NC0090000_Public Hearing Comments_20230317

Denard, Derek
From: Kaitlin Abernathy <[e-mail]>
Sent: Thursday, March 16, 2023 12:12 PM
To: SVC_DEQ.publiccomments
Subject: [External] permit#NC0090000
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Dear Wren Thedford,
I am writing to request the NC Department of Environmental Quality significantly strengthen
draft NPDES permit #NC0090000 to:
1) Add technology based discharged limits to the wastewater permit. Particularly for the known
carcinogen benzene found in gasoline. The current effluent limitation in the draft permit is five
times higher than the water quality standard for benzene.
2) Reduce the daily flow limit. The proposed flow limit of 500,000 gallons per day is almost 20
percent of the natural flow of the receiving stream, the North Prong of Clark Creek.
3) Strengthen water quality based limits.
4) Account for background levels of contamination when developing permit limits.
5) Require monitoring, disclosure and treatment of PFAS.
6) Require instream monitoring for hazardous constituents in gasoline downstream from the
discharge outfall.
If these improvements are not made, the permit should not be issued.
Thank you for your consideration.

Denard, Derek
From: Blue Belle <[e-mail]>
Sent: Thursday, March 16, 2023 5:24 PM
To: SVC_DEQ.publiccomments
Subject: [External] Release of groundwater at Colonial Pipeline Site
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What does this involve?
Why weren't homeowners near this area notified of this meeting?
I happened upon this information while looking for something else.
What do the people in the Pee Dee Basin think about this?
How clean is this water after treatment?
What is the treatment process?
i

Denard, Derek
From: Marc Bellet <[e-mail]>
Sent: Tuesday, March 14, 2023 11:07 AM
To: SVC_DEQ.publiccomments
Subject: [External] Colonial Pipeline - Wastewater Treatment Permit
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Based on my review of the Town of Huntersville Zoning Ordinance, the proposed use of the property as a
wastewater treatment plant is not an approved use. This matter should be addressed at the Public Hearing.
Thank you.
i

Denard, Derek
From: Nicole Bokhart <[e-mail]>
Sent: Thursday, March 16, 2023 7:51 PM
To: SVC_DEQ.publiccomments
Cc: Nick Bokhart
Subject: [External] Colonial Pipeline
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To Whom It May Concern:
My family and I have been Huntersville residents for about nine years now. We chose to move to Huntersville from a
much larger metropolitan area because we valued our health and were in search of a less populated area, with less
negative environmental impacts. My family and I have chosen to make significant life choices to lessen our
environmental footprint.
We were deeply saddened when we learned of the Colonial Pipeline gas leak. Later, we were very angry about the
mishandling of the event and the misinformation and/or gross miscalculations that Colonial Pipeline provided in the
days,weeks, and months after the spill was discovered. We do not have confidence that Colonial Pipeline will act
responsibly in the future based on how the initial spill was handled and communicated.
North Carolina should not grant Colonial Pipeline a wastewater discharge permit. We don't believe that they can be
trusted with the care of our community. What happens if the remediation process fails and unclean water is discharged
for any period of time?They had no awareness of the initial leak until a community member discovered it. Will they
have awareness in the event of a failure with the water treatment process? It could be devastating.
According to a WCNC article,this was the largest onshore oil spill in the nation and it happened just down the road from
our home. Please do not take any chances that could lead to additional environmental hardships.
Thank you for taking the time to review this comment. Please take the necessary steps to safeguard our town from
further environmental impact from Colonial Pipeline.
Best regards,
Nicholas and Nicole Bokhart
i

Denard, Derek
From: Rey Brown <[e-mail]>
Sent: Friday, March 17, 2023 11:12 AM
To: SVC_DEQ.publiccomments
Subject: [External] Colonial Pipeline
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To whom it may concern,
I am writing this email to place my opinion into public record regarding the permit request from
Colonial Pipeline to add a treatment center to their spill site, clean the fuel from the ground and
then deposit the remaining water into our creek system at the North Prong of Clark Creek. After
looking at the permit request, I am very concerned that Colonial Pipeline will not meet current
state standards of water quality for chemicals allowed in our drinking water. Also, I am
concerned that the amount of water and particulate will add a significant volume to the creek
system. We have not been given an explanation of the size and scope of the treatment building
on site and what sound and eye sore issues may arise. At a minimum the permit should not be
granted without the following improvements to the permit requirements
1. Add technology based discharged limits to the wastewater permit. Particularly for
the known carcinogen benzene found in gasoline. The current effluent limitation in the draft is 5
times higher than the water quality standard for benzene.
2. Reduce the daily flow limit. The proposed flow limit of 500,000 gallons per day is
almost 20 percent of the natural flow of the receiving stream, the North Prong of Clark Creek.
3. Strengthen water quality based limits
4. Account for background levels of contamination when developing permit limits.
5. Require monitoring, disclosure and treatment of PFAS
6. Require instream monitoring for hazardous constituents in gasoline downstream
from the discharge outfall.
I also feel there should be independent company that over sees the Colonial Pipeline through
the process to make sure they are meeting all proper procedure and to do all the
testing. Colonial Pipeline should not be allowed to conduct the monitoring. We have seen
failures from their ability to monitor the pipeline itself leading to this massive spill.
Thank you,
Fred Brown
Thank you,
Rey Brown
[e-mail]
i

Denard, Derek
From: Kim Burton <hrdchrgr331 @aol.com>
Sent: Friday, March 17, 2023 10:40 AM
To: SVC_DEQ.publiccomments
Subject: [External] Colonial Pipeline
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I am writing to place my opinion into public record regarding the permit request from Colonial Pipeline to add a treatment
center to their spill site, clean the fuel from the ground and then deposit the remaining water into our creek system at the
North Prong of Clark Creek. After looking at the permit request, I am very concerned that the Colonial Pipeline will not
meet current state standards of water quality for chemicals allowed in our drinking water. Also, I am concerned that the
amount of water and particulate will add a significant volume to the creek system. We have not been given an explanation
of the size and scope of the treatment building on site and what sound and eye sore issues may arise. At a minimum, the
permit should not be granted without the following improvements to the permit requirements.
1. Add technology based discharged limits to the wastewater permit. Particularly for the known carcinogen benzene
found in gasoline. The current effluent limitation in the draft is 5 times higher than the water quality standard for benzene.
2. Reduce the daily flow limit. The proposed flow limit of 500,000 gallons per day is almost 20 percent of the natural
flow of the receiving stream, the North Prong of Clark Creek.
3. Strengthen water quality based limits
4. Account for background levels of contamination when developing permit limits.
5. Require monitoring, disclosure and treatment of PFAS
6 Require instream monitoring for hazardous constituents in gasoline downstream from the discharge outfall.
I also feel there should be an independent company that oversees the Colonial Pipeline through this process to make sure
they are meeting all proper procedures and to do all the testing. Colonial Pipeline should not be allowed to conduct the
monitoring. We have seen failures from their ability to monitor the pipeline itself leading to this massive spill.
Kimberle Burton
15555 Huntersville Concord Road
Huntersville, NC 28078
1

From: Bret Baronak
To: SVC DEO.publiccomments
Cc: Bart Landless
Subject: [External]Colonial Pipeline Wastewater Permit-Mecklenburg County, NC
Date: Friday,March 17,2023 3:35:42 PM
Attachments: 3 17 23 CLC CTT Colonial Pipeline Permit Comment Letter.pdf
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Mr. Thredford,
Please find the attached comments from the Catawba Lands Conservancy and Carolina Thread Trail
concerning the Colonial Pipeline Wastewater Permit.
With gratitude,
Bret Baronak
Bret Baronak
Carolina Thread Trail, Director
Catawba Lands Conservancy I Carolina Thread Trail
2400 Park Road,Suite 1
Charlotte, NC 28203
T:704.342.3330 ext. 2216
Connect with the Conservancv:
facebook I instagram
Connect with the Thread Trail:

CATAWBA
CONSERVANCYLANDS • TRAIL
March 17, 2023
Wren Thredford, Wastewater Permitting
Attn: Colonial Pipeline Permit
NC Division of Water Resources
677 Mail Service Center
Raleigh, N.C., 27699-1617
Transmitted via email to:publiccomments®ncdenr.gov
Dear Ms. Thredford:
Catawba Lands Conservancy(CLC)and Carolina Thread Trail(CTT) are widely recognized in the
region for addressing the needs to protect, preserve and manage a balance between the natural and
built environments. The mission of CLC and CTT is "Saving Land and Connecting Lives to Nature."
There are currently 550 miles of trails and blueways (paddling trails) open for the public to enjoy
and over 77,000 acres conserved. The ultimate vision is a network consisting of 1,600 miles,
linking 85,000 acres of protect lands. In a rapidly growing region such as the Charlotte
metropolitan area, this does not come without challenges.
The Colonial Pipeline permit request to address issues with the spill, including the development of
a water treatment facility, is not without concern as it relates to our organization's mission. The
severity of the spill requires significant measures,and it may take many decades to remediate the
damage caused.
Colonial Pipeline is proposing to discharge up to 500,000 gallons per day of treated groundwater
into the North Prong Clarke Creek under a draft NPDES Permit NC0090000. CLC and CTT are
concerned that the levels of contaminants allowed to discharge into the North Prong Clarke Creek
will undermine our conservation efforts in the Clarke Creek watershed and public recreation work
along the Rocky River, into which Clarke Creek flows. As proposed, the permit would allow Colonial
Pipeline to discharge contaminated effluent that exceeds standards set forth in 15A NCAC 02B for
benzene(5x higher), toluene(1.3x higher), and vinyl chloride (5x higher).
Since 2000, CLC has worked to conserve 780 acres along Ramah Creek to protect the Clarke Creek
watershed and habitat for the Carolina Darter(Etheostoma collis). Clarke Creek is a 303(d)listed
impaired stream, which provides habitat for Carolina Darter, identified as a Species of Concern by
the NC Natural Heritage Program and a Species of Greatest Conservation Need by the NC Wildlife
Resources Commission. CLC and CTT are concerned that, if the permit is approved as submitted,
the elevated levels of contaminants may negatively impact the aquatic habitat of Clarke Creek and
pose a risk to the health of aquatic organisms,including the Carolina Darter. These impacts will
undermine the protection of the Clarke Creek watershed.
Clarke Creek is listed by NCDEQ as impaired due to a Fair, Poor or Severe Bioclassification,and
actions that may further exacerbate the degradation of the creek should be avoided. The proposed
discharge rate will increase flowrates by 20% over existing base flow for the North Prong of Clarke
Creek. It is not known what impacts the increased flow may have on existing sediment loads in the
channel, erosion potential along the banks of the North Prong Clarke Creek, or aquatic life.
2400 PARK ROAD, SUITE 1 • CHARLOTTE, NC 28203 • 704.342.3330
CATAWBALANDS.ORG CAROLINATHREADTRAIL.ORG

