NC0004308_Response to Correspondence_20220826

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ROY COOPER 4 , ' i ?
Governor % *� iorr,o,
ELIZABETH S.BISER
Secretory
RICHARD E.ROGERS,JR. NORTH CAROLINA
Director Environmental Quality
August 26, 2022
Robyn L. Gross,Director
Asset Management Americas Badin Business Park LLC
Badin Business Park LLC
201 Isabella Street, Suite 500
Pittsburgh,PA 15212-5858
Subject: Badin Business Park (Formerly
Alcoa)—Response to Correspondence
Dated 5/27/22 and 6/2/22
Permit NC0004308
Badin Facility
Stanly County
Dear Ms. Gross:
North Carolina Department of Environmental Quality(NCDEQ)is in receipt of Badin Business Park
(BBP) correspondence dated May 27, 2022 and June 2, 2022. We understand and appreciate the
considerable time and effort BBP has expressed to investigate / identify potential sources of fluoride
and total cyanide discharge concentrations to Little Mountain Creek and efforts to date to address the
discharge of these pollutants. In response to BBP correspondence NCDWR provides the following:
RESPONSE TO BBP'S MAY 27, 2022 CORRESPONDENCE
1. Very Old Storm Sewer System: We appreciate the formal update referenced in line item 1
of the May 27th correspondence.NCDWQ requests a summary with attachments of all studies
performed by BBP that "demonstrate the majority of the fluoride entering the system is a
result of groundwater infiltrating the very old storm sewer systems." To date data submitted
by BBP in eDMR routinely reflects exceedances for the pollutants identified.Thus,under 15A
NCAC 02B .0404 reasonable potential still exist for water quality violations. Regardless of
identifying the source(s) of fluoride and total cyanide within Outfall 005 the contaminated
storm water can and should be treated using treatment technologies, thus reducing, if
not eliminating the potential of water quality violations from Outfall 005 in the future.
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
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2. Water Quality Standards and Table 1: NCDWR appreciates the formal update referenced
in line item 2 of the May 27th correspondence. Data provided does not demonstrate that
fluoride and total cyanide concentrations in Little Mountain Creek downstream of
BBP consistently meet water quality standards. Data provided by BBP via eDMR
routinely reflects exceedances for the pollutants identified. Under 15A NCAC 02B .0404
reasonable potential still exist for water quality violations of acute and chronic criteria. The
data in Table 1 provides flowrate in USG/min not based upon a sanctioned/calibrated USGS
data station for Little Mountain Creek.The data in Table 1 is not reflective of the data provided
by BBP in eDMR. Historical data from eDMR reflects a monthly average flow —0.14 mgd
with a maximum reported of 0.26 mgd. The data provided in Table 1 reflects significant
variability which indicates the need for thorough data collection from USGS (e.g. 5-10years).
The data is not comparable to low-flow values as it could have high inaccuracy, especially for
a stream with high probability of zero-low flow.Thus,the facility must meet end of pipe limits.
Also, the data provided does not include any correlation to fluoride, total cyanide
concentrations, nor chronic criteria, nor include rainfall totals by month. Thus, the value of
the data is of limited use and is unsubstantiated.
3. Site Remediation Activities: We appreciate the summary of recent activities at the site
provided and agree that these actions "have been unsuccessful at bringing Outfall 005 into
consistent compliance with the fluoride limit" as expressed in line item 3 of the May 27th
correspondence. Based upon the information provided BBP has been unable to identify the
source(s) of fluoride in Outfall 005 on site.
