HomeMy WebLinkAboutNC0089915_technical correction_20210125ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
NORTH CAROLINA
Director Environmental Quality
January 25, 2021
Mr. Brian Long, Plant Manager
The Chemours Company / Fayetteville Works
22828 NC Highway 87 West
Fayetteville, NC 28306
Subject: NPDES Permit NC0089915
Technical correction /parameter codes
Fayetteville Works
Bladen County
Grade PC -II WPCS
Dear Mr. Long:
The Division has received questions from your facility's staff regarding the parameter codes
used for data entry in the Division's eDMR system. In addition, some parameter codes were
inadvertently omitted from your original permit. This permit modification provides the correct
parameter codes for outfall 003, as well as updated sampling frequencies as described in the previous
permit modification issued on December 14, 2020.
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). Insert the
attached pages into your permit and discard the old pages. The new pages take effect February 1, 2021.
This modified permit includes the following changes to the existing permit:
➢ Parameter codes for each parameter have been added to simplify and clarify data entry.
➢ Monitoring frequencies have been updated as per the 12/14/2020 permit modification
➢ Footnotes have been re -numbered and edited for clarity.
If any parts, measurement frequencies or sampling requirements contained in this modification
are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty
(30) days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless
such demand is made, this decision shall be final and binding.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mall Service Center I Raleigh, North Carolina 27699-1617
919.707.9000
This permit is not transferable except after notice to the Division. The Division may require
modification or revocation and reissuance of the permit. This permit does not affect the legal
requirements to obtain other permits which may be required by any other Federal, State, or Local
governmental regulation.
If you have any questions concerning these changes, please contact Dr. Sergei Chernikov
[sergei. chernikov@ncdenr. gov].
Sincerely,
s,
e�V S. Daniel Smith, Director
Division of Water Resources
cc: NPDES Unit (Laserfiche)
Permit NC0089915
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — OUTFALL 003
[15ANCAC 02B .0400 et seq., 02B .0500 et seq.]
Facility Physical -Chemical Grade II [15A NCAC 8G .0306]
Beginning on the February 1, 2021 and lasting through the expiration date, the Permittee is authorized to discharge
from Outfall 003 (treated surface water, groundwater, and stormwater) Such discharges shall be limited and
monitored by the Permittee as specified below:
PARAMETER CHARACTERISTICS
EFFLUENT LIMITS
MONITORING REQUIREMENTS
Monthly Average
Daily Maximum
Measurement Sample
Frequency Type
Sample
Location1
Flow
50050
1.58 MGD
Continuous
Recording
Effluent
Total Monthly Flow 82220
Monitor and Report (MG/month)
Monthly
Recording
or
Calculation
Effluent
Temperature (°C)
00010
See footnote 2
Weekly
Grab
Effluent, U & D
BOD, 5-day, 20°C C0310
30.0 mg/L
45.0 mg/L
Monthly
Composite
Effluent
TSS C0530
30.0 mg/L
45.0 mg/L
Monthly
Composite
Effluent
Dissolved Oxygen, mg/L 00300
Weekly
Grab
U & D
Turbidity 00700
Daily
Grab
Influent & Effluent
PMPA3 52624
0.054 pg/L
0.054 pg /L
Weekly
Grab
Influent & Effluent
PMPA3
QM624
Monitor and Report (pounds/month)
Monthly
Calculation
Effluent
PMPA3
QY624
Monitor and Report (pounds/year)
Annually
Calculation
Effluent
HFPO-DA3
52612
0.06 pg/L
0.06 Ng /L
Weekly
Grab
Influent & Effluent
HFPO-DA3
QM612
Monitor and Report (pounds/month)
Monthly
Calculation
Effluent
HFPO-DA3
QY612
Monitor and Report (pounds/year)
Annually
Calculation
Effluent
PFMOAA3
52613
0.85 pg/L
0.85 pg/L
Weekly
Grab
Influent & Effluent
PFMOAA3
QM613
Monitor and Report (pounds/month)
Monthly
Calculation
Effluent
PFMOAA3
QY613
Monitor and Report (pounds/year)
Annually
Calculation
Effluent
PFAS compounds, ng/L
See A. (5.)
Grab
See A. (5.)