CTT's current and planned trail network often follows the region's waterways. As proposed, the
processed water release directly into Clarke Creek also stands to undermine the experience for trail
users in the area. The benefits of providing a trail network are numerous and well-established:
outdoor recreation, physical and mental wellness, transportation choice, social equity and
protecting the integrity of our natural environment. Quality waterways are important for realizing
these benefits and for the trail experience.
The Rocky River is a very active corridor for both current and planned trail. The Rocky River
blueway(designated paddling trail) covers nearly 70 miles from Cabarrus County to Anson
County. There are currently twelve public river access points along the blueway providing access to
an outstanding paddling experience. The request to release treated water in the Rocky River basin,
with benzene levels in excess of the acceptable rate of this pollutant, will do much to compromise
favorability for use among the growing number of paddling enthusiasts in the region and could
threaten the economic development benefits to the communities along the River.
In addition to its popularity as a blue way, the Rocky River is also a significant corridor for trail
development. There currently eight miles of trail and greenway along the River, with many more
sections poised to open in the next five to ten years. This section of the Rocky River in Concord, is
part of the Carolina Thread Trail's "North-South Spine,"the highest priority trail corridor in the T 5-
county region. It will span for 740 miles from Great Fall, South Carolina, to Statesville, North
Carolina, when complete. An enjoyable trail experience is dependent on the integrity of the natural
environment and the safety of trail users.
CLC and CTT would request that NCDEQ require Colonial Pipeline to meet the 2B standards for
surface water discharges to protect human health from carcinogens through the consumption of
fish and/or to protect water for recreational use. Additionally, the organization would request
regular surveys of Clarke Creek and the North Prong Clarke Creek to monitor the population of
Carolina Darter to determine if the effluent discharge is having an impact on this imperiled species.
C _ r
C. Barton Landess
Executive Director
Catawba Lands Conservancy and Carolina Thread Trail

NCDEQ Public Hearing, Huntersville, March 16, 2023
Comments of Meg Blackwood, Colonial Pipeline
Hello, my name is Meg Blackwood and I'm Director of Right of Way, Land Management, and
Public Affairs at Colonial Pipeline Company. On behalf of Colonial, I'd like to thank you for
providing us an opportunity to briefly discuss our permit application and how it relates to the
important work that remains to be done at the Huntersville site.
As you're aware from our permit application and from our regular and ongoing discussions with
NCDEQ staff, Colonial has installed a hydraulic control well system that will allow us to speed
up the recovery efforts and limit further migration of the product underground. The NPDES
permit will allow us to operate this system.
This system, which is critical to ongoing recovery and remediation, will bring hundreds of gallons
of contact water to the surface per minute for treatment and discharge of treated water back into
the environment within the local watershed. Our proposal allows us to safely and efficiently
manage the water, in the most environmentally responsible manner with the least impact on our
neighbors.
To accomplish these activities, we propose a compact treatment system that can be trucked in
and assembled in packages that will be located on our property, set back from the road, and
housed to limit visual and noise impacts.
To be clear, this will not be a large wastewater treatment plant like those operated by local
governments.
As is clear from our draft permit, this system will treat water so that it meets or exceeds all
requirements set forth by the state. Continuous testing of the water prior to discharge to ensure
effective treatment will be stringent, with results reported directly and promptly to NCDEQ.
We believe returning treated water back to the local watershed, instead of trucking it away for
treatment, is the best option for the health of the community. It also avoids the need to bring
upwards of 100 trucks to the site daily if we were to transport it away for treatment elsewhere,
which would raise such safety concerns and be so disruptive that we do not consider that a
viable option.
Colonial has had a presence in the Mecklenburg County area, and Huntersville specifically, for
more than 50 years and we are committed to this community. This includes a local team
member whose sole responsibility is management of the site. Our top priority is protecting the
wellbeing of everyone touched by our operations, including our own team members and those
living or working nearby.
We are committed to being here as long it takes to remediate this site, and to earning back the
trust of the community.
Thank you again for your time and consideration.

Good Evening. My name is Nancy Neely and my address is 11130 Johnson Davis Rd in
Huntersville. Thank you for this opportunity to speak. I'll be brief.
I'm a long time resident of Huntersville, and I love where I live. I'm not an expert on gasoline
spills, and I'm not an expert on how to clean them up. I am a concerned citizen. I'm here to
amplify the voices of others that know much more than I do.
And I'm here to tell a story. Most of you have heard it, but I'm amazed at how many people
here in Mecklenburg County have never heard it.
On August 1V, 2020, two teenagers, Owen Fehr and Walker Sell, were cruising along the
Colonial Pipeline right-of-way in a 2 seat all-terrain vehicle when they discovered the spill.
Walker Sell was quoted as saying "It was just an overwhelming smell and then you almost
couldn't breathe Fortunately, they decided to call 911.
Colonial initially estimated the spill at about 60,000 gallons. As we know, that was a very poor
estimate.
And here we are nearly 3 years later. Without a doubt, the Colonial Pipeline gasoline spill of
2020 in Huntersville NC is the largest spill in NC
and it's arguably the largest spill to date in the continental US. Three things about this concern
me the most: 1) Colonial was not aware that the pipeline had a problem
and
2) Very few people in Mecklenburg county have heard of this and
3) Pipeline spills are not unusual. If you're curious how frequent, google it.
;Aowever, we're here tonight to talk about the clean up. And I'm here to urge DEQ to use their
power to ensure that Colonial does the right thing-for us
and for the environment, and not just for their shareholders and bottom line. Left to their own
devices, I'm not confident that will happen. According to the Yadkin Riverkeeper, DEQ needs to
strengthen the proposed permit to protect public health and water quality, specifically to
further limit Benzene levels and also to test for PFAs. DEQ please strengthen the proposed
permit!
Thank you for your kind attention.

Denard, Derek
From: Lorna Conway <[e-mail]>
Sent: Friday, March 17, 2023 10:57 AM
To: SVC_DEQ.publiccomments
Subject: [External] Colonial pipeline
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I am writing this email to place my opinion into public record regarding the permit request from Colonial
Pipeline to add a treatment center to their spill site, clean the fuel from the ground and then deposit the
remaining water into our creek system at the North Prong of Clark Creek. After looking at the permit request, I
am very concerned that Colonial Pipeline will not meet current state standards of water quality for chemicals
allowed in our drinking water. Also, I am concerned that the amount of water and particulate will add a
significant volume to the creek system. We have not been given an explanation of the size and scope of the
treatment building on site and what sound and eye sore issues may arise. At a minimum the permit should
not be granted without the following improvements to the permit requirements
1. Add technology based discharged limits to the wastewater permit. Particularly for the known
carcinogen benzene found in gasoline. The current effluent limitation in the draft is 5 times higher than the
water quality standard for benzene.
2. Reduce the daily flow limit. The proposed flow limit of 500,000 gallons per day is almost 20
percent of the natural flow of the receiving stream, the North Prong of Clark Creek.
3. Strengthen water quality based limits
4. Account for background levels of contamination when developing permit limits.
5. Require monitoring, disclosure and treatment of PFAS
6. Require instream monitoring for hazardous constituents in gasoline downstream from the
discharge outfall.
I also feel there should be independent company that over sees the Colonial Pipeline through the process to
make sure they are meeting all proper procedure and to do all the testing. Colonial Pipeline should not be
allowed to conduct the monitoring. We have seen failures from their ability to monitor the pipeline itself leading
to this massive spill.
Lorna Conway
Huntersville concord rd
Huntersville nc
Sent from my Whone
i

Denard, Derek
From: Kelli Dyk <[e-mail]>
Sent: Friday, March 17, 2023 2:37 PM
To: SVC_DEQ.publiccomments
Subject: [External] Colonial Pipeline concerns
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To whom it may concern:
I am writing this email to place my opinion into public record regarding the permit request from Colonial Pipeline to add
a treatment center to their spill site, clean the fuel from the ground and then deposit the remaining water into our creek
system at the North Prong of Clark Creek.After looking at the permit request, I am very concerned that Colonial Pipeline
will not meet current state standards of water quality for chemicals allowed in our drinking water.Also, I am concerned
that the amount of water and particulate will add a significant volume to the creek system. We have not been given an
explanation of the size and scope of the treatment building on site and what sound and eye sore issues may arise. At a
minimum the permit should not be granted without the following improvements to the permit requirements...
1.Add technology based discharged limits to the wastewater permit. Particularly for the known carcinogen benzene
found in gasoline.The current effluent limitation in the draft is 5 times higher than the water quality standard for
benzene.
2. Reduce the daily flow limit.The proposed flow limit of 500,000 gallons per day is almost 20 percent of the natural flow
of the receiving stream,the North Prong of Clark Creek.
3. Strengthen water quality based limits 4. Account for background levels of contamination when developing permit
limits.
5. Require monitoring, disclosure and treatment of PFAS 6. Require instream monitoring for hazardous constituents in
gasoline downstream from the discharge outfall.
I also feel there should be independent company that over sees the Colonial Pipeline through the process to make sure
they are meeting all proper procedure and to do all the testing. Colonial Pipeline should not be allowed to conduct the
monitoring. We have seen failures from their ability to monitor the pipeline itself leading to this massive spill.
Sincerely,
Kelli Dyk
Resident of the nearby Mirabella neighborhood
i

Denard, Derek
From: Chris Garth <[e-mail]>
Sent: Friday, March 17, 2023 3:37 PM
To: SVC_DEQ.publiccomments
Cc: [e-mail]
Subject: [External] Colonial Pipeline - Draft Permit Comments
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My comments following the public hearing last night:
Thanks to the NC DEQ and others that attended the meeting last night in Huntersville. I found that the presentations
and comments were helpful and intending to be positive with the exception of the lady from Cabarrus County that
thought the meeting attendees were, as a whole, "un-American complainers." I simply don't agree with her. Otherwise,
my comments and questions:
The draft permit limits include:
Benzene: 274 µg/L= 274 parts per billion of 0.274 parts per million.
Xylene(s)total: 858 µg/L= 858 parts per billion of 0.858 parts per million.
It is virtually impossible to understand these values. Questions:
• What are the results of previous studies that looked at the impact to amphibian populations in streams,
earthworms in the ground, etc.?
• What are the appropriate EPA defined Benzene (and Xylene) test methods?
• Is it practical to monitor the discharge chemistries more frequently than identified in the draft permit? I find
EPA methods 624.1 (wastewater) or 8260 (for surface water) but am not certain what is being required in
the draft permit.
I do not know what Best Available Technologies have been considered for the remediation? In addition to the activated
charcoal (carbon)filters, thermal oxidizers, etc., microbes that digest VOCs including benzene should be considered
when evaluating treatment methods. This type of remediation is used in the chemical industry and should be
considered here. "Bug' management is tricky but if the input flow characteristics are consistent, the process could be
stable and potentially effective. Are the flow volumes simply too high?
Globally,there must have been other gasoline releases to ground and surface waters from refineries, petroleum tank
farms, etc. that have been addressed with remediation.
• How does the Colonial spill compare to some of these?
• Are there any lessons learned that can support our response to this issue today?
Seasonal variation in stream volumes, caused by dry and rainy weather patterns, will affect the dilution of the discharge,
and may be a factor to consider.
• What percent of the flow in the North Prong Clark Creek, Clarke Creek and Rocky River will be the discharge
as opposed to normal flow from direct surface runoff.
• How will this vary during drought and rainy periods?
• Will it be feasible to reduce discharge limits and volumes during drought conditions?
i

