RoaringRiverFecalTMDL051111

Total Maximum Daily Load for Fecal Coliform
for the Roaring River in North Carolina

[Waterbody ID 12-46]

Final Report
May 2011

Prepared by:
NC Department of Environment and Natural Resources
Division of Water Quality
Planning Section
1617 Mail Service Center
Raleigh, NC 27699-1617
[phone]
Yadkin-Pee Dee River Basin
i

TMDL Summary Sheet

303(d) List Information

State: North Carolina
Counties: Wilkes
Basin: Yadkin- Pee Dee River Basin

Waterbody
Name Description Assessment
Unit (AU): Class 12digit
HU Impairment Miles
Roaring
River
From source
to Yadkin
River
12-46 B 03040101 Fecal
Coliform 5.9

Constituents of Concern: Fecal Coliform Bacteria
Reason for Listing: Standard Violations

Applicable Water Quality Standard for Class B Waters:

• Fecal coliform shall not exceed a geometric mean of 200/100 ml (membrane filter
count) based upon at least five consecutive samples examined during any 30 day
period, nor exceed 400/100 ml in more than 20 percent of the samples examined
during such period.

TMDL Development

Analysis/Modeling:
Load duration curves are based on cumulative frequency distribution of flow conditions in the
watershed. Allowable loads are average loads over the recurrence interval between the 95th
and 10th percent flow exceeded (excludes extreme drought (>95th percentile) and floods (<10th
percentile). Percent reductions are expressed as the average value between existing loads
(typically calculated using an equation to fit a curve through actual water quality violations) and
the allowable load at each percent flow exceeded.

Critical Conditions:
Critical conditions are accounted in the load curve analysis by using an extended period of
stream flow and water quality data, and by examining at what flow (percent flow exceeded) the
existing load violations occur.

ii
Seasonal Variation:
Seasonal variation in hydrology, climatic conditions, and watershed activities are represented
through the use of a continuous flow gage and the use of all readily available water quality data
collected in the watershed.

TMDL Allocation Summary

Pollutants/Watershed Existing
Load WLA LA MOS TMDL
Fecal Coliform (colony forming units (cfu)/day)
Roaring River 3.11E+12 1.058E+10 1.0252E+12 10% 1.0358E+12

Notes:
WLA = Wasteload Allocation, LA = Load Allocation, MOS = Margin of Safety.
1. LA = TMDL – WLA – MOS.
2. TMDL represents the average allowable load between the 95th and 10th percent
recurrence interval.
3. Explicit (10%) margin of safety is considered.
4. Overall reduction is based on the instantaneous standard of 400 cfu/100ml and is
assumed to be more stringent than the geometric mean standard.

Contributing Municipalities: NONE

Contributing NPDES Facilities TMDL Allocation Summary:
NPDES Permittee Existing Permitted
Load (cfu/day) WLA (cfu/day) Percent Reduction
Required
North Wilkes High
School 1.591E+08 1.591E+08 0%
Traphill Elementary
School 6.059E+07 6.059E+07 0%
NC DOT N/A 1.036E+10 0%

Estimated reduction by source for fecal coliform (shown in cfu/day) for the Roaring River:

WLA LA
Existing Load (cfu/day) 1.058E+10 3.103E+12
Allocation (cfu/day) 1.058E+10 1.0252E+12
Percent Reduction Needed 0% 67.1%

Public Notice Date: 3/12/11
Submittal Date: 4/19/2011
EPA Approval Date: 5/11/2011
iii
Table of Contents
1.0 Introduction ............................................................................................................................ 1
1.1 TMDL Definition .............................................................................................................. 1
1.2 TMDL Components ......................................................................................................... 1
1.3 Water Quality Target: North Carolina Standards and Classifications ............................. 2
1.4 Watershed Description ................................................................................................... 3
1.5 Water Quality Monitoring............................................................................................... 8
2.0 Source Assessment ............................................................................................................... 10
2.1 Nonpoint Source Assessment ....................................................................................... 10
2.2 Point Source Assessment .............................................................................................. 10
2.3 NPDES Stormwater Permits .......................................................................................... 11
3.0 Total Maximum Daily Loads and Loads and Load Allocation ............................................... 11
3.1 TMDL Objective ............................................................................................................. 11
3.2 Methodology ................................................................................................................. 12
3.2.1 Flow Duration Curve ................................................................................................. 12
3.2.2 Load Duration Curve ................................................................................................. 13
3.3 Total Maximum Daily Load ........................................................................................... 13
3.4 Margin of Safety (MOS) ................................................................................................ 14
3.5 TMDL Allocation ............................................................................................................ 15
3.5.1 Waste Load Allocation (WLA) ................................................................................... 16
3.5.2 Load Allocation (LA) .................................................................................................. 17
3.5.3 Critical Condition and Seasonal Variation ................................................................ 18
4.0 Summary and Future Consideration ..................................................................................... 18
4.1 Future Efforts ................................................................................................................ 18
5.0 Public Participation ................................................................................................................. 19
6.0 References .............................................................................................................................. 19
Appendix A: TMDL Data ............................................................................................................... 20
Appendix B. DWQ 5-in-30 Study ................................................................................................... 24
Appendix C. NPDES Fecal Coliform Permit Violations ................................................................. 25
Appendix D: Public Notification of TMDL for Fecal Coliform for the Roaring River ..................... 26
Appendix E: Public Comments ...................................................................................................... 28

1
1.0 Introduction

1.1 TMDL Definition
This report presents the development of a Fecal Coliform Total Maximum Daily Load (TMDL) for
the Roaring River in the Yadkin-Pee Dee River Basin (Figure 1.1) in North Carolina. As identified
by the North Carolina Division of Water Quality (DWQ), the impaired segment of the waterbody
is described in Table 1.1.

Figure 1.1 - Location of the Yadkin River Basin within North Carolina

Table 1.1 - Description of impaired segments for the Roaring River
Waterbody
Name Description Assessment
Unit (AU): Class Subbasin Impairment Miles
Roaring
River
From source
to Yadkin
River
12-46 B 03040101 Fecal
Coliform 5.9
Class B waters are freshwaters protected for primary recreation, which includes swimming on a frequent or organized basis and
all Class C uses. Class C waters are protected for secondary recreation, fishing, aquatic life including propagation and survival,
and wildlife.

