NC0089745_Comments_20180829

of UNITED STATES MARINE CORPS
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\\""Nt� MARINE CORPS INSTALLATIONS EAST—MARINE CORPS BASE
, I. PSC BOX 20005
44 "ilill' M CAMP LEJEUNE NC 28542-0005
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AUG 232018
Ms. Brianna Young
Division of Water Resources RECEIVEDIDENRJDWR
Compliance and Expedited Permitting Unit AUG 2 9 2018
North Carolina Department of
Environmental Quality Water Resources
1617 Mail Service Center Permitting Section
Raleigh, North Carolina 27699-1617
RE: Draft New NPDES Permit NC0089745, Camp Lejeune WTP, Onslow County
Dear Ms . Young:
Marine Corps Base Camp Lejeune (MCB CAMLEJ) appreciates the
opportunity to review the subject draft permit and agrees with the
majority of the contents as it closely follows agency guidance for
permitting wastewater discharges from water treatment plants (WTPs) .
However, MCB CAMLEJ would like you to consider that the effluent limit
of 50 pCi/L in Part I.A. (1) of the permit for Gross Beta Radiation may
not be practical as it was developed without accounting for the
dilution factor established in the Mixing Zone Study (MZS) performed
by one of our contractors and submitted with the permit application in
December 2017 . The NCDEQ provided Fact Sheet for Expedited Permit
Renewals delivered with the Draft NPDES permit does not include the
rationale for not considering this mixing in the Reasonable Potential
Analysis (RPA) for this parameter. Since beta particles normally
deposit their energy over longer distances as part of the mixing
process, we request that the RPA for Gross Beta Radiation account for
the dilution factor of ten (10) as outlined in the MZS and otherwise
used by the NCDEQ in the RPA for arsenic, copper, lead, and zinc. We
believe that this approach will show that an effluent limit for Gross
Beta Radiation is not necessary. MCB CAMLEJ agrees that monitoring
for this parameter is appropriate to confirm whether actual effluent
from the future operational plant has elevated levels of Gross Beta
Radiation.
If you have any questions or need further clarification of the
information provided please contact Mr. Robert Lowder, Environmental
Management Division (EMD) , at telephone [phone] .
Sincerely,
� 1 LZ'h'/�-
OHN R.
TOWNSON
Director, Environmental Management
By direction of
the Commanding General