NC0004952_Comments_20210625

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
MEMORANDUM
TO: Sergei Chernikov, Environmental Engineer III
NCDEQ Division of Water Resources, Industrial NPDES Permitting Unit
FROM: Olivia Munzer, Western Piedmont Coordinator
Habitat Conservation Division f l
DATE: 18 March 2021
SUBJECT: National Pollutant Discharge Elimination System Draft Permit for the Celanese Shelby Facility
in Cleveland County, North Carolina. DEQ Permit No. NC0004952.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
information. Our comments are provided in accordance with provisions of the United States National
Environmental Policy Act and Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et
seq.).
NC Department of Environmental Quality (NCDEQ) has issued a draft National Pollutant Discharge
Elimination System (NPDES) permit for the Celanese Shelby Facility, owned by CNA Holdings, LLC, located
at 2525 Blacksburg Road in Grover, Cleveland County, North Carolina. The draft NPDES permit authorizes the
discharge of wastewater and stormwater from the facility into Buffalo Creek in the Broad River basin. The draft
permit includes changes to the existing permit, including water quality effluent limits for Total Silver, Total
Hardness monitoring, and a monthly average effluent limit for Bis(2-ethylhexyl) phthalate (DEHP) of 8.67
µg/L.
The outfall is along Buffalo Creek in the Broad River basin. Buffalo Creek is classified as a Class C stream in
the Broad River basin. We have records of the state special concern Broad River spiny crayfish (Cambarus
spicatus) and the state significantly rare seagreen darter (Etheostoma thalassinum) in the watershed.
We have concerns for the discharge of phthalate into the stream. Effluent discharge is a source of phthalate in
rivers, and water is the primary routes of exposure of phthalate to humans (Munshi et al. 2013). Phthalate has
been found in fish and other aquatic organisms consumed by humans, and through bioamplification in the food
chain, people may be consuming higher concentrations of toxic substances (Munshi et al. 2013). Low dose
exposure to phthalate impairs human male genital development (Swan 2008, Swan et al. 2005). DEHP has been
shown to significantly inhibit the growth of fish, where body weight was diminished by up to 40 and 70% at
concentrations of 1 and 10 µg/L (Zanotelli et al. 2009). Liney et al. (2006) found effluent from wastewater,
which contained phthalates and other chemicals, disrupted the endocrine function of riverine fish, and
endocrine -disrupting compounds can have adverse physiological effects to freshwater mussels (Bouchard et al.
2009, Gagne et al. 201 la, Gagne et al. 2011b). Based upon the potential health risks to humans and aquatic
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Page 2
18 March 2021
Celanese Shelby Facility
DEQ Permit No. NC0004952
organisms, we recommend implementing measures to eliminate phthalates and any other endocrine -disrupting
chemicals [Table A (2)] from wastewater prior to discharge.
Thank you for the opportunity to comment on this project. If we can be of further assistance, please contact our
office at [phone] or [e-mail].
Literature Cited
Bouchard, B., F. Gagne, M. Fortier, and M Fournier. 2009. An in -situ study of the impacts of urban wastewater
on the immune and reproductive systems of the freshwater mussel Elliptio complanata. Comparative
Biochemistry and Physiology Part C: Toxicology and Pharmacology 150(2):132-140.
Gagne, F., C Andre, P. Cejka, R. Hausler, and M Fournier. 2011 a. Evidence of neuroendocrine disruption in
freshwater mussels exposed to municipal wastewaters. Science of the Total Environment 409(19):3711-3718.
Gagne, F., C Andre, P. Cejka, R. Hausler, and M Fournier. 2011b. Alterations in DNA metabolism in Elliptio
complanata mussels after exposure to municipal effluents. Comparative Biochemistry and Physiology Part C:
Toxicology and Pharmacology 154(2):100-107.
Liney, K.E., J.A. Hagger, C.R. Tyler, and M. Depledge. Health effects of fish of long -tern exposure to effluents
from wastewater treatment works. Environmental Health Perspectives 114(1):81-89.
Munshi, A.B., N. Karim, S. Shaukat, D. Hashmi, G.D. Boardman, and G. J. Flick. 2013. Toxicity of phthalate
esters in fish and shellfish from Virginia Beach using matrix solid phase dispersion (MSPD) and GC -MS.
Journal of The Chemical Society Pakistan 35(6) 1463-1471.
Swan, S.H. 2008. Environmental phthalate exposure in relation to reproductive outcomes and other health
endpoints in human. Environmental Research 108(2):177-184.
Swan, S.H., K.M. Main, F. Liu, S.L. Stewart, R.L. Kruse, A.M. Calafat, C.S. Mao, B. Redmon, C.L. Ternand, S.
Sullivan, J.L. Teague, and the Study for Future Families Research Team. 2005. Decrease in male anogenital
distance among male infants with prenatal phthalate exposure. Environmental Health Perspectives 113(8):1056-
1061
Zanotelli, V.R.T, S.C.F. Neuhauss, and M.U. Ehrengruber. 2009. Long-term exposure to bis(2-ethylhexyl)
phthalate (DEHP) inhibits growth of guppy fish (Poecilia reticulata). Journal of Applied Toxicology 30(1):29-
33.
ec: Corey Basinger, NCDWR