DEQ-CFW_00055372

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The Underground Injection Control program is a Federal Program under the Safe Drinking Water Act;
and regulated under 40 CFR Part 144 through 148. The Division of Water Resources within the
Department of Environmental Quality permits underground injection wells, and oversees their
compliance and enforcement. NC Administrative Code for this program is under 15A NCAC 2C .0200
(attached). One of the types of underground injection wells is the Aquifer Storage and Recovery (ASR).
ASR systems are intended to allow for injection of water into aquifers for temporary storage. ASR
systems provide an alternative to more traditional above ground storage tanks and lagoons. Cape Fear
Public Utility Authority (CFPUA) has a permitted ASR.
• Faced with increasing peak demands for water, CFF
manage periodic fluctuations of water supply and c
water for storage when there is excess supply and I
I for a permit for an ASR to
alternately injecting drinking
'ring water when there is
ur after a recharge and recovery of injected
it, Part X).
3, 2017 through May 10, 2017. CFPUA
include the ASR-1 and three of the
and monitoring wells).
• ASR permit number for the CFPUA is W10800149. It was originally issued 2008, renewed in
2011, 2013 and modified in 2016. The current permit will need to be renewed by 2021.
• Issues that must be addressed in an ASR permit application include:
o A complete water quality analysis of the water to be injected (all National Primary and
Secondary Drinking Water Standards) as well as a basic water quality analysis of native
water in the aquifer.
o Modeling of potential reactions between the injected water and native waters and
between the injected water and aquifer matrix.
o Groundwater monitoring at points other than the ASR well itself.
o Determination of an injection zone that specifies the horizontal and vertical portion of
the proposed injection activity. No violation of groundwater quality standards specified
in 15A NCAC 2L .0200 is allowed to occur outside this zone. (The injection zone is
indicated on the monitoring well map, attached)
• Disinfection by-products and disinfectants are the only compounds currently allowed to exceed
2L standards in the injected water, but this is only justified on the basis that the injected water is
treated drinking water to be recovered and used as treated drinking water.
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DEQ-CFW 00055372

November• .•• NCSU. — notificationand attached published
paper documenting occurrence of per- and polyfluoroalkyl substances (PFASs) in the Cape Fear
River -• with link to Chemours plant southof Fayetteville
During the ASR cycle tests, CFPUA injected 48.8 million gallons into the ASR. They stopped
injecting in June 2017.
a Cycle Test Injection #1 ended March 4, 2014 — total 13.75 MG stored
a Cycle Test Injection #2 ended June 13, 2014 — total 28.538 MG stored
a Due to repairs needed, and additional flushing and recovery, the Cycle Test Injection #3
was delayed. In November 2016, there was a total 24.4 MG stored
a Cycle Test injection #3 ended June 5, 2017 — 24.4 MG added; a total of 48.811 MG.
ASR #1well testing was done concurrently with raw and finished water testing for the GenX
compound. Below are the sampling results:
GenX Sampling Results
Week
Date
(ppt)
Lab Used
#1
6/22/2017
820
Test America, Colorado
#1
6/22/2017
588
EPA lab, Research Triangle (,ORD)
#2
6/29/2017
400
Test America, Colorado
#2
6/29/2017
336
EPA lab, Research Triangle (ORD)
#3
7/06/2017 ''
190
Test America, Colorado
#3
7/06/2017
148
EPA lab, Research Triangle (ORD)
#4
7/13/2017
120
Test America, Colorado
#4
7/13/2017
84
EPA lab, Research Triangle (ORD)
#5
7/20/2017
120
Test America, Colorado
#5
7/20/2017
94
EPA lab, Research Triangle (ORD)
PATH FORWARD
• The original intent of CFPUA was to pump out twice the volume that was injected, but not to
exceed 200 MG of recovered water. Since June 2017, CFPUA has pumped out a total of 232,700
gallons. The following table shows the dates and volumes of recovered water since June 2017.
Date
Recovered Water
6 /20/17
7,500 gallons
6/29/17
15,800 gallons
7/6/17
43,200 gallons
7/13/17
58,400 gallons
7/17/17
59,400 gallons
7/20/17
48,400 gallons
DEQ-CFW 00055373

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• With the exception of disinfectants and disinfection by-products, the permit requires that the
injected water shall at all times comply with groundwater quality standards in 15A NCAC 02L
• The permit requires regular monitoring for typical parameters of concern for a public water
supply (see attached permit requirements), but does not include GenX.
• 15A NCAC 02L.0202 does not specify a numeric value for a GenX groundwater standard;
therefore, the Class GA or Class GSA groundwater standard for GenX is the practical quantitation
limit [15A NCAC 02L .0202(b)(2)].
• 15A NCAC 2L .0106 (b) states that "Any person conducting or controlling an activity which
results in the discharge of a waste ... to the groundwaters of the State ... shall take immediate
action to terminate and control the discharge."
• The last sample results for the ASR shows GenX at 120 ppt and the DHHS health advisory level is
140 ppt.
• THE QUESTION IS did CFPUA know the water had GenX when they were still recharging the
aquifer? November 23, 2016, Dr. Knape with NC state, sent a paper he published in ES&T
Letters to NC DWR staff and CFPUA concerning GenX test results, where he states "None of the
91,
DEQ-CFW 00055374

newly discovered compounds being discharged by the Chemours plant south of Fayetteville are
removed by the advanced and conventional treatment processes employed in the Sweeney WTP
in Wilmington (see email attached).