Section 303(d) of the Clean Water Act (CWA) requires States to develop a list of water bodies
that do not meet water quality standards or have impaired uses. The list, referred to as the
303(d) list, is submitted biennially to the U.S. Environment Protection Agency (USEPA) for
review. The 303(d) process requires that a Total Maximum Daily Load (TMDL) be developed for
each of the waters appearing on the 303(d) list.
1.2 TMDL Components

The objective of a TMDL is to allocate allowable pollutant loads to known sources so that
actions may be taken to restore the water to its intended uses (USEPA, 1991). Generally, the
primary components of a TMDL, as identified by USEPA (1991, 2000) and the Federal Advisory
Committee (USEPA, 1998) are as follows:

2
Target identification or selection of pollutant(s) and end-point(s) for consideration. The
pollutant and end-point are generally associated with measurable water quality related
characteristics that indicate compliance with water quality standards.

Source assessment. All sources that contribute to the impairment should be identified and
loads quantified, where sufficient data exist.

Assimilative Capacity. Estimation of level of pollutant reduction needed to achieve water
quality goal. The level of pollution should be characterized for the water body, highlighting
how current conditions deviate from the target end-point. Generally, this component is
identified through water quality modeling.

Allocation of Pollutant Loads. Allocating pollutant control responsibility to the sources of
impairment. The waste load allocation portion of the TMDL accounts for the loads associated
with point sources. Similarly, the load allocation portion of the TMDL accounts for the loads
associated with nonpoint sources, stormwater, and natural background.

Margin of Safety. The margin of safety addresses uncertainties associated with pollutant loads,
modeling techniques, and data collection. Per EPA (2000a), the margin of safety may be
expressed explicitly as unallocated assimilative capacity or implicitly due to conservative
assumptions.

Seasonal Variation. The TMDL should consider seasonal variation in the pollutant loads and
end-point. Variability can arise due to stream flows, temperatures, and exceptional events
(e.g., droughts, hurricanes).

Critical Conditions. Critical conditions indicate the combination of environmental factors that
result in just meeting the water quality criterion and have an acceptably low frequency of
occurrence.

Section 303(d) of the CWA requires EPA to review all TMDLs for approval. Once EPA approves a
TMDL, the water body may be moved off the 303(d) list. Water bodies remain impaired until
compliance with water quality standards is achieved.
1.3 Water Quality Target: North Carolina Standards and Classifications

The North Carolina fresh water quality standard for Class B waters for fecal coliform (15A NCAC
02B. 0219) states:

The following water quality standards apply to surface waters that are for
primary recreation, including frequent or organized swimming and are classified
as Class B waters. Water quality standards applicable to Class C waters as
described in Rule .0211 of this Section also apply to Class B waters.
3
Organisms of coliform group: fecal coliforms not to exceed geometric
mean of 200/100 ml (MF count) based on at least five consecutive
samples examined during any 30-day period and not to exceed 400/100
ml in more than 20 percent of the samples examined during such period.

The North Carolina fresh water quality standard for Class C waters for fecal Coliform (15a NCAC
02B .0211) states:

Organisms of the coliform group: fecal coliforms shall not exceed a geometric
mean of 200/100ml (MF count) based upon at least five consecutive samples
examined during any 30 day period, nor exceed 400/100ml in more than 20
percent of the samples examined during such period; violations of the fecal
coliform standard are expected during rainfall events and, in some cases, this
violation is expected to be caused by uncontrollable nonpoint source pollution; all
coliform concentrations are to be analyzed using the membrane filter technique
unless high turbidity or other adverse conditions necessitate the tube dilution
method; in case of controversy over results, the MPN 5-tube dilution technique
shall be used as the reference method.
1.4 Watershed Description

The Roaring River is located in the Yadkin-Pee Dee River Basin in northern Wilkes County
(Figure 1.2). The watershed covers 139 square miles and is located along the Blue Ridge
Escarpment with an elevation change of 2,992 feet from the headwaters to the confluence with
the Yadkin River. The headwaters that form the Roaring River are located within Stone
Mountain State Park, the Blue Ridge Parkway, and several other conservation areas. These
areas are heavily forested. Agricultural land increases farther south and downstream towards
the Yadkin River.
4

Figure 1.2 - Roaring River watershed and surrounding area.
5
The population density and growth rate are low in the Roaring River watershed compared to
North Carolina as a whole (Table 1.2).

Table 1.2 - Population information
Area
Persons per
square mile,
2010
2000 Census
Population
2010 Census
Population
Population,
percent change
2000-2010
Watershed 48.7* 6,401 6,766* 5.7%*
Wilkes
County 91.6 65,630 69,340 5.7%
North
Carolina 195.8 8,046,406 9,535,483 18.5%
Source: http://2010.census.gov/2010census/data/
* Based on Wilkes County population percent change 2000-2010 (5.7%)

Land Cover

The land cover dataset used for this project was created by the NC Center for Geographic
Information and Analysis (CGIA) for the upper portion of the Yadkin River Basin. Data are
derived from Landsat 5 imagery from 2006 and 2007. The methodology used to create this
dataset was based on that used to create the 2001 National Land Cover Database (NLCD). In
addition, the NCDOT
integrated the road network right-of-way as an additional land class. Land cover classifications
and 30 meter grid cells are also based on those from the NLCD. Table 1.3 shows the area in
square miles for each of the land categories. The land cover is shown graphically in Figure 1.3.

Table 1.4 shows the land cover distribution adjacent to streams. These data were derived by
using GIS to select only land cover grid cells that were intersected by a 1:24000 stream
segment.

Table 1.3 - Land cover distribution in the Roaring River watershed
Land Cover Description
Area
(square
miles)
Area
(percent)
Deciduous Forest 75.70 54.21%
Pasture/Hay 26.40 18.91%
Evergreen Forest 16.97 12.15%
Mixed Forest 6.79 4.87%
Developed, Low Intensity 6.21 4.44%
Developed, Open Space 4.71 3.37%
6
Scrub/Shrub 1.06 0.76%
Grassland/Herbaceous 0.65 0.47%
Barren Land 0.36 0.26%
Developed, Medium Intensity 0.29 0.21%
Cultivated Crops 0.27 0.20%
Woody Wetlands 0.13 0.09%
Open Water 0.06 0.04%
Developed, High Intensity 0.03 0.02%
Total 139.63 100%
NCDOT* 1.5* 1.0%
* The NCDOT land cover was obtained from a modified CGIA land cover file provided by the
NCDOT and was calculated independently from the other land categories. NCDOT land is not
shown in Figure 1.3, however it generally follows the road-like distribution of the developed
land categories.

