Loading...
HomeMy WebLinkAboutNC0003298_Monitoring Information_20180104 ri (.7 0 PY INTERNATIONAL S PAPER RIEGELWOOD MILL JOHN L.RIEGEL ROAD RIEGELWOOD,NC 28456 January 4, 2018 Certified Mail: 7017 2620 0000 2411 5989 RECEIVED/DENR/DWR Ms. Cyndi Karoly JAN 08 2019 Chief, Water Sciences Section Water Resources NC DEQ Division of Water Quality Permitting Section 1621 Mail Service Center Raleigh, NC 27699-1621 SUBJECT: Dioxin Monitoring Study of Fish Tissue from the Cape Fear River in the Vicinity of the International Paper Company Mill at Riegelwood,NC—2018 Report NPDES Permit No.NC0003298 Dear Ms. Karoly: As you are aware,International Paper's(IP)Riegelwood,NC mill is required under NPDES Permit NC0003298 to conduct annual fish tissue collection and analysis for the isomers of dioxin and furan per the NC DEQ approved sampling plan referenced in the permit. To meet this requirement, IP has hired CZR Inc. (CZR)to conduct this sampling for the past 25 years. During this time, CZR has been successful each year in obtaining the requisite sample volumes and composites for the desired fish species. As in previous years, CZR had scheduled the fishing trips to begin in the fall of 2018.More specifically, CZR had initially scheduled to fish from September 17-20, 2018. On Friday, September 14,2018, Hurricane Florence made landfall near Wrightsville Beach,NC. The rainfall from this hurricane produced record setting precipitation. Mill records of the event as read from our rainfall gauge indicated that approximately 23 inches of rain fell on the mill site over a 5-day period after the hurricane landfall. Additionally, prior to this event,rainfall was just below 45 inches at the mill site and has reached approximately 83 inches for 2018. For comparison, normal rainfall is around 50 inches for a year for the mill location, based on the National Weather Service Advanced Hydrologic Prediction Service. On September 28,2018, CZR notified IP that unfavorable river levels and flows caused by the record rainfalls had prevented CZR from making the scheduled fishing trips in September. The plan was to reschedule for mid-October in hopes that the river level would lower. Subsequently,on October 17, 2018, CZR notified IP that river conditions had not improved and that fishing in these conditions was ill-advised. CZR would continue to monitor the situation and look for a window that would allow for fishing trips to be attempted. CZR also noted discussions with Frank Yelverton of the Cape Fear River Watch and Dr. Fred Scharf with UNC-Wilmington, who both indicated that the fish population of the Cape Fear River had suffered greatly during the severe flooding that resulted in depressed dissolved oxygen(DO)concentrations and contributed to high fish mortality. S:1Groups\EnvironmentallWastewaterlFish Tissue120181Annual Fish Tissue Dioxin Report.docx December 21, 2018 Page 2 of 2 On October 17, 2018, IP contacted Tom Tharrington in the NCDEQ Wilmington Regional Office in Wilmington,and Mr. Tharrington indicated that the Regional Office may support concessions regarding the sample gathering event. On October 18 and October 26, 2018,IP notified NC DEQ via email of the developing situation.On October 29,2018, IP received a call from Jeff Deberardinis(NC DEQ) inquiring about the situation. Mr. Deberardinis sent a follow-up email recounting our conversation and stressed NC DEQ's commitment to the safety of all concerned when attempting to obtain fish tissue for analysis in light of the current river conditions. IP submitted updates to Mr. Deberardinis via email as new information came available. Copies of the email communiques are included as an attachment to this letter. IP contacted Mr. Deberardinis on December 19 relaying information from CZR that river levels had not improved over the course of months and additional heavy rains had resulted in worsening conditions along the Cape Fear River. Additionally, CZR noted that fishing would not be feasible before the end of 2018. In order to fulfill the NPDES permit reporting requirement and Mr. Deberardinis' request for details outlining efforts made to fulfill those requirements, CZR drafted a memo describing fishing efforts and attempts. CZR's memo is also included as an attachment to this