NC0081949_Tuckertown_Powerhouse.pdf

DocuSign Envelope ID: 457C8002-D95F-434D-8BB6-E8B40DE13C8B
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
March 8, 2023
Mr. Paul Tran, South East Regional Manager
Cube Yadkin Generation LLC
P.O. Box 575
Badin, North Carolina 28009
Subject: NCO081949
Tuckertown Powerhouse
E. coli Study
Dear Mr. Tran,
The North Carolina Department of Environmental Quality (NCDEQ) is committed to proposing
a statewide Escherichia coli (E. coli) standard for primary recreation (Class B) freshwaters.
Shifting to a statewide E. coli standard requires additional monitoring across the state. This
monitoring is to be conducted in Class B waters by NCDEQ as well as by NPDES dischargers to
Class B waters that are potentially affected by the proposed standard.
Background
The EPA 2012 Recreational Water Quality Criteria for Bacterial Indicators of Fecal
Contamination' (EPA 20-F-12-058; 2012) recommends states set bacteriological water
quality standards for primary recreation freshwaters using either the Escherichia coli or
Enterococcus pathogenic indicators. North Carolina's current recreational surface water
quality standards for Class B (primary recreation) waters use the fecal coliform bacteria group
pathogenic indicator.
Additional monitoring will provide information necessary to allow NCDEQ to evaluate the
financial impacts of switching to an E. coli standard for all Class B freshwaters and this data
will inform the Regulatory Fiscal Note a required part of the rulemaking package. In addition,
further monitoring will allow NCDEQ to evaluate the scientific implications to existing Total
Maximum Daily Loads (TMDLs) that address current fecal coliform impairments.
Required Actions for Collection, Transport and Analysis of Samples under this Study
Facilities permitted under the National Pollution Discharge Elimination System (NPDES) which
employ processes associated with the discharge of bacteria into or slightly upstream of Class B
waters are hereby required to perform investigative monitoring. The authority for such
investigative actions can be found in 15A NCAC 02B .0508 (b)(2) and G.S. 143-215.66.
Sites to be monitored consist of the facility effluent, one site upstream of the facility and one site
downstream of the facility, and facility staff are responsible for sampling these sites and
transporting the samples to a laboratory. Upstream and downstream sampling locations should
reflect those identified in the facility's NPDES permit. Should the NPDES permit include
'Available online at https:llwww.0a. ovlwgclrecreational-water-quality-criteria-and-methods

DocuSign Envelope ID: 457C8002-D95F-434D-8BB6-E8B40DE13C8B
multiple upstream or downstream sampling locations, the upstream and downstream locations
nearest the wastewater treatment plant and its discharge point should be used. Each site will be
sampled for fecal coliform (Method SM 9222 D-2015 or SM 9221 E-2014 or IDEXX Colilert®-
18), E. coli (Method IDEXX Colilert® or IDEXX Colilert®-18), and turbidity (Method SM-
2130 B-2011) and be accompanied by a routine probe reading for temperature, dissolved oxygen
(DO), standard conductivity, and pH. Each instream sampling event shall also be accompanied
by a concurrent precipitation recording. If standard conductivity cannot be measured via probe at
any site, standard conductivity is to be measured in the laboratory (Method SM 2510 B-2011).
Five samples shall be taken at each sampling site during each month within the swim season of
April, May, June, July and August 2023, representing a variety of climatic conditions including
before and after rainfall events. For each sampling site, individual samples must be collected at
intervals greater than 12 hours.
Due to the nature of the study's sample analyses, samples must be analyzed by a laboratory
that is certified to perform those analyses within six hours of the time of collection for these
sites. Samples collected as part of this study will be delivered to a laboratory to allow for
sufficient receipt and set-up time to accommodate this six -hour time limit.
The laboratory to be utilized shall hold a current certification from the North Carolina
Wastewater/Groundwater Laboratory Certification Program to perform the requested method. It
is expected that analyses will be performed within method holding times, meet method quality
assurance requirements, and include sample dilution, if necessary, to achieve results within the
specified range of the method. Final results shall be reported without qualification. Results
should be submitted via electronic data deliverables (EDD) in the NCDEQ format (information
available at hgps://earthsoft.com/products/edp/ncdeq-edp-format/).
More Information
Attachment A identifies a list of labs that have been pre -approved as capable of conducting the
required analyses.
NCDEQ looks forward to working closely with you on this important public health issue. In
addition, NCDEQ plans to engage with stakeholders to communicate estimated timelines for
the evaluation and rulemaking process associated with the adoption of a statewide E. coli
standard for all Class B freshwaters, and this communication will include sharing any fecal
coliform and E. coli comparison data obtained as part of the above -mentioned monitoring.
Please contact either of the following DWR staff if you have any questions or concerns:
Nick Coco at 919-707-3609 or Elizabeth Kountis at 919-707-3685 or via email at
([e-mail]).
�foiljyed
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for C464531431644FE...
Richard Rogers, Director
Division of Water Resources, NCDEQ
cc: Michael Montebello, NPDES

DocuSign Envelope ID: 457C8002-D95F-434D-8BB6-E8B40DE13C8B
Attachment A
Labs approved by NCDEQ-DWR for E. Coli Analysis:
Microbac Laboratories, Inc.
K & W Laboratories
2592 Hope Mills Road
1121 Hwy. 24/27 W
Fayetteville, NC 28306
Midland, NC 28107
[phone]
[phone]
Environmental Chemists, Inc. (EnviroChem)
Environmental Chemists Inc./Outer Banks Div.
6602 Windmill Way
710 Bowsertown Road
Wilmington, NC 28405
Manteo, NC 27954
[phone]
[phone]
Cherokee WWTP Laboratory
Pace Analytical Services LLC - Eden NC
2000 Old #4 Road
205 East Meadow Road - Suite A
Cherokee, NC 28719
Eden, NC 27288
[phone]
[phone]
Charlotte Water- Environmental Laboratory Services
Pace Analytical Services LLC - West Columbia
4222 Westmont Drive
106 Vantage Point Dr.
Charlotte, NC 28217
West Columbia, SC 29172
[phone]
[phone]
Waypoint Analytical — Charlotte
Rogers & Callcott Engineers Inc.
449 Springbrook Road
426 Fairforest Way
Charlotte, NC 28217
Greenville, SC 29607
[phone]
[phone]
Should any Permittee choose to seek laboratory certification for E. coli analysis, please contact
Todd Crawford at 919-733-3908 ext. 202 or via email at [e-mail].
North Carolina Department of Environmental Quality Division of Water Resources
D E Q�� 512 North Salisbury Street 1611 Mail Service Center Raleigh, North Carolina 27699-
Noanicaaourv� —
1611
Ow., Mm�ffl—Mrawiror 919.707.9000