Table 1.4 - Land cover adjacent to streams in the Roaring River watershed
Description Land Cover Distribution
Adjacent to Streams
Deciduous Forest 33.4%
Evergreen Forest 19.9%
Pasture/Hay 16.3%
Mixed Forest 12.0%
Developed, Low Intensity 8.0%
Developed, Open Space 5.9%
Scrub/Shrub 2.1%
Woody Wetlands 0.7%
Cultivated Crops 0.7%
Open Water 0.5%
Grassland/Herbaceous 0.4%
Developed, Medium Intensity 0.1%
Barren Land 0.1%
Total 100.0%

7

Figure 1.3 - Land Cover distribution in the Roaring River watershed

8
1.5 Water Quality Monitoring

The DWQ has one monitoring station on the Roaring River: Q0660000 at state road 1990, near
the town of Roaring River. The location of this station is shown in Figure 1.4.

In addition to routine monthly samples, ten additional samples were taken at this station in
June (5 samples) and August (5 samples) of 2004 as part of a “5-in-30” study to determine if
fecal coliform concentrations exceeded the geometric mean portion of the standard (fecal
coliforms not to exceed geometric mean of 200cfu/100 ml based on at least five consecutive
samples examined during any 30-day period). These sampling dates are highlighted in
Appendix Table A.1. A more detailed accounting of this sampling can be found in Table 1.5.
Other locations in this watershed were also sampled during this study and their locations are
shown on Figure 1.4. The 5-in-30 study report can be found in Appendix B.

Table 1.5 - Roaring River water quality sampling
Station Sampling
Period
Number
of
Samples
Collected
Approximate
Sampling
Frequency
Number of
Samples
Exceeding
Standard (400
colony forming
units (cfu)/100
ml)
June 2004
5 in 30
Geomean1
August
2004 5 in
30
Geomean1
Q0660000
Jan. 2000
– Apr.
2010
148 monthly 17 (11%) 524
cfu/100 ml
264
cfu/100 ml
1. Geomean is calculated when there are five consecutive samples examined during any 30-day period.

9

Figure 1.4 - Water quality monitoring in the Roaring River watershed
10
2.0 Source Assessment
2.1 Nonpoint Source Assessment

Nonpoint sources are diffuse sources that typically cannot be identified as entering a water
body at a single location. Nonpoint source loading typically occurs during rain events when
surface runoff transports water carrying fecal coliform over the land surface and discharges it
into the stream network. The transport of fecal coliform from the land to the stream is dictated
by the hydrology, soil type, land use, and topography of the watershed.

There are many types of nonpoint sources in watersheds that contribute to stream
impairments. Fecal coliform bacteria from non-human sources originate from excretions from
warm-blooded wildlife, livestock and pets. Wildlife in the watershed are considered to make up
background concentrations of fecal coliform. A more direct path to the stream occurs when
wildlife defecate in, or even inhabit, the drainage network, including stream and wetland
channels, and stormwater conveyance pipes.

Grazing animals contribute fecal coliform through either direct access to streams or runoff from
deposition or manure spreading. Land cover data for the watershed indicates that pasture/hay
land area (grazing land) represents 19 percent of the watershed. Some of this land is
concentrated near the streams in the watershed (Figure 1.3) and runoff could be a contributing
factor if manure is improperly applied, particularly if just before a storm event. The land cover
shows that over 30 percent of the streams in the watershed have adjacent pasture/hay or
developed land with only a thin buffer of trees or no tree buffer. According to the Wilkes
County Soil and Water Conservation District (Wilkes Soil and Water) agriculture in this
watershed is primarily made up of corn, tobacco, cattle, and chickens. Numerous chicken
houses are visible in orthophotographs of the watershed. Wilkes Soil and Water suggests that
stream buffer compromises, over application of manure or spreading manure too close to
streams, and cattle overstocking may all be issues in this watershed. However, much of the
watershed is held in private land, and stream observations are limited.

Nonpoint source contributions to the bacterial levels from human activities generally arise from
malfunctioning or improperly-sited septic systems, or illicit straight pipes that bypass septic
systems. The Wilkes County Health Department is not aware of problematic areas in this
watershed regarding failing septic systems or straight pipe discharges.

2.2 Point Source Assessment

All wastewater discharges to surface water in the State of North Carolina must receive a permit
to control water pollution. The Clean Water Act of 1972 initiated strict control of wastewater
discharges with responsibility of enforcement given to the Environmental Protection Agency
(EPA). The EPA then created the National Pollutant Discharge Elimination System (NPDES) to
track and control point sources of pollution. The primary method of control is issuance of
11
permits to discharge with limitations on wastewater flow and constituents. The EPA delegated
permitting authority to the State of North Carolina in 1975. Table 2.1 shows dischargers
in the Roaring River watershed. Locations of dischargers are shown in Figure 1.4. Permit
violations for fecal coliform are shown in Appendix C.

Table 2.1 - NPDES Waste Water Dischargers in the Roaring River Watershed
Facility Permit Type
Permitted
Flow
(MGD)
Monthly
Average
Limit
Daily
Max
Limit
Fecal
Coliform
Permit
Violations
2000-Apr.
2010
North Wilkes
High School NC0076066
100%
Domestic
<1 MGD
0.0105 200#/
100ml
400#/
100ml 5
Traphill
Elementary
School
NC0046426
100%
Domestic
<1 MGD
0.004 200#/
100ml
400#/
100ml 1

In addition, human sewage can be discharged to surface waters during sanitary sewer overflow
(SSO) events due to a failure at a pump station or stormwater infiltration. There are no sanitary
sewers in this watershed.
2.3 NPDES Stormwater Permits
The only stormwater permit in the Roaring River watershed is held by the North Carolina
Department of Transportation (NC DOT), whose NPDES Phase I permit applies statewide. The
(NCDOT) has approximately 1.5 square miles of road and right-of-way in the 139 square-mile
watershed, which are covered under their statewide Phase I NPDES stormwater permit
(NCS000250). NPDES-permitted sources are to be included in the wasteload allocation (WLA)
per EPA guidance (USEPA, 2002).

3.0 Total Maximum Daily Loads and Loads and Load Allocation

3.1 TMDL Objective
The TMDL objective is to meet North Carolina water quality standards for fecal coliform, which
are not to exceed a geometric mean of 200/100 ml (MF count) based on at least five
consecutive samples examined during any 30-day period and not to exceed 400/100 ml in more
than 20 percent of the samples examined during such period.

