0.05). Therefore, no litter representation differences or litter bias was detected for any of the specific disease/ abnormality assessed. Ovarian Disease Analysis by Follicle and Cyst Counts Every 30th section of each pair of ovaries was stained with hematoxylin and eosin and three stained sections (150 µm apart) through the central portion of the ovary with the largest cross sections being evaluated. Ovary sections were assessed for two histopathologies, primordial follicle loss and polycystic ovary disease. Primordial follicle loss was determined by counting the number of primordial follicles per ovary section and averaging across three sections. An animal was scored as having primordial follicle loss if the primordial follicle number was less than that of the control mean minus two standard deviations. Primordial follicles had an oocyte surrounded by a single layer of either squamous or both squamous and cuboidal granulosa cells [70,71]. Follicles had to be non-atretic and showing an oocyte nucleus in order to be counted. Polycystic ovary histopathology was determined by microscopically counting the number of small cystic structures per section averaged across three sections. A polycystic ovary was defmed as having a number of small cysts that was more than the control mean plus two standard deviations. Cysts were defmed as fluid -filled structures of a specified size that were not filled with red blood cells and which were not follicular antrum. A single layer of cells may line cysts. Small cysts were 50 to 250 µm in diameter measured from the inner cellular boundary across the longest axis. Percentages of females with primordial follicle loss or polycystic ovarian disease were computed. Analysis of Puberty Onset Onset of puberty was assessed in females by daily examination for vaginal opening from 30 days of age and in males by balano- preputial separation from 35 days of age. For identifying a rat with a pubertal abnormality the mean from all the rats in control lineage evaluated for pubertal onset was computed and its standard deviation calculated. A range of normal pubertal onset was chosen based on the mean ±2 standard deviations. Any rat with a pubertal onset below this range was considered to have had an early pubertal onset and any rat with a pubertal onset above this range was considered to have had a delayed pubertal onset. The proportion of rats with pubertal abnormalities was computed from the total number of rats evaluated. Overall Disease/abnormality Incidence A table of the incidence of individual diseases/abnormalities in rats from each lineage was created and the proportion of individual disease, total disease and multiple disease incidences was computed. For the individual diseases, only those rats that showed a presence of histopathology (plus) or absence of disease (minus) are included in the computation, Supplemental Tables S3 and S3. For the total diseases/abnormalities, a column with total number of diseases for each rat was created and the number of plus signs were added up for each of the rats and the proportion was computed as the number of rats with total disease out of all the listed rats. For the multiple diseases/abnormalities, the proportion was computed as the number of rats with multiple histopathology out of all the listed rats. Epididymal Sperm Collection, Sperm Head Purification, DNA Isolation and Methylated DNA Immunoprecipitation (MeDIP) The epididymis was dissected free of connective tissue, a small cut made to the cauda and placed in 5 ml of F12 culture medium containing 0.1% bovine serum albumin for 10 minutes at 37°C and then kept at 4°C to immobilize the sperm. The epididymal tissue was minced and the released sperm centrifuged at 13, 000 xg and stored in fresh buffer at —20°C until processed further. Sperm heads were separated from tails through sonication following previously described protocol (without protease inhibitors) [72] and then purified using a series of washes and centrifugations [73] from a total of nine F3 generation rats per lineage (control or dioxin) that were 120 days of age. DNA extraction on the purified sperm heads was performed as previously described [4]. Equal concentrations of DNA from three individual sperm samples were used to produce three DNA pools per lineage and employed for PLOS ONE I www.plosone.org 12 September 2012 I Volume 7 I Issue 9 I e46249 Dioxin Induced Transgenerational Disease methylated DNA immunoprecipitation (MeDIP). MeDIP was performed as previously described [4,5]. MeDIP-Chip and MeDIP-PCR Analysis The comparative MeDIP-Chip was performed with Roche Nimblegen's Rat DNA Methylation 3 x720 K CpG Island Plus RefSeq Promoter Array, which contains three identical sub -arrays, with 720,000 probes per sub -array, scanning a total of 15,287 promoters (3,880 bp upstream and 970 bp downstream from transcription start site). Probe sizes range from 50-75 bp in length with the median probe spacing of 100 bp. Three different comparative (MeDIP vs. MeDIP) hybridization experiments were performed (3 sub -arrays) for dioxin lineage versus control, with each subarray encompassing DNA samples from 6 animals (3 each from dioxin and control). MeDIP DNA samples from experimen- tal lineages were labeled with Cy3 and MeDIP DNA samples from the control lineage were labeled with Cy5. The MeDIP = PCR was used to confirm the MeDIP-Chip analysis observations using two genes. The MeDIP genomic DNA was used for a semiquantitative PCR involving 30 cycles and primers specific to the DMR sites. The genes and primers used were: Hdac3, 3'TGGCGTATTTCTACGACCCC, 5 ' GGAATGTTTC C GGT GC CTTC and. Npc2, 3'AGAATGCTTCCACTTGCCGA, 5'CTCACCG- CAGTCCTTGAAGT. The PCR density for control versus dioxin lineage F3 generation sperm MeDIP samples from three different experi- ments were determined and normalized for fold change. A mean ± SEM was determined and statistical differences assessed with a U-Mann Whitney analysis. Bioinformatic and Statistical Analyses of Chip Data The bioinformatic analysis was performed as previously described [4,5]. The statistical analysis was performed in pairs of comparative IP hybridizations between dioxin (D) and controls (C) (e.g. DI-C1 and D2-C2; D1-C1 and D3-C3; D2-C2 and D3-C3). In order to assure the reproducibility of the candidates obtained, only the candidates showing significant changes in all of the single paired comparisons were chosen as a having a significant change in DNA methylation between dioxin lineage and control lineage. This is a very stringent approach to select for changes, since it only considers repeated changes in all paired analyses. Clustered Regions of interest were then determined by combining consec- utive probes with changed signal within 600 bases of each other, and based on whether their mean M values were positive or negative, with significance P-values less than 10-5. The statistically significant differential DNA methylated regions were identified and P-value associated with each region presented. Each region of interest was then annotated for gene and CpG content. This list was further reduced to those regions with an average intensity value exceeding 9.5 (log scale) and a CpG density > 1 CpG/ 100 bp. Associations between genes containing DMR and particular physiologic cellular processes were determined by an automated, References 1. Skinner MK, Manikkam M, Guerrero-Bosagna C (2010) Epigenetic transge- nerational actions of environmental factors in disease etiology. Trends Endocrinol Metab 21: 214-222. 2. Anway MD, Cupp AS, Uzumcu M, Skinner MK (2005) Epigenetic transgenerational actions of endocrine disruptors and male fertility. Science 308: 1466-1469. 3. Reik W, Dean W, Walter J (2001) Epigenetic reprogramming in mammalian development. Science 293: 1089-1093. unbiased survey of published literature using Pathway StudioTM software (Ariadne, Elsevier Inc., USA). Signaling pathway enrichment with genes containing DMR was determined by querying the library of KEGG pathways (Kyto Encyclopedia of Genes and Genomes, http://www.genomejp/kegg/pathway. html). Statistical Analysis of Rat Organ and Disease Data For statistical analysis, all the data on body and organ weights were used as input in the program GraphPad© Prism 5 statistical analysis program and t-tests were used to determine if the data from the dioxin lineage differ from those of control lineages. For the number of rats with disease, logistic regression analysis was used to analyze the data (control or dioxin and diseased or unaffected). All treatment differences were considered significant if P value was less than 0.05. Supporting Information Figure Si Dioxin and transgenerational endocrine effects. A. Control and dioxin F3 generation lineage serum testosterone concentrations. Testosterone concentrations (ng/dl) in F3 gener- ation control and dioxin lineage male rats. B. Serum estradiol concentrations in proestrus-estrus in F3 generation control and dioxin lineage females. C. Serum estradiol concentrations in diestrus in F3 generation control and dioxin lineage females. D. Testicular spermatogenic cell apoptosis. Number of apoptotic germ cells normalized to control means in control (open bars) and dioxin (black bars) lineage (**PG0.01). (PDF) Table Si. (PDF) Table S2. (PDF) Table S3. (PDF) Table S4. (PDF) Acknowledgments We thank the expert technical assistance of Dr. Eric Nilsson, Dr. Marina Savenkova, Ms. Renee Espinosa Najera, Ms. Jessica Shiflett, Ms. Ginger Beiro, Ms. Chrystal Bailey, Ms. Colleen Johns, Mr. Trevor Covert and Ms. Sean Leonard. We acknowledge the helpful advice of Dr. David Jackson and Dr. John Lewis, US Army Center for Environmental Health Research, Department of Defense (DOD), and the leadership at the DOD TATRC. Author Contributions Conceived and designed the experiments: MKS. Performed the experi- ments: MM RT CGB. Analyzed the data: MKS MM RT CGB. Wrote the paper: MKS MM. Edited the manuscript: MKS MM RT CGB. 4. Guerrero-Bosagna C, Settles M, Lucker B, Skinner M (2010) Epigenetic transgenerational actions of vinclozolin on promoter regions of the sperm epigenome. PLoS ONE 5: e13100. 5. Manikkam M, Guerrero-Bosagna C, Tracey R, Hague MM, Skinner MK (2012) Transgenerational Actions of Environmental Compounds on Reproduc- tive Disease and Epigenetic Biomarkers of Ancestral Exposures. PLoS ONE 7: e31901. PLOS ONE I www.plosone.org 13 September 2012 I Volume 7 I Issue 9 I e46249 Dioxin Induced Transgenerational Disease 6. 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Li X, Johnson DC, Rozman KK (1995) Reproductive effects of 2,3,7,8- tetrachlorodibenzo-p-dioxin (TCDD) in female rats: ovulation, hormonal regulation, and possible mechanism(s). Toxicol Appl Pharmacol 133: 321-327. 42. Moran FM, Tarara R, Chen J, Santos S, Cheney A, et al. (2001) Effect of dioxin on ovarian function in the cynomolgus macaque (M. fascicularis). Reprod Toxicol 15: 377-383. 43. Flaws JA, Sommer RJ, Silbergeld EK, Peterson RE, Hirshfield AN (1997) In utero and lactational exposure to 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) induces genital dysmorphogenesis in the female rat. Toxicol Appl Pharmacol 147: 351-362. 44. Gray LE Jr, Ostby JS (1995) In utero 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) alters reproductive morphology and function in female rat offspring. Toxicol Appl Pharmacol 133: 285-294. 45. Heimler I, Trewin AL, Chaffin CL, Rawlins RG, Hutz RJ (1998) Modulation of ovarian follicle maturation and effects on apoptotic cell death in Holtzman rats exposed to 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) in utero and lactation - ally. Reprod Toxicol 12: 69-73. 46. Gao X, Son DS, Terranova PF, Rozman KK (1999) Toxic equivalency factors of polychlorinated dibenzo-p-dioxins in an ovulation model: validation of the toxic equivalency concept for one aspect of endocrine disruption. Toxicol Appl Pharmacol 157: 107-116. 47. Kociba RJ, Keeler PA, Park CN, Gehring PJ (1976) 2,3,7,8-tetrachlorodibenzo- p-dioxin (TCDD): results of a 13-week oral toxicity study in rats. Toxicol Appl Pharmacol 35: 553-574. 48. Roby KF (2001) Alterations in follicle development, steroidogenesis, and gonadotropin receptor binding in a model of ovulatory blockade. Endocrinology 142: 2328-2335. 49. Roby K (2000) Mechanisms of TCDD-mediated inhibition of ovulation [Abstract] Biol Reprod 62: 284. 50. Salisbury TB, Marcinkiewicz JL (2002) In utero and lactational exposure to 2,3,7,8-tetrachlorodibenzo-p-dioxin and 2,3,4,7,8-pentachlorodibenzofuran re- duces growth and disrupts reproductive parameters in female rats. Biol Reprod 66: 1621-1626. 51. Silbergeld EK, Mattison DR (1987) Experimental and clinical studies on the reproductive toxicology of 2,3,7,8-tetrachlorodibenzo-p-dioxin. Am J Ind Med 11: 131-144. 52. Son DS, Ushinohama K, Gao X, Taylor CC, Roby KF, et al. (1999) 2,3,7,8- Tetrachlorodibenzo-p-dioxin (TCDD) blocks ovulation by a direct action on the ovary without alteration of ovarian steroidogenesis: lack of a direct effect on ovarian granulosa and thecal-interstitial cell steroidogenesis in vitro. Reprod Toxicol 13: 521-530. 53. Umbreit TH, Hesse EJ, Gallo MA (1987) Reproductive toxicity in female mice of dioxin -contaminated soils from a 2,4,5-trichlorophenoxyacetic acid manu- facturing site. Arch Environ Contam Toxicol 16: 461-466. 54. Mattison DR (1980) Morphology of oocyte and follicle destruction by polycyclic aromatic hydrocarbons in mice. Toxicol Appl Pharmacol 53: 249-259. 55. Davis BJ, McCurdy EA, Miller BD, Lucier GW, Tritscher AM (2000) Ovarian tumors in rats induced by chronic 2,3,7,8-tetrachlorodibenzo-p-dioxin treat- ment. Cancer Res 60: 5414-5419. 56. Eskenazi B, Warner M, Marks AR, Samuels S, Gerthoux PM, et al. (2005) Serum dioxin concentrations and age at menopause. Environ Health Perspect 113: 858-862. 57. Xu N, Azziz R, Goodarzi MO (2010) Epigenetics in polycystic ovary syndrome: a pilot study of global DNA methylation. Fertil Steril 94: 781-783 e781. 58. Xu N, Kwon S, Abbott DH, Geller DH, Dumesic DA, et al. (2011) Epigenetic mechanism underlying the development of polycystic ovary syndrome (PCOS)- like phenotypes in prenatally androgenized rhesus monkeys. PLoS ONE 6: e27286. PLOS ONE I www.plosone.org 14 September 2012 I Volume 7 I Issue 9 I e46249 Dioxin Induced Transgenerational Disease 59. DiVall SA, Radovick S (2009) Endocrinology of female puberty. Curr Opin Endocrinol Diabetes Obes 16: 1-4. 60. Jacobson -Dickman E, Lee MM (2009) The influence of endocrine disruptors on pubertal timing. Curr Opin Endocrinol Diabetes Obes 16: 25-30. 61. Kakeyama M, Sone H, Tohyama C (2008) Perinatal exposure of female rats to 2,3,7,8-tetrachlorodibenzo-p-dioxin induces central precocious puberty in the offspring. J Endocrinol 197: 351-358. 62. Traggiai C, Stanhope R (2003) Disorders of pubertal development. Best Pract Res Clin Obstet Gynaecol 17: 41-56. 63. Warner M, Samuels S, Mocarelli P, Gerthoux PM, Needham L, et al. (2004) Serum dioxin concentrations and age at menarche. Environ Health Perspect 112: 1289-1292. 64. Wolff MS, Britton JA, Russo JC (2005) TCDD and puberty in girls. Environ Health Perspect 113: A17; author reply A18. 65. Jirtle RL, Skinner MK (2007) Environmental epigenomics and disease susceptibility. Nat Rev Genet 8: 253-262. 66. Nilsson EE, Anway MD, Stanfield J, Skinner MK (2008) Transgenerational epigenetic effects of the endocrine disruptor vinclozolin on pregnancies and female adult onset disease. Reproduction 135: 713-721. 67. Stouder C, Paoloni-Giacobino A (2010) Transgenerational effects of the endocrine disruptor vinclozolin on the methylation pattern of imprinted genes in the mouse sperm. Reproduction 139: 373-379. 68. Rassoulzadegan M, Grandjean V, Gounon P, Vincent S, Gillot I, et al. (2006) RNA -mediated non-mendelian inheritance of an epigenetic change in the mouse. Nature 441: 469-474. 69. Wagner KD, Wagner N, Ghanbarian H, Grandjean V, Gounon P, et al. (2008) RNA induction and inheritance of epigenetic cardiac hypertrophy in the mouse. Dev Cell 14: 962-969. 70. Nilsson EE, Schindler R, Savenkova MI, Skinner MK (2011) Inhibitory actions of Anti-Mullerian Hormone (AMH) on ovarian primordial follicle assembly. PLoS ONE 6: e20087. 71. Meredith S, Dudenhoeffer G, Jackson K (2000) Classification of small type B/C follicles as primordial follicles in mature rats. J Reprod Fertil 119: 43-48. 72. Tateno H, Kimura Y, Yanagimachi R (2000) Sonication per se is not as deleterious to sperm chromosomes as previously inferred. Biol Reprod 63: 341- 346. 73. Ward WS, Kimura Y, Yanagimachi R (1999) An intact sperm nuclear matrix may be necessary for the mouse paternal genome to participate in embryonic development. Biol Reprod 60: 702-706. PLOS ONE I www.plosone.org 15 September 2012 I Volume 7 I Issue 9 I e46249 BIOLOGY VIM= Harmful emicals, stress and other influences can ermanently alter which genes are turned on without changing any of the genes' code. Now, it a • • ears, some of these "e • igenetic" changes are • assed down to and may cause disease in future generations By Michael K Spinner August 2014, ScientificAmerican.com 45 © 2014 Scientific American w Michael K. Skinner is a professor of biology at Washington State University. He has published more than 250 peer -reviewed articles, including dozens of studies on epigenetic transgenerational inheritance. f His Web site is at http://skinnerwsu.edu HEN MY KIDS WERE BORN, ABOUT 30 YEARS AGO, I KNEW THEY HAD INHERITED ABOUT half their DNA from me. At the time, the transfer of DNA from sperm or egg to an embryo was thought to be the only way that heritable information could flow from parents to children, at least in humans and other mammals. Of course, I understood that DNA is not destiny. Yes, many characteristics of a child may be written into his or her DNA and specifically into protein -coding genes —the sequences of DNA code that dictate the shapes and functions of proteins, the work- horses of the cell. But nurture matters, too. Many of the contin- gencies of life —what we eat, what pollutants are in our environ- ment, how often we are stressed —affect how the genes operate. Social and environmental influences are often invoked, for in- stance, to explain why identical twins can end up with different diseases despite having highly similar complements of genes. But we did not know back then that our biological bequest to our children includes more than just our DNA sequences —that, indeed, not just our kids but our grandchildren and great- grandchildren might inherit what is known as epigenetic infor- mation. Like DNA, epigenetic information resides in our chro- mosomes (which house our genes) and regulates cellular functions. But it is distinct from the DNA sequence and re- sponds to the environment. It can take various forms, including small molecules that attach chemically to the DNA and to pro- teins in chromosomes. Research at my laboratory and others, mainly on rats and mice, has found that certain pollutants —including agricultural chemicals, jet fuel and even some common plastics —can induce epigenetic modifications that cause disease and reproductive problems, all without changing the sequence of the animals' DNA. More startlingly, when such epimutations occur in the cells that give rise to eggs and sperm, they can apparently become fixed in place and then transmitted —along with any resulting health risks —to later generations. The science in this area is evolving rapidly, and long-term studies in people now hint that epimutations may pass from gen- eration to generation in humans as well. Given the many aspects of biology that we share with other mammals, it seems reason- able to expect that such epigenetic transgenerational inheritance does occur in people. If so, the implications for public health The actions of genes can be regulated by "epigenetic" factors, such as chemicals that attach to DNA and proteins in chromosomes and that encode informa- tion independently from the DNA sequence. Most epigenetic marks reset shortly after conception. could be profound. Some part of the increases in obesity, diabetes and other fast -rising diseases among baby boomers and more recent generations might have originated with their parents' and grandparents' exposure to pollutants such as DDT and dioxin. THE DARK MATTER OF THE GENOME EPIGENETIC EFFECTS ON CELLS have been recognized for some time, but the extent of their involvement has become clear only recent- ly. Decades ago biologists noticed that lots of places in mammali- an DNA have a methyl (CH3) radical attached to them [see box on pages 48 and 49]. In humans, this epigenetic mark often occurs where a cytosine (C) code letter precedes a guanine (G) in the DNA sequence, which happens at about 28 million spots along the chromosomes. Scientists first thought that the main func- tion of DNA methylation was to shut down transposons—dan- gerous stretches of DNA that can move themselves from their original positions on the chromosomes to other parts of the genome, sometimes in ways that cause disease. We now know that methylation also helps regulate the activity of normal genes and that it goes awry in many cancers and other disorders. In the 1990s researchers began to work out the operation of more kinds of epigenetic marks. They found that methyl, acetyl and several other chemical modifications can tag beadlike struc- tures composed of a group of proteins called histones. The DNA in chromosomes wraps around each histone bead. By control- ling how tightly the DNA loops around the histone groups and whether adjacent beads spread apart or bunch up, the histone marks can effectively turn entire sets of genes on and off. Genes in tightly wound areas, for instance, get hidden from proteins that switch on gene activity Other epigenetic actors have since emerged, including the ever shifting, three-dimensional structure of the DNA and chromo- somes and a number of RNA varieties known as noncoding RNAs. Some of these RNAs interact with the epigenetic marks that sit on DNA and the histones. (They are called noncoding to distinguish IN BRIEF Pollutants, stress, diet and other environmental fac- tors can cause persistent changes in the mix of epi- genetic marks in chromosomes and, in that way, can alter how cells and tissue behave. Surprisingly, some acquired changes can be passed on to descendants. Conceivably, the health of both you and your children may be affected by whatyour great-grandmother was exposed to during pregnancy. Epigenetic inheritance might play a role in health problems such as obesity and diabetes, as well as in the evolution of species. PRECEDING PAGES: CHRIS FR 46 Scientific American, August 2014 © 2014 Scientific American them from the RNA strands that get copied from DNA to serve as templates for making the proteins encoded by genes.) Together these epigenetic actors influence gene activity in complex ways that are independent of the DNA sequence. The interplay between the genes and the epigenome is dynamic and still rather mysterious. We do know, however, that each time a cell replicates, the epigenetic marks in its chromosomes get copied into the chromosomes of the daughter cells. Epigenetic events early in life can thus alter how cells behave later on. We also know that whereas cells work hard to protect the sequence of DNA in the chromosomes from any alterations, they revise the patterns of epigenetic marks during an organism's development and aging. These changes help to determine how cells specialize to become, for example, a skin cell or a brain cell; subtle shifts in epigenetic information modify which genes are As the great -great -grand - pups matured, the males suffered problems similar to those of their distant ancestors. All from a fleeting dose of widely used agricultural chemicals. active in each part of the body. Harmful chemicals, nutrient de- ficiencies and other stresses can also cause epigenetic marks to be added or removed in ways that affect gene activity. Today no one doubts that epigenetic effects play a crucial role in development, aging and even cancer. But biologists debate whether epimutations—abnormal epigenetic changes —can be passed down through many generations in mammals. Evidence from a rapidly growing number of experiments, by my group and many others, has convinced me that they can. ACCIDENTAL INHERITANCE MY FIRST GLIMPSE of multigenerational epimutations was a prod- uct of serendipity. About 13 years ago Andrea Cupp and I, with a few of our colleagues at Washington State University, were using rats to study the reproductive effects of two chemicals widely applied in farming —the pesticide methoxychlor and the fungi- cide vinclozolin. Like many agricultural chemicals, they are en- docrine disruptors: they interfere with the hormonal signals that help to direct the formation and operation of the reproduc- tive system. We had injected the chemicals into pregnant rats during the second week of gestation —when the embryo's gonads develop —and saw that nearly all male offspring grew up to have abnormal testes that make weak sperm and too few of them. We were not thinking about epigenetics at the time, and it never occurred to us that these defects might be heritable, so we had no plan to breed the rats that had been exposed to methoxy- chlor or vinclozolin while in the womb. But one day Cupp came into my office to apologize: by mistake, she had mated unrelated male and female pups from that experiment. I told her to check the grandchildren of the exposed dams for defects, although I did not expect she would find any. To our amazement, more than 90 percent of the males in these litters showed the same testicular abnormalities as their fathers, even though their parents were just pinhead -sized fetuses when they and their grandmothers were briefly exposed. This result was surprising because many toxicology studies had looked for evidence that environmental chemicals such as vinclozolin cause DNA mutations but had found none. We con- firmed ourselves that the frequency of genetic mutations was not elevated in the rats exposed to the agents. Moreover, classical genetics could not explain a new trait that appears with 90 per- cent frequency in different families. I knew, however, that the minuscule fetus con- tains primordial germ cells, which are the progeni- tor cells that give rise to sperm or eggs. Most likely, I thought, the chemical had directly influenced these progenitor cells, and this effect simply per- sisted as the cells divided into sperm or eggs —and eventually into grandchildren. If this were the case, then the brief chemical exposure caused the grandpups' testicular problems directly, and future generations should be perfectly normal. There was one sure test to find out whether direct influence was to blame. We bred a fourth generation and then a fifth, each time mating unre- lated descendants of the original exposed rats to avoid diluting the trait. As the great -grandchil- dren —and later the great -great -grandchildren — matured, the males of each generation suffered problems similar to those of their ancestors. All these changes stemmed from a fleeting (but unnaturally high) dose of agricul- tural chemicals that for decades were sprayed on fruits, vegeta- bles, vineyards and golf courses. I was shocked by these results. Over several years we repeated the experiments multiple times to confirm them and collect addi- tional evidence. The most plausible explanation, we concluded, was that the exposure causes an epimutation that interferes with gonad development in male embryos —and this epimutation passes from sperm to the cells of a developing embryo, including to primordial germ cells, and so on for generations. In 2005 we published these results in Science, along with our epimutation hypothesis and tantalizing but preliminary supportive evidence that exposure to the fungicide had altered methylation at several important spots in the DNA of the descendants' sperm. TROUBLING IMPLICATIONS A TEMPEST OF DEBATE ensued. One reason was that researchers at companies that sell vinclozolin, as well as a nonindustry study, reported difficulty reproducing some of our results —probably because they used different experimental methods, such as giv- ing the chemical orally, using inbred strains of rats, or breeding the affected males with those from an unexposed control lin- eage, a practice that depresses the trait substantially in subse- quent generations. In recent years, however, evidence has accumulated that epi- August 2014, ScientificAmerican.com 47 © 2014 Scientific American FINDINGS Inheritance outside the Genes Biologists have discovered that the life experiences of animals and plants —such as exposure to certain pollutants or stressful events — can affect the health of their descendants without mutating their DNA. Such exposures can have multigenerational effects on children Epigenetics in a Nutshell Genetic information is encoded by stretches of DNA inside the chromosomes of each cell. But another layer of information is encoded in epigenetic marks, which include chemicals such as methyl (CH3) that attach to the DNA and to the histone groups that the DNA encircles. When these epigenetic marks bind to DNA in or near genes, they often alter the amount of RNA or protein made from the genes. Sequence of DNA "code letters" Methyl and grandchildren through their direct actions on sperm, eggs and other reproductive cells. But transgenerational epigenetic inheritance, via heritable alterations to chemicals attached to the DNA inside these cells, can affect even more distant descendants. Ways That Epigenetic Traits Can Persist for Multiple Generations The direct effects of exposure to a pollutant or stressor can cause multigenerational but nonheritable traits in two generations if the exposure occurs to a male and his sperm or in up to three generations if it occurs to a female at a particular stage of pregnancy (blue highlighting on opposite page). For an epigenetic trait to be inherited by subsequent generations (red), altered marking must survive two distinct waves of reprogramming (below) after conception. Both waves remove most epigenetic tags from the chromosomes and later rewrite them afresh. Rodent studies indicate that such persistence is possible. Sperm Male exposed to stress or pollutant Stress or pollutant rican, August 2014 The first wave of epigenetic reprogramming happens just days after conception, when the embryo is a tiny ball of cells. Pregnant female exposed to stress or pollutant Early embryo at eight -cell stage Inside the fetus, primordial germ cells —precursors to eggs and sperm —may suffer direct exposure. A second reprogramming event resets most epigenetic marks on these cells to ensure that only genes appropriate to the gender of the fetus are activated. © 2014 Scientific American Histone group Acetyl and other chemical modifiers Fetus directly exposed to stress _ or pollutant •4* Illustration by Emily Cooper Multigenerational direct effect on eggs or sperm produced by exposed primordial germ cells Pups New traits in the pups could be explained by the direct exposure that occurred to their father's sperm or to their mother while they