INTRODUCTION

Blue Ridge Paper Products Plant is located off Highway 215 (175 Main Street), in Canton, NC.  The receiving waters for the facility wastewater are designated as the Pigeon River, French Broad River Basin.The permit for the Blue Ridge Paper Products’ Canton Mill on the Pigeon River, formerly owned by Champion International, has been the focus of one of the nation’s longest-lasting water quality struggles, with challenges from downstream Tennessee dating back long before the Clean Water Act, starting soon after Mill operations started almost 100

years ago. The permit was last renewed in 2007, and the permit approval very controversial because of high levels of contaminants in the plant’s wastewater discharge into the Pigeon River, including dioxins, heavy metals, and chlorine.  Wastewater color and high turbidity had also been a serious issue. Blue Ridge was required to modify the wastewater control technology as a permit requirement.  Contaminant levels have apparently decreased, after facility modifications, according to sampling completed by the company.

The permit for Blue Ridge Paper Products’ Canton Mill on the Pigeon River, formerly owned by Champion International, has been the focus of one of the nation’s longest-lasting water quality struggles, with challenges from downstream Tennessee dating back long before the Clean Water Act, starting soon after Mill operations started almost 100 years ago. The incongruity of a huge pulp mill on a small, pristine mountain river will continue to generate pressure to restore the downstream stretch of the Pigeon River until it is returned to high quality aquatic habitat, free of the color, odor and toxics of paper pulp production.

Blue Ridge Paper has requested renewal of its National Pollutant Discharge Elimination System (NPDES) discharge permit for its facility located at the Blue Ridge Paper Products Wastewater Treatment Plant, located off Highway 215 (175 Main Street), in Canton, to receiving waters designated as the Pigeon River, French Broad River Basin.

Revisions include changes in current monitoring requirements at the Fiberville Bridge and removal of a color variance. DWR agrees with the removal of the color variance, based on improved stream conditions noted during a reevaluation, including significant improvements to instream concentrations of color in the Pigeon River. The North Carolina Department of Water Resources (DWR) concludes the variance is no longer necessary. A summary of the history of the variance, review of applicable regulations, and a reevaluation of the stream conditions may be viewed on the NCDEQ website. DWR also agrees with the proposed renewal of the federal 316(a) temperature variance.  A fact sheet summarizes DWR’s rationale in developing the NPDES permit limits and monitoring conditions.

April 22, 2021

Ms. Anna Gurney

Wastewater Permitting
Attn: Blue Ridge Paper Products Permit
1617 Mail Service Center
Raleigh, N.C., 27699-1617

RE. Comments on the Draft NPDES Wastewater Discharge Permit #NC0000272 for Blue Ridge Pulp Mill, Canton, NC, with proposed removal of color variance and continuing use of Temperature Variance.

Dear Ms. Gurney:

Environmental Review, Inc. has reviewed the draft permit and has the following comments: 

NCDEC Fact Sheet for Draft Permit

INSTREAM MONTORING, Page 4. Figure 1. I find this map very difficult to read for many reasons. The symbols for the USGS sites and NPDES dischargers are difficult to see. The one label that is different than the rest has the text cut off. Indicating downstream direction would be useful. It would also be useful to mark where the water treatment and paper mill locations are themselves, maybe in its own zoomed in section of the map.

Draft Permit

Part I

A1-A3. Pages 4-9.  Effluent Limitations and Monitoring Requirements

There looks to be 5 locations for monitoring:  influent; effluent;the Pigeon River; and two other effluents of wastewater before entering the wastewater treatment plants. This does not seem to be enough locations, and ,in some cases, not enough sampling frequency. What is the justification for those that are only tested quarterly and annually?

A5. Page 11.  Instream Monitoring Special Condition

There are more sampling sites within Pigeon River for the special condition, what is the special condition? Is it relevant to Dioxin Monitoring?

A8. Pages 16,17. Requirements for Color Analysis and Compliance Special Condition

The pounds of true color are calculated for this permit only. Is there no standard otherwise? I believe 39 FR 430.11 is incorrectly referenced. 

A9. Page 17. Dioxin Monitoring Special Condition

Dioxin has historically been an issue in this watershed. What is the justification for only annual monitoring?  What are the monitoring requirements should other permit condition indices (e.g., fish tissue TCDD levels) exceed permit limits?

A10. Page 18. Dissolved Oxygen Special Condition

Are the oxygen injection facilities already in use, and do they help with maintaining a good dissolved oxygen level?  It is suggested  that DO be measured closer to the facility and downstream past milemark 57.7.  It is recommended that DO be measured in more than two locations so as to more complete data relative to the plant’s impacts on the Pigeon River dissolved oxygen levels.

A11. Page 18. Town of Canton Inflow and Infiltration Special Condition

What efforts are being done to decrease the amount of inflow/infiltration into the Town of Canton?  Should specific metrics be required to meet this condition?

A. (12.) Page 18. Clean Water Act Section 316(a) Thermal Variance

The renewed permit will continue the temperature variances approved for the 2010 Permit.  During the last permit renewal, the variance requirements were changed and the temperature difference between upstream and downstream monitoring locations (ΔT) was reduced from 13.90C to 8.50C . What was the scientific reason for allowing this anthropogenic temperature increase.?  The biological diversity and overall  health of the Pigeon River has significantly improved over the last 10 years. It is proposed that the ΔT Permit Variance be further decreased so as to provide steam conditions even more satisfactory to further support macroinvertebrate and fish species that appear to be recovering.

Thank you for considering our comments on this draft permit.

Regards,

Mary Plauche, MSc., Reviewer (Associate in North Carolina)

Gary D. Kollman, Sr. Reviewer (Associate in Washington)

Environmental Review, Inc.

1792 Rogers Ave

San Jose, California 95112