DEQ-CFW_00075308

Permit NC0003573
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
NPDES PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
The Chemours Company FC, LLC
is hereby authorized to discharge wastewater and stormwater from a facility located at
Chemours Company- Fayetteville Works
22828 NC Highway 87 W
Fayetteville
Bladen County
to receiving waters designated as the Cape Fear River in the Cape Fear River Basin in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts I, 1I, III, and IV
hereof.
The permit modification shall become effective July 1, 2015.
This permit and the authorization to discharge shall expire at midnight on October 31, 2016.
Signed this day October 28, 2015.
ge,.Jay Zimmerman, P.G.
l Director, Division of Water Resources
By Authority of the Environmental Management Commission
DEQ-CFW 00075308

North Carolina Department of Environmental Quality
Pat McCrory
Governor
M -. Michael Johnson, PE
Environmental Manager
The Chemours Company FC, LLC
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
Dear Mr. Johnson:
Donald R. van der Vaart
Secretary
October 28, 2015
Subject: NPDES Permit Modification
Permit NC0003573
Ownership Change
Bladen County
Class H Facility
Division personnel have reviewed and approved your request for permit modification of the subject permit, to
reflect new facility ownership effective July 1, 2015. Accordingly, we are enclosing modified pages to reflect
the new ownersbip. Please insert these modified pages into your current permit. A complete review of this
permit -will be conducted tivith your next permit renewal in 2016. This permit modification is issued pursuant
to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between
North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently
amended). If you have any questions, feel free to contact me at 919-807-6390 or via email at
tom.belnick a ncdenr.gov.
Sincerely,
C)V�
S. Jay Zimmerman. P.G.
Director, Division of Water Resources
cc: NPDES Files
Central Files
Ecopy:
EPA Region 4
DWR Fayetteville Regional Office/Water Quality
DWR Aquatic Toxicology
1601 Mail Service Center, Raleigh, North Carolina 27699-1601
Phone: [phone] Internet: www.nddenr.gov
An Equal Opportunity 1 Affirmative Action Employer
DEQ-CFW 00075309

Permit NC0003573
STATE OF NORTH C ANDNOLINA
ATURALRESOURCES
DIVISION OF
DEPARTMENT OF ENVIRONMENTMWATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
„T A .v%Tr►'AT e T _ pnT.T;[TTANT DISCHARGE ELIMINATION SY
111ti 11W.L11 • - "
tute 143-215. 1, other
ul standards
In compliance with the provisions of North Carolina thenNortheral taCarolina Environmental fManagem Management
and regulations promulgated and adopted y
Commission, and the Federal Water Pollution Control Act, as amended,
E.I. DuPont de Nemours & Co.
is hereby authorized to discharge wastewater and stormwater from a facility located at
DuPont - Fayetteville Works
22828 NC Highway 87
Duart Township
Bladen County
r in t to receiving waters designated as the Cape FearRive
ponsesetRiver fort Basin- in n Parts I, IIaccorIII, and1IV
effluent limitations, monitoring requirements, d
hereof.
The permit shall become effective March 1, 2012.
This permit and the authorization to discharge shall expire at midnight on October 31, 2016.
Signed this day February 6, 2012.
Charles Wakild P.E., Director
Division of Water Quality
onmental Management Commission
By Authority of the Envir
DEQ-CFW 00075310

Permit NC0003573
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked, and -as of this issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
E.I. DuPont de Nemours & Co., Inc.
is hereby authorized to:
1. Continue to operate existing wastewater treatment facilities consisting of:
• equalization;
• neutralization;
• aerated pre -digester tank;
• nutrient feed system;
• aeration tank;
• three clarifiers;
• effluent flow measurement;
• DAF unit;
• rotary filter for sludge thickening;
• sludge pump;
• sludge filter press; and
• steam heated sludge dryers.
2. Discharge treated process wastewater from Butacite®, Nafion®, SentryGlas®, and PVF
(polyvinyl fluoride resin), process stormwater, sanitary wastewater, and co_ -neutralized
regenerate from said treated facilities through internal outfall 001;
3. Discharge stormwater, non -contact cooling water, boiler blowdown and condensate,
cooling tower blowdown, and treated wastewater effluent from 001, through outfall 002
at the location specified on the attached map into the Cape Fear River, a class C, WS-1V
water in the Cape Fear River Basin.
DEQ-CFW 00075311

Permit NC0003573
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked,
and as of this issuance, any previously issued permit bearing this number' is no longer effective.
Therefore, the exclusive authority to operate and discharge from this facility arises under the permit
conditions, requirements, terms, and provisions included herein.
The Chemours Company PC, LLC
is hereby authorized to:
Continue to operate existing wastewater treatment facilities consisting of:
• equalization;
• neutralization;
• aerated pre -digester tank;
• nutrient feed system;
• aeration tank;
• three clarifiers;
• effluent flow measurement;
• DAF unit;
• rotary filter for sludge thickening;
• sludge pump;
• sludge filter press; and
• steam heated sludge dryers.
2. Discharge treated process wastewater from ButaciteO, Nafion0, SentryGlasO, and PVF
(polyvinyl fluoride resin), process stormwater, sanitary wastewater, and. co -neutralized
regenerate from said treated facilities through internal outfa11001;
3. Discharge stormwater, non -contact cooling water, boiler blowdown and condensate,
cooling tower blowdown, and treated wastewater effluent from 001, through outfall 002
at the location specified on the attached map into the Cape Fear River, a class C, WS-1V
water in the Cape Fear River Basin,
DEQ-CFW 00075312

Permit NC0003573
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning e the effective date . Much discharges shalermit and l be limited and expirationthrough the date,
bythe
thePPer1mittee as specified
ittee is authorized
to discharge from Outfall 001. S g
below:
PARAMETER
Flow (MGD)
BOD5, 20° C
Total Suspended Solids
Temperature
Oil & Grease
pH
40 CFR 414 Subpart I
EFFLUENT LIMITATIONS
Monthly Daily
Avera e Maximum
MONITORING REQUIREMENTS
urementT Sample T Sample
jEOContinuous
18E2.61bs/day:] E484.7lbs/day 3/Week
303.1lbs/day s/day 3/Week
Weekly
Monthly
Between 6.0 and 9.0 Standard Units 3/Week
See Condition A. (2)
Recording
Composite
Composite
Grab
Grab
Grab
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.
DEQ-CFW 00075313

Permit NC0003573
A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - SUBPART I
Beginning on the effective date of this permit and lasting through the expiration date, the Permittee shall comply
with the limitations and monitoring frequencies established below at outfall 001:
PARAMETER
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average'
Daily
Maximum'
Measurement
Frequency
Sample
Type
Sample
Location
Acenaphthene
0.166
0.444
See Note 2
Grab
Effluent
Acenaphthylene
0.166
0.444
See Note 2
Grab
Effluent
Acrylonitrile
0.723
1.821
See Note 2
Grab
Effluent
Anthracene
0.166
12.8 ug/L
See Note 2
Grab
Effluent
Benzene
0.278
1.024
See Note 2
Grab
Effluent
Benzo(a)anthracene
0.166
0.444
See Note 2
Grab
Effluent
.3,4-Benzofluoranthene
0.173
0.459
See Note 2
Grab
Effluent
Benzo(k)fluoranthene
0.166
0.444
See Note 2
Grab
Effluent
Benzo(a)pyrene
0.173
0.459
See Note 2
Grab
Effluent
Bis(2-ethylhexyl) phthalate
0.775
2.100
See Note 2
Grab
Effluent
Carbon Tetrachloride
0.135
0.286
See Note 2
Grab
Effluent
Chlorobenzene
0.113
0.211
See Note 2
Grab
Effluent
Chloroethane
0.783
2.017
See Note 2
Grab
Effluent
Chloroform
0.158
0.346
See Note 2
Grab
Effluent
2-Chlorophenol
0.233
0.738
See Note 2
Grab
Effluent
Chrysene
0.166
0.444
See Note 2
Grab
Effluent
Di-n-butyl phthalate
0.203
0.429
See Note 2
Grab
Effluent
112-Dichlorobenzene
0.580
1.227
See Note 2
Grab
Effluent
113-Dichlorobenzene
0.233
0.331
See Note 2
Grab
Effluent
1,4-Dichlorobenzene
0.113
0.211
See Note 2
Grab
Effluent
1,1-Dichloroethane
0.166
0.444
See Note 2
Grab
Effluent
1,2-Dichloroethane
0.512
1.588
See Note 2
Grab
Effluent
1,1-Dichloroethylene
0.120
0.188
See Note 2
Grab
Effluent
1,2-trans-Dichloroethylene
0.158
0.406
See Note 2
Grab
Effluent
2,4-Dichlorophenol
0.294
0.843
See Note 2
Grab
Effluent
1,2-Dichloropropane
1.152
1.731
See Note 2
Grab
Effluent
1,3-Dichloropropylene
0.218
0.331
See Note 2
Grab
Effluent
Diethyl phthalate
0.610
1.528
See Note 2
Grab
Effluent
2,4-Dimethylphenol
0.135
0.271
See Note 2
Grab
Effluent
Dimethyl phthalate
0.143
0.354
See Note 2
Grab
Effluent
4,6-Dinitro-o-cresol
0.587
2.085
See Note 2
Grab
Effluent
2,4-Dinitrophenol
0.534
0.926
See Note 2
Grab
Effluent
2,4-Dinitrotoluene
0.851
2.145
See Note 2
Grab
Effluent
2,6-Dinitrotoluene
1.919
12.3 ug/L
See Note 2
Grab
Effluent
[Ethylbenzene
0.241
0.813
See Note 2
Grab
Effluent
DEQ-CFW 00075314

Permit NC0003573
A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - SUBPART I (CONTUNUED)
Beginning on the effective date of this permit and lasting through the expiration date, the Permittee shall comply
with the limitations and monitoring frequencies established below at outfall 001:
PARAMETER
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
:::,Monthly
Average'
Daily
Maximum'
Measurement
Frequency
Sample
Type
Sample
Location
Fluoranthene
0.188
28.2 ug/L
See Note 2
Grab
Effluent
Fluorene
0.166
0.444
See Note 2
Grab
Effluent
Hexachlorobenzene
0.113
0.5 µg/L
Annually3
Grab
Effluent
Hexachlorobutadiene
0.151
0.369
See Note 2
Grab
Effluent
Hexachloroethane
0.158
0.406
See Note 2
Grab
Effluent
Methyl Chloride
0.647
1.430
See Note 2
Grab
Effluent
Methylene Chloride
0.301
0.670
See Note 2
Grab
Effluent
Naphthalene
Nitrobenzene
0.166
0.203
0.444
0.512
See Note 2
See Note 2
Grab
Grab
Effluent
Effluent
2-Nitrophenol
0.309
0.519
See Note 2
Grab
Effluent
4-Nitrophenol
0.542
0.933
See Note 2
Grab
Effluent
Phenanthrene
0.166
0.444
See Note 2
Grab
Effluent
Phenol
0.113
0.196
See Note 2
Grab
Effluent
Pyrene
0.188
0.504 -
See Note 2
Grab
Effluent
Tetrachloroethylene
0.166
0.422
See Note 2
Grab
Effluent
Toluene
0.196
0.602
See Note 2
Grab
Effluent
1,2,4-Trichlorobenzene
0.512
1.054
See Note 2
Grab
Effluent
1,1,1-Trichloroethane
0.158
0.406
See Note 2
Grab
Effluent
1,1,2-Trichloroethane
0.158
0.406
See Note 2
Grab
Effluent
Trichloroethylene
0.158
0.406
See Note 2
Grab
Effluent
Vinyl Chloride
0.783
2.017
See Note 2
GrabMEffluent
Total Chromium
8.355
20.849
Annually
Grab
Total Copper
10.914
25.441
Annually
GrabTotal
Cyanide
3.161
9.032
See Note 2
Grab
Total Lead
2.409
5.194
See Note 2
Grab
Effluent
Total Nickel
12.720
29.957
Annually
Grab
Effluent
Total Zinc
7.903
19.645
Annually
Grab
Effluent
Notes-
1. All units are lbs/day unless otherwise noted.
2. Monitoring for the specified parameters has been waived based on a demonstration made by the Permittee in
accordance with 40 CFR 122.44(a)(2)(i). This waiver is good only for the term of the permit. Please note that
any exceedence of the effluent limitations found herein shall be considered a permit violation subject to
appropriate enforcement action.
ailable shall be employed for determining the presence of
3. The most sensitive analytical method av
hexachlorobenzene in the effluent.
DEQ-CFW 00075315

Permit NC0003573
A. (3) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of this permit and lasting through the expiration date, the Permittee is authorized
to discharge from Outfall 002 (boiler blowdown, once -through cooling water, and treated wastewater from
outfall 001) Such discharges shall be limited and monitored by the Permittee as specified below:
PARAMETER
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
FrequencyELequenSy
Sample
Tye
Sample
Location'
Flow (MGD)
Continuous
Recording
Effluent or
Influent
Temperature, °C
See Note 2
Daily3
Grab
Effluent,
Upstream,
Downstream
BOD5, 20°C
Quarterly
Composite
Effluent
COD
Quarterly
Composite
Effluent
Fluoride (ug/L)
Quarterly
Grab
Effluent
Dissolved Oxygen
Weekly
Grab
Upstream,
Downstream
PFOA4
Monthly
Grab
Effluent
Total Phosphorus
Monthly
Composite
Effluent
Total Nitrogen
(NO2+NO3+T1�
Monthly
Y
Composite
mp
Effluent
Conductivity
Weekly
Grab
Upstream,
Downstream
Chronic Toxicity
See Note 5
Quarterly
Composite
Effluent
pH
Between 6.0 and 9.0 Standard Units
3/Week
Grab
Effluent
Notes:
1. Upstream shall be at the Permittee's river pump station; downstream shall be at the boat ramp approximately
4500 feet downstream at Prospect Hall Landing.
As a participant in the Middle Cape Fear River Basin Association, the instream monitoring requirements as
-stated above are waived. Should your membership in the agreement be terminated, you shall notify the
Division immediately and the instream monitoring requirements specified in your permit shall be reinstated.
2. The temperature of the effluent shall be such as not to cause an increase in the temperature of the receiving
stream of more than 2.8°C and in no case cause the ambient water temperature to exceed 32°C.
3. Daily shall be defined as every day except Saturdays, Sundays, and legal hohdays..Instream temperature
sampling shall be conducted weekly.
4. PFOA (Perfluorooctanoic acid) - The Cape Fear River water intake may be sampled for PFOA_ on a monthly
basis and reported as an upstream parameter in DWQ Form — MR-3.
5. Chronic Toxicity (Ceriodaphnia) P/F @ 3.3% February, May, August, November; see condition A. (4) of this
permit. The compliance monitoring point for chronic toxicity shall be downstream of the confluence of outfall
001 and 002.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.
DEQ-CFW 00075316

Permit NC0003573
A. (4) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY) — OUTFALL 002
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Cer-iodaphnia dubia at an effluent concentration of 3.3%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or
"North Carolina Phase Il Chronic Whole Effluent Toxicity Test Procedure" (Revised-February
and 1998)Noveor subsequent
uent
versions. The tests will be performed during the months of February, May, August,
r.
sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment
processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit
limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months
as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998)
or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection
methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP313 for the
pass/fail results and THP313 for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
Attention: Environmental Sciences Section
North Carolina Division of Water Quality
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting. chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the
permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No
Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Section at
the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water
Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include
alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.
DEQ-CFW 00075317

MSL000 M=10-034
Permit NC0003573
A. (5) RE -OPENER CONDITION
This permit shall be modified, or revoked and reissued to incorporate additional toxicity limitations and
monitoring requirements in the event toxicity testing or other studies conducted on the effluent or receiving
stream indicate that detrimental effects may be expected in the receiving stream as a result of this discharge.
A. (6) BIOCIDE CONDITION
The permittee shall not use any biocide except those approved in conjunction with the permit application. The
permittee shall notify the Director in writing not later than ninety (90) days prior to instituting use of any
additional biocide used in cooling systems which may be toxic to aquatic life other than those previously reported
to the Division of Water Quality. Such notification shall include completion of Biocide Worksheet Form 101 and a
map locating the discharge point and receiving stream.
7"

ChagnoThe
� (j��*" Chemours Company 910-483-46810
lsJ Fluoroproducts chemours com
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
CERTIFIED MAIL ARTICLE NUMBER 7002 0860 0006 9104 7828
RETURN RECEIPT REQUESTED
Ms. Wren Thedford
NCDEQ Division of Water Resources
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
SUBJECT: NPDES Permit Renewal Application
NPDES Permit No. NC0003573
Dear Ms. Thedford:
April 27, 2016
RECBVED/NCDEQ/DWR
MAY 017016
Water Quality
Permitting Section
The Chemours Company — Fayetteville Works is requesting renewal of NPDES Wastewater
Discharge Permit No. NC0003573. Since the issuance of the last permit, the ownership of this
facility changed from the DuPont Company to The Chemours Company FC, LLC. Also, two
separate companies, Kuraray America Inc. and the DuPont Company, are operating manufacturing
units and are treating and discharging their wastewaters under the Chemours' NPDES Permit.
Enclosed are the original and two copies of the General Information Form 1 (Form 3510-1),
Wastewater Discharge Information Form 2C (Form 3510-2C), and additional required supporting
documentation for renewal of the subject permit by the NC Division of Water Resources.
Included in the permit application are the following supplemental information documents: Sludge
Management Plan, Current Facility Wastewater Management, Current Facility Operating
Conditions, Alternate Application Schedule for §316(b) of the Clean Water Act, Elimination of
Monitoring Requirement for PFOA, and the non -reporting of bis(chloromethyl) ether.
If you have any questions or need additional information, please contact me at [phone].
Enclosures
DEQ-CFW 00075319

a Aleatse print or type in the unshaded areas only
Form Approved OMB No 2040-0086
FORM
U S. ENVIRONMENTAL PROTECTION AGENCY
I EPA I D NUMBER
1
\-.EPA GENERAL INFORMATION
s
TIA c
F
Consolidated Permits Program
NCD 04 7 3 6 8 6 4 2 1 D
GENERAL
(Read the "Generalltntrucaons" before starting)
,
2 31 14 1 15
LABEL ITEMS
GENERAL INSTRUCTIONS
If a preprinted label has been provided, affix it in the
designated space Review the information carefully, if any of it
I. EPA 1 D NUMBER
is incorrect, cross through it and enter the cores data in the
appropriate fill-in area below Also, if any of the preprinted data
is absent (the area to the heft of the label space lists the
III. FACILITY NAME PLEASE PLACE LABEL IN THIS SPACE information that should appear), please provide it in the proper
fill-in area(s) below If the label is complete and correct, you
V. FACILITY MAILING
need not complete Items I, III, V, and VI (except Vl-B which
ADDRESS
must be completed regardless) Complete all dams d no label
has been provided Refer to the instructions for detailed deco
VI FACILITY LOCATION
descriptions and for the legal authorizations under which this
date is collected
II POLLUTANT CHARACTERISTICS
INSTRUCTIONS Complete A through J to determine whether.you need to submit any permit application forms to the EPA If you answer'yes' to any questions, you must
submit this forth and the supplemental form listed in the parenthesis following the question Mark 'X" in the box in the thud column if the supplemental form is attached If
you answer'no' to each question, you need not submit any of these fortes. You may answer 'no' if your activity is excluded from permit requirements, see Section C of the
instructions See also, Section D of the instructions for definitions of bold-faced terms
nwk•x•
mark-)V
YES
ATTACHEO
YES
NO
ATTACHED
SPECIFIC QUESTIONS
SPECIFIC QUESTIONS
A Is this facility a publicly owned treatment works which
B Does or will this facility (either existing or proposed)
results in a discharge to waters of the U.S.? (FORM 2A)
X
include a concentrated animal feeding operation or
aquatic animal production facility which results In a
1e
1T
is
19
2D
r
discharge to waters of the U.S.? (FORM 2B)
C Is this a facility which currently results in discharges to
X
X
D Is this a proposed fatality (other than those described in A
waters of the U.S. other than those described in A or B
or 8 above) which will result in a discharge to waters of
X
above? (FORM 2C)
the U.S.? (FORM 2D)
22
23
1 24
2e
26
27
E Does or will this facility treat, store, or dispose of
F Do you or will you inject at this facility industrial or
hazardous wastes? (FORM 3)
X
municipal effluent below the lowermost stratum
X
containing, within one quarter mile of the well bore,
28
20
90
underground sources of drinking water? (FORM 4)
s,
G Do you or will you inject at this facility any produced water
H Do you or will you inject at this facility fluids for special
or other fluids which are brought to the surface in
processes such as mining of sulfur by the Frasch process,
connection with conventional or) or natural gas production,
X
solution mining of minerals, in situ combustion of fossil
X
inject fluids used for enhanced recovery of oil or natural
fuel, or recovery of geothermal energy? (FORM 4)
gas, or inject fluids for storage of liquid hydrocarbons?
(FORM 4)
3
x
37
b
30
I Is this facility a proposed stationary source which is one
J Is this facility a proposed stationary source which is
of the 28 industrial categories listed in the instructions and
�/
X
NOT one of the 28 industrial categories listed in the
X
which will potentially emit 100 tons per year of any air
instructions and which will potentially emit 250 tons per
pollutant regulated under the Clean Air Act and may affect
year of any air pollutant regulated under the Clean Air Act
ao
41
n
4
.5
or be located in an attainment area? (FORMS)
and may affect or be located in an attainment area?
(FORM 5)
III NAME OF FACILITY
c
I SKIP I C amours Company - Fayetteville Works
1e fe - 29 >D
60
IV FACILITY CONTACT
A NAME & TITLE (last, first, & title)
B PHONE (area code & no)
1,2
Johnson, ichael, nvironmen a onager(
1 ) 6 8-1 5
16
45 46 49 1 a9 sf ei- 55
V. FACILTY MAILING ADDRESS
A STREET OR PO BOX
c
3 2 828 NC Highway 87
1s to
n
B CITY OR TOWN
C STATE D ZIP CODE
4 Fayettevi le
Jc
1s is
C 2 3 6
al a1 a2 6 e1
M. FACILITY LOCATION
A STREET, ROUTE NO OR OTHER SPECIFIC IDENTIFIER
c
5 2 18 1 8 NC i9hway S
u 1e
43
B COUNTY NAME
Bladen
46
m
C CITY OR TOWN
D STATE
E ZIP CODE
F COUNTY CODE (if known)
16
F y t e i l
C
2 3 6
3 017
1s
1e
40
at a
ar 51
et sa
EPA Forth 351 D-1 (8-9D)
CONTINUE ON REVERSE
DEQ-CFW 00075320

GVr711NUtU rKUIVI I r r- rrtLnV I
VII SIC CODES 4-di it, in order of rion
A FIRST B SECOND
(sped) INDUSTRIAL ORGANIC CHEMICALS t
7
3083
(1peC�) LAMINATED PLASTICS PLATE, SHEET, AND PROFILE SHAPES
2869
15 16
19
16
16 ".
C THIRD D FOURTH
c
713081
(specify)UNSUPPORTED PLASTICS FILM AND SHEET c
NOTE Kuraray Butacite ButaciteO and SentryGla9m sheeting 7
2821
'
(tpech) PLASTIC MATERIALS AND RESINS
NOTE: DuPont PVF resin procesa unite
15 16
19
process units 15
16 19
VIII OPERATOR INFORMATION
B. Is the name listed in Item
A NAME
o
VIII-A also the owner?
s The
Chemours Company FC, LLC
55
0 YES ❑ NO
ee
15 lie
C. STATUS OF OPERATOR (linter the appropriate letter into die antli'er box if 'Other, "specify)
D PHONE (area code dr no )
F =FEDERAL M=PUBLIC(otherthonfederalorstate)
p
6pecify)
q
[phone]
S=STATE
0 = OTHER (specify)
se
zi a ze
P = PRIVATE
E STREET OR P 0 BOX
1 0 arket treet
55
F CITY OR TOWN
G STATE
H ZIP CODE
JIX INDIAN LAND
c
I I I I I I I I I
I I I
Is the facility located on Indian lands?
B
15 Ifi
Wilmington
W
DE
41 @
19898
47 - 51
❑ YES © NO
I 51
X EXISTING ENVIRONMENTAL PERMITS
A NPDES Dacha es to Surface Water
D PSD Air litntsvons from Pro aged Sources
777
NC0003573
�151'1
T
NC Title V Permit 03735
s
N
15
16
A 19
306
17
16
B UIC Under roundInectionofFfurds
E OTHER(soeci
C
T
I
NSA
c
9
T
I
1(specify)
W 0 3 431
Land Application Permit
9
U
15
IB
f7 19
30
15
18
17
I9
C RCRA ffaues
E OTHER s ecr
C
T
I
pzigLdrotts
NCD047368642
C I T I (spec)
g
9
R
15
16
17 16
30
1 151 16117 Jill 70
XI MAP
Attach to this application a topographic map of the area extending to at least one mile beyond property boundaries. The map must show the outline of the facility, the
location of each of its existing and proposed Intake and discharge structures, each of its hazardous waste treatment, storage, or disposal facilities, and each well where it
Injects fluids underground Include all springs, rivers, and other surface water bodies in the map area. See instructions for precise requirements
XII. NATURE OF BUSINESS (prowdea bnefdescn tion)
The Chemours Company - Fayetteville works (formerly the DuPont Company - Fayetteville Works) is a fluorinated
chemicals manufacturer situated on'a 2,200-acre property in northwestern Bladen County, NC.
The Chemours' products produced at the facility include fluorinated monomers and fluorinated vinyl ethers,
Nafion"' membranes and dispersion, and fluoropolymer processing aids. Chemours operates two natural gas / fuel
oil -fired boilers, which provides steam for the entire facility.
Also located at this facility are two tenant companies: Kuraray America Inc. and the DuPont Company. Kuraray
operates the Butacitem polyvinyl butyral (PVB) thermoplastic sheet and resin manufacturing unit and the
SentryGlasO ionoplast interlayer manufacturing unit. DuPont operates two polyvinyl fluoride (PVF) resin
manufacturing units.
Chemours receives and treats all of the Kuraray and DuPont process wastewater, sanitary wastewater, and contact
stormwater in the Chemours' owned and operated wastewater treatment plant, and discharges that treated
wastewater through Outfall 001 under the Chemours' NPDES Wastewater Discharge Permit (Permit No. NC0003573).
The Kuraray and DuPont non -contact cooling waters and stormwaters are discharged through Outfall 002 under the
Chemours' NPDES Wastewater Discharge Permit.
XIII CERTIFICATION (see instructions)
I certify under penalty of law that I have personally examined and am familiar with the information submitted in this application and all attachments and that, based on my
inquiry of those persons immediately responsible for obtaining the information contained in the applicatio I believe that the information is true, accurate, and complete 1
am aware that there are significant penalties for submitting false information, including the possibility of ft and imprisonment
A. NAME & OFFICIAL TITLE (type or print) BSI
ATURE"VVVV
C DATE SIGNED
% 1001
Ellis H. McGaughy - Plant Manager
I G p
COMMENTS FOR OFFICIAL USE ONLY
c
C
1s
55
1e
'
EPA Form 3510-1 (8-90)
DEQ-CFW 00075321

UNITED STATES DUART QUADRANGLE STATE OF NORTH CAROLINA
NORTH CAROLINA
DEPARTMENT OF NATURAL RESOURCI
DEPARTMENT OF THE INTERIOR AND COMMUNITY DEVELOPMENT
7.5 MINUTE SERIES (TOPOGRAPHIC)
a+RALEIGH. N. C.
GEOLOGICAL SURVEY aM, snr vAus IS' quwd+ANc,E
78" 5' 30" 695� C :.o ' .: ,` a97 5 699 (CEDARIV NE
CREEK)
' 52, 30"-
':Clam NM
/ am
,rlJ`�
C ` ake I J
ek - \ �kI 0.
%Tanks _ �(C r
a Ise
I �- 0
A57 _ Y'lat,(1
1 -� FACILITY LEGAL
+ m0 Dam BOUNDARY '� �"-- tme na No 3
$G'
N.
1 \ }1 \
Mla6
4I
SCALE 1:29 000
S ;
,�_.�....... MILES
2000 3000 a _ �000 5000 g.`pp� 10` !7
0� 2000
CONTOUR INTERVALS FEET �,• _ \
NATIONAL GCODETIC VERTICAL DATUM OF 1929 .
Duart
p `5 �' Roads y
THIS MAP COMPLIES WITH NATIONAL MAP ACCURACY STANDARDS %am,30 — ---��
47' 30" i- "�� FOR SALE BY U. S. GEOLOGICAL SURVEY, DENVER. COI.ORADO 80220, OR RESTON. VIRGINIA 22092
r \ A FOLDER DESCRIBING TOPOGRAPHIC MAPS AND SYMBOLS IS AVAILABLE ON REQUEST,
DEQ-CFW 00075322