letter. The conclusion of the CZR memo states,"Despite plans/efforts to collect and coordinate collections with other area fisheries biologists after Hurricane Florence,conditions did not allow fish collections in 2018." If river conditions had improved after the hurricane, the fishing expeditions would have been undertaken as normal. It is IP's position that this event constitutes a Force Majeure and our inability to meet the fish tissue collection requirement should not result in a permit violation. IP requests that NC DEQ exercise discretion when determining how to proceed with this matter. If you have questions or need additional information,please contact Kevin Burk(910.362.3476)or Kim Fail (910.362.4753)at your convenience. Sincerely, lee/AA/I/kr Gary Morrow Environmental, Health, Safety& Sustainability Manager Enclosure cc: Morella King, Regional Operations Supervisor NC DEQ—Wilmington Regional Office 127 Cardinal Drive Extension Wilmington,NC 28405 Julie Grzyb,NPDES Complex Permitting Supervisor NC DEQ Division of Water Quality 1617 Mail Service Center Raleigh,NC 27699-1617 kcb S:IGroupslEnvironmentallWastewaterlFish Tissue120181Annual Fish Tissue Dioxin Report.docx December 21, 2018 Page 2 of 2 Beth Dittman NC DHHS,Division of Public Health 1931 Mail Service Center Raleigh,NC 27699-1931 Tom Tharrington NC DEQ—Wilmington Regional Office 127 Cardinal Drive Extension Wilmington,NC 28405 kcb S:IGroupslEnvironmentallWastewaterlFish Tissue120i81Annual Fish Tissue Dioxin Report.docx „,,,,::, ,,, „, ,..,, ,,,,c z R .,_ 4709 COLLEGE ACRES DRIVE SUITE 2 INCORPORATED WILMINGTON, NORTH CAROLINA 28403-1725 ENVIRONMENTAL CONSULTANTS TEL 910-392-9253 FAX 910-392-9139 czrwilrn@czr-inc.com MEMORANDUM To: Mr. Kevin Burk, International Paper—Riegelwood Mill, North Carolina lc From: Sam Cooper and Randy Pulley, CZR Incorporated t, '.1-' Date: 20 December 2018 RE: Summary of circumstances resulting in unsuitable conditions for fall 2018 fish collections. Background • NPDES permit (#0003298)for the International Paper(IP) Riegelwood, NC mill requires collection and analysis of fish tissue for the presence of dioxins and furans. The results of the dioxin monitoring program are submitted to the North Carolina Division of Water Resources(NCDWR)within the Department of Environmental Quality, formerly the North Carolina Division of Water Quality within the Department of Environment and Natural Resources. • CZR Incorporated, an environmental consulting firm, has been contracted annually by IP to conduct the monitoring and prepare reports since 1993. Over the course of the last 25 years of collections CZR has successfully acquired samples each year for IP. Over the past ten years CZR has averaged over 125 fish caught per season and submitted the required 12 composite samples (four composites from each of three collection sites). • EPA indicates the most desirable collection period as late summer to early fall (i.e.,August to October) because the lipid content is generally highest at this time and this is normally the period when water levels are lower,which simplifies collection procedures(EPA, 2000). Collections have not been conducted in the spring and early summer to avoid the peak of spawning season for many species and reduce the potential catch of non-target migratory fish, including protected species(e.g., sturgeon). • Conditions most favorable for fish collections generally include: low water levels (gage height and discharge are near or below median daily values) and moderate temperatures(which avoid higher temperatures in the summer with low dissolved oxygen and cooler temperatures of less than 50-55 degrees Fahrenheit when fish are less active and less likely to be caught). Weather and River Conditions during 2018 Southeast North Carolina received an unprecedented amount of rainfall in 2018, particularly in the Wilmington area. Nearly half(23.02”) of Wilmington's average annual rainfall (57.61")fell during four days in September from Hurricane Florence. Although the sampling sites are upstream of Wilmington, Lock and Dam#1 and most of the Cape Fear drainage basin received over 20 inches of rain above normal(year to date total as of 20 December 2018). Rainfall for the year was above normal even prior to the hurricane 2151 