NC0020184_Pretreatment_EC_Letter_20221220

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ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
12/20/2022
Via Electronic Mail ([e-mail])
Ms. Stephanie Scheringer
Division Manager, Wastewater Treatment
Two Rivers Utilities
3000 Old Spencer Mountain Road
Gastonia, NC 28034
Subject: New Significant Industrial User (Pretreatment) Permit Applications
Two Rivers Utilities' Pretreatment Program
Long Creek WWTP, NPDES # NC0020184, Gaston County
Dear Ms. Scheringer:
The Division of Water Resources (DWR) is working to identify sources of PFAS to protect water
quality and drinking water supplies. Referring to both the EPA's Drinking Water Health Advisory
on PFAS and the 12/5/2022 EPA Memo titled Addressing PFAS Discharges in NPDES Permits
and Through the Pretreatment Program and Monitoring Programs, DWR expects that all local
pretreatment programs will conduct an emerging contaminant (EC) screening for new Significant
Industrial Users (SIU) permits, including for Piedmont Lithium's pending application. DWR
expects clear information regarding the presence of EC in new Sills' wastewater, sludge, and
solids. An approved local pretreatment program (Control Authority) has the primary responsibility
for reviewing SIU applications and issuing SIU permits. In DWR's oversight role of local
pretreatment programs, DWR expects Control Authorities to conduct the following EC screening
process for new SIU permits:
• Provide the attached "New SIU Permit Application PFAS Screening Questionnaire" in
SIU permit application materials to applicants;
• As required by 15A NCAC 02H .0917(a), continue to submit new SIU draft permits to
DWR thirty (30) days prior to the permit's effective date;
• When the Control Authority submits a draft SIU permit for a new industry to DWR for
review, include:
1 the completed "New SIU Permit Application PFAS Screening Questionnaire",
2. an EC Baseline Monitoring Plan prepared by the POTW based on the response
above,
3. a draft SIU permit that includes a requirement that the SIU implement the EC
Baseline Monitoring Plan.
AROLINA '
omm ep..orEMr nment o�.i
DE
NORTH C
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

DocuSign Envelope ID: 7F8195F8-2FA3-419B-AB8F-6FF5FE70025D
Federal and State pretreatment regulations require the Control Authority to effectively control and
document the discharge of wastewater from Significant/Categorical Industrial Users. It is the
Control Authority's responsibility to ensure that these objectives are consistently met.
If you have any questions or comments, please contact Keyes McGee at [phone] [email:
[e-mail]]. Thank you for your continued support of the Pretreatment Program.
Sincerely,
DocuSigned by:
. ,^
5FE7E4E08AEA49C...
For:
Michael J. Montebello
NPDES Branch Chief
Division of Water Resources
tkm\EC Screening Evaluation_TKM_12_20_22_TRU
Ec: David Shellenbarger, TRU
Michael Alexander, TRU
Cody Austin, TRU
Wes Bell, MRO
Stephanie Bolyard, PhD., CO
David Lambert, CO
Municipal Unit File
Central Files (Laserfische)
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

DocuSign Envelope ID: 7F8195F8-2FA3-419B-AB8F-6FF5FE70025D
NEW SIU PERMIT APPLICATION PFAS SCREENING QUESTIONNAIRE:
1. Do you use any material or products (directly or indirectly) in your operations that
contain fluorinated chemicals? If so, please identify what materials or products contain
fluorinated chemicals.
2. Will your facility formulate or create products (directly or indirectly) which contain
fluorinated chemicals? If so, please identify the specific fluorinated chemicals that may
be formulated or created.
3. Will your facility produce solid waste, liquid waste, wastewater effluent, or other waste
containing fluorinated chemicals? Please be as specific as possible to describe what
fluorinated chemicals may result in the facility's wastewater, solid waste, or sludge.
4. Are there processes or operations that use equipment, material, or components that
contain PFAS chemicals (e.g., surface coating, clean room applications, solvents,
lubricants, fittings, tubing, processing tools, packaging, facility infrastructure)? Could
these activities result in fluorinated chemicals being discharged as products, or by-
products (i.e., through leaching, chemical process, heat treatment, pressurization, etc.)?
5. List CAS numbers of all known or believed present fluorinated compounds from the
questions above. Please provide descriptions, quantities, and whether there are any
unknowns related to the above questions.
6. Are there other facilities or operations in the U.S. or internationally that are identical to or
may use processes similar to the project in North Carolina? If so, please provide facility
identification information and wastewater characterization including all PFAS
compounds?
7. Additionally, have any PFAS analytical results been collected with any analytical test
method similar to the following EPA Test Methods. Are any of the fluorinated
compounds listed in one of the following methods and can you provide us with data
resulting from these test methods?
• Methods 533 & 537.1 (drinking water)
• SW-846: Method 8327 (water)
• Draft Method 1633 (water, solids, tissue)
• "Total PFAS" Draft Method 1621 (wastewater)
DE
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