CHEMOURS COMPANY - FAYETTEVILLE WORKS
LOCATIONS OF INTAKE AND DISCHARGE STRUCTURES
DEQ-CFW 00075323

CHEMOURS COMPANY - FAYETTEVILLE WORKS
LOCATIONS OF HAZARDOUS WASTE MANAGEMENT FACILITIES
DEQ-CFW 00075324

EPA I D. NUMBER (coin tnnu tr,in I afl brm 1) Form Approved-
OMB
047 368 642 OMB No. 2040-0086.
ADDroval expires 3-31-98
FORM
U.S. ENVIRONMENTAL PROTECTION AGENCY
2C
APPLICATION FOR PERMIT TO DISCHARGE WASTEWATER
AO" EPA EXISTING MANUFACTURING, COMMERCIAL, MINING AND SILVICULTURE OPERATIONS
410
Consolidated Permits Program
NPDES
I OUTFALL LOCATION
For each outfall, list the latitude and longitude of its location to the nearest 15 seconds and the name of the receiving water.
A. OUTFALL NUMBER
B. LATITUDE
C. LONGITUDE
(h,l)
D. RECEIVING WATER (nanw)
1 DEG
1 2 MIN
3 SEC
1 DEG
2 MIN
3 SEC,
001
34.00
50.00
22.93
-78.00
50.00
11.47
Cape Fear River
002
34.00
50.00
21.58
-78.00
49.00
25.70
Cape Fear River
11. FLOWS, SOURCES OF POLLUTION, AND TREATMENT TECHNOLOGIES
A Attach a line drawing showing the water flow through the facility. Indicate sources of intake water, operations contributing wastewater to the effluent, and treatment units
labeled to correspond to the more detailed descriptions in Item B- Construct a water balance on the line drawing by showing average flows between intakes, operations.
treatment units, and outtalls. If a water balance cannot be determined (e.g., for certain mining activities), provide a pictorial description of the nature and amount of any
sources of water and any collection or treatment measures.
8 For each outfall, provide a description of (1) All operations contributing wastewater to the effluent, including process wastewater, sanitary wastewater, cooling water,
and storm water runoff. (2) The average Flow contributed by each operation: and (3) The treatment received by the wastewater Continue on additional sheets if
necessary
1 OUT-
2. OPERATION(S) CONTRIBUTING FLOW
3. TREATMENT
FALL
b AVERAGE FLOW
b LIST CODES FROM
NO. (le,i)
a. OPERATION (h,i)
(unh"I"+uu1')
a. DESCRIPTION
TABLE 2C-1
C:+ert:
:t; :-c +�ant:`a �-!:.'in1 r_o::e •��
-
1=. �. SG1 �al!da},
=:1?:.Li::I �A:- WASI_hAT=F T.E:AlT.E7T P:l::'
poi
.:ra ray c aa. ite K`_� ?recess
-
;•5 F_; gal %da;:
t1i In°lue::^ Sc¢c
_
- •-
Ffo 2:ocess
_ aalJd:ry
-. Frlcali�artaa --;-: mlr.i np anti
N_e,
_V_
- -
_
.,_..E54
D=•¢i❑
W—e:?eaer.'-•3ce
4 __<-Ciaescea TasY.
_
-n::ita:'y
S.W _,
10, C�Vfi aa1.'uay
r•.1 a�"iva _e.i 61 L:�ye Av. a^lc:t '1'a-tl:
A
- IT
51, 21E a,l'*iay
^la:-i`i. 711:: ^-l:i_I f1-2 1..
"CO'I'AL
I:-,FL'J_:iT TO W'.- d-
1, 2V5,?3c ,al%day
`_.r,
.q;u. -i^❑ _.:;m Sltmiae Drying
19. 943 yal/day
il -, Dissolved Ai: Flccaiian
'
-JI'r AL— -.-".1 .;-'1'A:. '�FF'�;J2:i'l'
.,lii,A=3 pal%day
.. S'_t:d�e Fi.l�e_
-
-
: 5:' li::r-•..cal .,- :.--. _ ..:,.i i_:11
S Q
002
.`.;11 i,°lve:,-.
1, 1:',, 412 _tal.'da•/
.t r-;aca-•. 'i lrezFl ..acec
1, 9t 3, v.=� aal!d.y
- co-m:�acee
-
OFFICIAL USE ONLY (.y(Lnwr Ku dchiw ,trG-rate,vi, ,)
EPA Form 3510-2C (8-90) PAGE 1 of 4 CONTINUE ON REVERSE
DEQ-CFW 00075326

CONTINUED FROM I Ht FnUN I
C. Except for storm runoff. leaks, or spills, are any of the discharges described in Items 11-A or B intermittent or seasonal?
❑ YES (<,unplere the till.. my t+rhlr) m NO (vo lit Se, non 111)
3 FREQUENCY
4 FLOW
a. DAYS PER
B TOTAL VOLUME
2 OPERATION(s)
WEEK
b MONTHS
a FLOW RATE (:J)
{yK-c ifr i mr rnrn,)
C DURATION
1 LONGTERM
2 MAXIMUM
1 LONGTERM
2 MAXIMUM
1. OUTFALL
CONTRIBUTING FLOW
('1a 0
PER YEAR
(ur +Ln .)
NUMBER (lr.,)
h>r
( 1
-vnitrl
(y,e<v/i moult,)
AVERAGE
DAILY
AVERAGE
DAILY
111. PRODUCTION
A. Does an effluent guideline limitation promulgated by EPA under Section 304 of the Clean Water Act apply to your facility?
0 YES (,wnph-le hrrn 1p-tf) ❑ NO (c++ w Srrhnu /I )
B. Are the limitations in the applicable effluent guideline expressed in terms of production (or other measure of operation)?
❑ YES (<omplele Item l/I-( ) W] NO(,!,, ru .\'e, twit P )
C- If you answered "yes" to Item III-B, list the quantity which represents an actual measurement of your level of production. expressed in the terms and units used in the
applicable effluent guideline. and indicate the affected outtalls.
1. AVERAGE DAILY PRODUCTION
2. AFFECTED OUTFALLS
(!r.>r+,net+rl/ ruunbrrc)
e. OPERATION. PRODUCT. MATERIAL. ETC.
a. QUANTITY PER DAY
b. UNITS OF MEASURE
(cpr<•rh)
IV. IMPROVEMENTS
A. Are you now required by any Federal. State or local authority to meet any implementation schedule for the constriction, upgrading or operations of wastewater
treatment equipment or practices or any other environmental programs which may affect the discharges described in this application? This includes. but is not limited to.
conditions, administrative or enforcement orders, enforcement compliance schedule letters. stipulations. court orders, and grant or loan conditions.
permit
❑ YES (ronrld -w t& lbhon'ur¢ rnhk) © NO (e" ro hewn W-B)
1 IDENTIFICATION OF CONDITION.
2. AFFECTED OUTFALLS
3, BRIEF DESCRIPTION OF PROJECT
4. FINAL COMPLIANCE DATE
AGREEMENT, ETC.
a NO.
b SOURCE OF DISCHARGE
a REQUIRED
b. PROJECTED
r
B. OPTIONAL You may attach additional sheets describing any additional water pollution control programs (or other environmental projects which may affect your
discharges) you now have underway or which you plan. Indicate whether each program is now underway or planned. and indicate your actual or planned schedules for
construction
❑ MARK -X" IF DESCRIPTION OF ADD)TIONAL CONTROL PROGRAMS IS ATTACHED
EPA Form 3510-2C (8-90) PAGE 2 of 4 GUN I mur UN YHUC J
DEQ-CFW 00075327

EPA I.D. NUMBER (copt _/inn lfrn l n1 /'w-In 1)
CONTINUED FROM PAGE 2 NCD 047 368 642
V INTAKE AND EFFLUENT CHARACTERISTICS
A. B. & C See instructions before proceeding — Complete one set of tables for each outfall — Annotate the outfall number in the space provided
NOTE: Tables V-A. V-B. and V-C are included on separate sheets numbered V-1 through V-9.
D. Use the space below to list any of the pollutants listed in Table 2c-3 of the instructions, which you know or have reason to believe is discharged or may be discharged
from any outfall. For every pollutant you list, briefly describe the reasons you believe it to be present and report any analytical data in your possession.
1. POLLUTANT
2. SOURCE
1. POLLUTANT
2. SOURCE
Nune of the pollutants listed
_
in Table 2C-3 are believed to
to present in the wastewater
discharge from thi site.
Vl. POTENTIAL DISCHARGES NOT COVERED BY ANALYSIS
Is any pollutant listed in Item V-C a substance or a component of a substance which you currently use or manufacture as an intermediate or final product or byproduct?
m YES (hw all ma-li p lltrranie hehm ). ❑ NO 6!a /u lien 17-M)
Antimony
Benzene
1,2-dichloroethane
Methylene chloride
Toluene
EPA Form 3510-2C (8-90) PAGE 3 of 4 CONTINUE ON REVERSE
DEQ-CFW 00075328

CONTINUED FROM THE FRONT
VII. BIOLOGICAL TOXICITY TESTING DATA
Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on a receiving water in
relation to your discharge within the last 3 years?
© YES (rdentilt II, rcati/ and dc,i rrhr Ih,n• pr,rpra hdhn, ) ❑ NO Lvo to Smug» I7/1)
The "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure" is performed each quarter in accordance
with the requirement of condition A(4) of the facility's NPDES Permit. The NCDEQ Division of Water Resources
has copies of the Form AT-1 test results that were submitted with the Discharge Monitoring Reports during the
period from February 2012 through February 2016.
The quarterly chronic test performed during February 2012, failed for the ceriodaphnia
dubia reproduction.
The required monthly chronic tests performed in March and April 2012 both passed. No other toxicity test
failures occurred during the five-year term of the current permit.
VIII. CONTRACT ANALYSIS INFORMATION
Were any of the analyses reported in Item V performed by a contract laboratory or consulting firm?
® YES (h,i the rnum, oddr: ,,_ mnl rrleph"lle »anrhrr ot. crud/+u1/rrrmlb onolrc. d /a. ❑ NO (,Cn m Frcrron Lt)
:.rrL sra lr luhnr,uorr or /inn h.•!ou)
C. TELEPHONE
D.POLLUTANTS ANALYZED
A NAME _
B ADDRESS
(aria rnd" d' no_)
(list)
TBL
2401 west 5th St[eet
910-738-6190
Chemical Oxygen Demand
Lumberton, NC 2835E
(COD); Total Organic
Carbon (TOC); Total
Susoerded Solids (TSS);
Ammonia (as N); Color;
Fecal Colifo_-m; Fluoride;
Nitrate -Nitrite (as N);
Nitrogen; Total Organic
tas N); Oil and Grease;
Tctal Phosphorus (as P);
Sulfate (as SO4);
Surfactants; Total
Aluminum; Total Iron;
Total Magnesium; Total
Manganese; Part C Metals,
Cyanide, and Total Phenols;
Pert C GC/MS - Volatile
Compounds; Part C GC/MS -
Acid Compounds; Part C
OCIMS - Base/Neutral
Compounds; Part C GC/M
Fraction - Pesticides
IX. CERTIFICATION
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that
qualified personnel property gather and evaluate the information submitted Based on my inquiry of the person or persons who manage the system or those persons
directly responsible for gathering the information, the information submitted is. to the best of my knowledge and belief, true. accurate. and complete. t am aware that there
are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.
A NAME & OFFICIAL TITLE (npr orpruu)
B PHONE NO. (,rrru r.nh A m, )
Ellis H. McGaughy - Plant Klan er
[phone]
C SIGN URE ,/ 4
0 DATE SIGNED
1
EPA Form 3510-2C (8-90) v U V PAGE 4 of 4
DEQ-CFW 00075329

FORM 2C ITEM IAA : LINE DRAWING NPDES PERMIT RDISNAL APPLICATION
Ck ursCOW-Fay bAlkWorks
WATER BALANCE jRevised 0421.2011i► NPDES Permfl NO. NC00035T3
Flow Unds: Gallons per Day
Basis: (1) Al Manu(adit Units operalklg
(2) Matlmum My average of measured flows (2013. 2015)
~ Cape Fear River
F&►ed W99
RLTERED r ,
AC<
�aet
YA,�
61tm�atlii�
T
1
!
Water
EIE
rum;tmtu KURARAYANERM KUNRAYAIERiCAS 'DUPOMT DUPONT
POTABLE�7 �A
CHMOURS ' BUTACe SENTRYMA POLYVBYL POLYVINYL
WATER 1O0D FLUOROP80DT POLYVRIYLBUTYRAL IAWATE RUM FLUORDE
MUFAMRMG MANUFACTURING MANUFACTURRIG i RESi RESM
SANITARY PROCESS PROCESS PROCESS11 PROCESSa2
FACaiIES e�
STORK•
WA1ER EWn 10S,82T
0, �- 15000T t
T 7
wim-
stma w
AMATED CLA�fI
DO SLUDGE e CATION
E�aalam 1, BKNKI u
DEWATER
Bottumye 2A93 DRYNIG
g
@
$ $
U U
U
i �
$
i pep
"e
U U
U
i g
z
DEQ—CFW 00075330

OUTFALL 001
PLEASE PRINT OR TYPE IN THE UNSHADED AREAS ONLY. You may report some or all of this information EPA I.D NUMBER (copy from item I of Form 1)
on separate sheets (use the some format) instead of completing these pages NCD 047 368 642
SEE INSTRUCTIONS,
OUTFALL N0,
V. INTAKEAND EFFLUENT CHARACTERISTICS (conbnuedfrom page 3 of Form 2-C)
of
PART A -You must provide the results of at least one analysis for every pollutant in this tape. Complete one table for each oubll. See instructions for additional details,
3. UNITS
4, INTAKE
2, EFFLUENT
(specr%vr(blank)
(op"60
b. MAXIMUM 30 DAY VALUE
c. LONG TERM AVRG, VALUE
a. LONGTERM
a MAXIMUM DAILY VALUE
(f adaNe)
(fmrodablej
AVERAGEVALUE
I NO. OF
a. CONCEN-
b. NO, OF
1. POLLUTANT I CONCENTRATION
(2) MASS
CONCENTRATION
(2) MASS
(1) CONCENTRATION
p) MASS
ANALYSES I
TRATION
b. MASS I
CONCENTRATION
(2) MASS
ANALYSES
a, Biochemical Oxygen
Demand (E01))
71.0
675.9
26.8
207.1
5.8
37.8
465
mg/L
lb.
n/a
n/a
n/a
b. Chemical Oxygen
Demand(COD)
32.1
313.2
1
mg/L
lb.
n/a
n/a
n/a
(T�} lOrganicCarbon
84.9
828,4
1
mg/L
lb.
n/a
n/a
n/a
d. Total Suspended
Solids (A
44.0
387.8
22.0
177.0
9.8
54.6
465
mg/L
lb,
n/a
n/a
n/a
a.Ammonia (asN)
0,414
4.0
1
mg/L
lb.
n/a
n/a
n/a
VALUE
VALUE
VALUE
VALUE
f.now
1.627
1.133
0.907
1095
MGD
MGD
n/a
n/a
g Temperature VALUE
VALUE
VALUE
VALUE
(wrnrer)
26.0
22.2
18.4
118
°C
n/a
n/a
h, Temperature
VALUE
VALUE
VALUE
VALUE
(nnnmer)
32.0
30.6
29.0
118
°C
n/a
n/a
MINIMUM
MAXIMUM
MINIMUM
MAXIMUM
I. PH
6.37
8.47
n/a
n/a
374
STANDARD UNITS
2a for any pollutant which is limited either
PART B - Mark'X' m column 2a for each pollutant you know or have reason to believe is present Mark'X' in column 2-b for each pollutant you believe to be absent If you mark column
directly, or indirectly but expressly, in an ef8rcent limitations guideline, you must provide the results of at least one analysis for that pollutant For other pollutants for which
you mark column 2a, you must provide
quantitative data or an explanation of their presence In your discharge, Complete one table for each ould. See the mstakhons for additional details and requirement.
2. MARK'X'
3, EFFLUENT
4. UNITS
5, INTAKE (aprional)
1, POLLUTANT
b. MAXIMUM 30 DAY VALUE
c LONG TERM AVRG. VALUE
a. LONG TERM AVERAGE
AND
7BEUEVED
a. MAXIMUM DAILY VALUE
(javataMe)
(r(mvadabte)
VALUE
CAS N0.
jfoulaNe)
EVED
ENT
d. NO.OF
ANALYSES
a. CONCEN-
TRATION
b, MASS
b NO.OF
ANALYSES
(1)
CONCENTRATION
(2)MASS CONCENTRATION
(t)
(2)MASS
1
CONCENTRATION
(2)M.ASS
CONCENTRATION
(2)MASS
a Bromide
�/
(24959-67.9)
X
,Toth
b ChkriResidual sidual
R
X
03
0..
03
1
�/ L
lb.
n a
/
n a
/
n / a
c.Color
X
10
n/a
1
PCU
n/a
n/a
n/a
n/a
d.Fecal Cokfomm
X
est. 2
n/a
1
col/dL
n/a
n/a
n/a
n/a
e, Fluoride
�/
X
170
1659
1
lb.
(169B448.e)
mg/L
n/a
n/a
n/a
If.N(asMtei16mte
X
0.065
0.6
1
mg/L
lb.
n/a
n/a
n/a
EPA Form 351D-2C (8.9D) PAGE V•1 CONTINUE ON REVERSE
DEQ-CFW 00075331

OUTFAII 001
ITEM V-B CONTINUED FROM FRONT
2. MARK'X'
3. EFFLUENT
4, UNITS
5. INTAKE (opaowo
1, POLLUTANT
b. MAXIMUM 30 DAY VALUE
c, LONGTERM AVRG, VALUE
a. LONG TERM
AND
a
b
a. MAXIMUM DAILY VALUE
(f avalable)
(i/mnda*)
AVERAGE VALUE
CAS NO,
BELIEVED
BELIEVED
d, NO. OF
a. CONCEN•
b. NO. OF
(1)
0)
(1)
(1)
(If iNdable)
PRESENT
ABSENT
CONCENTRATION
(2) MASS
CONCENTRATION
(2) MASS
CONCENTRATION
(2) MASS
ANALYSES
TRATION
b. MASS
CONCENTRATION
(2) Mo
ANALYSES
9• Mom,
TotalOrganic(as
x
1.016
9.9
1
mg/L
lb,
n/a
n/a
n/a
It Od and
Grease
<5.6
<50.0
5.2
42.5
0.26
1.87
36
mg/L
lb.
n/a
n/a
n/a
(eS P), Total
x
12.4
121.0
1
mq/L
lb.
n/a
n/a
n/a
(7723.14 )
1. RWmach*
(1)kha,Total
X
(2) Beta, Total
X
(3) Redlum,
�/
x
Total
(4) Radium 226,
Total
k, Sugafe
(also,)
1083
10568
1
mg/L
lb.
n/a
n/a
n/a
(14808.19 e)
I. Sulfide
�/
(01 Al
X
m. Sum
(z-TO
(14265.45.3)
n,SAdants
X
3.07
30.0
1
mg/L
lb.
n/a
n/a
n/a
o.Akno,
TOW
X
0.19
1.9
1
mg/L
lb.
n/a
n/a
n/a
U4294 M
p, Banum, Total
"
0��)
n
q, Boni, Total
944042-8j
r, Cobak Total
�/
(144048�4)
s.Iron, Trial
(743M)
X
0.28
2.7
1
mg/L
lb,
n/a
n/a
n/a
1. Magnesam,
TOW
X
2.26
22.1
1
mg/L
lb.
n/a
n/a
n/a
n43�)
u. Molybdenum,
TOW(7439*9
X
Y. Mangenese,
Total
X
<0.005
<0.049
1
mg/L
lb.
n/a
n/a
n/a
p439.96.5!
w. Tin, Total
\/
x
{7440 15)
3
0dandum,
Total
X
UW4 2.6)
EPA Form 3510.2C (W) PAGE V 2 CONTINUE ON PAGE W
DEQ-CFW 00075332

OUTFALL 001
EPA I.D. NUMBER (cope fmm Item I of form 1) OUTFALL NUMBER
NCD 047 368 642 1001
PART C - If yYou are aprimaryvrindustry and this outfall contains process wastewater, refer to Table 20 2 in the instructions to determine which of the GC/MS fractions you must test for. Mark'X' in column 2-a for all such GCIMS
industi
fractions that apply to your industry and for ALL toxic metals, cyanides, and Total phenols, fl you are not required to mark column 2a (secondary indushres, nonprocess wastewater ouf lis, and nonrequired GCtMS
fractions), mark in column 2-b for each pollutant you know or have reason to believe is present Mark `X' in column 2-c for each pollutant you believe is absent If you mark coumn 2a for any pollutant, you must
provide the results of at least one analysis for that pollufaM. If you mark coumn 2b for any pollutant, you must provide the results of at least one analysis for that pollutant fl you know or have reason to believe it will be
discharged in concentrations of 10 ppb or greater. If you mark column 2b for acroknn, acrylondrde, 2,4 drnitrophend, or 2-methyF4, 6 dmrtrophenol, you must provide the results a at least one analysis for each M these
pollutants which you know or have reason to believe that you discharge in concentrations of 100 ppb or greater. Otherwise, for pollutants for which you mark column 2b, you must either submit at least one analysts or
briefly describe the reasons the pollutant is expected to be discharged, Note that there are 7 pages to this part, please review each carefully Complete one table (all 7 popes) for each oulfall See Instructions for
additional details and requirements,
2, MARK'X'
3. EFFLUENT
4. UNITS
5. INTAKE (opyno
1. POLLUTANT
b MAXIMUM 30 DAY VALUE
c, LONG TERM AVRG,
a. LONG TERM
AND
a
b
c
a. MAXIMUM DAILY VALUE
(f aiwdable)
VALUE (f wadable)
d. NO. OF
a. CONCEN•
AVERAGE VALUE
b NO, OF
(1)
CONCENTRATION
(2) MASS
(1)
CONCENTRATION
(2} MASS
(1)
CONCENTRATION
(2) MASS
11}
CONCENTRATION
(2) MASS
CAS NUMBER
(f available)
TESTING
REQUIRED
BELIEVED
PRESENT
BELIEVED
ABSENT
ANALYSES
TRATION
to MASS
ANALYSES
METALS, CYANIDE, AND TOTAL PHENOLS
iM.Anhmony,Total
X
<0.002
<0.020
1
mg/L
lb.
n/a
n/a
n/a
2M.Arsenic,ToW
X
<0.005
<0.049
1
mg/L
lb.
n/a
n/a
n/a
(744D•38.2)
3M Beryllium, Total
X
<0.001
<0.010
1
mg/L
lb.
n/a
n/a
n/a
(744041.7)
4M.Cadmium, Total
V
<0.002
<0.020
1
mg/L
lb.
n/a
n/a
n/a
(744043.9)
SM.Chromum,
V
X
0.010
0.070
0.010
0.070
0.004
0.034
4
mg/L
lb.
n/a
n/a
n/a
ToW U440.47.3)
6M.Copper, Toul
V
0.007
0.050
0.007
0.050
0.0055
0,047
4
mg/L
lb,
n/a
n/a
n/a
(744050.8}
A
7M,Lead, Total
X
<0.003
(0.029
1
mg/L
lb.
n/a
n/a
n/a
(7092.1)
8M Mercury'Total
V
<0.0002
<0.002
1
mg/L
lb.
n/a
n/a
n/a
(7439.91.6)
/�
9M. Nickel, Total
0,012
0.090
0.012
0.090
0.0083
0,065
4
mg/L
lb.
n/a
n/a
n/a
(7440-02-0)
10M.Selenium,
X
<0.005
<0.049
1
mg/L
lb,
n/a
n/a
n/a
Tow rn82.49.2)
/�
11M Sltver,Total
X
<0.002
<0.020
1
mg/L
lb.
n/a
n/a
n/a
V440.22.4)
!�
12M Thallium,
V
X
<0.005
<0.049
1
mg/L
lb,
n/a
n/a
n/a
Total (7440.28-0)
13M.Zinc, Total
V
0.042
0,390
0,042
0.390
0.0343
0.286
4
mg/L
lb.
n/a
n/a
n/a
(74404H)
A
14M.Cyanide,
�/
<0,005
<0.049
1
mg/L
lb.
n/a
n/a
n/a
Toil (57-12-5)
15M.Phenols,
V
X
<0.0400
<0.390
1
mg/L
lb.
n/a
Total
DIOXIN
2,3,7,8 Teha
DESCRIBE RESULTS not apPlicaeie
chlorodibenzo-P-
X
DroxIn (17601.6)
EPA Form 3510.2C (8.90) PAGE V-3 CONTINUE ON REVERSE
DEQ-CFW 00075333

OUTFALL 001
CONTINUED FROM THE FRONT
2, MARK `X
3 EFFLUENT
4, UNITS
5, INTAKE (ophnna�
1. POLLUTANT
b. MAXIMUM 30 DAY VALUE
c, LONG TERM AVRG,
a. LONG TERM
AND
a
b
c
a. MAXIMUM DAIIY VALUE
(rf amlable)
VALUE (rf m�rlable)
AVERAGE VALUE
CAS NUMBER
TESToG
BELIEVED
BELIEVED
d. NO. OF
a CONCEN
b. NO OF
(1)
(1)
(1)
(tl
(rfauarlable)
REQUIRED
PRESENT
ABSENT
CONCENTRATION
(2)MASS
CONCENTRATION
(2)MASS
CONCENTRATION
pmASS
ANALYSES
TRATION
b.MASS
CONCENTRATION
(2)mAss
ANALYSES
GCIMS FRACTION -VOLATILE COMPOUNDS
W.Accrolem
(107.02.8)
<0.0500
<0.488
1
mg/L
lb.
n/a
n/a
n/a
2V'Ac*o*
(107.13.1)
X
<0.0100
<0.098
1
mg/L
lb.
n/a
n/a
n/a
3V.B 2Jeee
X
c0.00100
<0.10
1
mg/L
lb.
n/a
n/a
n/a
W. &s (Chloro•
�
mdbAEgw
Not Req
ired
per NCDWR
NPDES
Permitt'g
Unit
(5424&1)
�X\
5V.Bmmotorm
g5.25.2)
X
<0,00100
<0.10
1
I mg/L
lb.
n/a
n/a
n/a
'we"
Tetradrb*
<0.00100
<0.10
1
mg/L
lb.
n/a
n/a
n/a
(%23.�
7V.CNorobenme
V
<0.00100
<0.10
1
mg/L
lb.
n/a
n/a
n/a
BV.CNomdh
bmuxr me
x
<0.00100
(0.10
1
mg/L
lb.
n/a
n/a
n/a
(124.4 )
W.ChbWharm
am)x
40.00500
<0.049
1
mg/L
lb.
n/a
n/a
n/a
loV, 2-CNom-
etyMoEmW
<0.0500
<0.488
1
mg/L
lb.
n/a
n/a
n/a
(11a75-B)
liv. 3) Womform
X
<0.00500
<0.049
1
mg/L
lb,
n/a
n/a
n/a
12V. Dmhloro-
bmwndane
<0.00100
<0.10
1
mg/L
lb.
n/a
n/a
n/a
(75.27.4)
13V, D chbro.
&oromeboe
<0.00500
<0.049
1
mg/L
lb.
n/a
n/a
n/a
g5.71Aj
14V.1,1Ddrlora
V
<0.00100
<0.10
1
mg/L
lb.
n/a
n/a
n/a
ethane (7&34.3)
/�
e>hana(1p7.OB-2)
dane(107- 2)
Y
/\
<0.00100
<0.10
1
mg/L
lb.
n/a
n/a
n/a
16V,1,1•acNaro
e8rylenep5.354)
/`
X
<0.00100
<0.10
1
mg/L
lb.
n/a
n/a
n/a
1,22DD
X
<0.00100
<0.10
1
mg/L
lb.
n/a
n/a
n/a
MR
18V.1,3.DkNom-
v.
X
<0.00100
<0.10
1
mg/L
lb,
n/a
n/a
n/a
(542.79)
19V�
x
<0.00100
<0.10
1
mg/L
lb.
n/a
n/a
n/a
(IO041�4)
(10
20V MeN
X
<0.00500
<0. 049
1
mgJL
lb.
n/a
n/a
n/a
Bromde(14839)
21v.MeihyiX-1
<0.00250
<0.024
1
mg/L
lb.
n/a
n/a
n/a
CNonde (14-B7.3)
EPA Fomt 3510.2C (8-W) PAGE V4 CONTINUE ON PAGE V-5
DEQ-CFW 00075334

