DEQ-CFW_00009709

From: Moore, Sandra [SANDRA.MOORE]
Sent: 6/8/2010 1:07:07 PM
To: Clark, Alan [/O=NCMAIL/OU=EXCHANGE ADMINISTRATIVE GROUP
(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=ALAN.CLARK]
Subject: RE: Lower Cape Fear Reclass/PFOA risk assessment
Hi Alan,
No they didn't answer the question and yes, previously they had stated that PFCA could be treated with a carbon filter
so I'm thinking they don't: want to get too involved in this issue. If the NCSAB recommendation ends up being the higher
than the highest level detected it is probably a non -issue. Guess we'll wait and see. 'f'hanks for your thoughts.
Please note new e-mail address
State Water Quality Standards 'Co -coordinator
Division of Water Quality
NC Department of Environment and Natural Resources
1617 Moff Service Center, Raleigh, NC 27 99-1 17
Sandra. [e-mail]
(919) 07-6417
Note: R-moil correspondence to and,from this address may be subject to the North drarolino Public Records Low and may be disclosed
to third parties.
From:
Tuesday, - 08, 2010 8:58 AM
Moore, Sandra
Manning, 3eff
Subject: RE: s .ramFearO, risk assessmeril
Sandra, that's interesting. She really didn't answer your question regarding treatment options, Reading between the
lines based on her reference to conventional water treatment systems, she seems to be saying that the water treatment
plants :should not have go to additional lengths to remove this pollutant that: she feels :should be treated at any
Upstream discharge site(s). I tend to agree with that idea to the extent we can and should control upstream discharges,
to the extent possible, through the NPDES program. However, if the PFCA is already in the river well above Dupont and
coming from indeterminate sources, I would think it: would behoove PWS to consider what: other treatment: options
might be available at their plants to safeguard their customers. I thought she told dos that they could use carbon
filtration in previous communications.
By the way, since the highest PFOA level that was measured in the river was .141 ug/I and the SAB's recommendation
was in the .9 to 1.6 range, how much a concern should PWS have toward PFCA?
Alan
From: Moore,
Sent: Tuesday, June 08, 2010 8:34 AM
LMiles,Cc: Manning, 3eff; Clark, J
RE: Lower
Cape Fearre 1)i. risk assessmen)
DEQ-CFW 00009709

Jessica,
Thanks for your comments.
Sandra
Please vote new e-mail address
Sandra Moore
State Water Quality Standards Co -coordinator
Division of Water Quality
NC Department of Environment and Natural Resources
16.17 flail ,Service Center, Raleigh, h, C 699-1617
Sandra. moore ncdenr.gov
[phone]
Note: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From: Miles,essica
Sent: Tuesday, 3une 08, 2010 . AM
LowerTo: Moore, Sandra; Benoy, Debra; Midgette, Robert
Cc: Kountis, Elizabeth; Brower, Connie; Munden, Wayne
Subject: RE: .•.Fear•A risk assessmen)
Sandra,
Conventional water treatment processes relied or) in forth Carolina are not designed to rernove chemicals such as
PFCA. There should be no expectation of reduction in PFCA concentration by virtue of water treatment: plant:
processes. 'Therefore, we Relieve that DWQ should sat discharge limits with the understanding that water treatment
plants are not designed to reduce the concentration of PFCA. Under the Federal Safe Drinking Water Act, the North
Carolina Drinking Water Act: and the Rules Governing Public Water Systems, PFCA is not: regulated. As water syst:erris
are not required to monitor or treat for PFCA we have no data regarding treatment process removal efficiencies for
PFCA or analytical methods.
.I.hanks for the opportunity to comment.
Jessica
Jessica Codreau Miles, P.F., KEE, Chief
North Carolina Public Water Supply Section
main (91.9) 733-2321.
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From: Moore,. d
Monday, May 10, 201012:01 PM
To: Miles, 3essica; Benoy, Debra; Midgette, Robert
Cc: Kountis, Elizabeth; Moore, Sandra; Brower, Connie
Subject: Lower Cape Fear Reclass/PFOA risk assessment
DEQ-CFW 00009710

Several years ago an application to reclassify a portion of the Cape Fear River was submitted by the Lower Cape Fear
Water and Sewer Authority inorder toinstall awater supply intake. This intake was tubelocated approximately five
miles downstream of the permitted outfall of the Dupont Facility, which manufactures perfluorooctanoic acid (PFOA or
C-3). The Public Water Supply Section reviewed the application and concluded in a February 8, 2008 letter to DWQ that
PFOA should not prevent the reclassification of the requested section of the Cape Fear as a public water
supply. Sampling data atthe time indicated that there was no significant increase in PFOA caused by the Dupont
discharge and that current levels of PFOA were below any known health based site specific or groundwater proposed
standard. Dupont monitors for PF0Ainits NPDE5effluent and inthe Cape Fear River. Back inJOO6,the highest
concentration found in the Cape Fear River was 0.141 ug/L at Erwin, 33 miles north of and upstream from the DuPont
The N[Science Advisory Board has posted adraft PerOuorooctanoicAcid (PF0A)risk assessment totheir web site for
public comment until June 1,2OlO(link be|ovv). The N[SA8'sdraft recommendation toD\NQisaninterim maximum
allowable concentration (IMAC) for PFOA in groundwater at a value in the range of 0.9 1.6ppb(uo/L). The current
groundwater interim standard for PFOAis2ppb. Once the NCSA8risk assessment isfinalized, DVV{lwill reevaluate the
current PFOAinterim groundwater standard. The N[SABrisk assessment isavailable at
The DVVQ is requesting the PVVSS's input on how the water treatment plants that are utilizing the [ape Fear River can
deal with the range ofO.9 1.6 ppb, especially the new reclassification that DWQ did last year in the lower Cape Fear
where PFOAwas aconcern. Specifically, can plants treat PFOAand monitor inthe range ofD.9 1.6ppb? |sso, what
treatment options (for example, carbon filter) are available that would treat to the 0.9 - 1.6 ppb range?
We greatly appreciate any information or insight that you may be able to give us. If you have any questions or need
additional information, don't hesitate to contact me.
State Water Quality Standards Co -coordinator
Division ofWater Quality
NC Department oƒEnvironment and Natural Resources
1617Mail Service Center, Raleigh, NC 27699-1617
Sandra. [e-mail]
Note: E-moilcorrespondence toandfrom this address may be subject to the North Carolina Public Records Low and may be disclosed
to third parties.
OEQ-CFVV_00009711