12
3.2 Methodology

The load duration curve method is intended to be a simple method to calculate pollutant
reductions. This method was chosen for the Roaring River because of the availability of long-
term data and is an efficient method to calculate a percent load reduction from nonpoint
sources. The methodology used to develop the load duration curve was based on Cleland
(2002).The required load reduction was determined based on water quality monitoring and
stream flow data from January 2000 through April 2010.
3.2.1 Flow Duration Curve
Development of a flow duration curve is the first step of the load duration approach. A flow
duration curve employs a cumulative frequency distribution of measured daily stream flow over
the period of record. The curve relates flow values measured at the monitoring station for the
percent of time the flow values were equaled or exceeded. Flows are ranked from lowest,
which are exceeded nearly 100 percent of the time, to highest, which are exceeded less than 1
percent of the time. Reliability of the flow duration curve depends on the period of record
available at monitoring stations. Accuracy of the curve increases when longer periods of record
are used. The flow duration curve, shown in Figure 3.1, was used to determine the seasonality
and flow regimes during which the exceedances of the pollutants occurred.

Figure 3.1 - Flow Duration Curve for the Roaring River at DWQ Station Q0660000
1
10
100
1000
10000
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Da
i
l
y

S
t
r
e
a
m

F
l
o
w

(
c
f
s
)
<-- Higher Flows Percent of Days Flow Exceeded Lower Flows -->
Flow Duration Curve for the Roaring River at DWQ Station Q0660000
13
Daily flow data were used from USGS Roaring River gauging station 02112120, co-located with
the DWQ station.
3.2.2 Load Duration Curve
A load duration curve is developed by multiplying the flow values along the flow duration curve
by the pollutant concentration and the appropriate conversion factors. The allowable load
assumes a fecal coliform concentration based on water quality numeric criteria and margin of
safety. The target, or allowable load line, resembles the flow duration curve; hence it
determines the assimilative capacity of a stream or river under different flow conditions. Values
above the line are exceedances and values below the line are acceptable loads. Therefore, a
load duration curve can help define the flow regime during which exceedances occur. Figure 3.2
shows existing loads plotted against the allowable load. For the Roaring River, the criteria
violations occurred mostly during moist and high flow conditions. Few exceedances during dry
conditions suggest that point sources in the watershed may not be a significant source of fecal
coliform bacteria in this watershed.

Figure 3.2 – Load Duration Curve for the Roaring River at DWQ Station Q0660000
3.3 Total Maximum Daily Load

Total Maximum Daily Load (TMDL) can be defined as the total amount of pollutant that can be
assimilated by the receiving water body while achieving water quality standards. A TMDL can
be expressed as the sum of all point source wasteload allocations (WLAs), nonpoint source load
allocations (LAs), and an appropriate margin of safety (MOS), which takes into account any
uncertainty concerning the relationship between effluent limitations and water quality. This
definition can be expressed by equation 3.1.

100000000
1E+09
1E+10
1E+11
1E+12
1E+13
1E+14
1E+15
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Fe
c
a
l

C
o
l
i
f
o
r
m

L
o
a
d

(
c
f
u
/
d
a
y
)
<--- Higher flows Percent Days Flow Exceeded Lower Flows-->
Load Duration Curve for the Roaring River at DWQ Station Q0660000
Allowable Load Actual Load
Moist ConditionsHigh Flows Mid-Range Flows Dry Conditions Low Flows
14
∑∑++=MOSLAsWLAsTMDL (3.1)

The purpose of the TMDL is to estimate allowable pollutant loads and to allocate those loads in
order to implement control measures and to achieve water quality standards. The Code of
Federal Regulations (40 CFR § 130.2 (1)) states that TMDLs can be expressed in terms of mass
per time, toxicity, or other appropriate measures. For fecal coliform contamination, TMDLs are
expressed as counts, or colony forming units (cfu), per 100 milliliters. TMDLs represent the
maximum one-day load the river can assimilate and maintain the water quality criterion. A load
duration curve approach was utilized to estimate the TMDL for fecal coliform.
3.4 Margin of Safety (MOS)

The MOS is included in the TMDL estimation to account for the uncertainty in the simulated
relationship between the pollutants and the water quality standard. In this study, the MOS was
explicitly included in following TMDL analysis by setting the TMDL target at 10 percent lower
than the water quality target for fecal coliform. The water quality standard and the target can
be seen in Table 3.1.

Table 3.1 - Water quality standards and margin of safety
Pollutant Standard Target w/ 10% MOS
Fecal
Coliform
(cfu/day)
400
cfu/100ml 360 cfu/100 ml

Target Reduction

The load reduction needed to meet the instantaneous fecal coliform standard was estimated
with the observed data that exceeded the applicable water quality standard (360 cfu/100 ml)
within the 10th to 95th percentile flow recurrence range. Typically the remaining flow recurrence
range is not included in the TMDL calculation to allow cases of extreme drought or flood to be
excluded.

A polynomial curve equation for the data points violating the water quality criterion was
estimated. The equation is presented in Equation 3.2.

y = -9E+12x2 + 8E+12x + 2E+12 R² = 0.0116 (3.2)
Where, Y = fecal coliform (cfu/100ml) and X = Percent Flow Exceeded.

To present the TMDLs as a single value, the existing load was calculated from the polynomial
curve equation as the average of the load violations occurring when the flow exceeded at a
frequency greater than 10 percent and less than 95 percent. Additionally, the average load was
calculated by using percent flow exceedances in multiples of 5 percent. The allowable loadings
15
for each exceedance were calculated from the TMDL target value, which includes the 10
percent MOS. The target curve based on the allowable load and the polynomial curve based on
the exceedances are shown in Figure 3.3.

The necessary percent reduction was calculated by taking the difference between the average
of the polynomial curve load estimates and the average of the allowable load estimates. For
example, at each recurrence interval between 10 and 95 (again using recurrence intervals in
multiple of 5), the equation of the polynomial curve was used to estimate the existing load.
The allowable load was then calculated in a similar fashion by substituting the allowable load
curve. The estimated values are given in Appendix Table A.2.

Figure 3.3 - Load duration curve with allowable and estimated exceeding loads of fecal coliform
in the Roaring River at station Q0660000
3.5 TMDL Allocation

As identified by the above load duration curve method, a significant reduction of fecal coliform
is needed in the Roaring River. A summary of the reductions needed is provided in Table 3.2
(also, see Appendix Table A.2).