OUTFALL 001
!`nAITWHCn CDMI DAr±C 1t_A
2. MARK W
3, EFFLUENT
4, UNITS
5. INTAKE (opt,
1 POLLUTANT
b. MAXIMUM 30 DAY VALUE
c. LONG TERM AVRG.
a. LONG TERM
a
h
c
a MAXIMUM DAILY VALUE
(rf available)
VALUE (tf milable)
AVERAGE VALUE
b, N0. OF
(1)
CONCENTRATION
(2) MASS
(1)
CONCENTRATION
(2) MASS
(i)
CONCENTRATION
(2) MASS
i11
CONCENTRATION
(2j MASS
CAS NMIDUMBER
(if available)
TESTING
REQUIRED
BELIEVED
PRESENT
BEUEVED
ABSENT
d. NO.
ANALYSES
a CONCEN•
TRATION
b MASS
ANALYSES
GCIMS FRACTION -VOLATILE COMPOUNDS (conamred)
22V.Methone
X
<0.00500
<0.049
1
mg/L
lb,
n/a
n/a
n/a
Chlodde V544
23V.1,1,2,2-
Tet lomethane
x
<0.00100
<0.010
1
mg/L
lb.
n/a
n/a
n/a
24V.Tehadrbro.
X
<0.00100
<0.010
1
mg/L
lb,
n/a
n/a
n/a
et*e(127.18.4)
25V Tokm
X
<0.00500
<0.049
1
1 mg/L
lb.
n/a
n/a
n/a
(108.88.3)
26V,1,2-Trans-
Dzhlorcemyleene
X
<0.00100
<0.010
1
mg/L
lb.
n/a
n/a
n/a
15660.5
27V,1,1,1-Trkhvo•
�/
x
<0,00100
<0.010
1
mg/L
lb.
n/a
n/a
n/a
e me (71.55�
28V 1,1,2Tnchloro-
X
<0.00100
(0.010
1
mg/L
lb.
n/a
n/a
n/a
ethane pB-00,5)
29VT40loro-
X
(0.00100
<0.010
1
mg/L
lb.
n/a
n/a
n/a
eklene gHl,B)
30V. TmWo*
8uoromethane
x
<0.00500
<0.049
1
mg/L
lb,
n/a
n/a
n/a
5894
31V.Vinyl Chlodde
X
<0.00100
<0.010
7
1
mg/L
lb.
nia
n/a
n/a
gRI-4)
GC/MS FRACTION -ACID COMPOUNDS
1A.2-Chlorophend
X
<0.0100
c0.098
1
mg/L
lb.
n/a
n/a
n/a
(657.8)
/�
2A.2,4•D'chlao-
<0.0100
<0.09B
1
mg/L
lb,
n/a
n/a
n/a
phend (1m2)
3A.2,44Drmetk
X
<0.0100
<0.098
1
mg/L
lb,
n/a
n/a
n/a
phenol (1VA7.9)
4A.4,6.DM*O.
X
<0.0100
<0.098
1
mg/L
lb.
n/a
n/a
n/a
Creed (534.52-1)
SA'Z¢Dht*
X
<0.0100
<0.098
1
mg/L
lb.
n/a
n/a
n/a
Ord (51.28.5)
K2-Ndrophend
V
<0.0100
<0.098
1
mg/L
lb.
n/a
n/a
n/a
(88.75.5)
7A.4- mphend
x
<0.0100
<0.098
1
mg/L
lb.
n/a
n/a
n/a
0-02. (107)
BA,P-Chbro•M.
X
<0.0100
<0.098
1
mg/L
lb.
n/a
n/a
n/a
Cresol (59.50.7)
/\
9A Penlachlo*
X
<0. 0100
(0.098
1
mg/L
lb.
n/a
n/a
n/a
phend (87.86.5)
10A,Ph6d
<0.0100
<0,098
1
mg/L
lb.
n/a
n/a
n/a
(108.95.2)
11A,2,4,6-Tddoro-
X
<0.0100
<0.098
1.
mg/L
lb,
n/a
n/a
n/a
phend (80-0 2)
EPA Form 351kC (8-90) PAGE V-5 CONTINUE ON REVERSE
DEQ-CFW 00075335

OUTFALL 001
CONTINUED FROM THE FRONT
2. MARK'X'
3. EFFLUENT
4. UNITS
5. INTAKE (oAlroeal
1 POLLUTANT
b, MAXIMUM 30 DAY VALUE
c. LONG TERM AVRG.
a, LONG TERM
AND
a
b
c
a MAXIMUM DAILY VALUE
(jmmlable)
VALUE (f aenrlable)
AVERAGE VALUE
CAS NUMBER
TESTING
BELIEVED
BELIEVED
d, NO, OF
a. CONCEN-
b NO. OF
(t)
(1)
(1)
(1)
(rfmnrlable)
REQUIRED
PRESENT
ABSENT
CONCENTRATION
(2)LIASS
CONCENTRATION
(2)NASS
CONCENTRATION
MASS
ANALYSES
TRATION
b.MASS
CONCENTRATION
p)MASS
ANALYSES
GCIMS FRACTION - BASEINEUTRAL COMPOUNDS
%Acem"ene
V
<0.00100
<0.01
1
mg/L
lb.
n/a
n/a
n/a
(032.9)
/�
2B.Acen*y*e
(2SOM)
/�
<0,00100
<0.01
1
mgJL
lb,
n/a
n/a
n/a
3B.Arbaceae
(120- R
V
!�
<0.00100
<0.01
1
mg/L
lb.
n/a
n/a
n/a
4B. ��r�
X
<0.0100
<0.098
1
mg/L
lb.
n/a
n/a
n/a
58. Benzo (a)
Anthracene
X
<0.00100
<0.01
1
mg/L
lb.
n/a
n/a
n/a
()
6B Benze(a)
Pyrene (50.32.8)
X
<0.00100
<0.01
1
mg/L
lb,
n/a
n/a
n/a
76.3,4•Bemo-
flunithene
(0.00100
<0.01
1
mg/L
lb.
n/a
n/a
n/a
(2699.2)
8B,BenzoWm)
Perylene (191.24.2)
x
<0.00100
<0.01
1
L
lb.
n/a
n/a
n/a
9B Berm (1)
Rbarenthene
X
<0,0010D
<0.01
1
mg/L
lb,
n/a
n/a
n/a
(207.99)
1DB. Bis (2-Clda&
etlba� Methane
X
<0.0100
<0.098
1
mg/L
lb,
n/a
n/a
n/a
(111.91.1)
118. Bis (2-Cblam-
elEthef
X
<0.0100
<0.098
1
mg/L
lb.
n/a
n/a
n/a
(111.44.4)
112B. Bic (2-
cbtarorwpffim
X
<0.0100
<0.098
1
mg/L
lb.
n/a
n/a
n/a
E#W(102*1)
12, Bo (2-Edgf-
tre,0Phthalate
X
<0.00300
<0.029
1
mg/L
lb.
n/a
n/a
n/a
(117.817)
14B 4-Bromopheayl
Phce)iEther
X
<0.0100
<0.098
1
mg/L
lb.
n/a
n/a
n/a
(101�3)
15B'BLYBe"
PMhalale ie5
<0.00300
<0.029
1
mg/L
lb.
n/a
n/a
n/a
16B.2-Chloro-
nwffi*"1e
X
<0.00100
<0.01
1
mg/L
lb,
n/a
n/a
n/a
(9158 7)
17B. 4-Chlom-
phenyl Phenyl Ether
V
<0.0100
<0.098
1
mg/L
lb,
n/a
n/a
n/a
0005.72.3)
18B Chrysene
(218.01.9)
x
<0.00100
(0.01
1
mg/L
lb.
n/a
n/a
n/a
198 Dibenzo (a,b)
Antlaacene
(53 O)
X
<0.00100
<0.01
1
mg/L
lb,
n/a
n/a
n/a
208,uaft*
benzene (95,%l)
X
<0,00100
<0.01
1
mg/L
lb.
n/a
n/a
n/a
218.13MI°3a
(5417ib�e)
X
<0.00100
<0.01
1
mg/L
lb.
/a
n/a
n/a
EPA Form 3510.2C (8.90) PAGE V-6 CONTINUE ON PAGE V-7
DEQ-CFW 00075336

OUTFALL 001
meriui icn conu oeee v-a
2,MARKW
3 EFFLUENT
4.UNITS
5INTAKE (opnona�
1. POLLUTANT
b, MAXIMUM 30 DAY VALUE
c. LONG TERM AVRG.
a, LONG TERM
AND
7ESENT
b,
c
a. MAXIMUM DAILY VALUE
(fmilahle)
VALUE (fwloble)
d. N0.OF
a. CONCEN•
AVERAGE VALUECAS
b, N0,OF
(1)
CONCENTRATION
(2) MASS
(t)
CONCENTRATION
(2) MASS
(1)
CONCENTRATION
(2) MAss
(1)
CONCENTRATION
(2) IdAss
NUMBERLEVED
(rf milaNe)
BELIEVED
ABSENT
ANALYSES
TRATION
b, MASS
ANALYSES
GC/MS FRACTION
—BASEINEUTRAL
COMPOUNDS
(comimte4
22B.1,4-DOb*
�/
<0,00100
<0.001
1
mg/L
lb.
n/a
n/a
n/a
benzene OWx
238.3,3•achloro-
x
<0,0100
(0.098
1
mg/L
lb.
n/a
n/a
n/a
benzidine Pl-94.1)
248.a
PhihNate("2)
/� x
40,00300
c0.029
1
mg/L
lb.
n/a
n/a
n/a
258.IXmelhl4
PhBielete
<0.00300
<0.029
1
mg/L
lb.
n/a
n/a
n/a
(131.11.3)
26B.NN• #
X
40,00300
<0.029
1
mg/L
lb.
n/a
n/a
n/a
Pdalaate (84.74-2)
27B,2,40nd*
�/
x
<0.0100
<0.098
1
mg/L
lb.
n/a
n/a
n/a
lohrene (121-%2)
26B.2,6•ambo.
V
<0.0100
<0.098
1
mg/L
lb.
n/a
n/a
n/a
tohm (BOB•20.2)
A
29B.D40dfi
X
<0.00300
cO.029
1
mg/L
lb.
n/a
n/a
n/a
Pldhalate (117-W)
30B,1,24phenyN
hydmme (as Azo-
X
<0.0100
40.098
1
mg/L
lb,
n/a
n/a
n/a
benzene) (122.66.7)
31B Fluorentheae
v
<0.00100
c0.001
1
mg/L
lb.
n/a
n/a
n/a
(2"-0)
A
32B,Fluorene
x
<0.00100
<0.001
1
mg/L
lb.
n/a
n/a
n/a
(86.73d)
33B,Hexachbro-
X
<0.00100
c0.001
1
mg/L
lb.
n/a
n/a
n/a
benzene (118.74.1)
34B'Hexer *
x
<0.0100
40.098
1
mg/L
lb,
n/a
n/a
n/a
buW ene (87-%3)
35B. Hexaddaro-
cpdopenlafte
X
<0,0100
<0.098
1
mg/L
lb,
n/a
n/a
n/a
(17-47-4)
36BHexaftro-
X
<0.0100
<0.098
1
mg/L
lb.
n/a
n/a
n/a
dam (67.72.1)
/�
376, Mdeno
(1,2,3<djPyrena
<0.00100
<0.001
1
mg/L
lb,
n/a
n/a
n/a
(19339.5)
38B Isophorone
<0.0100
<0.098
1
mg/L
lb.
n/a
n/a
n/a
39B,Naphlhalene
V
<0,00100
<0.001
1
mg/L
lb.
n/a
n/a
n/a
(91.20.3)
/�
40B.Iene
X
<0.0100
<0.098
1
mg/L
lb.
n/a
n/a
n/a
Wm)
418. N4JBro•
sodane omme
<0.0100
<0.098
1
mg/L
lb,
n/a
n/a
n/a
r(62
<0.0100
<0.098
1
mg/L
lb.
n/a
n/a
n/a
EPA Form 351(QC (8.90) PAGE V-7 . CONTINUE ON REVERSE
DEQ-CFW 00075337

OUTFALL 001
CONTINUED FROM THE FRONT
2 MARK'X' '
3 EFFLUENT
4. UNITS
5 INTAKE (opr+onao
1, POLLUTANT
b MAXIMUM 30 DAY VALUEJ
c. LONG TERM AVRG,
a. LONG TERM
AND
TTES12NOBEUbEEVEND
aMAXIMUM DAILY VALUE
(+f mitable)
VALUE (rf mnrlaNa)
AVERAGE VALUE
CAS NUMBER
BELIEVED
d. NO.OF
a. CONCEN-
b. NO, OF
(t)
(1)
(1)
(1)
(Javadabfe)
ABSENT
CONCENTRATION
(2jtdASs
CONCENTRA1bN
(2)MASS
MNCENIRATIM
MMO
ANALYSES
TRATION
b.MASS
COfNNRATION
(2)Mc
ANALYSES
GC1MS FRACTION- BASE/NEUTRAL COMPOUNDS (cwinned)
43B. W V .
sodipher*he
X
<0.0100
<0.098
1
mg/L
lb,
n/a
n/a
n/a
(BB )
44BPBe�n hl+rene
V
<0.00100
<0.001
1
mg/L
lb,
n/a
n/a
n/a
45B. Pyrene
(In"<0.00100
<0.001
1
mg/L
lb.
n/a
n/a
n/a
468.1,2,4•Trr-
chlorobome
X
c0.0100
<0.098
1
mg/L
1b.
n/a
n/a
n/a
(12042-1)
GCIMS FRACTION
- PESTICIDES
iP.
(*2)
l� X
<0.000050
de-4
1
mg/L
lb,
n/a
n/a
n/a
2P.a-BHC
(318� ")
�/
/�
<0.000050
de-4
1
mg/L
lb.
n/a
n/a
n/a
3P'WC
(3194�r7)
X
<0.000050
de-4
1-
mg/L
lb.
n/a
n/a
n/a
4P )
(sm5P.RHC
XBHC
<0.000050
de-4
1
mg/L
lb.
n/a
n/a
n/a
01"")
!�
X
<0.000050
de-4
1
mg/L
lb.
n/a
n/a
n/a
BP.CNAme
(57.7�)
X
/\
<0,000050
<0.005
1
mg/L
lb.
n/a
n/a
n/a
7P.4,4•DDT
X
<0,000050
<5e-4
1
mgJL
lb.
n/a
n/a
n/a
(DW)
/�
BP.4'4•DDE
U2.59)
�/
/�
<0,000050
<5e-4
i
mgJL
lb.
n/a
n/a
n/a
9P.4,4'-DDD
02.50)
V
/�
<0,000050
<5e-4
1
mg/L
lb.
tt/a
n/a
n/a
lop.
X
<0.000050
de-4
1
mg/L
lb.
n/a
n/a
n/a
15&29.7)no *n
X
<0.000050
<5e-4
1
mg/L
lb.
n/a
n/a
n/a
1YP EMo ft
(115.29.7j
�j
x
<0.000050
de-4
1
mg/L
lb.
n/a
n/a
n/a
13P EndosuNan
SuNe
<0.000050
de-4
1
mg/L
lb,
n/a
n/a
n/a
(1031-07.8j
12P Endue
P •2M)
�/
x
(0.000050
<5e-4
1
mg/L
lb.
n/a
n/a
n/a
15P, Eedmr
AW"e
X
<0.000050
<5e-4
1
mg/L
lb.
n/a
n/a
n/a
pa21.93a)
16P. Heptachlor
<0.000050
de-4
1
rog/L
lb.
n/a
n/a
n/a
EPA Form 3510.2C (NO) PAGE V-6 CONTINUE ON PAGE V 9
DEQ-CFW 00075338

OUTFALL 001
EPA 10, NUMBER (copvfrom Item i of roan l) OUTFALL NUMBER
NCD 047 368 642 001
uunm�uw rwm
rnv� v I MARK"X°
3. EFFLUENT
4 UNITS
5, INTAKE (opaona�
1, POLLUTANT
b MAXIMUM 30 DAY VALUE
c, LONG TERM AVRG,
a. LONG TERM
AND
a
b.
c
a. MAXIMUM DAILY VALUE
Of mmilable)
VALUE (f avatbble)
d, NO. OF
a. CONCEN•
AVERAGE VALUE
b, N0, OF
(1)
CKENTRATION
(2) MASS
(i)
CONCALT%
(2) MASS
(1)
CONCENTRATION
(2) MASS
(1)
CONCENTRATION
(2) MASS
CAS NUMBER
(ifamloble)
TESTING
REQUIRED
BEUEVED
PRESENT
BELIEVED
ABSENT
ANALYSES
TRATION
b. MASS
ANALYSES
GC/MS FRACTION - PESTICIDES (commO
17P. HepWIor
Epoxde
x
<0.000050
<5e-4
1
mg/L
lb,
n/a
n/a
n/a
(1024-57-3)
10P.PCB-1242
Y
<0.000500
<0.005
1
mg/L
lb.
n/a
n/a
n/a
(53469.21.9)
/�
19P.PCB-1254
v
<0.000500
<0.005
1
mg/L
lb,
n/a
n/a
n/a
(11097-SI)
A
20P,PCB4221
V
<0.000500
<0.005
1
mg/L
lb.
n/a
n/a
n/a
(11104426.2)
A
21P.PCB•1232
x
<0.000500
<0.005
1
mg/L
lb.
n/a
n/a
n/a
(11141
22P.PCB-1248
v
<0.000500
<0.005
1
mg/L
lb,
n/a
n/a
n/a
(12672.29-6)
A
23P.PCB-1260
�j
x
<0.000500
<0.005
1
mg/L
lb.
n/a
n/a
n/a
(1109&2
24P, PCB-1016
�/
x
<O.000500
<0.005
1
mg/L
lb.
n/a
n/a
n/a
(12674-11-2)
25P,Toxaphene
v
<0.000500
<0.005
1
mg/L
lb,
n/a
(8001.35 2)
/�
EPA Form 351 D-2C (8-90)
PAGE V•9
DEQ-CFW 00075339

OUTFALL 002
PLEASE PRINT OR TYPE IN THE UNSHADED AREAS ONLY. You may report some or all of ft information EPA I.D. NUMBER (cony from [rem 1 of Form 1)
on separate sheets (use Are some Airmao instead of completing these pages. NCD 047 368 642
SEE INSTRUCTIONS.
OUTFALL NO.
V.INTAKE AND EFFLUENT CHARACTERISTICS (caftedhompage 3ofForm 2-C) os
PART A -You must provide the results of at least one analysis for every pollutant In this table:, Complete one table; for each ould. See msUurborxa for additional details.
3. UNITS
4. INTAKE
2. EFFLUENT
(speedy fMonk)
(09ro0
b, MAXIMUM 30 DAY VALUE
c LONGTERM AVRG, VALUE
a. LONG TERM
a, MAXIMUM DAILY VALUE
(if aradaNe)
(if avada6le)
AVERAGE VALUE
d, NO OF
a. CONCEN•
b. NO. OF
(1)
(1)
(1)
1. POLLUTANT I
CONCENTRATION
12) MA55
CONCENTRATION
(2) MASS
(1) CONCENTRATION
(2) MASS
ANALYSES I
TRATTON
b. MASS I
CONCENTRATION
(2) MASS
ANALYSES
a. Biochemical Oxygen
Demand (ADD)
3.9
762.1
3.9
762.1
1.4
185.7
12
mg/L
lb,
n/a
n/a
n/a
b. Chemical Oxygen
33.7
4898
33.7
4898
4.37
458.6
12
mg/L
lb.
n/a
n/a
n/a
Demand (COD)
c.ToWOrprkCarbon
12.8
1135
1
mg/L
lb,
n/a
n/a
n/a
(TM
d. ToW S*S(Suspended
Solids (7S4)
10.6
939.7
1
m9/ L
lb,
n/a
n/a
n/a
e,AmmhonM(aeN)
0.410
36.3
1
mg/L
lb.
n/a
n/a
n/a
VALUE
VALUE
VALUE
.VALUE
LFlow
34.791
26,813
14.556
1095
MGD
MGD
n/a
n/a
g.Temperature
VALUE
22.0
VALUE
18. B
VALUE
14.1
188
'C
VALUE
n/a
n/a
(winter)
h Temperature
VALUE
VALUE
VALUE
VALUE
(summer)
33.0
31.1
30.0
190
C
n/a
n/a
MINIMUM
MAXIMUM
MINIMUM
MAXIMUM
hPH
6.11
8.16
n/a
n/a
647
STANDARD UNITS
PART B - Mark 'X' in column 2-a for each pollutant you know or have reason to believe is present Mark'X' in eolumm 2-b for each pokhrd you believe to be absent If you mark column 2a for any pollutant whhhth ltmwted elther
direct or mdire* but exproo, In an effluent IhmhtaW guhd*e, you must provide the results of at Mast one analysis for that pollutant For other pduWb for which you mark column 2a, you muss provide
quantitative data or an explanation d their presence in your discharge. Complete one table for each outell. See the instructions for additional details and requirements.
2 MARK'X'
3. EFFLUENT
4. UNITS
5, INTAKE (opeonoll
1. POLLUTANT
b. MAXIMUM 30 DAY VALUE
to LONGTERM AVRG VALUE
a. LONG TERM AVERAGE
AND
a
b
a. MAXIMUM DAILY VALUE
(fava"e)
(1011t10ble)
VALUE
CAS NO.
BE IEVED
BELIEVED
d. NO. OF
a. CONCEN•
b. NO. OF
(1)
(1)
0)
0)
(f avmla6)e)
PRESENT
ABSENT
CONCENTRATION
(Y)MASS
CO aNTRATION
(2) MASS
CONCENTRATION
(2) MASS
ANALYSES
TRATION
b MASS
OCNCENTRATION
(2) MASS
ANALYSES
a. Bromide
�/
(24959$7.9)
X
R�iC m,Taal
V
0.14
12.4
1
mg/L
lb.
n/a
n/a
n/a
GC&
X
27
n/a
1
PCU
n/a
n/a
n/a
n/a
d Fed Worm
X
est, 2
n/a
1
col/dL
n/a
n/a
n/a
n/a
�. Nome
18984- 8.8)
X
1
35.1
4110
35.1
4110
17.3
1783
12
mg/L
lb.
n/a
n/a
n/a
tNkate-ftte
(asM
X
2.4
442.9
2.4
442.9
1.04
127.5
36
mg/L
lb.
n/a
n/a
n/a
EPA Form 3510.2C (8.90) PAGE V•1 CONTINUE ON REVERSE
DEQ-CFW 00075340

4UTFALL 002
iteu �� n nnununrn eenu ron►rr
V 2, MARK "X"v
3, EFFLUENT
4. UNITS
5, INTAKE (opaona�
1. POLLUTANT
b. MAXIMUM 30 DAY VALUE
c, LONG TERM AVRG, VALUE
a, LONG TERM
AND
7PRESENT
b,
a. MAXIMUM DAILY VALUE
(f mnrMhle)
(f mndnhlc}
AVERAGEVALUE
b, NO.OF
(�)
CONCENTRATION
(2)MASS
(11
C4�lCENTRAT t
(2)MASS
(1)d
CONCENTRATION
(2)MASS
�
tXNJCENTRATION
(2)MASS
CASN0,BELIEVED
Wavmlable}
ABSENT
NO.OF
ANALYSES
a, CONCEN-
TRATION
b.MASS
ANALYSES
To Nitrogen,
c(m
x
0.362
32.1
1
mg/L
1b.
n/a
n/a
n/a
I
M
I
h.Oil And
<4.76
<422
1
mg/L
lb.
n/a
n/a
n/a
Gmw
. Phosphorus(as P),Tool
1.2
154
1.2
154
0.8
85.8
36
mg/L
lb.
n/a
n/a
n/a
(7723.14-0)
/X`
I. Radioactit
(1)Alpha,Tool
X
(2) Beta, TOW
X
(3) Radium,
�/
x
Total
(4) Radium 226,
x
Total
/�
k, Sufiate
(���}
X
105
9309
1
m9/L
lb,
n/a
n/a
n/a
(14IM79.8)
I. Sulfide
�/
x
(m�
(a SuIMe
(as S0,)
X
(1426545.3)
n.Surfaclants
X
0.552
48.9
1
mg/L
lb.
n/a
n/a
n/a
o. Aluminum.
Total
X
1.27
112,E
1
mg/L
lb.
n/a
n/a
n/a
0429,-5)
p. Banum, Total
6440.39.3)
X
q Boron, Total
V44042.8)
X
r, Cobalt, Total
X
(1440484)
s Iron,Tot81
x
1.15
102.0
1
mg/L
1b.
n/a
n/a
n/a
(1439. U)
t. Magneaum,
Total
X
2.26
200.4
1
mg/L
lb.
n/a
n/a
n/a
p431}954}
U. Moybdenum,
Total
X
9439- 7)
V. Manganese,
TOW
X
0.069
6.12
1
mg/L
lb.
n/a
n/a
n/a
U43w,
Tm, Total
�/
x
(7440.31v�
Y.Tdanium,
Total
T
X
(7440.32.6)
EPA Form 3610-2C (8-90) PAGE V•2 CONTINUE ON PAGE V-3
DEQ-CFW 00075341

0UTFALL 002
EPA I,D. NUMBER (M,fmm bear 1 of Form 1) OUTFALL NUMBER
CONTINUFD FROM PAAF 3 OF FORM 2d: NCD 047 368 642 002
PART C - If you are a primary industry and this odfall contains process wastewater, refer to Table 2a2 in the instructions to determine which of the GCIMS fractions you must test for. Mark 'X' in column 2-2 for a9 such GC/MS
fractions that apply to your industry and for ALL toxic metals, cyandes, and total phenols. If you are not required to mark column 2a (secondary industries, nonprocess wastewater aft, and nonrep-ad GCAWS
hacdons), mark 'X' in column 2-b for each pollutant you know or have reason to believe Is present Mark ')V in cxdumn 2-c for each pollutant you believe is absent If you mark column 2a for any pollutant, you must
provide the results of at least one analysis for chat pollutant If you mark column 2b for any pollutant, you must provide the results of at least one analysis for that pollutant d you know or have reason to believe d will be
discharged in concentrations of 1 D ppb or greater If you mark column 2b for arxdern, araylordnle, 2,4 drnstrophend, or 2-me%yl4, 6 dmdrophenol, you must provide the reshdts of at least one analysts for each of these
pollutants which you know or have reason to believe tot you discharge in concentrations of 100 ppb or greater, Otherwise, for poll Ants for which you mark column 2b, you must either submit at least one analysis or
briefly describe the reasons the pollutant is expected to be discharged Note that there are 7 pages to this part, please review each carefully Complete one table (all 7 pages) for each Wall. See instructions for
additional details and requirements.
2, MARK'X'
3. EFFLUENT
4. UNITS
5, INTAKE (oprronaQ
1. POLLUTANT
b. MAXIMUM 30 DAY VALUE
c. LONG TERM AVRG.
a. LONG TERM
AND
a
b
c
a. MAXIMUM DAILY VALUE
(jmadable)
I VALUE (tf mihNe)
AVERAGE VALUE
CAS NUMBER
TESTING
BELIEVED
BELIEVED
d. 140. OF
ANALYSES
1 a. CONCEIT
TRATION
b MASS
b NO OF
ANALYSES
11)
(1)
(1)
(1}
ffamdable)
REQUIRED
PRESENT
ABSENT
OXENTRATION
j2)MASS
CONCENTRATION
AmCONCENTRATION
(?)MASS
CONCENTRATION
pass
METALS, CYANIDE, AND TOTAL PHENOLS
1M,Antimony, Tolal
X
<0.002
<0.177
1
mg/L
lb.
n/a
n/a
n/a
2M Anwrrrc,Total
V
<0.005
<0.443
1
mg/L
lb.
n/a
n/a
n/a
3M.Bery6um,Totel
X
(0.001
<0.089
1
mg/L
lb.
n/a
n/a
n/a
(7440-41.71
4M Cadmium, Taal
V
<0.002
<0.177
1
mg/L
lb.
n/a
n/a
n/a
(144049)
5M.Chromium,
X
X
<0.005
<0.433
1
mg/L
lb.
n/a
n/a
n/a
Total (744047.3)
6M. Copper, ToW
V
0.005
0.443
1
mg/L
lb.
n/a
n/a
n/a
7M. Lead, Total
X
X
(0,003
40.266
1
mg/L
lb.
n/a
n/a
n/a
0439.92-1)
8M Mercury, Tow
X
<0.0002
<0.018
i
mg/L
A.
n/a
n/a
n/a
6439.97.6)
9M.Nickel, Total
X
<0.005
<0.433
1
mg/L
lb.
n/a
n/a
n/a
p440-02-0)
10M.Selenum,
X
<0.005
<0.433
1
mg/L
lb.
n/a
n/a
n/a
ToW (7782.49.2)
IIM.Silver, Total
V
<0.002
<0.177
1
mg/L
lb.
n/a
n/a
n/a
g440.22.4)
12M.Thallwm,
V
<0.005
<0.433
1
mg/L
lb.
n/a
n/a
n/a
Total (7440.10)
13M.Zrrro,Total
�/
X
0,008
0,709
1
mg/L
lb.
n/a
n/a
n/a
U440 66fii)
14M. Cyanide,
Total(57.12.5)
V
/�
<0.005
<0.433
1
mg/L
lb.
n/a
n/a
n/a
15M. Phenols'
X
0.0433
3.84
1
mg/L
lb.
n/a
n/a
n/a
Total
DIOXIN
2,3,7,8•Teba•
DESCRIBE RESULTS nos applicable
chlorooft P•
X
Dioxin (1764-01.6)
EPA Form 351(W (8-90) PAGE V-3 CONTINUE ON REVERSE
DEQ-CFW 00075342

