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NC0004979_Plant_Allen_Steam_Station.pdfDocuSign Envelope ID: 457C8002-D95F-434D-8BB6-E8B40DE13C8B ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Mr. Jeffrey Flanagan, General Manager Duke Energy Carolinas LLC 253 Plant Allen Road Belmont, North Carolina 28012 Dear Mr. Flanagan, NORTH CAROLINA Environmental Quality March 8, 2023 Subject: NC0004979 Plant Allen Steam Station E. coli Study 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 20-17-12-058; 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 (firstname.lastname@ncdenr. gov). C 4531 3JA44FE... for Ric ar ogers, 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 (910)864-1920 (704)888-1211 Environmental Chemists, Inc. (EnviroChem) Environmental Chemists Inc./Outer Banks Div. 6602 Windmill Way 710 Bowsertown Road Wilmington, NC 28405 Manteo, NC 27954 (910)392-0223 (252)473-5702 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 (828)359-6771 (919)834-4984 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 (980)722-6611 (803)227-3167 Waypoint Analytical — Charlotte Rogers & Callcott Engineers Inc. 449 Springbrook Road 426 Fairforest Way Charlotte, NC 28217 Greenville, SC 29607 (704)529-6364 (864)232-1556 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 todd.crawford@ncdenr.gov. 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