Total Phosphorus, mg/L C0665
Monthly
Composite
Effluent
Total Nitrogen, mg/L C0600
(NO2+NO3+TKN)
Monthly
Composite
Effluent
Conductivity 00094
Monthly
Grab
Upstream,
Downstream
Page 3of12
Permit NC0089915
PARAMETER CHARACTERISTICS
EFFLUENT LIMITS
MONITORING REQUIREMENTS
Monthly Average
Daily Maximum
Measurement
Frequency
Sample
Type
Sample
Location
Chronic Toxicity TGP3B
See footnote 4
Quarterly
Composite
Effluent
pH 00400
Between 6.0 and 9.0 Standard Units
Weekly
Grab
Effluent
Mercury (Method 1631E) COMER
Monitor and Report (ng/L)
Quarterly
Grab
Effluent
Total Selenium 01147
Quarterly
Composite
Effluent
Total Silvers 01077
0.48 pg/L5
2.01 pg/L
Monthly
Composite
Effluent
Total Cobalts 01037
23.9 pg/L
23.9 pg/L
Monthly
Composite
Effluent
Total Cadmium, pg/L 01027
Quarterly
Composite
Effluent
Total Copper, pg/L 01042
Quarterly
Composite
Effluent
Total Cyanide, pg/L 00720
Quarterly
Composite
Effluent
Total Lead, pg/L 01051
Quarterly
Composite
Effluent
Total Thallium, pg/L 01059
Quarterly
Composite
Effluent
Total Hardness [as CaCO3] 00900
(mg/L)
Quarterly
Composite
Grab
Effluent
Upstream7
Footnotes:
1. Influent: influent to the Old Outfall 002 Wastewater Treatment System. Note the Outfall 003 concentration
limitations do not apply to the influent. Influent sampling is required to calculate the HFPO-DA and
PFMOAA percent removal.
Effluent: Outfall 003 (effluent from the Old Outfall 002 Wastewater Treatment System).
U: upstream monitoring shall be at the Permittee's Cape Fear River Water Intake.
D: downstream 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 for
conventional parameters (DO, temperature, and conductivity) 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. The Permittee shall remove indicator parameters HFPO-DA, PFMOAA, and PMPA at an efficiency of 99% in
order to reduce PFAS loading to the Cape Fear River. The effluent limits listed above are Technology Based
Effluent Limits ("TBELs") calculated to ensure a minimum of 99% removal efficiency. In addition to
complying with these effluent limits the Permittee must demonstrate compliance with the 99% removal
efficiency requirement by calculating monthly removal efficiency for HFPO-DA, PFMOAA, and PMPA
pursuant to condition A. (6.). The Permittee may request revision of the 99% removal efficiency requirement
upon a demonstration that influent concentrations of PFAS have been reduced to such a level that 99% removal
is no longer technically feasible. However, notwithstanding any such revision, Chemours shall continue to
operate the Treatment System at optimal efficiency.
4. Chronic Toxicity (Ceriodaphnia) P/F @ 12.5%; testing shall be performed quarterly during February, May,
August, November; see A. (2.) of this permit.
Page 4 of 12
Permit NC0089915
5. Sufficiently sensitive test methods shall be used to analyze for Silver. The Division shall consider all
effluent Silver values reported below the PQL to be in compliance with the Monthly Average Silver limit.
As of the effective date of this permit, DWR recommends a target PQL of 1.0 µg/L for Silver.
6. After 12 months of sampling the facility can apply for a reduction in sampling if all the sampling results
demonstrate concentrations below detection levels. The facility shall be employing the sufficiently sensitive
test methods.
7. The permittee shall sample instream hardness upstream of the facility's discharge. The sample shall be
representative of the hardness in the stream. If the permittee is a member of the Monitoring Coalition
Program, sampling for instream hardness may be waived as long as the Monitoring Coalition agrees to
sample hardness at the nearest upstream location, at a minimum frequency of quarterly, and the permittee
has obtained approval from DWR -NPDES Permitting Unit that the upstream station being monitored by
the coalition is representative of the receiving stream for this discharge. The permittee is responsible for
submitting instream hardness test results with its DMRs as results are received from the coalition. If
coalition membership is cancelled or the Monitoring Coalition terminates instream hardness sampling at
the approved station, the permittee will immediately notify the Division and resume sampling for instream
hardness, upstream of its discharge, as required in Section A. (1.).
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.
The facility shall develop a Dam (collection system) Operation and Maintenance Plan (Plan) to ensure
maximum dry weather flow (- 610 gpm) in the channel is consistently captured and treated. Similar efforts
shall be applied at the sumps/dams or other devices that will be used to capture water from the seeps.
The Plan shall be provided to the DEQ no later than October 18, 2020 for review and approval. Upon
approval, the Plan becomes an integral part of the permit.
The facility shall complete and submit EPA Form 2C for this Outfall no later than March 30, 2021.