NCDEQ does appreciate the technical discussion of various fluoride wastewater treatment
studies "all with mixed success, specifically with sustainable treatment of fluoride in
wastewaters to low ppm levels on a continuous or interim basis"in the"White Paper"entitled
"Re: Fluoride Removal from Industrial Wastewaters—A Technology Review". The treatment
studies investigated had very high concentrations of Fluoride in an industrial effluent or
stormwater. BBP has a diluted mix of Groundwater and stormwater with a mean value of 2.1
mg/L for Fluoride (monthly average). BBP should perform pilot studies and literature reviews
relevant to Badin Business Park's situation where there are low concentrations (2-5 mg/L) of
Fluoride in stormwater/effluent. The EPA treatment database has reported effluent with low
Fluoride content to near zero after treatment. This office believes that all available
technologies have not been explored. BBP should explore relevant treatment alternatives
through literature review, facility funded pilot studies etc. for low concentrations of Fluoride
(2-5 mg/L, corresponding to treatment requirement level) in stormwater.The results from such efforts
should be translated to a plan,construction and installation of a satisfactory treatment system.
The plan should be submitted to NCDWR prior to construction and/or installation.
4. Mixing Zones: NCDEQ appreciates the "considerable time and effort that BBP has taken
to investigate the potential for a direct discharge to Little Mountain Creek"; however,
numerous factors play into mixing zones. Most importantly, current USGS data is required
to provide a 7Q10 determination. A single data point from a potentially abandoned USGS
or WWTP station from 20 plus years ago cannot be used for a 7Q10 determination especially
...1) North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street i 1611 Mail Service Center I Raleigh North Carolina 27699-1611
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919.707.9000
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when USGS has made a more recent determination.The effort to pursue this option was solely
at the discretion of BBP personnel. Further, under 15A NCAC 02B .0204 mixing zones will
not:
i. result in acute toxicity to aquatic life or prevent free passage of aquatic organisms;
ii. result in offensive conditions;
iu. produce undesirable aquatic life or result in a dominance of nuisance species;
iv. endanger the public health or welfare.
Mixing zones can only be established on a case by case basis at the discretion of the NCDEQ
per 15A NCAC 2B.0204.
5. In response to specific assertions and/or proposals made in the May 27th, 2022
correspondence the following responses are provided.
a. USGS Data Points: It is solely at the discretion of BBP to pursue, develop,propose and
possibly conduct a study to determine if a non-documented previous assessment of USGS
data can be validated.
b. Unsubstantiated Flow Data Points: NCDWR is not able to permit a discharge to Little
Mountain Creek utilizing unsubstantiated "previously determined 7Q10" data that is now
outdated.
c. Hydrograph-Controlled Release: The data provided in Attachment 1 of the May 27th
correspondence is irrelevant to this discussion. Each state and each waterbody within each
state has its own applicable rules, regulations, and requirements and thus data regarding
what has transpired in Florida, Georgia, Kentucky, Alabama, and South Carolina is not
applicable. NCDWR must adhere to the rules and regulations as established by the North
Carolina Environmental Management Commission and the EPA. Specifically, in regards
to the proposed Hydrograph-Controlled Release (HCR) by ftn Associates Ltd; this
approach is not an acceptable method within NC under 2B water quality regulations to
address the discharge volume of fluoride to Little Mountain Creek.. Additionally,
evaluation of the data submitted raised the following concerns:
i. Based upon the HCR proposal (Attachment 1 of the 5/27/22 BBP correspondence)
developed by ftn Associates Ltd it appears that BBP may have data that reveals
pollutant sources upstream of the site were caused by past site activities.NCDWR
request copies of all data that indicate existence of pollutants and/or
pollutant sources upstream of the site.
ii. The information supplied is not adequate;including,but not limited to the lack of
adequate USGS approved flow data. USGS flow stream data is typically based
upon an extended data set and thus the proposal "to establish a flow monitoring
station in Little Mountain Creek in order to update the historic 7Q10
determination"will not timely address current discharge exceedances.