Alternate AlA South • SUITE 2000 • JUPITER, FLORIDA 33477-3902 TEL 561-747-7455 • FAX 561-747-7576 • czrinc@czr-inc.com • www.CZRINC.com 20 December 2018 Page 2 of 3 season and weather patterns from non-tropical systems brought well-above normal rainfall amounts in January, May,June,July,and November. Cape Fear River levels have been very high throughout the drainage basin due to the record rainfall. Based on data collected and reported by USGS as part of the National Water Information System (https://waterdata.usgs.gov/nc/nwis/rt),the region's streamflow conditions have been well above median gage height(feet)and discharge (cubic feet per second)for most of the fall(August through December). Other than a few hours on 12 October 2018,the gage height at Lock and Dam#1 has been above 17 feet since Hurricane Florence in September. The historical daily median gage height for September for this location is approximately 15 feet. Lock and Dann#1 is located below the control collection site and above. the two downstream collection locations and CZR uses this USGS monitoring site because it provides the most accurate data to reflect river conditions at the collection sites. Efforts to Collect Fish in 2018 Although historical median Cape Fear River gage heights at Lock and Dam#1 are between 15-16 feet, actual gage heights were above 17 feet for most of August 2018;therefore,CZR scheduled fish collections to begin 17-20 September 2018, hopeful that river levels and discharge would subside enough by mid- September to allow collections. Hurricane Florence's landfall near Wrightsville Beach on 14 September disrupted that plan and produced unsuitable conditions for fishing. CZR rescheduled the collections throughout the course of the fall (15-19 October,the weeks before,during, and after Thanksgiving), but the unsuitable high river levels and discharge continued for the remainder of the year. Other fisheries biologists in the region were also unable to sample or collect fish from the IP collection areas. CZR contacted the North Carolina Division of Wildlife Resource Commission (NCWRC)after Hurricane Florence to coordinate efforts with the Fisheries Biologist (Kyle Rachels) responsible for District 4, which includes the IP locations. Mr. Rachels planned to sample the Cape Fear after Hurricane Florence to assess the fish population, but was also unable to sample due to unsuitable fishing conditions. Mr. Rachels agreed to collect from locations to overlap the IP sites in an effort to help collect fish for laboratory analysis. Mr. Rachels indicated the NCWRC shocking boat was more successful in waters with less than 7,000(preferably less than 5,000)cubic feet per second (cfs)flow and when water temperatures were above mid/lower 50s F. CZR and NCWRC planned to combine fishing efforts but suitable river and fish collection conditions did not occur for the remainder of the year. Flow for most of August through November was above 7,000 cfs and the median values for this same timeframe is primarily less than 2,000 cfs. Flow has remained above 10,000 cfs through December to date and the median for this period is near 3,000 cfs. Swift currents and debris carried by flood waters resulted in unsafe fishing conditions and made fish collection methods ineffective or impossible to implement. Effects from Hurricane Florence Above average rainfall and extensive flooding from Hurricane Florence resulted in excessive organic and inorganic debris in rivers throughout NC during the fall of 2018. The excessive organic debris resulted in very low oxygen levels which was responsible for substantial fish kills in the Cape Fear drainage basin. Photographs of many large dead fish covering portions of parking lots at Lock&Dam#1,the parking lot at the Battleship North Carolina, and along Interstate 40 were posted in a variety of public media outlets and in a NCWRC announcement(NCWRC 4 Oct 2018 link provided below). 