• If not, what might be the impact to the ecology of the affected surface waters—especially in North Prong
Clark Creek?
I am concerned with the draft permit defined monitoring processes including testing criteria and frequencies. In my
opinion, discharge should be from an (admittedly) large tank and follow testing for benzene and other organics per
tightened discharge limits. Also, I believe that monthly sampling and testing of the organics is not enough. Continuous,
non-monitored discharge during a month could allow "slugs" of outlier(high) concentration to be discharged without
any community awareness. Slugs such as these could result from events such as the blasting that Libby(lives
approximately half mile from pipeline) mentioned during her comments.
Strictly as a point of fact, the spilled gasoline was not owned by Colonial Pipeline but by many stakeholders that
produced or purchased the fuel for distribution. I don't think that we know how long the pipeline was leaking but
multiple products (gasoline, diesel, home heating oil,jet fuel)flow through the pipeline 24/7 per a schedule managed by
Colonial. I understand that Colonial Pipeline is the responsible party in this case but other stakeholders are involved
indirectly and have very deep pockets. Similar to the issues related to coal ash,this spill and its consequences are an
externalized cost to our community due to our societies continued consumption of fossil fuels. A stronger financial
penalty(greater than $4.75 million) in addition to more stringent permit requirements should be considered. A
significant portion of the$4.75 (or more) million should be directed to increasing public awareness of issues related to
the continuing consumption of petroleum fuels. This should certainly include explanation of the positive impacts and
benefits of car-pooling, remote work, more efficient vehicles, etc. as well as all of the negative environmental impacts
such as air quality, climate change, resource consumption, etc.
Thank you.
Chris Garth
Huntersville, NC 28078
z

Denard, Derek
From: Stacy Hensley <[e-mail]>
Sent: Thursday, March 16, 2023 9:21 AM
To: SVC_DEQ.publiccomments
Subject: [External] Colonial Pipeline NPDES permit#NC0090000
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Dear Wren Thedford,
I am writing to request the NC Department of Environmental Quality significantly strengthen
draft NPDES permit #NC0090000 to:
1) Add technology based discharged limits to the wastewater permit. Particularly for the known
carcinogen benzene found in gasoline. The current effluent limitation in the draft permit is five
times higher than the water quality standard for benzene.
2) Reduce the daily flow limit. The proposed flow limit of 500,000 gallons per day is almost 20
percent of the natural flow of the receiving stream, the North Prong of Clark Creek.
3) Strengthen water quality based limits.
4) Account for background levels of contamination when developing permit limits.
5) Require monitoring, disclosure and treatment of PFAS.
6) Require instream monitoring for hazardous constituents in gasoline downstream from the
discharge outfall.
If these improvements are not made, the permit should not be issued.
Thank you for your consideration.
Stacy Hensley
15133 Ewart Road
Huntersville, NC 28078
704-904-6544
i

Denard, Derek
From: Patrick lannuccilli <[e-mail]>
Sent: Thursday, March 16, 2023 8:45 PM
To: SVC_DEQ.publiccomments
Subject: [External] Colonial Pipeline
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Dear DEQ,
I attended the public hearing on 3/16/22 to gather information on the Colonial Pipeline
discharge plan.
hope when all is said and done the land where the spill occurred be returned to the state at
which it was before the spill.
A biological assessment must be made of the impact to the plants and animals in the area to
ensure that the least harm will be done to the local environment.
I am also standing in solidarity with the Yadkin Riverkeeper proposal to request the NC
Department of Environmental Quality significantly strengthen draft NPDES permit #NC0090000
to:
1) Add technology based discharged limits to the wastewater permit. Particularly for the known
carcinogen benzene found in gasoline. The current effluent limitation in the draft permit is five
times higher than the water quality standard for benzene.
2) Reduce the daily flow limit. The proposed flow limit of 500,000 gallons per day is almost 20
percent of the natural flow of the receiving stream, the North Prong of Clark Creek.
3) Strengthen water quality based limits.
4) Account for background levels of contamination when developing permit limits.
5) Require monitoring, disclosure and treatment of PFAS.
6) Require instream monitoring for hazardous constituents in gasoline downstream from the
discharge outfall.
If these improvements are not made, the permit should not be issued.
Thank you for your consideration.

Sincerely,
Patrick lannuccilli
10321 Passau Path Dr
Huntersville NC 28078
704-966-9671
z

Denard, Derek
From: Eliana Janssen <[e-mail]>
Sent: Friday, March 17, 2023 10:37 AM
To: SVC_DEQ.publiccomments
Subject: [External] Colonial Pipeline
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To whom it may concern,
I am writing this email to place my opinion into public record regarding the permit request from
Colonial Pipeline to add a treatment center to their spill site, clean the fuel from the ground and
then deposit the remaining water into our creek system at the North Prong of Clark Creek. After
looking at the permit request, I am very concerned that Colonial Pipeline will not meet current
state standards of water quality for chemicals allowed in our drinking water. Also, I am
concerned that the amount of water and particulate will add a significant volume to the creek
system. We have not been given an explanation of the size and scope of the treatment building
on site and what sound and eye sore issues may arise. At a minimum the permit should not be
granted without the following improvements to the permit requirements
1. Add technology based discharged limits to the wastewater permit. Particularly for
the known carcinogen benzene found in gasoline. The current effluent limitation in the draft is 5
times higher than the water quality standard for benzene.
2. Reduce the daily flow limit. The proposed flow limit of 500,000 gallons per day is
almost 20 percent of the natural flow of the receiving stream, the North Prong of Clark Creek.
3. Strengthen water quality based limits
4. Account for background levels of contamination when developing permit limits.
5. Require monitoring, disclosure and treatment of PFAS
6. Require instream monitoring for hazardous constituents in gasoline downstream
from the discharge outfall.
I also feel there should be independent company that over sees the Colonial Pipeline through
the process to make sure they are meeting all proper procedure and to do all the
testing. Colonial Pipeline should not be allowed to conduct the monitoring. We have seen
failures from their ability to monitor the pipeline itself leading to this massive spill.
Thank you,
Eliana Janssen
Eliana Janssen
1

Denard, Derek
From: phx_jjk <[e-mail]>
Sent: Friday, March 17, 2023 4:35 PM
To: SVC_DEQ.publiccomments
Subject: [External] Colonial Pipeline NPDES Permit#NC0090000
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I would like the record to reflect that I am for a NPDES solution and NOT for running trucks up and down our
roads 24/7. Not only for the added cost, but the added traffic, road damage, air and noise pollution.
Thank you
John Kosir
13223 Union Square Dr
Huntersville, NC
480-206-7233
i

Denard, Derek
From: Colleen McDaniel <[e-mail]>
Sent: Thursday, March 16, 2023 8:42 AM
To: SVC_DEQ.publiccomments
Subject: [External] NPDES draft permit for#NC0090000
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To: [e-mail]
From: Colleen McDaniel
Dear Wren Thedford,
I am reaching out today to request that NCDEQ make the NCDES permit draft#NC0090000 much stronger
After researching the topics related to gasoline contamination, I agree with the requests that the Yadkin River
Keepers suggest as stated below:
1) Add technology based discharged limits to the wastewater permit. Particularly for the known carcinogen
benzene found in gasoline. The current effluent limitation in the draft permit is five times higher than the
water quality standard for benzene.
2) Reduce the daily flow limit. The proposed flow limit of 500,000 gallons per day is almost 20 percent of the
natural flow of the receiving stream, the North Prong of Clark Creek.
3) Strengthen water quality based limits.
4) Account for background levels of contamination when developing permit limits.
5) Require monitoring, disclosure and treatment of PFAS.
6) Require instream monitoring for hazardous constituents in gasoline downstream from the discharge outfall.
If these improvements are not made, the permit should not be issued.
Thank you for your consideration.
Colleen McDaniel
Owner/Designer of The Inspired Garden, Inc.
colleen(a inspiredgarden.com
252-561-6122
0
i

Connection to Charlotte Water is prohibited by a sewer use ordinance. Pumping and
hauling the treated water would require approximately 115 trucks per day that will be
operating 24 hours a day in a residential area. The other alternatives were deemed
technically infeasible due to engineering restrictions, lack of available land, and
protection of groundwater. Thus, the identified best alternative would be a discharge
to surface waters.
The groundwater remediation system includes a recovery well system, an oil/water
separator with skimmed storage tank for recovered oil, a bag filter bank, an air
stripper unit, a thermal oxidizer unit or granular activated carbon units, liquid phase
granular activated carbon vessels, and an outfall structure.
The draft permit is crafted to protect all appropriate water quality standards by
treating for identified petroleum hydrocarbons, toxicants and chlorinated solvents
present in the groundwater post spill. Initial groundwater data reviewed for this
application indicated that PFAS was not present above practical quantitation limits.
Additional data is being collected and analyzed for PFAs contaminant prior to
possible issuance of a final permit. Comments received during the public hearing
process will be incorporated into the final analysis and decision-making process.
ALL DOCUMENTS RELATED TO THIS PERMIT CAN BE FOUND BY
ACCESSING THIS QR CODE.
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Denard, Derek
From: Jessie Oldham <[e-mail]>
Sent: Friday, March 17, 2023 4:40 PM
To: SVC_DEQ.publiccomments
Subject: [External] Colonial Pipeline
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To whom it may concern,
I am writing this email to place my opinion into public record regarding the permit request from Colonial
Pipeline to add a treatment center to their spill site, clean the fuel from the ground and then deposit the
remaining water into our creek system at the North Prong of Clark Creek. After looking at the permit
request, I am very concerned that Colonial Pipeline will not meet current state standards of water quality
for chemicals allowed in our drinking water. Also, I am concerned that the amount of water and
particulate will add a significant volume to the creek system. We have not been given an explanation of
the size and scope of the treatment building on site and what sound and eye sore issues may arise. At a
minimum the permit should not be granted without the following improvements to the permit requirements
1. Add technology based discharged limits to the wastewater permit. Particularly for the
known carcinogen benzene found in gasoline. The current effluent limitation in the draft is 5 times higher
than the water quality standard for benzene.
2. Reduce the daily flow limit. The proposed flow limit of 500,000 gallons per day is almost 20
percent of the natural flow of the receiving stream, the North Prong of Clark Creek.
3. Strengthen water quality based limits
4. Account for background levels of contamination when developing permit limits.
5. Require monitoring, disclosure and treatment of PFAS
6. Require instream monitoring for hazardous constituents in gasoline downstream from the
discharge outfall.
I also feel there should be independent company that over sees the Colonial Pipeline through the process
to make sure they are meeting all proper procedure and to do all the testing. Colonial Pipeline should not
be allowed to conduct the monitoring. We have seen failures from their ability to monitor the pipeline
itself leading to this massive spill.
Signed,
Jessie Oldham
i