D—� 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
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ii.i. Based upon the limited information supplied the facilities that operate under a
HCR scenario are the exception rather than the rule. They are generally used
for DO concerns and most states do not allow HCR's to address exceedances for
toxicants. In addition, the scenarios provided are not similar to the conditions at
BBP and Little Mountain Creek.
iv. The proposal indicates "the daily maximum concentration limits would be equal
to the criteria to protect from acute toxicity (24 mg/L fluoride and 46.6 µg/L
cyanide)". Any proposal should address all chronic and acute water quality
standards.
6. Treatment Options: We understand that BBP has evaluated various treatment options to
address pollutant discharges off site involving fluoride at their sites worldwide. NCDEQ
appreciates the detailed technical information provided in Attachment 2, specifically within
the "White Paper" entitled "Re: Fluoride Removal from Industrial Wastewaters — A
Technology Review".
a) As stated previously BBP should fully evaluate all options to address water quality
violations, including options to treat storm water prior to discharge and continue efforts
to find and eliminate all pollutant sources (e.g. some form of site remediation activities). As
discussed with NCDEQ Assistant Secretary for the Environment, Sushma Masemore, at
the meeting in March 2022, BBP should explore and present to DWR available
technologies relevant to the BBP situation to address water quality exceedances. This
office believes that all available technologies have not been explored and BBP shall assess,
through literature reviews and facility funded pilot studies,treatment technologies for low
concentrations of Fluoride (2-5 mg/L) in stormwater/effluent. The results from such
efforts should be translated to construction and installation of a satisfactory treatment
system. Again, we appreciate the time and effort put into developing this white paper;
however, recurring water quality violations must be addressed.
RESPONSE TO BBP'S JUNE 2, 2022 COMMUNICATIONS
In response to BBP recent communication dated 6/2/2022 to Director Richard Rogers regarding
"support the hydrologic data collection for the period of July 1, 2022 through June 30, 2023" there is
insufficient detail within the letter to formulate a complete response. The request suggests that the
study is designed to capture only 1 year of flow data.Modeling adhering to USGS and EPA standards
typically requires an extended data set. Thus, the proposal is not comprehensive enough to support a
new critical low-flow determination.
1 ALL SITE OPERATIONS AND ACTIVITIES COVERED IN PERMIT RENEWAL
Also based upon information provided and observations made BBP is now leasing space to other
businesses. Long-term all operations and facilities on the site must be covered (identified) and comply
with the Permit. Thus, the Permit renewal must include and address all site activities,including those
of tenants.
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CONCLUSION
Please note that we received BBP's responses to DWR's NPDES Permitting Unit's letter requesting
additional information/clarifications dated May 17, 2022. Staff are reviewing those responses and
drafting a renewal permit. In the meantime,we look forward to receiving information from BBP on
a proposed treatment option that can be installed at Outfall 005 in order to eliminate any future
violations.
To avoid delays in the permitting process please provide a response within sixty (60) days of
the date of this correspondence.
If you have any questions please contact Amir Adaryani, Ph.D. at: 919-707-3704 or via email at:
[e-mail] or Doug Dowden at: 919-707-3605 or via email at:
doug.dowdenna,ncdenr.gov.
Sincerely,
(—DocuSigned by:
VOL+S U) VOWIVA
boiifPige9t®4den
Environmental Program Supervisor II
Industrial NPDES Permitting Unit
cc: Central Files
Central Office: Assistant Secretary for the Environment Sushma Masemore,Director Richard
Rogers,Deputy Director Julie Grzyb,Asher Spiller Attorney at Law,WQPS Manager Michael
Montebello, PIO Anna Gurney, Environmental Engineer I Amir Adaryani Ph.D. via email
Morrisville Regional Office—Corey Basinger via email
Michael Scott,NCDEQ via email;Joy Hicks, NCDEQ via email
Jason Mibroda,Alcoa Corp. via email—[e-mail]
Cameron Henley,Moore&VanAllen via email: [e-mail]
North Carolina Department ofEnvironmenta cQuality I Division o£Water Resources
. ) 512 North Salisbury Street 11611 Mail Service Center I Raleigh North Carolina 27699-1611
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