20 December 2018 Page 3 of 3 CZR also discussed with Mr. Frank Yelverton (fisheries biologist formerly with the Corps of Engineers and current Director of the Cape Fear River Watch) who indicated that fish populations may be reduced or slow to recover over the fall/winter even after dissolved oxygen levels return to normal. Dr. Fred Scharf with UNCW attempted fish collections in the NE Cape Fear River in early October(further downstream and in a river source different than the Cape Fear) and did not catch any catfish in areas where the species is normally abundant. Even if river conditions had allowed fishing, it is likely that catches would have been greatly reduced because of the effects of Hurricane Florence on the local fish populations. In addition to the low oxygen levels, the high flow/discharge resulted in: - Reduced access due to damage to boat ramps (ramp at Lock and Dam#1 was impassable for weeks and CZR visited on 5 November for confirmation of site conditions at both ramps used for fishing). - Swift currents which prevented setting of passive gear(nets and trot lines)and carried large debris - Periods of unsafe conditions for launching/boating/fishing. - High conductivities in the water which impair or prevent electrofishing success. Coordination/Notification of Collection Difficulties CZR monitored the river for suitable fishing conditions and updated IP throughout the fish collection season. Over the course of the past 25 years the area has experienced many hurricanes and post-hurricane conditions and CZR was able to fish and collect composites to fulfill permit conditions. On 18 October 2018 IP notified NCDEQ staff via email on the status of unsuitable fish collection conditions. IP spoke with Mr. Jeff Deberardinis with NCDEQ via phone conversation on 29 October 2018 about the situation. Subsequent email updates were provided to Mr. Deberardinis explaining the continued difficulties. Despite plans/efforts to collect and coordinate collections with other area fisheries biologists after Hurricane Florence, conditions did not allow fish collections in 2018. Sources EPA, 2000. Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories. Volume 1, Fish Sampling and Analysis,Third Edition. EPA 823-B-00-007 November 2000. NOAA Rainfall Summary info (observed, normal, departure from normal, percent of normal): https://water.weather.gov/precip/ USGS river level data for NC and Lock and Dam#1 (Site 02105769): https://waterdata.usgs.gov/nc/nwis/rt https://waterdata.usgs.gov/nc/nwis/uv?site no=02105769 Hurricane Florence NOAA summary for Southeast NC: https://www.weather.gov/ilm/HurricaneFlorence NCWRC info on fish kill due to Hurricane Florence: https://www.ncwildlife.org/News/wildlife-commission-biologists-investigate-widespread-fish-kills-after- hurricane-florence Charlotte Observer news info on fish kill near Burgaw due to Hurricane Florence: https://www.charlotteobserver.com/news/local/article219556240.html Kevin Burk From: Deberardinis, Jeff <jeff.deberardinis@ncdenr.gov> Sent: Wednesday, December 19, 2018 4:48 PM To: Kevin Burk Subject: [External] : RE: [External] Cape Fear River Fishing Thanks for the update Kevin. Happy Holidays! From: Kevin Burk<Kevin.Burk@ipaper.com> Sent:Wednesday, December 19, 2018 4:08 PM To: Deberardinis,Jeff<jeff.deberardinis@ncdenr.gov> Subject: RE: [External] Cape Fear River Fishing CAUTION: Report Steam. Jeff, as a final update...I just got a memo from CZR that I am reading through. It essentially says that river conditions have not and will not allow for fish collection this year. I'll send you a detailed explanation of efforts once I have it pulled together. Thanks and let me know if you have any questions. INTERNATIONALS PAPER Kevin Burk Sr. Environmental Engineer IP-Riegelwood 865 John L. Riegel Rd, Riegelwood, NC 28456 Office: 910.362.3476 Cell: 910.398.3140 From: Deberardinis,Jeff<jeff.deberardinis@ncdenr.Rov> Sent: Friday, November 09, 2018 2:29 PM To: Kevin Burk<Kevin.Burk@ipaper.com> Subject: [External] : RE: [External] Cape Fear River Fishing 1 Kevin, I appreciate the update. Best of luck to the sampling crews, I hope they find some success. Thanks, and have a good weekend! Jeff From: Kevin Burk<Kevin.Burk@ipaper.com> Sent: Friday, November 09, 2018 1:48 PM To: Deberardinis,Jeff<jeff.deberardinis@ncdenr.gov> Subject: [External] Cape Fear River Fishing CAUTION: Report Spam. Jeff, I wanted to update you on our fishing attempts. Looks like CZR will attempt a fishing expedition (possibly teaming up with NCWRC) the weeks of 11/12 (before Thanksgiving) and 11/26 (after Thanksgiving). Let me know if