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Talking Points for the 2021 Draft Permit 000000272 for Pigeon River Pollution Discharge

This permit is unacceptable. It does not demonstrate the spirit of the Clean Water Act NPDES permitting system in that it does not actually reduce pollution to the Pigeon River during the next permitting cycle.

This permit in fact proposes an increase in the amount of chloroform, a dangerous toxic and cancer causing chemical, used in the bleaching process. The daily maximum load of 10.5/lb per day is enough chloroform to kill 321 people per day, in its concentrated form. No wonder river guides suffer painful rashes and allergic reactions to being exposed to the Pigeon's toxic waters.

This permit calls for a 17% increase in water taken from the Pigeon River at a time when water resources across the globe are in jeopardy.

As an organization comprised of members who have regular direct contact with the Pigeon River, members who are professional commercial river guides, members who are private boaters and kayakers, swimmers, and fishermen, our representatives can tell you that the color of the river is brown, dark and sweet tea colored on many days. The river smells like the acrid papermill, all the way to Newport, Tennessee. One can observe foam and often professional river guides deal with rashes and reactions to the many chemicals that comprise the color pollution.

This permit calls for no changes to color pollution with no reductions being called for whatsoever, a violation of the Clean Water Act and the 1997 Settlement Agreement between downstream communities and the paper mill.

The proposed removal of this color variance is basically an admittance by the NC DEQ that

water quality standards are being met and no further reductions to color pollution are required.

The color variance must not be dropped until color pollution is down to an annual average of 20,000 pounds per day with daily maximum limits of 50,000 lbs/day not 105,250 as currently stated, which downstream communities have called for over 20 years. This permit calls for a status quo of 36,000 pounds of color per day annual average, the same as the previous permit cycle, which is not an improvement.

There are problems with attempts to assess the true color units downstream in Tennessee. Members of CWEET has observed that testing for color at mile 24.7 Browns Bridge is conducted 1.3 miles downstream of the actual TN/ NC State line. This provides significant dilution to the Pigeon River from Big Creek and Tobes Creek. It has been observed that testing occurs when the dam is operating below 600 cfs, not at the mimimum recreational flow for whitewater rafting which is 1200 cfs. When water is measured below 600 cfs we can observe that the majority of the water in the river is from Big Creek and Tobes Creek, not actual flow from the main Pigeon River as the majority of polluted water is being held back in Waterville Lake while the majority of water in the riverbed at flows of less than 600 cfs is primarily from tributaries downstream of the Waterville dam. Downstream testing should occur when the flows are operating an average recreational release ranging frois between 1200-2000 cfs which is the flow at which water color appears and smells worst. Measuring water flow at Brown Bridge when the dam is not fully releasing the polluted water is simply not an accurate measurement for color in TN. One can observe that the water is clean and clear when the dam is releasing at small flows of 600 cfs or less and brown dirty and smelly at releases of 1200 cfs or more.

Also, it has never been observed that the company contracted to measure color on the Pigeon actually measures the water at the Pigeon River prior to mixing with Big Creek at mile 26, as called for by the 1997 Settlement Agreement. It would require a boat to access that flow of Pigeon River and Big Creek prior to mixing. We have never observed this type of testing at this location taking place. It should be measured from a boat at the mouth of the dam release for an accurate measurement, prior to mixing with Big Creek as dictated by the 1997 Settlement Agreement.

The color variance must not be removed until downstream communities are satisfied with the condition of the Pigeon River, which is currently not meeting all it's designated uses and remains on the Tennessee 303d list for impaired rivers due to color pollution.

This draft permit ashamedly uses public health as a rationale for removing the color variance stating that there has never been a public health advisory related to color in North Carolina.

There is an advisory, however, issued for color in Tennessee. The fact is that the Pigeon River is listed as impaired for color pollution by the state of Tennessee. Color is comprised of toxic chemicals. Its is a public health issue for the hundreds of thousands of boaters who are yearly exposed to full body contact with its toxic waters.

Blue Ridge Paper Products has requested an increase in water usage from 29.0 million gallons per day to 34 million gallons per day. This is a 17% increase in water usage.

This increase should not be approved until an environmental assessment is conducted to determine what the impacts would be on water quality.

Additionally the draft permit calls for an increase in chloroform usage from the current limits of 5.1/lb day monthy average to a proposed limit of 6.27 pounds per day monthly average, which is a 22% increase in chloroform averaged monthly. As for daily maximums allowed an increase from 8.6 lb/day 10.5/lbs per day daily maximum is also unacceptable. That is a 22% increase of chloroform daily.

We know that chloroform is a dangerous toxic and carcinogenic chemical used in the paper making process and increases of this type of pollution are unacceptable. In a world of climate change and dwindling clean water resources the mill can and should become a leader in marketing non-bleached paper products. Consumer demand for environmentally friendly paper products is at an all-time high, and in the fast changing world of 2021, what better time for the mill to become an innovative leader in marketing brown, not bleached white paper products. Bright white paper is unnecessary and incredibly damaging to the environment and without good reason.

The chloroform cannot be increased. If so, CWEET and the public will call upon the EPA to again rescind this dirty permit.

It is time for the Pigeon River to be clean. It's time for our beautiful resource to be finally protected after 115 years of pollution. The water that flows above the mill is crystal clear and of high quality. We want the same crystal clear properties for the downstream communities of Hartford and Newport that are enjoyed by users of the river upstream of Blue Ridge Paper. Our whitewater rafting industry, our swimmers, our fisherman, our wildlife and microbiology , and all future generations depend on clean water. Water is life. When will the bureaucrats at NC DEQ remember that you cannot eat money?

Lets leave a legacy of tight regulations that actually protect our nation's waters and decrease pollution until is eliminated! If not us, then who will?

For more information on how YOU can help protect the Pigeon River from pollution, click here:


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