OUTFALL 002
rnutuu ien eenu tue Eenut
2 MARK'X'
3. EFFLUENT
4 UNITS
5. INTAKE (oprramrl!
1 POLLUTANT
b. MAXIMUM 30 DAY VALUE
c. LONG TERM AVRG,
a. LONG TERM
AND
a
b
c
a MAXIMUM DAILY VALUE
(r(mwilable)
VALUE(rfmwrlable)
d. NO. QF
a. CONCEN•
AVERAGEVALUE
b NO.OF
(1)
(2) MASS
it)(1)
CONCENTRATION
(2) MRSS
CONCENTRATION
(2) MASS
0)
CONCENTRATION
(2) MASSANALYSES
CAS NUMBER
(if available)
TESTING
REQUIRED
BELIEVED
PRESENT
BELIEVED
ABSENT lCONCENTRATIONJ
ANALYSES
TRATION
b. MASS
GCIMS FRACTION -VOLATILE COMPOUNDS
1V.Acml m
�(
x
<0.0500
<4.433
1
mg/L
lb.
n/a
n/a
n/a
(107-02-8)
2V.Awylondnle
X
<0.0100
<0.887
1
mg/L
lb.
n/a
n/a
n/a
(107.13.1)
3V.Benzene
X
(0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
(]1.43.2)
4V, &s (Chl-
mulAfter
x
Not Req
fired
per NCDWR
NPDES
Permitt'g
Unit
(542.88.1)
5V Bmrndorm
X
(0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
U5.25.2)
6V, Carbon
Tetrachloride
X
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
(%23.5)
7V.Chlorobenzene
V
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
brorrromethane
x
<0.00100
<0.084
1
mg/L
lb.
n/a
n/a
n/a
(12448.1)
9V.Chlomethane
�/
x
<0.00500
<0.443
1
mg/L
lb,
n/a
n/a
n/a
U5-&3)
10V.2-Chloro-
e8lyMnoEther
X
<0.0500
<4.433
1
mg/L
lb.
n/a
n/a
n/a
(110.79)
ttv.chbdorm
x
0.0248
2.199
1
mg/L
lb.
n/a
n/a
n/a
(67-W)
12V. Dichloro-
br�2momelhene
0.00422
0.374
1
mg/L
lb.
n/a
n/a
n/a
13V. D chloro-
�uorom
<0.00500
<0.443
1
mg/L
lb.
n/a
n/a
n/a
14V.1,14)dWo-
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
ethane (7543)
A
15V.1,2-Dr Wo.
V
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
ethane (1074)&2)
/�
16V.1,1 achbro-
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
etlrylme(75.354)
/\
17V.1,24chloro•
<0.00100
<0.089
1
mg/L
lb,
n/a
n/a
n/a
propane VH7-5)
tev, I l Drc bo-
proNene
x
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
(542.75.6)
19V.Eth0enzene
x
<0.00100
<0.089
1
mg/L
lb,
n/a
n/a
n/a
(10D41.4)
2av
X
<0.00500
<0.443
1
mg/L
lb.
n/a
n/a
n/a
39)
21u.Me8ryl
<0.00250
<0.222
1
mg/L
lb.
n/a
n/a
n/a
Chbdde (i4$1.3}
EPA Form 3510.2C (B-90) PAGE V-4 CONTINUE ON PAGE V-5
DEQ-CFW 00075343

OUTFAII 002
CONTINUED FROM PAGE V-d
2. MARK'X'
3. EFFLUENT
4. UNITS
51NTAKE (optional
1. POLLUTANT
b, MAXIMUM 30 DAY VALUE
c, LONGTERM AVRG,
a. LONG TERM
AND
a
b.
c
a, MAXIMUM DAILY VALUE
(i(amilable)
VALUE (� available)
AVERAGE VALUE
CAS NUMBER
(if milahh)
�pNG
REQUIRED
BELIEVED
PRESENT
BELIEVED
ABSENT
d. N0, OF
ANALYSES
a CONCEN•
TRATION
b. MASS
b. NO OF
ANALYSES
11)
ODNCENTRATION
g) MASS
(1)
CONCENTRATIDN
(2) MASS
(1)
CONCENTRATIO
(2) MASS
(1)
CONCENTRATION
(2) MASS
GCIMS FRACTION -VOLATILE COMPOUNDS (conn*
22V,Mekke
V
<0.00500
<0.443
1
mg/L
lb.
n/a
n/a
n/a
Chbnde (15.M
/\
23V,1,1,2,2-
TeVachbroethane
X
<0.00100
<0.089
1
mg/L
lb,
n/a
n/a
n/a
34
24V.T&d610*
X
c0.00100
c0,089
1
mg/L
lb.
n/a
n/a
n/a
e8rylene (127.18ag
254,Tobene
�(
<0.00500
<0.443
1
mg/L
lb.
n/a
n/a
n/a
(108�86�3)
/
26V.12-Tram
okwo lhyiene
1
X
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
27V,1,1,1•Trbb*
ethane (11�5&)
v
/�
(0.00100
c0.089
1
mg/L
lb.
n/a
n/a,
n/a
28V,1,12-Tw%ro-
V
<0.00100
c0.089
1
mg/L
lb.
n/a
n/a
n/a
e8 W (794►0.5)
/\
29VToddoro.
v
<0,00100
c0.089
1
mg/L
lb.
n/a
n/a
n/a
30V, Tnddoro•
fluormdhane
x
<0,00500
<0.443
1
mg/L
lb.
n/a
n/a
n/a
OHM
31V.VoChWde
3
c0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
-4)
GC/MS FRACTION -ACID COMPOUNDS
1A.2-Chbrophend
v
<0.0100
<0.8B7
1
mg/L
lb,
n/a'
n/a
n/a
(95.57-8)
2A 2,40ftD
X
<0.0100
<0.887
1
mg/L
lb.
n/a
n/a
n/a
0enol(IM2)
3A.2,4.Dme*
X
<0.0100
<0,887
1
mg/L
lb.
n/a
n/a
n/a
4A.4,6-DWro0-
<0.0100
<0,887
1
mg/L
lb.
n/a
n/a
n/a
Cmw(M521)
5A,2,4•Dr&o•
X
<0.0100
<0,8B7
1
mg/L
lb.
n/a
n/a
n/a
phend (51-s&
aA,2-rophend
V
c0.0100
<0.887
1
mg/L
lb.
n/a
n/a
n/a
(88.755j
/`
7A,WWend
V
<0.0100
<0.887
1
mg/L
lb,
n/a
n/a
n/a
(100.02-7)
/`
aAP-Cwo.M•
X
<0.0100
<0.887
1
mg/L
lb.
n/a
n/a
n/a
Cresol (59.50.7)
9A Perdoddo*
X
<0.0100
<0.887
1
mg/L
lb.
n/a
n/a
n/a
phenol (81.86.5)
10A.Phenol
X
<0.0100
<0.887
1
mg/L
lb,
n/a
n/a
n/a
(108*2)
llA.2,4,6.T6chbm-
V
<0.0100
<0.887
1
mg/L
lb.
n/a
n/a
n/a
phend ("2)
/�
EPA Form 351(QC (NO) PAGE V-5 CONTINUE ON REVERSE
DEQ-CFW 00075344

OUTFAII 001
(KMITIAII ICh COM TWC CDAKIT
2 MARK'X"
3. EFFLUENT
4. UNITS
5 INTAKE (opnow4
1. POLLUTANT
b, MAXIMUM 30 DAY VALUE
c. LONG TERM AVRG.
a. LONG TERM
AND
a
b
a
a, MAXIMUMDAILYVALUE
((fararlahle)
VALUE(rjmwdahle)
AVERAGEVALUE
b NO.OF
(1)
CONCENTRATION
(4)MASS
(1)
CONCENTRATION
(2)MW
(1)
CONCENTRATION
(2)MASS
(1)
CONCENTRATION
(2)MASS
CAS NUMBER
(rfavmlable)
TESTING
REQUIRED
BELIEVED
PRESENT
BELIEVED
ABSENT
d. NO. OF
ANALYSES
a. CONCEN•
TRATION
b MASS
ANALYSES
GCIMS FRACTION - BASEINEUTRAL
COMPOUNDS
1B.A,cenaphthene
V
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
(W2-9)
/N
2B.Acenaphtylene
V
<0.00100
<0,089
1
mg/L
lb.
n/a
n/a
n/a
3B.Anthracene
x V
<0.00100
<0,089
1
mg/L
lb.
n/a
n/a
n/a
(12a12-7)
4B,Walme
X
<0.0100
<0.8B7
1
mg/L
lb.
n/a
n/a
n/a
(92-87-5)
5B, Benzo (a)
Anthracene
�(
<0.00100
<O.OB9
1
mg/L
lb,
n/a
n/a
n/a
(%-W)
/ \
6B Beazo(a)
X
<0.00100
40,089
1
mg/L
lb.
n/a
n/a
n/a
Pyrene (5N2.8)
1B.3,4-BWo-
0uoranthene
X
(0,00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
(205.99.2)
88'Berm Va)
X
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
Perylene (191.24-2)
9B. Benzo (k)
%ora here
�(
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
(2D7.04)
`\
10B. Bs (24'hloro-
eiW Whane
�(
x
<0.0100
<0.887
1
mg/L
lb,
n/a
n/a
n/a
(111 Bi•1)
11B Bis(2-Chloo
X
<0.0100
<0.887
1
mg/L
lb,
n/a
n/a
n/a
C111)r
128, Bls (2.
allay sopm[A
X
<0.0100
<0.887
1
mg/L
lb.
n/a
n/a
n/a
Ether(1024KH)
`\
13B, Bic (1-Eihll-
IgV4Phlhawe
<0.00300
<0.266
1
mg/L
lb,
n/a
n/a
n/a
(117.81-n
146, 4.8romopheryl
PheryEd
X
<0.0100
<0.887
1
mg/L
lb.
n/a
n/a
n/a
(101,%3)
15B BuyBenzyl
X
<0.00300
<0.266
1
mg/L
lb.
n/a
n/a
n/a
Phthalate (85�68•T)
16B, 2-Chloro-
naphthalene
�(
<0,00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
(91a8.7)
/ `
17B.4-C*ro.
phen�PhenAEther
X
<0.0100
<0.887
1
mg/L
lb,
n/a
n/a
n/a
g005.72.3)
188.Chrysene
X
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
(21841.9)
19B, Dibenzo (0)
Ar4hracene
X
<0,00100
<O.OB9
1
mg/L
lb.
n/a
n/a
n/a
(D70.3)
20B.
<0,00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
benzene (Z-50.1)
21B,1,3.Mloro.
V
<0.00100
<0.089
1
mg/L
lb.
I n/a
n/a
n/a
benzene (541.73.1)
EPA Form 3510.2C (8-90) PAGE V-6 CONTINUE ON PAGE V•7
DEQ-CFW 00075345

QUTFAll002
CONTINUED FROM PAGE V.6
2. MARK `X'
3 EFFLUENT
4. UNITS
5 INTAKE (opeowo
1. POLLUTANT
b. MAXIMUM 30 DAY VALUE
c. LONG TERM AVRG.
a LONGTERM
AND
a
b
rw
a, MAXIMUM DAILY VALUE
(if awalable)
VALUE (�f awvlable}
AVERAGE VALUE
CAS NUMBER
TESTING
BELIEVED
BELIEVED
d NO OF
a. CONCEN•
b NO, OF
(t)
(1)
It)
(1)
(rf avarlable)
REQUIRED
PRESENT'
ABSENT
CONCENTRATION
(2) MASS
CONCENTRATION
(2) MASS
CONCENTRATION
�) MASS
ANALYSES
TRATION
b, MASS
pRAnpN
(2)
YSES
GCIMS FRACTION
- BASEINEUTRAL
COMPOUNDS (coeamrerl)
22B,1,4-Mow
V
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
benzene (106�46�7)
/\
238,3,MOora-
V
<0.0100
<0.887
1
mg/L
lb.
n/a
n/a
n/a
beddine(91.94.1)
A
24B DteW PhOudate (84*2)
x
<0.00300
<0.226
1
mg/L
lb.
n/a
n/a
a/a
256. Dmtclh}4
PMhaMle
X
<0.00300
cO.226
1
mg/L
lb.
n/a
n/a
n/a
(131.11.3)
26B,DImN4Arlyl
X
<0.00300
<0.226
1
mg/L
lb.
n/a
n/a
n/a
PMhalate (8M74.2)
27B.2,44mdro-
V
x
<0.0100
<0.887
1
mg/L
lb,
n/a
n/a
n/a
(121.14.2)
28B.2,Wibo•
toluene (WO-2)/�
X
<0.0100
<0.887
1
mg/L
lb.
n/a
n/a
n/a
29B,DE"
Phlhalale (11740)
<0.00300
<0.226
1
mg/L
lb.
n/a
n/a
n/a
30B 1,2-aPhmy�
hprbazme(as A*
X
<0.0100
(0.887
1
mg/L
lb.
n/a
n/a
n/a
benzene) (122.6&7)
31B.Rmnfte
mom" (
X
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
32B,Fluorene
(973.1)
x-
<0.00100
<0.0B9
1
mg/L
lb.
n/a
n/a
n/a
33B. Nro.
benzene (118.74 )
X
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
348,bro-
WAene (B74W)
X
<0.0100
<0.887
1
mg/L
lb.
n/a
n/a
n/a
7B. HemMoro.
c &WAadiene
X
<0.0100
<0.887
1
mg/L
lb,
n/a
n/a
n/a
(77r47.4)
36BHexaN0fo.
X
<0,0100
<0.887
1
mg/L
lb.
n/a
n/a
n/a
eltme (67.724)
318, Indeno
(1,2.30P"m
X
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
(I
38B,ls*orone
X
<0.0100
<0.887
1
mg/L
lb.
n/a
n/a
n/a
(78.59.1}
39B.NaphMne
X
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
(91.20,3)
40B.wobenzene
(99")
X
<0.0100
c0.887
1
mg/L
lb.
n/a
n/a
n/a
416 Who.
sodanedlywe
X
<0.0100
<0.887
1
mg/L
lb.
n/a
n/a
n/a
(62.79)
428. N-N
N-PmP7lamme
X
<0.0100
<0.887
1
mg/L
lb.
n/a
n/a
n/a
(621 B4 7}
EPA Form 3510.2C (84) PAGE V-7 CONTINUE ON REVERSE
DEQ-CFW 00075346

OUTFALL 002
GUNTINUEU MUM
I HMO i
4. UNITS
5. INTAKE (opaana�
2. MARK "X"
3 EFFLUENT
1. POLLUTANT
b. MAXIMUM 30 DAY VALUE
c. LONGTERM AVRG.
a. LONG TERM
AND
a
b.
c
a MAXIMUM DAILY VALUE
(r%mailable)
VALUE(Javarla6le)
U. NO OF
a CONCEN•
AVERAGEVALUE
b, NO OF
CAS NUMBER
(ifwilable)
TESTING
REOUIRED
BELIEVED
PRESENT
BELIEVED
ABSENT
(11
CONCENTRATION
(2)MASS
(1)
CONCENTRAMN
(2)MASS
(1)
CONCENTRATION
(2)MASS
ANALYSES
TRAiION
b.MASS
(t)
ENTRATpN
j2)MASS
NALYSES
GCIMS FRACTION- BASEINEUTRAL
COMPOUNDS
(connmred)
43B. N-Ndro-
sodiphenylamine
�(
x
<0.0100
<0.887
1
mg/L
lb.
n/a
n/a
n/a
(86.3a6)
44B Phenatrene
�/
x
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
(BS-0t B}
45B)
X
<0.00100
<0.089
1
mg/L
lb.
n/a
n/a
n/a
46B.1,2,4-TrF
chimbenzene
X
<0.0100 <0.887 1 mg/L lb. n/a n/a n/a
(12H2.1)
GCIMS FRACTION
- PESTICIDES
1P.Alddn
X
<0.000050
<0.005
1
mg/L
lb.
n/a
n/a
n/a
(3D9-0D•2)
2P.a-BHC
X
<0.000050
<0.005
1
mg/L
lb,
n/'a
n/a
n/a
(31Hk)
3P."HC
x
<0.000050
<0.005
1
mg/L
lb,
n/a
n/a
n/a
(31W
4P.tBHC
V
<0.000050
<0.005
1
mg/L
lb.
n/a
n/a
n/a
(WO)
/�
WRHC
X
<0.000050
<0.005
1
mg/L
lb.
n/a
n/a
n/a
Plum)
(5'ii4.9*e
X
<0.000050
<0.049
1
mg/L
lb.
n/a
n/a
n/a
7P.4#-DDT
<0.000050
<0.005
1
mg/L
lb.
n/a
n/a
n/a
(50 a3)
8P.4,4'-DOE
�!
x
<0.000050
<0.005
1
mg/L
lb.
n/a
n/a
n/a
(72.559)
F.4,4'•DDD
x
<0.000050
<0.005
1
mg/L
lb.
n/a
n/a
n/a
(12.54 8)
lDP,Dlebdn
�/
x
<0.000050
<0.005
1
mg/L
lb.
n/a
n/a
n/a
(�57-1)
t1P,aEnosuban
x
<0.000050
<0.005
1
mg/L
lb.
n/a
n/a
n/a
(115 2lI Tj
12P.gr& dlan
V
<0.000050
<0.005
1
mg/L
lb.
n/a
n/a
n/a
(115.21I
A
13P. Endosuffan
Sul*
<0.000050
<0.005
1
mg/L
lb.
n/a
n/a
n/a
(1031-07-8)
14P Endon
x
(0.000050
<0.005
1
mg/L
1-b.
n/a
n/a
n/a
U2.2H)
15P. Enddn
Woe
X
<0.000050
(0.005
1
mg/L
lb,
n/a
n/a
n/a
(7421.93�4)
16P.HePwIor
V
<0.000050
<0.005
1
mg/L
lb.
n/a
n/a
n/a
n.� no
n�nr i n
EPA Form 3510.2C (8-90) PAGE V-s I v^ � - .
DEQ-CFW 00075347

OUTFALL 002
EPA I.D. NUMBER (copy from Item 1 ofro m 1) OUTFALL NUMBER
NCD 047 368 642 002
CONTINUED FROM PAGE V-B
2. MARK'X'
3 EFFLUENT
4. UNITS
5. INTAKE (opoowo
1, POLLUTANT
b, MAXIMUM 30 DAY VALUE
c. LONG TERM AVRG.
a, LONG TERM
AND
a
b
c
a, MAXIMUM DAILY VALUE
(if madaNe)
VALUE (f o<at le)
AVERAGE VALUE
CAS NUMBER
TESTING
BELIEVED
BELIEVED
d. NO. OF
a. CONCEN-
b NO. OF
(1)
I
(1)
(1)
(1)
(if mailable)
REQUIRED
PRESENT
ABSENT
CONCENTRATION
(2) MASS
CONCENTRATION
(2) MASS
CONCENTRATION
(2) MASS
ANALYSES
TRATION
b, MASS
CONCENTRATION
()
YSE
GC/MS FRACTION -PESTICIDES (con►moe4
17P Nepfaft
Ep0)°d
x
<0.000050
<0.005
1
Tag/L
lb.
n/a
n/a
n/a
(1024.51.3)
16P.PCB-1242
(M21.9)
x
c0,000500
<0.044
1
mg/L
lb.
n/a
n/a
n/a
19P PCIW54
(11097-W1)
V
A
<0.000500
<0.044
1
mg/L
lb.
n/a
n/a
n/a
20P PCB•1221
(11104282)
V
/�
<0.000500
cO.044
1
mg/L
lb.
n/a
n/a
n/a
1P411&R
X
<0.000500
<0.044
1
mg/L
lb.
n/a
n/a
n/a
22P.PCB•1248
(12672.2K
/�
x
<0.000500
<0.044
1
mg/L
lb.
n/a
n/a
n/a
23P.PCB•126D
(1109&625j
X
<0.000500
c0.044
1
mg/L
lb.
n/a
n/a
n/a
24P, PCB•1016
(12674.11.2)
X
<0.000500
<0.044
1
mg/L
lb.
n/a
n/a
n/a
25P. Tomphew
(6001.35.2)
x
c0.000500
<0.044
1
mg/L
lb.
n/a
n/a
n/a
EPA Form 3510.2C (NO)
PAGE V 9
DEQ-CFW 00075348

w Chemours Company — Fayetteville Works NPDES Permit No. NC0003573
Supplemental Information — Permit Renewal Application — April 27, 2016
Sludge Management Plan
The Chemours Company — Fayetteville Works operates a Class 3 Wastewater Treatment Plant
which is comprised of a single -stage activated sludge biological system.
Excess sludge is removed from the system by diverting part of the Recycled Activated Sludge (at
approximately 0.6% solids) from the clarifiers to a Dissolved Air Floatation ("DAF") unit for
initial thickening.
The sludge from the DAF (at approximately 3% solids) is transferred to a Mix Tank where polymer
agents are added to enhance the dewatering process.
The semi -thickened sludge is transferred from the Mix Tank to a Rotary Filter for final thickening,
whereby the sludge is thickened to 6% solids.
The thickened sludge is then transferred to a Screw Press where it is dewatered to a concentration
of 9-20% solids.
Following the Screw Press, the sludge is typically dried in steam heated dryers to a concentration
of 40-55% solids.
The dried sludge, or on occasion the dewatered sludge, is transported off -site to a commercial
Subtitle D landfill. This sludge is currently being disposed of at the Waste Industries "Sampson
County" Landfill near Roseboro, NC.
In 2015, the average weekly quantity of generated wasted sludge was approximately 35,000 lb.
DEQ-CFW 00075349

Chemours Company — Fayetteville Works NPDES Permit No. NC0003573
Supplemental Information - Permit Renewal Application — April 27, 2016
Current Facility Wastewater Management
Process wastewater and stormwater from the various manufacturing areas are collected in the
respective area sumps and ultimately conveyed via a gravity flow underground process sewer pipe
to the facility's central wastewater treatment plant ("WWTP"). Sanitary sewage is conveyed via
a separate underground sewer system to the WWTP. The permitted flowrate of the WWTP is
2.0 MGD, with an actual average flowrate of approximately 1.2 MGD.
This untreated process wastewater is commingled in the WWTP Influent Sump where it is pumped
to an 850,000-gallon Equalization Basin. The Equalization Basin is mixed with two floating
submerged mixers. Three floating surface aerators in the basin cool and aerate the incoming
wastewater.
A 175,000-gallon Emergency Retention Tank is available for temporary storage of untreated
wastewater which may need additional treatment or acclimation in the WWTP activated sludge
process at a controlled rate that allows for proper biological treatment.
Untreated wastewater from the Equalization Basin is normally pumped to a 250,000-gallon
Predigester Tank in which initial biological activity with the WWTP activated sludge begins. The
Predigester Tank is aerated. The partially treated wastewater from the Predigester Tank is pumped
to a 1,700,000-gallon Aeration Tank.
The Aeration Tank is the unit where the majority of the biological activity occurs. The Aeration
Tank is aerated primarily by a diffused air system located in the bottom of the tank. The tank can
have supplemental aeration via one or two floating Biomixers® that injects air through submerged
rotors.
The biologically treated wastewater is then sent to one of two in -ground clarifiers (119,000 gallons
and 168,000 gallons respectively) or an above -ground 679,000-gallon clarifier; with all clarifiers
being operated in parallel. The clarified treated effluent is discharged to and through Outfall 001.
The wasted activated sludge is sent to a Dissolved Air Floatation (DAF) unit, then to a 47,000
gallon Sludge Storage Tank, and finally to a Rotary Filter for thickening. The thickened sludge is
dewatered in a Sludge Press, and can be dried in a steam -heated dryer for additional moisture
removal. The dewatered sludge or dewatered/dried sludge is transported off -site to a commercial
Subtitle D landfill.
Non -contact process cooling water and non -process stormwater are conveyed via surface ditches.
In addition, excess riverwater flow and Outfall 001 effluent are discharged directly to a surface
ditch. The combined, total flow of water from the site is discharged through and monitored at
Outfall 002. The discharged treated wastewater is conveyed via an underground pipe to the Cape
Fear River, where it enters the river at a point approximately 1,500 feet upstream of the William
O. Huske Lock & Dam (aka Lock &.Dam No. 3).
DEQ-CFW 00075350

r�
Chemours Company — Fayetteville Works NPDES Permit No. NC0003573
Supplemental Information — Permit Renewal Application - April 27, 2016
Current Facility Operating Conditions
Chemours Fluoromonomers/Nafion® Membrane Manufacturing Area:
The Chemours Company — Fayetteville Works' Fluoromonomers / Nafion® Membrane
manufacturing area produces several final products. ChemoursTM NafionO Membrane is a plastic
film used in the chloroalkali industry and in electrochemical fuel cells. ChemoursTM Nafion®
Polymer Dispersions are used in the fabrication of thin films and coating formulations for fuel
cells membranes, catalyst coatings, sensors, and a variety of electrochemical applications.
The HFPO monomer and the Vinyl Ether monomers are used to manufacture various
fluorochemical products such as ChemoursTM Teflon®. Wastewater generated from this
manufacturing facility is discharged to the Chemours' wastewater treatment plant.
Chemours Polymer Processing Aid ("PPA") Manufacturing Area:
The Chemours Company — Fayetteville Works' PPA manufacturing area produces a polymer
processing aid. The processing aid produced in this unit is used in the manufacturing of
fluoropolymers and fluorinated telomers,•but none of the produced processing aid is used at the
Fayetteville Works site. All process wastewater generated from this manufacturing facility is
collected and shipped off -site for disposal. No process wastewater from this manufacturing facility
is discharged to the Chemours' wastewater treatment plant or to the Cape Fear River.
Kuraray Butacite® Manufacturing Area:
The Kuraray America Inc. — Fayetteville Plant's Butacite® manufacturing area produces two final
products. KurarayTM Butacite® Interlayer plastic sheeting is the final product used in safety glass
such as automobile windshields. Polyvinyl butyral resin is shipped off -site as a transfer to other
Kuraray locations for final processing. Wastewater generated from this manufacturing facility is
discharged to the Chemours' wastewater treatment plant.
Kuraray SentryGlas® Manufacturing Area:
The Kuraray America Inc. — Fayetteville Plant's SentryGlas® manufacturing area produces
KurarayTM SentryGlas® ionoplast interlayer laminate. SentryGlase interlayer is used for
laminated safety glass in side, rear, and overhead automobile windows. It is also used in
architectural applications desiring safety glass. There is no contact process wastewater generated
from this manufacturing facility, therefore only sanitary waste from this area is treated in the
Chemours' wastewater treatment plant. This manufacturing facility does discharge non -contact
cooling water to a surface ditch and ultimately to Outfall 002.
DuPont Polyvinyl Fluoride ("PVF") Manufacturing Area:
The DuPont Company — Fayetteville Works' PVF manufacturing area produces polyvinyl fluoride
resin that is used in the electronics industry as a backing for photovoltaic cells, as well as many
other uses. Wastewater generated from this manufacturing facility is discharged to the Chemours'
wastewater treatment plant.
DEQ-CFW 00075351

M *I Chemours Company — Fayetteville Works NPDES Permit No. NCO003573
Supplemental Information — Permit Renewal Application — April 27, 2016
Alternate Application Schedule for §316(b) of the Clean Water Act
Final regulations implementing §316(b) of the Clean Water Act, which establish requirements for
cooling water intake structures at existing facilities, were published in the Federal Register on
August 15, 2014 with an effective date of October 14, 2014.
The Chemours Company — Fayetteville Works ("Chemours") operates a cooling water intake
structure on the Cape Fear River that is subject to this new Federal Cooling Water Intake Structure
Rule ("the Rule") as codified in 40 CFR Part 125.
The Rule requires the owner or operator of a facility subject to Subpart J whose currently effective
permit expires after July 14, 2018, to submit to the Director the information required in the
applicable provisions of 40 CFR 122.21(r) when applying for a subsequent permit.
Pursuant to 40 CFR 125.95(a)(2), the owner or operator of a facility subject to Part 125 Subpart J,
"Requirements Applicable to Cooling Water Intake Structures for Existing Facilities Under
Section 316(b) of the Clean Water Act", whose currently effective permit expires prior to July 14,
2018, may request the Director to establish an alternate schedule for the submission of the
information required in 40 CFR 122.21(r) when applying for a subsequent (renewed) permit.
On October 20, 2015, a letter was sent from Michael E. Johnson, Environmental Manager,
Chemours Company — Fayetteville Works, to Dr. Sergei Chernikov, NCDEQ Division of Water
Resources' NPDES Complex Permitting Unit, requesting an alternate schedule whereby all the
materials'required by the Rule will be submitted with the 2021 renewal application.
On February 26, 2016, a letter was sent from S. Jay Zimmerman, Director, NCDEQ Division of
Water Resources, to Michael E. Johnson, Environmental Manager, Chemours Company —
Fayetteville Works, wherein the requested alternate schedule for submission of required CWIS
information with the next permit renewal in 2021 was approved. A copy of Mr. Zimmerman's
letter is attached to this application package.
DEQ-CFW 00075352

