WQ0002503_Email_20200117 (3)

Strickland, Bev
From: Sipe, Randy
Sent: Friday, January 17, 2020 4:31 PM
To: Tim Floyd
Cc: '[e-mail]'; Connie Pettis ([e-mail]); '[e-mail]';
May, David; Tankard, Robert
Subject: RE: [External] Frit Car
Ti m,
Our office has reviewed your letter and we have the following comments.
Based on the discussion of groundwater monitoring results collected since the inception of low flow sampling at
the site it appears that, with the exception of iron, there have essentially been no exceedances of the limits in
the permit at the monitoring wells around the spray field during this time period, negating the need to develop
site background levels with the exception of iron. We do not consider the TOC values an issue given that no
VOCs have been detected and the annual analysis of VOCs will continue to occur as described in the permit.
It is proposed that the use of conventional groundwater sampling methods (bailers) have impacted groundwater
monitoring results prior to 2017. Because two thirds of the data collected from the background wells in 2018
were collected in this manner, we are uncomfortable with using this data in the evaluation of an iron
background level for the site. We would have preferred that the background data had been collected wholly
using a sampling technique believed to able to produce data representative of actual groundwater
conditions. Also, we are not comfortable with using two standard deviations plus an average for calculation of a
potential background level. Thirdly, we are not comfortable with evaluating iron background levels at the site
without knowing the iron concentrations in the effluent being produced by the treatment system.
The data presented in the discussion of chromium concentrations in the effluent from the treatment system do
not appear to correlate to the concentrations included on the monthly monitoring reports that have been
submitted.
Dwight Randy Sipe P.G.
Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources
252 948 3849 office
randy.sipea-ncdenr.gov
North Carolina Department of Environmental Quality
943 Washington Square Mall
Washington, NC 27889
<'-'-�Nothlng 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: Tim Floyd [mailto:[e-mail]]
Sent: Monday, December 30, 2019 1:10 PM
To: Sipe, Randy <[e-mail]>
Cc: '[e-mail]' <[e-mail]>; Connie Pettis ([e-mail]) <[e-mail]>;
'[e-mail]' <[e-mail]>
Subject: [External] Frit Car
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Randy:
Please find a response to your comments from your May 2019 Evaluation Report. The response addresses the items
listed in your letter. I did not prepare the original report, therefore, I chose to respond to your comments in letter form.
I'll be happy to revise the report if this is not sufficient. Although not required by the permit, Frit Car has added the
chromium and iron tested to the effluent. This added monitoring will begin on the next effluent sampling.
I have received a temporary license from the NC Board for licensing of Geologist. I have prepared to send a formal
licensing request for both me individually and our company upon the expiration of the temporary license. I apologize for
the delay in submitting the response. There was confusion as to whether I had received a temp approval prior to my
request. My temporary license was not issued until November. Please contact me at your earliest convenience to
discuss if you have further questions or comments.
Thanks,
Timothy N. Floyd, PG
Principal
Poly, Inc.
2135 University Blvd, Suite A, Tuscaloosa, AL 35401
205.752.4037 (work)
205.710.2319 (direct)
205.752.4063 (fax)
205.913.0330 (cell)
E-mail: tflovd(@ooly-inc.com
1=1OLY
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