Denard, Derek
From: gerard reid <[e-mail]>
Sent: Thursday, March 16, 2023 8:43 PM
To: SVC_DEQ.publiccomments
Subject: [External] COLONIAL PIPELINE
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ATTN: Colonial Pipeline Permit
Dear Mr. Thredford,
I attended the Public Hearing for Colonial Pipeline's NPDES Permit#NC0090000 in Huntersville on March 16, 2023. 1
understand this comment period is specific to the issuance of this permit and not a forum to hash out the how/why this
happened and the perceived failure of Colonial Pipeline to address many issues.
In regards to this permit I agree with the Southern Environmental Law Center and The Yadkin River Keepers in adjusting
the permit to require lower Benzene levels than what is currently required for the discharged water and adding a binding
condition to insure the proper operation and maintenance of the system to be used for the duration of the permit. I would
also align with any additional comments/recommendations these two groups make as they have the resources and
knowledge to review and decipher the information especially given the extremely short notice those of us in the
community have had with this comment period.
Sincerely,
Karen K. Reid
1

Denard, Derek
From: Linsey Scott <[e-mail]>
Sent: Friday, March 17, 2023 4:41 PM
To: SVC_DEQ.publiccomments
Subject: [External] Colonial Pipeline
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Hi,
I live less than 2 miles from what I understand to be the largest oil spill in the states history. I do not believe the state
and the company have not been forthcoming with information about the effects to the community. Now I understand
that the company has applied for a permit to "speed up"their clean up efforts yet they refused to take questions in a
public hearing that most of us did not find out about until on the evening local news after the fact.
I'm really disappointed in the information that's been released, notification process, and actions taken thus far by both
the state and the company. I want the state to know that I do not have confidence in the permitting process or that the
actions that the company is asking to take will ultimately not impact the local residents and water sources they plan to
discharge into. While I think we would all appreciate this being resolved, it is on the state to ensure that the company is
releasing accurate and transparent information. To date, statements from the company have been lacking. Statements
from the state have been lacking. Aside from a local government representative no one seems to be taking this
seriously. Maybe you don't think there's an impact to those that live close by. It would be great it you'd perform public
outreach if that's the case and the company was put in a position where the state demand they answer the questions of
local residents who are concerned for their health and well being as a result of an incident that was no fault of their
own.
I'd also suggest that there should be a mandatory disclosure within a specified distance from a pipeline (oil, natural gas,
other). Most of us were unaware there was a pipeline and public searchable online resources do not clearly indicate the
actual location of these transmission pipelines to a level of detail that allows residents to determine their proximity.
Sent from Mail for Windows
i

Denard, Derek
From: Grzyb,Julie
Sent: Monday, March 20, 2023 3:14 PM
To: Montebello, Michael J; Hennessy,John; Denard, Derek
Subject: Fw: [External] Colonial Pipeline hearing follow-up
Attachments: 2022-10-24 Comments on NPDES NCO090000 - Final.pdf, F.Alshahrani et al. - GAC Study.pdf
FYI - Please see email below and attached information from SELC.
Julie
Julie A.Grzyb
Deputy Director, Division of Water Resources
North Carolina Department of Environmental Quality
Office: [phone] 1 Cell: [phone]
[e-mail]
I C,NOH I H CAI-iCJLINZA
Department of Environmental Quality IN
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Patrick Hunter<[e-mail]>
Sent: Friday, March 17, 2023 12:17 PM
To: Grzyb,Julie<[e-mail]>
Cc: Henry Gargan <[e-mail]>
Subject: [External] Colonial Pipeline hearing follow-up
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
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Julie,
Good to see you last night at the Colonial Pipeline NPDES permit public hearing in Huntersville. I'm attaching our
comments on the draft permit. I'm also attaching one of several studies available showing the potential to use GAC to
remove benzene, MTBE, and toluene from water. There are multiple other studies available online.As you know, DEQ
also has significant data confirming the ability of GAC to remove PFAS.
According to the Oregon Health Authority, benzene "can be reduced below 5 ppb in drinking water using granular
activated carbon filtration." EPA has similarly concluded that "GAC is a proven technology with high removal efficiencies
(up to 99.9%)for many VOCs."
The EPA document also explains why it is critical that DEQ implement TBELs in the Colonial Pipeline permit. For
example, the GAC technology Colonial proposes to use should result in discharges of pollutants at levels far below those
set through WQBELs in the draft permit. The EPA paper confirms that improper or infrequent maintenance of GAC
filters reduces their efficacy.The WQBELs set in the draft permit are so high that Colonial would be able to save money
i

by skipping necessary filter maintenance—which would result in discharges of significantly more pollution to North
Prong Clarke Creek than is achievable by using properly maintained GAC filters—but remain below the current
WQBELs. Allowing these high pollution discharges by relying solely on WQBELs puts the local community unnecessarily
at risk, including people who use or walk along North Prong Clarke Creek as several people noted at last night's hearing.
TBELs are intended to prevent this situation. Where technology is available to achieve pollutant reductions below those
required through WQBELs, the Clean Water Act requires imposition of TBELs to achieve those reductions.
To be clear, I'm not suggesting that Colonial intends to neglect their wastewater treatment system but the community is
counting on DEQ to impose appropriate TBELs—which the Clean Water Act requires—to ensure the wastewater and
North Prong Clarke Creek are consistently as clean as practicable.
Please let me know if you'd like to talk about this further or if I can provide additional information.
Best,
Patrick
Patrick Hunter(he/him)
Asheville Office Managing Attorney
Southern Environmental Law Center
48 Patton Ave, Suite 304
Asheville, NC 28801
phunter(a_selcnc.org
Tel: [phone]
Fax: [phone]
PRIVILEGE AND CONFIDENTIALITY NOTICE
This message is intended only for the use of the individual or entity to which it is addressed and may contain information that is
privileged,confidential,and exempt from disclosure under applicable law. If you are not the intended recipient of this message,you
are hereby notified that disseminating,distributing,or copying it or any attachment to it is strictly prohibited. If you have received
this message in error,please notify me immediately by email and delete the original message.
2

SOUTHERN 48 Patton Avenue,Suite 304 Telephone [phone]
ENVIRONMENTAL Asheville,NC 28801 Facsimile 828-258-2024
LAW
CENTER
October 24, 2022
Via Electronic Mail and U.S. Mail
NCDEQ/DWR/NPDES
Water Quality Permitting Section
c/o Derek Denard
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
[e-mail]
Re: Draft NPDES Permit No. NCO090000
Dear Mr. Denard:
Please accept these comments on behalf of the Catawba Riverkeeper Foundation, Yadkin
Riverkeeper and the Southern Environmental Law Center concerning DEQ's review of draft
NPDES Permit No. NCO090000 for wastewater discharges from a groundwater remediation
system to be operated by the Colonial Pipeline Company ("Colonial").
The Yadkin Riverkeeper is a nonprofit, membership organization whose mission is to
protect and enhance the Yadkin-Pee Dee River basin through education, advocacy, and action.
The organization works to ensure a healthy Yadkin-Pee Dee River that provides clean drinking
water and is safe for recreational use by the basin's nearly three million residents.
The Catawba Riverkeeper Foundation is a local, community-based group of members and
volunteers working primarily to protect the 8,900 miles of waterways within the Catawba-
Wateree basin. The Catawba Riverkeeper Foundation is headquartered in Charlotte,NC. Many
of its members reside near and use waters within the vicinity of the proposed groundwater
remediation system, even though that system will be located in the Yadkin-Pee Dee River basin.
Members of both the Catawba Riverkeeper Foundation and Yadkin Riverkeeper are concerned
about the effects of pollution from the proposed discharge.
The Southern Environmental Law Center is a nonprofit, legal organization working to
protect the basic right to clean air, clean water, and a livable climate; to preserve the South's
natural treasures and rich biodiversity; and to provide a healthy environment for all.
The proposed NPDES permit would allow Colonial to extract, treat, and discharge 0.576
million gallons of contaminated groundwater per day (as a monthly average) into North Prong
Clark Creek, near the site of a 2020 gasoline spill from one of its pipelines. As DEQ is aware, the
spill has long been a headache for nearby residents; construction and operation of a new
wastewater treatment plant will add to the cumulative burden on this community. To ensure the
community is informed of this most recent development,we respectfully request that DEQ
Charlottesville Chapel Hill Atlanta Asheville Birmingham Charleston Nashville Richmond Washington,DC

hold a public hearing to allow affected residents and other stakeholders to comment on the
draft permit.
We understand that time is of the essence to ensure the cleanup operation is as successful
as possible: Under the ongoing remediation scheme, the removal of contaminated groundwater is
limited by how much extracted groundwater can be loaded onto trucks each day. Approving this
discharge permit sooner rather than later would relieve that bottleneck and allow Colonial to
extract greater volumes of water before the contaminant plume radiates even farther into the
water table than it already has.
We therefore urge DEQ to promptly fix the errors in the draft permit identified below and
act quickly to ensure the final permit complies with the law. Many of our concerns would be
mitigated or resolved through application of technology-based effluent limitations ("TBELs").
The Clean Water Act requires DEQ to impose TBELs in NPDES permits, but the agency has
failed to do so for nearly every contaminant listed in the draft permit. In our experience, DEQ
frequently bypasses this critical step when developing NPDES permits leading to ongoing,
unnecessarily high—and illegal—pollutant loading in waterways across the state.
Application of TBELs is straightforward here. Not only is technology widely available to
treat the discharges to bring contaminant levels well below those authorized in the draft permit
but Colonial has already explained that it plans to use that technology. Yet DEQ never takes this
technology into account when developing effluent limitations in the draft permit. This violates
the Clean Water Act. DEQ must revise the draft permit to include TBELs as required.
Of particular importance, DEQ must require Colonial to disclose if the class of chemicals
known as per- and polyfluoroalkyl substances ("PFAS") may be present in the effluent from the
proposed wastewater treatment plant—regardless of whether Colonial is the original source of
those PFAS in the environment—and apply TBELs appropriately and water quality-based
effluent limitations as necessary. North Carolina has recognized the numerous adverse effects
associated with PFAS exposure;' there is no reason these compounds should be unnecessarily
added to our surface waters.
I. DEQ must impose TBELs for all constituent pollutants.
The draft permit only imposes TBELs on three constituent pollutants (total suspended
solids, oil & grease, and chloroethane),2 leaving the remainder accountable only to meeting
limits calculated based on numeric water quality standards (water-quality based effluent
limitations or"WQBELs") or in-stream target values (for pollutants with no numeric water
quality standard). For reasons that follow, these omissions are inconsistent with DEQ's
obligations under the Clean Water Act and must be swiftly corrected.
I North Carolina DEQ,Action Strategy for PFAS(June 7,2022),at 5,available at
https://deq.nc.gov/media/30108/open#:-:text=North%20Carolina%20is%20working%20aggressively,nonstick%20p
roducts%20and%20firefighting%20foams.
2 Draft Fact Sheet for NPDES Permit No.0090000(Sept.20,2022)("Draft Fact Sheet"),at 8-9.
2