were in the womb. If the pups' primordial germ cells were exposed, then their eggs or sperm may also be tainted by such direct effects and could be passed on to grandpups. Such direct effects are not, strictly speaking, inherited. Multigenerational direct effect if exposure occurred when a grandmother was pregnant Transgenerational inheritance if only a male ancestor was exposed Transgenerational inheritance from an ancestor of either sex Transgenerational inheritance from an ancestor of either sex Grandpups Truetransgenerational inheritance can appear in the third generation if the exposure occurred to a male grandparent. Studies to date have observed this phenomenon for several kinds of exposures. Ancestral exposure: Fear conditioning to an unfamiliar odor Inherited trait: Heightened startle response when the odor is present Ancestral exposure: High -fat diet and a drug that causes prediabetes Inherited trait: Glucose intolerance and insulin resistance Great-Grandpups In most studies of this phenomenon, researchers expose pregnant females to a toxic compound or stressful condition. They must then breed at least fourth -generation offspring to prove that new traits are truly heritable. Ancestral exposure: Methoxychlor; vinclozolin Inherited trait: Reduced sperm count and motility; heightened anxiety in females Ancestral exposure: Dioxin Inherited trait: Low testosterone in males; infertility or premature delivery in females Ancestral exposure: Bisphenol A (BPA) Inherited trait: Low testosterone in males; abnormal ovaries or early puberty in females Ancestral exposure: Jet fuel; DDT Inherited trait: High rates of obesity; polycystic ovarian disease Great-Great-Grandpups A few studies have continued on to a fifth generation and found that some effects persisted. Ancestral exposure: Vinclozolin; DDT Inherited trait: Prostate, kidney and testicular disease in males; obesity in males; ovarian disease in females August 2014, ScientificAmerican.com 49 © 2014 Scientific American mutations can persist for several genera- tions. Follow-up studies at my lab have shown that the great-grandchildren of fun- gicide -treated rats have consistently al- tered patterns of methylation in their sperm, testes and ovaries, as well as abnor- mal gene activity in their primordial germ cells. We also found that fourth -generation offspring are prone to weight gain and anx- iety; they even select mates differently. Meanwhile we and other scientists have added more pollutants and stressors to the list of factors that induce the effect, and transgenerational inheritance of acquired characteristics has been observed in a wide range of species, including plants, flies, worms, fish, rodents and pigs. My team reported in 2012 that expo- sure of pregnant rats to either the pollut- ant dioxin, jet fuel, insect repellent, or a combination of bisphenol A (BPA) and phthalates —chemical components of plas- tics in food containers and tooth fillings — induce a variety of heritable disorders in fourth -generation descendants, such as pubertal abnormalities, obesity, and diseases of the ovaries, kid- neys and prostate. We have observed hundreds of exposure -spe- cific changes in DNA methylation patterns in sperm. The effects do not follow the inheritance patterns of classical genetics, so we believe that epimutations, not mutations to the DNA sequence, are causing these disorders. Kaylon Bruner-Tran and Kevin Osteen of the Vanderbilt Uni- versity School of Medicine also studied dioxin's effects on mice and found that about half of the daughters of exposed dams were infertile; among those that could get pregnant, many had premature deliveries. These problems conceiving and gestating persisted for at least two more generations. The chemical doses in these studies are much larger than one would typically receive from a contaminated environment, but research by Jennifer Wolstenholme and others at the University of Virginia School of Medicine reported transgenerational effects from doses that are more comparable to human experi- ence. They found that when mice were given enough BPA in their food to produce blood levels similar to those measured in pregnant American women, their descendants out to the fifth generation spent less time exploring their cages and more time interacting with other mice. The researchers suspect that the personality shift was caused by altered activity of the genes for oxytocin and vasopressin, both of which are known to affect social behavior. Although it seems likely that, as in our study on BPA, the effects coincide with altered DNA methylation pat- terns, the evidence for this association is still indirect. Other kinds of epigenetic changes could also be involved. Studies are now under way that may be able to determine whether epimutations affect multiple generations of people as they do rodents. One such investigation is following up on an unfortunate natural experiment. In 1976 an explosion at a chem- ical plant in Seveso, Italy, exposed nearby residents to the high- est concentrations of dioxin ever recorded in a public release of FOGGING WITH DDT, a common mosquito -control practice in the 1940s and 1950s, might have caused epimutations that persist even in some babies born today. this chemical. Scientists measured the amount of dioxin circu- lating in the blood of nearly 1,000 affected women and have fol- lowed them to observe their health. In 2010 the researchers reported that for each 10-fold increase in a woman's exposure to dioxin during the accident, the average time needed to get pregnant rose by 25 percent, and the risk of infertility doubled. The team also observed in 2013 that women who were younger than 13 years at the time of the accident had, as adults, double the normal risk of developing metabolic syn- drome —a collection of conditions, such as elevated blood pres- sure and blood glucose, that together predispose people to diabe- tes and heart disease. They found that many granddaughters of exposed women have abnormal results on thyroid tests. Given that reproductive and metabolic disorders seem to be the most common kinds of ailments transmitted via the epig- enome in lab animals, these findings hint that dioxins may pro- mote epimutations in humans The suspicion will be strength- ened if, in years to come, the children and grandchildren of the exposed women show higher rates of infertility, obesity and related conditions —and show abnormal methylation patterns. Capitalizing on another natural experiment, Marcus Pembrey of University College London, Lars Olov Bygren of the Karolinska Institute in Stockholm and their colleagues have done an intrigu- ing series of studies using data from about 300 people born in 1890, 1905 and 1920 in Overkalix, Sweden, as well as their par- ents and grandparents. The researchers compared death records for the study subjects against reconstructed estimates of food supply in the town, which went through several two-year periods during the 19th century when good harvests were followed by crop failures. It appears that women whose paternal grandmoth- ers experienced one of these feast -famine swings as young chil- dren had markedly higher rates of fatal cardiovascular disease. Curiously, the increased risk was not seen for men, nor for women whose maternal grandmother or grandfathers endured 0 SCIENTIFICAMERICAN ONLINE Watch a video of Skinner talking about epigenetic inheritance at ScientificAmerican.com/aug2014/epigenetics © 2014 Scientific American a rapid dive into food scarcity. For various reasons, such an odd inheritance pattern strongly suggests that epigenetics are at work and, in particular, a phenomenon known as imprinting. Similar observations have been made in descendants of a Dutch population that experienced famine during World War II. THE EPIGENETIC IMPRINT OF PARENTHOOD DESPITE THE MOUNTING evidence, many biologists still recoil from the idea that environmentally induced epimutations can settle into the germ line. The hypothesis seems to contradict a long- established belief that nearly all epigenetic marks are erased from the DNA and then rewritten during the reproductive pro- cess —not just once but twice. These processes, the reasoning goes, should wipe clean any acquired epimutations before they can cause trouble in the next generation. This same logic is anoth- er reason that our 2005 findings met with such a firestorm. The erasures do occur, but just how thoroughly is an open question. The first wave of removal happens within days after concep- tion. Methyl marks are stripped from the chromosomes —a pro- cess that confers on the embryonic stem cells the ability to give rise to every kind of cell. The tags are then added back while the fetus starts to develop. As the cells divide and specialize, distinc- tive patterns of DNA methylation appear in each cell type and help to tailor the cells to fit their particular functions. Something shields a few special genes from this first wave of epigenetic erasure, however. Biologists refer to these genes as maternally or paternally "imprinted" because the epigenetic marks are preserved and guarantee that only the mother's copy or the father's copy of the gene gets used for making a protein. For example, in my children the gene IGF2, which encodes a hormone important for fetal growth, is active only on the chro- mosome they inherited from me. The copy of the gene from their mother is shut down by the combined action of DNA meth- ylation and a form of noncoding RNA. The second wave of epigenetic erasure and reprogramming begins later, when a rat fetus is the size of a pinhead and a human fetus is the size of a pea. This is when primordial germ cells start to appear inside the embryo's newly formed gonads — and when we administer vinclozolin or other pollutants to lab animals in our experiments on epigenetic inheritance. In rats, this period lasts about a week; in humans, it stretches from the sixth to the 18th week of pregnancy. This second wave is thought to be essentially complete — methyl marks are stripped off even the imprinted genes in the precursor cells to eggs and sperm. Later, however, marks are add- ed again to establish the sex -appropriate pattern: in females, the chromosomes that will end up in eggs get a maternal methylation pattern, whereas in males, the chromosomes that will end up in sperm get a paternal pattern. The process avoids any offspring receiving two inactivated or two activated copies of imprinted genes when what it needs is one active and one inactive copy. The same mechanism that reestablishes tags on imprinted genes might be influenced by environmental insults to fix new epimutations into the germ line. If an exposure —whether to a pollutant, a hormonal imbalance brought on by stress, or a nutri- tional deficiency that affects methylation—hits the embryo when that second sweep is about to begin, it might alter which epigene- tic tags are brushed away forever and which are spared the broom or reset at the end of the reprogramming phase. Most epimutations probably have little consequence or get corrected in the next generation, but every rule has an excep- tion. If an epimutation in a germ -line cell becomes protected from the reprogramming of the epigenome, in much the same way that an imprinted gene is, it may hang on to affect the next generation —and perhaps many generations down the line. If this idea is correct, epigenetic inheritance could have important consequences for medicine. Some scientists are inves- tigating whether "obesogens"—environmental chemicals that upset human metabolism in ways that induce weight gain — might increase the risk of obesity in heritable ways. Bruce Blum- berg and his colleagues at the University of California, Irvine, showed last year that pregnant mice that drank water laced with tributyltin, widely used to keep barnacles off ship hulls, bore pups prone to developing extra fat cells and fatty livers. The changes persisted for two more generations, an effect that is most easily explained by an epimutation. Thus, although shifts in lifestyle and food availability no doubt account for much of the increase in obesity, diabetes and other "rich -country" diseas- es over the past 50 years, it is conceivable that ancestral expo- sures have increased our susceptibility to such diseases. In countries like the U.S. where children in the 1940s and 1950s were exposed to DDT, for example, it might be significant that when we injected animals with DDT, we found that more than half of the fourth -generation great-grandpups developed obesity —even though the second -generation offspring were nor- mal in size —and that epigenetics seemed to be at fault. In three generations since the 1950s, the obesity rate among American adults has risen dramatically and now exceeds 35 percent. If the environment can sometimes directly produce long- term, transgenerational changes in gene activity without first altering the DNA coding sequence, then the classical view of evolution —as a slow product of random mutations that get "selected" because of the reproductive or survival advantage they offer —will have to be expanded. It is even conceivable that epigenetic inheritance could explain why new species emerge more often than one would expect, given the rarity of advanta- geous genetic mutations. Epigenetic changes appear to occur 1,000 times more frequently. The most important effect of epi- genetic marks —maybe their reason for existing —might be to wildly expand the number of variant individuals in a popula- tion. Natural selection would then pick the best adapted among them to thrive and carry on—genome, epigenome, and all. MORE TO EXPLORE Epigenetic Transgenerational Actions of Environmental Factors in Disease Etiology. Michael K. Skinner, Mohan Manikkam and Carlos Guerrero-Bosagna in Trends in Endocrinology and Metabolism, VoI.21, No. 4, pages 214-222; April 2010. Understanding Transgenerational Epigenetic Inheritance via the Gametes in Mammals. Lucia Daxinger and Emma Whitelaw in Nature Reviews Genetics, Vol.13, No. 3, pages 153-162; March 2012. Genomic Imprinting in Mammals. Denise P. Barlow and Marisa S. Bartolomei in Cold Spring Harbor Perspectives in Biology, Vol. 6, No.2, Article No. a018382; February 1, 2014. FROM OUR ARCHIVES The Unseen Genome: Beyond DNA. W. Wayt Gibbs; December 2003. Hidden Switches in the Mind. Eric.). Nestler, December2011. scientificamerican.com/magazine/sa © 2014 Scientific American August 2014, ScientificAmerican.com 51 _ • ENVIRONMENTAL EPIGENETICS Environmental Epigenetics, 2018, 1-13 doi: 10.1093/eep/dvy016 Review article REVIEW ARTICLE Environmentally induced epigenetic transgenerational inheritance of disease Eric E. Nilsson, Ingrid Sadler-Riggleman and Michael K. Skinner* Center for Reproductive Biology, School of Biological Sciences, Washington State University, Pullman, WA 99164-4236, USA *Correspondence address. Center for Reproductive Biology, School of Biological Sciences, Washington State University, Pullman, WA 99164-4236, USA. Tel: +1-509-335-1524; Fax: +1-509-335-2176; E-mail: skinner@wsu.edu Managing Editor: Isabelle Mansuy Abstract Ancestral environmental exposures such as toxicants, abnormal nutrition or stress can promote the epigenetic transge- nerational inheritance of disease and phenotypic variation. These environmental factors induce the epigenetic reprogram- ming of the germline (sperm and egg). The germline epimutations can in turn increase disease susceptibility of subsequent generations of the exposed ancestors. A variety of environmental factors, species and exposure specificity of this induced epigenetic transgenerational inheritance of disease is discussed with a consideration of generational toxicology. The molec- ular mechanisms and processes involved in the ability of these inherited epimutations to increase disease susceptibility are discussed. In addition to altered disease susceptibility, the potential impact of the epigenetic inheritance on phenotypic var- iation and evolution is considered. Observations suggest environmentally induced epigenetic transgenerational inheritance of disease is a critical aspect of disease etiology, toxicology and evolution that needs to be considered. Key words: epigenetics; transgenerational; non -genetic inheritance; disease etiology; evolution; review Introduction The term epigenetics was originally coined by C.H. Waddington in the 1940s in relation to his studies of gene -environment interactions involving non -Mendelian inherited phenomena [1, 2]. More recent molecular oriented definitions are that epige- netics refers to 'the molecular factors and processes around the DNA that regulate genome activity independent of DNA sequence, and that are mitotically stable' [3] (Table 1). These molecular factors include DNA methylation [4], histone modifi- cations [5], non -coding RNAs [6, 7], chromatin structure [8], and RNA methylation [9] (Fig. 1). The complex integration of epige- netic modifications is referred to as the 'epigenome'. The first whole epigenome analysis was accomplished in 2005, mapping histone acetylation and methylation in yeast [10]. Epigenetic processes are critical for allowing an organism to respond to its environment with changes in gene expression. In addition, epi- genetic mechanisms allow a stem cell type to develop into a dif- ferentiated cell type [3, 11, 12] (Fig. 2). Therefore, epigenetic processes are an integral part of normal biology. Molecular Epigenetic Mechanisms There are a variety of epigenetic factors that act around the DNA in a cell to regulate gene expression and genome activity. DNA methylation is the most extensively studied epigenetic factor. DNA methylation involves a small (methyl) chemical Received 8 February 2018; revised 1 May 2018; accepted 15 May 2018 © The Author(s) 2018. Published by Oxford University Press. This is an Open Access article distributed under the terms of the Creative Commons Attribution Non -Commercial License (http://creativecommons.org/ licenses/by-nc/4.0/), which permits non-commercial re -use, distribution, and reproduction in any medium, provided the original work is properly cited. For commercial re -use, please contact journals.permissions@oup.com 1 Downloaded from https://academic.oup.com/eep/article-abstract/4/2/dvy016/5055600 by Washinton State University Libraries user on 18 July 2018 2 I Environmental Epigenetics, 2018, Vol. 4, No. 2 Table 1: glossary terms and definitions Glossary term Definition Epigenetics Epigenetic transgenerational inheritance Multigenerational Epimutation Molecular factors and processes around DNA that regulate genome activity independent of DNA sequence, and are mitotically stable Germline mediated inheritance of epigenetic information between generations in the absence of continued direct environmental influences Direct exposure of multiple generations Environmentally induced differential presence of epigenetic alterations that can lead to altered genome activity when compared to organisms not having the exposure Methy[ation Figure 1: epigenetic mechanisms and processes (marks). Modified from [122] group being attached to DNA, primarily at the cytosine base when it is adjacent to a guanine residue [4, 13] to produce 5-methylcytosine (5mC). Other chemical modifications of cytosine bases in DNA have also been described. The TET (ten -eleven translocation) family of enzymes can oxidize 5mC to 5-hydroxymethylcytosine (5hmC), 5-formylcytosine (5fC), and 5-carboxylcytosine (5caC) [14]. In broad terms, the presence of 5mC often represses DNA transcription, while 5hmC is permissive to transcription [15, 16]. However, one of the main functions appears in the DNA methylation erasure during early development [17]. N(6)-methyladenine is an epigenetic modifi- cation to the adenine base of DNA that was once thought to only be present in prokaryotic organisms, but has now been described in mammalian embryonic stem cells [18]. The histone proteins that DNA is wrapped around create the nucleosome and can be chemically modified to alter gene ex- pression. There are many different histone post -translational modifications including lysine acetylation, lysine and arginine methylation, arginine citrullination, lysine ubiquitination, ly- sine sumoylation, ADP-ribosylation, proline isomerization, and serine/threonine/tyrosine phosphorylation [19]. These modifi- cations can change chromatin structure or recruit transcrip- tional cofactors to DNA in order to regulate gene expression. EPIGENETIC MECHANISMS AND MARKS • DNA Methylation • Histone Modifications • Chromatin Structure • Non -coding RNA • RNA methylation Alternatively, they can act as repressive marks to reduce gene expression in major regions of the genome such as heterochro- matin. In broad terms, histone acetylation can increase tran- scription, while methylation can be repressive to transcription. Non -coding RNA molecules can act as epigenetic factors [20]. These are small and long RNA molecules that do not code for a protein, but rather function as RNA to regulate gene expression. The non -coding RNA molecules that act as epigenetic factors are not DNA sequence dependent, so the majority do not rely on having a nucleotide sequence that is complimentary to a specific DNA or RNA region in order to function. Long non - coding RNAs (lncRNAs) [21] and transfer RNA -derived small RNAs (tsRNAs) [22] are examples of RNA classes that are present in sperm and can act as epigenetic factors that affect subse- quent generations [23]. RNA molecules can themselves be epigenetically modified and so affect translation and gene expression [24]. The most prevalent reversible modification to the internal sequence of mRNA is methylation of adenosine to form N(6)-methyladeno- sine (m(6)A). m(6)A mRNA methylation is associated with post - transcriptional regulation [25, 26]. Cytosine methylation (m3C) in both mRNA and tRNA also occurs [27, 28]. Methylation of tRNA inhibits processing of tRNA into tsRNA halves, which Downloaded from https://academic.oup.com/eep/article-abstract/4/2/dvy016/5055600 by Washinton State University Libraries user on 18 July 2018 Environmental Epigenetics, 2018, Vol. 4, No. 2 I 3 EPIGENETIC AND GENETIC CASCADE OF EVENTS INVOLVED IN DEVELOPMENT 4i+ Epigenetics Genetics Environmentally Modified 4111111*NormaI Gename Activity (Transcriptome) Disease Etiology Phenotypic Variation Figure 2: epigenetic and genetic cascade of events involved in development. Cascade of genetic and epigenetic stages interacting to promote differentiated cells. The critical window of exposure allows environmental factors to alter the epigenetic cascade to obtain a modified differentiated site and to cause altered transcriptomes to increase disease susceptibility and phenotypic variation. Modified from [3] themselves affect transcription [22, 29, 30]. Therefore, RNA methylation is the most recent epigenetic molecular factor identified. The coiling, looping, and general structure of DNA is termed chromatin structure and is also an epigenetic factor [8]. The three-dimensional structure of DNA can make certain regions of the genome accessible to transcription machinery, such as bring enhancer regions near gene promoters to affect gene ex- pression. Therefore, epigenetic molecular processes include DNA methylation, histone modifications, non -coding RNAs, RNA methylation, and chromatin structure. Epigenetic Transgenerational Inheritance The definition of epigenetic transgenerational inheritance is 'germline-mediated inheritance of epigenetic information be- tween generations in the absence of continued direct environ- mental influences that leads to phenotypic variation' [3, 31] (Table 1). Multigenerational exposures, in contrast, refer to ob- served effects in subsequent generations that are the result of direct exposure [31] (Table 1; Fig. 3). Direct environmental expo- sure of the parents, considered to be the FO generation, can also affect the germline (sperm or eggs) of either parent. Therefore, the next generation (F1) derived from this germline is still con- sidered exposed, and so is not truly transgenerational. For pre- conception parental exposures the F2 generation offspring is considered the first transgenerational unexposed generation (Fig. 3). The situation is different when a gestating female is ex- posed, because then the fetus and the fetus' germline are di- rectly exposed as well. In that case, the F3 generation is the first unexposed transgenerational offspring [31] (Fig. 3). The Agouti mouse model is an example of multigenerational inheritance [32-34]. When pregnant Agouti mice are exposed to a methyl donor in their diet, they experience increased methyl- ation on an allele of their Agouti gene, which leads to a coat color change in their offspring. Generally, this change is not passed on to future generations. Instead the normal process of epigenetic reprogramming in the germline and early embryo returns the DNA methylation state to its original setting. An increasing number of examples of transgenerational in- heritance of disease are present in the literature (Table 2). Some of the first experiments to establish the potential for epigenetic transgenerational inheritance were performed by Conrad Waddington, who coined the term 'epigenetic' [1, 35]. In these studies, it was found that a heat shock induced wing structure change in Drosophila melanogaster persisted for more than seven generations [35]. An even earlier study in Guinea pigs demon- strated transgenerational inheritance of decreased fertility and increased mortality for four generations after ancestral expo- sure to ethanol vapor, although this was not attributed to epige- netic inheritance at the time [36]. One of the first studies to associate molecular epigenetic changes with transgenerational inheritance of disease in mammals was an investigation of the effects of treating pregnant rats with the agricultural fungicide vinclozolin [37]. The F3 generation (great -grand offspring) dem- onstrated reproductive abnormalities such as increased testicu- lar germ cell apoptosis and decreased sperm motility. These transgenerational phenotypes were correlated with changes in DNA methylation in the F3 generation sperm [37]. Several environmental toxicants including vinclozolin, DDT (dichlorodiphenyltrichloroethane), methoxychlor, plastic de- rived compounds, hydrocarbons, atrazine, tributyltin have been shown to promote the transgenerational inheritance of in- creased disease susceptibility in rodent models [38, 39] (Table 2). The diseases that were increased transgenerationally included testis, prostate and kidney disease, obesity, polycystic ovaries, reduced oocyte number in the ovaries, and cancer [39]. For the purposes of this review, more recently published investigations of epigenetic transgenerational inheritance of disease will be highlighted, (Table 2). Exposure of mice to the phthalate plastic derived compound DEHP (di(2-ethylhexyl) phthalate) has been shown to result in transgenerational changes to stress Downloaded from https://academic.oup.com/eep/article-abstract/4/2/dvy016/5055600 by Washinton State University Libraries user on 18 July 2018 4 I Environmental Epigenetics, 2018, Vol. 4, No. 2 Female ! Male Environmental Exposure F1 FO F2 Generation First Unexposed Multigenerational Exposures Transgenerational Inheritance { Gestating Female Environmental Exposure F3 Generation First Unexposed Figure 3: environmentally induced transgenerational epigenetic inheritance. Schematic of multigenerational versus transgenerational environmental exposures. Modified from [31] Table 2: examples of transgenerational inheritance from specific exposures and specific effects Exposure Effects Reference Environmental toxicants Vinclozolin Vinclozolin Methoxychlor Permethrin/DEET Dioxin BPA/phthalates Hydrocarbon mixture (jet fuel) Vinclozolin, permethrin/DEET, plastics, dioxin, jet fuel DDT Phthalate Phthalate Tributyltin BPA BPA Atrazine Benzo[a]pyrene Mercury Other exposures Caloric restriction High -fat diet Folate Stress Drought Heat/salt stress Prediabetes/diabetes Smoking Ethanol Heat stress Impaired male fertility; prostate, kidney disease, tumors, immune and reproductive pathologies Gender -specific changes in anxiety -like behavior Impaired male fertility; kidney disease, ovary disease, and obesity Prostate, kidney disease Prostate, kidney disease, reduced fertility, negative effects on pregnancy outcome Prostate, kidney disease; obesity Prostate, kidney disease; obesity; immune and reproductive pathologies Polycystic ovaries, reduced primordial follicle pool Obesity Disruption of testicular germ cell organization and spermatogonial stem cell function, changes in hormones and behavior Disrupted ovarian function Increase in fat depot size Cardiac disease; reduced fertility Changes in social behavior and neural gene expression Testicular disease, early puberty, lean phenotype Behavioral and physiological deficits Behavior change Cardiovascular mortality Increased body size; reduced insulin sensitivity, increased mammary cancer Congenital malformations Reduced social interaction; increased stress resilience; disrupted neural connectivity; physiology changes; increased anxiety DNA methylation changes Accelerated flowering, increased salt tolerance Impaired glucose tolerance; reduced insulin sensitivity, male subfertility Abnormal pulmonary function Neurological defects; decreased fertility Increased Hsp70 production and tolerance to heat stress; wing structure changes [37, 78, 94] [85] [37, 86] [81] [80, 123] [43] [46] [82] [45] [40, 124] [41] [38] [48, 72] [42] [125] [50] [49] [56, 77] [57-59] [126] [51-55] [127] [128] [61, 62] [129] [36, 47, 130] [131, 132] hormones, behavior [40], and ovarian function [41]. Earlier stud- ies in mice [42] showed that ancestral exposure to the plastic derived compound bisphenol A (BPA) caused changes in social behavior in juvenile mice and changes in expression of neural genes such as oxytocin and vasopressin. Earlier studies in rats have shown that exposure to a mixture of BPA and phthalates induces transgenerational increases in pubertal abnormalities, testis disease, and ovarian disease [43]. Ancestral exposure of Downloaded from https://academic.oup.com/eep/article-abstract/4/2/dvy016/5055600 by Washinton State University Libraries user on 18 July 2018 Environmental Epigenetics, 2018, Vol. 4, No. 2 I 5 ENVIRONMENTALLY INDUCED EPIGENETIC TRANSGENERATIONAL INHERITANCE Environmental Toxicants Vinclozolin (Agricultural Fungicide) Methoxychlor(Agricultural Pesticide) DioxinlTCDD (Industrial Contaminant) Plastic Compounds (BPA& Phthalates) Mercury Other Types Exposures Pennethrin & DEET (Insect Repellents) DDT (Pesticide) Tributyltin (Industrial Toxicant & Biocide) Hydrocarbons (Jet Fuel) Atrazine Nutrition (High Fat or Caloric Restriction) Temperature & Drought (Plant Health & Flowering) 00 Plants Files Worms Fish Smoking &Alcohol Stress (Behavioral) Bird Rodents Figure 4: environmentally induced epigenetic transgenerational inheritance. Various exposures and species investigated mice to the toxicant tributyltin results in a transgenerational in- crease in obesity [38, 