Table 3.2 - Reduction required for fecal coliform
Pollutant Target with
MOS
Average
Exceeding Load
Allowable Load
(TMDL-MOS)
Average Reduction
Required
Fecal Coliform
(cfu/day)
<360
cfu/100ml 3.11E+12 1.04E+12 66.7%

y = -9E+12x2 + 8E+12x + 2E+12
R² = 0.0116
100000000
1E+09
1E+10
1E+11
1E+12
1E+13
1E+14
1E+15
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Fe
c
a
l

C
o
l
i
f
o
r
m

L
o
a
d

(
c
f
u
/
d
a
y
)
<--- Higher flows Percent Days Flow Exceeded Lower Flows-->
Load Duration Curve for the Roaring River at DWQ Station Q0660000
Allowable Load Actual Load Exceedances Poly. (Exceedances)
16
The TMDL objectives require the instream fecal coliform concentrations to meet both the
instantaneous standard of 400 cfu/100ml and the geometric mean standard of 200 cfu/100ml.
This analysis used the instantaneous standard as the endpoint for the fecal coliform TMDL in
the creek. To verify that the required reduction will also meet the geometric mean standard,
the reduction was applied to those fecal coliform concentrations measured during the sampling
to calculate the geometric mean (highlighted in Appendix Table A.1) and a new geometric mean
was calculated. The results of this analysis are shown in Table 3.3 and indicate that the
required reduction will meet the geometric mean portion of the fecal coliform standard.

Table 3.3 - Verification of geometric mean portion of fecal coliform standard
Sampling Period Measured
Geometric Mean
Geometric Mean with
Reduction
June 2004 524 174
August 2004 264 88

3.5.1 Waste Load Allocation (WLA)
Two waste water treatment facilities (WWTF) plus the NC Department of Transportation hold
NPDES permits in the Roaring River Watershed. The two WWTF load contributions are shown in
Table 3.4

Table 3.4 – Existing NPDES Load Contributions
Facility Name Permit
Number
Flow
(mgd)
Flow
(cfs)
Permit Limit
(Daily Max)
Load
(cfu/day)
% of
Average
Ambient
Station
Load
Stream
Miles to
DWQ
station
North Wilkes
High School NC0076066 0.0105 0.016 400#/100ml 159053352 0.007% 6.4
Traphill
Elementary
School
NC0046426 0.004 0.006 400#/100ml

60591753

0.003% 11

In order to estimate contributions from the WWTFs, it was assumed that all fecal coliform
discharged reaches the ambient station with no attenuation. Based on facility limits of flow and
the more stringent daily fecal coliform concentrations, the combined WWTF load contributes
less than 1% of the average load at DWQ station Q0660000 based on data from years 2000
through 2010. Factoring actual distances from the Ambient Station, bacteria die-off, and the
small loading percentage calculated above, it appears that these WWTFs do not present a
significant load to the Roaring River. Therefore it was assumed that the WWTFs are adequately
regulated under existing permits and the waste load allocations in this TMDL were calculated at
17
the existing permit limits. The waste load allocation for NPDES permittes in the Roaring River
watershed are shown in Table 3.5.

Table 3.5 – NPDES waste load allocations and required reductions
NPDES Permittee Permitted Load
(cfu/day) WLA (cfu/day) Percent Reduction
Required
North Wilkes High
School 1.591E+08 1.591E+08 0%
Traphill Elementary
School 6.059E+07 6.059E+07 0%
NC DOT - Stormwater n/a 1.036E+10 0%
Total 1.058E+10 0%

Monitoring data is not available for stormwater draining from NCDOT areas in the watershed.
Consequently, the NCDOT WLA was assigned as 1 percent of the load allocation, based on DOT
land comprising 1 percent of the watershed from the land cover data in section 1.4. The NC
DOT will continue to implement measures required by the NPDES stormwater permit
(NCS000250), including illicit discharge detection and elimination, post-construction controls,
management of hydraulic encroachments, sediment and erosion control, BMP retrofits,
stormwater pollution prevention for industrial facilities, research, and education programs.
3.5.2 Load Allocation (LA)
All fecal coliform loadings from nonpoint sources such as non-MS4 urban land, agriculture land,
and forestlands are reported as the LA. The estimated contributions of fecal coliform from the
nonpoint sources are presented in Table 3.6. The estimated percent reduction needed from
nonpoint sources is 67%, as shown in Table 3.7.

Table 3.6 – Estimated TMDL and load allocation for fecal coliform for the Roaring River
Pollutant
Average
Exceeding
Load
WLA LA Explicit
MOS1 TMDL
Fecal
Coliform
(cfu/day)
3.11E+12 1.058E+10 1.0252E+12 10 % 1.0358E+12
Note: The Margin of safety is included in the TMDL by lowering the Fecal Coliform standard from 400 to 360 cfu/100 ml.

18
Table 3.7 – Estimated reduction by source for fecal coliform (shown in cfu/day) for the Roaring
River
WLA LA
Existing Load (cfu/day) 1.058E+10 3.103E+12
Allocation (cfu/day) 1.058E+10 1.0252E+12
Percent Reduction 0% 67%
3.5.3 Critical Condition and Seasonal Variation
Critical conditions are considered in the load duration curve analysis by using an extended
period of stream flow and water quality data, and by examining the flows (percent flow
exceeded) where the existing loads exceed the target line.

Seasonal variation is considered in the development of the TMDLs, because allocation applies
to all seasons. According to the load duration curve (Figure 3.3), exceedances for fecal coliform
occurred mostly during mid range to high flow conditions throughout the year; therefore, wet
weather conditions are critical for fecal coliform loading to the Roaring River.

4.0 Summary and Future Consideration

This report presents the development of the Fecal Coliform Total Maximum Daily Load (TMDL)
for the Roaring River in the Yadkin Pee-Dee River Basin.

