NC0003816_More Information (Requested)_20220422

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Timothy Lawrence
MCAS Cherry Point
4223 Access Road
PSC Box 8006
Cherry Point, NC 28533
NORTH CAROLINA
Environmental Quality
April 22, 2022
Subject: Request for Additional Information
NPDES Application NC0003816
Marine Corps Air Station - Cherry Point
Dear Sir:
The Division has reviewed your application for the subject permit and associated comments on the draft
permit (publicly noticed early 2020) by the Washington Regional office. To proceed with the review
process in a timely manner in accordance with N.C.G.S. 143-215.1 and 15A NCAC 2H.0105 the following
additional and/or revised information is required:
1. How often is the AFFF treatment system operating, if still operating? Please provide detailed
information (volume treated/discharged, PFAS sampling results of effluent, etc.) since January 2020.
If it is no longer operating, please indicate that operation of this unit has ceased, when it ceased
operation and if it will be used in the future.
2. Considering the existing AFFF system, and the industrial processes, DWR request one-time sampling
and analysis of PFAS compounds for outfalls 001, 002 and CO 1. The sampling and analysis specifically
must include the following:
• Perfluorooctanoic acid (PFOA)
• Perfluorooctane sulfonate (PFOS)
• 6:2 fluorotelomer sulfonic acid (6:2 FTSA)
• Perfluorohexanoic acid (PFHxA)
• Perfluoropentanoic acid (PFPeA)
• Perfluoroheptanoic acid (PFHpA)
The sampling should be done when any of the outfalls potentially affected by PFAS release (treated or
untreated; intermittent or constant, if any) for a single day's composite during normal working hours.
The objective is to capture the worst -case scenario in normal operation condition, and to isolate possible
PFAS sources. Since at present there is no EPA -approved analytical method for analyzing PFAS in
wastewaters (non -potable) that is approved for Clean Water Act compliance in accordance with 40 CFR
Part 136, the analytical method for the mentioned compounds shall be compliant with the requirements
set forth in the Department of Defense (DoD) Quality Systems Manual (QSM) for Environmental
Laboratories (DoD QSM 5.1 or later [Table B-15: Per- and Polyfluoroalkyl Substances (PFAS) Using
oep.m.m oremrnment Want -
DEQ3NORTH CAROLINA
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

Liquid Chromatography Tandem Mass] Spectrometry (LC/MS/MS) With Isotope Dilution or Internal
Standard Quantification in Matrices Other Than Drinking Water]). At a minimum, the laboratory
selected shall be able to analyze and quantify the PFAS listed above, at or below 10 ng/L (excluding
6:2 FTSA).
3. Please provide details about any other known and/or suspected waste streams containing PFAS
affecting any of the permitted outfalls. Please include details as what activities/plans the facility has in
place to contain, or control any possible PFAS-laden discharge?
To proceed within the review process in a timely manner and avoid delays a response is needed within 60
calendar days. If no response is received within 60 calendar days [per 15A NCAC 2H.0107(b)], the project
will be deactivated and withdrawn from our review process.
If you have any questions, please contact at 919-707-3704 or email at [e-mail].
Sincerely, DocuSigned by:
LI4ts
w VOW bttAA,
57287E56E81A40D...
Douglas Dowden
Environmental Program Supervisor II
Division of Water Resources/NCDENR
Ecopy: Amir Adaryani
Washington Reginal Office/Water Quality
Robert Bullock
Robert Tankard
D_E
NORTH CAROLINA
gaparhneM of Environment,/quay
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000