you have any questions or concerns and have a good weekend. Thanks, INTERNATIONALE&PAPER Kevin Burk Sr. Environmental Engineer I P-Riegelwood 865 John L. Riegel Rd, Riegelwood, NC 28456 Office: 910.362.3476_ Cell: 910.398.3140 From:Sam Cooper<scooper@czr-inc.com> Sent:Thursday, November 01, 2018 5:23 PM To: Kevin Burk<Kevin.Burk@ipaper.com> Cc: Kimberly Fail<Kimberly.Fail@ipaper.com>; Gary W Morrow<Gary.Morrow@ipaper.com>;Julia Berger<iberger@czr-inc.com> Subject: [External] : RE: [External] RE: Cape Fear River Fishing Hello Kevin, Just a follow-up to my phone call to you from earlier today. I have talked with a couple of NCWRC staff who sample fish, and NCWRC is going to try to sample in November to evaluate the effects of the storm and recent fish kills. Kyle Rachels is the NCWRC fisheries biologist for the area we sample for IP and he is waiting for conditions to improve before trying to sample the Cape Fear River. He did not anticipate suitable conditions next week. We have discussed trying to 2 combine our efforts and he said he would be glad to try some of our sampling sites. If conditions improve we will try the week before Thanksgiving and if conditions are not favorable that week, we may try the week after Thanksgiving. —Sam Samuel Cooper CZR Incorporated 4709 College Acres Drive, Suite #2 Wilmington, NC 28403 910 392-9253 - office 910 392-9139 - fax ENVIRONMENTAL CONSULTANTS From:Sam Cooper [mailto:scooper@czr-inc.com] Sent: Wednesday, October 31, 2018 11:04 AM To: 'Kevin Burk' <Kevin.Burk@ipaper.com> Cc: 'Kimberly Fail' <Kimberly.Fail@ipaper.com>; 'Gary W Morrow' <Gary.Morrow@ipaper.com>;Julia Berger<jberger@czr-inc.com> Subject: RE: [External] RE: Cape Fear River Fishing Hello Kevin and all, Thank you for the update. We will continue to watch the river levels and weather for an opportunity to fish. It is best to have a series of days with lower river levels along with favorable weather. We will let you know when we plan to fish. Current river height and discharge are still very high (discharge today is over 4.5 times above the mean and would like that parameter to be much closer to at the 75th percentile).—Sam Samuel Cooper CZR Incorporated 4709 College Acres Drive, Suite #2 Wilmington, NC 28403 910 392-9253 - office 910 392-9139 - fax 3 ENVIRONMENTAL CONSULTANTS Daily discharge, cubic feet per second -- statistics for Oct 31 based on 37 years of recordc„2rr 25th ,t 75th Most Recent Min •percen percen- Instantaneous Max (2012),` tile ! Median Mean tile Value Oct 31 (1991) • 555 1100 11 1560 12810 ( 3020 i12700 r18300 Gage height, feet Most recent instantaneous value: 19.43 10-31-2018 09:45 EDT USGS 02105769 CRPE FERR R AT LOCK 111 MR KELLY, MC 20.00 19.50 - —..._ 19.88 • 18.58 i8.e8 17,50 17.88 Oct Oct Oct Oct Oct OCt Oct Oct 24 25 26 27 28 29 30 31 2010 2818 2818 2018 2818 2G18 2810 2010 4 From: Kevin Burk [mailto:Kevin.Burk@ipaper.com] Sent:Tuesday, October 30, 2018 8:21 AM • To: scooper@czr-inc.com Cc: Kimberly Fail <Kimberly.Fail@ipaper.com>; Gary W Morrow<Gary.Morrow@ipaper.com> Subject: FW: [External] RE: Cape Fear River Fishing Sam, I got a reply from Water Sciences regarding our fishing efforts this year. See below the response from Jeff Deberardinis. Please make your best effort the safely obtain whatever fish you can to satisfy the requirement and document the success/failure of those attempts. I was looking at the river levels this morning and Lock and Dam 1 is at about 19.5'. Keep me apprised of your plans and progress. Thanks, INTERNATIONAL®PAPE R Kevin Burk Sr. Environmental Engineer IP-Riegelwood 865 John L. Riegel Rd, Riegelwood, NC 28456 Office: 910.362.3476 Cell: 910.398.3140 From: Deberardinis,Jeff<jeff.deberardinis@ncdenr.gov> Sent: Monday, October 29, 2018 3:05 PM To: Kevin Burk<Kevin.Burk@ipaper.com> Cc: Karoly, Cyndi<cyndi.karoly@ncdenr.gov>; King, Morella s<morella.sanchez-king@ncdenr.gov>; Gregson,Jim<jim.gregson@ncdenr.gov>;Tharrington,Tom <tom.tharrington@ncdenr.gov>; Kimberly Fail<Kimberly.Fail@ipaper.com>; Gary W Morrow<Gary.Morrow@ipaper.com>; Fleek, Eric<eric.fleek@ncdenr.gov> Subject: [External] : RE: [External] RE: Cape Fear River Fishing Hi Kevin, It was good talking to you this morning. We appreciate you reaching out to us about CZR's fish collection difficulties