WQ0002503_Comments on Iron Background Evaluation_20210511

DocuSign Envelope ID: 011ABDF9-7283-492C-887B-D1A5A767B823
ROY COOPER
Governor
DONNE DELLI-GATT1
Secretary
S. DANIEL SMITH
Director
Mr. David Davis, P.G.
Senior Geologist
Poly, Inc.
Post Office Box 64
Shannon, Alabama 35142-0064
NORTH CAROLINA
Environmental Quality
May 11, 2021
RE: Iron Background Evaluation Comments
Frit Car, Inc.
Bridgeton, Craven County, North Carolina
Permit No. WQ0002503
Dear Mr. Davis:
The Washington Regional Office has reviewed the results of the Iron background
investigation that Poly, Inc. has performed at the Frit Car facility in Bridgeton, NC that you
submitted to our office on April 29, 2021. The report proposes the use of background data from
temporary background wells TM1 and TM3 as well as monitoring wells MW2, MW6, and MW7
located around the facilities spray field. It was our understanding, based on the proposal submitted
to our office in your May 11, 2020 letter, that site specific Iron background levels would be
developed from data collected at TM1 and TM3, located in areas of the facility away from the
spray field. Our office is not comfortable with using data from wells located in the vicinity of the
spray field and inside the Compliance Boundary, as defined in 15A NCAC 02L .0107, to develop
background levels. Especially, since effluent quality data at the facility included in the report
presents Iron concentrations with an average of approximately 26 mg/L, which is almost one order
of magnitude greater that the North Carolina Groundwater Standard of 0.3 mg/L.
We request that you recalculate a site specific Iron background level using the data
from TM1 and TM3. If Iron concentrations are detected above this background level in wells
located at the Review Boundary around the spray field, as defined in 15A NCAC 02L .0108, Frit
Car will need to evaluate if the background level has been exceeded at the Compliance Boundary,
as required by 15A NCAC 021 .0106(b). Exceedance of the background level at the Compliance
Boundary will require development of a Corrective Action Plan, as required by 15 A NCAC
02L .0106(f) and (h). Corrective Actions could include modifications to the wastewater treatment
system to reduce the Iron concentration in the effluent or the use of other effluent disposal options.
Should conclusions determine that improvements to the wastewater treatment system are
warranted, other disposal options such as Industrial Pump and Haul may be feasible.
wocARouto
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North Carolina Department of Environmental Quality I Division of Water Resources
Washington Regional Office 1943 Washington Square Mall I Washington, North Carolina 27889
252.946.6481

DocuSign Envelope ID: 011ABDF9-7283-492C-887B-D1A5A767B823
David Davis
May 11, 2021
Page 2 of 2
Thank you for your continued cooperation. Should you have any questions concerning the
contents of this letter, please contact me at [phone].
cc: Laserfiche
NORT DE _
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Sincerely,
Dwight Randy Sipe P.G., Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality I Division of Water Resources
Washington Regional Office 1943 Washington Square Mall I Washington, North Carolina 27889
252.946.6481