NC0004308_Comments_20220829

CONCERNED CITIZENS OF WEST BADIN COMMUNITY August 29, 2022
Mr. Richard Rogers
Director, Division of Water Resources
Mr. Michael Scott
Director, Division of Waste Management
North Carolina Department of Environmental Quality
1646 Mail Service Center
Raleigh, NC 27699-1646
Via email to Mr. Richard Rogers, [e-mail], and Mr. Michael Scott,
[e-mail]
Re: Request for Public Hearing and Substantive Recommendations for Alcoa's
Badin Business Park Renewed NPDES Permit (NC0004308)
Dear Mr. Rogers and Mr. Scott:
The Concerned Citizens of West Badin Community (CCWBC) respectfully submits these
comments ahead of Alcoa's Badin Business Park's ("BBP") National Pollutant Discharge
Elimination System ("NPDES") permit renewal in October 2022 for the Alcoa Badin Works
facility.
The CCWBC formed in 2013. We are former workers for the Alcoa plant and West Badin
community members. The community of West Badin is most severely impacted by
contamination from the former Alcoa smelting facility. We urge the North Carolina Department
of Environmental Quality ("NC DEQ") to incorporate our recommendations into the renewed
permit. Additionally, we request a public hearing pursuant to the provisions of N.C. Gen. Stat. §
143-215.1(c)(3) and 15A N.C. Admin. Code 02H .0111(a)(1)-(2), as well as the Clean Water
Act.
Several members of the CCWBC were employed at the Alcoa facility for decades. Many had
jobs that required disposal of industrial waste. One CCWBC member, Richard Leak, recalls:
"We dumped spent potliner in the landfill in our neighborhood, we washed PCB lined buckets in
that water. So we know, without any testing, what kind of contamination exists in Badin Lake
and Little Mountain Creek." As an environmental justice community, the citizens of West Badin
deserve justice for the prolonged exposure to hazardous waste produced by Alcoa and their

subsidiaries since 1917. For years, we have seen illness and death in our community. There is no
reason Alcoa's BBP should have any lenience on their monitoring and pollutant discharges.
The CCWBC agrees with and has signed onto the letter submitted by the Duke Environmental
Law and Policy Clinic, dated August 6, 2022, concerning Alcoa's BBP NPDES permit. As the
most directly impacted community members of West Badin, we would like to take this
opportunity to underline our main concerns, as follows.
1. The new permit should require Alcoa's BBP to remove the source material for the
hazardous pollutants prior to submission of any permit applications in the future.
Particularly, Alcoa's BBP should be required to clean up the old trash dump and the
former plant site. In 1998, the United States Environmental Protection Agency ("US
EPA") banned untreated spent potliner from land disposal. The next permit term should
motivate Alcoa to remove its buried hazardous wastes from the site, reducing the ongoing
discharge of pollutants to Little Mountain Creek and Badin Lake.
2. The new permit should eliminate Outfalls 012 and 013 from discharging into the public
access and swimming area on Badin Lake.
3. The new permit should not allow Alcoa's BBP to divert discharge from Outfall 005 into
Little Mountain Creek as a solution to meet permit limits, nor should it allow the use of
any mixing zones.
4. The new permit should consider the new recreational space development near the old ball
field in increased monitoring and pollutant discharge limitations at Outfall 002.
5. As pollutant discharge from Alcoa's BPP is a matter of major public interest, we request
a public hearing before any decision is made with regard to the permit's renewal.
NC DEQ has issued permits for the Alcoa Badin Works facility that are too loose to
meaningfully protect the health of the surrounding communities. NC DEQ needs to protect the
surface waters, not create permits that allow compliance by manipulating the sampling system.
Implementing our recommendations listed in this letter as well as the August 6 letter from the
Duke Environmental Law and Policy Clinic would provide greater protection to Badin Lake and
Little Mountain Creek, as well as a step toward justice in the West Badin community for the
century of exposure to hazardous waste produced by Alcoa and their subsidiaries.
Given the documented negative impacts on water quality and public health, we urge NC DEQ to
seriously consider our recommendations when drafting Alcoa's BBP's renewed NPDES permit.
Thank you for your work and your service to North Carolina. We look forward to the public
hearing on this matter.
Sincerely,
The Concerned Citizens of West Badin Community