Water Resources
ENVIRONMENTAL QUALITY
February 26, 2016
Mr. Michael E. Johnson, P.E.
Environmental Manager
Chemours Company
22828 NC Highway 87 West
Fayetteville, North Carolina 28306-7332
PAT MCCRORY
Gorcrnor
DONALD R. VAN DER VAART
, rerary
S. JAY ZIMMERMAN
Subject: Alternate CWA 316(b) Application Schedule
NPDES Permit NCO003573
Fayetteville Works
Bladen County
Dear Mr. Johnson:
Director
The Clean Water Act Section 316(b) Cooling Water Intake Structure (CWIS) Final Rule outlines
regulations and standards for the design and operation of cooling water intake structures under the
NPDES program. Your current permit expires October 31, 2016, with renewal application due by May 4,
2016. Since your permit expires prior to July 14, 2018, under 40 CFR 125.95(a)(2), you have requested
an alternative schedule for submission of CWIS permit application information required in 40 CFR Part
122.21( r). Based on Division review, an alternate schedule for submission of required CWIS information
with the next permit renewal in 2021 is approved. This schedule date will be established in the 2016
permit renewal as well.
Please note that facilities should begin to adapt their systems to comply with CWA Section 316(b)
requirements. If you have any questions, please contact Tom Belnick with the NPDES Permitting Unit at
919-807-6390 or via email: tom.belnick(i�nedenr.gov
Sin c ely,
S. Jay Zimmerman, P.G.
Director, Division of Water Resources
Cc: NPDES File
Central File
Ec: US EPA Region 4
US FWS
NC WRC
NC DWR/Fayetteville Region
State of North Carolina I Environmental Quality ( Water Resources
1617 Mad Service Center I Raleigh, North Carolina 27699-1617
919 707 9000
DEQ-CFW 00075353

Chemours Company — Fayetteville Works NPDES Permit No. NCO003573
Supplemental Information — Permit Renewal Application — April 27, 2016
Elimination of Monitoring Requirement for PFOA
In December 2002, the DuPont Company — Fayetteville Works began production of,ammonium
perfluorooctanoate ("APFO"), which is the ammonium salt of perfluorooctanoic acid ("PFOA").
The renewed NPDES Permit No. NC0003573 that became effective on July 1, 2007, included a
requirement for monthly monitoring of PFOA at Outfall 002.
In 2006 the North Carolina Division of Water Quality ("DWQ"), in consultation with the North
Carolina Division of Waste Management and the North Carolina Department of Health and Human
Services, established an Interim Maximum Allowable Concentration ("IMAC") of 2 µg/L for
PFOA, which was intended for the protection of groundwater as a source of drinking water.
Following the issuance of this temporary health -based level, DWQ requested the assistance of the
North Carolina Secretary's Science Advisory Board on Toxic Air Pollutants ("NCSAB") in
reviewing the toxicological literature on PFOA and recommending to DWQ an update of the
IMAC for PFOA in groundwater. On August 10, 2012, the NCSAB issued their recommendation
to DWQ that the IMAC for PFOA in groundwater be reduced to 1 µg/L.
During the 3-year period from 20`13 to 2015, the average monthly concentration of the final
effluent discharge at Outfall 002 was 0.027 µg/L PFOA, with a maximum concentration of
0.088 µg/L PFOA. During the same period, the average monthly concentration of the incoming
water from the Cape Fear River to the site, which is 99% of the effluent flow at Outfall 002, was
0.012 µg/L PFOA, with a maximum concentration of 0.031 µg/L PFOA.
The production of APFO at this facility ceased in April 2013.
The Chemours Company — Fayetteville Works (formerly the DuPont Company — Fayetteville
Works) is requesting that the monthly monitoring requirement for PFOA at Outfall 002 be
eliminated in the renewed NPDES Permit No. NCO003573 for the following reasons:
• APFO is no longer manufactured at this facility and has not been produced at the facility
since April 2013;
• APFO is not and has never been used as a process aid or a raw material at this facility;
• The 3-year average concentration at Outfall 002 was 0.027 µg/L PFOA, versus the current
NC-DWR IMAC of 2 µg/L PFOA and the NCSAB recommended 1 µg/L PFOA; and
• PFOA is present at low concentrations throughout the Cape Fear River basin, and that
background level of PFOA in the Cape Fear River water contributes to the concentration
measured at Outfall 002.
DEQ-CFW 00075354

Chemours•Company — Fayetteville Works NPDES Permit No. NC0003573
l�
Supplemental Information — Permit Renewal Application — April 27, 2016
Form 2C Permit Application — Bis(chloromethyl) ether
Bis(chloromethyl) ether (CAS No. 542-88-1) was not analyzed for, and consequently was not
reported on Page V-4 of Form 2C for both Outfall 001 and Outfall 002.
On November 28, 2014, the State of Oregon's Department of Environmental Quality ("ODEQ")
issued a memorandum (Noce ') addressing the issue of analyzing for bis(chloromethyl) ether
("BCME"). In this memorandum, ODEQ states:
" Based on the chemical's rapid hydrolysis in water, there are no analytical methods to measure
BCME in water samples. Currently, the only analytical techniques available for this compound
are for air samples. Region 10 EPA staff queried its Manchester Environmental Lab in Port
Orchard, WA about potential, analytical methods for BCME. Staff at the lab confirmed that
there is no EPA method for BCME because of its rapid degradation in water."
Because of the lack of an•EPA approved analytical method for bis(chloromethyl) ether in a water
matrix, ODEQ concluded:
" Given its rapid hydrolysis in water, there are no recommended analytical methods for BCME
in water samples. Because BCME is not quantifiable in wastewater, DEQ will not require
permit holders to monitor or conduct reasonable potential analyses for this toxic pollutant."
In an April 13, 2106, email from Tom Belnick, Supervisor of the NCDEQ Division of Water
Resources' NPDES Complex Permitting Unit, to Michael Johnson, Environmental Manager,
Chemours Company — Fayetteville Works, Mr. Belnick stated:
"I checked with our DWR analytical lab, and they concur with Oregon's position and are not
aware of any labs using even R&D methods for this analyte. Therefore, you can omit this
parameter from your application renewal."
Note l: http://www.deq.state.or.us/wq/standards/docs/toxics/BisChloromethylMemo.pdf
DEQ-CFW 00075355

BROOKS �_.
---"'� PIERCE
FOUNDED 1897
August 3, 2017
Via Certified Mail
E.I. du Pont de Nemours and Company
c/o CT Corporation System, Registered Agent
160 Mine Lake Court, Suite 200
Raleigh, NC 27615-6417
Ellis H. McGaughy
Fayetteville Works Plant Manager
The Chemours Company FC, LLC
22828 NC Highway 87 West
Fayetteville, NC 28306-7332
V. Anne Heard
Region 4 Administrator
U.S. Environmental Protection Agency
61 Forsyth Street, S.W.
Mail Code: 9T25
Atlanta, GA 30303-8960
Michael S. Regan
Secretary
N.C. Department of Environmental Quality
1601 Mail Service Center
Raleigh, NC 27699-1601
Michael Scott
N.C. DEQ, Division of Waste Management
1646 Mail Service Center
Raleigh, NC 27699-1646
Josh Stein
N.C. Attorney General
N.C. Department of Justice
9001 Mail Service Center
Raleigh, NC 27699-9001
2000 RENAISSANCE PLAZA
230 NORTH ELM STREET
GREENSBORo, NC 27401
T 336.373.8850
F 336.378.1001
WWW.BROOILSPIFRCE.COP:I
The Chemours Company FC, LLC
c/o CT Corporation System, Registered Agent
160 Mine Lake Court, Suite 200
Raleigh, NC 27615-6417
Scott Pruitt
Administrator
U.S. Environmental Protection Agency
William Jefferson Clinton Building
1200 Pennsylvania Avenue, N. W.
Mail Code: 1101A
Washington, DC 20460
Jeff Sessions
U.S. Attorney General
U.S. Department of Justice
950 Pennsylvania Avenue, NW
Washington, DC 20530-0001
S. Jay Zimmerman
N.C. DEQ, Division of Water Resources
1611 Mail Service Center
Raleigh, NC 27699-1611
Governor Roy Cooper
N.C. Office of the Governor
20301 Mail Service Center
Raleigh, NC 27699-0301
DEQ-CFW 00075356

Re: Notice of Intent to Bring Citizen Suit Against:
(a) The Chemours Company FC, LLC (Chemours) and
(b) E.I. DuPont de Nemours & Company (DuPont)
Ladies and Gentlemen:
Our law firm represents Cape Fear Public Utility Authority ("CFPUA") in connection with
perfluorinated chemicals ("PFCs") released by Chemours and DuPont into the Cape Fear River at
the Fayetteville Works facility. The Fayetteville Works facility is a chemical manufacturing
facility owned and operated by Chemours and is located on the Cape Fear River near Fayetteville,
North Carolina. The Cape Fear River is a major source for drinking water.
CFPUA is a water authority created pursuant to North Carolina General Statutes Chapter
162A that provides potable water to residents of New Hanover County and the City of Wilmington.
One of CFPUA's water supply intakes is located on the Cape Fear River in Bladen County, North
Carolina, downstream of the Fayetteville Works facility.
You are hereby provided notice that CFPUA, through undersigned counsel, intends to file
a lawsuit against Chemours and DuPont in federal court to enforce the requirements of the Clean
Water Act ("CWA") and Resource Conservation and Recovery Act ("RCRA"). The federal court
complaint will allege that: Chemours is in continuing violation of an "effluent standard or
limitation" under the CWA (33 U.S.C. § 1365(a)(1)); and Chemours and DuPont have contributed,
and Chemours is contributing, "to the past or present handling, storage, treatment, transportation,
or disposal of any solid or hazardous waste which may present an imminent and substantial
endangerment to health or the environment" in violation of RCRA (42 U.S.C. § 6972(a)(1)(B)).
This notice is provided to you pursuant to and in accordance with the requirements of Section
505(b)(1)(A) of the CWA, 33 U.S.C. § 1365(b)(1)(A), and Section 7002(b)(2)(A) of RCRA, 42
U.S.C. § 6972(b)(2)(A).
In accordance with CWA Section 505(b)(1)(A) and applicable rules governing the
provision of notice of intent to file a CWA citizen suit at 40 C.F.R. Part 135, and RCRA Section
7002(b)(2)(A) and applicable rules governing the provision of notice of intent to file a RCRA
citizen suit at 40 C.F.R. Part 254, CFPUA hereby provides the following information:
A. Facts
1) Fayetteville Works Facility operations
Chemours was a wholly owned subsidiary of DuPont when it acquired the Fayetteville
Works facility from DuPont on February 1, 2015. Chemours later separated from DuPont in July
2015. The Fayetteville Works facility had been operated by DuPont since the early 1970s. DuPont
still operates a manufacturing area at the facility.
The Fayetteville Works facility has five discrete manufacturing areas: (i)
Fluoromonomers/Nafion (operated by Chemours); (ii) Polymer Processing Aid ("PPA") (operated
by Chemours); (iii) Butacite (operated by Kuraray and rented from Chemours); (iv) SentryGlas
2
DEQ-CFW 00075357

(operated by Kuraray and rented from Chemours); and (v) Polyvinyl Fluoride ("PVF") (operated
by DuPont and rented from Chemours). The wastewater from each of the manufacturing areas
flows through Chemours' on -site wastewater treatment plant ("WWTP"), is diluted with much
larger volumes of water, and is ultimately discharged into the Cape Fear River at Outfall 002. The
Fayetteville Works facility is operating under NPDES Permit No. NC0003573 (the "NPDES
Permit"), the most recent version of which was issued to Chemours for the point source discharge
from the entire Fayetteville Works facility.
According to a Chemours representative, the Fayetteville Works facility has been
generating and discharging a substance or group of substances, now identified as GenX, as a
byproduct since 1980. Based upon information and belief, the generation of GenX at the
Fayetteville Works facility, as a product, byproduct or otherwise, has been and is accompanied by
the generation of GenX Pollutants which are defined in this notice as follows:
• chemicals collectively identified by DuPont and Chemours as "GenX";
• chemicals that are structurally or functionally or otherwise similar to GenX that result from
or are associated with the manufacture, use, processing, treatment, or disposal of GenX;
• perfluoroalkyl ether carboxylic acids (PFECAs); and
• chemicals that are structurally or functionally or otherwise similar to PFECAs that result
from or are associated with the manufacture, use, processing, treatment, or disposal of
PFECAs.
More specifically, the GenX Pollutants include, without limitation, the following GenX Pollutants
found in the Cape Fear River in the vicinity of the CFPUA intakes:
• GenX (described in more detail in section A.3 of this notice);
Perfluoroalkyl ether carboxylic acids with one ether group (mono -ether PFECAs)
including:
o Perfluoro-2-methoxyacetic acid; C3HF503; CAS No. 674-13-5
o Perfluoro-3-methoxypropanoic acid; C4HF703; CAS No. 377-73-1
o Perfluoro-4-methoxybutanoic acid; C5HF903; CAS No. 863090-89-5
Perfluoroalkyl ether carboxylic acids with multiple ether group (multi -ether PFECAs)
including:
o Perfluoro(3,5-dioxahexanoic) acid; C4HF704; CAS No. 39492-88-1
o Perfluoro(3,5,7-trioxaoctanoic) acid; C5HF905; CAS No. 39492-89-2
o Perfluoro(3,5,7,9-tetraoxadecanoic) acid; C6HF1106; CAS No. 39492-90-5
By 2011, in addition to its generation as a byproduct, GenX was intentionally manufactured
at the Fayetteville Works facility as a replacement for another substance or group of substances
called "C8" (CAS No. 3825-26-1). C8 is also known as perfluorooctanoic acid ("PFOA") or its
salt, ammonium perfluorooctanoate ("APFO"). The substance is a long -chain synthetic
DEQ-CFW 00075358

perfluorinated carboxylic acid' used in the manufacturing of products such as Teflon. CFPUA is
informed and believes that C8 was discontinued because of its adverse effects on the environment
and human health and that studies indicate GenX has similar adverse effects. Based on information
and belief, Chemours and DuPont have released, and Chemours continues to release, GenX and
GenX Pollutants into air, soil, surface water, and groundwater at the Fayetteville Works facility.
2) DuPont's NPDES Permit applications and production of C8
In or around December 1995, DuPont submitted to North Carolina Department of
Environment and Natural Resources' ("DENR"), as part of its NPDES Permit renewal application,
a request to reroute the Nafion wastewater to bypass the facility's wastewater treatment plant.
According to DuPont, the only significant pollutant in the "low biodegradable" wastewater was
fluoride, which was not removed in the water treatment process, so the wastewater only added to
the hydraulic load at the WWTP. The 1996 NPDES Permit appears to have authorized the bypass.
Based upon information and belief, the Nafion wastewater also included GenX Pollutants.
On May 3, 2001, DuPont submitted a renewal application for its 1996 NPDES Permit in
which the company disclosed its intent to begin manufacturing C8 at the Fayetteville Works
facility. DuPont had previously been purchasing C8 from 3M, but CFPUA is informed and
believes that 3M stopped manufacturing the substance due to concerns over its persistence,
bioaccumulation and toxicity. CFPUA is informed and believes that, by the time of its 2001
NPDES renewal application:
a) DuPont had been conducting medical studies on C8 for decades. DuPont already
"understood that PFOA [i.e., C8] caused cancerous testicular, pancreatic, and liver
tumors in lab animals. One laboratory study suggested possible DNA damage from
PFOA exposure, and a study of workers linked exposure with prostate cancer."
Nathaniel Rich, The Lawyer Who Became DuPont's Worst Nightmare, The NY Times
Magazine, Jan. 6, 2016.
b) In 1991, DuPont set an internal exposure guideline of 1 ppb.
c) DuPont had been the defendant in a federal lawsuit over adverse health effects arising
from C8 contamination from its facility in Parkersburg, West Virginia, and a class
action regarding adverse health effects was filed against the company in August 2001.
However, CFPUA is informed and believes that DuPont in its 2001 NPDES Permit renewal
application failed to disclose any of the studies or health data on C8 in its possession. Instead,
DuPont represented to DEQ's Division of Water Quality3 ("DWQ") that: (i) based on "medical
surveillance of its own employees and epidemiological data from others in the industry," C8 "does
not pose a health concern to humans or animals at levels present in the workplace or environment";
(ii) DuPont had used C8 for forty years "with no observed health effects in workers"; and (iii) the
compound "is neither a known developmental toxin nor a known human carcinogen." The 2001
' PFOA is considered a long -chain PFC because it has a string of eight carbons off the carboxylic
acid compound —hence the name "C8."
'Now Department of Environmental Quality ("DEQ").
3 Now Division of Water Resources ("DWR").
2
DEQ-CFW 00075359

NPDES Permit application requested authorization to discharge the C8 wastewater directly to a
dedicated outfall, bypassing the facility's WWTP. CFPUA understands that, beginning in the fall
of 2002, DuPont started manufacturing C8 at the Fayetteville Works facility. The renewal NPDES
Permit, however, was not issued until January 2004. Because later submissions from DuPont
represented that the C8 manufacturing operation was constructed to have no process wastewater
discharges, and that the wastewater would be captured and incinerated off site, the 2004 NPDES
Permit did not include authorization for discharge of the C8 manufacturing wastewater. Upon
information and belief, the wastewater from C8 manufacturing included GenX Pollutants.
3) Phase out of C8 and transition to GenX
In 2006, EPA initiated a voluntary PFOA Stewardship Program, in which DuPont
participated, calling for the complete elimination of PFOA (i.e,, C8) both from emissions to all
media and from product content by 2015. DuPont identified GenX as a viable replacement
compound. GenX (CAS Nos. 13252-13-6 and 62037-80-3) falls within a category of chemicals
known as short-chain4 PFECAs.
DuPont submitted its next NPDES Permit renewal application on May 1, 2006. As to the
manufacture of C8, DuPont represented in its application that: (i) the wastewater "is collected and
shipped off -site for disposal"; (ii) "[n]o process wastewater from this manufacturing facility is
discharged to the site's biological WWTP or to the Cape Fear River"; and (iii) the C8 produced at
the facility "is used to produce fluoropolymers and fluorinated telomers, but none of the produced
[C8] is used at the Fayetteville Works site." As to the Nafion manufacturing operations, DuPont
disclosed in its application that the plant manufactures five final products, including FLPR Vinyl
Ether monomers and HFPO monomers (hexafluoropropylene oxide, CAS No. 428-59-1).
According to DuPont, the Vinyl Ether and HFPO monomers are shipped to other DuPont locations
to produce various fluoroebemical products such as Teflon, and the Nafion wastewater was now
being treated in the facility's WWTP.
The renewal NPDES Permit was issued May 25, 2007. Although all C8 process
wastewater was to be captured and disposed of off -site, the permit included a monitoring condition
for C8 due to known groundwater contamination.
In 2008, DuPont submitted to the EPA pre -manufacture notices for GenX (P-08-508 and
P-08-509) pursuant to the Toxic Substances Control Act ("TSCA"). On January 28, 2009, EPA
and DuPont entered the TSCA Consent Order governing the manufacture of GenX. The Consent
Order specified that "EPA has concerns that [GenX] will persist in the environment, could
bioaccumulate, and be toxic (`PBT') to people, wild mammals, and birds," and that, based on
available data, "EPA has human health concerns" for GenX. TSCA Consent Order at vii., Due to
the likelihood that GenX would be used as a substitute for C8, EPA determined that "more
information is needed on the toxicity and pharmacokinetics" of GenX, and noted the "high concern
for possible environmental effects over the long-term." TSCA Consent Order at xi—xii.
Accordingly, EPA concluded that "uncontrolled manufacture, import, processing, distribution in
4 GenX is a short -chain PFC in that two shorter carbon chains are connected by an ether linkage
as opposed to the unbroken eight -carbon chain in C8.
DEQ-CFW 00075360

commerce, use, and disposal of [GenX] may present an unreasonable risk of injury to human health
and the environment." TSCA Consent Order at xv. Due to the stated concerns of EPA, the Consent
Order authorized the manufacture of GenX but required that DuPont "recover and capture
(destroy) or recycle [GenX] at an overall efficiency of 99% from all effluent process streams and
the air emissions (point source and fugitive)." TSCA Consent Order at 36.
As part of its NPDES permit renewal process, DuPont representatives, including its
environmental manager Michael Johnson, met in August 2010 with DWQ to discuss the phase -out
of C8. During that meeting, CFPUA is informed and believes that DuPont identified the C8
replacement as "GenX" and, consistent with the disclosures in its renewal application, represented
that the wastewater generated from the manufacture of GenX would be captured and disposed of
off -site.
On April 29, 2011, DuPont submitted another NPDES Permit renewal application. CFPUA
is informed and believes that DuPont had begun transitioning from C8 to GenX by that time.
Where its disclosures previously identified the manufacture of C8, DuPont instead identified the
manufacturing area as a "PPA [polymer processing aid] manufacturing area." DuPont represented
in its application that: (i) the "processing aids produced in this unit are used to produce
fluoropolymers and fluorinated telomers, but none of the produced processing aids are used at the
Fayetteville Works site"; (ii) "[a]ll process wastewater generated from this manufacturing facility
is collected and shipped off -site for disposal'; and (iii) "[n]o process wastewater from this
manufacturing facility is discharged to the site's biological WWTP or to the Cape Fear River."
DuPont's representations regarding the Nafion plant are essentially identical to its May 2006
NPDES application. The effluent from the Nafion wastewater is represented as being heavily
diluted with noncontact river water and other water prior to discharge.
The NPDES Permit renewal was issued February 6, 2012, and advised DuPont that the
Cape Fear River segment into which DuPont is discharging wastewater had been reclassified to a
water supply classification—WS-IV. As with the prior NPDES permit, PFOA (i.e., C8)
monitoring conditions were included; PFOA monitoring was required at Outfall 002—after
dilution with large volumes of non -contact river water and other water. The 2012 NPDES Permit
does not authorize the discharge of GenX or any other GenX Pollutants.
4) RCRA investigation of C8 contamination
At some point after DuPont began the manufacture of C8 at its Fayetteville Works facility,
the site became contaminated with C8 in the soil and groundwater, due (on information and belief)
to some combination of spills, leaks, releases, discharges, and air emissions. DuPont conducted a
RCRA Facility Investigation (RFI) under the Hazardous and Solid Waste Amendments Corrective
Action Program, which led to the issuance of a Phase III RFI Report in February 2014, revised
August 2014. According to the RFI Report, at least seven releases occurred between March 2011
and February 2013, including a release from the PPA facility in June 2011, a release from the
Nafion facility in March 2012, and a release from the Waste Fluorocarbon Storage Tank in March
2012. Based upon information and belief, at the time of some or all of those releases, DuPont was
manufacturing or otherwise producing GenX Pollutants, which are likely to have been
contaminants in one or more of the releases.
0
DEQ-CFW 00075361

Earlier RFI reports —in particular the Phase I RFI dated April 14, 2003 and revised August
1, 2003, the Phase II RFI dated June 2006 and its August 2009 Addendum —include additional
findings regarding historical contamination and releases at the Fayetteville Works facility. Among
other things, the RFIs: (i) identify C8 contamination in soil and groundwater throughout the
Fayetteville Works facility, and posit that some of the contamination is due to deposition of C8 air
emissions; (ii) indicate that until 1990, unlined lagoons constructed in or around 1979 were used
as biosludge settlement lagoons for wastewater from throughout the facility, before discharging to
the Cape Fear River; and (iii) acknowledge historical releases at the Nafion manufacturing area,
including from solid waste management units (SWMUs) handling Nafion wastewater. CFPUA is
informed and believes that DuPont was generating GenX Pollutants at the Fayetteville Works
facility during the time of the activities and releases at the facility identified in the RFIs, such that
GenX Pollutants were constituents of the contamination and releases described in the RFIs.
5) Change of ownership and 2016 NPDES Permit application
On June 19, 2015, DuPont submitted an ownership change request, notifying DWR of the
pending transfer of the Fayetteville Works facility to Chemours and requesting a permit
amendment. On June 24, 2015, Michael Johnson, Chemours' (and previously DuPont's)
environmental manager, met with DWQ officials to discuss a "new" perfluorinated compound
identified in the Cape Fear River, GenX, which had been identified by N.C. State University
researchers conducting sampling on the Cape Fear River as part of a study commissioned by EPA.
The researchers have since published their results, Legacy and Emerging Perfluoroalkyl
Substances are Important Drinking Water Contaminants in the Cape Fear River Watershed of
North Carolina, in Environmental Science & Technology Letters (November 10, 2016) ("Knappe
Report"). CFPUA is informed and believes that DuPont represented to DWQ that GenX was CS's
replacement, and that GenX was no longer being discharged to the Cape Fear. The 2012 NPDES
Permit was amended to reflect the change of ownership effective July 1, 2015.
Chemours submitted its most recent NPDES Permit renewal application on April 27, 2016.
The application contained essentially identical representations regarding the PPA and Nafion
manufacturing areas as the April 2011 renewal application. Similar to the prior application, the
effluent from the Nafion wastewater is represented as being heavily diluted with noncontact river
water and other water prior to discharge.
The April 2016 NPDES renewal application requested that the C8 monitoring condition be
removed from the NPDES Permit. Chemours' justification for the request was that C8 monitoring
at Outfall 002 showed an average C8 concentration of .027 ug/L—below the recommended Interim
Maximum Allowable Concentration ("IMAC") of 1 ug/L. Chemours' further asserted that non -
contact water from the Cape Fear River —which Chemours represented constituted 99% of the
effluent flow at Outfall 002—had an average C8 concentration of .012 ug/L, thus contributing to
the total C8 in the effluent. Based on Chemours' representations: (i) the pre -dilution effluent —
only 1% of the final discharge —would be the cause of the increase in C8 concentration from .012
ug/L to .027 ug/L at Outfall 002, and (ii) the actual concentration of C8 in Chemours' effluent
prior to dilution by water from the Cape Fear River would be 1.5 ug/L, which exceeds by 50
percent the IMAC upon which Chemours chose to base its request. In addition, groundwater
monitoring results in the RFI Report suggest that Chemours' on -site C8 contamination may have
7
DEQ-CFW 00075362

impacted Willis Creek, which flows into Cape Fear River just upstream of Chemours' intake,
potentially contributing to the reported 0.12 ug/L concentration of C8 in the Cape Fear River at
the Chemours intake.
6) Discovery of GenX in the Cape Fear River
The Knappe Report shows that GenX, along with six other GenX Pollutants, are present in
the Cape Fear River, downstream of the Fayetteville Works facility. The report found that GenX
was in the raw water at CFPUA's intake at mean concentrations of 631 ng/L, and six other GenX
Pollutants (all PFECAs) were found at even higher levels. Based upon information and belief, the
Fayetteville Works facility is the source of each of the GenX Pollutants at CFPUA's intake.
The Knappe Report indicates that CFPUA's water treatment plant is largely ineffective at
removing PFECAs from the water during the treatment process. With regard to treatment options,
although reverse osmosis might be effective, it is not practicable to implement at the scale required
given the volume of water treated by CFPUA. Finally, carbon filtration is not known to be
effective at removing PFECAs.
Once publicly confronted about GenX contamination in the Cape Fear River, Chemours:
(a) asserted that GenX is an "unregulated" chemical that was being discharged as a byproduct from
its Nafion-related manufacturing processes, in particular during the manufacture of vinyl ethers;
(b) disclosed that GenX was in its air emissions as part of those same processes; and (c) explained
that GenX had been discharged from its vinyl ether process, unabated, from 1980 until November
2013, at which time abatement technology was implemented to reduce the GenX discharge by 80
percent. Following public outcry, Chemours committed to taking steps to prevent discharge of
any wastewaters containing GenX by June 21, 2017. However, as recently as July 12, 2017, GenX
was identified in Chemours' effluent being discharged to the Cape Fear River.
After reviewing the available data regarding the PBT characteristics of GenX and
consultation with EPA, North Carolina Department of Health and Human Services ("DHHS")
issued a Risk Assessment on July 14, 2017 setting a health goal of 140 ng/L. Subsequent testing
has shown GenX present in the raw CFPUA's intake, and in the Authority's finished water, at
concentrations in excess of the health goal.
B. Chemours is violating CWA and RCRA, and Chemours and DuPont have
violated RCRA
1) The specific standard, limitation or order alleged to be violated under CWA
Section 505(a)(1) of the CWA permits citizens to commence a civil action against "any
person ... who is alleged to be in violation of ... an effluent standard or limitation under this
Act," 33 U.S.C. § 1365(a)(1), including the prohibition against discharging pollutants without an
NPDES permit. 33 U.S.C. § 1311(a).
"Pollutants" under the CWA include "chemical wastes ... and industrial ... waste
discharged into water." 33 U.S.C. § 1362(6). GenX Pollutants, including GenX, are "pollutants"
8
DEQ-CFW 00075363

as defined under the CWA. Based on information and belief, GenX Pollutants have been and
continue to be among CWA pollutants that are discharged into the Cape Fear River from the
Fayetteville Works. Based on information and belief, GenX Pollutants are discharged by DuPont
from its manufacturing area to the Cape Fear River, using the Chemours WWTP as a conduit.
Based on information and belief, the WWTP does not effectively remove GenX Pollutants from
wastewater that is routed through it.
The NPDES Permit does not authorize, and has never authorized, discharge of GenX
Pollutants from the Fayetteville Works facility. In order to operate in compliance with an NPDES
permit, the permit holder must (1) comply with the express terms of the permit; and (2) not make
a discharge of pollutants that was not within the reasonable contemplation of the permitting
authority at the time the permit was granted. Piney Run Pres. Ass'n v. County Comm'rs of Carroll
County, 268 F.3d 255 (4th Cir. 2001). Because Chemours and DuPont never identified the GenX
Pollutants as constituents in their effluent, the substances could not have been within the
contemplation of DEQ, and are therefore not authorized to be discharged by the NPDES Permit.
In addition, DuPont's and Chemours' unauthorized discharges of GenX Pollutants are
causing violations of North Carolina water quality standards adopted and enforced pursuant to the
CWA, including water quality standards for "oils, deleterious substances, colored, or other
wastes," 15A NCAC 2B .0211(12), and for "toxic substances." 15A NCAC 2B .0208, 15A NCAC
2B .0211 (incorporating 15A NCAC 2B .0208 by reference), and 15A NCAC 2B .0216(3)(a) and
(h)•
2) The specific permit standard regulation condition requirement or order
which has allegedly been violated under RCRA
Section 7002(a)(1)(B) of RCRA permits citizens to commence a civil action against:
any person ... including any past or present generator, past or present transporter,
or past or present owner or operator of a treatment, storage, or disposal facility, who
has contributed or who is contributing to the past or present handling, storage,
treatment, transportation, or disposal of any solid or hazardous waste which may
present an imminent and substantial endangerment to health or the environment.
42 U.S.C. § 6972(a)(1)(B).
Chemours and DuPont are both in violation of this provision, based on their discharges,
disposals and other releases of GenX Pollutants described above and discussed in more detail
below.
3) Activities alleged to be a violation of CWA and RCRA
The CWA violations by DuPont and Chemours are the historic and ongoing unpermitted
discharges of GenX Pollutants at and from the Fayetteville Works facility (including without
limitation discharges from the WWTP) and the resulting violations of water quality standards as
previously described.
0
DEQ-CFW 00075364