on the Cape Fear River this year following Hurricane Florence. As I said in our conversation, we do understand how difficult it must be right now to find any viable fish to sample for tissues given the severity and extent of hypoxic conditions following the storm. We also understand that persistent high flows continue to hinder any safe sampling progress.This has been an extremely atypical year for sure. With that said, we do appreciate CZR's efforts to continue fish collections when conditions on the river are once again safe and better suited for fishing. Safety and common sense are always paramount when engaging in this type of work. So long as CZR's efforts are well documented in the 2018 report as in past years, I don't foresee any heartburn regarding the anticipated low numbers of collected fish. If at some point suspension of efforts is warranted due to a lack of fish in the river, please notify us of the suspension and provide a justification in the 2018 report. 5 Please let me know if I can be of any further assistance. Thanks, Jeff From: Karoly, Cyndi Sent: Monday, October 29, 2018 8:35 AM To: Deberardinis,Jeff<jeff.deberardinis@ncdenr.gov> Subject: FW: [External] RE: Cape Fear River Fishing Jeff—can you please respond to Mr. Burk? Thank you. Cyndi Karoly Water Sciences Section Chief NC Division of Water Resources NC Department of Environmental Quality 919-743-8416 office Cyndi.Karoly@ncdenr.gov 4401 Reedy Creek Road Raleigh, NC, 27611 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Kevin Burk [mailto:Kevin.Burk@ipaper.com] Sent: Friday, October 26, 2018 2:27 PM To: Karoly, Cyndi<cvndi.karoly@ncdenr.gov>; King, Morella s<morella.sanchez-king@ncdenr.gov>; Gregson,Jim <jim.gregson@ncdenr.gov>;Tharrington,Tom <tom.tharrington@ncdenr.gov> Cc: Kimberly Fail<Kimberly.Fail@ipaper.com>; Gary W Morrow<Gary.Morrow@ipaper.com> Subject: [External] RE: Cape Fear River Fishing CAUTION: Report Spam. 6 I wanted to reach out again on or questions regarding the fishing for this year. The river level is still about 18.5 feet, which makes fishing difficult in the best of circumstances. We'd really appreciate any input you may have on the topic. We are available for a call. Just let us know when. Thanks. INTERNATIONAL /)PAPER Kevin Burk Sr. Environmental Engineer IP-Riegelwood 865 John L. Riegel Rd, Riegelwood, NC 28456 Office: 910.362.3476 Cell: 910.398.3140 From: Kevin Burk Sent:Thursday, October 18, 2018 3:31 PM To: 'cyndi.karoly@ncdenr.gov'<cyndi.karoly@ncdenr.gov>; 'King, Morella s' <morella.sanchez-king(a@ncdenr.gov>; 'Gregson,Jim' <jim.gregson@ncdenr.gov>; 'tom.tharrington@ncdenr.gov'<tom.tharrington@ncdenr.gov> Cc: Kimberly Fail<Kimberly.Fail@ipaper.com>; Gary W Morrow<Gary.Morrow@ipaper.com> Subject: Cape Fear River Fishing All, as you are aware, International Paper's Riegelwood, North Carolina mill is required in the NPDES Permit#0003298 to perform annual fish tissue sampling, to analyze for dioxin and dibenzofuran content and report the results to the Division of Water Quality. To meet this requirement, IP contracts with CZR for the annual sampling event. Yesterday morning we received a communication from our fish tissue sampling contractor, CZR, regarding concerns they have around successfully completing the annual fish tissue sampling along the Cape Fear River. They have expressed concerns that impacts caused by Hurricane Florence experienced in the Cape Fear River Basin have adversely impacted fish populations. As noted below CZR feels that the probability is low that they will be able to obtain all the necessary species at sufficient numbers and sizes. Flooding which washed large amounts of organic material into the Cape Fear depressed DO concentrations in the river. This had an adverse impact on the fish populations considerably reducing their numbers. Included in CZR's email below are links to news articles investigating the situation. Also, a link is included to the DEQ report about water quality concerns related to Hurricane Matthew for consideration. As cooler temperatures approach it becomes less and less likely that representative sampling can be obtained. CZR also indicates that river levels, which are currently at greater than 19 foot at Lock and Dam 1, will further hinder fishing