NC0089109_Monitoring (Information)_20191223

ROY COOPER
Governor
MICHAELS.REGAN
Secretary
LINDA CULPEPPER
Director
December 2011, 2019
Timothy Basilone
3000 GSK Drive
Suite 201
Moon Township, PA 15108
NORTH CAROLINA
Environmental Quality
Subject: Review of AZR Fish Tissue Monitoring Plan (NC0080109).
Dear Mr. Basilone:
Thank you for your submission of the Fish Tissue Monitoring Plan for NPDES Permit
NC0080109. Based on our review of the plan, we offer the following comments, suggestions,
and requests:
• As stated in the permit, fish tissue monitoring of arsenic (As), cadmium (Cd), and zinc
(Zn) must be performed once during the 5-year AZR NPDES permit cycle. For clarity
please include these terms in the beginning of the AZR fish tissue monitoring plan, as
well as in the final report.
• Please omit the last two paragraphs on page 2 through page 4 (including Figure 1 and
Table 1). The referenced 2019 NCDWR fish tissue monitoring activities were conducted
via internal agency request, and not specifically intended to serve as a model for NPDES
fish tissue contaminant monitoring of the Broad River. However, it would be reasonable
to list those species collected by DWR in 2019, and to specify which of those species
are being targeted for the required ARZ fish tissue monitoring.
• The plan should outline AZR's proposal to compare arsenic (As), cadmium (Cd), and
zinc (Zn) fish fillet concentrations from two separate locations in the vicinity of the AZR
waste water discharge (upstream control, and downstream). Site boundaries should be
separated by a reasonable distance (_> 1 mile) to characterize the potential impact of
AZR's waste water discharge on As, Cd, and Zn concentrations in fish. All of the current
NPDES fish tissue monitoring plans in the state of North Carolina share this paradigm of
upstream -downstream comparisons for the purpose of determining a facility's potential
impact on fish contaminant levels.
• The boundaries of the proposed downstream fish collection reach are reasonable and
therefore will be accepted as is.
• We suggest placement of the upstream sample reach (control) to be above the Jack -
McKinney Road bridge (approximately 3 river miles above the AZR waste water
�DF North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1634 Mail Service Center I Raleigh, North Carolina 27699-1634
919.707.9000

discharge), to create considerable distance between the two reaches and provide similar
habitat types and species assemblages for contaminant comparisons.
The plan should outline an attempt to collect 10 individuals of 3 targeted species from
both sample reaches (total of 30 fish from each sample reach), with a minimum of 6
individuals per species meeting the permit requirement (total of 18 fish from each
sample reach).
Based on the NCDWR's 2019 fish collections, the most likely target species in this
section of the Broad River include Largemouth Bass (top predator), Redbreast Sunfish
(mid-trophic insectivore), and Notchlip Redhorse (mid-trophic omnivore). Other suitable
species of bass, sunfish, suckers, catfish, or carp should also be retained during
collection efforts. These fish samples may be submitted for analysis if target species are
absent or low in numbers, or as supplemental observations.
In the final monitoring report, please provide data comparisons to fish consumption
screening levels set by the North Carolina Department of Health and Human Services
(NCDHHS) and the United States Environmental Protection Agency (USEPA).
If you have any questions regarding these comments or requests, please do not hesitate to
contact me.
Sincerely,
Cyndi Karoly
Chief, Water Sciences Section
Cc: Landon Davidson, Asheville Regional Office
Julie Grzyb, Complex Permitting Unit
Kennedy Holt, NC DHHS