A. The Clean Water Act requires DEQ to evaluate technologies available to treat
pollutants and impose TBELs accordingly.
Congress passed the Clean Water Act in 1972 "to restore and maintain the chemical,
physical, and biological integrity of the Nation's waters." 33 U.S.C. § 1251(a). To that end,
Congress established an"interim goal of[achieving] water quality which provides for the
protection and propagation of fish, shellfish, and wildlife and provides for recreation . . . by July
1, 1983" and a longer-term"goal that the discharge of pollutants into the navigable waters be
eliminated by 1985."Id. § 1251(a)(1), (2) (emphasis added). To meet those goals, Congress
prohibited the discharge of pollutants from point sources4 without a permit. See id. § 1311(a).
The Clean Water Act's National Pollutant Discharge Elimination System("NPDES")permitting
program is structured around progressive improvements in pollution control over time to meet
Congress's "national goal" of eliminating discharges of pollutants. See id. § 1251(a)(1).5
NPDES permits control pollution through two primary mechanisms: first,by setting
limits based on technologies available to treat pollutants (using TBELs), and second, by setting
any additional limits necessary to ensure compliance with water quality standards (using
WQBELs). 33 U.S.C. §§ 1311(b), 1314(b); 40 C.F.R. § 122.44(a)(1), (d). Every NPDES permit
"shall" contain TBELs,which set the minimum level of control required in every NPDES permit.
40 C.F.R. § 125.3(a). DEQ may issue a NPDES permit only if the permit assures compliance
with all technology-based and water quality-based effluent limits. 33 U.S.C. § 1342(a)(1)(A); 40
C.F.R. § 122.43(a).
Stated differently, to comply with the Clean Water Act, a permit writer first imposes
TBELs and subsequently evaluates the need to impose additional WQBELs if the TBELs are
insufficient to ensure compliance with water quality standards. TBELs "are developed
independently of the potential impact of a discharge on the receiving water,which is addressed
through water quality standards and water quality based effluent limitations." EPA,NPDES
Permit Writers' Manual at 5-1.6 A discharger must implement TBELs, even if doing so goes
beyond the level necessary to meet water quality standards.Id.; see 15A NCAC 2B.0404(a) ("if
the discharge is subject to both technology based and water quality based effluent limitations for
a parameter, the more stringent limit shall apply"). Permit writers run afoul of the Clean Water
Act by focusing exclusively on WQBELs, in part,because doing so forecloses the Congressional
goal of eliminating discharges of pollutants to navigable waters—discharges would be
maintained so long as they did not violate water quality standards.
3"The term`pollutant' means dredged spoil,solid waste,incinerator residue,sewage,garbage,sewage sludge,
munitions,chemical wastes,biological materials,radioactive materials,heat,wrecked or discarded equipment,rock,
sand,cellar dirt and industrial,municipal,and agricultural waste discharged into water."33 U.S.C.§ 1362(6).
a"The term`point source'means any discernible,confined and discrete conveyance,including but not limited to any
pipe,ditch,channel,tunnel,conduit,well,discrete fissure,container,rolling stock,concentrated animal feeding
operation,or vessel or other floating craft,from which pollutants are or may be discharged."33 U.S.C. § 1362(14).
5 North Carolina administers the NPDES program within its borders under delegated authority from EPA.See
National Pollutant Discharge Elimination System Memorandum of Agreement Between The State Of North
Carolina And The United States Environmental Protection Agency Region 4(2007)available at
https://www.ppa.eov/sites/default/files/2013-09/documents/nc-moa-ppdes.pdf.
6 Available at https://www.epa.gov/sites/production/files/2015-09/documents/pwm 2010.pdf.
3

Technology-based limits are derived from one of two sources: (1)national effluent
limitation guidelines issued by EPA for various industries, 33 U.S.C. § 1314(b), or(2) case-by-
case determinations using permit writers' "best professional judgment" (`BPJ"), when EPA has
not issued an effluent limitation guideline for an industry. See 33 U.S.C. § 1342(a)(1)(B); 40
C.F.R. § 125.3(c)(2). Restated, "[w]here EPA-promulgated effluent guidelines are not applicable
to a non-[publicly owned treatment works] discharge, such requirements are established on a
case-by-case basis using BPJ." EPA,NPDES Permit Writers' Manual at 5-45. North Carolina
rules likewise direct staff to calculate TBELs using "available information" in the absence of a
promulgated effluent limitation guideline. 15A NCAC 02B .0406(b)(3).
B. DWR failed to include TBELS for constituent pollutants in the draft permit.
Almost all the limits the draft permit imposes on the discharge's constituent pollutants
are based only on a WQBEL developed to ensure compliance with numeric water quality
standards for individual pollutants or in-stream target values.' The Clean Water Act requires
more. As explained above, WQBELs are only a backstop when TBELs alone would not provide
for the attainment of water quality-based standards. The draft permit includes no indication that
DEQ considered whether technology exists to achieve the further pollutant reductions the Clean
Water Act requires—or even that DEQ factored into its analysis the technology that Colonial has
already committed to use. Instead, DEQ skipped directly to applying WQBELs for all but three
pollutants. DEQ must take the additional step—which should have been its first step—to
consider and apply TBELs before finalizing the permit.
The draft permit includes a TBEL for total suspended solids based on an EPA-issued
effluent limitation guideline.$ But DEQ's legal obligation to impose TBELs is not contingent on
whether EPA has issued effluent limitation guidelines. In a step in the right direction, DEQ has
also imposed TBELs using BPJ for oil and grease and chloroethane.9 Unfortunately, DEQ stops
there and does not complete the necessary step of exercising BPJ to determine if it should impose
TBELs for any other pollutant. The requirement for permit writers to use BPJ to impose a TBEL
is unequivocal; DEQ must use BPJ to apply TBELs to other pollutants.
As noted above, the failure to develop and apply TBELs here is particularly striking
because technologies are readily available to reduce the discharge of many of the relevant
pollutants and because Colonial has disclosed that it plans to use those technologies. Restated,
DEQ developed effluent limits without accounting for technology the permittee has already
agreed to use at this site. This demonstrates a clear failure to exercise BPJ to set TBELs—in
violation of the Clean Water Act—and permits Colonial to discharge unreasonably high amounts
of many pollutants.
Draft Fact Sheet at 11-13.
1Id. at 11 (citing 40 C.F.R.Part 133)
9Id.at 11-12.
4

According to the draft permit, Colonial plans to utilize granular activated carbon to treat
contaminated groundwater before discharging it to North Prong Clark Creek!!As scientists and
other state agencies have acknowledged,packed tower aeration and granular activated carbon are
both capable of reducing benzene concentrations, for instance, below 5 parts per billion—the
federal standard for drinking water, and more than 50 times lower than the 274 parts per billion
upper limit the draft permit would impose." These technologies are also used to treat other
aromatic hydrocarbons identified by DEQ's reasonable potential analysis for this draft permit.12
In other words,use of granular activated carbon here should result in reductions in effluent levels
for multiple constituents planned to be discharged by Colonial (including, as discussed below,
PFAS). Colonial has told DEQ it plans to treat the groundwater using granular activated carbon;
unmistakably, this technology is available for use at this site; DEQ must factor this technology
into its analysis and implement TBELs as the Clean Water Act requires.
Importantly, calculating effluent limitations accounting for the use of granular activated
carbon could make a meaningful difference in the amount of pollution discharged to North Prong
Clark Creek. Perhaps most obviously, it would ensure that Colonial follows through on its
commitments to implement that technique. But more importantly, because the effectiveness of
granular activated carbon treatment depends in large part on how the filters are maintained,13
using the technology to establish TBELs would hold the permittee accountable for a high
standard of maintenance and diligence.
DEQ must demonstrate in the final permit that it has investigated the availability and
capabilities of technologies to treat the pollutants that will be discharged from this facility. This
unquestionably must include technologies Colonial has already committed to use. Where such
technology exists, DEQ must require Colonial to reduce effluent pollutant concentrations to the
levels achievable with such technology through application of TBELs.
II. DEQ must require Colonial to disclose whether PFAS will be present in the
discharge and, if so, apply appropriate controls—including TBELs.
In response to the 2020 gasoline spill, it appears that foam containing high levels of
PFAS (through cross-contamination or otherwise)was used as a suppressant. Perhaps as a result,
monitoring around the spill site has detected PFAS in soil and groundwater samples—the same
groundwater Colonial plans to treat and discharge through the proposed wastewater treatment
1°Draft NPDES Permit No.NCO090000("Draft Permit"),at 2.
11 See Oregon Health Authority,Benzene and Drinking Water,at 2,available at
hllps://www.ore,gon.,gov/oha/PH/HEALTHYENVIRONMENTS/DRINKINGWATER/MONITORING/Documents/
health/benzene.pdf("Benzene can be reduced below 5 ppb in drinking water using granular activated carbon
filtration or packed tower aeration.").
12 Draft Fact Sheet at 11-12;see also Abdukarem L Amhamed et al., Optimizing the design parameters of a packed
column aerator for VOC removal:A real case study on polluted ground water,J.OF OIL,GAS,AND PETROCHEMICAL
SCI. (2022)(explaining how benzene,ethyl-benzene,toluene,and xylenes are typically found and treated together in
groundwater remediation after gasoline spills).
13 U.S.EPA,Wastewater Technology Fact Sheet: Granular Activated Carbon Adsorption and Regeneration
(September 2000),at 5,available at
https://nepis.epa.gov/Exe/ZyPDF.cgi/P 1001 QTK.PDF?Dockey=P 1001 QTK.PDF.
5