44]. Earlier investigations in pregnant rat exposures to DDT, jet fuel hydrocarbons, or a BPA/phthalates mix will also increase obesity transgenerationally [43, 45, 46]. Other recently published investigations indicate that ethanol exposure of pregnant mice can cause transgenerational neuro- logical changes in descendants that resemble those of Fetal Alcohol Spectrum Disorders [47]. In zebrafish, BPA exposure of males can result in the transgenerational inheritance of heart disorders in the F2 generation [48]. Zebrafish exposure to mer- cury [49] or to the industrial pollutant benzopyrene [50] induces the transgenerational inheritance of abnormal neurobehaviors that are correlated with epigenetic changes (i.e. epimutations) in sperm (Table 2) [49, 50]. Exposure to environmental factors other than toxicants can also induce transgenerational inheritance (Table 2). The stress of matemal separation in mice transgenerationally disrupts func- tional connectivity throughout the brain [51], as well as both impairing social interactions and cognition and making the de- scendant mice more stress resilient [52]. Mice subjected to restraint stress also transmitted reduced anxiety levels to their transgenera- tional descendants [53]. Conversely, social hierarchy stress in mice was shown to increase anxiety behaviors transgenerationally [54]. This raises the possibility that several psychological stressors can induce different transgenerational effects. In pregnant rats, the stressors of forced swim and restraint induce transgenerational in- heritance of physiological changes such as alterations in catechol- amine biosynthesis and immune response [55]. Other examples of transgenerational inheritance have been observed with caloric restriction or high fat diets. The Overkalix study by Bygren et al. [56] shows how cardiovascular mortality in humans can be influenced by reduced childhood and adoles- cent food supply. Effects were shown to reach into the second generation. Maternal high fat diet in mice can increase body size and reduce insulin sensitivity in F3 generation female off- spring [57], although Masuyama et al. [58] demonstrated that a normal diet in utero for three subsequent generations can return glucose and lipid metabolism to normal. In addition, 0 0 Pigs Humans a maternal high fat diet in mice can transgenerationally in- crease mammary cancer risk [59]. Previous studies with rats demonstrated that exposure of pregnant animals to the envi- ronmental toxicant vinclozolin also promoted a transgenera- tional increase in tumors [60]. Interestingly, diabetes in mice can induce transgenerational inheritance of male subfertility [61]. A paternal prediabetic condition in mice can be inherited transgenerationally as shown by impaired glucose tolerance and decreased insulin sensitivity [62]. Similarly, male rats fed a high fat diet promoted transgenerational inheritance of im- paired glucose tolerance in F2 generation offspring [63]. Species Diversity of Epigenetic Transgenerational Inheritance Epigenetic transgenerational inheritance has been identified to occur in a wide variety of organisms (Fig. 4). This review focuses on examples of epigenetic transgenerational inheritance of dis- ease or abnormalities in different animal species. A number of studies have demonstrated the environment (e.g. heat and drought) can induce the epigenetic transgenerational inheri- tance of phenotypic variation in plants [64]. In the nematode worm Caenorhabditis elegans increased longevity that is associ- ated with the histone modification H3K4me3 methylation can be transgenerationally inherited for up to three generations [65]. As mentioned previously, Waddington performed early experiments using the model insect species D. melanogaster and demonstrated that a heat shock induced wing structure changes that persisted for more than seven generations [1, 35] and now for hundreds of generations in today's stocks. In more recent examples, it has been found that a high -sugar maternal fly diet can alter the larval body composition for the next two generations [66]. Similarly, a high fat larval diet in fruit flies can cause transgenerational alterations to F2 generation pupal and egg size [67]. Manipulations of the protein levels in the diet of fruit flies can affect longevity and reproduction for three subse- quent generations, and this effect is associated with histone Downloaded from https://academic.oup.com/eep/article-abstract/4/2/dvy016/5055600 by Washinton State University Libraries user on 18 July 2018 6 I Environmental Epigenetics, 2018, Vol. 4, No. 2 modifications [68, 69]. In another arthropod species, the crusta- cean Daphnia magna, exposure to the toxicant 5-azacytidine results in decreased body length and reduced levels of DNA methylation in non -exposed subsequent generations [70]. Several species of fish have shown epigenetic transgenera- tional inheritance of disease. Zebrafish exposed to the environ- mental toxicants benzo(a)pyrene [50], methylmercury [49] or dioxin [71] transmit to their grand -offspring behavioral changes, visual defects, increased body mass, skeletal abnormalities and/ or decreased fertility, sometimes associated with changes in DNA methylation. Medaka exposed to the endocrine disruptors BPA or ethinylestradiol produce grand -offspring and great - grand -offspring with reduced fertility [72]. Some bird species have shown evidence of epigenetic trans - generational inheritance. In a study with quail eggs exposed to the environmental estrogen genistein [73] the great -grand off- spring age at which the first egg was laid was significantly greater. In ducks, feeding a methionine-deficient diet produces grand -offspring with altered weight gain and changes in meta- bolic parameters [74]. In mammals most studies of epigenetic transgenerational inheritance have occurred in rodents [75]. Another experimen- tal mammal involves pigs and abnormal nutritional induced epigenetic transgenerational inheritance [76]. Examples of transgenerational inheritance of increased susceptibility to dis- eases have been outlined above for rats, mice and Guinea pigs [36, 37, 41, 44, 45]. Evidence of epigenetic transgenerational in- heritance of disease in humans comes from retrospective stud- ies such as those including the Dutch and Swedish famines [56, 77]. As previously mentioned, the descendants of people ex- posed to famine conditions as children 9-12 years of age in Sweden were investigated and it was found that men whose grandfathers had been exposed to famine had an increased risk of mortality due to diabetes, and similarly women whose grandmothers were exposed had increased risk [31]. Due to the conservation of environmentally induced epigenetic transge- nerational inheritance from plants to humans all organisms will utilize epigenetic inheritance to facilitate environmental adaptation and response. Phenotypic Diversity of Transgenerationally Inherited Diseases Studies of the effects of ancestral exposure to an array of toxi- cants (Table 2) demonstrate epigenetic transgenerational inher- itance of a variety of diseases and abnormalities, including testis disease [37], prostate and kidney disease [43, 46, 78-82], mammary tumors [78], immune and reproductive pathologies [46, 78, 83, 84], obesity [45, 46], behavioral effects [85] and many others listed in Table 2. The disease phenotypes observed in these experiments often depend on the specific exposure of the FO generation. For example, increased obesity risk in rats is inherited transgenerationally after ancestral exposure to DDT, plastic compounds, hydrocarbons and methoxychlor [43, 45, 86], but not dioxins. Jet fuel hydrocarbons induce an elevated rate of luteal ovarian cyst formation in F3 females [46, 82], a phenotype not observed with other exposures. On the other hand, some ovarian disorders such as polycystic ovaries and re- duction of the primordial follicle pool size have been shown to be inherited transgenerationally after exposure of the FO gener- ation to many of the toxicants studied [84, 87]. The explanation for this phenomenon may be that some developmental pro- cesses, in this case ovarian follicle development, are more sensitive to epigenetic and gene expression changes in their de- velopmental regulatory networks, and so will be more easily af- fected than those of other cells and tissues (Fig. 2). Epigenetic processes are major mechanisms by which organisms respond and adapt to their environment. Therefore, how can environmental epigenetic insults result in transge- nerational inheritance of increased disease susceptibility? Since this is a maladaptive response one possible answer may be seen in the predictive adaptive response hypothesis [88]. In this hypothesis an environmental stressor like famine may epige- netically promote an adaptive (thrifty) phenotype in subsequent generations. If the current environment of those descendants has more than adequate nutrients, diseases such as diabetes and obesity are promoted. Another possibility is that an envi- ronmental insult, such as exposure to a toxicant, may interfere with the normal molecular epigenetic machinery and result in stochastic and/or directed epigenetic changes that could be con- sidered epimutations. The term epimutation is defined as 'the environmentally induced differential presence of epigenetic alterations that can lead to altered genome activity, when compared to organisms not having exposure' (Table 1). If these epimutations occur in germ cells they can lead to transgenera- tional inheritance of a wider range of phenotypes in the prog- eny. Some of those phenotypes may be poorly adapted and develop disease. This would explain an increase in disease sus- ceptibility in organisms whose ancestors were exposed to envi- ronmental insults. However, phenotypic variation is the 'raw material' upon which natural selection acts. Therefore, the in- creased phenotypic variation may also result in some individu- als who are better adapted to an altered environment which can facilitate natural selection and evolution [89]. Developmental Etiology of Epigenetic Transgenerational Inheritance A number of reproductive processes involve DNA methylation changes that normally will be reset by genome-wide DNA meth- ylation reprogramming events. The two main developmental periods are in the early embryo after fertilization and during germ cell specification at gonadal sex determination [90, 91] (Fig. 5). This phenomenon allows embryonic stem cells to de- velop by removing epigenetic constraints to promote pluripo- tency. Some parental epigenetic changes, such as imprinted genes, are protected from being reprogrammed during these de- velopmental periods. In contrast, some parent specific imprints are established during this epigenetic reprogramming [92]. Environmentally induced DNA methylation alterations called differential DNA methylation regions (DMRs) [93] present in germ cells behave as imprinted -like genes in the way their methylation patterns persist. By definition, true imprinted genes display 'parent -of -origin allelic transmission with mono - allelic gene expression'. DMRs often demonstrate parent -of - origin allelic transmission, but monoallelic gene expression has not been demonstrated. Differentially methylated sites connected with transgenerational inheritance are called 'imprinted -like' [94]. The transmission of epigenetic informa- tion to future generations via germ cells can alter the epige- nome of the developing embryonic stem cells which would be expected to promote changes to the epigenetic and transcrip- tomic programming of all derived somatic cells [95]. Those tis- sues that are sensitive to alterations in their epigenomes and transcriptomes may show increased susceptibility and preva- lence of disease development [93, 96] (Fig. 2). Normal biology Downloaded from https://academic.oup.com/eep/article-abstract/4/2/dvy016/5055600 by Washinton State University Libraries user on 18 July 2018 Environmental Epigenetics, 2018, Vol. 4, No. 2 I 7 Qi L a) 2 F1 generation F2 generation r h i, rr rr it e �4 Gonadal sex determination Adult development Early embryogenesis Figure 5: epigenetic reprogramming during primordial germ cell development at gonadal sex determination and following fertilization in the early embryo. Modified from [94] requires alterations of epigenetics for the development of stem cell populations and subsequent somatic cell differentiation. The epigenetic transgenerational inheritance molecular process is directly linked to these epigenetic reprogramming processes in the germline and the developing embryo. Germline Epimutations It is a prerequisite for environmentally induced epigenetic transgenerational inheritance that there be epigenetic changes (i.e. epimutations) in the germline, because the germ cells (sperm and egg) are the only cells that can transmit molecular information between generations from the parents to their off- spring. Early studies investigating transgenerational epimuta- tions in germ cells used pregnant rats exposed to vinclozolin during the period of gonadal sex determination when epige- netic reprogramming of the fetal germ cells occurs. A genome- wide promoter analysis was applied to look for epigenetic changes in the sperm DNA and approximately 50 differential DMRs were identified in gene promoters in vinclozolin lineage F3 generation sperm DNA versus control lineage [97]. Similar experiments have been performed in rats using a number of ad- ditional toxicants including dioxin [80], a mixture of permethrin and DEET (N,N-diethyl-meta-toluamide) [81], BPA and phtha- lates [43] and jet fuel (hydrocarbons) [46]. All these toxicants were found to promote transgenerational inheritance of both disease and sperm DMRs. Interestingly, it was observed that each toxicant produced an exposure -specific set of DNA meth- ylation changes in the sperm, and comparisons between the different toxicant exposures demonstrated negligible overlap between them [82]. This raises the possibility that these 'epige- netic signatures' may be used in the future as a diagnostic tool to determine if an individual has had a particular environmen- tal toxicant exposure in their ancestry. The examination of the genomic features of all these DMRs identified a low CpG density termed CpG deserts [98] and a DNA sequence motif called Environmental Induced Differential Methylation Consensus Sequence 1 (EDM1). Nearly all the DMRs identified with numer- ous exposures had these genomic features [39]. A machine learning analysis used this data to identify approximately 40 000 potential genome-wide DMR sites susceptible to environ- mental alterations [99]. Further studies are needed to determine the utility of these potential epimutation sites as biomarkers for exposure and disease. Comparisons have been made of the DMRs induced in the di- rect exposure F1 generation and transgenerational F3 genera- tion vinclozolin lineage male sperm [100]. As described above, when the gestating female is directly exposed to a toxicant the F1 generation fetus is also directly exposed, as are the develop- ing germ cells within the F1 generation fetus that will generate the F2 generation. The F3 generation animals are the first non - exposed transgenerational descendants (Fig. 3). Therefore, the molecular mechanisms of inducing epigenetic changes is differ- ent in the direct exposure F1 generation, and in the F1 genera- tion germ cells (sperm) that will produce the F2 generation, when compared with mechanisms by which epimutations are induced in the transgenerational F3 generation. In a study in- volving vinclozolin exposure of gestating female rats there was a distinct set of DNA methylation changes in the F1 generation sperm that was different from the set of methylation changes in the transgenerational F3 generation sperm [100]. This sug- gests that the direct exposure induced F1 generation sperm epi- mutations promote epigenetic alterations during germ cell development in subsequent generations that lead to the differ- ent DMRs in the F3 generation. This mechanism appears to be associated with altered early embryonic development of the stem cells. In addition to DNA methylation, other epigenetic factors such as non -coding RNA (ncRNA) can also contribute to epige- netic transgenerational inheritance. Small ncRNAs of the microRNA class are altered in the sperm of stressed vs. un- stressed mice and have been shown experimentally to promote a change in the hypothalamic -pituitary -adrenal stress axis re- activity of offspring [101]. Another class of small non -coding RNAs associated with transgenerational sperm are 5' halves of tRNAs [102]. These stRNA 5' halves and microRNAs are transge- nerationally altered in the F3 generation sperm of rats ances- trally exposed to vinclozolin during pregnancy [102]. A number Downloaded from https://academic.oup.com/eep/article-abstract/4/2/dvy016/5055600 by Washinton State University Libraries user on 18 July 2018 8 I Environmental Epigenetics, 2018, Vol. 4, No. 2 of studies have demonstrated the potential role of ncRNA in epigenetic transgenerational inheritance [103]. Another epigenetic factor present in sperm and associated with transgenerational inheritance is the retention of histone proteins [104]. During spermatogenesis in vertebrates the his - tone cores that DNA is wrapped around in most somatic cell types are replaced by protamines, allowing for more tightly compacted DNA in sperm heads [105]. However, 1-10% of histo- nes are retained in mammals, depending on species [106]. These retained sperm histones have been implicated in regulat- ing gene expression in the resulting offspring [107]. In a recent transgenerational study using rats, Ben Mammar et al. [108] demonstrated that a specific set of histones are retained in F3 generation control lineage sperm. This same set of histones is retained in F3 generation rats ancestrally exposed to vinclozolin or DDT, but additional sites of histone retention are induced in the vinclozolin and DDT lineage sperm [108]. Therefore, histone retention also appears to be associated with sperm mediated transgenerational inheritance of disease following ancestral DDT or vinclozolin exposure [104, 108]. Since post -translational modifications of histones are known to be an epigenetic factor that regulates gene expression studies have investigated histone modifications present in sperm. Histone H3 methylation changes in retained sperm his - tones have been correlated with fertility in humans [109] and with survival of offspring in mice [110]. Histone modifications have been correlated with epigenetic transgenerational inheri- tance of altered phenotypes in C. elegans [111], Drosophila [112], and recently in mammals [104]. Previous transgenerational studies have focused on epige- netic factors and epimutations in sperm due to the relative ease of obtaining large numbers of sperm cells. Several studies have shown that epigenetic transgenerational inheritance is medi- ated through the female germline [45, 86]. Eggs cannot be obtained in large enough quantity to allow traditional molecular analysis. Future studies with single cell analyses may be needed to document the role of epimutations in eggs. Epigenetic factors in eggs appear to play an equally important role in epigenetic inheritance, but remain to be investigated. The epigenetic trans - generational inheritance of disease following environmental exposures will likely be mediated by the integrated actions and combination of different epigenetic factors present in gametes. A recent study in rats demonstrated that after treatment of ges- tating females with DDT or vinclozolin there were concurrent transgenerational alterations in F3 generation sperm in DNA methylation, histone retention, and non -coding RNAs [108, 113]. Therefore, transgenerational alterations in all the different epi- genetic processes appear to be involved in the epigenetic trans - generational inheritance phenomenon. Transgenerational Gene Expression Changes Transgenerational inheritance of environmentally induced epi- genetic changes requires transmission through the germ line from parents to future generations. However, epigenetic changes themselves would not cause disease, rather they must manifest as changes in gene expression. Ensuing disease such as cancer, prostate or kidney abnormalities, and obesity are brought on by disturbances in gene expression in the pertinent somatic cells. The hypothesis is that the epimutations in the germline alter the epigenome of the embryonic stem cells that then affect all subsequent somatic cell epigenomes and tran- scriptomes [87, 95] (Fig. 2). These cell and tissue specific epimu- tations promote tissue specific alterations in transcriptomes [96]. These aberrant transcriptomes could then lead to a suscep- tibility for physiological abnormalities and disease (Fig. 2). Exposure of FO generation animals to environmental toxi- cants will affect and change the transcriptomes of potentially all tissues in future generations [96]. In a study of rats ances- trally exposed to vinclozolin the transcriptomes of 11 different tissue types from adult male and female animals were exam- ined [96]. It was found that there were gene expression differen- ces between control and vinclozolin lineage animals in the different tissues with minimal overlap in the differentially expressed genes between tissues. However, there was signifi- cant overlap in the physiological pathways and cellular pro- cesses that were affected by gene expression changes in different tissues. For example, both prostate and liver tissues were enriched for genes in transcription and focal adhesion pro- cesses, but the specific genes altered were not the same in each tissue [96]. These observations warranted a closer look at the ge- nomic locations of epimutations and differentially expressed genes. Looking across the different tissue types it was found that there were regions of the genome that had statistically over -represented clusters of gene expression changes [96]. These regions in the genome were called epigenetic control regions (ECR). These ECR are 2-5 megabase in size and have clusters of genes. Within these ECRs are DNA methylation epi- mutations and long non -coding RNA (ncRNA) expression sites [114]. The long ncRNAs play a role in regulation of distal gene transcription and epigenetic regulation [115, 116]. Observations suggest that within an ECR many of the genes are epigenetically regulated up or down as a block. Therefore, in one cell type those genes within the ECR normally expressed would be regu- lated while in another cell type a different set of genes within the ECR normally expressed would be affected. Epigenetic alter- ations within the ECR can influence gene expression in a variety of cell types differently [96]. Interestingly, the location of ECRs has been shown to co -localize with clusters of transgenera- tional epimutations (e.g. DMRs) found after ancestral toxicant exposures [117]. Several studies have suggested how the molecular mecha- nisms of environmentally induced transgenerational inheri- tance may lead to tissue specific disease occurrence. As mentioned earlier, two ovarian disorders, polycystic ovarian syndrome, and primary ovarian insufficiency (premature reduc- tion of the primary follicle pool) were both induced transgenera- tionally by a number of environmental toxicants [83]. Analysis of this phenomenon involved the isolation of a specific cell type from the tissue that is associated with the disease in the vinclo- zolin lineage animals. The granulosa cells were isolated from the ovarian follicles of young female rats prior to disease onset. The epigenomes and transcriptomes of these granulosa cells from control and vinclozolin lineages were analyzed and com- pared [87]. Granulosa cells from F3 generation vinclozolin line- age rats had differences in both the epigenome and the transcriptome compared with the control lineage. Interestingly, some of the affected genes had been previously shown to be as- sociated with polycystic ovarian syndrome and primary ovarian insufficiency [87]. Similar results were obtained when the mo- lecular basis of transgenerational male infertility in rats was ex- amined. As above, changes in the epigenome and transcriptome were found in testicular Sertoli cells of F3 genera- tion rats after ancestral vinclozolin exposure [95]. Several of the differentially regulated genes identified were known to be asso- ciated with male infertility, such as HDAC1 and HSP90AA1 [118, 119]. In addition, a number of Sertoli cell genes associated with pyruvate production were down -regulated and this is Downloaded from https://academic.oup.com/eep/article-abstract/4/2/dvy016/5055600 by Washinton State University Libraries user on 18 July 2018 Environmental Epigenetics, 2018, Vol. 4, No. 2 I 9 known to impact spermatogenic cell survival and promote germ cell apoptosis, which is one of the testis pathology phenotypes observed [95]. Therefore, the environmentally induced transge- nerational changes in the somatic cell epigenomes are associated with transgenerational changes in gene expression, which are related to the increases in disease development observed. Experimental and Technical Approach Limitations One of the main experimental design issues and limitations is a consideration of what constitutes a multigenerational or inter - generational direct exposure versus a true non -exposed trans - generational generation. A number of past studies have referred to F1 generation fetal exposure or F1 generation germline that will generate the F2 generation as transgenerational experiments (Fig. 3). Many previous reports have not carefully considered this issue and misinterpreted the results as transge- nerational. A multigenerational or intergenerational exposure experiment is important and helps elucidate risk of exposure on multiple generations physiology and pathology. However, the mechanisms involved are distinct and impacts different than transgenerational generations [31]. This non -genetic form of in- heritance needs to be distinguished from multiple generation exposure that is due to direct exposures and toxicities. Another experimental design issue is the use of mixed cell populations for an epigenetic analysis [120]. Every cell type in the body has the same DNA sequence, so for genetic analysis a mixed cell population does not affect the data or observations. In contrast, each cell type in the organism has a very distinct epigenome to allow the cell type to have its unique cell biology and physiology. The reason a neuron is distinct from a hepato- cyte is not the genetic sequence, but the epigenetic differences between the cell types that regulate the unique gene expres- sion. Therefore, an epigenetic analysis of mixed cell populations are influenced by small changes in specific cell population numbers which will alter the epigenetic data experimentally ob- served without an actual change in molecular epigenetics [120]. A number of epigenetic studies have used whole blood which contains over 20 different cell populations to do epigenetics. Twin studies using this approach have not been revealing due to the variation in cell populations in the blood and inability to dissect out specific epigenetic changes. Purifying a specific cell type such as monocytes from the blood will be far more useful for epigenetic analyses than use of the mixed cell population. Therefore, epigenetic analysis optimally requires purified cell populations [120]. Epigenetic molecular procedures have dramatically devel- oped over the past decade to provide greater accuracy and pre- cision. The technology of next generation sequencing is superior to array technology and previous biochemical proce- dures. The current procedures for DNA methylation, ncRNA and histone modifications use next generation sequencing which should be considered the optimal approach for any genome- wide analysis. If a few selected sites are examined then the ar- ray technology or biochemical approach can be used and are less costly. For the genome-wide approaches, the different DNA methylation approaches are methylated DNA immunoprecipi- tation (MeDIP) sequencing (MeDIP-Seq) and bisulfite sequencing (BS-Seq). The MeDIP-Seq is biased to low density CpG <20% while the BS-Seq is biased to high density CpG. All these procedures are efficient, but the limitation in CpG bias needs to be considered in the interpretation of the data obtained. The RNA-Seq and chromatin immunoprecipitation ChIP-Seq approaches are the optimal procedures currently available with few alterations. Third generation sequencing that may be able to assess epigenetic modifications during the sequencing will be a future technology to elucidate the DNA methylation CpG density bias, but remains to be optimized. The rate at which epi- genetic technology is developing suggests within the next five years we will likely be using new technologies. The research in this area needs to consider the limitations of some of the technology currently used. Conclusions Research in the area of environmentally induced epigenetic transgenerational inheritance of disease and phenotypic varia- tion has provided evidence of transgenerational inheritance of epimutations in plants, worms, flies, fish, birds, pigs, mice, rats, and humans [121] (Fig. 4). Ancestral exposure to environmental influences such as toxicants, abnormal nutrition, or stress can induce changes in the germline epigenome that are transmitted to descendants. These epimutations caused by individual expo- sures must occur in the germline in order to be transmitted. When these germline epigenetic changes become imprinted - like and escape the normal processes of epigenetic reprogram- ming, then epigenetic transgenerational inheritance can occur. Since the embryonic stem cells develop an altered epigenome, these epimutations subsequently induce somatic cell altera- tions in the epigenome and transcriptome, which will increase disease susceptibility in the offspring. Therefore, these ances- tral exposures to environmental toxicants can lead to transge- nerational changes in the epigenome and transcriptome of future generations and lead to an increased incidence of dis- ease. Although DNA methylation is the most thoroughly stud- ied epigenetic mechanism, other epigenetic processes are equally important. Future research will need to investigate the multiple epigenetic mechanisms and how they integrate. The developmental aspects of how the epigenetic transgenerational inheritance of disease develops are still unclear. How epimuta- tions in sperm result in epigenetic changes in the resultant em- bryo needs to be investigated. How the derived embryonic stem cell changes can lead to epigenetic and transcriptome changes in the function of an adult organ associated with disease also remain to be elucidated on a molecular level. The potential role these ancestral exposures and epigenetic transgenerational in- heritance have on disease etiology needs to be seriously consid- ered. In addition, it may be clinically useful to determine what epimutation patterns or signatures are associated with specific disease and/or ancestral exposures in humans. Epigenetic bio- marker signatures may be used in the future as a diagnostic tool to assess if an individual has a specific disease susceptibility or environmental toxicant exposures. This will facilitate preventa- tive medicine and therapeutic approaches to mitigate associ- ated disease risks. Acknowledgements We apologize to authors whose studies on the topic were not presented or referenced, but the increase in research in the area has grown significantly. We acknowledge the assis- tance of Dr Millissia Ben Maamar for critical review of the Downloaded from https://academic.oup.com/eep/article-abstract/4/2/dvy016/5055600 by Washinton State University Libraries user on 18 July 2018 10 I Environmental Epigenetics, 2018, Vol. 4, No. 2 manuscript and Ms Heather Johnson in preparing the man- uscript. This was supported by a John Templeton Foundation grant (50183) and NIH (ES012974) grant to M.K.S. Conflict of interest statement. None declared. References 1. Waddington CH. Organisers and Genes. Cambridge: Cambridge University Press, 1940. 