From time -to -time the Middle Cape Fear River has experienced flooding conditions which are documented to
cause a significant increase in water levels below Lock and Dam #3, consistent with the location of proposed
Outfall 003. During these events a backwater condition propagates upstream in the "Old Outfall 002
Stream". Historical observation indicates that the Old Outfall 002 Stream levels can rise significantly (consistent
with the flooded Cape Fear River levels) and would be expected, at times, to be equal to or significantly greater
than the invert elevation of the treatment system intake dam and associated pumping system. During these
flooded backwater conditions elevated sediment load and reduced flow velocity gradients are expected to cause
significant sediment deposition within the collection dam and pumping structure. The sediment load may cause
failure of the pumping and treatment system during the flooded backwater condition. Requirement for treatment
shall be suspended during these force majeure flooding events and be allowed 48 hours after the backwater stream
level falls below the invert of the intake collection dam to safely maintain the influent collection structure and re-
initiate collection and treatment. The triggering Cape Fear River flood elevations; event documentation and
notification requirements; and procedure for treatment cessation and safe restart shall be included in the approved
Dam Operation and Maintenance Plan. Whenever treatment is suspended under this condition, the permittee shall
document the flooding in the DMR for that month including the time of flooding above the intake invert, when
the water recedes below the intake invert, and time that treatment resumes.
Page 5 of 12
Weaver, Charles
From: Chernikov, Sergei
Sent: Monday, January 25. 2021 8:31 AM
To: Weaver, Charles; 'Fields, Dianne L'; Brantley. Mari..
Subject: RE: 52620 vs. 52624 - solved
Looks good to me.
Thank you, Charles!
Sergei Chernikov, Ph.D.
Environmental Engineer 111
Industrial NPDES Permitting Unit
NEW Tel. 919-707-3606
1617 Mail Service Center, Raleigh, NC 27699-1617
Express Mail: 512 N. Salisbury St., Raleigh, NC 27604
From: Weaver. Cnarse
Sent: Monday, January 25, 2021 7:58 AM
To: 'Fields, Dianne L' <DIANNE.L.FIELDS@chemours.com>; Brantley, Mark <mark.brantley@ncdenr.gov>
Cc: Chernikov, Sergei <sergei.chernikov@ncdenr.gov>
Subject: 52620 vs. 52624 - solved
When we were first setting up the PFAS effluent codes in BIMS, we knew we would need codes for both mass and
concentration measurements. 52624 was chosen for PMPA, with the following codes:
52624 — concentration
QM624 — quantity monthly
QY624 — quantity annually
Code 52620 does NOT have any codes for mass measurements, so that's why it wasn't used for the effluent sampling of
PMPA.
I've attached a rough draft of a corrected effluent sheet showing all the parameter codes. I'll add Turbidity and then
everything for the effluent will be correct. I'll issue a minor modification/technical correction with an effective date of
2/1/2021.
We'll leave 52624 for effluent PMPA and 52620 for instream PMPA. That will actually make it easier to separate the
data for future evaluation. etc.
Let me know if this solution sounds reasonable.
Charles H. Weaver
Environmental Soecialisi
N.C. DEQ / Division of Water Resources
919-707-3616
charles.weaver@mcdenr.gov
(mailing address) 1617 Mail Service Center, Raleigh, NC 27699-1617
1
Weaver, Charles
From: Fields, Dianne L <DIANNE.L.FIELDS@chemours.com>
Sent: Monday, January 25, 2021 9:27 AM
To: Weaver, Charles; Brantley, Mark
Cc: Compton, Christel E
Subject: RE: ?RE: [External] FW: ?52620 vs. 52624 - solved
CAUTION. External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Thank you for the update.
Regards,
Dianne
From: Weaver, Charles <charies.weaver@ncdenr.gov>
Sent: Monday, January 25. 2021 9:24 AM
To: Fields, Dianne L <DIANNE.L.FIELDS@chemours.com>; Brantley, Mark <mark.brantley@ncdenr.gov
Cc: Compton, Christel E <CHRISTEL.E.COMPTON@chemours.com>
Subject: ?RE: [External] FW: ?52620 vs. 52624 - solved
External email. Confirm links and attachments before opening.
See answers below
From: Fields. Dianne L <DIANNE.L.FIELDS@chemours.com>
Sent: Monday. January 25. 2021 9:11 AM
To: Weaver, Charles <charles.weaver@ncdenr.gov>; Brantley, Mark <mark.brantley@ncdenr.gov>
Cc: Compton, Christel E <CHRISTEL.E.COMPTON@chemours.com>
Subject: [External] FW: ?52620 vs. 52624 - solved
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Charles,
Thank you for your follow up on this matter of PMPA. Please note that the monthly PMPA will be the same analytical
result for that particular weekly sample.