plant. Accordingly, it is possible—if not likely—that the discharge from the wastewater
treatment plant will contain PFAS. Colonial must disclose if PFAS will be discharged and, if so,
DEQ must impose appropriate TBELs and, as discussed in Section III, WQBELs as necessary.
A. PFAS present serious threats to human health.
PFAS are a group of man-made chemicals manufactured and used broadly by industry
since the 1940s.14 The human health and environmental problems associated with PFAS
exposure are now widely known; PFAS pose a significant threat to human health at extremely
low concentrations. Two of the most studied PFASperfluorooctanoic acid and perfluorooctane
sulfonate—are bioaccumulative and highly persistent in humans.15 These PFAS have been
shown to cause developmental effects to fetuses and infants, kidney and testicular cancer, liver
malfunction,hypothyroidism, high cholesterol, ulcerative colitis, obesity, decreased immune
response to vaccines, reduced hormone levels, delayed puberty, and lower birth weight and
size.16 Studies show that exposure to mixtures of different PFAS can worsen these health
effects."
EPA recently recognized PFAS as "an urgent public health and environmental issue
facing communities across the United States."18 And EPA has called on"[e]very level of
governmentfederal, Tribal, state, and local [ ] to exercise increased and sustained leadership
to accelerate progress to clean up PFAS contamination [and] prevent new contamination,"
specifically calling on states to "[1]everage NPDES permitting to reduce PFAS discharges to
waterways."19
14 Lifetime Drinking Water Health Advisories for Four Perfluoroalkyl Substances, 87 Fed.Reg.36,848,36,849
(June 21,2022); Our Current Understanding of the Human Health and Environmental Risks of PFAS,U.S.EPA,
hops://www.epa.goy/pfas/our-current-understanding-human-health-and-environmental-risks-pfas.
1187 Fed.Reg. at 36,849;U.S.EPA,Interim Drinking Water Health Advisory:Perfluorooctanoic Acid(PFOA)
CASRN 335-67-1 (June 2022),at 3-4,available at hops://www.epa.gov/system/files/documents/2022-06/interim-
pfoa-2022.pdf;U.S.Env't Prot.Agency,Interim Drinking Water Health Advisory:Perfluorooctane Sulfonic Acid
(PFOS)CASRN 1763-23-1 (June 2022),at 3-4,available at hgps://www.epa.gov/system/files/documents/2022-
06/interim-pfos-2022.pdf.
16 Arlene Blum et al., The Madrid Statement on Poly-and Perfluoroalkyl Substances(PFASs), 123 ENV'T.HEALTH
PERSP. 5,A 107(May 2015);U.S.Env't Prot.Agency,Drinking Water Health Advisories for PFAS:Fact Sheet for
Communities,at 1-2(June 2022),available at https://www.epa.gov/system/files/documents/2022-06/drinking-
water-ha-pfas-factsheet-communities.pdf.
17 Emma V.Preston et al.,Prenatal Exposure to Per-and Polyfluoroalkyl Substances and Maternal and Neonatal
Thyroid Function in the Project Viva Cohort:A Mixtures Approach, 139 ENV'T INT'L 1 (2020),
https://perma.cc/DJK3-87SN.
18 EPA,PFA Strategic Roadmap:EPA's Commitments to Action 2021-2024 at 1,available at
https://www.gpa.gov/system/files/documents/2021-10/pfas-roadmap final-508.pdf.
19 Id.
6

B. Colonial's effluent discharges will likely contain PFAS.
It appears likely that Colonial's discharges will contain PFAS. The initial response to the
spill involved treating the site using 1,100 gallons of vapor- and fire-suppressing foam,20 which
lab results show contained dangerously high levels of dozens of PFAS compounds—some
exceeding 20,000 parts per trillion.21 Recent health advisory levels for some PFAS compounds
start as low as hundredths or thousandths of parts per trillion.22 PFAS has been detected in
groundwater at the site at levels up to 154 parts per trillion.23 Colonial's sampling to date may
underestimate the amount of PFAS onsite as the company only treats concentrations from its
groundwater sampling above 10 parts per trillion as significant even though levels below this
threshold can negatively impact people and the environment.24
PFAS released at the sitethrough the use of vapor- and fire-suppressing foam or
otherwise—are likely to persist in the environment for a significant period of time. PFAS are
also highly durable and mobile, able to easily seep into groundwater through soil and spread
through the water table.25 If PFAS reach Colonial's recovery wells—even if that does not happen
for months or years—their persistent nature makes it highly likely they will be present in
discharges through the wastewater treatment plant.
Colonial does not contest the detectable presence of PFAS at the site but suggests the
source of the PFAS is unrelated to the 2020 gasoline spill and subsequent remediation efforts.26
To be clear, the origin of any PFAS present is immaterial to Colonial's obligations here: If PFAS
is or may be present in contaminated groundwater processed through Colonial's wastewater
treatment plant, Colonial must account for it through the NPDES permitting process, even if
Colonial is not the original source of the PFAS.
21 See Technical Memorandum from TRC Environmental Corporation to Sam McEwen(Colonial), 1 (Oct. 30,
2021).North Carolina Attorney General Josh Stein announced on Oct. 18 that he was filing two new lawsuits
against manufacturers of some of these foams for their role in introducing PFAS into the environment.See Attorney
General Josh Stein Files Two Additional Lawsuits Over Toxic Firefighting Foam,N.C.DEPT.OF JUSTICE(Oct. 18,
2022),https://ncdoj.gov/attorney a neral-josh-stein-files-two-additional-lawsuits-over-toxic-firefightin -fg oam/.
u Monitoring Report at PDF 127(disclosing levels of PFAS compounds found in"raw product");see also Lisa
Sorg,Mystery Deepens Over Origin of Dangerous Chemicals Found at Massive Gasoline Spill,N.C.POL'Y WATCH
(March 30,2021).
22 U.S.EPA,Lifetime Drinking Water Health Advisories for Four Perfluoralkyl Substances(June 21,2022),87 Fed.
Reg. 36,848.
23 See Technical Memorandum,Figure 2.
24 Id.at 5.
25 U.S.EPA,Addressing Challenges of PFAS:Protecting Groundwater and Treating Contaminated Sources(Sept.
20,2021),https://www.epa.gov/sciencematters/addressing-challenges-pfas-protecting-groundwater-and-treating-
contaminated-sources.
26 See Technical Memorandum at 12(arguing that detected"PFAS compounds are not sourced from or associated
with the Huntersville release and do not warrant additional investigation").
7

C. Colonial must fully disclose any PFAS that maybe present in its discharges.
The Clean Water Act requires permittees to assess and disclose the pollutants in their
effluent. DEQ has acknowledged this requirement applies to PFAS. In its enforcement action
against The Chemours Company, LLC, for the company's discharge of GenX and other PFAS
into the Cape Fear River, the agency stated:
Part of the permit applicant's burden in this regard is to disclose all relevant
information, such as the presence of known constituents in a discharge that pose a
potential risk to human health. The permit applicant is required to disclose "all
known toxic components that can be reasonably expected to be in the discharge,
including but not limited to those contained in a priority pollutant analysis." 15A
N.C.A.C. 2H .01050) (emphasis added).27
DEQ further acknowledged that Chemours had violated its NPDES permit and state water
quality laws by"failing to fully disclose all known toxic components reasonably expected to be
in [the company's] discharge."28
DEQ's position in the Chemours enforcement case was correct. The Clean Water Act
generally prohibits discharges to streams and rivers. See 33 U.S.C. § 1311(a). The NPDES
permitting program is a limited exception to that prohibition,see Nat'l Assn of Home Builders v.
Def. of Wildlife, 551 U.S. 644, 650 (2007), and discharges under the program cannot be approved
unless they are disclosed,see In re Ketchikan Pulp Co., 7 E.A.D. 605 (EPA) (1998);Piney Run
Pres. Ass'n v. Cty. Comm'rs of Carroll Cty., Maryland, 268 F.3d. 255 (4th Cir. 2001); Southern
Appalachian Mountain Stewards v. A & G Coal Corp., 758 F.3d 560 (4th Cir. 2014). EPA has
also stressed the need for disclosure of pollutants during the permitting process:
[D]ischargers have a duty to be aware of any significant pollutant levels in their
discharge. [...] Most important, [the disclosure requirements] provide the
information which the permit writers need to determine what pollutants are likely
to be discharged in significant amounts and to set appropriate permit limits. [...]
[P]ermit writers need to know what pollutants are present in an effluent to
determine approval permit limits in the absence of applicable effluent guidelines.29
If a permit holder is discharging a pollutant that it did not disclose in its NPDES permit
application, it is in violation of the permit and the Clean Water Act.Piney Run, 268 F.3d. at 268.
Despite the likely presence of HAS in groundwater that will be treated through the
proposed wastewater treatment system, we have been unable to find any information in
27 Amended Complaint,N.C.Dept.of Environmental Quality v.Chemours, 17 CVS 580,6-7(N.C. Super.2018)
(hereinafter"N.C.DEQ Amended Complaint")(citing 33 U.S.C. § 1342(k),Piney Run Pres.Assn v. Cty. Commis
of Carroll Cty.,MD,268 F.3d 255,265(4th Cir.2001)).
28 Id. at 33.
29 Consolidated Permit Application Forms for EPA Programs,45 Fed.Reg.33,526-31 (May 19, 1980).
8