Available water quality data were reviewed to determine the critical periods and the sources
that lead to exceedances of the standard. The necessary percent reduction to meet the TMDL
requirement was then calculated by taking a difference between the average of the polynomial
curve load estimates and the average of the allowable load estimates. The summary of the
results is as follows:

• A 67.1% percent reduction in nonpoint source contributions of fecal coliform is required
in order to meet the water quality standard in the Roaring River. It appears that
nonpoint sources are responsible for the exceedance of fecal coliform standards.
4.1 Future Efforts

Reduction of fecal coliform bacteria in this watershed will result from reduced overland and
stormwater runoff, and improved land management. Landowners, stakeholder groups, local
governments, and agencies are encouraged to utilize all available funding sources for water
quality improvement projects within the watershed. The following programs provide technical
and financial resources for reducing non-point source pollution:

• The North Carolina Soil and Water Conservation Service
19
• The Natural Resources Conservation Service
• Clean Water Act Section 319 Nonpoint source pollution control grant
• North Carolina Clean Water Management Trust Fund
• 205(j) Water Quality Management Planning Grant

5.0 Public Participation

TBD

6.0 References

Cleland, B.R. 2002. TMDL Development from the “Bottom Up” – Part II: Using load duration
curves to connect the pieces. Proceedings from the WEF National TMDL Science and Policy
2002 Conference.

U.S. Environmental Protection Agency (USEPA). 1991. Guidance for Water Quality-Based
Decisions: The TMDL Process. Assessment and Watershed Protection Division, Washington, DC.

U.S. Environmental Protection Agency (USEPA) 1998. Draft Final TMDL Federal Advisory
Committee Report. U.S. Environmental Protection Agency, Federal Advisory Committee (FACA).
Draft final TMDL Federal Advisory Committee Report. 4/28/98.

U.S. Environmental Protection Agency (USEPA) 2000. Revisions to the Water Quality Planning
and Management Regulation and Revisions to the National Pollutant Discharge Elimination
System Program in Support of Revisions to the Water Quality Planning and management
Regulation; Final Rule. Fed. Reg. 65:43586-43670 (July 13, 2000).

U.S. Census Bureau:
Wilkes - http://quickfacts.census.gov/qfd/states/37/37193.html

20

Appendix A: TMDL Data

Table A.1. Water Quality and Flow Data for the Roaring River at DWQ Ambient Station
Q0660000 (highlighted rows indicate data was collected for 5 in 30 testing).

Date
Result
(cfu/100
mL)
Flow
(cfs)
2/7/2000 18 98
3/23/2000 73 190
4/12/2000 45 112
5/9/2000 36 100
7/19/2000 150 50
8/15/2000 180 49
9/12/2000 140 51
10/10/2000 64 40
11/8/2000 27 44
12/27/2000 54 43
1/9/2001 100 40
2/8/2001 *Non-detect 57
4/23/2001 27 76
5/7/2001 19 60
6/12/2001 140 46
7/12/2001 190 43
8/14/2001 3000 153
9/6/2001 210 51
10/9/2001 21 34
11/7/2001 24 42
12/11/2001 10000 272
1/10/2002 10 59
2/20/2002 28 68
3/7/2002 4 73
7/9/2002 120 24
8/1/2002 51 29
9/9/2002 140 19
10/1/2002 150 85
11/14/2002 170 213
12/9/2002 32 114
1/15/2003 13 118
2/4/2003 340 124
3/12/2003 7 131
Date
Result
(cfu/100
mL)
Flow
(cfs)
4/24/2003 130 309
5/19/2003 155 196
6/4/2003 2000 370
7/9/2003 370 340
8/12/2003 770 289
9/4/2003 13000 331
10/13/2003 110 135
11/12/2003 48 147
12/1/2003 67 235
1/5/2004 110 187
3/15/2004 5 150
4/19/2004 35 179
5/13/2004 180 128
6/1/2004 290 114
6/8/2004 310 118
6/11/2004 1100 137
6/22/2004 2100 394
6/25/2004 190 252
7/26/2004 190 92
8/20/2004 136 92
8/26/2004 270 96
8/27/2004 320 90
9/3/2004 191 102
9/22/2004 310 239
9/24/2004 500 195
9/29/2004 870 517
10/27/2004 140 168
11/3/2004 88 160
12/13/2004 100 229
1/6/2005 140 183
2/3/2005 170 215
3/8/2005 120 187
4/7/2005 170 248
Geomean
=
523.87
Geomean
=
264.25
21
Date
Result
(cfu/100
mL)
Flow
(cfs)
5/19/2005 70 175
6/15/2005 410 146
7/14/2005 2200 277
8/25/2005 160 101
10/25/2005 100 80
11/15/2005 49 77
12/14/2005 68 121
1/31/2006 10 145
3/15/2006 2 87
4/6/2006 9 83
5/17/2006 27 78
6/15/2006 87 50
7/17/2006 140 66
8/10/2006 150 62
9/12/2006 770 95
10/25/2006 50 61
11/14/2006 77 109
12/5/2006 28 115
1/16/2007 140 193
2/19/2007 1 122
3/7/2007 6 181
4/26/2007 21 148
5/29/2007 46 79
6/19/2007 110 62
7/16/2007 35 50
8/20/2007 39 29
9/10/2007 190 30
10/10/2007 240 38
10/31/2007 130 85
11/27/2007 160 87
1/10/2008 73 86
2/19/2008 23 104
3/6/2008 47 131
4/14/2008 35 116
4/24/2008 38 108
5/12/2008 93 112
5/27/2008 40 68
6/9/2008 77 48
6/25/2008 44 32
Date
Result
(cfu/100
mL)
Flow
(cfs)
7/8/2008 4000 72
7/21/2008 41 25
8/6/2008 8 18
8/18/2008 9 17
9/9/2008 2000 117
9/22/2008 53 46
10/8/2008 67 63
10/20/2008 26 56
11/13/2008 400 150
11/20/2008 12 74
12/3/2008 13 87
12/17/2008 140 185
1/12/2009 25 202
1/27/2009 54 114
2/4/2009 5 106
2/17/2009 3 88
3/17/2009 44 181
3/25/2009 47 130
4/14/2009 120 194
4/30/2009 380 181
5/12/2009 50 197
5/27/2009 1200 923
6/9/2009 600 246
6/24/2009 70 197
7/14/2009 33 132
7/23/2009 80 131
8/4/2009 170 102
8/31/2009 120 80
9/9/2009 530 73
9/30/2009 80 117
10/15/2009 250 128
10/29/2009 61 155
11/4/2009 26 139
12/1/2009 27 118
12/14/2009 98 305
12/21/2009 140 197
1/7/2010 18 150
1/27/2010 34 497
2/9/2010 70 379
22
Date
Result
(cfu/100
mL)
Flow
(cfs)
2/17/2010 1 241
3/10/2010 24 205
Date
Result
(cfu/100
mL)
Flow
(cfs)
3/23/2010 98 463
4/7/2010 17 243

Figure A.1. Daily average flow (cfs) measured at USGS Gage 02112120.