The RCRA violations by Chemours and DuPont are the historic and ongoing contribution
to the disposals and other releases of GenX Pollutants to soil, groundwater, surface water, and air
at and from the Fayetteville Works facility, which have contaminated and are contaminating the
Cape Fear River. As determined by DHHS in its Risk Assessment, and consistent with the health
concerns identified by EPA in its TSCA Consent Order, and as indicated in study reports such as
Evaluation of substances used in the GenX technology by Chemours, Dordecht, National Institute
for Public Health and the Environment, The Netherlands (2016) at page 3 of 92 (GenX substances
"are perfluorinated hydrocarbons and poorly degradable in the environment ... [and] are causing
similar harmful effects as PFOA (such as carcinogenic [effects] and effects on the liver.")), the
GenX released in the Cape Fear River may present an imminent and substantial endangerment to
health or the environment. Other GenX Pollutants in the Cape Fear River are similar substances
to GenX and should be expected to have similar effects and therefore may present an imminent
and substantial endangerment to health or the environment.
The dates of the violations are as identified in Part A above.
On June 27, 2017, CFPUA sent written Requests for Information to Chemours, requesting
information regarding, among other things, Chemours' and DuPont's historical use, discharges,
releases, and emissions of GenX Pollutants, as well as information regarding GenX Pollutants'
effect on human or environmental health. To date, Chemours has refused to provide the requested
information. CFPUA expressly reserves the right to supplement its prospective citizen suit with
any information currently withheld by Chemours that is later disclosed in discovery.
4) Persons responsible for the alleged violation
The persons responsible for the alleged violation currently known to CFPUA include Ellis
H. McGaughy, Fayetteville Works plant manager, and Michael E. Johnson, Fayetteville Works
plant environmental manager.
5) Name, address, and telephone number of person givingnotice
otice
The name and contact information of the person giving notice is as follows:
Cape Fear Public Utility Authority
235 Government Center Drive
Wilmington, NC 28403
Attn: Jim Flechtner
Telephone: [phone]
The counsel for CFPUA is Brooks, Pierce, McLendon, Humphrey, and Leonard, L.L.P., of
Greensboro, North Carolina. The name and contact information of counsel for the person giving
notice is as follows:
10
DEQ-CFW 00075365

George W. House
V. Randall Tinsley
Joseph A. Ponzi
Brooks, Pierce, McLendon, Humphrey & Leonard, L.L.P.
2000 Renaissance Plaza
230 North Elm Street
Greensboro, NC 27401
Telephone: [phone]
Facsimile: [phone]
Messrs. House, Tinsley, and Ponzi are providing this notice as counsel for CFPUA.
6) Notice of intent to sue
CFPUA intends to file suit not earlier than 60 days after this notice is given as authorized
by the Clean Water Act. CFPUA intends to file suit not earlier than 90 days after this notice is
given as authorized by the Resource Conservation Recovery Act.
Pursuant to the CWA, RCRA, and EPA's rules at 40 C.F.R. Part 135 and Part 254, copies
of this notice letter are being served on the EPA Administrator, the EPA Regional Administrator,
the United States Attorney General, the N.C. DEQ Secretary, the N.C. DWR Director, and the
N.C. DWM Director.
cc: Bill Lane, NC DEQ
11
Sincerely,
L
Georg7Wouse
V. Randall Tinsley
Joseph A. Ponzi
DEQ-CFW 00075366

15A NCAC 02C .0219 AQUIFER STORAGE AND RECOVERY WELLS
(a) Aquifer Storage and Recovery Wells are used to inject potable water for the purposes of subsurface storage and
for later recovery of the injected water. All Aquifer Storage and Recovery Wells require permits.
(b) Permit Applications. In addition to the permit requirements set forth in Rule .0211 of this Section, an
application shall be submitted, in duplicate, to the Director on forms furnished by the Director and shall include the
following:
(1) Site Description that includes the following:
(A) the name of the well owner or person otherwise legally responsible for the injection well,
his or her mailing address and telephone number, and status as a federal, state, private,
public, or other entity;
(B) the name of the property owner, if different from the well owner, their physical address,
mailing address, and telephone number;
(C) the name, mailing address, telephone number, and geographic coordinates of the facility
for which the application is submitted; and
(D) a list of all permits associated with the injection well system.
(2) Project Description. A description of what problem the project is intended to solve or what
objective the project is intended to achieve and shall include the following:
(A) history and scope of the problem or objective;
(B) what is currently being done to solve the problem or achieve the objective;
(C) why existing practices are insufficient to solve the problem or achieve the objective;
(D) what other alternatives were considered to solve the problem or achieve the objective;
and
(E) how this option was determined to be the most effective or desirable to solve the problem
or achieve the objective.
(3) Demonstration of Financial Responsibility as required in Rule .0208 of this Section.
(4) Injection Zone Determination. The applicant shall specify the horizontal and vertical portion of
the injection zone within which the proposed injection activity shall occur based on the hydraulic
properties of that portion of the injection zone specified. No violation of groundwater quality
standards specified in Subchapter 02L resulting from the injection shall occur outside the specified
portion of the injection zone as detected by a monitoring plan approved by the Director.
(5) Hydrogeologic Evaluation. If required by G.S. 89E, G.S. 89C, or G.S. 89F, a licensed geologist,
professional engineer, or licensed soil scientist shall prepare a hydrogeologic evaluation of the
facility to a depth that includes the injection zone determined in accordance with Subparagraph
(b)(4) of this Rule. A description of the hydrogeologic evaluation shall include all of the
following:
(A) regional and local geology and hydrogeology;
(B) changes in lithology underlying the facility;
(C) depth to the mean seasonal high water table;
(D) hydraulic conductivity, transmissivity, and storativity of the injection zone based on tests
of site -specific material, including a description of the test(s) used to determine these
parameters;
(E) rate and direction of groundwater flow as determined by predictive calculations or
computer modeling; and
(F) lithostratigraphic and hydrostratigraphic logs of test and injection wells.
(6) Area of Review. The area of review shall be calculated using the procedure for determining the
zone of endangering influence specified in 40 CFR 146.6(a). The applicant must identify all wells
within the area of review that penetrate the injection or confining zone, and repair or permanently
abandon all wells that are improperly constructed or abandoned.
(7) Analyses of the injection zone(s) including:
(A) test results of the native groundwater and the proposed recharge water for the parameters
listed in Subparagraph (h)(4) of this Rule;
(B) geochemical analyses of representative samples of the aquifer matrix to determine the
type and quantity of reactive minerals; and
(C) evaluation of the chemical compatibility of the native groundwater, injected water, and
the aquifer matrix using site specific geochemical data and hydraulic properties of the
injection zones, geochemical modeling, and any other analytical tool required. The
DEQ-CFW 00075367

chemical compatibility evaluation shall identify potential changes in groundwater quality
resulting from the injection activities within the area of review specified in Subparagraph
(b)(6) of this Rule.
(8) Injection Procedure. The applicant shall submit a description of the proposed injection procedure
that includes the following:
(A) the proposed average and maximum daily rate and quantity of injectant;
(B) the average maximum injection pressure expressed in units of pounds per square inch
(psi);
(C) calculation of fracture pressures of confining units expressed in units of psi; and
(D) the total or estimated volume to be injected.
(9) Injection well construction details including:
(A) the number and depth of injection wells;
(B) indication of whether the injection wells are existing or proposed;
(C) depth and type of casing;
(D) depth and type of screen material;
(E) depth and type of grout; and
(F) plans and specifications of the surface and subsurface construction of each injection well
or well system.
(10) Monitoring Wells. Monitoring wells shall be located so as to detect any movement of injection
fluids, process byproducts, or formation fluids outside the injection zone as determined by the
applicant in accordance with Subparagraph (b)(4) of this Rule. The monitoring schedule shall be
consistent with the proposed injection schedule, pace of the anticipated reactions, and rate of
transport of the injected fluid. The applicant shall submit a monitoring plan that includes the
following:
(A) a list of monitoring parameters and analytical methods to be used;
(B) other parameters that may serve to indicate the progress of the intended reactions;
(C) a list of existing and proposed monitoring wells to be used; and
(D) a sampling schedule to monitor the proposed injection.
(11) Well Data Tabulation. A tabulation of data on all existing or abandoned wells within the area of
review of the injection well(s) that penetrate the proposed injection zone, including water supply
wells, monitoring wells, and wells proposed for use as injection or monitoring wells. Such data
shall include a description of each well's type, depth, and record of abandonment or completion.
(12) Plan of Action. A proposed plan of action to be taken if the proposed injection operation causes
fracturing of confining units, results in adverse geochemical reactions, or otherwise threatens
groundwater quality.
(13) Maps and Cross -Sections. Scaled, site -specific site plans or maps depicting the location,
orientation, and relationship of facility components including the following:
(A) area map based on the most recent USGS 7.5' topographic map of the area, at a scale of
1:24,000 and showing the location of the proposed injection site;
(B) topographic contour intervals showing all facility related structures, property boundaries,
streams, springs, lakes, ponds, and other surface drainage features;
(C) all existing or abandoned wells within the area of review of the injection well(s), listed in
the tabulation required in Subparagraph (b)(I I) of this Rule, that penetrate the proposed
injection zone, including water supply wells, monitoring wells, and wells proposed for
use as injection wells;
(D) potentiometric surface map(s) of each hydrostratigraphic unit in the injection zone(s) that
show the direction of groundwater movement, and all existing and proposed wells;
(E) cross-section(s) that show the horizontal and vertical extent of the injection zone(s),
lithostratigraphic units, hydrostratigraphic units, and all existing and proposed wells,
complete with casing and screen intervals; and
(F) any existing sources of potential or known groundwater contamination, including waste
storage, treatment, or disposal systems within the area of review of the injection well or
well system.
(14) Such other information as deemed necessary by the Director for the protection of human health
and the environment.
DEQ-CFW 00075368

(c) Injection Volumes. The Director may establish maximum injection volumes and pressures necessary to assure
that:
(1) fractures are not initiated in the confining zone(s);
(2) injected fluids do not migrate outside the injection zonj or area;
(3) injected fluids do not cause or contribute to the migration of contamination into uncontaminated
areas; and
(4) there is compliance with operating requirements.
(d) Injection.
(1) Injection may not commence until construction is complete, the permittee has submitted notice of
completion of construction to the Director, and the Director has inspected or otherwise reviewed
the injection well and finds it in compliance with the permit conditions. If the permittee has not
received notice from the Director of intent to inspect or otherwise review the injection well within
10 days after the Director receives the notice, the permittee may commence injection.
(2) Prior to granting approval for the operation, the Director shall consider the following information:
(A) all available logging and testing data on the well;
(B) a demonstration of mechanical integrity pursuant to Rule .0207 of this Section;
(C) the proposed operating procedures;
(D) the results of the formation testing program; and
(E) the status of corrective action on defective wells in the area of review.
(e) Well Construction.
(1) Wells shall not be located where:
(A) surface water or runoff will accumulate around the well due to depressions, drainage
ways, or other landscapes that will concentrate water around the well;
(B) a person would be required to enter confined spaces to perform sampling and inspection
activities; or
(C) injectants or formation fluids would migrate outside the approved injection zone as
determined by the applicant in accordance with Subparagraph (b)(4) of this Rule.
(2) The methods and materials used in construction shall not threaten the physical or mechanical
integrity of the well during its lifetime and shall be compatible with the proposed injection
activities.
(3) The well shall be constructed in such a manner that surface water or contaminants from the land
surface cannot migrate along the borehole annulus either during or after construction.
(4) The borehole shall not penetrate to a depth greater than the depth at which injection will occur
unless the purpose of the borehole is the investigation of the geophysical and geochemical
characteristics of an aquifer. Following completion of the investigation, the borehole beneath the
zone of injection shall be completely grouted to prevent the migration of any contaminants.
(5) Drilling fluids and additives shall contain only potable water and may be comprised of one or
more of the following:
(A) the formation material encountered during drilling;
(B) materials manufactured specifically for the purpose of borehole conditioning or well
construction; or
(C) materials approved by the Director, based on a demonstration of not adversely affecting
human health or groundwater quality.
(6) Only grouts listed under Rule .0107 of this Subchapter shall be used with the exception that
bentonite grout shall not be used:
(A) to seal zones of water with a chloride concentration of 1,500 milligrams per liter or
greater as determined by tests conducted at the time of construction; or
(B) in areas of the State subject to saltwater intrusion that may expose the grout to water with
a chloride concentration of 1,500 milligrams per liter or greater at any time during the life
of the well.
(7) The annular space between the borehole and casing shall be grouted:
(A) with a grout that is non -reactive with the casing or screen materials, the formation, or the
injectant
(B) from land surface to the top of the gravel pack and in such a way that there is no
interconnection of aquifers or zones having differences in water quality that would result
in degradation of any aquifer or zone; and
DEQ-CFW 00075369

(C) so that the grout extends outward from the casing wall to a minimum thickness equal to
either one-third of the diameter of the outside dimension of the casing or two inches,
whichever is greater; but in no case shall a well be required to have an annular grout seal
thickness greater than four inches.
(8) Grout shall be emplaced Around the casing by one of the following methods:
(A) Pressure. Grout shall be pumped or forced under pressure through the. bottom of the
casing until it fills the annular space around the casing and overflows at the surface;
(B) Pumping. Grout shall be pumped into place through a hose or pipe extended to the
bottom of the annular space which can be raised as the grout is applied. The grout hose
or pipe shall remain submerged in grout during the entire application; or
(C) Other. Grout may be emplaced in the annular space by gravity flow in such a way to
ensure complete filling of the space. Gravity flow shall not be used if water or any
visible obstruction is present in the annular space at the time of grouting.
(9) All grout mixtures shall be prepared prior to emplacement per the manufacturer's directions with
the exception that bentonite chips or pellets may be emplaced by gravity flow if water is present or
otherwise hydrated in place.
(10) If an outer casing is installed, it shall be grouted by either the pumping or pressure method.
(11) The well shall be grouted within seven days after the casing is set or before the drilling equipment
leaves the site, whichever occurs first.
(12) No additives that will accelerate the process of hydration shall be used in grout for thermoplastic
well casing.
(13) A casing shall be installed that extends from at least 12 inches above land surface to the top of the
injection zone.
(14) Wells with casing extending less than 12 inches above land surface may be approved by the
Director only when one of the following conditions is met:
(A) site specific conditions directly related to business activities, such as vehicle traffic,
would endanger the physical integrity of the well; or
(B) it is not operationally feasible for the well head to be completed 12 inches above land
surface due to the engineering design requirements_ of the system.
(15) Multi -screened wells shall not connect aquifers or zones having differences in water quality which
would result in a degradation of any aquifer or zone.
(16) Prior to removing the equipment from the site, the top of the casing shall be sealed with a water-
tight cap or well seal, as defined in G.S. 87-85, to preclude contaminants from entering the well.
(17) Packing materials for gravel and sand packed wells shall be:
(A) composed of quartz, granite, or other hard, non -reactive rock material;
(B) clean, of uniform size, water -washed and free from clay, silt, or other deleterious
material;
(C) disinfected prior to subsurface emplacement;
(D) emplaced such that it shall not connect aquifers or zones having differences in water
quality that would result in the deterioration of the water qualities in any aquifer or zone;
(E) evenly distributed around the screen and shall extend to a depth at least one foot above
the top of the screen. A minimum one -foot thick seal, comprised of bentonite clay or
other sealing material approved by the Director, shall be emplaced directly above and in
contact with the packing material.
(18) Each injection well shall have a well identification plate that meets the criteria specified in Rule
.0107 of this Subchapter.
(19) A hose bibb, sampling tap, or other collection equipment approved by the Director shall be
installed on the line entering the injection well such that a sample of the injectant can be obtained
immediately prior to its entering the injection well.
(20) If applicable, all piping, wiring, and vents shall enter the well through the top of the casing unless
otherwise approved by the Director based on a design demonstrated to preclude surficial
contaminants from entering the well.
(21) The well head shall be completed in such a manner so as to preclude surficial contaminants from
entering the well and well head protection shall include:
(A) an accessible external sanitary seal installed around the casing and grouting; and
DEQ-CFW 00075370

(B) a water -tight cap or seal compatible with the casing and installed so that it cannot be
removed without the use of hand or power tools.
(f) Testing.
(1) Appropriate logs and other tests conducted during the drilling and construction of the wells shall
be submitted to the Director after completion of well construction. A descriptive report
interpreting the results of such logs and tests shall be prepared by a log analyst and submitted to
the Director after completion of the tests. The appropriateness of the logs and tests shall be
determined by the Director based on the intended function, depth, construction, and other
characteristics of the well; availability of similar data in the area of the drilling site; and the need
for additional information that may arise from time to time as the construction of the well
progresses. At a minimum, such logs and tests shall include:
(A) lithostratigraphic logs of the entire borehole;
(B) hydrosrati graphic logs of the entire borehole; and
(C) deviation checks conducted on all holes where pilot holes and reaming are used, and at
sufficiently frequent intervals to assure that vertical avenues for fluid migration in the
form of diverging holes are not created during drilling.
(2) When the injection zone is a water -bearing formation, the following information concerning the
injection zone as determined by the applicant in accordance with Subparagraph (b)(4) of this Rule
shall be submitted to the Director after completion of the determinations in an integrated form
which includes the following:
(A) fluid pressure;
(B) fluid temperature;
(C) fracture pressure;
(D) other physical and chemical characteristics of the injection zone;
(E) physical and chemical characteristics of the formation fluids; and
(F) compatibility of injected fluids with formation fluids.
(3) When the injection formation is not a water bearing formation, only the fracture pressure and other
physical and chemical characteristics of the injection zone shall be determined or calculated and
submitted to the Director after completion of the determinations.
(4) Tests for mechanical integrity shall be conducted prior to operation and every 10 years thereafter
in accordance with Rule .0207 of this Section. The Director may require more frequent
mechanical integrity testing as set out in Rule .0207 of this Section.
(g) Operation and Maintenance.
(1) Pressure at the well head shall be limited to a maximum which will ensure that the pressure in the
injection zone does not initiate new fractures or propagate existing fractures in the injection zone,
initiate fractures in the confining zone, or cause the migration of injected or formation fluids
outside the injection zone or area.
(2) Injection between the outermost casing and the well borehole is prohibited.
(3) Monitoring of the operating processes at the well head shall be provided for by the well owner, as
well as protection against damage during construction and use.
(h) Monitoring.
(1) Monitoring
shall be required by the Director to demonstrate protection of the groundwaters of the
State.
(2) In determining the type, density, frequency, and scope of monitoring, the Director shall consider
the following:
(A)
physical and chemical characteristics of the injection zone;
(B)
physical and chemical characteristics of the injected fluid(s);
(C)
volume and rate of discharge of the injected fluid(s);
(D)
compatibility of the injected fluid(s) with the formation fluid(s);
(E)
the number, type and location of all wells, mines, surface bodies of water, and structures
within the area of review;
(F)
proposed injection procedures;
(G)
expected changes in pressure, formation fluid displacement, and direction of movement
of injected fluid;
DEQ-CFW 00075371

(H) proposals of corrective action to be taken in the event that a failure in any phase of
injection operations that renders the groundwaters unsuitable for their best intended usage
as defined in 15A NCAC 02L .0202; and
(I) the life expectancy of the injection operations.
(3) Samples and measurements taken for the purpose of monitoring shall be representative of the
monitored activity.
(4) The following analytical parameters shall be included:
(A) disinfectants and disinfection byproducts;
(B) radium, radionuclides, and gross alpha radiation;
(C) Reduction Potential (Eh), pH, Total Dissolved Solids (TDS), Biological Oxygen Demand
(BOD), Total Oxygen Demand (TOD), Chemical Oxygen Demand (COD), temperature,
conductivity, dissolved oxygen;
(D) coliform, Escherichia coli (E. Coli), Giardia, Cryptosporidium;
(E) parameters deemed appropriate by the Director based on the source water, injection zone
formation materials, native groundwater, or any other reason deemed necessary to protect
groundwater, human health, or the environment; and
(F) other parameters for which National Primary and Secondary Drinking Water Standards
have been established.
(5) Analysis of the physical, chemical, biological, or radiological characteristics of the injected fluid
shall be made monthly or more frequently, as necessary, in order to provide representative data for
characterization of the injectant.
(6) Continuous recording devices to monitor the injection pressure, flow, rate, and volume of injected
fluid shall be installed.
(7) Monitoring wells associated with the injection site shall be monitored quarterly or on a schedule
determined by the Director to detect any migration of injected fluids from the injection zone.
(8) Monitoring wells completed in the injection zone and any of those zones adjacent to the injection
zone may be affected by the injection operations. If affected, the Director may require additional
monitor wells located to detect any movement of injection fluids, process byproducts, or formation
fluids outside the injection zone as determined by the applicant in accordance with Subparagraph
(b)(4) of this Rule. If the operation is affected by subsidence or catastrophic collapse, the
monitoring wells shall be located so that they will not be physically affected and shall be of an
adequate number to detect movement of injected fluids, process byproducts, or formation fluids
outside the injection zone or area. In determining the number, location and spacing of monitoring
wells, the following criteria shall be considered by the Director:
(A) the population relying on the groundwater resource affected, or potentially affected, by
the injection operation;
(B) the proximity of the injection operation to points of withdrawal of groundwater;
(C) the local geology and hydrology;
(D) the operating pressures;
(E) the chemical characteristics and volume of the injected fluid, formation water, and
process by products; and
(F) the density of injection wells.
(i) Reporting.
(1) A record of the construction, abandonment, or repairs of the injection well shall be submitted to
the Director within 30 days of completion of the specified activities.
(2) All sampling results shall be reported to the Division quarterly, or on a frequency determined by
the Director, and based on the reaction rates, injection rates, likelihood of secondary impacts, and
site -specific hydrogeologic information.
(3) The results of tests required in Paragraph (f) of this Rule shall be submitted to the Director within
30 days of the completion of the test. Results may be submitted within an alternate timeframe
approved by the Director.
(j) Public Notice. Public notice of intent to issue permits for applications submitted pursuant to this rule shall be
given prior to permit issuance.
(1) Such notice shall:
(A) be posted on the Division website and given in press releases via media outlets having
coverage within the area of review;
DEQ-CFW 00075372

(B) provide 30 days for public comments to be submitted to the Director; and
(C) include a description of details of the project, such as the permit applicant; the location,
number, and depth of injection wells; and the injectant type, source, and volume.
(2) After the public comment period has ended the Director shall:
(A) consider the comments submitted and determine if a public hearing is warranted;
(B) determine if the draft permit shall be issued, modified, or denied; and
(C) post notice on the Division website as of the final permitting action, which shall include
the issued permit or the reason for denial if the permit was denied.
(3) In determining if a public hearing is warranted, the Director's consideration shall include the
following:
(A) requests by property owners within the area of review;
(B) potential harm to the public by not having a public hearing;
(C) potential harm to the applicant due to the delay in having a public hearing; and
(D) the likelihood of obtaining new information regarding the proposed injection.
History Note: Authority G.S. 87-87; 87-88; 87-90; 87-94; 87-95; 89E-13; 89E-18; 143-211; 143-214.2(b); 143-
215.IA; 143-215.3(a)(1); 143-215.3(c); 150B-19(4); 40 CFR Part 144.52(a)(7); 40 CFR Part
145.11(a)(20);
Eff. May 1, 2012.
DEQ-CFW 00075373

W8000PD
M
MW800CH
RECEIVED / DENR
/ DWQ
Aquifer Protection
Section
DEC 2 0 2010
MW3000PD
MW300CH
ASR #2
W ER TO ER
MW2UPD
�FSTeRo ASR #1
Ok gVFN�� MW4SA- COREHOL
MW7 LPD N
LEGEND
ASR WELL SCALE IN FEET
&ft AL M
wmA
PROPERTY LINE MONITORING WELL 0 60' 120,
DOT RIGHT-OF-WAY
t"=t 20'
GROUNDWATER MANAGEMENT A55OCIATES, INC.
File: DRAWINGS/70201
LOCATION OF ASR AND MONITORING WELLS
Date: 12/15/2010
WELLS
Project No. 70201
CAPE FEAR PUBLIC UTILITY AUTHORITY, NEW HANOVER CO., NC
Figure
DEQ-CFW 00075374

9
11
i
I
z
I
I �
3
I
� N ASR Q2
I I
A er2e
O
i
I
i I TANK DRAIN/OVERFLOW
I STRUCTURE
EXIST. JUNCTION BOX
WATER TOWER
I
a
I I
o I
I
COMCfiETE:
I w I
I , M'
1"
100 FT. RADIUS
(TYP.)
f .•
ASR #1
LEGEND
EXISTING WATER -SUPPLY
-�- WELL IN THE UPPER
SCALE IN FEET
— - - — PROPERTY LINE PEEDEE AQUIFER
o zs'
So'
- - OFFSET CORE HOLE (CH-1)
o CHAIN -LINK FENCE ABANDONED
1"=s0'
_
i SHRUBS/TREES t LOWER PEEDEE AQUIFER MONITORING WELL
Croundnahr Nanogommd Aummoa, Inc.
File: GJR\GMA\70201
WESTBROOK SITE
WESTBROOK SITE
PLAN
Date: 6 7 2007
Project No. 70201
CITY OF WILMINGTON, NEW HANOVER CO., NC
Figure 3
DEQ-CFW 00075375