Colonial's permit application materials30 or the draft permit related to PFAS. To be sure, other
documents prepared by Colonial in connection with the 2020 gasoline spill and subsequent
remedial actions (discussed above) indicate that PFAS are likely present at this site but Colonial
is obligated to clearly disclose the presence of HAS through the NPDES application process to
ensure the permit writer is aware of PFAS' potential presence here and can apply TBELs and
WQBELs appropriately.
D. DEQ must set appropriate effluent limits for any discharges of PFAS through the
proposed wastewater treatment plant.
Once pollutants are disclosed, DEQ must evaluate and impose TBELs on a case-by-case
basis as discussed above. This includes PFAS.
Effective treatment technologies for PFAS are available that must be assessed through the
TBELs process. Granular activated carbon is a cost effective and efficient technology that is
capable of reducing PFAS concentrations to virtually nondetectable levels. A granular activated
carbon treatment system at the Chemours' facility, for example, has reduced HAS
concentrations as high as 345,000 parts per trillion from a creek contaminated by groundwater
beneath the facility to nearly nondetectable concentrations.3 1 And DEQ has used TBELs to
control PFAS in an NPDES permit. The agency issued an NPDES permit for Chemours that
incorporates TBELs for HAS to ensure that the company uses the best available technology—in
that case, granular activated carbon—to treat highly contaminated groundwater.32 DEQ should
likewise require Colonial to fully characterize and disclose any PFAS discharges and to assess
the best level of PFAS removal its granular activated carbon system will be able to achieve. DEQ
must then implement TBELs based on that level of removal.
As noted above, there is no reason DEQ should not develop TBELs for PFAS and other
pollutants based on reductions achievable with granular activated carbon technology because
Colonial has already explained that it plans to use that technology at this site. Designing effluent
limits based on the technology will help ensure it is properly maintained and operated to remove
pollutants. Use of granular activated carbon and development of TBELs based on its use may be
sufficient to protect water quality but, if not, DEQ must impose WQBELs as discussed below.
11 Colonial Pipeline Co.,Application for NPDES Permit to Discharge Wastewater(Aug. 13,2021),tbls.A—E
(describing pollutants"believed present").
31 See Parsons,Engineering Report—Old Outfall 002 GA Pilot Study Results(Sept.2019),available at
https://www.chemours.com/j a/-/media/files/corporate/12e-old-outfall-2-gac-pilot-report-2019-09-
30.pdf?rev=6el242091aa846f888afa895eff80e2e&hash=040CAA7522E3D64B9E5445ED6F96BOFB;see also
Chemours Outfall 003,NPDES No.NC0089915 Discharge Monitoring Reports(2020-2022),available at
https://penna.cc/8YND-XT5M.
sz See Chemours Outfall 004,NPDES NO.NC0090042,fact sheet,
https://deq.nc.gov/media/31345/download?attachment;Chemours Outfall 004,NPDES NO.NC0090042,final
NPDES permit,https:Hdeq.nc.gov/media/31343/download?attachment.
9

III. The draft permit's WQBELs fail to ensure compliance with water quality
standards and maintenance of designated uses.
The Clean Water Act charges states with identifying "designated uses" for jurisdictional
waterbodies and promulgating water quality standards to protect those uses. See 40 C.F.R. §
131.10(a) ("Each State must specify appropriate water uses to be achieved and protected"); 40
C.F.R. § 131.3(i) (defining water quality standards as "a designated use or uses... and water
quality criteria for such waters based upon such uses."). North Carolina implements this
procedure by classifying waterbodies and assigning water quality standards for each
classification. See N.C. Gen. Stat. § 143-214.1; 15A NCAC 213.0101, .0301.North Prong Clark
Creek is a designated class C water.33 The "best use" of class C waters "shall be aquatic life
propagation, survival, and maintenance of biological integrity (including fishing and fish);
wildlife; secondary contact recreation; agriculture; and any other usage except for primary
contact recreation or as a source of water supply for drinking, culinary, and food processing
purposes." 15A NCAC 213.0211. North Carolina has promulgated water quality standards to
protect this "best use."See id.; id. 213.0208. "Sources of water pollution that preclude any of
these uses on either a short-term or long-term basis shall be deemed to violate a water quality
standard."Id. 213.0211.
As discussed above, WQBELs are intended to "keep the concentration of a pollutant in a
waterway at or below"the water quality standard promulgated to protect the designated use.Am.
Paper Inst., Inc. v. U.S. E.P.A., 996 F.2d 346, 350 (D.C. Cir. 1993). DEQ may not issue an
NPDES permit"until the applicant provides sufficient evidence to ensure that the proposed
system will comply with all applicable water quality standards" and"[n]o permit may be issued
when the imposition of conditions cannot reasonably ensure compliance with applicable water
quality standards." 15A NCAC 2H.0112(c). The vast majority of limits imposed in the draft
permit are WQBELs. Unfortunately, these limits are insufficient to ensure compliance with water
quality standards and maintenance of"best uses." DEQ's WQBELs for carcinogens will allow
North Prong Clark Creek to exceed regulatory levels for those constituents for significant
portions of time. This problem can potentially be resolved by adding a daily flow limit,which is
independently required under the Clean Water Act, and by appropriately developing TBELs.
DEQ must also consider narrative water quality standards when developing WQBELs. This step
is particularly important here given the toxic mix of chemicals in the discharge.
A. The WQBELs do not ensure compliance with numeric water quality standards for
carcinogens.
The WQBELs imposed in the draft permit for carcinogens fail to ensure compliance with
numeric water quality standards because they are calculated using the mean annual flow of North
Prong Clark Creek. While this approach may work in some instances, it falls short here where
the effluent will frequently constitute a substantial, and sometimes the majority, of water in the
receiving stream.
ss Draft Fact Sheet at 2.
10

North Carolina has promulgated numeric water quality standards applicable to class C
waters for carcinogens. See 15A NCAC 2B.0208(a)(2)(B). For example, the numeric water
quality standard for benzene is meant to prevent concentrations of that constituent in class C
waters over 51 parts per billion. Id.
WQBELs for carcinogens are developed using a proportion (the in-stream waste
concentration, or"IWC") of the mean annual flow and assume zero background pollution. 15A
NCAC 02B .0206(a)(4)(B). The IWC is defined by EPA as "the concentration of the effluent in
the receiving water after mixing."34 The draft permit authorizes discharge of 0.576 million
gallons per day as a monthly average into a stream with an average flow of 3.9 cubic feet per
second.35 Accordingly, the permitted discharge volume's IWC is 18.62 percent of the mean
annual flow rate of the North Prong Clark Creek, the receiving stream. To achieve the 51 parts
per billion water quality standard for benzene, the draft permit divides 51 parts per billion by the
mean annual IWC, otherwise expressed as 0.1862,producing an allowable concentration in the
discharge of 274 parts per billion (more than five times the water quality standard). This same
calculation was applied to set the discharge limit for vinyl chloride (another carcinogen) at 12.88
parts per billion—the water quality standard of 2.4 parts per billion is 18.62 percent of the
WQBEL in the draft permit.Id. .0208(a)(2)(B)(xvii).
Use of mean annual flow to calculate IWC and subsequently WQBELs may be
appropriate in some instances—such as when the effluent discharged represents a smaller portion
of the total water in the receiving stream. But here,North Prong Clark Creek will frequently be
overwhelmed by effluent from the proposed wastewater treatment plant. Given the small
assimilative capacity of the receiving stream, DEQ's approach to using mean annual flow does
not ensure compliance with water quality standards. There are at least two common scenarios
where water quality standards for carcinogens will be violated.
First, DEQ's WQBEL is calculated to allow the maximum discharge of carcinogens
without violating a water quality standard when North Prong Clark Creek is at its mean annual
flow. But whenever flow is below that level—which is likely to be frequent—DEQ's WQBEL
will fail to ensure that water quality standards for benzene and other carcinogens will be
maintained. Restated, the WQBEL may ensure compliance with water quality standards in North
Prong Clark Creek at mean annual flow or higher but not when flow is lower.
Second, the WQBELs were developed using a discharge rate (0.576 million gallons per
day)measured as a monthly average. Use of a monthly average limit alone allows Colonial's
discharge rate to exceed this average during certain periods of the month so long as it balances
those high discharges with low discharges. On days when discharges are high, there is no
guarantee that water quality standards will be maintained because DEQ's analysis assumes no
more than 0.576 million gallons will be discharged per day—yet the permit lacks any daily flow
limit enforcing this restriction. This will be particularly problematic on days when the discharge
flow rate is higher than average,but the flow of North Prong Clark Creek is lower than average:
31 U.S.EPA,Whole Effluent Toxicity Training Course(1996),at 6(emphasis added),available at
https://nois.epa.gov/Exe/ZyPDF.cgi/91025HIS.PDF?Dockey=91025HIS.PDF.
15 Draft Fact Sheet at 1,3.
11

On those days, IWC and in-stream contaminant levels will be far higher than DEQ assumes in its
permit analysis.
To be clear, it is irrelevant that the proposed WQBELs may ensure compliance with
water quality standards some of the time. "Sources of water pollution that preclude [designated
uses] on either a short-term or long-term basis shall be deemed to violate a water quality
standard." 15A NCAC 2B.0211 (emphasis added). And DEQ may not issue a permit when
"imposition of conditions cannot reasonably ensure compliance with applicable water quality
standards." 15A NCAC 2H.0I 12(c).
However, this problem can potentially be resolved relatively easily. First, DEQ must
impose a daily flow limit to match the flow assumptions used to develop WQBELs. A daily flow
limit is also independently required under the Clean Water Act. See 40 C.F.R. § 122.45(d)(1)
(requiring that"all permit effluent limitations, standards, and prohibitions ... unless
impracticable be stated as a maximum daily and average monthly discharge limitations").
Second,proper application of TBELs for carcinogens should avoid the need to develop
WQBELs entirely because the technology Colonial already plans to use at this site is likely to
remove pollutants to a degree that numeric water quality standards for carcinogens will not be
threatened. Nevertheless, as written the WQBELs in the draft permit fail to comply with the
requirements of the Clean Water Act and North Carolina's implementing regulations.
B. DEQ must consider background concentrations of contaminants when developing
WQBELs.
Because WQBELs are meant to prevent exceedances of water quality standards, DEQ
must factor background concentrations of constituents into its analysis when calculating effluent
limits. Here, DEQ assumes a background concentration of zero for all constituents except NH3.36
But at least toluene and lead have been detected at relatively high levels in onsite surface
waters.37 DEQ must factor these background concentrations (and those known for other
contaminants) into its WQBEL analysis to ensure the permitted discharge does not lead to a
violation of water quality standards.
C. DEQ must consider narrative water quality standards when developing WQBELs.
Finally, even without the errors noted above, DEQ's effort to develop WQBELs would
fall short because it fails to take narrative water quality standards into account. Proper
application of narrative water quality standards is critical here where many pollutants addressed
in the permit lack numeric water quality standards, including PFAS, and where the pollutants
will be released in combination.
North Carolina's narrative water quality standard for toxic substances explains that "the
concentration of toxic substances, either alone or in combination with other wastes, in surface
waters shall not render waters injurious to aquatic life or wildlife, recreational activities, or
36 See NPDES Implementation of Instream Dissolved Metals Criteria at 3 (attached to Draft Fact Sheet).
37 Draft Fact Sheet at 3.
12