attempts. Typically, the fishing trips are done when levels are around 15 to 17 foot. Yesterday afternoon, we spoke with Tom Tharrington in the Wilmington Regional Office about our concerns. Tom indicated that the Regional Office may support concessions from the Department regarding this sample gathering event and encouraged us to reach out to the Water Sciences Section for guidance. This email is to request that guidance from the Department on how best to proceed. We are open to setting up a call between all interested parties. Please let us know what questions you have. We look forward to working through this potential issue with you. You may reply directly to this email or reach me at the contact information provided below. Thank you. INTERNATIONALS PAPER Kevin Burk Sr. Environmental Engineer IP-Riegelwood 865 John L. Riegel Rd, Riegelwood, NC 28456 Office: 910.362.3476 Cell: 910.398.3140 From:Sam Cooper<scooper@czr-inc.com> Sent: Wednesday, October 17, 2018 12:32 PM To: Kevin Burk<Kevin.Burk@ipaper.com> Cc:Julia Berger<iberger@czr-inc.com> Subject: [External] : Cape Fear River fishing Hello Kevin, As a follow-up to our conversation this morning;we normally fish in September and October when water levels are below 17 feet at Lock& Dam#1. As you area aware rainfall this year has been very high and we had fishing scheduled for the weeks after Florence well prior to the development of Florence. We have currently postponed fishing and are waiting for lower water levels suitable for collection. However,the hurricane resulted in major fish kills in the Cape Fear River and NCWRC predicts conditions and fish population will be affected for weeks. Although DO levels may be returning to near"normal," recovery of fish may take some time. We talked with Frank Yelverton (biologist formerly with Corps of Engineers for 35+years and now director of Cape Fear River Watch) last week and he said the parking lots of both the NC Battleship and Lock&Dam 1 were full of dead fish following the storm. Dr. Fred Scharf with UNCW tried to collect fish in the NE Cape Fear last week and did not catch or see a catfish, in areas normally abundant with catfish. We still may need to fish, or try to fish,to document the effort and fishing success; however,the river level needs to drop some more in order for conditions to become suitable for collections(nets, hook& line, or shocking). It might be prudent for IP to approach the state to make them aware and give them some context of the situation? We remain poised to fish and will continue to monitor the river levels at Lock&Dam#1. We have less experience fishing these sites in November and December. However, after waiting for high waters from Hurricane Mathew to recede, we did fish 4 days in early November 2016 and had success catching some bluegill and catfish. The river level was very high at Lock& Dam after Matthew(27+feet—13 Oct 2016)and dropped to less than 16.5 feet within a month. I don't think there were any substantial fish kills documented in the Cape Fear River from Matthew but they were documented in the Neuse and Pamlico/Tar basins. Link to NCWRC info on fish kill due to Hurricane Florence: https://www.ncwildlife.org/Newslwildlife-commission-biologists-investigate-widespread-fish-kil ls-after-hurricane-florence 8 link to news clip on fish kill near Burgaw due to Hurricane Florence: https://www.charlotteobserver.com/news/local/article219556240.html Good resource on effects of hurricane on water quality: link to WQ report on effects of Hurricane Matthew in 2016: https://files.nc.gov/ncdeq/Water%20Quality/Water Sciences/Effects%20of%20Hurricane%20Matthew%20on%20NC%20Surface%20Water5%20Final.pdf Gage height, feet Most recent instantaneous value: 19.36 10-17-2018 10:45 EDT USGS 02105769 CAPE FEAR R AT LOCK R1 NR KELLY, NC 20.0 .' 19.0 4 18.0 . 