DEQ-CFW_00048561

From: Goyt,Ju|ie [/O=EXCHANGELABS/OU=EXCHANGEADMINISTRATIVE GROUP
(FYD|BOHF2]SPDLT)/CN=REOP|ENTS/CN=75D1654D45154C2A8BO859GA2C9AF282-JAGRZY8]
Sent: 8/29/I0I62:I4:33PW1
To: Templeton, Mike [/h=NCMA|L/ou=ExchangeAdministrative Group
(FYD|8OHF233PDO)/cn=Redpient$cn=mike.temp|eton]
CC: Be|nick,Tom [/v=ExchangeLabs/ou=ExchanXeAdministrative Group
(FYD|8OHFZ33PDO)/cn=Redpient$cn=9bZ6435493eI4b3986935598ac339bIb-tbe|nick]
Subject: FVV:Middle Cape Fear Basin Monitoring Coalition Hardness Monitoring
Attachments K8CF8AUpstream Sample Lncadons.x|sx
From: Chad Ham [maiku:[e-mail]]
Sent: Monday, August 29,2D1G9:56AK4
To: Karo|y,[yndi<cyndikaro|y@ncdenr.0ov>
Cc 'BiU.Kreutzberger@[HJK4zom' <Bi|iKreutzber8er@[HJK4.com>; Poupart, ]eff^je#[e-mail]>;
Zimmerman, Jay ^[e-mail]>;Grzyb,Julie ^ju|ie.8rzyb0Dncdenr.8ov>
Subject: Middle Cape Fear Basin Monitoring Coalition Hardness Monitoring
sm
K has come to my attention that at least one of the draft permits issued in the [ape Fear Basin contains an upstream
hardness monitoring requirement on a quarterly basis for the duration of the permit. | was told this monitoring
requirement will be included in other permits since hardness data is needed to calculate metals limits for the new
dissolved metals standards. Middle [ape Fear Basin Association (M[F8A) members are concerned that this could
become trend for not only hardness but also other parameters such as metals when data is needed for permitting
purposes. If these types of additional parameters are regularly required in the ambient monitoring provision for
individual permittees itcould jeopardize the basinw/ide monitoring program because the key that holds this program
together is the waiver of the upstream — downstream monitoring in individual member's permits.
Prior toJuly of 1998 the water quality data being collected in the middle section of the [ape Fear River was sporadic,
uncoordinated, and lacked adequate CyA/\Q[ protocols to ensure data qua|ity. Municipal and industrial wastewater
dischargers did most of the sampling and analysis per their NPIDES permit requirements. Each entity was responsible for
data collection upstream and downstream of their respective discharge. Parametric coverage was usually minima[
including basic field measurements and for a few permittees, BOD, Fecal Co|iform, Ammonia, and specific metals. The
sampling typically occurred from the bank of the river or stream rather than mid -stream, which resulted in data that did
not represent the true condition of the water body. The data was submitted via hard copy DK4R and not available in
electronic format. It and was only available to modeling and permit staff of the agency, after a significant effort to
capture the paper data.
In 1997, a coalition of dischargers in the middle section of the Cape Fear River approached the North Carolina Division of
Water Quality (now N[DE[) with a request to implement a comprehensive water quality monitoring program in the
middle [ape Fear River in exchange for a waiver of the ambient monitoring requirements in their NPDE8
permits. NCDEQ agreed to the request and in July of 1998 the Middle Cape Fear River Basin Association's water quality
monitoring program began.
Members of M[FBA coordinated with NCDE(l staff and thoughtfully laid out a badnw/de monitoring plan that would
provide the most meaningful data at key locations, eliminate duplication of effort, increase parametric coverage and
ensure high quality data. In exchange for adding stations at locations that were unrelated to NPDES dischargers, i.e.,
streams that were previously unmonitored with no NPDES discharges, some of the specific upstream —duvvnutream
stations were left out of the sampling plan. This concept was applied to the other basinvvide monitoring coalitions
across the state.
OEQ-CFVV_00048561

This approach provides significant benefits to both association members and N[DE{l For association members, we are
assured that the data collected is accurate and represents actual conditions in the water body. We feel confident that if
a problem is identified, itisa real problem and not data quality orlocation anomaly. For N[DEQ,the station and
parametric coverage is broader and includes both point and non -point impacts. This supplements N[DECys ambient
monitoring program and provides significantly more data for the 303d/305b water quality assessments. Additionally,
the data is provided to the agency in a monthly summary spreadsheet rather than being reported on each individual
hard copy DMR. This allows quicker review ofthe data and better facilitates making the data available to NCDE(lstaff
and the public through STORET. M[F8A, in cooperation with the Upper and Lower monitoring coalitions, maintains all
of their data in a database that is accessible to any interested party via the internet through UNC-Wilmington.
In order to ensure the continued success of the basinwide monitoring coalitions, the MCFBA requests that rather than
requiring individual permittees to monitor for hardness and potentially other parameters as part of their permit, that
NCDEQ work with us to supplement data collection through the coalition monitoring program.
For example, | have attached atable that shows all ofthe upstream sample locations for the MCF8Amembers. You will
note that most of the discharges have an upstream sample station that is already being sampled. Atthese locations
adding quarterly hardness tothe parametric coverage is not big deal because our contractor isalready inthe field and
would simply add another parameter tothe existing monitoring program. However, there are three discharges that
currently have no M[FBAupstream sampling station. Those discharges are Carolina Trace, Town of Broadway, and Holly
Springs. Requiring our contractor to pick up one parameter at three new stations on a quarterly basis might not bethe
most cost effective solution. Alternatives might include limiting data collection at these stations to quarterly during the
same year that N[DE{ldoes their data collection for basin planning purposes or, perhaps the downstream location
hardness could be used tocalculate potential metals limits.
Another example isthe Town ofSpring Lake. M[F8Aused tohave asample station upstream ofthe Spring Lake VVVVTP
atHVVY87South atManchester Road (B728UUO). But atNCDE[ysrequest, xveadded station 873OODOOand stopped
monitoring B7280000 since B7280000 is a NCDEQ ambient monitoring station. Since NCDE{lisalready collecting
ambient data at the Spring Lake upstream site perhaps NCDEQ could add hardness at that station rather than requiring
Spring Lake or the MCFBA to do so.
In summary, MCFBA is requesting that NCDEQ:s Water Science Section and the NCDEQ Permitting Section coordinate
with ustofind the most cost effective solution that meets everyone's needs rather than inserting permit specific
upstream—dovvnutream monitoring requirements in individual NPDES permits.
Thank you for your consideration in this matter.
VV/REnWronmenta| Programs Manager
Fayetteville Public Works Commission
POBox lO89
Fayetteville, NC 28302
910'223'4702
910-797-4203 (mobile)
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DEQ-CFW-00048563