2. Van Speybroeck L. From epigenesis to epigenetics: the case of C. H. Waddington. Ann N Y Acad Sci 2002;981:61-81. 3. Skinner MK. 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Constancia M, Pickard B, Kelsey G, Reik W. Imprinting mech- anisms. Genome Res 1998;8:881-900. Skinner MK, Manikkam M, Guerrero-Bosagna C. Epigenetic transgenerational actions of environmental factors in dis- ease etiology. Trends Endocrinol Metab 2010;21:214-22. Jirtle RL, Skinner MK. Environmental epigenomics and dis- ease susceptibility. Nat Rev Genet 2007;8:253-62. Guerrero-Bosagna C, Savenkova M, Haque MM, Nilsson E, Skinner MK. Environmentally induced epigenetic transge- nerational inheritance of altered sertoli cell transcriptome and epigenome: molecular etiology of male infertility. PLoS One 2013;8:1-12, e59922. Skinner MK, Manikkam M, Haque MM, Zhang B, Savenkova M. Epigenetic transgenerational inheritance of somatic tran- scriptomes and epigenetic control regions. Genome Biol 2012; 13:R91. Guerrero-Bosagna C, Settles M, Lucker B, Skinner M. Epigenetic transgenerational actions of vinclozolin on pro- moter regions of the sperm epigenome. PLoS One 2010;5: 1-17, e13100. 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Ancestral vinclozolin expo- sure alters the epigenetic transgenerational inheritance of sperm small noncoding RNAs. Environ Epigenet 2016;2:1-10, dvw001. . Gapp K, Jawaid A, Sarkies P, Bohacek J, Pelczar P, Prados J, Farinelli L, Miska E, Mansuy IM. Implication of sperm RNAs in transgenerational inheritance of the effects of early trauma in mice. Nat Neurosci 2014;17:667-9. . Skinner MK, Ben Maamar M, Sadler-Riggleman I, Beck D, Nilsson E, McBirney M, Klukovich R, Xie Y, Tang C, Yan W. Alterations in sperm DNA methylation, non -coding RNA and histone retention associate with DDT -induced epige- netic transgenerational inheritance of disease. Epigenet Chromatin 2018;4:8. Downloaded from https://academic.oup.com/eep/article-abstract/4/2/dvy016/5055600 by Washinton State University Libraries user on 18 July 2018 Environmental Epigenetics, 2018, Vol. 4, No. 2 I 13 105. Bao J, Bedford MT. Epigenetic regulation of the histone-to- protamine transition during spermiogenesis. 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Gene assimilation of an acquired charac- ter. Evolution 1953;7:118-26. across generations. Biol Downloaded from https://academic.oup.com/eep/article-abstract/4/2/dvy016/5055600 by Washinton State University Libraries user on 18 July 2018 From: Linda Lewanski To: SVC DENR.publiccomments Subject: [External] Blue Ridge Paper Company #0000272 Date: Thursday, January 14, 2021 2:02:45 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Please strengthen the requirements for this permit. It's imperative for our residcnta, visitors and wildlife to Clean the Pigeon River Linda Lewanski 4236083028 Sent from my iPhone From: Katy Mcbuhr To: SVC DENR.publiccomments Subject: [External] Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 14, 2021 4:38:09 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spam@nc.gov> I am writing to urge you to do everything you can to keep the water in the pigion river clean!! My family plays and swims in this river all year long! It is our home and this river is the most important place to us in the world! For 10 years I have worked on this river as a professional guide. For 10 years I have talked about the pollution. I have to shower right away after playing in the water or I get a rash. Please keep/make our special river clean! Katy and Mitch Buhr + family Bybee TN Sent from my iPhone From: To: Subject: Date: Suzanne Phillips SVC DENR.oubliccomments [External] Blue Ridge Paper Products, NC #0000272 Thursday, January 14, 2021 1:09:13 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. I'm sending this email in response to your request for public comment on Blue Ridge Paper's request to have water quality standards lowered on the Pigeon River. As a resident of Waterville Lake, fed by the Pigeon, I must strongly object to any lowering of water quality on this waterway. A smelly, dirty river will have a major impact on the lake, putting my health, property value, and quality of life at serious risk. Wildlife, such as our vibrant fish population, elk, bear, and bald eagles will also suffer adverse effects from polluted waters. Much progress has been made on the river in the last couple of decades, I believe more progress needs to be made, not less. Haywood County markets itself as a prime spot for tourism all over the country, I can't help but think polluted waterways in the county will diminish it's attractiveness as a vacation and second home community to an up and coming generation that is environmentally conscious and choose to spend their dollars in like minded communities. Businesses looking to locate in Haywood County will also take their employee's quality of life into consideration before making an investment here. It's time to look toward the future of our community and chart a course that will bring maximum benefit to all it's citizens instead of implementing policies that only benefit the bottom line of a company that has always disregarded it's downstream neighbors (who make up the vast majority of Haywood County). Thank you for the opportunity to speak out- Suzanne Phillips Sent from Yahoo Mail on Android From: Chernikov, Sergei To: SVC DENR.publiccomments Subject: FW: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 14, 2021 10:04:26 AM Sergei Chernikov, Ph.D. Environmental Engineer III Industrial NPDES Permitting Unit NEW Tel. 919-707-3606 1617 Mail Service Center, Raleigh, NC 27699-1617 Express Mail: 512 N. Salisbury St., Raleigh, NC 27604 Original Message From: GRAYJERNIGAN@everyactioncustom.com[mailto:GRAYJERNIGAN@everyactioncustom.com] Sent: Thursday, January 14, 2021 10:03 AM To: Chernikov, Sergei <sergei.chernikov@ncdenr.gov> Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spam@nc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Department of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Gray Jernigan 52 Waynesville Ave Asheville, NC 28806-4632 GRAYJERNIGAN@GMAIL.COM From: Chernikov, Sergei To: SVC DENR.publiccomments Subject: FW: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 14, 2021 10:22:15 AM Sergei Chernikov, Ph.D. Environmental Engineer III Industrial NPDES Permitting Unit NEW Tel. 919-707-3606 1617 Mail Service Center, Raleigh, NC 27699-1617 Express Mail: 512 N. Salisbury St., Raleigh, NC 27604 Original Message From: mtncallie@everyactioncustom.com[mailto:mtncallie@everyactioncustom.com] Sent: Thursday, January 14, 2021 10:21 AM To: Chernikov, Sergei <sergei.chernikov@ncdenr.gov> Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spam@nc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Department of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill discharge more. Thank you for the opportunity to comment and your consideration of these important issues for the continued improvement of water quality in the Pigeon River. Sincerely, Callie Moore 3190 Tusquittee Rd Hayesville, NC 28904-7592 mtncallie@gmail.com From: Chernikov, Sergei To: SVC DENR.publiccomments Subject: FW: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 14, 2021 10:13:20 AM Sergei Chernikov, Ph.D. Environmental Engineer III Industrial NPDES Permitting Unit NEW Tel. 919-707-3606 1617 Mail Service Center, Raleigh, NC 27699-1617 Express Mail: 512 N. Salisbury St., Raleigh, NC 27604 Original Message From: mary@everyactioncustom.com [mailto:mary@everyactioncustom.com] Sent: Thursday, January 14, 2021 10:12 AM To: Chernikov, Sergei <sergei.chernikov@ncdenr.gov> Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spam@nc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Department of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. I hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Mary Goodkind 23 Ridgefield PI Biltmore Forest, NC 28803-3019 mary@lindleyg.com From: To: Subject: Date: ploarkofalaol.con1 Gurney, Anna' aohamis900a0Jail.com: SVC DENR.oubliccomments. jonathon.burrrmtn.aov. duane.uhlsOnewoortolaintalk.com Re: [External] CANTON Thursday, January 19, 20219:22:36 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Soam ----Original Message From: Gumey, Anna <anna.gurney@ncdenr.gov> To: olparko@aol.com <olparko@aol.com> Cc: jan.compton@tn.gov <jan.compton@tn.gov> Sent: Thu, Jan 14, 2021 8:15 am Subject: FW: [External] CANTON Hello Ms. Overall, Below are responses to your follow up questions. 1. Who is your lab (Name, phone number): As mentioned DEQ has an in-house chemistry lab under its Water Science Section located in Raleigh. https//deq.nc gov/about/divisions/water-resources/water-resources-data/water-sciences-home-nage. Questions for the lab group may be routed through me. Please be aware, generally paper companies over the past several years are no longer using the industrial process that creates dioxin. Lab work is not performed for dioxin in the Pigeon as it is no longer present in the permittee's effluent water. Perha.s ou did not read the articles I sent ou. Or the Abstract. Oh es, dioxin is present. That - for your/NC purposes - it is not present -is irreoneous, and in m 2. Questions surrounding abstract: Thank you for sending over. However it remains unclear as to your questions related to it. Please provide direct questions and I will provide responses to you, or refer you to the documents previously sent by Serge Chernikov and me. 3. Mussels & the Pigeon: As mentioned, DWR does not conduct testing specifically for mussels. The latest biological assessment data on the Pigeon can be found in the table below. Our normal five-year schedule is 2012, 2017 and next will be 2022. The 2014 data you have was from an additional study conducted between the scheduled ones. Isn't that interesting? All those years of color and dioxin and you don't test the mussels? After all Canton has done to us for 113 years on the Pigeon River, formerly known as the, Dead Pigeon River. And NC doesn't test the mussels? And what with all those endangered mussels that only occur on the Western side of Appalachia. From: "THE HISTORY of the PIGEON RIVER RECOVERY PROJECT:" • Paper mill in Canton, NC began operations in 1908. Its toxic effluent extirpated all snails, mussels and most fish species • Effluents included coffee colored tannins and lignins, toxins such as dioxin • Under TN Water Control Act, TN has right to unpolluted water • TN must reclaim polluted waters • TDEC initiated efforts to restore the rivers ecosystem • Modernization of mill processes drastically reduced waste effluent • This led to a return of some fish species; however, 24 non -game species were still missing. It was fascinating speaking to one of the scientists on this study. Yet, you are just testing for bugs and snails?' I don't call that an abundance of caution on North Carolina's part. By the way, I just received a video where the color of the Pigeon is dark and unacceptable. And the poor neighbors - say it stinks to high heaven. Really? After all these years? That's just not going to work for us anymore. Plain words are best understood. Benthic Community Table Stream PIGEON R PIGEON R PIGEON R PIGEON R PIGEON R PIGEON R PIGEON R Site Location I-40 OFF NC 215 OFF NC 215 SR 1338 SR 1338 SR 1642 SR 1642 County Cocke, TN Haywood Haywood Haywood Haywood Haywood Haywood Slte ID EB250 EB251 EB251 EB254 EB254 EB257 EB257 Collection date 8/22/2012 8/21/2012 8/24/2017 8/22/2012 8/23/2017 8/21/2012 8/24/2017 BAU sample number 11485 11489 12290 11490 12283 11488 12289 Sample method Full Scale Full Scale Full Scale Full Scale Full Scale Full Scale EPT Criteria Summer/ Mountain Summer/ Mountain Summer/ Mountain Summer/ Mountain Summer/ Mountain Summer/ Mountain Summer/ Mountain Richness Ephemeroptera 20 19 16 20 16 10 4 Plecoptera 3 2 1 5 3 0 3 Trichoptera 14 13 10 17 10 11 11 Odonata 2 12 10 11 7 9 Megaloptera 1 2 2 2 2 1 Coleoptera 3 7 7 9 8 6 Chironomidae 6 17 13 6 12 8 non-Chironomidae Diptera 6 2 1 3 2 3 Oligochaeta 2 1 2 1 2 1 Mollusca 4 6 6 6 7 3 Other taxa 4 7 3 4 6 4 Total taxa richness 65 88 71 84 75 56 Other biological metrics Total EPT 37 34 27 42 29 21 18 Seasonal EPT Corrected EPT EPT abundance 244 189 80 203 176 121 100 EPT Biotic Index 3.25 3.45 3.30 3.52 3.65 4.15 4.29 NCBI 3.55 4.24 5.01 4.30 4.74 5.50 --- Seasonal Correction Corrected NCBI Bioclassification Excellent Good Good -Fair Good Good Good -Fair Fair * denotes a tentative classifeation 4: "dark seepage" on the north bank of the river mentioned in the 2007 Shareholder Report ... So is 2020. What is causing the color and the seepage? DWR has no indication of issues related to "dark seepage. What in the world would TN gain out of lifting this color variance? Did you get pressure? Political pressure? Shareholder pressure? Why in the world would NC do this? From the reevaluation document, previously sent to you and located on our website, supporting the variance removal: Based on the evidence and data presented, the Division of Water Resources believes that the current Blue Ridge Paper, LLC discharge (where is the evidence that your belief is valid, Anna??999 ) meets the North Carolina narrative standard, and that the facility does not qualify for a continuance of the variance under regulations in 40 CFR Part 131, as the original variance was written for an expected limited timeframe and purpose and the state may not adopt a variance if the criterion can be achieved. The Division believes that through the past diligent application of advanced and innovative technology, akin to a "Pollutant Minimization Plan", according to 40 CFR Part 131.14 (b)(1)(ii)(A)(3) and a reevaluation under the requirements of 40 CFR Part 131.14 (b) (1)(v), the facility has achieved compliance with the intention of the NC narrative water quality standard at 15A NCAC 02B .0211 and is no longer eligible to continue the variance. Please note that removing or "lifting" the color variance means that Blue Ridge would now be required to comply with our state's water quality standards, which they have successfully achieved through "application of advanced and innovative technology." Detailed info can be found in the documents sent to you previously. Clearly - you did not read the articles I sent. I am not impressed with NC standards. The destruction of the Pigeon River is no longer acceptable to the TN side of the line. If I am not mistaken, I am not alone in this matter. There comes a time- enough is enough. That's in human terms. That's just in plain old terms of humanity. At this point, I'm willing to put my money where my mouth is. Enough. Look at the history. All NC has done is defend this plant to employ NC folk. That's all NC has been done on the backs of the poor hill people of TN. Look at the damage. Per the science -I sent you--- it's irreversible. So, you writing me as though I am an amateur is not to be tolerated. Send me to your supervisor if need be. Quoting NC law to me is not Federal law nor is it TN State Law. And if the EPA cannot arbitrate on behalf of TN on this - then there's a real big problem here. And the BFR Canton installed is how old? Exactly how old? 20 years or more? That would no longer be state of the art. 5.Your request to extend the public comment period and the emails from other citizens that were inadvertently sent to me, were routed to the correct email address. We appreciate the comments, but under requirements mandated by the CWA and state procedures, comments must be sent to the proper email address, which insures receipt and consideration. Thanks in advance for passing this info along to your group for any future comments. Seriously? I'll ask my atty about that. I figure you got 10 or so notices from TN folk from concerned citizens that I alerted. I trust those comments will be included in the Public Comments for the Public Record. I will be looking for them. Further, Anna, again, the decisions we make today determine the future of this planet and that paper mill has long since warn out its welcome in TN. Not to put too fine a point on it, Anna, but we're done over here. Between NC and TN, EPA, F&W, etc. all the regulators are dropping the ball and I'm done having to play this game. Park Overall Anna From: oloarko@aol.com [mailto:oloarko@aol.com] Sent: Tuesday, January 12, 2021 4:49 PM To: Gurney, Anna <anna.gurney@ncdenr.gov>. aoharris40@gmail.com• jan.compton@tn.gov hesterlee.craig@eoa.gov Subject: [External] CANTON CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Soam Hello Ms. Overall, According to our phone conversation and a previous email from you, you are requesting from NC Division of Water Resources, the following information (my responses in red): 1. Balanced and Indigenous Species Study on the Pigeon River in January of 2014 I provided a link to the study on 1/9/2021; you confirmed receipt and that this was the document you requested In that case, I would like to formally request an extension on this permit. My secretary had to quarantine for Covid and I am running behind. Since we have a history with Canton since 1908, and we have not been on the winning side of the border, I formally request a 45 day extension due to the pandemic. The choices we make today determine the future of this planet and we feel the Pigeon is a serious problem that requires serious work and attention. I will have to send the study you sent me to UPS to copy for me. They are available today. Again, this is a formal request for 45 day extension on this permit. Request for hard copy: Due to the COVID 19 pandemic, many of the NC staff members are working from home. Therefore there would be a delay in fulfilling your request, and as you mentioned a fee. I will have to check but I believe it's 10 cents per page and postage. Please let me know if you still wish to receive it. 2. In laymans terms, the exact kinds of Dioxin NC DEQ measures for, how often tests are performed - and if they appear, what happens? Please review the following documents for answers, as all are written for public understanding: attached Draft Permit (the Dioxin Condition is on page 17. If they violate permit limit, there will be a fine or violation notice) The reason I ask is because — back in the day- on an NBC? ABC? news channel - the VP of Champion told me the dioxin in the river was from tires in the water. Tires in the water. I just don't want to be hoodwinked again. I hope you understand. • Draft Fact sheet link https://files.nc.gov/ncdeq/272-Draft%20fact%20sheet%20- %202020.pdf • And from the EPA: https://www.epa.gov/dioxin/learn-about-dioxin I think I told you on the phone, I was not a beginner? Didn't I? I think I did. 3. Who is your lab? State of NC has its own lab. When the state examines waters for Dioxin, a certified contract laboratory is used Again, what is the name your lab? I also require the address and phone # for it. 4. Request for a discussion w/Anna of abstract sent to Sergei C. We have not received an abstract from you. Sergei has received emails with various comments in which he has responded. If you have specific questions related to an abstract, please email to me with questions and I will obtain responses. I have attached one of the abstracts here. The questions re: this particular abstract- speak for themselves. I have also contacted NIH and am waiting to hear back. 5. Formal request for an extension on this permit comment time. A formal request should be emailed to: publiccomments@ncdenr.gov. You can also make this request during Public Hearing as the decision on the extension of the comment period will be made by that Hearing Officer. https://deq.nc.gov/news/press- releases/2020/11 /24/deq-sets-public-hearing-date-and-accepts-public-comments-blue- ridge. Will do. 6. A contact person in the State of Tennessee, as you explained you were unable to locate the correct contact there later mentioning Johnathan Burr. I enjoyed him very much. I look forward to his comments on behalf of TN, to NC. Please contact Jan Compton for any inquiries related to Tennessee. I will be your contact for NC inquiries moving forward. I thought we had established that already? 7. Mussels and the Pigeon DWR requires one biological assessment during a permit cycle (5 years). Our next biological communities assessment is scheduled for 2022. Our data and collection methods are not specific to mussels. The N.C. Wildlife Resources Commission (and some academia) conduct mussel -specific surveys, and they may have data to better address your mussel questions. The study you sent me is dated 2014? This is 2021? So where is your once every 5 year study? I require a copy of that. Why is there still color in the river? What is the color that is going in the river? How much of it is old? How old is it? How much of it is Dioxin? In fact, what is the chemical content of the color? In parts per million of each chemical you list for me. I'm not asking you for what you test for ---I'm asking you for exactly--- what it is? Exactly what is in the color? If you don't know, who does? The natural color of ambient water varies across the state. Many factors can change the color such as leaf litter, natural decay of plant materials, presence or absence of clay soils, etc. Dioxin is colorless and numerical limits for the discharge are regulated by the permit (in accordance with applicable water quality standards) to assure protection of downstream uses. See Question 2 (above) for the US EPA link to published information on Dioxin. Again, more information can be found in the permit renewal fact sheet and other documents provided to you previously. Here are a couple more resource links in case you do not have these: https://www.tn.gov/content/dam/tn/environment/water/documents/Pigeon_02_Report.pdf https://deq. nc.gov/news/events/notice-intent-issue-npdes-wastewater-discharge-perm it- nc0000272-proposed-removal-color https://deq. nc.gov/news/events/notice-intent-issue-npdes-wastewater-discharge-permit- nc0000272-proposed-removal-color My main question is re: the "dark seepage" on the north bank of the river mentioned in the 2007 Shareholder Report which I copied and pasted to you. It is also available online. So is 2020, which is very interesting. What is causing the color and the seepage? I have spoken with your, Lee Hill, today. He has no idea. He referred me to a geologist, Ms. Wiener, and she has not yet returned my call. My other question is what in the world would TN gain out of lifting this color variance? Did you get pressure? Political pressure? Shareholder pressure? Why in the world would NC do this? Perhaps you could explain it to me in a way that would make sense to Tennesseans? That would be appreciated. I believe this covers all your inquiries. Lastly, thanks for your interest in these proceedings, and as mentioned above, please submit all public comments through the following email address: publiccomments@ncdenr.gov, with Blue Ridge Paper in the subject line. This assures that your concerns and comments are submitted for consideration in the official proceedings conducted by the Department. I have sent folks to you already. Please assure me you are forwarding those comments onto the correct email. I have 2 other comment periods coming due on the TN side of the line at the same time-ish. And, as I said, my secy has been out. So. Take care, You too. Park Overall Anna Gurney From: To: Subject: Date: Anderson Huffman SVC DENR.publiccomments [External] Blue Ridge Paper Products, NC #0000272 Friday, January 15, 2021 7:18:47 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. The pigeon river has been ruined from the dumping of toxic waste. I was told as a child in the 1960s not to swim or drink from the dark brown water. I was amazed that the color of the river was absent just upriver from the canton paper mill. The river is starting to look better many years later. Don't let the paper mill ruin the river again. AK Huffman From: To: Subject: Date: Monika Knizley SVC DENR.publiccomments [External] Blue Ridge Paper products, NC #0000272 Friday, January 15, 2021 12:13:22 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. To Whom It May Concern, I can not fathom why you would remove the "color variance" protections from the permit. If the company is doing what it is supposed to and being a good neighbor, they should be able to meet or even exceed the testing standards. Instead they want it removed, this shows me that the company does not want to preserve the waterways and does not want testing. That means we need to test them and hold them to the highest standard for wild life, and our grandchildren. We do not get many chances in life to make a stand, here is the opportunity for the government to show the people that you know what is the right thing and do it! Clean Water is everyone's responsibility, and it sits on your shoulders to ensure that Paper Mill does it part and continues to clean the river above its current values to ensure that the future has clean water. Sincerely a Concerned Citizen, Monika Knizley 122 Laurel Trail Cosby, TN 37722 From: To: Subject: Date: couchx4 SVC DENR.publiccomments [External] FW: Friday, January 15, 2021 4:11:27 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Sent from my Verizon, Samsung Galaxy smartphone Original message From: couchx4 <couchx4@bellsouth.net> Date: 1/11/21 8:04 PM (GMT-05:00) To: anna.gurney@ncdenr.gov Subject: No-- to the variance on NPDES RENEWAL NC0000272. No-- to the variance on Blue Ridge Paper Products. Sent from my Verizon, Samsung Galaxy smartphone From: To: Subject: Date: William Woody SVC DENR.oubliccomments [External] Fwd: No-- to the variance on NPDES RENEWAL NC0000272 Blue Ridge Paper Products Friday, January 15, 2021 5:16:53 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Mrs. Gurney and all those concerned, I am sending this email to offer my opinion on the variance requested by Blue Ridge Paper Products company. The variance needs to be denied. The river in Newport Tennessee still 30 years later is not clean. It's still far from the pristine river it once was. Has it improved, it has, I remember standing on the banks with my father and uncles as we fished watching gobs of white foam floating down past us the smell unimaginable. Yet today, the fish still aren't safe to eat. Dioxin signs are still posted. Mercury signs have recently been added and posted. The water still has a smell that makes it clear that it's not clean and pure. Too much damage was done...we cannot walk it back. We've watched it slowly...ever so slowly get to where it is today. Eagles nesting in the cliffs across from the courthouse in downtown Newport. More wildlife coming in year after year. Cranes, geese, ducks. More fish, larger fish. Why risk undoing that, for a little bit more money in the pocket of the company that destroyed the river to begin with. Choose what's right, Come down visit Newport and it's River Walk. See what an investment in the river does for communities. Don't let them destroy it again. William M. Woody Parrottsville, Tennessee From: swarren28806@everyactioncustom.com on behalf of Rev.Susan Warren To: Chernikov, Seraei Subject: [External] Keep Pollution Standards HIGH for Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:40 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. It feels vitally important to me ecologically to keep the highest enviornmental standards for the Pigeon River. Revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. Either the company itself could and should find cleaner ways to produce the paper, and or the regulators should achieve those goals while balancing the interests and needs of industry by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept linent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Rev.Susan Warren 656 Sand Hill Rd Asheville, NC 28806-1554 swarren28806@gmail.com From: meredith.dowling@aevervactioncustom.com on behalf of Meredith Dowling To: Chernikov Sergei Subject: [External] NPDES permit for Blue Ridge Paper Products (NC#0000272) Date: Friday, January 15, 2021 9:04:02 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft NPDES permit for Blue Ridge Paper Products (dba Evergreen Packaging) is a step backwards for addressing water quality issues that threaten the health of the Pigeon River. As a WNC resident with an MS Environmental Science and a background in water quality, I support the permit analysis conducted by local Waterkeepers and urge you to correct the following deficiencies before finalizing the permit: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade, with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for TSS and BOD. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream recreational users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit increases those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Meredith Dowling 23 Normandy Rd Asheville, NC 28803-2222 meredith.dowling@gmail.com From: kandsteve@everyactioncustom.com on behalf of Kaye Cox -Andrews To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:40:07 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, I am very disappointed that the draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. As a former raft guide on the Pigeon river and a current recreational boater there, I am particularly concerned about persons who might swim in it, accidentally or intentionally. Please consider that the way to improve water quality would be to slowly reduce permit discharge limits over time. The draft permit as proposed by the Depai l.ment of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Current hot water temperature limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a DAILY average limit for the mill. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Kaye Cox -Andrews 8 Sandon Cir Asheville, NC 28804-2421 kandsteve@bellsouth.net From: rb719504@everyactioncustom.com on behalf of Randy Bernard To: Chernikov, Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:40:14 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backward when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Department of Environmental Quality (DEQ) takes a step backward by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Randy Bernard 18 Plateau Rd Asheville, NC 28805-1955 rb719504@gmail.com From: ELIENELLIE4Cc@evervactioncustom.com on behalf of Claudia Nix To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:40:18 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. I do not understand why the DEQ would desire reducing the discharge allowance which will increase dangerous chemicals in the water. DEQ should be working to improve water quality not reduce it. Please stay on the line to improve water quality not reduce it. Thank you for your time and consideration of these important issues. Sincerely, Claudia Nix 72 Sherwood Rd Asheville, NC 28803-2437 ELIENELLIE4@GMAIL.COM From: vbower@everyactioncustom.com on behalf of Virginia Bower To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:53:50 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, For our planet's sake, for our children's sake, for their children's sake. Let's be good stewards of this beautiful planet. The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept anent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Virginia Bower 45 Kenilworth Rd Asheville, NC 28803-2542 vbower@mhu.edu From: mollyhannahmcintoshCa@everyactioncustom.com on behalf of Molly McIntosh To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:54:10 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Molly McIntosh 709 Brookshire St Asheville, NC 28803-2817 mollyhannahmcintosh@gmail.com From: pmomich@everyactioncustom.com on behalf of Pat Momich To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:55:01 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Pat Momich 7839 NC 208 H Marshall, NC 28753-7536 pmomich@gmail.com From: barbarasloss@everyactioncustom.com on behalf of Barbara Sloss To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:55:10 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Our waterways are important resources held in common that need protection and oversight from DEQ. Clean, unpolluted, water is used by people for recreation and consumption and should not be degraded by industry. It all flows downstream and point source pollution can be prevented if there is the political will and funding (which the user should shoulder a great deal of that burden). Thank you for your time and consideration of these important issues. Sincerely, Barbara Sloss 5 Wagon Rd Asheville, NC 28805-2613 barbarasloss@yahoo.com From: ivan marcotte@everyactioncustom.com on behalf of Ivan Marcotte To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:55:17 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Ivan Marcotte 60 N Market St Apt 801 Asheville, NC 28801-8122 ivan_marcotte@yahoo.com From: rebeccancarrier@evervactioncustom.com on behalf of Rebecca Carrier To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:55:18 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Rebecca Carrier 26 Luther Franklin Ln Linville Falls, NC 28647 rebeccancarrier@gmail.com From: dewaldg@evervactioncustom.com on behalf of George deWalder To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:55:23 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Clean water benefits everyone. It should not be full of pollution! Thank you for your time and consideration of these important issues. Sincerely, George deWalder 48 Stratford Rd Asheville, NC 28804-1517 dewaldg@charter.net From: aimeeoallozzi(&evervactioncustom.com on behalf of Aimee Pallozzi To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:55:27 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Aimee Pallozzi 20 Whitted Kill Candler, NC 28715-9201 aimeepallozzi@gmail.com From: alyssamelton16@everyactioncustom.com on behalf of Alvssa Melton To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:55:36 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Alyssa Melton 21 Reynolda Dr Asheville, NC 28803-9518 alyssamelton16@gmail.com From: southworthw@everyactioncustom.com on behalf of Win Southworth To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:55:40 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, Please revise the discharge permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. Regulations must not be made less strict. Gradually reducing permit discharge permits over time is the way to proceed. Frequent monitoring needs to be steady to enforce that pollutant levels get healthier over time. Please correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Win Southworth 211 Pine St Black Mountain, NC 28711-3021 southworthw@hotmail.com From: cindy shealy@everyactioncustom.com on behalf of Cynthia Shealy To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:55:52 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Cynthia Shealy 8 Tarpon Ave Asheville, NC 28806-3122 cindy_shealy@charter.net From: andrew.breunig@everyactioncustom.com on behalf of Andrew Breuniq To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:55:54 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Andrew Breunig 62 Belmont Ave Asheville, NC 28806-3119 andrew.breunig@gmail.com From: timbirth@everyactioncustom.com on behalf of Timothy Birthisel To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:55:55 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, I was recently surprised to learn that the draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. Regulators should achieve the goals of the continuous improvement we badly need in this situation while balancing the needs of industry is by slowly reducing permit discharge limits over time. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain or increase the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues, I sure hope you will rethink this plan! Sincerely, Timothy Birthisel 19 Sourwood Ln Asheville, NC 28805-2626 timbirth@gmail.com From: tbyersabc@everyactioncustom.com on behalf of Tom Byers To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:55:59 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Tom Byers 467 Old Stone Gate P1 Asheville, NC 28804-8300 tbyersabc@gmail.com From: alixgarrison(aevervactioncustom.com on behalf of Alix Johnson To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:10 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Alix Johnson 76 N Liberty St Asheville, NC 28801-1831 alixgarrison@gmail.com From: cisimonds4@ evervactioncustom.com on behalf of Cynthia Simonds To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:12 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. Clean, abundant water for fish and wildlife habitat make it possible for sportsmen and women to pursue their passion. Every year, over 47 million Americans head into the field to hunt or fish. The hunting and fishing industries in the United States directly employ 483,000 Americans and adds billions of dollars in additional spending. The economic benefits of hunting and fishing — which total $200 billion a year — are especially pronounced in rural areas. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Department of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Cynthia Simonds 704 Laurel Ave Black Mountain, NC 28711-2926 cjsimonds4@gmail.com From: AnitaAnita@everyactioncustom.com on behalf of Anita Slavkoff To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:13 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Anita Slavkoff 71 A Magnolia Ave Asheville, NC 28801-1728 AnitaAnita@aol.com From: jwibdarrett(aevervactioncustom.com on behalf of Janet Garrett To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:13 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept liuent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. DEQ should maintain the same Dioxin sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Janet Garrett 40 Deerhaven Ln Asheville, NC 28803-3304 jwjbgarrett@gmail.com From: bjgrasso@everyactioncustom.com on behalf of Brian Grasso To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:16 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Brian Grasso 53 Alabama Ave Asheville, NC 28806-4163 bj grasso@alumni.unca. edi From: stevewilcox397@everyactioncustom.com on behalf of Stephan Wilcox To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:19 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Stephan Wilcox 294 Gardenside Rd Mars Hill, NC 28754-5786 stevewilcox397@gmail.com From: sweissman4@everyactioncustom.com on behalf of Stephen Weissman To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:21 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Stephen Weissman 8 Oak Ct Candler, NC 28715-9454 sweissman4@gmail.com From: ronlambe@everyactioncustom.com on behalf of Ron Lambe To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:23 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Ron Lambe 104 Trotter P1 Asheville, NC 28806-2523 ronlambe@yahoo.com From: j1428182©evervactioncustom.com on behalf of Justin Landry To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:26 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Justin Landry 119 Chestnut P1 Arden, NC 28704-2902 j1428182@yahoo.com From: ernestwboyd@evervactioncustom.com on behalf of ernie bovd To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:27 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, ernie boyd 167 A Pearson Dr Asheville, NC 28801-1600 ernestwboyd@gmail.com From: rich(aevervactioncustom.com on behalf of Richard Boulter To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:30 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Richard Boulter 404 Mandavilla Dr Burnsville, NC 28714-9369 rich@appdrywall.com From: ryanlansche@everyactioncustom.com on behalf of Ryan Lansche To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:33 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Ryan Lansche 121 Chatham Rd Asheville, NC 28804-3307 ryanlansche@gmail.com From: karkra©everyactioncustom.com on behalf of Richard Kark To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:35 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Richard Kark 420 Lady Huntingdon Ln Asheville, NC 28803-2000 karkra@uwec.edu From: cathv.nieman@aevervactioncustom.com on behalf of Cathy Nieman To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:38 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Cathy Nieman 312 Ivy Hill Rd Weaverville, NC 28787-9652 cathy.nieman@gmail.com From: maglionicl@everyactioncustom.com on behalf of Jude Maglione To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:44 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Jude Maglione 10 Moreview Dr Asheville, NC 28803-2713 maglionicl@aol.com From: degravejc@everyactioncustom.com on behalf of James DeGrave To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:46 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, James DeGrave 35 Yorktown Cir Arden, NC 28704-9692 degravej c@charter.net From: timothy@evervactioncustom.com on behalf of Timothy Burgin To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:51 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Timothy Burgin 135 Louisiana Ave Asheville, NC 28806-3421 timothy@japamalabeads.com From: dwcurtevervactioncustom.com on behalf of David Curtis To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:56:57 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, David Curtis 10 Southwicke Ct Arden, NC 28704-9433 dwcurt@charter.net From: vic.reiser11@evervactioncustom.com on behalf of Victoria Reiser To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:57:15 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Victoria Reiser 387 Stoney Fork Rd Barnardsville, NC 28709-9799 vic.reiserll@gmail.com From: amarkie1998@everyactioncustom.com on behalf of Alysha Pennachio To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:57:27 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Alysha Pennachio 56 Salem Ave Asheville, NC 28804-3338 amarkie1998@yahoo.com From: Msgailt@everyactioncustom.com on behalf of Gail Thomas To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:57:30 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, Please make all of our streams, rivers, lakes and all water at all levels in this state safe for both swimming and fishing! ! ! ! The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Depai anent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Gail Thomas 447 Webb Cove Rd Asheville, NC 28804-1963 Msgailt@bellsouth.net From: stokely.jim@everyactioncustom.com on behalf of )im Stokely To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:57:59 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The purpose of the Clean Water Act of 1972, which has since been amended with no alteration to its main purpose, is to "restore and maintain the chemical, physical, and biological integrity of the Nation's waters." Two important variables contributing to the integrity of water are color and fecal coliform. I take extreme exception to the NC DEQ's draft permit recommendation to remove the color variance, and to set a Fecal Coliform limit of 200/100mL monthly average, for Blue Ridge Paper Products. These revisions to the existing permit would severely impact any progress the City of Newport, Tennessee, has made with regard to utilizing the Pigeon River for primary recreation activities such as wading, swimming, or simply strolling beside the Pigeon River and admiring its beauty. With regard to color, a 2002 US Department of Agriculture Report noted that "Public perceptions of pollution influence decisions to recreate...Water clarity is important for swimming suitability...Similarly, water color influences recreation decisions with blue being most suitable, followed by green, and lastly yellow." There are large perceptual differences between the light yellow at 25 PCU (Platinum -Cobalt Units), the barely tolerable yellow at 50 PCU, and the heavy yellow at 100 PCU. The current permit allows BRPP "an instream true color value of 50 platinum cobalt units," and the current permit requires that "the facility meet an instream color of 50 PCU at the TN/NC state line." The draft permit proposes removing the instream PCU limit altogether, and moving the monitoring requirement "that the facility meet a monthly average delta (A) Color of 50 PCU" to the Fiberville Bridge. These changes would reverse the incremental progress that has been made to get the Pigeon River to point where it suitable for primary recreation. Please retain the current permit's provisions affecting color, and consider lowering the instream 50 PCU limit in order to encourage swimmers, waders, etc. With regard to fecal coliform, the EPA recommended 2012 recreational water quality criteria for E.coli in fresh water, even estimating that 32 of every 1,000 primary contact recreators would become ill, was an average 100 colony forming units per 100 milliliters (cfu/100 mL). The draft permit proposes a limit of 200 cfu/100 mL. Please lower the limit to 100 cfu/100 mL or below to be consistent with recommended EPA standards. Sincerely, Jim Stokely 60 Shuford Rd Weaverville, NC 28787-9478 stokely.jim@gmail.com From: michaeldbeth@everyactioncustom.com on behalf of Mary Beth Fields To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:59:41 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Mary Beth Fields 123 Carriage Dr Fairview, NC 28730-7633 michaeldbeth@bellsouth.net From: porterkiger@everyactioncustom.com on behalf of Kim Porter To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:00:21 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Kim Porter 26 Twin Hills Dr Weaverville, NC 28787-9498 porterkiger@gmail.com From: Ibo.boggess@ evervactioncustom.com on behalf of Laura Boggess To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:00:47 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Laura Boggess 501 Bailey St Mars Hill, NC 28754-6209 lbo.boggess@gmail.com From: wolfmommv@evervactioncustom.com on behalf of Nancy Brown To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:00:53 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Nancy Brown 48 Elijah Hall Rd Black Mountain, NC 28711-8805 wolfmommy@msn com From: vfahrer@everyactioncustom.com on behalf of Victor Fahrer To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:00:57 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Victor Fahrer 333 Montford Ave Asheville, NC 28801-1609 vfahrer@charter.net From: chelsea@evervactioncustom.com on behalf of Chelsea Easter To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:02:51 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Chelsea Easter 35 Haywood St Asheville, NC 28801-2875 chelsea@southwings.org From: maryannerackoff@ everyactioncustom.com on behalf of Maryanne R.Rackoff To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:03:33 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, Blue Ridge Paper Products has a long history on the Pigeon River in Canton. It has provided good quality jobs for decades, but also caused significant environmental impacts to the Pigeon River. Significant improvements in the amount and quality of the discharge to the river have helped, but more is needed. The draft permit as proposed by the Depat linent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Maryanne R. Rackoff 45 Tree Top Dr Arden, NC 28704-3040 maryannerackoff@yahoo.com From: christmerrick@caevervactioncustom.com on behalf of Christine Merrick To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:03:38 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, After the Flint Michigan disaster, we all need to be more on the watch for pollutants getting into our waterways. Clean water is so important for us and our children. These pollutants will affect not only the people in Canton but all of us. We need to realize that the earth is a valuable resource and should be cared for and respected in order to insure it's habitability for generations to come. The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept anent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Christine Merrick 117 Buckner Rd Black Mountain, NC 28711-9494 christmerrick@gmail.com From: mletsjov@evervactioncustom.com on behalf of Morris Letsinger To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:04:50 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Morris Letsinger 123 Virginia Ave Asheville, NC 28806-3217 mletsjoy@gmail.com From: emily@everyactioncustom.com on behalf of Emily Zucchino To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:04:56 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, As a longtime resident of WNC, I am very concerned about the weakening of these regulations. The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept l.ment of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Emily Zucchino 80 Debra Ln Asheville, NC 28806-1904 emily@dogwoodalliance.org From: helenhevr otterv(�evervactioncustom.com on behalf of Helen Hev To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:05:18 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept ltuent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. I know that for my own family, I check the volume and speed of the river before we get in our kayaks to explore a section. I trust that our governments standards in the Clean Water Act have been monitored and met. I would hope that 3 times every 5 years is NOT too many times. If I had my way, it would be checked every year, but I understand we need to compromise. I just think we don't have to compromise AGAIN. The Clean Water Act already accounted for compromises needed to keep businesses afloat. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Helen Hey 214 Pine St Black Mountain, NC 28711-3022 helenheypottery@yahoo.com From: rosecare@everyactioncustom.com on behalf of carolyn lewellen To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:05:23 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spam(a@nc.gov> Dear Water Resources Sergie Chernikov, I am shocked and angry, actually, that the standards for clean water which is safe for fish and for swimming are not being improved, but allow more dangerous discharge and worse conditions. It is bad enough that the paper plant releases waste, but that the water treatment for Canton releases unacceptable amounts of E-coli into the river. The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. I support the suggestions made by Mountain True and Urge you to improve the quality of our mountain water ways and the quality of life for all of us in the mountains and down stream. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Department of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, carolyn lewellen 64 Beasley Cove Rd Hot Springs, NC 28743-7252 rosecare@frontier.com From: neylanIk@evervactioncustom.com on behalf of Lisa Nevlan To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:05:29 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, I moved here for the recreational opportunities, and that requires clean water. The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept tinent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Lisa Neylan 414 Windswept Dr Asheville, NC 28801-4214 neylanik@gmail.com From: kenworthy.sarah@everyactioncustom.com on behalf of Sarah Hutcheson To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:05:30 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Sarah Hutcheson 134 Hilltop Rd Black Mountain, NC 28711-2620 kenworthy.sarah@gmail.com From: cj7steen@everyactioncustom.com on behalf of Lynn Hanson To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:05:33 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The citizens of this area value, use and need our river. We cannot use our river if it is not clean. This is a valuable resource and contributes to NC's huge outdoor, recreation and tourism industries. The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Lynn Hanson 20 Kirby Rd Asheville, NC 28806-8908 cj7steen@yahoo.com From: eddcort3@everyactioncustom.com on behalf of Edward Cortright To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:05:37 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spam(a@nc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Edward Cortright 4 Alpine Way Asheville, NC 28805-1536 eddcort3@gmail.com From: fillory@evervactioncustom.com on behalf of Toni Meador To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:05:37 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Toni Meador 84 Distant View Dr Asheville, NC 28803-2477 fillory@aol.com From: chas.jansen@everyactioncustom.com on behalf of Charles Jansen To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:05:40 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, As a person of faith responding to scriptural callings to care for Creation, I believe we must do better to protect water purity for all the life that depends upon it. The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable & supportive of the natural biodiversity of WNC. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Depat anent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, adversely impacting fish & other wild life. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills specifically are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Please take greater responsibility by protecting the Pigeon River so that it continues to support - rather than degrade - the many living communities that depend upon it. Thank you for your time and consideration of these important issues. Sincerely, Charles Jansen 98 Dorchester Ave Asheville, NC 28806-3525 chasjansen@mtsu.edu From: lenorekw@everyactioncustom.com on behalf of Lenore Madeleine To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:05:43 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Lenore Madeleine 700 Vista Lake Dr Apt 308 Candler, NC 28715-7191 lenorekw@yahoo.com From: hermanralohCo evervactioncustom.com on behalf of Ralph Herman To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:05:44 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Ralph Herman 110 Pyatt Heights Rd Marion, NC 28752-5781 hermanralph@gmail.com From: cathdoug@everyactioncustom.com on behalf of Catherine Douglass To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:05:46 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Catherine Douglass 111 Zander Way Asheville, NC 28805-1564 cathdoug@gmail.com From: lea.dutton@everyactioncustom.com on behalf of Elizabeth Dutton To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:05:48 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, Hello, I am writing to ask that the draft permit as it stands is updated to strengthen, not weaken, discharge and monitoring levels. As you know, the purpose of the Clean Water Act was to make Pigeon River safe for fishing and swimming This is still not a reality and Blue Ridge Paper Products needs to be encouraged through stronger regulations and close monitoring to continue to improve their processes. As a taxpayer, I expect my hard-earned tax dollars to go toward making our waters safer, not backtracking. Here are some specific issues that need to be addressed through stronger regulations and monitoring: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. We are calling on the Department of Environmental Quality to create a daily average limit for the mill, so we can make sure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. For these reasons we call on DEQ to continue the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. There is an urgent need for significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 lb/day (as monthly average) or 8.61b/day (daily maximum). The 2021 proposed permit ups those limits to 6.27 lb/day (as a monthly average) and 10.5 lb/day (daily maximum). DEQ should be reducing those allowance, not letting the papermill pollute more. Thank you for your consideration. Sincerely, Elizabeth Dutton 343 Hillside St Asheville, NC 28801-1358 lea.dufton@mindspring.com From: Iuogo.al.sole@everyactioncustom.com on behalf of Gina DeBreto To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:05:52 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Gina DeBreto 2 High Country Rd Weaverville, NC 28787-9374 luogo.al.sole@gmail.com From: karl.jsk88@everyactioncustom.com on behalf of Karl Kauffman To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:05:53 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Karl Kauffman 300 District Dr Apt 221 Asheville, NC 28803-0246 karl.jsk88@gmail.com From: weccleston(aevervactioncustom.com on behalf of James Eccleston To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:05:54 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, James Eccleston 48 Salola St Asheville, NC 28806-2409 weccleston@gmail.com From: mreynolds@everyactioncustom.com on behalf of joseah Reynolds To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:06:00 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Joseph Reynolds 62 Davenport Rd Asheville, NC 28806-2964 mreynolds@thefsi.us From: bw.trotter@everyactioncustom.com on behalf of Ben Trotter To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:06:04 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Ben Trotter 2 Maplewood Rd Asheville, NC 28804-2825 bw.trotter@gmail.com From: jickson28@everyactioncustom.com on behalf of James Dickson To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:06:04 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, James Dickson 372 Depot St Apt 114 Asheville, NC 28801-4367 jickson28@gmail.com From: jleeger@everyactioncustom.com on behalf of Josh Leeger To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:06:05 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Josh Leeger 155 Bradley St Asheville, NC 28806-4447 jleeger@gmail.com From: oavco@evervactioncustom.com on behalf of Gavin Dillard To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:06:16 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Gavin Dillard 528 Padgettown Rd Black Mountain, NC 28711-9408 gavco@me.com From: jeanann.wheelock@everyactioncustom.com on behalf of jean wheelock To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 9:45:16 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, jean wheelock 53 Trail Top Dr Asheville, NC 28805-0049 jeanann.wheelock@gmail.com From: jeanann.wheelock(aevervactioncustom.com on behalf of jean wheelock To: SVC DENR.publiccomments Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 10:18:19 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Public Comments Reviewer, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, jean wheelock 53 Trail Top Dr Asheville, NC 28805-0049 jeanann.wheelock@gmail.com From: bleep2112@everyactioncustom.com on behalf of Raymond Occhiointi To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 15, 2021 8:40:10 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Raymond Occhipinti 265 Brooklyn Rd Asheville, NC 28803-1509 bleep2112@yahoo.com From: To: Subject: Date: Thomas Wasmund SVC DENR.publiccomments [External] Regarding Blue Ridge Paper Products, NC #0000272 Friday, January 15, 2021 2:39:31 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. To whom it may concern, I'm writing to express my opposition to Permit #NC0000272. As stewards of our waterways it is essential that we enlist independent bodies to monitor and collect pollution data as is consistent with the Clean Water Act and especially that we should continue to require the existing color variance standards. Without independent monitoring we risk permanently injuring our waterways. Thank you, Thomas Wasmund I PE Proficient Engineering, Inc. I Mechanical 6025 BROOKVALE LN. SUITE 202 KNOXVILLE, TN 37919 D: 865.245.9198 C: 865.310.2563 0: 865.409.5755 proficientengineering.com Copyright - Proficient Engineering, Inc. From: JEFF LUSTER To: SVC DENR.publiccomments Subject: [External] "Blue Ridge Paper Products" Date: Saturday, January 16, 2021 1:45:23 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> NC is pulling a fast one. Say no to lifting the color variance. It does nothing for TN. It leaves us with stink and creepy color. I won't go in to the dioxins right now.The Canton Mill has done this to us for 113 years. That plant has long outlived it's life expectancy and to me, that is the most beautiful drive in the nation along the Pigeon. Yet they ruined it. The choices we make about this planet determine the future of the world. Thank you From: To: Subject: Date: Cheryl Vaughn SVC DENR.publiccomments [External] Blue Ridge Paper Products Saturday, January 16, 2021 12:20:47 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. No- to the variance on NPDES RENEWAL NC0000272. No- to the variance on Blue Ridge Paper Products. From: To: Subject: Date: Robert Otto SVC DENR.publiccomments [External] Blue ridge paper. NC 272 Saturday, January 16, 2021 11:01:02 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. If a permit is needed then it is clearly against the public interest so, obviously, the permit should be denied. From: To: Subject: Date: Mark Bourne SVC DENR.oubliccomments [External] Fwd: Blue Ridge Paper Products Saturday, January 16, 2021 9:49:28 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Please see below. Obviously the fact that the previous email doesn't count if not sent to this email address says all we need to know about the intent of this regulatory body and process. Mark B. Begin forwarded message: From: Mark Bourne <mgble@yahoo.com> Date: January 11, 2021 at 10:27:30 PM EST To: anna.gurney@ncdenr.gov Subject: Blue Ridge Paper Products Dear Ms. Gurney I am writing in objection to the variance on NPDES RENEWAL NC0000272. No-- to the variance on Blue Ridge Paper Products. Until this company can prove that dioxin does not contribute to the rise in cancer seen in the affected region, we should not be permitting this potential risk for purposes of private parties profit. Mark Bourne 1631 Sequoyah Dr Mooresburg, TN From: To: Subject: Date: Steve Cox SVC DENR.Dubliccomments [External] Fwd: NPDES RENEWAL NC0000272 Saturday, January 16, 2021 12:52:28 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. RE: NPDES RENEWAL NC0000272 Please, No. No to the variance on Blue Ridge Paper Products. Our river is dirty and toxic enough as it is. Thank you. From: Bill Gorman To: SVC DENR.publiccomments Subject: [External] Blue Ridge paper mill 0000272 Date: Sunday, January 17, 2021 3:41:34 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> We lived in the river and received part of the original settle years ago. We sold and moved to Cosby. The river has finally come back to life. It needs to stay that way and continue to improve and stay beautiful and healthy. This new variance let's the fix guard the hen house again. We all witnessed how that turned out. The Smoky Mountains have unprecedented beauty that those who live here, work here, respect and enjoy. This variance change is dangerous to the river and those people who use it, live by it as well as the fish and animals who have come back from when the river was poisoned by pollution from the paper mill. If anything the rules need to get tighter not looser. Bill and Donna Gorman Sent from my iPhone From: Gave Norton To: SVC DENR.publiccomments Subject: [External] Blue Ridge Paper Products Date: Sunday, January 17, 2021 10:45:28 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Vote No to lifting of the color variance Protect our water!! Sent from my iPhone From: To: Subject: Date: Sherry Duncan SVC DENR.oubliccomments [External] Blue Ridge Paper Products Monday, January 18, 2021 11:37:36 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. This is to request that you do everything possible to help IMPROVE our Pigeon River water quality and do NOT allow environment standards to be relaxed or reduced. If anything, more could be done to help further improve the quality of water in this river, those protections should be added as well, rather than reducing any current requirements. This not only affects the residence living along the river, but also affects the property values, businesses, growth of downstream communities and health of everyone downstream from this plant. One business should not be allowed to prosper and spend less on environmental protections at the expense of the thousands of people and businesses it affects in Tennessee. Anything less than requiring the maximum protections available will be considered a lack of responsibility from elected and environmental officials. I hope our officials see the need for this protection and will do all possible to protect our beautiful river. Please do not allow this one paper mill in NC to have any leniency in regard to this matter. Thank you. Sherry Duncan Sherry Duncan Mortgage Loan Officer Citizen National Bank 200 Forks of the River Pkwy Sevierville, TN 37862 DIRECT: (865) 414-0322 FAX: 865-674-5106 Email: sherryduncan@cnbtn.com Website for applications online: www.applywithsherryduncan.com NMLS# 185967 The contents of this e-mail message and any attachments are confidential and are intended solely for addressee. The information may also be legally privileged. From: To: Subject: Date: charles cheney SVC DENR.publiccomments [External] Blue Ridge Paper Products, NC #0000272 Tuesday, January 19, 2021 1:00:08 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. I moved from Maryland to get away from polluted rivers and streams. I fished the Susquehanna River above the Conowingo Dam with my father through the 1960's and 1970's. The fishing was fabulous for crappie, bass, bluegill and channel catfish. By the time the year 2000 rolled around, other than catfish, the river became "dead" because of all of the pollutants dumped into the river from Harrisburg, PA and points North. I moved to Tennessee to enjoy fishing with my sons in my golden years on the French Broad River. Last year fishing on this river was awful, not just for me, but most fisherman I spoke to gave me the same reports. Is this pollution problem following me again? The Pigeon Forge River empties into the French Broad River. I understand that Blue Ridge Paper Products has the capability to clean up the water they discharge into the Pigeon Forge River, but profits appear to be more important than having clean rivers. The Clean Water Act was supposed to clean up pollution in our waterways. Finally, the chemicals that are being dumped into the Pigeon Forge River, which feeds into the French Broad River and Douglas Lake, are being ingested by thousands of people who get their drinking water from these bodies of water. Since my drinking water comes from the French Broad River/Douglas Lake, I am ingesting these chemicals on a daily basis. This looks like corporate greed being placed over the concerns and health of American citizens. From: To: Subject: Date: Kasha Schoolmeester Williamson SVC DENR.oubliccomments [External] It"s time to Limit evergreen packaging and other pollutants into the Pigeon River Tuesday, January 19, 2021 9:56:19 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. As a homeowner and a tourism business owner in Haywood County North Carolina, we implore you to not pass the current permit request of Evergreen / Blue Ridge packaging paper mill into the pit Pigeon River. As Haywood County residents we have seen a strong uptake increase of Tourism dollars versus the tax dollars that flow in from Industries such as the paper mills and packaging plants. Tourism supports small restaurants shopping, recreational outlets. small businesses , small B&B owners like myself and can increase home ownership and longer -term revenues versus and Industrial manufacturing plant which will probably not be a long-term viable Business Solution for the great state of North Carolina. Why destroy the natural resources of Western North Carolina and Eastern Tennessee for manufacturing tax dollars. Our neighborhood is on a tributary of the Pigeon River and we see it getting dirtier and dirtier each passing year. thank you for your consideration kasha and Kelly Williamson. 571-295-8800 From: johi72097@everyactioncustom.com on behalf of Heidi Sherman To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Monday, January 18, 2021 9:16:26 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act almost 50 years after its passage to make our River be fishable and swimmable. Sincerely, Heidi Sherman 335 Ridge View Dr Asheville, NC 28803-9401 johi72097@aol.com From: olparko©aol.com To: SVC DENR.Dubliccomments Subject: [External] Public Comments NC0000272 Blue Ridge Paper/Evergreen Packaging Date: Wednesday, January 20, 2021 4:45:46 PM Attachments: Abstract Dioxin (1).pdf Blue Ridge Paper Products changes name, moves headquarters (2).pdf CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Jan. 20, 2021 To Whom it May Concern: When we began work on the Pigeon River it was in 1997. All the wells on Douglas Lake were closed due to the high rate of cancer; that's the fact. In the Abstract from, Chemosphere, that was dated, Dec. 2019, that I mailed previously to your, Anna Gurney, it says, "Unchlorinated precursor elimination reduced but did not stop formation of 2,3,7,8- TCDD/F from elemental chlorine bleaching." That is a problem for TN. The Abstract is attached above. Further, in the 2007 Shareholder Report entitled: Blue Ridge Paper Products Shareholder Annual Report 2007, it says: "International Paper has also agreed to indemnify us for liabilities, including any remediation or additional capital expenditures required by the North Carolina Department of Health, Environment and Natural Resources, associated specifically with the seepage of dark colored materials from the Canton Mill into the northern banks of the Pigeon River that occurred prior to May 14, 1999." Yet, it is unclear to me and to my broker--- who now owns the liability for the Canton Mill? I require the name of the owner. Is it Rank Group? Reynolds Group? Who is the owner? On the NC Secretary of State page, only a manager is listed. A, Mr. Mark Lightfoot. And why is his email, redacted? Is he a state secret? Who is the owner of the Canton Paper Mill as of today? I am a shareholder and am having trouble getting that simple question answered. Why is it so difficult to find out who owns the controlling interest in this flailing company? Reynolds Group Holdings Limited's, "Strategic Communications and Advisory," ICRINC, is stalling me. As this paper mill just lost 7 million, per the attached article, is this an effort to save jobs? If it is, these jobs have been on the backs of the TN hill people for 113 years. And that's enough. Your cutting edge technology is now over 20 years old. And stalling a shareholder who simply asks for the owner, the majority interest- in a company - is unheard of in my financial life. Who fixed the, "dark colored seepage?" When? What engineer was hired? Where is that paperwork? As a resident of TN, I require that paperwork. I am glad the dioxin numbers have gone down -per those that make such regulations. But, I want to know who fixed the seepage and when? Who is measuring the cumulative effect of this dioxin and where is NCDENR's reports on that? Who holds the controlling interest in this company? And who owns the liability? Further: "(January 19, 2001) -- The National Toxicology Program announced today the publication of an addendum to its Ninth Report on Carcinogens that adds 2,3,7,8-tetrachlorodibenzo-p-dioxin, also known as TCDD or Dioxin, to the list of substances "known to be human carcinogens." Notice the date. I want all this information herein added to the public record along with my other Public Comments and Scientific Journal attachments sent to the NC Public Comment address on Jan. 13, 2021. I look forward to a timely response to my questions. Ms. Park Overall 1374 Ripley Island Rd. Afton, TN 37616 1/7/2021 The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/F... Download Chemosphere Volume 236, December 2019, 124386 Review The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/Fs Peter Axegard Show more u Outline ( 4 Share » Cite https://doi.org/10.1016/j.chemosphere.2019.124386 Get rights and content Under a Creative Commons license open access Highlights • 2,3,7,8-TCDD and 2,3,7,8 TCDF are the dominant congeners formed when kraft pulp is bleached with elemental chlorine. • This PCDD/F fingerprint for elemental chlorine bleached kraft pulp was unique compared to all other documented sources. • The level ofunchlorinated precursors in other process chemicals affected the amount of2,3,7,8-TCDD/F formed. • Unchlorinated precursor elimination reduced but did not stop formation of2,3,7,8- TCDD/F from elemental chlorine bleaching. https://www.sciencedirect.com/science/article/pii/S0045653519316078 1/26 1/7/2021 The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/F... Download • PCDD/Fs are found in background levels in food, soil, air, unbleached pulp, bleached pulp, paper and fiber products. • PCDD/Fs from bleaching are determined by a congener analysis and comparison to known sources, blanks and unbleached samples. Ab stract The article reviews the transition from bleaching kraft pulp with elemental chlorine to bleaching with chlorine dioxide with respect to formation of chlorinated dioxins and furans (PCDD/Fs). New data is also presented for bleaching with 100% chlorine dioxide and the effect of elemental chlorine impurities. The typical fingerprint of PCDD/Fs in pulp bleached with elemental chlorine was unique compared to all other sources such as incineration and metallurgic processes. 2,3,7,8- TCDD and 2,3,7,8-TCDF were the dominating congeners formed during the period pulp was bleached with elemental chlorine. Elimination ofunchlorinated precursors lowered, but did not eliminate, the formation of2,3,7,8-TCDD and 2,3,7,8-TCDF. The formation of2,3,7,8-TCDD and 2,3,7,8-TCDF increases exponentially with the amount of elemental chlorine used. Replacing elemental chlorine with chlorine dioxide (with levels of elemental chlorine contamination of <0.3% in the chlorine dioxide) in pulp bleaching eliminates the formation of 2,3,7,8-TCDD and 2,3,7,8-TCDF. PCDD/Fs can also be found in background levels in ecosystems, food, soil and air as well as in unbleached pulp, bleached pulp, and paper and fiber products. Thus, the only way to determine if PCDD/Fs are present from bleaching is to make a full congener analysis and compare to known sources and processes as well as to laboratory blanks and unbleached reference samples. Previous Next Keywords Chlorine dioxide; Elemental chlorine; Bleaching; Kraft pulp; PCDD/Fs; 2,3,7,8-TCDD and 2,3,7,8-TCDF 1. Introduction https://www.sciencedirect.com/science/article/pii/S0045653519316078 2/26 1/7/2021 The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/F... Download J16 l.Qlll1' 1l.0 Ul.I.0 1.1111JJ1V11J V V llll. IJ0.Jl 1.. VV UI.I.QUI. J U11Ul. 1 J LQ11Li.L.L VV llll.11 L. V11J 111 Ul.11 lJ 111Q� still contribute to environmental impact is of ongoing interest (Lindholm-Lehto et al., 2015, Singh and Srivastava, 2019). Historically, one of the key variables has been the choice of bleaching chemicals since this can lead to a wide range of by-products. This is particularly true of the use of chlorine, or chlorine containing chemicals (Solomon, 1996). Since the late 1980's, the use of elemental chlorine in bleaching kraft pulp has mainly been replaced with chlorine dioxide and oxygen. Bleaching without elemental chlorine is commonly called Elemental Chlorine Free (ECF) bleaching. The conversion from bleaching with elemental chlorine to ECF-bleaching has resulted in the elimination of the formation of2,3,7,8-chlorinated dibenzofurans and dibenzo-p-dioxins (2,3,7,8-TCDF and 2,3,7,8-TCDD) in the bleaching process. These substances belong to a group of chemical compounds called polychlorinated dibenzo-p- dioxins and dibenzofurans (PCDD/Fs), commonly called dioxins. There are many sources of PCDD/Fs: direct sources such as chemical production processes and thermal and combustion processes, as well as indirect sources such as soils, sediments, old dumpsites of contaminated waste and atmospheric precipitation from combustion sources (UNEP, 2013; Ballschmiter and Bacher, 1996; Weber et al., 2018). As a result, PCDD/Fs can be found everywhere in very low concentrations, in spite of the fact that the generation of these substances has been reduced dramatically or even eliminated over the past decades. In the U.S., the EPA reports a reduction of dioxin emissions from all sources by approximately 90% between 1987 and 2000 (U.S. EPA, 2006). Reported releases from pulp bleaching were lowered by 99.7% during the same time period. In order to understand where specific types of PCDD/Fs come from, it is critical to examine the fingerprint of the PCDD/Fs formed by different types of processes (Rappe, 1994; Hagenmaier et al., 1994). This paper reviews the scientific literature and presents previously unpublished data on the transition of the pulp industry from elemental chlorine bleaching to ECF-bleaching and how it resulted in the elimination of PCDD/Fs. This paper also provides perspective on why the remaining amount is indistinguishable from environmental background. Since the fingerprint of the PCDD/F formation during elemental chlorine bleaching of pulp is unlike any other industrial or thermal process it provides a definitive tool for documenting elimination. 2. Pulp production and the use ofbleaching chemicals The technology for the production of bleached pulp for printing paper, hygiene products, packaging and other applications has developed gradually since chemical pulp was introduced in the 1880s (for a comprehensive review of the evolution of the global pulp and paper industry see Lamberg et al., 2012). Chemical pulps are produced by using either the kraft or sulfite pulping process. Kraft pulping is by far the most common process, with sulfite pulp production, at https://www.sciencedirect.com/science/article/pii/S0045653519316078 3/26 1/7/2021 The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/F... Download Lill. 1L.111V Val Vl 116 Qlll.l VV VVU 1QVV 111Q 11.11Q1, VV QJ al that time carried out in a sequence of stages with sodium hydroxide and elemental chlorine in the form of chlorine gas and hypochlorous acid. Kraft pulp began to be manufactured in the 1920s, but its use was mainly limited to packaging grades due to the brown color and high fiber strength as compared to sulfite pulps. Bleaching kraft pulp with elemental chlorine was not commercially possible then due to a severe loss of fiber strength from cellulose degradation. This changed completely with a new technique using elemental chlorine bleaching as the main bleaching chemical in combination with smaller amounts chlorine dioxide in the final bleaching stages, which was developed in Sweden and Canada in the 1940s. This new technique preserved fiber strength at the high brightness levels needed for bleached paper board, hygiene products, such as tissue and diapers, as well as for printing and writing paper. This new approach was rapidly applied by the pulp industry globally and for decades this was the state of art bleaching technique. From the late 1980s and onward, elemental chlorine has been gradually replaced with chlorine dioxide and oxygen. The use of oxygen delignification reduces the amount oflignin in the pulp by up to about 50%, which lowers the need for bleaching chemicals. Since the 1990s, Elemental Chlorine Free (ECF) bleaching, with or without oxygen delignification prior to bleaching, has become the main bleaching method globally. Of the total amount ofbleached pulp produced in 2006, 88% was ECF-bleached, 5% Totally Chlorine Free bleached (TCF) and 6% bleached with elemental chlorine (Pryke, 2007). Essentially all newly built pulp mills use ECF bleaching, many of which are located in South America. A small number of pulp mills with ECF- and TCF-bleaching use ozone and peracetic acid. 3. Polychlorinated dibenzo-p-dioxins and dibenzofurans (PCDD/Fs) Dioxins, are chlorinated derivatives of the two tricyclic compounds, dibenzo-p-dioxin (DBD) and dibenzofuran (DBF). Substituting hydrogen atoms with chlorine atoms in DBD gives rise to 75 possible polychlorinated dibenzo-p-dioxins (PCDDs). Similarly, a total of 135 polychlorinated dibenzofurans (PCDFs) can be formed from DBF (Rappe, 1994). All of the PCDDs and the PCDFs are congeners, each of these is a distinct chemical entity with unique physical, chemical and biological properties. Congeners with same number of chlorine atoms are grouped together into homologue groups from mono -to octa-chlorinated congeners. Common references to the full chemical names have resulted in truncated versions of the names which are often used for publication purposes. For example, 2,3,7,8-TCDD and its dibenzofuran analogue 2,3,7,8-TCDF are commonly referred to as 2,3,7,8-TCDD/F when grouped together. In this paper, polychlorinated dibenzo-p-dioxins and dibenzofurans will be hereinafter referred to as PCDD/Fs. PCDD/Fs are potent pollutants due their high lipophilicity, low biodegradability and the ability to interact with metabolic processes in humans and other life forms causing toxic and sublethal effects (Bandeira, 1984 and NIOSH Bulletin 40, 1984). The toxicity varies significantly depending https://www.sciencedirect.com/science/article/pii/S0045653519316078 4/26 1/7/2021 The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/F... Download Ql JLUl11l.13 1l4..6Q1.1 V 1. 1.111.1.1J 11QV1. Vl.l.11 IUl, l.0 WA- 1U111V1 UI. V l.1VJJllll.11l, 1. 1Ulll. llV11, reproductive development, dermatologic disorders and a host of other adverse effects (National Research Council, 2006 and references therein). All 17 individual congeners with 2,3,7,8 chlorine substitutions are believed to exert toxicity through a common mechanism, with potencies that vary by several orders of magnitude (van den Berg et al., 2006). In the 1970s, the formation of PCDD/Fs was identified as a general problem related to the industrial use of elemental chlorine (overview given by Weber et al., 2008). Metallurgical processing and incineration were shown to be significant sources of PCDD/Fs The most toxic dioxin, 2,3,7,8-TCDD, was identified as a contaminant in chlorinated phenoxy acid herbicides used for defoliation and control of hardwood trees. A well-known example of dioxin - contamination resulting from the use of chlorinated phenoxy acids as the active substance, was the use of the chemical product Agent Orange, for defoliation during the Vietnam war (Martin, 2018). Chlorinated phenoxy acids have also been used in agriculture and forestry for tree control and were likely sources of increased levels of 2,3,7,8-TCDD in local environments. While the first reported synthesis of a chlorinated dioxin dates back to 1872 (reviewed in Holmstedt, 1980), it wasn't until 1957 that Kimmig and Schulze first published studies linking TCDD contamination of technical 2,4,5-trichlorophenol with human chloracne (Kimmig and Schulz, 1957). In 1957, in the U.S. reports of so-called chick edema disease of unknown etiology were being reported that would later be traced to contamination of the feed with chlorinated dioxins that originated from industrial preservation of cow hides with further use of the fat in the hides (Firestone, 1973; Hayward et al., 1999). By the late 1970s various environmental contamination events had occurred that lead to widespread interest in understanding the potential for health effects of chlorinated dioxins (Hites, 2011). In his "Prolegomena to Seveso", Holmstedt (1980) discusses the history of the understanding of dioxin formation that evolved out of the catastrophic incidences within the chlorophenol manufacturing industry dating back to Nitro West Virginia in 1949. 4. Pulp bleaching with elemental chlorine and the formation of PCDD/Fs In 1987, for the first time, it was reported in the scientific literature that 2,3,7,8-TCDD and 2,3,7,8-TCDF had been found in sediments and crabs collected outside a Swedish kraft pulp mill using elemental chlorine bleaching. The crabs were reported to contain 170 pg/g of 2,3,7,8 TCDD and 590 pg/g of2,3,7,8-TCDF. Samples from the sedimentation lagoon at the mill were also analyzed and the concentrations of2,3,7,8-TCDD and 2,3,7,8-TCDF were found to be 120 and 890 pg/g respectively (Rappe et al 1987). This indicated that the bleaching of kraft pulp could be a source ofPCDD/Fs. At the same time similar results were published by the U.S. Environmental Protection Agency (U.S. National Dioxin U.S. EPA National Dioxin Study, 1987) and a few years https://www.sciencedirect.com/science/article/pii/S0045653519316078 5/26 1/7/2021 The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/F... Download The reactions between lignin and elemental chlorine has been extensively studied (Gierer, 1986; Dence et al., 1962; Ni et al., 1995). Elemental chlorine is a very reactive bleaching chemical with high oxidation power and reacts with the aromatic (phenolic) lignin structures in the wood fiber. The main reaction is an aromatic substitution of hydrogen atoms with chlorine atoms on the aromatic rings and results in chlorinated organic material. The chlorination of aromatic rings follows the principles of electrophilic aromatic substitution and proceeds in a step -wise manner. The first chlorine atom is introduced quite easily. The introduction of the second and subsequent chlorine atoms is more difficult since with each substitution the aromatic ring is deactivated by one order of magnitude (Ni et al., 1995). Several scientific articles have shown that bleaching pulp with elemental chlorine causes the formation of2,3,7,8-TCDD and a 4-10 times higher concentration of2,3,7,8-TCDF (Voss et al., 1988, Swanson et al 1988, Kringstad et al., 1989, Axegard, 1989, Axegard and Renberg, 1989, Berry et al., 1989, Rappe et al., 1989, Rappe et at 1990). Some of these articles also showed that 1,2,7,8- TCDF was produced in a 1:1 ratio to that of2,3,7,8-TCDF. One significant source for 2,3,7,8 - TCDF and 1,2,7,8-TCDF is the chlor-alkali process used to make chlorine gas by electrolysis of sodium chloride in water, particularly if graphite electrodes are used (Rappe et al., 1990; Yamamoto et at, 2018). Significant amounts of DBF in the graphite electrodes leads to the characteristic 2,3,7,8-TCDF/1,2,7,8 TCDF pattern. This same pattern occurs in pulp bleaching with elemental chlorine if significant amounts of unchlorinated DBF are present (see discussion below). However, because pulp also contains other phenolic precursors both PCDD and PCDF can be formed. It is important to note that 1,2,7,8-TCDF is not routinely analyzed because it is not one of the 2,3,7,8-substituted PCCD/Fs and is therefore not considered to be of toxicological concern (van den Berg et al., 2006). Reported levels of the concentration in elemental chlorine bleached pulps were 11 pg/g for 2,3,7,8-TCDD and 50pg/g for 2,3,7,8-TCDF (Swanson et al 1988) or higher. Similar results were reported by Axegard (1989) for laboratory and industrially bleached pulps. The U.S. EPA "104- mill" study from 1990 reported median vales in industrial pulps of 6.6 and 18 pg/g for 2,3,7,8- TCDD and 2,3,7,8-TCDF respectively, with a corresponding range of 0.4-124 and 1.4-716 respectively. The content of2,3,7,8-TCDD and 2,3,7,8-TCDF in bleached pulp reflects about one third of the total formation while about one third is found in the effluent discharge and one third in the mill wastewater sludge (U.S. EPA, 1990). In the same study, the maximum and mean values were reported for thel7 toxic PCDD/Fs. These data are plotted in Fig. 1, Fig. 2 and show that the three congeners 2,3,7,8-TCDD, 2,3,7,8-TCDF and OCDD (Octa-CDD) dominate. It is also obvious that the maximum values are about two orders of magnitude higher compared to the mean values, indicating a huge variation in use of elemental chlorine. OCDD will not be discussed more here as it is only formed in bleaching at high levels elemental chlorine, mainly in reactions https://www.sciencedirect.com/science/article/pii/S0045653519316078 6/26 1/7/2021 The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/F... Download l.Vll VJ1V11 Q11U Q 1JVVl VV V1111116 ,.. 11V11V11111L111. 11161.1. V ..1J W. VULL 11QV1. Vlll.11 Vl.l.11 llll. 11.J U11 Vl the use ofpentachlorophenol in wood treatment and from the use of slimicides in the production of pulp and paper (Borysiewicz and Kolsut, 2004). 12 10 8 6 4 1988 Mean values in pulp, pg/g 2 - 0 .-4 '1) A A % A. 1, 1, '5)1" 0 cg4 '"C 1 e ,,,b0, ,,,.. .,,,,,., ,„... ,,,, ,,,, _,, ., , 4,3 ,c,,,3 ..,;„, r,..,„0„ 4,,t, Nolr Q g q .09 4z, ..6F ' C 9 Vc. < e 401 ''' t 4 ( c 1 4 4 ; 5 t 4 c V4 ' 4 c 1 ( 61( c ps t Download : Download high-res image (242KB) Download : Download full-size image Fig. 1. Mean values ofthe 17 toxic PCDD/Fs in mill pulps (Source: U.S. EPA, 2006). Boa - 1988 Max values in pulp, pg/g 700 — 600 500 400 300 200 100 ..f. — <3. e 6i, _660c t (pig 0 — , - 1 ,,c) ,$) <314 oc, 4, https://www.sciencedirect.com/science/article/pii/S0045653519316078 7/26 1/7/2021 The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/F... Download Fig. 2. Maximum values of the 17 toxic PCDD/Fs in mil pulpsSource: U.S. EPA 1990. It was also reported that the formation of2,3,7,8-TCDD and 2,3,7,8-TCDF occurs in proportion to the ratio of the amount of elemental chlorine versus the amount oflignin in the pulp (Axegard 1988a and b). The amount oflignin is quantified using a unit called the kappa number. The higher the kappa number the greater the amount oflignin in the pulp. The ratio between the amount of elemental chlorine applied and the kappa number is defined here as the chlorine multiple. It has also been shown in several studies that the congener pattern for PCDD/Fs resulting from bleaching with elemental chlorine is very typical, with a formation of2,3,7,8-TCDD and 2,3,7,8- TCDF as the dominant congeners formed (Cleverly et 1997; Kringstad et al 1999; Rappe, 1994, U.S. EPA, 1990). The ratio between 2,3,7,8-TCDF and 2,3,7,8-TCDD is fairly consistent and in most cases has been shown to be between 4 and 10. Where the non -toxic 1,2,7,8-TCDF is reported, the amount has been shown to be 1:1 to the amount of2,3,7,8-TCDF. The PCDD/F congener pattern from elemental chlorine bleaching is dominated by 2,3,7,8-TCDD and a 4-10 times higher concentration of 2,3,7,8-TCDF and is significantly different compared to other sources (Dopico and Gomez, 2015; Buekens et al., 2000; Cleverly et al., 1997; Rappe et al., 1990; Rappe, 1994). Waste incineration and metallurgical processes are the main producers of PCDD/Fs in industrial environments. Other processes that result in PCDD/Fs are cement kilns, coal power plants, and crematory incinerators. In contemporary mandated emissions reporting, each of these processes has its own particular emission factors (UNEP Toolkit, 2013). The PCDD/F fingerprints of thermal processing have a broad congener spectrum with some variation in the pattern depending on combustion conditions and the cooling section. Thus, the congener profiles ofPCDD/Fs vary significantly depending on the source. In contrast, elemental chlorine in bleaching of pulp produces 2,3,7,8-TCDD and 2,3,7,8-TCDF as the main congeners with 2,3,7,8- TCDF at 4-10 higher concentration than 2,3,7,8-TCDD. It is relevant to compare the PCDD/F-profile in pulp products that have not been bleached with chlorine and chlorine dioxide (Berry et al., 1993). Table 1 shows the results from the analysis of20 commercial pulp samples. 