17.0 . L o 16.0 co 15.0 14.0 Oct Oct Oct Oct Oct Oct Oct Oct Oct 01 03 05 07 09 11 13 15 17 2018 2018 2018 2018 2018 2018 2018 2018 2018 ---- Provisional Data Subject to Revision ---- Median daily statistic (23 years) Gage height Samuel Cooper CZR Incorporated 4709 College Acres Drive, Suite #2 9 Wilmington, NC 28403 910 392-9253 - office 910 392-9139 - fax CZR ENVIRONMENTAL CONSULTANTS 10 Kevin Burk From: Deberardinis, Jeff <jeff.deberardinis@ncdenr.gov> Sent: Thursday, November 15, 2018 11:28 AM To: Kevin Burk Cc: Kimberly Fail; Gary W Morrow Subject: [External]: RE: [External] : update on CZR - Cape Fear River fishing Thanks for the update Kevin, I've been watching flows as well, pretty amazing the amount of rain we've received this year. Looks like it will be a while before it is safe for crews to get out. Just how it goes I guess. Thanks again for keeping me posted. Have a nice Thanksgiving, Jeff From: Kevin Burk<Kevin.Burk@ipaper.com> Sent:Thursday, November 15, 2018 10:40 AM To: Deberardinis,Jeff<jeff.deberardinis@ncdenr.gov> Cc: Kimberly Fail <Kimberly.Fail@ipaper.com>; Gary W Morrow<Gary.Morrow@ipaper.com> Subject: FW: [External] : update on CZR -Cape Fear River fishing CAUTION: Report Spam. Jeff. see the latest input from CZR on fishing conditions. Please let me know of any concerns or questions you may have. INTERNATIONAL®PAPER Kevin Burk Sr. Environmental Engineer IP-Riegelwood 865 John L. Riegel Rd, Riegelwood, NC 28456 Office: 910.362.3476 Cell: 910.398.3140 From: Sam Cooper<scooper@czr-inc.com> Sent:Thursday, November 15, 2018 10:34 AM 1 To: Kevin Burk<Kevin.Burk@ipaper.com> Cc: Kimberly Fail <Kimberly.Fail@ipaper.com>; Gary W Morrow<Gary.Morrow@ipaper.com>;Julia Berger<jberger@czr-inc.com>; Randy Pulley<rpulley@czr- inc.com> Subject: [External] : update on CZR-Cape Fear River fishing Hello Kevin and all, Conditions are still not good for fishing and starting to look doubtful for Dec (see emails below). We will keep watching and update you again after Thanksgiving. - Sam Samuel Cooper CZR Incorporated 4709 College Acres Drive, Suite #2 Wilmington, NC 28403 910 392-9253 - office 910 392-9139 - fax CZR- ENVIRONMENTAL CONSULTANTS From:Sam Cooper [mailto:scooper@czr-inc.com] Sent:Thursday, November 15, 2018 10:27 AM To: 'Rachels, Kyle T' <kyle.rachels@ncwildlife.org> Cc:Julia Berger<iberger@czr-inc.com>; Randy Pulley<rpulley@czr-inc.com> Subject: RE: [External] CZR-Cape Fear River fishing Kyle, Thanks for your email and input. We've been watching and certainly understand. We too will sample if/when conditions allow. Thanks, and hope you have a nice Thanksgiving week. -Sam Samuel Cooper 2 CZR Incorporated 4709 College Acres Drive, Suite #2 Wilmington, NC 28403 910 392-9253 - office 910 392-9139 - fax CZR I ENVIRONMENTAL CONSULTANTS From: Rachels, Kyle T [mailto:kyle.rachels@ncwildlife.org] Sent:Thursday, November 15, 2018 9:34 AM To:Sam Cooper<scooper@czr-inc.com> Subject: RE: [External] CZR- Cape Fear River fishing Hey Sam, This rain isn't doing us any favors—forecast is for the river to reach minor flood stage this weekend and carry through next week.Jordan Lake is back to 10-ft above the guide curve with additional rain expected; USACOE will likely increase releases towards the end of next week, which could keep river levels high into December. Definitely no chance of sampling next week, and starting to look doubtful the week of the 26th. I'd like to sample when conditions cooperate, but with the water rising and cooling it's starting to look like it may not happen this year unless we get a dry week with 70F air temperatures. Best, Kyle 3 CAPE FEAR RIVER AT LOCK 1 Universal Time(UTC) 14Z 14Z 14Z 14Z 14Z 14Z 14Z 14Z 14Z Nov 12 Nov 13 Nov 14 Nov 15 Nov 16 Nov 17 Nov 18 Nov 19 Nov 20 31 - Latest observed value: 20.85 ft at 8:45 AM I I Record: 30.7' EST 15-Nov-2018 Flood Stage Is 24 ft "" s 30 Ell -- -� -73.4 29 - -68.5 Ma•or._28.G' • :`: i 28 -63.6 27 - 4111111111 = -�r -58.8 26 .'-r. - . 54.0 Ti I- 0 d 25 - 24.4 ft -48.4 24 Minor: 24 0' 42.2 N 23 - -34.4 V 22 Action• 22 0' • 27.1 21 - 20.85fi -20.8 20 - -15.4 19 - -10.9 18 - -7.2 17 4.4 9am gam 9am gam gam gam gam 9am 9am Mon Tue Wed Thu Fri Sat Sun Mon Tue Nov 12 Nov 13 Nov 14 Nov 15 Nov 16 Nov 17 Nov 18 Nov 19 Nov 20 Site Time(EST) Graph Created(9:21AM Nov 15,2018) --+-- Observed --f--Forecast(issu ed 2:48AM Nov 15) I CPFN7(plotting HGIRG) "Gage 0" Datum: -2.9' I 'Observations courtesy of US Geological Survey From: Sam Cooper<scooper@czr-inc.com> Sent:Thursday, November 01, 2018 4:23 PM To: Rachels, Kyle T<kyle.rachels@ncwildlife.org> Cc:Julia Berger<ibereerc czr-inc.com>; Randy Pulley<rpulley@czr-inc.com> Subject: [External] CZR-Cape Fear River fishing CAUTION: Report Spam. Hello Kyle, 4