WQ0002503_Correspondence_20211029

October 29, 2021

Michael Newby
Senior Vice President
Frit Car, Inc.
Post Office Box 1340
Brewton, Alabama 36427

RE: Iron Background Evaluation Comments
Frit Car, Inc.
Bridgeton, Craven County, North Carolina
Permit No. WQ0002503

Dear Mr. Newby:

The Washington Regional Office has reviewed the letter containing the revised results of
the iron background groundwater investigation performed at the Frit Car facility in Bridgeton, NC
that Poly, Inc. submitted to our office on September 27, 2021. Our office has the following two
comments on the contents of the letter.

 We agree with the concept used to develop the proposed site-specific iron background
groundwater value presented in the letter; however, because the North Carolina
Groundwater Standards given in 15A NCAC 2L .0202(h) are total concentrations, any site-
specific groundwater background values should also be calculated as total concentrations.
We request that the proposed iron background value for the Frit Car facility be recalculated
using total iron concentrations.
 The letter states that Frit Car is evaluating modifications to the treatment system to reduce
effluent iron concentrations. We request that Frit Car provide our office with a proposed
schedule for the completion of this evaluation process and implementation of any system
modifications. We view the irrigation/pump and haul procedure proposed in the letter as
only a temporary measure and effluent quality must be addressed as part of a permanent
solution.
Please note, should there be interest in pursuing permanent modification of the existing
wastewater treatment system, such improvements shall not be constructed and
implemented without first securing necessary permit amendments. Likewise, should a
pathway forward to address performance concerns of the existing wastewater system
include termination of use, the Division can guide you through a permanent closure process
that would allow the permit to be rescinded.

DocuSign Envelope ID: 1DED49C5-51E9-4CEC-9C2A-21D906B7F13B

Michael Newby
October 29, 2021
Page 2 of 2

Once these two comments are addressed, our office will begin evaluating the groundwater
monitoring results from the Frit Car facility using the site-specific total iron background value.
Thank you for your continued cooperation. Should you have any questions concerning the
contents of this letter, please contact me at [phone].

Sincerely,

Dwight Randy Sipe P.G., Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ

cc: David Davis, PG – Poly, Inc. (electronic copy)
Tim Floyd, PG – Poly, Inc. (electronic copy)
Laserfiche

DocuSign Envelope ID: 1DED49C5-51E9-4CEC-9C2A-21D906B7F13B