NC0006564_Comments_20220228 (2)

CATAWBA
RIVERKEEPEW
February 28, 2022
NCDEQ/DWR/NPDES
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Julia Byrd,
The Catawba Riverkeeper Foundation is a member -funded environmental nonprofit that educates and
advocates forthe protection of the Catawba-Wateree River and all its tributaries. Our organization
represents over 6,000 active members who rely on the watershed for drinking water, recreation, and
electricity. The North Fork of the Catawba River is a majortributary to Lake James and is a designated
Class B trout water. We appreciate the opportunity to comment on the Baxter Healthcare Corporation's
NPDES permit (NC00006564) and make the following recommendations:
• Monitor and limit turbidity
The facility discharges into a designated trout water. Facility discharge should be monitored
to ensure stream turbidity does not exceed 10 NTUs.
• Place limits on discharge temperature
The facility discharges into a designated trout water. The draft permit does not include a
temperature limit despite the published fact sheet showing a0.67°C average increase and a
max downstream temp of 24.3°C. This appears to violate 15A NCAC 02B .0211(18) "...the
temperature for trout waters shall not be increased by more than 0.5 degrees C (0.9 degrees
F) due to the discharge of heated liquids, but in no case to exceed 20 degrees C (68 degrees
F.
• Monitor E. coli in addition to fecal coliform
The facility discharges into a designated Class B water. For the last 36 years, the EPA has
recommended using E. coli instead of fecal coliform as an indicator for pathogens. Last year
DWR finally proposed updatingthe standard and the Environmental Management
Commission is expected to vote on it in March. North Fork users should not have to wait
another 5 years fora more accurate measure of fecal contamination.
• Increased monitoring and reporting frequency of Total Nitrogen, Total Phosphorus, and
Hardness.
Data Collected by the Lake James Environmental Association (UEA) and a 2018 DWR
Catawba Nutrient Study indicates that the North Fork is a major contributor of nutrients into
Lake James. The 2017 DWR Lake James Survey and Dr. Mark Brennerof Warren Wilson
A WATERKEEPER ALLIANCE° Member
115 Willow Drive McAdenville NC 28211
Phone: [phone] Fax: [phone]
www.catawbariverkeeper.org

College have reported elevated densities of phytoplankton atthe lake'swestern end. An
increase in the monitoringfrequencywill allow a more accurate quantification of the
facility's contribution, if any. While the permitfact sheet lists a current and proposed
frequency ofl/month, the published draft permit decreases the requirement to quarterly
monitoring.
For the River,
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BrandonJones
Catawba Riverkeeper
A WATERKEEPER ALLIANCE° Member
115 Willow Drive McAdenville NC 28211
Phone: [phone] Fax: [phone]
www.catawbariverkeeper.org