85% and 95% of the samples contained detectable amounts of 2,3,7,8- TCDF and OCDD, respectively. While 1,2,3,4,6,7,8-HpCDD, OCDF and 1,2,3,4,6,7,8-HpCDF were found in 50%, 30% and 25% the samples, respectively. This PCDD/F congener pattern does not reflect the typical elemental chlorine bleaching pattern and must therefore originate from other sources. It also provides evidence that even if either of the signature molecules of chlorine https://www.sciencedirect.com/science/article/pii/S0045653519316078 8/26 1/7/2021 The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/F... Download Table 1. Concentrations in pg/g of PCDD/Fs in unbleached and TCF bleached pulp samples. Source: Berry et al., (1993). Unbleached Ground- TMP CTMP TCF % detects Average kraft wood kraft all samples 2 samples 5 samples 7 samples 5 samples 1 sample 2,3,7,8-TCDD 0.2 0.1 10% 0.2 1,2,3,7,8-PeCDD 0% 1,2,3,4,7,8-HxCDD 0.1 5% 0.1 1,2,3,6,7,8-HxCDD 1.4 0.2 10% 0.8 1,2,3,7,8,9-HxCDD 0.4 0.1 15% 0.3 1,2,3,4,6,7,8-HpCDD 0.8 0.4 0.6 0.6 1.1 50% 0.7 OCDD 3.0 21.7 15.6 26.4 17.0 95% 18.2 2,3,7,8-TCDF 0.2 0.4 0.3 0.4 1.8 85% 0.4 1,2,3,7,8-PeCDF 0.3 5% 0.3 2,3,4,7,8-PeCDF 1,2,3,4,7,8-HxCDF 1,2,3,6,7,8-HxCDF 2,3,4,6,7,8-HxCDF 1,2,3,7,8,9-HxCDF 1,2,3,4,6,7,8-HpCDF 0.5 20% 0.5 1,2,3,4,7,8,9-HpCDF OCDF 3.5 1.1 30% 3.2 5. Unchlorinated precursors and their role in the presence of PCDD/Fs in elemental chlorine bleached pulp https://www.sciencedi rect. com/science/article/pii/S0045653519316078 9/26 1/7/2021 The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/F... Download LLL/L1/1VV llll111lA1 llll.l 1111.11.QJl.11 llll. 1V1111Q11V11 V1 L�,J,/,V- 1 ULL/1' VV lll.11 1.11.1111.111Q11111Vlllll. VV QJ used in bleaching (Voss et al., 1988; Allen et al., 1989). Luthe and Berry 1996 demonstrated that the reduction in formation of2,3,7,8-TCDD/F was a function ofboth the level of chlorine dioxide substitution for elemental chlorine and the concentration of DBD/DBF in the pulp before bleaching. At 100% chlorine dioxide substitution, 2,3,7,8-TCDD was non -detectable at the 0.1 pg/g level and the amount of 2,3,7,8-TCDF was 0.2-0.7 pg/g, which was at the same level as that found in unbleached pulp. However, avoiding DBD/DBF-containing mineral oil -based defoamers reduced, but did not eliminate the formation of PCCD/Fs during bleaching with elemental chlorine. It has been found that there are DBD/DBF precursors in the lignin in compression wood located in branches and wood around branches in softwood trees (Hruitfjord and Negri, 1992). This may be the reason why bleaching softwood pulps with elemental chlorine results in a higher formation of PCDD/Fs than for hardwood pulps which do not contain compression wood. Black liquor evaporation condensate and incoming process water may also contain unchlorinated precursors for both PCDDs and PCDFs in pulp bleaching with elemental chlorine (Rappe et al., 1989). It has also been proposed that dioxin impurities originating from agrochemical herbicides, are transferred from industrial raw water to the pulp mill and consequently enter the black liquor, and that the dioxins are then transferred and concentrated into the black liquor condensate by vapor distillation (Nakamata and Ohi, 1993). The introduction of oxygen delignification before the bleaching plant has been shown to have a minor effect on the formation of2,3,7,8-TCDD/F despite a significant removal of lignin (Kringstad et al 1989, Berry et al., 1991). The main benefit of oxygen delignification with regard to PCDD/F is that unchlorinated precursors are partially removed by improved washing and steam distillation (Berry et at, 1989). Historically, starting in the 1880s another significant cause of the formation of PCDD/Fs was the use of graphite electrodes when producing elemental chlorine. In the production process, the graphite electrode was consumed and a by-product, graphite electrode sludge, was produced. The graphite sludge was shown to contain extremely high levels of2,3,7,8-TCDF and levels as high as 52,000 pg/g have been reported (Rappe et al., 1990). A range of highly chlorinated furans, from PCDFs up to OCDFs were also found. The elemental chlorine product shipped to industrial users contained some of these contaminants. In pulp mills, these contaminants resulted in deposits called chlorine butter which caused chloracne in personnel exposed to it. It should also be kept in mind that many pulp mills produced elemental chlorine at the mill site using graphite electrodes. The use of graphite electrode was replaced with titanium electrodes during the 1990s. 6. Pulp bleaching with chlorine dioxide and the lack of formation of PCDD/Fs https://www.sciencedirect.com/science/article/pii/S0045653519316078 10/26 1/7/2021 The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/F... Download LL LLL. LLLI L.J 1L.J U. 6 111 Q 1...1.L.6IQLLL.0 116 V 1 L11 A. 1Q16l. 11L1111V1.1 V1 I.QL VV.A./ . QL.1LA �'1V L1.1, J. .JVllll. low -chlorinated substances are formed, but no highly chlorinated substances have been found (Dence et al., 1962; Gierer, 1986; Brage et al., 1991; Ni et al., 1994). Bleaching with 100% chlorine dioxide has been shown in several articles not to form any 2,3,7,8-TCDD and 2,3,7,8-TCDF (Luthe and Berry, 1996, Kringstad et al., 1989; Axegard, 1989, Axegard and Renberg, 1989, Berry et al. 1989, Axegard and Bergnor, 2011). The effect of substituting elemental chlorine with chlorine dioxide is not linear. The formation of2,3,7,8-TCDD/Fs follows an exponential curve, when the level of elemental chlorine is reduced, the formation of2,3,7,8-TCDD and 2,3,7,8-TCDF decreases to a level where no formation can be detected (Axegard 1988a, b; 1989, Axegard and Renberg, 1989, Berry et al., 1989). This is illustrated in Fig. 3, where non -detectable levels are reported they are defined as the level of detection which at the time in the best laboratories was about 0.5-1 and 0.1-0.5 pg/g for 2,3,7,8-TCDF and 2,3,7,8-TCDD respectively in pulp. These non -detectable levels occur even before all elemental chlorine has been replaced with chlorine dioxide at an elemental chlorine multiple of about 0.1, which corresponds to about 50% chlorine dioxide substitution. It should be noted that industrial and laboratory data provide similar results. It should also be observed that the use of oxygen delignification before bleaching reduces the lignin content of the pulp, but at a given chlorine multiple the effect of oxygen delignification on the levels of 2,3,7,8- TCDD and 2,3,7,8-TCDF is limited, see also discussion above. https://www.sciencedirect.com/science/article/pii/S0045653519316078 11/26 1/7/2021 The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/F... Download 80 70 60 50 40 30 20 10 l� a 0,00 ■ A. iaL No 02 delignification With 02 delignifEcation D A II ---A--ANNA 0 •O 0.05 0_10 0,15 0.20 0.25 0.30 CI,- multiple 14 12 1'0 3 6 lab mill 0 No 02 delignification A With 02 delignification ■ I a 4 • 2 oD a &AL 0 0.00 0,05 0.10 0,15 0.20 0.25 0.30 Cl2- mullIplo Download : Download high-res image (315KB) Download : Download full-size image Fig. 3. Amount in pg/g of2,3,7,8-TCDF (upper) and 2,3,7,8-TCDD (lower) in bleached softwood kraft pulps versus the C12-multiple (amount of elemental chlorine relative to the amount oflignin before bleaching). Zero Cl2-multiple corresponds to 100% substitution (ECF) and a 0.10 Cl2- multiple is approximately a 50% substitution. Typical Cl2 -multiples used in pulp mills during the 1980s ranged from 0.2 to 0.3. Source: Axegard (1988b). In one study an industrial softwood kraft pulp was oxygen delignified and then further bleached in the laboratory with chlorine dioxide containing different amounts of elemental chlorine: 0.3% elemental chlorine (D100), 5% (D95) and 8.5% (D91.5). respectively. All 17 of the 2.3.7.8-PCDD/Fs congeners were analyzed and reported as higher and lower bound concentrations respectively (Axegard and Bergnor, 2011). It should be noted that the pulp, for research purposes, was spiked with 100 ppm dibenzofuran (DBF) which is a significantly higher level than the background levels found in pulp from modern bleacheries. Thus, the PCDF levels found in the study are significantly higher than what would be found in modern bleached pulp. https://www.sciencedirect.com/science/article/pii/S0045653519316078 12/26 1/7/2021 The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/F... Download Lam, J,/,V-1 ULL Q11LA Lam J/,V-1 UL1' L. IAlLA L/l. V VJI.l V L.LA QJ L.L.L 1. L.13 L11L Vl L.—LULL/ 11111. LA1lJ.A Lt1 . V1l.QL. ,, QJ all values were at or below the levels in the blank or incoming oxygen delignified pulp. It should be noted that the levels of detection are below 0.02 pg/g for 2,3,7,8-TCDD and 2,3,7,8-TCDF. This is a clear indication that 100% chlorine dioxide bleaching does not produce 2,3,7,8-TCDD and 2,3,7,8-TCDF. The table also shows that the level of2,3,4,6,7,8-HxCDF is slightly increased after chlorine dioxide pulp bleaching. However, the concentration measured was 3 times higher than the detection level and the same as in the blank in Table 2, thus the result is statistically uncertain. Also, this congener has never been associated in scientific literature with elemental chlorine bleaching or ECF-bleaching. Therefore, the congeners detected that are not related to bleaching can be assumed to be part of the background of environmental PCDD/Fs contaminants and have been shown in previous studies to be sporadically present at these very low levels in many types of samples. Table 2. The content of 17 PCDD/Fs in an industrial oxygen delignified softwood kraft pulp before and after chlorine dioxide bleaching in laboratory scale. The chlorine dioxide had a content of 0.3% (D100) elemental chlorine, expressed as percentage of total oxidation power. The pulp had kappa number 11 after oxygen delignification and was spiked with 100 ppm DBF. Level of Detection (LOD) were reported as values 3 times above the blank level. Values that are shown in italics in parenthesis are between 3 and 10 times the LOD and have extended measurement uncertainty, according to the laboratory that did the tests. Quantifiable values are those that are 10 times the LOD. Source: Previously unpublished analytical data related to Axegard and Bergnor (2011). PCCD/F analyses were carried out by University ofUmea, Sweden. 2378-TCDD 12378-PeCDD 123478-HxCDD 123678-HxCDD 123789-HxCDD 1234678HpCDD OCDD 2378-TCDF Mill 02-delignified pg/g nd nd nd nd nd 0.006 0.108 0.002 D100 LOD pg/g LOD 0.008 nd 0.019 0.005 nd 0.003 0.005 nd 0.026 0.005 nd 0.025 0.002 nd 0.028 nd 0.024 0.14 0.048 (0.034) 0.013 https://www.sciencedirect.com/science/article/pii/S0045653519316078 13/26 1/7/2021 The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/F... Download 12378-PeCDF nd 0.016 nd 0.020 23478-PeCDF nd 0.002 nd 0.022 123478-HxCDF 0.142 nd 0.019 123678-HxCDF nd 0.003 nd 0.016 123789-HxCDF nd 0.005 nd 0.018 234678-HxCDF nd 0.005 (0.055) 0.024 1234678-HpCDF 0.384 0.061 0.024 1234789-HpCDF 0.121 nd 0.018 OCDF 0.193 0.16 0.048 Today, the vast majority of wood -based kraft pulp mills producing bleached pulp use 100% chlorine dioxide. There are, however, in some developing countries and China, a number of non - wood -based (i.e., wheat straw, bamboo, sugar cane bagasse, and reed) pulp mills that use elemental chlorine which still causes the formation of2,3,7,8-TCDD and 2,3,7,8-TCDF (Wang et al., 2012; Fang et al., 2017; Xiao et al., 2017). Conversion from 100% elemental chlorine bleaching to ECF-bleaching in four mills has resulted in a reduction of dioxin toxicity equivalents of about 98% (Xiao et al., 2017). China now has a project from the Global Environment Facility for the phase out of elemental chlorine, which aims to support China in developing and adopting a long-term action plan to guide the promotion of a sector -wide BAT/BEP adoption (https://www.thegeforg/proj ect/dioxins-reductions-pulp-and-paper-industry-china). 7. Chlorine dioxide production and implications for the elimination of PCDD/Fs Today, chlorine dioxide is produced at the pulp mill via the chemical reduction of sodium chlorate to chlorine dioxide using one of several commercially available processes. Elemental chlorine can be formed as an impurity in the chlorine dioxide generation system depending on which process is used. Therefore, a careful selection of the chlorine dioxide generation method will decrease the formation of elemental chlorine impurities and the formation of PCDD/Fs. From the 1970s to the 1990s the reduction of chlorate to chlorine dioxide was carried out with hydrogen chloride (HC1). The HC1-based method results in a significant formation of elemental chlorine in the chlorine dioxide. The HC1 method is therefore not used by modern kraft pulp mills producing ECF-bleached pulp. Today, chlorine dioxide in the vast majority ofbleached kraft https://www.sciencedirect.com/science/article/pii/S0045653519316078 14/26 1/7/2021 The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/F... Download L.+V 11/. 1V1111J U3111, JV-l.Qi1l.0 11111.61 Q ll.0 FL kJ U.W. 11V11 Vl JQ IL Q.L.W. 1.111Vlllll. U1Vt11Ul. 11Q V higher levels of elemental chlorine. In one study (Axegard and Bergnor, 2011), an industrial oxygen bleached softwood kraft pulp was bleached with chlorine dioxide containing 0.3%, 5% and 8.5% elemental chlorine, expressed as percentage of total oxidation power, covering the range of elemental chlorine content that resulted from commercially available chlorine dioxide generation processes, including integrated processes. The reason for using 0.3% elemental chlorine as a chlorine dioxide reference was that, as mentioned above, modern chlorine dioxide processes via reduction with hydrogen peroxide or methanol achieve this level of elemental chlorine in the chlorine dioxide. The pulp was spiked with 100 ppm DBF and a world class laboratory with extremely low detection limits was used for the dioxin analysis. The result was reported as 2,3,7,8-TCDD Toxicity Equivalents (TEQ) Lower Bound and indicated a potential risk for the generation of PCDD/Fs when there was a level of more than 5% elemental chlorine in the chlorine dioxide. In Table 3 the corresponding, and until now unpublished, analytical data are shown. It can be noted that the amounts of all of the 17 analyzed congeners in the sample with 0.3% elemental chlorine (of total oxidation power) were on the same level as in the blank, while a tendency could be seen that some furan congeners increased in the sample with 5% and 8.5% elemental chlorine. It can also be noted that positive detects for 0.3% and 5% elemental chorine (marked with an asterisk) are at the same level or lower than the blank. Table 3. The content of 17 PCDD/Fs in an industrial oxygen delignified softwood kraft pulp after chlorine dioxide bleaching in laboratory scale. The chlorine dioxide had a content of 0.3% (D100), 5% (D95) and 8.5% (D91.5) elemental chlorine, expressed as percentage of total oxidation power. The pulp had kappa number 11 after oxygen delignification and was spiked with 100ppm DBF. LOD were reported as values 3 times above the blank level. Values that are shown in italics in parenthesis are between 3 and 10 times the LOD and have extended measurement uncertainty, according to the laboratory that did the tests. Quantifiable values are those that are 10 times the LOD. Source: Previously unpublished analytical data from Axegard and Bergnor (2011). PCCD/F analyses were carried out by University ofUmea, Sweden. 2378-TCDD LAB BLANK D100 D95 D91.5 0.3% C12 5% C12 8.5% C12 pg/g LOD pg/g LOD pg/g LOD pg/g LOD nd 0.016 nd 0.019 nd 0.029 nd 0.056 https://www.sciencedirect.com/science/article/pii/S0045653519316078 15/26 1/7/2021 The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/F... Download pg/g LOD pg/g LOD pg/g LOD pg/g LOD 12378-PeCDD nd 0.032 nd 0.031 nd 0.060 nd 0.095 123478-HxCDD 0.064 0.015 nd 0.026 (0.060) 0.024 (0.081) 0.048 123678-HxCDD (0.056) 0.025 nd 0.025 (0.061) 0.036 nd 0.060 123789-HxCDD Nd 0.027 nd 0.028 (0.061) 0.049 nd 0.080 1234678-HpCDD (0.029) 0.025 nd 0.024 (0.091) 0.036 (0.18) 0.078 OCDD (0.053) 0.050 0.14 0.048 (0.12) 0.049 (0.25) 0.10 2378-TCDF 0.056 0.012 (0.034) 0.013 0.14 0.020 0.12 0.036 12378-PeCDF 0.083 0.021 nd 0.020 (0.048) 0.030 (0.10) 0.047 23478-PeCDF (0.051) 0.022 nd 0.022 nd 0.039 nd 0.071 123478-HxCDF 0.12 0.017 nd 0.019 0.14 0.034 0.35 0.043 123678-HxCDF 0.077 0.016 nd 0.016 nd 0.030 0.12 0.032 123789-HxCDF 0.096 0.025 nd 0.018 (0.11) 0.039 (0.1.7) 0.074 234678-HxCDF (0.056) 0.018 (0.055) 0.024 (0.066) 0.032 (0.15) 0.065 1234678-HpCDF 0.12 0.025 (0.061) 0.024 0.16 0.030 0.34 0.045 1234789-HpCDF 0.12 0.022 nd 0.018 0.12 0.032 0.41 0.066 OCDF 0.21 0.050 0.16 0.048 1.2 0.049 0.65 0.088 Currently, the UNEP Toolkit reports very low emission factors of PCDD/Fs from kraft mills using ECF bleaching. The UNEP review and the previously unpublished data above demonstrate that the emission factors for ECF mills using chlorine dioxide with less than 0.3% elemental chlorine should be zero. It is also important to note that EU's 2015 Best Available Technology (BAT) document stipulates that "the only processes that can provide chlorine dioxide without formation of elemental chlorine are methanol -based and hydrogen peroxide -based SVP-and R-processes and the sulfur dioxide -based Mathieson process," (Suhr et al., 2015). 8. Conclusions • The typical fingerprint PCDD/Fs for kraft pulp bleached with elemental chlorine was unique compared to all other documented sources such as incineration and metallurgic processes. https://www.sciencedirect.com/science/article/pii/S0045653519316078 16/26 1/7/2021 The effect of the transition from elemental chlorine bleaching to chlorine dioxide bleaching in the pulp industry on the formation of PCDD/F... Download • The level ofunchlorinated precursors in other process -related chemicals played a role in the amount 2,3,7,8-TCDD and 2,3,7,8-TCDF formed. Elimination ofunchlorinated precursors lowered, but did not eliminate the formation of 2,3,7,8-TCDD and 2,3,7,8-TCDF when bleaching with elemental chlorine. • Replacing elemental chlorine with chlorine dioxide (with levels of elemental chlorine contamination of 0.3% or less in the chlorine dioxide) in pulp bleaching eliminates the formation of2,3,7,8-TCDD and 2,3,7,8-TCDD during the bleaching process with chlorine dioxide. • PCDD/Fs can be found in background levels in ecosystems, food, soil and air as well as in unbleached pulp, bleached pulp, and paper and fiber products. Thus, the only way to determine if PCDD/Fs are present from bleaching is to make a full congener analysis and compare to known sources and processes as well as laboratory blanks and unbleached reference samples. Acknowledgements This literature review has been financially supported by Procter and Gamble, United States.. Recommended articles Citing articles (6) References Allen et al., 1989 L.H. Allen, R.M. Berry, B. Fleming, C.E. Luthe, R.H. Voss Evidence that oil -based additives are an indirect source of the TCDD and TCDF produced in kraft bleach plants Chemosphere, 20 (10-12) (1989), pp. 1611-1618 1989 View Record in Scopus Google Scholar Axegard, 1988a P. Axegard Methods to minimize the formation oflipophilic chloro-organics in bleaching Proceedings Tappi International Pulp Bleaching Conf 1988 (1988), pp. 69-75 View Record in Scopus Google Scholar Axegard,1988b P. 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CRELXTM https://www.sciencedirect.com/science/article/pii/S0045653519316078 26/26 • SUBSIBEI (https: situp ecirc.com/subscribe/smoky-mountain-news) • ABOUT+3CONTACT • .ADVERTISE • M p MANAGE SUBSCRIPTION /contacts /advertise htt s situ ecirc.com subscriber_login/smoky-mountain-news) • OTH PUBLIC TIONS (https: issuu.com smo ymountain/stacks/2764a325866645c491e6b245ead54cf9) Smoky Mountain (/index.php) Support the Smoky Mountain News and independent, award -winning journalism Contribute Blue Ridge Paper Products changes name, moves headquarters it Written by Admin (/archives/itemlist/user/62-admin) 0 o5 September 2007 A Archived News (/archives/itemlist/category/6o-archived-news) By Julia Merchant • Staff Writer Blue Ridge Paper Products, long one of the largest employers in Western North Carolina, is no longer — at least in name. An internal memo sent to employees Aug. 24 announced that the company's name has officially been changed to Evergreen Packaging Group to reflect its new ownership by the New Zealand -based Rank Group. The memo also stated that the company's corporate headquarters is being moved from Canton to Memphis, Tenn. It seems as though Evergreen has already set up shop in Memphis — they list their new address on Poplar Avenue in the memo, along with a new Memphis phone number. FEARLESS. CURIOUS GENEROUS (/component/banners/click/3o7) An Empowering Weekly Newsletter by women, tutwornen, about women. 1121Ettps://www.smokymountainnews.com/ar blue-ridge-paper-products-changes-name-moves- headquarters#top) Former Blue Ridge Paper CEO Rich Lozyniak declined to relocate to the new headquarters and resigned from the company. His final day was last week. A new management team has already been put in place at Evergreen Packaging Group, though it includes only two members of upper management from former Blue Ridge Paper Products — Phillip Bowen, vice president of sales and marketing, and Terry Huskey, vice president of paper sales. There is no indication what the new ownership means for rank -and -file jobs at the mill. Blue Ridge Paper Products posted a $7.6 million loss for the financial quarter ending June 3o, according to information from the Securities and Exchange Commission. Blue Ridge (now Evergreen) employees are set to receive a payout from the Employee Stock Ownership Nan, which they agreed to in exchange for the sale of their shares of the company. The average payout is estimated at around $20,00o per employee, and will be doled out around Oct. 12. The company employs nearly 1,ioo workers at its two plants in Canton and Waynesville. 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A11 rights reserved. P.O. Box 629, Waynesville, NC 28786 • 828.452.4251 (http://www.smliv.com) Srin.tDOUR— �8i[I l 1 � /� vl ES Go to top (https://www.smokymountainnews.com/archives/item/8313- blue-ridge-paper-products-changes-name-moves- headquarters#top) From: To: Subject: Date: Brown, Jamie Branam SVC DENR.publiccomments [External] Blue Ridge Paper Products, NC #0000272 Wednesday, January 20, 2021 2:15:17 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. North Carolina Div. of Environmental Quality, I am writing to protest the proposed permit for Blue Ridge Paper Company for the Pigeon River. I was born and raised in Cocke County and spent a number of years away securing my education. When I returned home in the early 80's I became involved with the Dead Pigeon River Council due to my passionate concern for the polluted river. My father had taken me to the head waters as a young child and let me get a drink of water and then took me down river to show me what the paper company had done to destroy this wonderful natural resource. This experience never left me and when I came home I was determined to be a part of the solution. We have fought all these years for this river and what it means to our community as well as our families. North Carolina, the people that work for the mill and the paper company has greatly benefited financially on the backs of a poor mountain community and people. I have personally watched families not able to make a living in our community having to move away and not have access to their extended family- a critical value in our community. When. people visit and consider coming here to open businesses the river has always been a huge deterrent while you have enjoyed prosperity related to the paper mill. I know they have not made ONE SINGLE improvement in the mill that was not a direct result of our efforts in pushing for a clean river. They fought us every step of the way and have lost multiple lawsuits. The man that currently owns the mill would not be allowed to operate this mill in his home country because it does not meet their environmental standards. Pause and think about that for just a few minutes. Three years ago my husband retired and we bought a farm in Cosby and now our land joins the river. I have a front row seat on my front porch to the everyday condition of the river. It is certainly much better then when we became active in the 80's BUT is has deteriorated in the last year. We see beige and brown foam floating past our house and when we walk down to the river there are huge ugly mounds of the foam. The color varies from day to day and at times the color is horrible. The idea that any regulation should be lifted is reprehensible and less than honorable. The idea of the permit was to give them time to get the river to an acceptable place. This has not happened. There should be marked improvement with every cycle of the permit. The technology exists to make this plant efficient and the river pristine. They should be required to purchase and install this technology. Canadian plants use this technology. If they will not modernize to this point they should be shut down. Over 100 years of pollution is enough! This fight will not end and we will as a community and as landowners find ourselves in the legal system again unless the improvements are made. Thank you for your consideration, Dr. Jamie Branam Brown Jamie Branam Brown. PhD. HS-BCP Listed Rule 31 Family Mediator Graduate Coordinator Human Services Professor Human Services / Women's Gender & Sexuality Studies Department of Counseling and Human Services Clemmer College brownjb@etsu.edu From: lewisdeboaevervactioncustom.com on behalf of Deborah Lewis To: SVC DENR.Dubliccomments Subject: [External] comment on Blue Ridge Paper Products, NC Date: Wednesday, January 20, 2021 9:33:33 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Public Comments Reviewer, As someone who frequently uses the Pigeon River for recreation I think the draft wastewater discharge permit for Blue Ridge Paper Products will damage water quality and the health of people and wildlife that use the water of the Pigeon River. The Clean Water Act protects water quality and applies to the Pigeon River in NC. he draft permit as proposed by the Department of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Deborah Lewis 532 N Griffing Blvd Asheville, NC 28804-2816 lewisdebo@gmail.com From: lewisdebo@everyactioncustom.com on behalf of Deborah Lewis To: Chernikov, Seraei Subject: [External] comment on Blue Ridge Paper Products, NC Date: Thursday, January 21, 2021 9:15:57 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, As someone who frequently uses the Pigeon River for recreation I think the draft wastewater discharge permit for Blue Ridge Paper Products will damage water quality and the health of people and wildlife that use the water of the Pigeon River. The Clean Water Act protects water quality and applies to the Pigeon River in NC. he draft permit as proposed by the Department of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Deborah Lewis 532 N Griffing Blvd Asheville, NC 28804-2816 lewisdebo@gmail.com From: rocatgo©everyactioncustom.com on behalf of ROSEMARY TANN To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:16:09 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, ROSEMARY TANN 14 Painted Trillium Trl Black Mountain, NC 28711-5525 rocatgo@gmail.com From: kcrutch@everyactioncustom.com on behalf of Karen Crutchfield To: Chernikov. Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:19:45 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products does not sufficiently protect the waters of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. Thank you for your time and consideration of these important issues. Sincerely, Karen Crutchfield 124 Mountain Dr Biltmore Lake, NC 28715-8914 kcrutch@aol.com From: janice.stevenson80(aevervactioncustom.com on behalf of Janice Stevenson To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:20:17 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Janice Stevenson 21 Von Ruck Ter Asheville, NC 28801-2027 janice.stevenson80@yahoo.com From: bobdurivage@everyactioncustom.com on behalf of Robert durivaae To: Chernikov, Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:20:24 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Robert durivage 29 Northstar Trl Weaverville, NC 28787-8643 bobdurivage@yahoo.com From: pmcurtin@ everyactioncustom.com on behalf of Paul Curtin To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:20:27 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Paul Curtin 128 Stonecrest Dr Asheville, NC 28803-8514 pmcurtin@hotmail.com From: jusbyn©everyactioncustom.com on behalf of Jusbvn Lockard To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:20:33 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Jusbyn Lockard 5223 Knoxville, TN 37918 jusbyn@gmail.com From: mollyhannahmcintosh©everyactioncustom.com on behalf of Molly McIntosh To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:20:47 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Molly McIntosh 709 Brookshire St Asheville, NC 28803-2817 mollyhannahmcintosh@gmail.com From: ryanlansche@everyactioncustom.com on behalf of Ryan Lansche To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:20:51 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Ryan Lansche 121 Chatham Rd Asheville, NC 28804-3307 ryanlansche@gmail.com From: eva louise@everyactioncustom.com on behalf of Eva Humphrey To: Chernikov. Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:21:00 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Eva Humphrey 814 Fairview St Asheville, NC 28803-2823 eva_louise@icloud.com From: jlamarca@everyactioncustom.com on behalf of Kate Lamar To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:21:07 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Kate Lamar 438 Haw Branch Rd Barnardsville, NC 28709-9762 jlamarca@charter.net From: macombs42(aevervactioncustom.com on behalf of Mary Combs To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:21:12 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Mary Combs 1602 Airport Rd Marion, NC 28752-3882 macombs42@yahoo.com From: Ibo.boggess@ evervactioncustom.com on behalf of Laura Boggess To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:21:22 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Laura Boggess 501 Bailey St Mars Hill, NC 28754-6209 lbo.boggess@gmail.com From: eneuhaus@everyactioncustom.com on behalf of Eric Neuhaus To: Chernikov. Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:21:31 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Eric Neuhaus 167 B Haywood Rd Asheville, NC 28806-4523 eneuhaus@wildlandseng.com From: beckvlbrown@@evervactioncustom.com on behalf of Becky Brown To: Chernikov, Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:21:37 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Becky Brown 4 Redfern St Asheville, NC 28806-2618 beckylbrown@gmail.com From: MJCinWNCC&evervactioncustom.com on behalf of Mary Curry To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:21:43 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, As citizens of western North Carolina who use the Pigeon, we demand that you safeguard our health and our economy. Correct the following moral and economic deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Personally, I believe that all dioxin should be banned and huge fines imposed for any dumping of this deadly poison. The death rate from dioxin -related disease among my Canton -area friends is still horrendous; this isn't an academic issue to me --it's personal, it's human. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. I think its executives can limp along with their current millionaire lifestyles in exchange for not killing or sickening their fellow citizens and damaging tourism. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform sharply, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Mary Curry 123 Winchester Dr Waynesville, NC 28785-9313 MJCinWNC@gmail.com From: brooksandra308©evervactioncustom.com on behalf of Sandra Brooks To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:21:45 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, KEEP OUR RIVERS CLEAN!! The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept l.ment of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Sandra Brooks 24 Meeting St Asheville, NC 28803-0167 brooksandra308@gmail.com From: kevin.wavne.vountC@evervactioncustom.com on behalf of Kevin Yount To: Chernikov, Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:21:51 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. Many people use the Pigeon river downstream of the plant as there is a great whitewater section just across the border in Tennessee used by both commercial rafting companies and private boaters. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept l.iuent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Kevin Yount 19 English Ivy Rd Asheville, NC 28806-5514 kevin.wayne.yount@gmail.com From: ienherman77Ccaevervactioncustom.com on behalf of lenny Herman To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:22:00 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Jenny Herman 255 Garren Creek Rd Fairview, NC 28730-7605 jenherman77@yahoo.com From: thompsonael4@everyactioncustom.com on behalf of Andrea Thompson To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:22:05 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The history between the Pigeon River and the mill in Canton is a sordid one. Improvements have been made over time, but the draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. This is a social justice issue! I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be safe for recreation and wildlife, especially if downstream municipalities are still using the river for drinking water. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept l.iuent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Andrea Thompson 55 Farm View Rd Fairview, NC 28730-8532 thompsonae 14@gmail.com From: Qinoer.kowaI@ evervactioncustom.com on behalf of Virginia Kowal To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:22:14 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Virginia Kowal 109 D And G Rd Hot Springs, NC 28743-7348 ginger.kowal@gmail.com From: cpjustice69@everyactioncustom.com on behalf of Cynthia Justice To: Chernikov, Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:22:20 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. This is especially important, of course, when people are eating fish from the river, swimming and playing in the river. We need clean places to be able to trust for our families to use. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Cynthia Justice 21 Park Rd Asheville, NC 28803-3001 cpjustice69@gmail.com From: nancyacopine@everyactioncustom.com on behalf of Nancy Acooine To: Chernikov, Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:22:27 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Nancy Acopine 81 Lakeshore Dr Asheville, NC 28804-2443 nancyacopine@gmail.com From: micahwheat(&evervactioncustom.com on behalf of Micah Wheat To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:22:28 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Micah Wheat 8 Bent Tree Rd Asheville, NC 28804-3701 micahwheat@gmail.com From: wolfmommv@evervactioncustom.com on behalf of Nancy Brown To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:22:36 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Nancy Brown 48 Elijah Hall Rd Black Mountain, NC 28711-8805 wolfmommy@msn com From: hermanralphCo evervactioncustom.com on behalf of Ralph Herman To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:22:45 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Ralph Herman 110 Pyatt Heights Rd Marion, NC 28752-5781 hermanralph@gmail.com From: imtwilsonCalevervactioncustom.com on behalf of Jan Wilson To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:22:49 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Jan Wilson 85 Mount Clare Ave Asheville, NC 28801-1850 jmtwilson@netzero.net From: Tomhud21@everyactioncustom.com on behalf of Tom Hudson To: Chernikov, Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:22:55 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The Pigeon River is a valuable resource for Western North Carolina. It would greatly benefit the residents of the area if the water were clean enough to swim in and the fish safe to eat. The draft wastewater discharge permit for Blue Ridge Paper Products makes this less possible by relaxing standards for water temperature which can lead to larger and more frequent fish kills Additionally, the relaxed standards would allow greater pollution from dioxin, fecal coliform, and chloroform. Rather than relaxing regulations, current regulations should be maintained if not tightened in order to improve the water quality in the Pigeon River. Sincerely, Tom Hudson 26 Mountain View Dr Black Mountain, NC 28711-9786 Tomhud21@gmail.com From: sailswithgraceevervactioncustom.com on behalf of Marcelle Crago To: Chernikov, Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:23:14 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, We come up every summer to the area and really hope that Pigeon River will continue getting cleaner. The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept l.ment of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Marcelle Crago 5116 S Lockwood Ridge Rd Sarasota, FL 34231-7428 sailswithgrace@yahoo.com From: ansmoker@evervactioncustom.com on behalf of Art Smoker To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:23:18 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Art Smoker 284 Arrowood Corner Rd Mars Hill, NC 28754-9143 ansmoker@gmail.com From: gracefuchs5678@everyactioncustom.com on behalf of Grace Fuchs To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:23:26 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Grace Fuchs 28 Forsythe St Asheville, NC 28801-1106 gracefuchs5678@gmail.com From: mchislett714@everyactioncustom.com on behalf of Meu Chislett To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:23:30 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft permit as proposed by the Department of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. Of concern is hot water discharge by relaxing the monitoring of water discharge temperature which could and has potentially killed many fish. In addition please do not decrease the monitoring of Dioxin as we all know this could be catastrophic for the fish. I am also concerned about the fecal coliform present in the Pigeon river and have learned that Blue Ridge paper mill has it's own water treatment plant. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. This certainly is not in line with the Clean Water act. We need to preserve our rivers for many reasons including for recreation, commerce and it's inherent beauty. Please do not make changes to the permits which would relax these regulations and monitoring. Thank you for your time and consideration of these important issues. Sincerely, Meg Chislett 14 Jarnaul Ave Asheville, NC 28804-2249 mchislett714@gmail.com From: sweissman4@everyactioncustom.com on behalf of Stephen Weissman To: Chernikov, Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:23:34 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Stephen Weissman 8 Oak Ct Candler, NC 28715-9454 sweissman4@gmail.com From: ronlambe@everyactioncustom.com on behalf of Ron Lambe To: Chernikov. Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:23:41 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Ron Lambe 104 Trotter P1 Asheville, NC 28806-2523 ronlambe@yahoo.com From: rlarge@everyactioncustom.com on behalf of Rita Large To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:23:46 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Rita Large 18 Lynwood Cir Asheville, NC 28806-2145 rlarge@charter.net From: rocatgo©everyactioncustom.com on behalf of ROSEMARY TANN To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:23:47 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, ROSEMARY TANN 14 Painted Trillium Trl Black Mountain, NC 28711-5525 rocatgo@gmail.com From: jI428182©evervactioncustom.com on behalf of Justin Landry To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:23:53 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Justin Landry 119 Chestnut P1 Arden, NC 28704-2902 j1428182@yahoo.com From: sundownslim@everyactioncustom.com on behalf of Joshua Martin To: Chernikov. Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:24:01 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Joshua Martin 86 Deaver St Asheville, NC 28806-4557 sundownslim@gmail.com From: asiaevervactioncustom.com on behalf of Asia Suler To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:24:02 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, I believe that the draft wastewater permit for Blue Ridge Paper Products is a major step backwards when it comes to water quality and the health of the Pigeon River. I'm asking you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable! The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept l.ment of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Asia Suler 115 Blannahassett Is # 107 Marshall, NC 28753-9039 asia@onewillowapothecaries.com From: agheermans@everyactioncustom.com on behalf of Amnda heermans To: Chernikov. Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:24:06 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The day will be an exciting one when we can proclaim the Pigeon River one of the healthiest in the state for which you can claim credit. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept ltnent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Amnda heermans 19 Seldom Home Dr Black Mountain, NC 28711-8781 agheermans@gmail.com From: cysampson@evervactioncustom.com on behalf of Cynthia Sampson To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:24:06 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Cynthia Sampson 1 Battle Sq Apt 306 Asheville, NC 28801-2740 cysampson@aol.com From: ieffhunter.0l@evervactioncustom.com on behalf of Zeffrev Hunter To: Chernikov. Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:24:09 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Jeffrey Hunter PO Box 983 Burnsville, NC 28714-0983 jeffhunter.01@gmail.com From: cathv.nieman@caevervactioncustom.com on behalf of Cathy Nieman To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:24:13 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Cathy Nieman 312 Ivy Hill Rd Weaverville, NC 28787-9652 cathy.nieman@gmail.com From: easter678603@evervactioncustom.com on behalf of Alisa Vargas To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:24:20 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Alisa Vargas PO Box 1868 Marion, NC 28752-1868 easter678603@gmail.com From: rubiasavacie@&evervactioncustom.com on behalf of Alicia Swaringen To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:24:26 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Alicia Swaringen 62 Rosewood Ave Asheville, NC 28801-1616 rubiasavage@gmail.com From: frodaddv125@ evervactioncustom.com on behalf of Charlie Froelich To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:24:30 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Charlie Froelich 16 Heather Mist Dr Weaverville, NC 28787-8000 frodaddy125@yahoo.com From: amandalevesque466@everyactioncustom.com on behalf of Amanda Levesaue To: Chernikov, Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:24:35 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Amanda Levesque 1 Battle Sq Apt 309 Asheville, NC 28801-2740 amandalevesque466@gmail.com From: britesoiritl(a�evervactioncustom.com on behalf of Lori Bright To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:24:39 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Lori Bright 75 Hickory Tree Rd Asheville, NC 28805-1697 britespiritl@yahoo.com From: iohauser41Ccaevervactioncustom.com on behalf of Dorothy Hauser To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:24:51 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Dorothy Hauser 6 Fairway Dr Asheville, NC 28805-2406 johauser41@juno.com From: andreainblueridge(aeveryactioncustom.com on behalf of Andrea and Fred Thompson To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:24:57 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, PLEASE HELP SAVE OUR PLANET! It is so scary to go backwards when it comes to healthy water quality. Whatever pollutes our water, in return kills nature and humanity. Water is our lifeline. We so desperately need to reverse the downward spiral we are in. PLEASE help us keep our beautiful mountain communities safe and clean before it is too late!!! The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Department of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Andrea and Fred Thompson 112 Fulton Dr Hendersonville, NC 28792-9509 andreainblueridge@gmail.com From: puroledocj evervactioncustom.com on behalf of BRIDGET J DUNFORD To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:25:04 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, Please strengthen environmental protections in NC. This is not the time to remove water protections in NC.Enhanced water protections benefits all North Carolinians and businesses. The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Depai anent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, BRIDGET J DUNFORD 525 Patton Valley Dr Nebo, NC 28761-7710 purpledog@hughes.net From: emilvdstein77Calevervactioncustom.com on behalf of Emily Stein To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:25:06 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Emily Stein 115 Swannanoa Ave Asheville, NC 28806-4432 emilydstein77@gmail.com From: jwbromer@everyactioncustom.com on behalf of john Bromer To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:25:10 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. Please work for the environment. The government of destruction has been repudiated. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept anent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, John Bromer 255 Lakey Gap Acres Black Mountain, NC 28711-9647 jwbromer@yahoo.com From: bbrookshire@@evervactioncustom.com on behalf of Becky Brookshire To: Chernikov, Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:25:17 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Becky Brookshire 3187 Anderson Branch Rd Marshall, NC 28753-6300 bbrookshire@usa.net From: summerwhelden@everyactioncustom.com on behalf of Summer Whelden To: Chernikov, Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:25:23 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, Please take action to preserve our most precious, life giving resource: water! The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept anent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Summer Whelden 19 Cardinal Ridge Dr Asheville, NC 28805-2022 summerwhelden@gmail.com From: redcerceCcaevervactioncustom.com on behalf of Tonva Cerce To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:25:27 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Tonya Cerce 105 Gibbs St Swannanoa, NC 28778-3219 redcerce@yahoo.com From: jeanann.wheelock@everyactioncustom.com on behalf of jean wheelock To: Chernikov. Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 1:08:59 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, jean wheelock 53 Trail Top Dr Asheville, NC 28805-0049 jeanann.wheelock@gmail.com From: jeanann.wheelock(alevervactioncustom.com on behalf of jean wheelock To: SVC DENR.oubliccomments Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 1:09:06 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Public Comments Reviewer, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, jean wheelock 53 Trail Top Dr Asheville, NC 28805-0049 jeanann.wheelock@gmail.com From: rebecca(aevervactioncustom.com on behalf of Rebecca Ward To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 1:09:38 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Rebecca Ward 68 Gudger Rd Candler, NC 28715-9213 rebecca@squarefootavl.com From: lenorekw@everyactioncustom.com on behalf of Lenore Madeleine To: Chernikov, Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:16:07 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Lenore Madeleine 700 Vista Lake Dr Apt 308 Candler, NC 28715-7191 lenorekw@yahoo.com From: carolmarty@ evervactioncustom.com on behalf of Carol Marty To: Chernikov Seraei Subject: [External] Re: increase controls on Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:23:09 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, We need more controls on pollution, not less! The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. The Pigeon River is currently well known as a "dirty river". I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept l.ment of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The DEQ should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Please make the choice for safety and health of people, wildlife and rivers, NOT corporate profits. PLEASE— Stop the madness. Sincerely, Carol Marty 215 Summit St Asheville, NC 28803-2722 carolmarty@ymail.com From: caespinosal@everyactioncustom.com on behalf of Carlos Espinosa To: Chernikov Sergei Subject: [External] RE: Keep the Future Healty! Date: Thursday, January 21, 2021 9:21:27 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Carlos Espinosa 212 Central Ave Black Mountain, NC 28711-2713 caespinosal@gmail.com From: lindsev.mcintosh8(aevervactioncustom.com on behalf of Lindsey McIntosh To: Chernikov, Seraei Subject: [External] Re: Stop Killing the Pigeon, Blue Ridge Paper Products, NC #0000272 Date: Thursday, January 21, 2021 9:23:26 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, My name is Lindsey, a longtime resident of Appalachia, raised in Asheville, and lover of all things natural and pure in our community. MountainTrue helped to inform me about the proposed permit plan for Blue Ridge Paper Products, and to summarize my thoughts into one word would be appalled. It is appalling that people, some born in these communities and some new residents of the mountains, would think it is just to allow these increasing damages to be perpetuated onto our local waterways. The Pigeon River is a life force of the Canton community. It is not a solution to the plants dumping needs. We take pride and value our mountain homes for their beauty, but that support and aesthetic heritage stems from the rivers that have given it life. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. Plan and simple as that, folks. The draft permit as proposed by the Department of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. All in all, the DEQs propositions are disgusting. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you, and I hope that you will make the right choice, the community's choice. Sincerely, Lindsey McIntosh 1929 Sussex Rd Blacksburg, VA 24060-6511 lindsey.mcintosh8@gmail.com From: pattvcunninc hamwoolf@caevervactioncustom.com on behalf of Patricia Cunningham -Woolf To: Chernikov, Sergei Subject: [External] Tourism and Economy Depend on Health Waterways Date: Thursday, January 21, 2021 9:23:41 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Patricia Cunningham -Woolf 12 Ellenwood Dr Asheville, NC 28804-2316 paftycunninghamwoolf@gmail.com From: 4pressons@everyactioncustom.com on behalf of susan presson To: Chernikov, Seraei Subject: [External] don"t let the Pigeon River get so polluted AGAIN! Date: Friday, January 22, 2021 8:58:13 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, susan presson 78 Rosewood Ave Asheville, NC 28801-1616 4pressons@gmail.com From: Rregenfuss To: SVC DENR.publiccomments Subject: [External] Pigeon River Clean Water Act Date: Friday, January 22, 2021 7:41:06 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> I urge you to enact stricter measures ensuring clean water in the Pigeon River watershed. As an avid outdoorsman I often paddle it's water and hike it's shore. We need to do a better job improving the Pigeon's water quality. Respectfully, Richard Regenfuss 92 Streamside Waynesville, NC 28785 Sent from my iPhone From: snam5370C@evervactioncustom.com on behalf of S.Nam To: SVC DENR.oubliccomments Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 12:43:30 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Public Comments Reviewer, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, S. Nam 165 Bennett Ave Apt 4L New York, NY 10040-4080 snam5370@ymail.com From: puroledoci evervactioncustom.com on behalf of BRIDGET J DUNFORD To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:57:23 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, PLEASE KEEP OUR WATER FREE FROM POLLUTION AND MAINTAIN STRONG ACTIONS TO MEET THE GOALS OF THE CLEAN WATER ACT. The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Depai liuent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, BRIDGET J DUNFORD 525 Patton Valley Dr Nebo, NC 28761-7710 purpledog@hughes.net From: adanto@everyactioncustom.com on behalf of Croitiene ganMorvn To: Chernikov, Seraei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:57:26 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Croitiene ganMoryn 6211 SE 24th Ave Ocala, FL 34480-8122 adanto@jps.net From: mary©everyactioncustom.com on behalf of Mary Goodkind To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:57:27 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Mary Goodkind 23 Ridgefield P1 Biltmore Forest, NC 28803-3019 mary@lindleyg.com From: doendvil@aevervactioncustom.com on behalf of Derek Gendvil To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:57:31 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Derek Gendvil 9030 W Sahara Ave Las Vegas, NV 89117-5744 dgendvil@gmail.com From: amandalevesque466@everyactioncustom.com on behalf of Amanda Levesaue To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:57:34 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Amanda Levesque 1 Battle Sq Apt 309 Asheville, NC 28801-2740 amandalevesque466@gmail.com From: maglionicl@everyactioncustom.com on behalf of Jude Maglione To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:57:38 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Jude Maglione 10 Moreview Dr Asheville, NC 28803-2713 maglionicl@aol.com From: alyssamelton16@everyactioncustom.com on behalf of Alvssa Melton To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:57:40 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Alyssa Melton 21 Reynolda Dr Asheville, NC 28803-9518 alyssamelton16@gmail.com From: osfritch(caevervactioncustom.com on behalf of Gloria Fritch To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:57:43 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Gloria Fritch 102 W Farm Creek Dr Asheville, NC 28806-1552 gsfritch@bellsouth.net From: paula@everyactioncustom.com on behalf of Paula Stober To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:57:45 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, Please oppose the wastewater discharge permit for Blue Ridge Paper Products. The draft is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept ltuent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. I hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Paula Stober 3607 Timberoak Dr Greensboro, NC 27410-2142 paula@bucklen.com From: suepharmon@everyactioncustom.com on behalf of Susan Harmon To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:57:50 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, I do hope you'll consider the following. The public is paying attention. The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept l.ment of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Susan Harmon 3705 Hilidale Rd Oakwood, GA 30566-2211 suepharmon@gmail.com From: Iuogo.al.sole@everyactioncustom.com on behalf of Gina D To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:57:54 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Gina D 2 High Country Rd Weaverville, NC 28787-9374 luogo.al.sole@gmail.com From: vbower@everyactioncustom.com on behalf of Virginia Bower To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:57:54 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Virginia Bower 45 Kenilworth Rd Asheville, NC 28803-2542 vbower@mhu.edu From: andjoel@everyactioncustom.com on behalf of Joel Anderson To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:57:58 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Joel Anderson 5 Sweet Gum Dr Asheville, NC 28805-8203 andjoel@aol.com From: fallenmitten©everyactioncustom.com on behalf of Eric Benson To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:58:00 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Eric Benson 1005 S Victor St Champaign, IL 61821-4807 fallenmiften@gmail.com From: neuhauseDC@evervactioncustom.com on behalf of Eric Neuhaus To: Chernikov Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:58:01 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Eric Neuhaus 10 Peace St Asheville, NC 28806-4315 neuhausep@gmail.com From: glennliming70(Tevervactioncustom.com on behalf of Glenn Liming To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:58:04 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Glenn Liming 2 Josie Ln Asheville, NC 28804-9794 glennliming70@gmail.com From: mleachoarker(&evervactioncustom.com on behalf of Marjorie Leach -Parker To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:58:06 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Marjorie Leach -Parker 2061 Lyndora Rd Virginia Beach, VA 23464-8618 mleachparker@yahoo.com From: mpatchin71@everyactioncustom.com on behalf of michele martin To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:58:08 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, michele martin 2184 Finger Bridge Rd Hickory, NC 28602-7154 mpatchin71@yahoo.com From: karkra©everyactioncustom.com on behalf of Richard Kark To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:58:11 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Richard Kark 420 Lady Huntingdon Ln Asheville, NC 28803-2000 karkra@uwec.edu From: jhabbot(aevervactioncustom.com on behalf of Jayne Abbot To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:58:12 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, As a long time whitewater paddler I have experienced both the dirty and the cleaner Pigeon River. When I first paddled the Pigeon in the mid-1990's, the water smelled very bad and did not feel good on my skin. I didn't go back for years after that. I was pleasantly surprised when I did got back to paddle the river years later at how much cleaner it was, and it continued to be cleaner every year. It is discouraging to see the step backward the draft wastewater discharge permit for Blue Ridge Paper Products is proposing when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Department of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and therefore monitoring on at least the same schedule should be continued until dioxin is no longer present in fish tissue samples. Secondly, the permit renewal cycle is many years overdue, the last fish tissue sample was taken over six years ago. That means, if new sampling is conducted only once in the next five years, that could mean that we only have one sample in 11 years. Recommendation: DEQ should maintain the same sampling schedule of three times within every five years. Fecal Coliform: The mill not only processes its own waste, but also serves as a wastewater treatment plant for the town of Canton. Violations for fecal coliform have been frequent in the last decade with MountainTrue documenting at least 25 permit violations, sometimes in excess of 250 times the safe limit for fecal coliform. The Mill has also commonly violated its permitted standards for total suspended solids and biological oxygen demand. Recommendation: DEQ should require significant improvements to the wastewater treatment plant to ensure the river and downstream river recreation users are protected from harmful and dangerous levels of bacteria in the river. Chloroform: DEQ is proposing to allow the mill to increase their discharge of chloroform, a possible carcinogen. The goal of the Clean Water Act is to reduce pollution discharges until all waters are fishable and swimmable. In this instance, not only is the discharge not decreasing, but the mill will be allowed to discharge even more cancer causing chemicals into the Pigeon River. The 2010 permit allowed for chloroform discharge allowances of 5.1 or 8.6 monthly. The 2021 proposed permit ups those limits to 6.27 lbs/day (as a monthly average) and 10.5 lbs/day (daily maximum). Recommendation: DEQ should reduce discharge allowance for chloroform, not let the paper mill pollute more. Thank you for your time and consideration of these important issues. Sincerely, Jayne Abbot 109 011ie Weaver Rd Weaverville, NC 28787-8302 jhabbot@charter.net From: katratl(aevervactioncustom.com on behalf of Kathy Ratcliff To: Chernikov, Sergei Subject: [External] Re: Blue Ridge Paper Products, NC #0000272 Date: Friday, January 22, 2021 8:58:16 AM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.<mailto:report.spamnanc.gov> Dear Water Resources Sergie Chernikov, The draft wastewater discharge permit for Blue Ridge Paper Products is a step backwards when it comes to water quality and the health of the Pigeon River. I ask you to revise the permit to meet the goals of the Clean Water Act to make our River be fishable and swimmable. The way that regulators should achieve those goals while balancing the interests and needs of industry is by slowly reducing permit discharge limits over time. The draft permit as proposed by the Dept intent of Environmental Quality (DEQ) takes a step backwards by weakening regulations, requiring less monitoring and allowing for more pollution to be discharged to the river. We hope you correct the following deficiencies: Temperature: Over 8,500 fish were killed in the summer of 2007 from an extremely hot discharge from the paper mill. This hot water discharge did not violate the temperature permit limits at the mill, because their limits rely on a monthly average, which allows wild swings in the temperature of the discharge, and potential fish kills. Recommendation: The Department of Environmental Quality should set a daily average limit for the mill to ensure that aquatic life is protected and future fish kills are avoided. Dioxin: Reduction in dioxin fish monitoring in the draft permit is being proposed. Current monitoring requires monitoring 3 times in 5 years, but the new draft permit reduces that to once every 5 years. This is problematic for two reasons. The most recent sampling conducted in 2014 still shows dioxin in fish tissue, and th