DEQ-CFW_00024348

BROOKS
PIECE
FOUNDED i8q?
'�o
Mice Of rhq sacry�ary
2017
uaust 4, 2017
Michael S. Regan, Secretary
N.C. Department of Environmental Quality
1.601 Mail. Service Center
Raleigh., NC 2769..1601
S, Jay Zimmerman, Director
NC I EQ, Division of Water Resources
1.611 Mail. Service Center
.alei h., NC; 276994611
2'-w NORTH ELm STREET
GREENSBORO, NC 27401
T '336.37x SRSO
F 336,378,1001
Re� Request for Interim Maximum Allowable Concentrations for
Perflcaorinated Compounds in Groundwater
We are environmental counsel for the Cape Fear Public L)tility Authority ("CHUA.")
The discharge of -various perfluorinated compounds by the Chemourrs Fayetteville Works
facility into the Cape ;Fear River has resulted in those compounds c;ontarninating the source water
that is withdrawn, treated and distributed by several public drinking eater supply systems,
includirr the C F'P A , and various corporate operators over many years, "I'he North Carolina
Department of health- and. Human Services `NCD1111S) continues to review .niaterials and. remise
toxicological and. epidemiological findings about the effects of those per -fluorinated compounds
on the citizens of the State of North. Carolina and the natural environment,
In addition to the use of Cape Fear River source for drinking water, those; waters distributed
to citizens and industry have been used for agricultural irrigation, earn washing, system
maintenance, residential lawn Lind garden. hoses, well drilling fluids, etc., over decades. The tawny;
uses of water have resulted in the natural percolation of water downward to groundwater. In
additio.n., C1'PUA"s AquiferStorage and. .Recovery Well stares treated drinking rater from the
C t-. pe pears contaminated. by the discharges under Nl'DES NC 000 57 .3.
North_ Carolina Adininistrative Code (I5A. NCAC 1121-0202(c) provides .. or establishment
of health lased groundwater Interim Maxirrr_uni AlloN al-Ae; Concentrations (IMACs)o An IMAC
has already been established for PFOA arrd. PFOS compounds that are sirni.lar to GenX— and the
other perfluorinated compounds now being `cured in the Cape Hear, t7PI.A. requests that the
Secre=y and,`or the Director prioritize and establish groundwater IMAC;S l:or all perfluorinated
compounds discharged under NPDES NC000 573,
DEQ-CFW 00024348

Sincerely,
')Ioor e Ho se z
.t YY
Si
V e Randall Tinsley
Joseph. A. 'a nzi
DEQ—CFW 00024349