»Understood. PMPA is one compound with two parameter codes, thanks to EPA«
In other words, we are using the monthly sample to count as one of the weekly samples for PMPA as well as PFMOAA
and HFPO-DA. So in the eDMR we entered in that data for example on 12/8/2020 in form Outfall: 003 — Location:
Effluent and the form Outfall: 003C — Location: Effluent as the same value. Will both of these forms have 52624 on
them. Likewise we will enter data on form Outfall: 003 — Location: Influent and the form Outfall: 003B — Location:
Influent as the same value. Will these both be switched to 52620.
»No. The effluent eDMR will list 52624, and the instream locations will list 52620. We understand that the same
sample numbers will be entered using two different coaes.«
i
It is confusing to me that only PMPA has two codes and not HFPO-DA and PFMOAA which have the same criteria on the
effluent. Can you comment on why HFPO-DA and PFMOAA don't have a similar issue?
,PMPA was given duplicate codes [52620 and 52624] by EPA when we were setting up the data entry for PFAS
omoounas. To my knowledge, there are no duplicates for HFPO-DA and PFMOAA in our system, so this problem did
not arise for them.«
You said that these changes will be effective on 2/1/2021. So should 1 wait until then to download the forms for the
January eDMR or will they only be effective for February eDMR?
»Do the January eDMR using the same forms as you used for December 2020. I can't back -date the permit changes to
January 1, so they have to take effect 2/1/2021. This will minimally change your data -entry process; this modification is
more to fill in gaps in the permit and make sure everyone knows why both 52620 and 52624 are in the permit. Sergei is
OK with this solution.«
CHW
Regards,
Dianne
Dianne L Fields
Sr. Environmental Consultant
910-678-1384
The Chemours Company
Fayetteville Works Plant
22828 NC Hwy 87 West
Fayetteville, NC 28306
Chemours'
From: Weaver. Charles<charles.weaverCa@ncdenr.gov>
Sent: Monday. January 25, 2021 7:58 AM
To: Fields, Dianne L <DIANNE.L.FIELDS@chemours.com>; Brantley, Mark <mark.brantley@ncdenr.gov>
Cc: Chernikov, Sergei <sergei.chernikov@ncdenr.gov>
Subject: ?52620 vs. 52624 - solved
' External email. Confirm links and attachments before opening.
When we were first setting up the PFAS effluent codes in BIMS, we knew we would need codes for both mass and
:oncentration measurements. 52624 was chosen for PMPA, with the following codes:
52624 — concentration
QM624 — quantity monthly
QY624 — quantity annually
Code 52620 does NOT have any codes for mass measurements, so that's why it wasn't used for the effluent sampling of
PMPA.
I've attached a rough draft of a corrected effluent sheet showing all the parameter codes. I'll add Turbidity ana tnen
everything for the effluent will be correct. I'II issue a minor modification/technical correction with an effective date of
2/1/2021.
2
We'll leave 52624 for effluent PMPA and 52620 for instream PMPA. That will actually make it easier to separate the
data for future evaluation, etc.
Let me know if this solution sounds reasonabir
Charles H. Weaver
Environmental Specialist
N.C. DEQ / Division of Water Resources
919-707-3616
charies.weaver@ncdenr.gov
(mailing address) 1617 Mail Service Center, Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
<="" style='
This communication is for use by the intended recipient and contains information that may be privileged, confidential of
copyrighted under applicable law. If you are not the intended recipient, you are hereby formally notified that any use.
copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify the sender by return e-mail
and delete this e-mail from your system. Unless explicitly and conspicuously designated as "E-Contract Intended", this e-
mail does not constitute a contract offer, a contract amendment, or an acceptance of a contract offer. This e-mail does
not constitute a consent to the use of sender's contact information for direct marketing purposes or for transfers of data
to third parties.
https://www.chemours.com/en/email-disclaimer
<=." style="">
This communication is for use by the intended recipient and contains information that may be privileged, confidential or
copyrighted under applicable law. If you are not the intended recipient, you are hereby formally notified that any use,
copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify the sender by return e-mail
and delete this e-mail from your system. Unless explicitly and conspicuously designated as "E-Contract Intended", this e-
mail does not constitute a contract offer, a contract amendment, or an acceptance of a contract offer. This e-mail does
not constitute a consent to the use of sender's contact information for direct marketing purposes or for transfers of data
to third parties.
https://www.chemours.com/en/email-disclaimer