DEQ-CFW_00003105

Grzyb, Julie
Subject: FW: Follow up - GenX
Regarding industrial permits:
1) Who needs a wastewater discharge permit, what does the company have to submit in an application, what chemicals
are regulated, and how are limitations developed.
Here is some general information that I hope will help walk you through the process.
NC Administrative Code requires (15A NCAC 02H .0101) a permit for control of sources of water pollution by providing the
requirements and procedures for application and issuance of state NPDES permits for a discharge from an outlet, point source,
or disposal system discharging to the surface waters of the state. These rules reflect FederNPDES permitting laws under 40
CFR 122 which the State implements. /ill A;,f c,5r ���"`'�'� � W D
Major industrial discharges, such as Chemours, are required to completAPA NPDES applications which require a certain
amount of sampling as described in 48 FR 14153, Apr 1, 1983. Applicants evaluate effluent for priority pollutants as defined by
EPA. Link to application forms: https://deg.nc.gov/permitting-applications
EPA has established effluent guidelines for over 57 different types of Industrial categories. Chemours is subject to the Organic
Chemicals, Plastics, and Synthetic Fibers (OCPSF) Point Source Category (40 CFR Part 414). Each industrial applicant must
characterize their wastestreams (define sources and provide test analysis of the contaminants contained in the wastewater
being discharged and specific wastestreams if required by federal categorical standards). The applicant is required to give the
discharge volume of each wastestream and what treatment will be provided to meet State and Federal Standards for the
receiving stream to which they propose to discharge.
The applicant may be required to perform a model for its oxygen consuming wastes —to protect dissolved oxygen in the
stream. Also, depending on the receiving stream classification (use) they may have to perform a treatability study to confirm
treatment levels and/or a nutrient response model to protect Nutrient Sensitive Waters.
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Federal Categorical Guidelines often have set technology based effluent limitations that NPDES puts in the permit. These limits
are usually based on long-term production numbers or long-term process flows from specific manufacturing areas. In addition,
limits and/or monitoring for pollutants of concern for particular types of wastewaters are put in the permit. And last, the
discharge characterization supplied in the application (each chemical sampled per the list supplied by EPA) is compared against
State and Federal Water Quality Standards or Criteria to see if there is potential to violate any standards/ criteria instream. If
so, additional limitations are added to the permit.
If the permittee identifies a unique contaminant, NPDES reviews EPA databases for guidance on how to regulate the
contaminant and contacts DWR's Standard's Branch for assistance. As described in rule 15A NCAC 02B .0208 "For carcinogens,
the concentrations of toxic substances shall not result in unacceptable health risks and [... I An unacceptable health risk for
cancer shall be considered to be more than one case of cancer per one million people exposed (1-6 risk level)..." Therefore if
EPA has a study that has determined this risk level, than NC DWR's Standards Branch would review this concentration and
establish a NC standard/criteria NPDES could use to determine a NPDES permit limitation.
Water Quality Based Effluent Limitations are based on stream use designations (Class C, Trout, Water Supply, etc.), stream
flows at the point of discharge (critical low -flow) and the discharge flow from the facility. Therefore WQBEL's all start by using
the same Water Quality Based Aquatic Life or Human Health standard/criteria but after stream use, stream flows, and
permitted flows are accounted for the permit limits will vary from permit to permit.
Major industrial draft permits are sent to public notice, EPA, and the permittee - all at the same time for a minimum of thirty
days. Anyone can comment or request a hearing. If no hearing is requested the permit can be issued 15 days after the end of
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DEQ-CFW 00003105