Table A.2. Estimation of Load Reduction Required in Fecal Coliform for the Roaring River at
Station Q0660000.
% Flow
Exceeded
Flow
(cfs)
Actual
Load
Allowable
Load
Reduction
Needed
10% 260 2.71E+12 2.2909E+12

15% 217 2.9975E+12 1.9121E+12
20% 192 3.24E+12 1.6918E+12
25% 172 3.4375E+12 1.5155E+12
30% 159 3.59E+12 1.401E+12
35% 147 3.6975E+12 1.2953E+12
40% 134 3.76E+12 1.1807E+12
45% 122 3.7775E+12 1.075E+12
50% 110 3.75E+12 9.6925E+11
55% 100 3.6775E+12 8.8113E+11
60% 90 3.56E+12 7.9302E+11
65% 81 3.3975E+12 7.1372E+11
70% 74 3.19E+12 6.5204E+11
75% 66 2.9375E+12 5.8155E+11
0
500
1000
1500
2000
2500
3000
3500
1/
1
/
2
0
0
0
6/
1
/
2
0
0
0
11
/
1
/
2
0
0
0
4/
1
/
2
0
0
1
9/
1
/
2
0
0
1
2/
1
/
2
0
0
2
7/
1
/
2
0
0
2
12
/
1
/
2
0
0
2
5/
1
/
2
0
0
3
10
/
1
/
2
0
0
3
3/
1
/
2
0
0
4
8/
1
/
2
0
0
4
1/
1
/
2
0
0
5
6/
1
/
2
0
0
5
11
/
1
/
2
0
0
5
4/
1
/
2
0
0
6
9/
1
/
2
0
0
6
2/
1
/
2
0
0
7
7/
1
/
2
0
0
7
12
/
1
/
2
0
0
7
5/
1
/
2
0
0
8
10
/
1
/
2
0
0
8
3/
1
/
2
0
0
9
8/
1
/
2
0
0
9
1/
1
/
2
0
1
0
Fl
o
w

(
C
F
S
)
23
% Flow
Exceeded
Flow
(cfs)
Actual
Load
Allowable
Load
Reduction
Needed
80% 59 2.64E+12 5.1987E+11
85% 53 2.2975E+12 4.67E+11
90% 44 1.91E+12 3.877E+11
95% 36 1.4775E+12 3.1721E+11
Average 3.1138E+12 1.0358E+12 66.7%

24

Appendix B. DWQ 5-in-30 Study

Michael F. Easley, Governor

William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality

North Carolina Division of Water Quality 585 Waughtown Street Winston Salem, NC 27107 Phone [phone] Customer Service
Internet: h2o.enr.state.nc.us FAX [phone] 1-877-623-6748

An Equal Opportunity/Affirmative Action Employer – 50% Recycled/10% Post Consumer Paper

2004 Roaring River Fecal Coliform investigation

The fecal coliform data collected during January through December 2003 for all Ambient Monitoring stations have been
screened to identify waterbodies sampled that may be at risk for not fully supporting recreation uses, i.e. those with
geometric means >200 colonies/100ml or >20% of samples exceeding 400 colonies/100ml.

One site on the “B” classified Roaring River was found to have elevated fecal coliform numbers in the calendar year of
2003. In June and August of 2004, investigative sampling (5 samples in 30 days) was initiated to determine if standard
2B.0219 (3b) was violated. In addition to the Ambient monitoring station Q0660000, Roaring River nr Roaring River, 2
more stations upstream were sampled in June and 7 more in August to aid in locating potential coliform sources. The
results and comments follow.

Roaring River nr Roaring River (Ambient site Q0660000)

The Roaring River nr Roaring River exceeded one part of standard 2B.0219(3b) in the June and August sampling: fecal
coliforms not to exceed a geometric mean of 200/100 ml based upon at least five consecutive samples examined during
any 30-day period. It did however meet the portion of the standard not to exceed 400/100 ml in more than 20 percent of
the samples examined during such period in August, but exceeded in June. Refer to attached table and map.

East Prong Roaring River @ SR1945 (study site Q066A)

The East Prong Roaring River exceeded one part of standard 2B.0219(3b) in the June and August sampling: fecal
coliforms not to exceed a geometric mean of 200/100 ml based upon at least five consecutive samples examined during
any 30-day period. It did however meet the portion of the standard not to exceed 400/100 ml in more than 20 percent of
the samples examined during such period in August, but exceeded in June. Refer to attached table and map.

Roaring River@ SR1002 (Traphill Rd.) (study site Q066B)

The Roaring River nr Traphill exceeded one part of standard 2B.0219(3b) in the June and August sampling: fecal
coliforms not to exceed a geometric mean of 200/100 ml based upon at least five consecutive samples examined during
any 30-day period. It did however meet the portion of the standard not to exceed 400/100 ml in more than 20 percent of
the samples examined during such period in June and August. Refer to attached table and map.

East Prong@ SR1002 (Traphill Rd.) (study site Q066C)

The East Prong @ SR1002 was not sampled in June but exceeded one part of standard 2B.0219(3b) in the August
sampling: fecal coliforms not to exceed a geometric mean of 200/100 ml based upon at least five consecutive samples
examined during any 30-day period. It did however meet the portion of the standard not to exceed 400/100 ml in more
than 20 percent of the samples examined during such period in August. Refer to attached table and map.

Tributary @ SR1730 (study site Q066D)

The tributary @ SR1730 was not sampled in June but exceeded one part of standard 2B.0219(3b) in the August
sampling: fecal coliforms not to exceed a geometric mean of 200/100 ml based upon at least five consecutive samples
examined during any 30-day period. It did however meet the portion of the standard not to exceed 400/100 ml in more
than 20 percent of the samples examined during such period in August. Refer to attached table and map.

Tributary @ SR 1730 (upstream) (study site Q066E)

The tributary @ SR 1730 upstream was not sampled in June but exceeded one part of standard 2B.0219(3b) in the
August sampling: fecal coliforms not to exceed a geometric mean of 200/100 ml based upon at least five consecutive
samples examined during any 30-day period. It did however meet the portion of the standard not to exceed 400/100 ml in
more than 20 percent of the samples examined during such period in August. Refer to attached table and map.