WaterResources
ENVIRONMENTAL QUALITY
February 12, 2016
Jim Flechtner, Executive Director
Cape Fear Public Utility Authority
235 Government Center Drive
Wilmington, NC 28403
Re: Issuance of Injection Permit WI0800149
Cape Fear Public Utility Authority Westbrook Avenue ASR Well
New Hanover County, NC
Dear Mr. Flechtner:
PAT MCCRORY
Govemor
DONALD R. VAN DER VAART
Secretary
S. JAY ZIMMERMAN
Direclor
In accordance with the permit renewal with modification request application received on October 28, 2015, and
additional information received February 3, 2016, we are forwarding permit number WI.0800149. This permit
is to inject treated drinking water for aquifer storage and recovery (ASR) cycle testing at the Westbrook Avenue
ASR well, located at 132 Westbrook Avenue, Wilmington, New Hanover County, NC 28403. Furthermore,
the permit has been modified to allow the well to be reconfigured from open -hole construction to a well
having a screen with packing material consisting of Silibeads©.
This permit shall be effective from date of issuance until January 31, 2021, and shall be subject to the
conditions and limitations stated therein, including the requirement to submit a Final Project Evaluation (FPE)
as stated in PART VI MONITORING AND REPORTING REQUIREMENTS. Please read the entire permit
to ensure that you are aware of all compliance requirements of the permit.
Please note the following:
© Per permit condition Part 11.8, within 30 days of completion, please send copies of a Well
Construction Record (Form GW-1) showing the modified well construction to the
Wilmington Regional Office and to my attention at the Central Office. Addresses are
indicated in the attached permit.
® Per permit condition Part III.1, at least forty-eight (48) hours prior to constructing or
operating each injection well, the Permittee shall notify the Underground Injection Control
(UIC) Central Office staff, telephone number 919-807-6412, and the Wilmington Regional
Office staff, telephone number 910-796-7215.
In order to continue uninterrupted legal use of this well for the stated purpose, you should submit an application
to renew the permit 120 days prior to, its expiration date. As indicated in the permit, this permit is not
transferable to any person without prior notice to, and approval by, the Director of the Division of Water
Resources. If you have any questions regarding your permit or the Underground Injection Control Program
please call me at [phone].
State or North Carolina I Emviromnental Quality I Water Resources
1611 Mail senice Center I Raleigh, North Carolina 27699-1611
919 707 9000
DEQ-CFW 00075376

Cape Fear Public Utility Authority Page 2 of 2
Best Regards,
Michael Rogers, P.G. (NC & FL)
UIC Program Manager, Hydrogeologist
Division of Water Resources
Water Quality Regional Operations Section
cc: Jim Gregson and Morella Sanchez -King, WQROS — Wilmington Regional Office
Central Office File, W10800149
R. David Pyne, ASR Systems, 540 NE 5` Ave.,. Gainesville, FL 32601
DEQ-CFW 00075377

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH, NORTH CAROLINA
PERMIT FOR THE CONSTRUCTION AND CYCLE TESTING OF A WELL FOR INJECTION
In accordance with the provisions of Article 7, Chapter 87; Article 21, Chapter 143; and other
applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Cape Fear Public Utility Authority
FOR THE OPERATION OF ONE (1) AQUIFER STORAGE AND RECOVERY INJECTION WELL,
defined in Title 15A North Carolina Administrative Code 2C .0209(5)(b)(ii), to inject treated drinking water
for aquifer storage and recovery cycle testing. This injection well is located at 132 Westbrook Avenue,
Wilmington, New Hanover County, North Carolina 28403, and will be operated in accordance with the permit
renewal and modification request received on October 28, 2015, and in conformity with the specifications and
supporting data previously submitted. February 3, 2016, all of which are filed with the Department of
Envirorunental Quality and are considered a part of this permit.
This pen -nit is for Operation only and does not waive any provisions of the Water Use Act or any other
applicable Laws, Rules, or Regulations. Operation and use of an injection well shall be in compliance with
Title 15A North Carolina Administrative Code 02C .0100 and .0200, and any other Laws, Rules, and
Regulations pertaining to well construction and use.
This permit shall be effective, unless revoked, from the date of its issuance until January 31, 2021, and shall
be subject to the specified conditions and limitations set forth in this permit.
Permit issued this the ( � day of February, 2016.
S. Jay Zimmerman, Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Pemit No. \N'10800149
PAGE I of
DEQ-CFW 00075378

PART I - WELL CONSTRUCTION GENERAL CONDITIONS
1. The Permittee must comply with all conditions of this permit and with the standards and criteria specified
in Criteria and Standards Applicable to Injection Wells (15A NCAC 02C .0200). Any noncompliance
with conditions of this permit constitutes a violation of the North Carolina Well Construction Act and is
grounds for enforcement action as provided for in N.C.G.S. 87-94.
2. This permit shall become voidable unless the facility is constructed in accordance with the conditions of
this permit, the approved plans and specifications, and other supporting data.
3. Each'injection well shall not connect aquifers or zones that have differences in water quality that would
result in a degradation of any aquifer or zone or that have significant differences in head.
4. Each injection well shall be constructed in such a manner that water from land surface cannot migrate
into the gravel pack or well screen.
5. Each injection well shall be secured to reasonably insure against unauthorized access and use. Each well
shall be permanently labeled with a warning that it is for injection purposes and the entrance to each well
must be secured with a locking cap.
6. Each injection well shall be afforded reasonable protection against damage during construction and use.
7. Each injection well shall have permanently affixed an identification plate.
PART II - OPERATION AND USE GENERAL CONDITIONS
This permit is effective only with respect to the nature, volume of materials, and rate of injection as
described in the application and other supporting data.
2. This permit is not transferable without prior notice to, and approval by, the Director of the Division of
Water Resources (Director). In the event there is a desire for the facility to change ownership, or there is
a name change of the Permittee, a formal permit amendment request must be submitted to the Director,
including any supporting materials as may be appropriate, at least 30 days prior to the date of the. change.
3. The issuance of this permit shall not relieve the Permittee of the responsibility of complying with any and
all statutes, rules, regulations, or ordinances which may. be imposed by other local, state, and federal
agencies which have jurisdiction. Furthermore, the issuance of this permit does not imply that all
regulatory requirements have been met.
PART III - PERFORMANCE STANDARDS
1. The injection facility shall be effectively maintained and operated at all times so that there is no
contamination of groundwater which will render it unsatisfactory for normal use. In the event that the
facility fails to perform satisfactorily, including the creation of nuisance conditions or failure of the
injection zone to adequately assimilate the injected fluid, the Permittee shall take immediate corrective
actions including those actions that may be required by the Division of Water Resources such as the
repair, modification, or abandonment of the injection facility.
I'ermitNo. W10800149
PAGE 2 of 7
DEQ-CFW 00075379

2. The Permittee shall be required to comply with the terms and conditions of this permit even if
compliance requires a reduction or elimination of the permitted activity.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to surface or
groundwater resulting from the operation of this facility.
PART IV — WELL CONSTRUCTION SPECIAL CONDITIONS
1. At least forty-eight (48) hours prior to constructing or operating each injection well, the Permittee shall
notify the Underground Injection Control (UIC) Central Office staff, telephone number 919-807-6412, and
the Wilmington Regional Office staff, telephone number 910-796-7215.
2. Per the permit renewal and modification request received on October 28, 2015, additional information
received February 3, 2016, and after a variance request was approved by the Wilmington Regional Office
on November 13, 2015, the ASR well will be modified from open -hole to a well having casing and a screen
with packing material consisting of Silibeads®.
PART V - OPERATION AND MAINTENANCE REQUIREMENTS
1. The injection facility shall be properly maintained and operated at all times.
2. The Permittee must notify the Division and receive prior written approval from the Director of any
planned physical alterations or additions in the permitted facility or activity not specifically authorized by
the permit.
3. With the exception of disinfectants and disinfection by-products, the injected water shall at all times
comply with groundwater quality standards in 15A NCAC 02L .0202 at the point of injection.
Concentrations of disinfectants and disinfection by-products in the injected water at the point of injection
shall at all times be less than the maximum contaminant levels required by the NC Department of Health
and Human Services.
4. Prior to operation of the injection well, a mechanical integrity test shall be conducted in accordance with
15A NCAC 2C .0207(b). The results of the mechanical integrity test shall be reported in accordance
with 15A NCAC 2C .0207(c) to the Water Quality Regional Operations Section UIC Program and to the
Water Quality Regional Operations Section Wilmington Regional Office.
5. During operation of the injection well, injection pressures as measured at the wellhead shall not exceed
60 pounds per square inch.
6. At least forty-eight (48) hours prior to the initiation of the operation of the facility for injection, the
Permittee must notify by telephone the Water Quality Regional Operations Section UIC Program staff,
telephone number (91.9) 807-6412 and Wilmington Regional Office staff, telephone number (910) 796-
7215. Notification is required so that Division staff can inspect or otherwise review the injection facility
and determine if it is in compliance with permit conditions.
Permit No. W10800149
PAGE 3 cif 7
DEQ-CFW 00075380

PART VI - INSPECTIONS
1. Any duly authorized officer, employee, or representative of the Division of Water Resources may, upon
presentation of credentials, enter and inspect any property, premises, or place on or related to the
injection facility at any reasonable time for the purpose of determining compliance with this permit, may
inspect or copy any records that must be maintained under the terms and conditions of this permit, and
may obtain samples of groundwater, surface water, or injection fluids.
2. Department representatives shall have reasonable access for purposes of inspection, observation, and
sampling associated with injection and any related facilities as provided for in N.C.G.S. 87-90.
3. Provisions shall be made for collecting any necessary and appropriate samples associated with the
injection facility activities.
PART VII - MONITORING AND REPORTING REQUIREMENTS
1. The monitoring plan in PART X — MONITORING PLAN of this permit shall be followed. Within 60
days after each cycle of testing all sample results shall be submitted as described in Part IX.3 of this
permit:
2. The Permittee shall produce a final project evaluation (FPE) within 9 months after completing injection
cycle testing activities. This document shall assess the injection project's findings in a written summary.
This summary shall include: (1) an assessment of the impact of the injection activities on water quality of
the injected water and"native groundwater, (2) an assessment of the physical impacts (hydraulic and
otherwise) of the injection system on the injection zone and native groundwater, and (3) any other
pertinent findings. The FPE shall also contain monitoring well sampling data and pertinent head data.
The final project evaluation shall be submitted to the addresses given in Part IX.3.
3. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge of the
occurrence, to the Wilmington Regional Office, telephone number [phone], any of the following:
(A) Any occurrence at the injection facility which results in any unusual operating circumstances,
with the exception of routine maintenance;
(B) Any failure due to known or unknown reasons, that renders the facility incapable of proper
injection operations, such as mechanical or electrical failures.
4. Where the Permittee becomes aware of an omission of any relevant facts in a permit application, or of
any incorrect information submitted in said application or in any report to the Director, the relevant and
correct facts or information shall be promptly submitted to the Director by the Permittee.
5. In the event that the permitted facility fails to perform satisfactorily, the Permittee shall take such
immediate action as may required by the Director.
PART VHI - PERMIT RENEWAL
The Permittee shall, at least 120 days prior to the expiration of this permit, request an extension.
Permit No. W10900149
PAGE 4 of 7
DEQ-CFW 00075381

PART IX - CHANGE OF WELL STATUS
1. The Permittee shall provide written notification within 30 days of any change of status of an injection
well. Such a change would include the discontinued use of a well for injection. If a well is taken
completely out of service temporarily, the Permittee must install a sanitary seal. If a well is not to be
used for any purpose that well should be permanently abandoned.
2. When operations have ceased at the facility and a well will no longer be used for any purpose, the
Permittee shall abandon that injection well in accordance with the procedures specified in 15A NCAC
.0240, including but not limited to the following:
(A) All casing and materials may be removed prior to initiation of abandonment procedures if the
Director finds such removal will not be responsible for, or contribute to, the contamination of an
underground source of drinking water.
(B) The entire depth of each well shall be sounded before it is sealed to insure freedom from
obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected, prior to sealing, if the Director determines that failure to
do so could lead to the contamination of an underground source of drinking water.
(D) Drilled wells shall be completely filled with cement grout, which shall be introduced into the well
through a pipe which extends to the bottom of the well and is raised as the well is filled.
(E) In the case of gravel -packed wells in which the casing and screens have not been removed, neat -
cement shall be injected into the well completely filling it from the bottom of the casing to the
top.
(F) In those cases when, as a result of the injection operations, a subsurface cavity has been created,
each well shall be'abandoned in such a manner that will prevent the movement of fluids into or
between underground sources of drinking water- and in accordance with the terms and conditions
of the permit.
(G)The Permittee shall submit a Well Abandonment Record (Form GW-30) as specified in 15A
NCAC 2C .0219(i)(1) within 30 days of completion of abandomnent.
3. The written documentation required to be submitted referenced above shall be submitted to:
Division of Water Resources Division of Water Resources
WQROS and WQROS - Wilmington Regional Off -ice
1636 Mail Service Center 127 Cardinal Drive Extension
Raleigh, NC 27699-1636 Wilmington, NC 28405
Permit No. W10800149 PAGE' 5 of 7
DEQ-CFW 00075382

PART X — MONITORING PLAN
1. The following sampling and analysis plan shall be followed:
Frequency of Anal sis or Data Collection
Parameters or
Constituents
Wells
ASR-1
MW-3
MW4
MW-5
300'
MW-6
300'
MW-7
800'
MW-8
800,
Units
UPDA
CHA
SA
UPDA
CHA
UPDA
CHA
Water Level/Pressure
ft/psi
C
A
A
A
A
A
A
Flow Rate
gpm
C
-
-
-
-
-
-
Cumulative Volume
MG
C
-
-
-
-
-
-
Field
Measurements
Temperature
OF
A
E
-
E
E
E
E
Dissolved Oxygen
mg/I
A
E
-
E
E
E
E
Redox Potential
my
A
E
-
E
E
E
E
H
A
E
-
E
E
E
E
S. Conductivity
umhos/cm
A
E
-
W
E
E
E
Laborato Measurements
Alkalinity, Total
mg/I
D,E
E
-
M
E
E
E
Arsenic
ug/I
D,E
E
-
M
E
E
E
Ammonia
mg/I
D,E
E
-
M
E
E
E
Bicarbonate
mg/I
D,E
E
-
M
E
E
E
Calcium
mg/I
D,E
E
-
M
E
E
E
Chloride
mg/I
I D,E
W
-
M
E
W
E
Chlorine
mg/I
D,E
E
-
M
E
E
E
Fluoride
mg/I
D,E
E
-
M
E
E
E
Haloacetic Acids
Ng/l
D,E
E
-
M
E
E
E
Hardness, Total
mg/I
D-E
E
-
M
E
E
E
Iron, Total
mg/I
D,E
E
-
M
E
E
E
Iron, Dissolved
mg/l
D,E
E
-
M
E
E
E
Magnesium
mg/I
D,E
E
-
M
E
E
E
Manganese, Total
mg/I
D,E
E
-
M
E
E
E
Manganese, Dissolved
mg/I
D,E
E
-
M
E
E
E
Phosphate
mg/I
D,E
E
-
M
E
E
E
Potassium
mg/i
I D,E
E
-
M
E
E
E
Silica
mg/I
D,E
E
-
M
E
E
E
Sodium
mg/l
D,E
E
-
M
E
E
E
Sulfate
mg/I
D,E
E
-
M
E
E
E
Sulfide
mg/I
D,E
E
-
M
E
E
E
Total Dissolved Solids
mg/I
D,E
E
-
M
E
E
E
Total Organic Carbon
mg/I
D,E
E
-
M
E
E
E
Total Trihalomethanes
}ig/l
D,E
L':
-
M
E
E
E
bromodichloromethane
Ng/I
D,E
E
-
M
E
E
E
bromoform
pg/I
D,E
I E
-
M
E
E
E
chlorodibromomethane
pg/I
D,E
E
-
M
E
E
E
chloroform
pg/I
D,E
E
-
M
E
E
E
bromate
Ng/l
D,E
E
-
M
E
E
E
Turbidity
NTU
D,E
E
-
M
E
E
E
Color
PCU
D,E
E
-
M
E
E
E
Total suspended solids
mg/I
D,E I
E
-
M
E
E
E
Carbonate alkalinity
mg/l
D,E
E
-
M
E
E
E
Non -carbonate hardness
mg/1
D,E
E
-
M
E
E
E
Orthophosphate
mg/l
D,E
E I
- I
M
E
E
E
Hydrogen sulfide
mg/1
D,E
E I
- I
M
E
E
E
Notes: A beginning, middle and end of recharge; beginning, middle and end of recovery, and at least
weekly
C continuous
Permit No. M0800149
PAGE 6 of 7
DEQ-CFW 00075383

D recharge water sample every two weeks during recharge periods; beginning, middle, and
end of recovery for ASR-1
M monthly, increasing to weekly if chloride or conductivity concentrations increase by 20%
from background levels
W weekly
E background sampling before Cycle 1 injection, and sampling at the end of Cycle 3
CHA Castle Hayne Aquifer
SA Surficial Aquifer
UPDA Upper Peedee Aquifer
MW-5 300' monitor well located 300 ft from ASR-1
2. Background samples shall be collected prior to injection from the recharge water at the site and from
wells ASR-1, MW-3, MW-5, MW-6, MW-7, and MW-8. Analytical parameters shall consist of those
constituents listed in the table in Part X.I and those parameters specified in the NC Department of Health
and Human Services lists for New Well Inorganics Chemical Analysis, Pesticides and Synthetic Organic
Chemicals Analysis, Volatile Organic Chemicals Analysis, Radiological Analysis, and Bacteriological
Analysis.
3. In the event that more test cycles are deemed necessary on the basis of field conditions beyond the three
(3) scheduled preliminary cycle test results, a sampling and analysis plan similar to that specified above
shall be used for each subsequent cycle.
4. In addition to the sampling and analysis plan above:
A. During recharge and recovery phases of all cycles, flow rate and total flow volume at the injection
wellhead shall be monitored and recorded at regular intervals as determined by the project
engineer.
B. During recharge phases, injection pressure at the injection wellhead shall be monitored and
recorded at regular intervals as detenined by the project engineer.
C. During all phases of the cycle test, water level or total head shall be monitored and recorded at
regular' intervals as determined by the project engineer at ASR wells and all observation wells.
5. Groundwater samples may be prepared and analyzed by drinking water analytical methods in accordance
with the approval letter of the Director of the Division of Water Resources (Former Division of Water
Quality) dated December 7, 2010.
PermitNn. \ 108001a9
PAGE 7 of 7
DEQ-CFW 00075384

CAPE FEAR PUBLIC UTILITY AUTHORITY (CFPUA) AQUIFER STORAGE AND RECOVERY (ASR)
August 7, 2017
Background:
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
CFPUA Aquifer Storage and Recovery Site
• Faced with increasing peak demands for water, CF
manage periodic fluctuations of water supply and
water for storage when there is excess.supply and
insufficient supply.
• To determine whether the system at phis site was;
constructed one ii
and has conduce
• The permit dicta
water and what tc
• Cycle test 3 was p
ry we.l.l_(ASR-1,
ycI` t sts_of injection _sI
how oftel�=sampling m.0
ample for (see attached
posed for -the period Ma
site
I for a permit"fo- an ASR to
alternately injecting drinking
!ring water when there is
ble fora full-scale ASR operation, CFPUA
fly act[ in the Upper Peedee Aquifer
after_a­bf_,&tharge and recovery of injected
rmit, Part X).
1_29, 2017 through May 10, 2017. CFPUA
to include the ASR-1 and three of the
-1- and monitoring wells).
• ASR permit number for"the_CFPUA is10800149. It was originally issued 2008, renewed in
2011, 2023band modified rn 016. TM current permit will need to be renewed by 2021.
• Issues thati must be addreO,"". in an ASR permit application include:
o A complete wateri_quality analysis of the water to be injected (all National Primary and
Secondary Drin:kmg-: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.
f 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.
DEQ-CFW 00075385

GENX Discovery
During the ASR cycle tests, CFPUA injected 48.8 million gallons into the ASR. They stopped
injecting in June 2017.
o Cycle Test Injection #1 ended March 4, 2014 — total 13.75 MG stored
o Cycle Test Injection #2 ended June 13, 2014—total 28.538 MG stored
o 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
o Cycle Test injection #3 ended June 5, 2017 — 24.4 MG added; a to of 48.811 MG-"',,
ASR #1well testing was done concurrently with raw and finished water t n
compound. Below are the sampling results:
Week
Date
GenX Sampling Results
(ppt)
_ Lab Used
#1
6/22/2017
820 =
Te nerica, Colorado
#1
6/22/2017
588 = —
EPA lab, Rest-h Triangle (ORD)
#2
6/29/2017
400
Test Americarado
#2
6/29/2017
=__ 336
EPIANI TnngIORD)
#3
7/06/2017
==9_(=
Nest America, Colorado
#3
7/06/2017
MA8^ =_—
EPA ISSIR Triangle (ORD)
#4
7/13/201
10= =
Nest AMrerica, Colorado
#4
7/132p17
=- 84 =
EPA lam, -'Research Triangle (ORD)
#5 _7/20/20:7=_
— - _120 _
Test America, Colorado
`-
EPA lab, Research Triangle (ORD)
H FORWARD --
• The original intent of CFPUA-was to p=urnp out twice the volume that was injected, but
exceed 200 MG of recovered water. Since June 2017, CFPUA has pumped out a tot of 212,70
gallons. The following table shows the dates and volumes of recovered water since
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
• CFPUA has proposed to pump from the ASR at approximately 500 GPM. Pumping rates are not
expected to affect water levels in adjacent water supply wells or exceed capacity of downstream
2
DEQ-CFW 00075386

pump stations in the wastewater collection system. This water will be sent to the Northside
WWTP, starting approximately September 1, 2017.
• Other wells being tested include:
o An adjacent private well (Mr. Paige well) , located ^750 feet from the ASR. GenX testing
results were non -detect, and
o the Wrightsville Beach public water supply well #11, located approximately 3,000 feet
from the ASR. GenX test concentrations ranged from 24 to 44 ppt.
• Two more wells will be placed in the PeeDee aquifer between the ASR and Wrightsville Beach to
monitor GenX concentrations.
• CFPUA plans on constructing a temporary forcemain from the ASR well to tie in to the sewer
force main along Military Cutoff Road (approximately 3,000 feet).
o CFPUA will physically disconnect the ASR well from the water supply distribution
system.
o CFPUA will install a Reduced Pressure
forcemain to the sewer forcemain any
force main.
o They will continue to test for GenX as
recovered water to be pumped.
,ne-(R,PZ) at the,well end of the temporary
check valve prior to connection to the sewer
ey pump and better determine total volume of
• Currently CFPUA is seeking guidance from the Division on "acceptable concentrations within the
ASR system. _
o It will be difficult to pump water Iurnti.l non -detest levels of GenX are found without
impacting water supply welts in thearea�
o CFPUA recent1wrequested the Division to prioritize and establish groundwater IMACS
for all perfluorinatedcompounds discharged under,NPDES NC0003573.
Items to Consider
• With the exception 1sinfs and disinfecti-on by-products, the permit requires that the
injected water shall at altimes complyw0, groundwater quality standards in 15A NCAC 02L
• The__permit requires regular monitoring for typical parameters of concern for a public water
supply (see attached pern_it requirements), but does not include GenX.
• 15A NCACO21_ .0202 does not specify" -ornumeric value for a GenX groundwater standard;
therefore,4he-Class GA or Class GSA groundwater standard for GenX is the practical quantitation
limit [15A NCA, 02L.0202(b)(2)].
• 15A NCAC 2L 0i-0- (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
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).
3
DEQ-CFW 00075387

rYN-
_ 3� �p►-� sa
1r�
g- $ UP
`c' 4 1 - - tuolcsf-ol-
DEQ-CFW 00075388

Watts, Debra
From:
Gregson, Jim
Sent:
Tuesday, August 01, 2017 4:22 PM
To:
Watts, Debra
Cc:
King, Morella s; Kegley, Geoff; Risgaard, Jon; Wilson, Nat; Rogers, Michael
Subject:
RE: ASR Update
Debra,
The 200MG was an early estimate. They propose to pump at least 48MG which was the volume injected. They have
explored treatment options but nothing looks promising. RO looks like the only effective treatment but then they would
have reject water to get rid of. I don't know how they could treat it and return it because it would be coming out of and
going in the same well. There is also no way they can store that volume of water above ground to treat it and re -inject
it. The total volume removed will be based on monitoring well data for GenX while they are pumping and/or any
guidance we give them on acceptable levels.
Jim Gregson
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources
Department of Environmental Quality
910.796.7215 Reception Desk
910.796.7386 Direct
910.350.2004 Fax
Jim. gregson(iOcdenr. gov
Wilmington Regional Office
127 Cardinal Drive Ext
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Pudic Records Law and may ,be disclosed to third parties.
From: Watts, Debra
Sent: Tuesday, August 01, 2017 3:38 PM
To: Gregson, Jim <jim.gregson@ncdenr,gov>
Cc: King, Morella s <[e-mail]>; Kegley, Geoff <[e-mail]>; Risgaard, Jon
<[e-mail]>; Watts, Debra <[e-mail]>; Wilson, Nat <[e-mail]>; Rogers,
Michael <[e-mail]>
Subject: RE: ASR Update
Nat
See the email below.
Jim
A couple of things.
• First, thanks for keeping us up-to-date.
DEQ-CFW 00075389

Second, I'm going to try and talk to Linda Culpepper this afternoon and see what are our options are as far as
compliance level for the ASR. If we meet to discuss with staff like Standards and Classifications (Jeff Manning's
group), I'll invite you and your staff as well.
Third, in talking with some of the Hydros here, I'm wondering if the Catlin group has been too quick in making this
decision of withdrawing 200MG of water from the ASR, Even though they have pumped this water into the ASR, I
think we need to keep Nat Wilson's group informed in that this may have implications as far as capacity use i.e.
how this would affect the aquifer area wide.
And finally, has the Catlin group looked at other options, like dilution with water from another source? Running
the currently stored water through some kind of filter and returning to storage? Etc.
We will still look to see what kind of guidelines we can provide, but thought I'd share the above for your consideration.
Debra Watts
Supervisor, Animal Feeding Operations and Groundwater Protection Branch
Division of Water Resources
North Carolina Department of Environmental Quality
919 807 6338 office
debra.watts (a-ncdenr.gov
512 N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699-1636
-'"'Nothing Compares --
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Gregson, Jim
Sent: Tuesday, August 01, 2017 2:27 PM
To: Watts, Debra <[e-mail]>
Cc: King, Morella s <[e-mail]>; Kegley, Geoff <[e-mail]>; Risgaard, Jon
<[e-mail]>
Subject: ASR Update
Debra,
Geoff and I met with CFPUA and Rick Catlin at the ASR site this morning to discuss the plans for pumping the 48MG of
treated water out of the well. The Authority still plans on constructing a temporary line from the well approximately
3,000 feet to tie in to the sewer force main along Military Cutoff Road. From there it would flow to the Bradly Creek
Pump Station and ultimately to the Northside WWTP. They will physically disconnect the well from the distribution
system and install an RPZ at the well end of the temporary line and a check valve at the force main tap. Original estimates
were to pump around 2X the injected volume or around 200 MG. They will test for GenX as they pump and determine
total volume to be pumped based on test results. They are seeking guidance from the Division on acceptable
concentrations knowing that it will be very difficult to pump to the non -detect level without impacting wells in the
area. Gary McSmith indicated they were working on a request to Jay for the adoption of an IMAC for at least the known
fluorinated compound. The last test results I have seen for the ASR site are below the health advisory level of 140 parts
per trillion.
Jim Gregson
DEQ-CFW 00075390

q* 'r, .
CAPE FEAR PUBLIC UTILITY AUTHORITY (CFPUA) AQUIFER STORAGE AND RECOVERY (ASR)
August 7, 2017
Background:
The Underground Injection Control program is a Federal Program under the Safe brinking 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 s 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.
CFPUA Aquifer Storage and Recovery Site
f,•
• Faced with increasing peak demands for water, CFPUA applied for a permit for an ASR to
manage periodic fluctuations of water supply and demand by alternately injecting drinking
water for storage when there is excess supply and later recovering water when there is
insufficient supply.
• To determine whether the system at this site was capable for a full-scale ASR operation, CFPUA
constructed one injection/recovery,:vveli (ASR-1, currently active) in the Upper Peedee Aquifer
and has conducted cycle tests of *rejection, storage, and recovery.
• The permit dictates how often sampling must occur after a recharge and recovery of injected
water and what to sample fcoisee attached permit, Part X).
• Cycle test 3 was proposedffor the period March 29, 2017 through May 10, 2017. CFPUA
proposed six weeks of tg0ting during this period to include the ASR-1 and three of the
monitoring wells (see attached site map of ASR-1 and monitoring wells).
CFPUA Permit
• ASR permit number for the CFPUA is W10800149. It was originally issued 2008, renewed in
2011, 2013 a)id 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.
DEQ-CFW 00075391

