NC0089109_FishTissue_20200505

ROY COOPER
Governor
MICHAELS.REGAN
Secretary
LINDA CULPEPPER
Director
May 5th, 2020
Timothy Basilone
3000 GSK Drive
Suite 201
Moon Township, PA 15108
NORTH CAROLINA
Environmental Quality
Subject: Review of 2020 AZR Fish Tissue Monitoring Plan (NC0080109)
Dear Mr. Basilone:
Thank you for your submission of the revised Fish Tissue Monitoring Plan for NPDES Permit
NC0080109. Based on our review of the plan, we offer the following comments, suggestions,
and requests:
• In the monitoring report, please report fish total lengths (LT) in millimeters (mm) instead
of cm as stated in the monitoring plan.
With regard to which species should have skin removed during fish fillet processing, NC
DWR follows USEPA Guidance for Assessing Chemical Contaminant Data for Use in
Fish Advisories that states "Fish without scales (e.g., catfish) should be skinned prior to
filleting". This guidance is also followed by all NPDES facilities in NC that are required to
conduct fish tissue trace element analysis. Therefore, please do not have scaled fish
such as suckers and carp skinned during processing, just catfish (including bullhead).
If you accept the aforementioned provisions, you need not submit a revised plan.
If you have any questions regarding these comments or requests, please do not hesitate to
contact me.
Si ce1
Cyndi Karoly
Chief, Water Sciences Section
Cc: Landon Davidson, Asheville Regional Office
Julie Grzyb, Complex Permitting Unit
Kennedy Holt, NC DHHS
D_E QJ� 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
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