Middle Prong @ SR 1736 (study site Q066F)

The Middle Prong @ SR 1736 was not sampled in June but exceeded the standard 2B.0219(3b) in the August sampling:
fecal coliforms not to exceed a geometric mean of 200/100 ml based upon at least five consecutive samples examined
during any 30-day period, as well as exceeding the standard of 400/100 ml in more than 20 percent of the samples
examined during such period. Refer to attached table and map.

Middle Prong @ SR1735 (study site Q066G)

The Middle Prong @ SR1735 was not sampled in June but exceeded the standard 2B.0219(3b) in the August sampling:
fecal coliforms not to exceed a geometric mean of 200/100 ml based upon at least five consecutive samples examined
during any 30-day period, as well as exceeding the standard of 400/100 ml in more than 20 percent of the samples
examined during such period. Refer to attached table and map.

Little Sandy @ SR 1944 (study site Q066H)

The Little Sandy @ SR 1944 was not sampled in June but exceeded one part of standard 2B.0219(3b) in the August
sampling: fecal coliforms not to exceed a geometric mean of 200/100 ml based upon at least five consecutive samples
examined during any 30-day period. It did however meet the portion of the standard not to exceed 400/100 ml in more
than 20 percent of the samples examined during such period in August. Refer to attached table and map.

June 2004 Roaring River 5-in-30 Sampling

Roaring River Fecal
Coliform Sample
Locations
6/1/04
Results:
Col/100ml
6/8/04
Results:
Col/100ml
6/11/04
Results:
Col/100ml
6/22/04
Results:
Col/100ml
6/25/04
Results:
Col/100ml
Geo. Mean
RR @ Roaring River 290 310 1100 2100 190 579
RR @ SR 1945 480 1200 100 900 280 388
RR @ Traphill Rd.
260 180 330 200 250 239

August, 2004 Roaring River 5-in-35* Sampling

Roaring River Fecal
Coliform Sample
Locations
8/20/04
Results
Col/100ml
8/2704
Results:
Col/100ml
9/3/04
Results:
Col/100ml
9/22/04
Results:
Col/100ml
9/24/04
Results:
Col/100ml
Geo Mean
RR @ Roaring River
Q0660000 136 320 191 310 500 264
East Prong @ SR 1945
Q066A 350 230 490 180 350 301
RR @ Traphill Rd.
Q066B 320 380 210 90 250 225
East Prong @SR 1002
Q066C 250 290 127 130 350 211
Trib @ SR 1730
Q066D 250 390 240 230 40 185
Trib @ SR 1730 upstream
Q066E 150 240 170 110 500 202
Middle Prong @ 1736
Q066F 450 550 450 260 136 330
Middle Prong @ 1735
Q066G 500 1200 700 190 109 387
Little Sandy @ SR 1944
Q066H 300 180 520 260 300 294
*Due to adverse weather in August, the sampling period exceeded the 30 day protocal

25

Appendix C. NPDES Fecal Coliform Permit Violations

Table C.1. Permit violations for fecal coliform for the NPDES dischargers in the watershed as of
March 2011. Rows highlighted in yellow show violations that occurred during the study period
of this TMDL.

Permit # Date Description Limit
(cfu/100ml)
Calculated
(cfu/100ml)
NC 0076066 10/1/2010 Daily max 400 440
NC 0076066 9/30/2010 Monthly avg. 200 290
NC 0076066 8/31/2010 Monthly avg. 200 258
NC 0076066 1/14/10 Daily max 400 480
NC 0076066 1/28/10 Daily max 400 510
NC 0076066 1/31/10 Monthly avg. 200 497
NC 0076066 6/30/09 Monthly avg. 200 226
NC 0076066 8/28/08 Daily max 400 520
NC 0046426 12/31/08 Monthly avg. 200 229

26
Appendix D: Public Notification of TMDL for Fecal Coliform for the Roaring River

The TMDL public comment period was announced on the NC Modeling and TMDL website on
3/14/11, on the WRRI listserv on 3/12/11.

• Notice on the Modeling and TMDL Website:
http://portal.ncdenr.org/web/wq/ps/mtu

3/14/2011 Public Review Draft Roaring River TMDL is available for review and
comment. The comment period extends through April 12, 2011. Comment
submittal instructions are available with the above link.

• WRRI listserv email received regarding public comment period:

The WRRI Daily Digest
Volume 1 : Issue 732 : "text" Format

201103/6 : DRAFT Total Maximum Daily Load for the Roaring River, Yadkin -
Pee Dee River Basin, North Carolina
"Painter, Andy" <[e-mail]>

Date: Fri, 11 Mar 2011 15:23:04 -0500
From: "Painter, Andy" <[e-mail]>
To: "[e-mail]" <[e-mail]>
Subject: DRAFT Total Maximum Daily Load for the Roaring River, Yadkin - Pee
Dee River Basin, North Carolina
Message-ID:
<[e-mail]>

Please post the following announcement on the WRRI listserv. Thanks!

Now Available for Public Comment

DRAFT Total Maximum Daily Load for Fecal Coliform for the Roaring River,
Yadkin - Pee Dee River Basin, North Carolina

March 2011
North Carolina Department of Environment and Natural Resources Division of
Water Quality

This draft TMDL report was prepared as a requirement of the Federal Water
Pollution Control Act, Section 303(d). Interested parties are invited to
comment on the draft TMDL report by April 12, 2011. Comments concerning the
report should be directed to Andy Painter at
[e-mail]<mailto:[e-mail]> or write to:

Andy Painter
27
NC Division of Water Quality
Planning Section
1617 Mail Service Center
Raleigh, NC 27699

The draft TMDL can be downloaded from the following link:
http://portal.ncdenr.org/c/document_library/get_file?uuid=507f9f1c-741f-4a9b-
993d-ce85308db37c&groupId=38364

28
Appendix E: Public Comments

Public Comment Roaring River Fecal Coliform Bacteria TMDL Responsiveness Summary

April 2011

The public comment period extended from May 12, 2011 through April 12, 2011. Comments
were received from the North Carolina Department of Transportation. These comments with
the NC Division of Water Quality responses are provided in the Responsiveness Summary
presented below.

1)

Response: DWQ has renamed the column headings in tables 3.2 and 3.6 from “Existing Load” to
“Average Exceeding Load.”

2)
29

Response: We appreciate NCDOTs efforts to improve water quality.
30