GENX Discovery
During the ASR cycle tests, CFPUA injected 48.8 million gallons into the ASR. They stopped
injecting in June 2017.
o Cycle Test Injection #1 ended March 4, 2014 — total 13.75 MG stored
o Cycle Test Injection #2 ended June 13, 2014 — total 28.538 MG stored
o 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
o 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:
Week
Date
GenX Sampling Results (p�
Lab Used
#1
6/22/2017
820
Test America, Colorado
#1
6/22/2017
588 `"
SPA lab, Research Triangle
l..
(ORD)
#2
6/29/2017
400
Te4f""\\ rica, Colorado
#2
6/29/2017
AN 336
EPA lab, (2arch Triangle
i4�k� a
(ORD)
#3
7/06/2017
"Qa
Test America, Colorado
#3
7/06/20148
EPA lab, Research Triangle
`�� ^ .` �:
(ORD)
�s
a.
�:��
#4
7/13/20�,
01
u;, ;.max 12
Test America Colorado
,
Am
#4
EPA lab, Research Triangle
�. �. ����.F`
(ORD)
#5
7/20/2017`�
�.,. 120
Test America, Colorado
#5
7%20/2017
EPA lab, Research Triangle
(ORD)
PATH FORWARD
• The original intent of C,FPUA was to pump out twice the volume that was injected up to 200
million gallons. So far they have pumped out a total of 232,700 gallons during the six weeks of
GenX sampling of the ASR Well:
0 6 /20/17 7,500 gallons
0 6/29/17 15,800 gallons
0 7/6/17 43,200 gallons
0 7/13/17
58400 gallons
0 7/17/17
59,400 gallons
0 7/20/17
48,400 gallons
DEQ-CFW 00075392

4. , . 0
• Water is being proposed to be pumped from the ASR at approximately 500 GPM which is not
expected to affect wells in the neighborhood or overwhelm downstream pump stations. This
water will be sent to the Northside WWTP, starting approximately September 1, 2017.
• Other wells being tested are a private well nearby (750 feet from the ASR, Mr. Paige) where
testing results were non -detect. Also, the Wrightsville Beach public water supply well #11,
located approximately 3000 feet from the ASR, has been tested. GenX test concentrations
ranged from 24 to 44 ppt.
• Two more wells will be placed in the PeeDee aquifer between the ASR and Wrightsville Beach to
monitor GenX concentrations.
• CFPUA still plans on constructing a temporary line from the ASR well to tie in to the sewer force
main along Military Cutoff Road (approximately 3,000 feet).
o CFPUA will physically disconnect the ASR well from the distribution system and install a
Reduced Pressure Zone (RPZ) at the well end of the temporary line and a check valve at
the sewer force main.
o They will continue to test for GenX as they pump and better determine total volume of
recovered water to be pumped.
• Currently CFPUA is seeking guidance from the Division on acceptable concentrations.
o It will be difficult to pump water until non -detect levels of GenX are found without
impacting water supply wells in the area.
o CFPUA recently requested the Division to prioritize and establish groundwater IMACS
for all perfluorinated compounds discharged under NPDES NC0003573.
Items to Consider
• 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
.0202.
• 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 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
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).
DEQ-CFW 00075393

VV05
woto5
pivf5
ogles
&', T
V3 C
Expansion Request - DWR
Classification
Annual Salary
Social Security
Retirement
Health
Total
Engineer
$65,273
$
4,993
$
11,181
$ 5,869
$
87,317
Engineer
$65,273
$
4,993
$
11,181
$ 5,869
$
87,317
Engineer
$65,273
$
4,993
$
11,181
$ 5,869
$
87,317
Engineer
$65,273
$
4,993
$
11,181
$ 5,869
$
87,317
Environmental Specialist
$52,502
$
4,016
$
8,994
$ 5,869
$
71,381
Environmental Specialist
$52,502
$
4,016
$
8,994
$ 5,869
$
71,381
Environmental Specialist
$52,502
$
4,016
$
8,994
$ 5,869
$
71,381
Hydrogeologist
$47,892
$
3,664
$
8,204
$ 5,869
$
65,629
Hydrogeologist
$47,892
$
3,664
$
8,204
$ 5,869
$
65,629
Program Consultant' `
$67,555
$
5,168
$
11,572
$ 5,869
$
90,164
Program Consultant `
$67,555
$
5,168
$
11,572
$ 5,869
$
90,164-
Business Technology Analyst
$96,864
$
7,410
$
16,593
$ 5,869
$
126,736
Environmental Senior Specialist
$58,346
$
4,463
$
9,995
$ 5,869
$
78,673
Environmental Senior Specialist
$58,346
$
4,463
$
9,995
$ 5,869
$
78,673
Chemist III
$66,555
$
5,091
$
11,401
$ 5,869
$
88,916
Chemist III
$66,555
$
5,091
$
11,401
$ 5,869
$
88,916
Total (16.0 FTE)
$996,158
$76,206
$170,642
$93,904
$1,336,910
Operating Requirements
Transportation -Ground- In State
$
20,078
General Office Supplies
$
7,200
PC/Printer Equipment
$
29,900
Phone
$
9,375
Meals
$
6,606
Hotel
$
9,500
Contractual
$
730,000
Total
$
812,659
Total Salary and Operating
$2,149,569
Position description
NPDES Permitting and backlog
NPDES Permitting and backlog
Nondischarge Permitting
Dedicated to special permitting needs
NPDES Permitting - compliance & inspection
Nondischarge Permitting
Wetlands and 401 permitting backlog
Nondischarge Permitting - compliance & inspection
Water Quality Regional Operations Staff (WQROS) support
for permitting and technical assistance in the field.
Emerging contaminants such as GenX to help establish
priorities and work with local health directors, researchers
and laboratories
Water Quality Regional Operations Staff (WQROS) support.
to address emerging contaminant issues to include working
with local government wastewater treatment technologies
Database development to full integrate wastewater data
with public water supply and groundwater data for
comprehensive evaluation of water systems
NPDES Permitting and backlog
Emer in contaminants support to sample and evaluate
waste streams for potential sources.
Analysis of emerging contaminants
Quality Assurance review for emerging contaminant
evaluations

ROY COOPER
Governor
MICHAEL S. REGAN
secretary
Environmental
Quality
July 21, 2017
Mr. Ellis H. McGaughy
Plant Manager
The Chemours Company FC, LLC
DBA, Chemours Company- Fayetteville Works
22828 NC Highway 87 West
Fayetteville, North Carolina 28306-7332
Dear Mr. McGaughy:
The presence of GenX and other emerging contaminants in the Cape Fear River is an issue of significant
concern in the Cape Fear River watershed. The North Carolina Department of Environmental Quality
(DEQ), in collaboration with the North Carolina Department of Health and Human Services (DHHS), is
investigating this important issue.
It is our understanding that Chemours (and previously DuPont) has been discharging GenX into the Cape
Fear River dating back to the 1980's. As previously requested, and in conjunction with our review of your
pending NPDES renewal application and pursuant to NCGS 143-215. I(c)(1), please submit to DEQ any
and all records in the possession of Chemours related to the discharge of GenX and other emerging
contaminants. This includes records pertaining to production levels of GenX and other products for which
emerging contaminants are a byproduct; discharge levels of emerging contaminants into the Cape Fear
River or anywhere else; and sampling data in your possession related to discharge of GenX and other
emerging contaminants recently and in the past. Finally, I ask that you immediately inform DEQ of any
records relevant to this request that you are aware of but that are not in the possession of Chemours.
Please submit the requested information as soon as possible, but no more than 14 days from the date of
this letter to:
NC Dept. of Environmental Quality
Division of Water Resources
ATTN: Linda Culpepper
1636 Mail Service Center
Raleigh, NC 27699-1636
Thank you for your cooperation on this matter.
Sincerely,
Michael Regan
Secretary
State of North Carolina ! Environmental Quality
217 West Jones Street 1 1601 Mall Service Center I Raleigh, North Carolina 27699-1601
919 707 8600
DEQ-CFW 00075395

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FOUNDED 1897
June 19, 2017
By email to: [e-mail]
By FedEx to:
Secretary Michael S. Regan
Department of Environmental Quality
217 West Jones Street
Raleigh, North Carolina 27603
2000 RENAISSANCE PLAZA
230 NORTH ELM STREET
GREENSBORO, NC 27401
T 336.373.8850
F 336.378.1001
WWW.BROOKSPIERCE.COM
Re: GenX in the Cape Fear River; First Set of Requests for DEQ Action
Dear Secretary Regan:
We are environmental counsel for the Cape Fear Public Utility Authority
("CFPUA'). This letter is our first set of requests on behalf of CFPUA for DEQ
monitoring, permitting, and regulatory actions. We anticipate future requests as we
obtain and consider additional information. Our requests do not limit or narrow in
any way the requests made by CFPUA in its resolution of June 16, 2017. See Exhibit
1 (enclosed).
In this letter, we refer collectively to the following pollutants as "GenX
Pollutants":
(1) chemicals collectively identified by DuPont Company and The Chemours
Company FC, LLC as "GenX";
(2) chemicals that are structurally or functionally or otherwise similar to GenX
that result from the manufacture, use, processing, treatment, or disposal of
GenX ("Post-GenX Chemicals");
(3) perfluoroalkyl ether carboxylic acids (PFECAs); and
(4) chemicals that are structurally or functionally or otherwise similar to
PFECAs that result from manufacture, use, processing, treatment, or
disposal of PFECAs ("Post-PFECA Chemicals").
Sampling Program for GenX Pollutants
We request DEQ cause the implementation of an extensive sampling and
analysis program to detect and determine the concentrations of GenX Pollutants in
certain effluents, in the Cape Fear River, and in the tissues of aquatic organisms in
the Cape Fear River.
DEQ-CFW 00075397

The program should include analysis of samples using currently available
methods to determine the presence and concentrations of GenX Pollutants. In
addition, each sampling event should include the collection, preservation, and secure
storage of multiple, additional samples to allow future analyses using analytical
methods that will be developed but do not currently exist. As new analytical methods
become available, stored samples should be analyzed. The requested sampling should
include, but not be limited to, the following:
1. CFPUA Intakes. For at least one year, collect at least weekly water
samples from the Cape Fear River at the CFPUA intakes, in coordination
with CFPUA.
2. Process Streams. For at least one year, on an unannounced basis, collect
weekly samples of the effluent from each separate process stream that
contributes wastewater to Outfall 001, with the hour of each sampling event
to be randomly selected such that sample collection may occur at any hour
within each 24-hour period.
3. Outfall 001. For at least one year, collect unannounced weekly samples of
the effluent from Outfall 001, with the hour of each sampling event to be
randomly selected such that sample collection may occur at any hour within
each 24-hour period.
4. Outfall 002. For at least one year, collect unannounced samples of the
effluent from Outfall 002 at the same time samples are collected from
Outfall 001.
5. Aquatic Organism Tissue. Collect tissue samples from appropriate
species of fish, benthic organisms (e.g., freshwater clams, mussels, crayfish,
etc.) at Outfall 002, at the CFPUA intakes, and at a midpoint between the
two locations.
6. Sediment Samples. Collect sediment samples at Outfall 002 and at
appropriately spaced points downstream of Outfall 002.
NPDES Permit Conditions or Denial of Renewal Application
We understand that Chemours has applied for reissuance of the NPDES
permit for the Chemours industrial wastewater discharge to the Cape Fear River
from its Chemours Company — Fayetteville Works near Fayetteville, North Carolina,
NPDES Permit No. NC0003573 (the "Chemours Permit"). We also understand that
the application is still under consideration by DEQ.
DEQ-CFW 00075398

We request on behalf of CFPUA that DEQ include conditions in the Chemours
Permit required by 15A NCAC 2H .0112(c):
The permit applicant has the burden of providing sufficient
evidence to reasonably ensure that the proposed system will comply
with all applicable water quality standards and requirements. No
permit may be issued when the imposition of conditions cannot
reasonably ensure compliance with applicable water quality standards
and regulations....
15A NCAC 2H .0112(c). If Chemours, for any reason, does not provide sufficient
evidence to reasonably ensure that the proposed system will comply with all
applicable water quality standards and requirements, we request the Chemours
application for permit renewal be denied.
More specifically, we request the inclusion of the following conditions:
GenX WQBEL. Add a water quality based effluent limit that sufficiently
limits the discharge of GenX Pollutants to reasonably ensure that GenX Pollutants
occur in the Cape Fear River in "only such amounts as shall not render the waters
injurious to public health" as required by 15A NCAC 2B .0211(12) ("GenX WQBEL").
If DEQ is unable to determine the GenX WQBEL or for any other reason does
not add the GenX WQBEL as a permit condition, we request DEQ condition the
Chemours Permit to prohibit the discharge of GenX Pollutants.
GenX TBEL. Impose a technology -based effluent limit that requires the
removal of at least 99% of GenX Pollutants from the effluent of each separate
industrial process that contributes to the Outfall 001 effluent ("GenX TBEL"). We
note that DEQ's authority includes, but is not limited to, the following:
For industrial categories or parts of categories for which effluent limits
and guidelines have not been published and adopted, effluent
limitations for existing industrial waste discharges, or new industrial
waste discharges shall be calculated by the staff using the projected
limits of the Environmental Protection Agency, the Environmental
Protection Agency development document and other available
information in order to achieve the purposes of Article 21. Such limits
developed by the staff shall be subject to approval by the Director.
3
DEQ-CFW 00075399

15A N.C. Admin. Code 2B .0406(e) (italics added). The purposes of Article 21 include
the following:
Standards of water and air purity shall be designed to protect human
health ... to prevent damage to public and private property ... to provide
a permanent foundation for healthy industrial development and to
secure for the people of North Carolina, now and in the future, the
beneficial uses of these great natural resources.
N.C. Gen. Stat. § 143-211(c).
Moreover, the GenX TBEL is mandated by statute as follows:
All permit decisions shall require that the practicable waste treatment
and disposal alternative with the least adverse impact on the
environment be utilized.
N.C. Gen. Stat. § 143-215.1(b)(2). Adverse environmental impact as well as the
practicability of 99% removal are both established by EPA's Toxic Substances Control
Act Consent Order signed by EPA on January 26, 2009 that allows the manufacture
of GenX in the United States ("TSCA Order") and information used by EPA to craft
the TSCA Order.
In addition, North Carolina water quality standards prohibit the discharge
into the Cape Fear River at the location of the Chemours facility of any industrial
wastes that "have an adverse effect on human health or that are not treated to the
satisfaction of the [Environmental Management] Commission and in accordance with
the requirements of the Division [of Water Resources]." 15A NCAC 2B .0216(3)(a).
If DEQ does not add the GenX WQBEL as a permit condition, we request DEQ
condition the NPDES Permit to prohibit the discharge of GenX Pollutants.
3. Other NPDES Permit Actions
We request that DEQ assess and determine whether the use of "noncontact
Cape Fear River water" to apparently dilute the industrial wastewater effluent by a
factor of more than 25:1 complies with all regulatory and statutory requirements.
We request that DEQ assess and determine whether the use of an in -river
sampling location for whole effluent toxicity complies with all regulatory and
statutory requirements, and whether sampling should instead occur at the outfall.
4
DEQ-CFW 00075400

Public Health Determination
We request that DEQ request and obtain a determination from the
Department of Health and Human Services whether or not the Chemours discharge
point to the Cape Fear River is an "outlet for the disposal of waste [that] is, or would
be, sufficiently close to the [CFPUA] intake works ... as to have an adverse effect on
the public health." N.C. Gen. Stat. § 143-215.1(a2).
On behalf of CFPUA, we look forward to working with you and your
department on this important matter.
Sincerely,
geW.H se
V. Randall Tinsley
5
DEQ-CFW 00075401

Exhibit 1
(CFPUA Resolution)
DEQ-CFW 00075402

CAPE FEAR PUBLIC UTILITY AUTHORITY
RESOLUTION
Whereas Cape Fear Public Utility Authority (CPPUA) furnishes water for the City of Wilmington
and sections of New Hanover County.
Whereas the Chemours Company ("Chemours") has informed the public that It fs releasing
fluorochemical compounds known as GenX into the Cape Fear River with its wastewater effluent at its
manufacturing facility located in Fayetteville, North Carolina.
Whereas Chemours' renewal applicat'ron-for NPD€S Permit NC0003573 dated April 27, 2016 did
not disclose to the North Carolina Department of Environmental Quality ("DEC") and the public that its
effluent wastewater contained fluorochemical compounds and specifically those compounds known as
GenX.
Whereas Chemours, the U.S. Environmental Protection Agency ("EPA") and the North Carolina
Department of Health and Human Services ("DHHS") believe that there is some evidence that the
fluorochemicals currently present in the Cape Fear River will not harm human health or the
environment, none of these parties will say for certain.
Whereas CFPUA has reviewed the EPA's Consent Order ("Order") under the Toxic Substances
Control Act signed January 26, 2009 allowing the manufacture of GenX in the United States.
Whereas the Order states: "EPA has concerns that these PMN substances will persist In the
environment, could bio-accumulate, and be toxic (."PBT") to people, wild mammals and birds. EPA's
.concerns are based upon data on the PMN substances, analogy to other [ 1 chemicals, and to
perfluorooctanoic acid ("PFOA") and perfluorooctane sulfonate ("PFOS") which are both currently under
review by EPA for PBT concerns. And further, "EPA has human health concerns for the PMN
substances."
Whereas the Order requires Chemours to "recover and capture ,(destroy) or recycle the PMN
substances at an overall efficiency of 99% from all effluent process streams and the air emissions (point
source and fugitive.)"
Whereas the EPA 'request certain studies be completed by Chemours for EPA's review to allow
the EPA to determine at what level the chemical compounds known as GenX can be safely consumed, if
at all, by the public.
Whereas the EPA has advised CFPUA that it has not completed those studies.
Whereas under the North Carolina Administrative Code which was adopted to implement the
General Statutes of North Carolina, a "Discharge Is the addition of any man induced -waste effluent
either directly or indirectly to state surface waters." And an "Industrial Discharge" is "the discharge of
industrial process treated wastewater".15A NCAC 213.0202 (25 and 36).
Whereas "deleterious substances" or "other Wastes" are permitted to occur in the Cape Fear
River In "only such amounts as shall not render the waters injurious to public health." 15A NCAC 2B
.0211(12). Anygreater amount would be an unlawful violation of a North Carolina surface water quality
standard.
DEQ-CFW 00075403

Whereas North Carolina water quality standards prohibit the discharge into the Cape Fear River
at the location of the Chemours facility of any Industrial wastes that."have an adverse effect on human
health or that are not treated to the satisfaction of the [Environmental Management] Commission and
In accordance with the requirements of the Division [of Water Resources]." 15A NCAC 2B.0216(3)(a).
Arid, "[a]ny dischargers or industrial users subject to pretreatment standards may be required by the
Commission to disclose all chemical constituents present or potentially present in their wastes and
chemicals that could be spilled or be present in runoff from their facility which may have an adverse
Impact on downstream water supplies. These facilities may be required to have spill and treatment
failure control plans as well as perform special monitoring for toxic substances." Id.
Whereas the current version of NPDES Permit NC0003573 issued to Chemours by DEQ on
October 28, 2015 provides for the permit to be modified or revoked and reissued to incorporate
additional toxicity limitations and monitoring requirements "in the event toxicity testing or other studies
conducted on the effluent or receiving stream indicate that detrimental effects may be expected in the
receiving waters as a result of this discharge." NPDES Permit No. NC0003573 at A.(5).
Whereas GenX is clearly persistent enough to travel miles from the Chemours manufacturing
facility to the CFPUA drinking water intake.
Whereas the CFPUA wants to protect and will take such actions as are necessary to protect its
water users from any harm.
Whereas EPA and DEQ have authority to take actions to protect the CFPUA's water users and
should promptly take all such actions. ,
Now, therefore, be it resolved:
1. CFPUA requests DEQ:
a, To Immediately modify NPDES Permit NC0003573 to require daily sampling and
testing of all waste streams leaving the Chemours manufacturing facility (including
any affiliates or tenants discharging through the Chemours wastewater treatment
plant) for all fluorochemicals, including those known as GenX, being discharged into
the Cape Fear River from outfalls 001 and 002 ; and
b. To immediately consult wih DHHS and determine whether the concentrations of
the GenX compounds in the wastewater discharge to the Cape Fear River from the
Chemours manufacturing facility are protective of human health, taking into
account all relevant factors including, without limitation, toxicity, persistence in the
environment, and bioaccumulation; and
c. To Immediately modify NPDES Permit NC0003573 to prevent any discharge of the
GenX compounds from the Chemours manufacturing facility wastewater treatment
plant until paragraphs 1.a. and b. have been completed.
2. The CFPUA requests EPA determine whether Chemours has;
DEQ-CFW 00075404

a. For each month in which Chemours has discharged any amount of GenX to the Cape
Fear River, continuously captured/destroyed 99% of GenX from its wastewater
treatment plant effluent streams; and
b. Has established at Its Fayetteville facility the necessary processes and procedures to
ensure that 99% of GenX is being and will continue to be captured/destroyed from
its wastewater treatment plant effluent streams.
3. CFPUA requests EPA immediately review the studies It has received from Chemours and any
sampling it is aware of and determine immediately whether the concentrations of -the GenX compounds
in the wastewaters from the Chemours manufacturing facility wastewater treatment plant being
discharged to the Cape Fear River are protective of human health, taking into account all relevant
factors including, without limitation, toxicity, persistence in the. environment, and bioaccumulation and
to immediately modify PMN P-08-508 and P-08-509 to prevent the discharge of any fluorochemical
compounds into the Cape Fear River until these determinations can be made.
4. CFPUA requests Chemours act responsibly and cease all discharges that contain fluorochemical
compounds until DHHS and EPA determine what levels of concentration for each such compound being
discharged can be safely discharged to protect human health and the environment.
This 16th day of June, 2017.
Michael C. Brown, 111
Chairman of the Board
Attest:
C. Lawrence Sneeden, Secretary
DEQ-CFW 00075405

t
CAPE FEAR PUBLIC UTILITY AUTHORITY
RESOLUTION
Whereas Cape Fear Public Utility Authority (CFPUA) furnishes water for the City of Wilmington
and sections of New Hanover County.
Whereas the Chemours Company ("Chemours") has informed the public that it is releasing
fluorochemical compounds known as GenX into the Cape Fear River with its wastewater effluent at its
manufacturing facility located in Fayetteville, North Carolina.
Whereas Chemours' renewal application for NPDES Permit NCO003573 dated April 27, 2016 did
not disclose to the North Carolina Department of Environmental Quality ("DEW) and the public that its
effluent wastewater contained fluorochemical compounds and specifically those compounds known as
GenX.
Whereas Chemours, the U.S. Environmental Protection Agency ("EPA") and the North Carolina
Department of Health and Human Services ("DHHS") believe that there is some evidence that the
fluorochemicals currently present in the Cape Fear River will not harm human health or the
environment, none of these parties will say for certain.
Whereas CFPUA has reviewed the EPA's Consent Order ("Order") under the Toxic Substances
Control Act signed January 26, 2009 allowing the manufacture of GenX in the United States.
Whereas the Order states: "EPA has concerns that these PMN substances will persist in the
environment, could bio-accumulate, and be toxic ("PBT") to people, wild mammals and birds. EPA's
concerns are based upon data on the PMN substances, analogy to other [ ] chemicals, and to
perfluorooctanoic acid ("PFOA") and perfluorooctane sulfonate ("PFOS") which are both currently under
review by EPA for PBT concerns." And further, "EPA has human health concerns for the PMN
substances."
Whereas the Order requires Chemours to "recover and capture (destroy) or recycle the PMN
substances at an overall efficiency of 99% from all effluent process streams and the air emissions (point
source and fugitive.)"
Whereas the EPA request certain studies be completed by Chemours for EPA's review to allow
the EPA to determine at what level the chemical compounds known as GenX can be safely consumed, if
at all, by the public.
Whereas the EPA has advised CFPUA that it has not completed those studies.
Whereas under the North Carolina Administrative Code which was adopted to implement the
General Statutes of North Carolina, a "Discharge is the addition of any man induced -waste effluent
either directly or indirectly to state surface waters." And an "Industrial Discharge" is "the discharge of
industrial process treated wastewater". 15A NCAC 213.0202 (25 and 36).
Whereas "deleterious substances" or "other wastes" are permitted to occur in the Cape Fear
River in "only such amounts as shall not render the waters injurious to public health." 15A NCAC 28
.0211(12). Any greater amount would be an unlawful violation of a North Carolina surface water quality
standard.
DEQ-CFW 00075406

Whereas North Carolina water quality standards prohibit the discharge into the Cape Fear River
at the location of the Chemours facility of any industrial wastes that "have an adverse effect on human
health or that are not treated to the satisfaction of the [Environmental Management] Commission and
in accordance with the requirements of the Division [of Water Resources]." 15A NCAC 2B.0216(3)(a).
And, "[a]ny dischargers or industrial users subject to pretreatment standards may be required by the
Commission to disclose all chemical constituents present or potentially present in their wastes and
chemicals that could be spilled or be present in runoff from their facility which may have an adverse
impact on downstream water supplies. These facilities may be required to have spill and treatment
failure control plans as well as perform special monitoring for toxic substances." Id.
Whereas the current version of NPDES Permit NC0003573 issued to Chemours by DEQ on
October 28, 2015 provides for the permit to be modified or revoked and reissued to incorporate
additional toxicity limitations and monitoring requirements "in the event toxicity testing or other studies
conducted on the effluent or receiving stream indicate that detrimental effects may be expected in the
receiving waters as a result of this discharge." NPDES Permit No. NC0003573 at A.(5).
Whereas GenX is clearly persistent enough to travel miles from the Chemours manufacturing
facility to the CFPUA drinking water intake.
Whereas the CFPUA wants to protect and will take such actions as are necessary to protect its
water users from any harm.
Whereas EPA and DEQ have authority to take actions to protect the CFPUA's water users and
should promptly take all such actions.
Now, therefore, be it resolved:
1. CFPUA requests DEQ:
a. To immediately modify NPDES Permit NC0003573 to require daily sampling and
testing of all waste streams leaving the Chemours manufacturing facility (including
any affiliates or tenants discharging through the Chemours wastewater treatment
plant) for all fluorochemicals, including those known as GenX, being discharged into .
the Cape Fear River from outfalls 001 and 002 ; and
b. To immediately consult wih DHHS and determine whether the concentrations of
the GenX compounds in the wastewater discharge to the Cape Fear River from the
Chemours manufacturing facility are protective of human health, taking into
account all relevant factors including, without limitation, toxicity, persistence in the
environment, and bioaccumulation; and
c. To immediately modify NPDES Permit NC0003573 to prevent any discharge of the
GenX compounds from the Chemours manufacturing facility wastewater treatment
plant until paragraphs La. and b. have been completed.
2. The CFPUA requests EPA determine whether Chemours has:
DEQ-CFW 00075407

For each month in which Chemours has discharged any amount of GenX to the Cape
Fear River, continuously captured/destroyed 99% of GenX from its wastewater
treatment plant effluent streams; and
b. Has established at its Fayetteville facility the necessary processes and procedures to
ensure that 99% of GenX is being and will continue to be captured/destroyed from
its wastewater treatment plant effluent streams.
3. CFPUA requests EPA immediately review the studies it has received from Chemours and any
sampling it is aware of and determine immediately whether the concentrations of the GenX compounds
in the wastewaters from the Chemours manufacturing facility wastewater treatment plant being
discharged to the Cape Fear River are protective of human health, taking into account all relevant
factors including, without limitation, toxicity, persistence in the environment, and bioaccumulation and
to immediately modify PMN P-08-508 and P-08-509 to prevent the discharge of any fluorochemical
compounds into the Cape Fear River until these determinations can be made.
4. CFPUA requests Chemours act responsibly and cease all discharges that contain fluorochemical
compounds until DHHS and EPA determine what levels of concentration for each such compound being
discharged can be safely discharged to protect human health and the environment.
This 16th day of June, 2017.
7Zr,S�7
Michael C. Brown, III
Chairman of the Board
Attest:
C. Lawrence Sneeden, Secretary
DEQ-CFW 00075408

CAPE FEAR PUBLIC UTILITY AUTHORITY
RESOLUTION
WHEREAS, on June 16, 2017, the Cape Fear Public Utility Authority Board passed a resolution
requesting that NCDEQ and EPA take certain actions regarding the Chemours manufacturing facility's
wastewater treatment plant.
WHEREAS, the Board believes that these actions should be taken in a timely fashion.
NOW, THEREFORE, the Cape Fear Public Utility Authority authorizes its independent
environmental counsel to take whatever actions deemed necessary to accomplish the objectives of the
aforementioned resolution.
Adopted this, the 16th day of June, 2017.
!r
Michael C. Brown, III, Chairman
7
Attest: � G
_ c _/J
C. Lawrence Sneeden, Jr., Secretary
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DEQ-CFW 00075409