public health, nor shall it impair the waters for any designated uses." 15A NCAC 213.0208(a).
Toxic substances are defined as:
any substance or combination of substances (including disease-causing agents)
that, after discharge and upon exposure, ingestion, inhalation, or assimilation into
any organism, either directly from the environment or indirectly by ingestion
through food chains, has the potential to cause death, disease, behavioral
abnormalities, cancer, genetic mutations, physiological malfunctions (including
malfunctions or suppression in reproduction or growth), or physical deformities in
such organisms or their offspring.
15A NCAC 2B.0202(57).
Many of the pollutants released constitute "toxic substances"under this definition. DEQ
has recognized that PFAS also constitute a"toxic substance,"38 and has included limits for PFAS
referencing the toxic substances narrative water quality standard and EPA's health advisory for
GenX in at least one NPDES permit.39 DEQ must assess the combined effect on North Prong
Clark Creek of the numerous pollutants proposed to be discharged from Colonial's wastewater
treatment plant to ensure compliance with North Carolina's narrative water quality standards.
DEQ's siloed approach to developing WQBELs pollutant-by-pollutant using numeric water
quality standards or in-stream target values fails to ensure compliance with this standard. In other
words, even if DEQ had appropriately developed a WQBEL for benzene, it has still failed to
consider the effect on water quality of authorizing the discharge of high amounts of benzene,
lead, naphthalene, toluene, xylenes, methyl tert-butyl ether and many other constituents in
combination and whether that discharge is consistent with North Carolina's narrative water
quality standard for toxic substances.
Proper application of the narrative water quality standard for toxic substances should also
lead to a zero or near-zero discharge limit for PFAS which, as noted throughout, are highly toxic.
Like its approach to developing WQBELs for numeric water quality standards and in-
stream target values, DEQ can potentially show compliance with the toxic substances narrative
water quality standard by appropriately applying TBELs which should lead to significant
reductions in permit limits for many pollutants.
38 N.C.DEQ Amended Complaint at 32(stating that"the process wastewater from[Chemours]
Fluoromonomers/Nafion®Membrane Manufacturing Area contains and has contained substances or combinations
of substances which meet the definition of"toxic substance"set forth in 15A N.C.A.C.2B .0202,"referring to
GenX and other PFAS).
39 See Chemours Outfall 004,NPDES NO.NC0090042,fact sheet,at 11-12,
https://deq.nc.gov/media/31345/download?attachment;Chemours Outfall 004,NPDES NO.NC0090042,final
NPDES permit,https:Hdeq.nc.gov/media/31343/download?attachment.
13

IV. Conclusion
The solution to many of the problems highlighted in this comment letter is
straightforward: DEQ must properly impose TBELs as required under the Clean Water Act. At
the most basic level, this requires DEQ to consider technology Colonial has already explained it
intends to use when developing effluent limits. We respectfully request that DEQ make the
foregoing changes to the draft permit before finalization. We additionally request that DEQ hold
a public hearing on the draft permit to help community members better understand and provide
feedback on this important and complex process.
Please inform Patrick Hunter([e-mail]) of issuance of any final permit.
Sincerely,
pa�t' K //. t T
Patrick Hunter
Managing Attorney
Southern Environmental Law Center
[e-mail]
Henry Gargan
Associate Attorney
[e-mail]
14

www.nature.com/scientificreports
scientific reports
IN Check for updates
OPEN Removal of benzene, MTBE
and toluene from contaminated
waters using biochar-based liquid
activated carbon
F.Alshahranil, B.Tawabinill,T.Salehz, M.Alrayaan',S.Alaama', R. Nasser', P.Soupios',
P. Kirmizakis', M. Mahmoud4,T.Oyehan'&E.Safi'
Fuel components such as benzene,toluene,and methyl tertiary-butyl ether(MTBE)are frequently
detected pollutants in groundwater resources.Ex-situ remediation technologies by activated carbon
have been used for treatment for many years.However,due to high cost of these technology,more
attention has been given to the in-situ remediation methods of contaminated groundwaters using
liquid carbon adsorbents.Literature search showed limited studies on using adsorbents in liquid
form for the removal of such contaminants.Therefore,this lab-scale study investigates the capacity
of using raw biochar-based liquid activated carbon and iron-modified biochar-based liquid activated
carbon to remove these pollutants.The adsorption efficiency of the synthesized liquid activated
carbon and iron-modified liquid activated carbon mixed with sand,limestone,and 1:1 mixture of sand/
limestone,was tested using batch suspension experiments.Adsorption by granular activated carbon
was also investigated for comparison with liquid activated carbon.Results of the study revealed that
mixing of liquid activated carbon or LAC-Fe on subsurface materials had not improved the removal
efficiency of MTBE.At the same time,it showed a slight improvement in the adsorption efficiency
of benzene and toluene.In all cases,the removal by GAC was higher with around 80%and 90%for
MTBE and BT,respectively.Results also showed that benzene and toluene were better removed
by liquid activated carbon and iron-modified liquid activated carbon(—40%)than MTBE(—20%).
It is also found that water chemistry(i.e.,salinity and pH)had insignificant effects on the removal
efficiency of pollutants under the study conditions.It can be concluded that more research is needed
to improve the capacity of biochar-based liquid-activated carbon in removing MTBE,benzene and
toluene compounds that will lead to improve the utilization of liquid activated carbon for the in-situ
remediation of contaminated groundwaters.
Fuel compounds such as benzene,toluene,ethylbenzene,and xylene(a.k.a BTEX)and fuel additives such as
methyl tertiary-butyl ether(a.k.a MTBE)are well-known pollutants that may cause serious environmental and
health issues if not removed from the water before use. BTEX and MTBE are highly mobile and soluble in
groundwater,regulated up to 5 µg/L and 13 µg/L in drinking water','.MTBE is substantially more soluble than
BTEX,sorbs less,is less likely to volatilize out of groundwater,and is less likely to be biodegraded','.For the last
decades,BTEX removal has become a focus as it is toxic and carcinogenic even at low concentrations'.In the
2000s,the United States and Canada banned MTBE use'after a study reported its widespread occurrence in
shallow groundwater'.However,the recent call for reducing carbon emissions appears to favor the increased use
of MTBE,and its production is predicted to continue growing through 2050'.Wide treatment applications have
been applied for MTBE&BTEX remediation,including physical,chemical and biological methods'-15.MTBE
adsorption by activated carbon(AC)was studied,and it found high solubility of MTBE in water is a disadvantage
of granular activated carbon(GAC)adsorption and took around 15 h for total removal".Thermally modified
diatomite was investigated"to adsorb MTBE&BTEX and found the highest adsorption by modified diatomite
'Department of Geosciences,College of Petroleum Engineering&Geosciences,King Fand University of Petroleum
& Minerals, Dhahran 31261, Saudi Arabia. 'Department of Chemistry, King Fand University of Petroleum &
Minerals, Dhahran 31263, Saudi Arabia. 'Saudi Arabian Oil Company, Dhahran, Saudi Arabia. `Department of
Petroleum Engineering, College of Petroleum Engineering &Geosciences, King Fand University of Petroleum &
Minerals,Dhahran 31261,Saudi Arabia. email:[e-mail]
Scientific Reports (2022)'12:-19651 1 https://doi.org/10.1038/s41598-022-24283-6 natureportfolio

www.nature.com/scientificreports/
at 550°C and lower adsorption at 750°C and 950'C.For effective sorption of MTBE on activated carbon,the
AC surface should be tailored to have sufficient small diameter mesopores having pore volumes within the range
of 14-200 A18,19 Achieving these pore size limits suggests reducing the particle size to minute size ranges.Pan
et al.20 reported that AC particle size range of as low as 140 nm is favourable for removing hydrophilic and high
molecular weight organic compounds.Nanomaterials have smaller size ranges and have so far proved effective
in the sorption of many contaminants in pump-and-treat and(field)aquifer remediation21.22.MTBE adsorp-
tion via hydrophobic zeolites(silicalite,dealuminated Y,mordenite,and beta)wasinvestigated23 and found
to perform better than GAC,particularly in the µg/L range.In another study,activated carbon was obtained
from five residues for BTEX adsorption and found low adsorption maybe due to porosity or surface chemical
parameters they contained acid24.Thermally treated lignite at several temperature ranges was studied into batch
adsorption experiment and found effective adsorption of MTBE,BTEX&TAME(tertiary amyl methyl ether)at
lignite 750°C25.Another MTBE removal study by composites of polyacrylamide(PAM)-zeolite than untreated
zeolite and GAC found efficient MTBE treatment26.BTEX adsorption tested by rice husk and found effective27.
Moreover,ordered mesoporous carbon(OMC)proves the high efficiency of BTEX adsorption28.Organo-
sepiolite material was found to be a high-potential adsorbent for BTEX adsorption29.Another study for MTBE
treatment by GAC adsorption found practical and high operation costs compared with air stripping and advanced
oxidation30.Peat and angico hardwood sawdust"showed good potential for BTEX adsorption from produced
water.Ordered Mesoporous Carbon(OMC)32 was found to have 27%higher efficiency than GAC.BTEX adsorp-
tion by montmorillonite modified33 with polyethylene glycol was investigated,and found good adsorption at
200%cation exchange capacity within 24 h.Smectite organoclay for a single-solute system to adsorb Benzene
was investigated and found adsorption in the range of 55-90%adsorption34.BTEX adsorption was investigated
via biochar from palm pits impregnated with ferrous(III)chloride(FeCl3)"and found high adsorption efficiency
with increasing pH,contact time,and adsorbent amount.
Biochar is the solid,porous,carbonaceous material produced by biomass pyrolysis in the temperature range
of 300-800°C36-31 The combination of biochar production conditions,pyrolysis method,and feedstock material
result in distinctively different physical and chemical properties39.These properties control the behavior and
performance of biochar in various applications,such as an additive in soils,soil remediation,and wastewater
treatment40,41 In wastewater treatment,biochar has been mainly used either as a reusable adsorbent of contami-
nants or as a substrate for developing catalysts for the oxidative degradation of organic substances42.Another
interesting study by Date Palm was found a promising adsorbent for many pollutants in aqueous solution43 and
it needs further research for an adsorption-desorption-re-adsorption approach to achieve a zero waste strategy.
The impact of surface modification on the adsorptive removal of BTEX onto solid carbonaceous material was
studied and achieved sorption equilibrium within 30 min44.Adsorption technology on alarge scale is expensive;
alternative low-cost adsorbents draw researchers'attention.Their manufacturing takes around 1-2 days with a
15-120 min adsorption process duration45.Another investigation by sulfonated carbon(SC)using the H2SO4
was found in higher adsorption than mesoporous Carbon synthesized under different hydrothermal ranges46
Moringa Oleifera Seeds and Banana Pee147 were investigated and compared with GAC and found promising
adsorbents.
Similar to nanoparticles,-activated carbons(LAC)are currently being used and investigated as adsorbents
for in situ groundwater treatment.For instance,in 2015,Georgi et al.41 prepared LAC and injected them into
the subsurface to study its mobility within the aquifer.While the mobility depended on the chemical stabilizers
used for making the LAC,the LAC's efficacy in remediating organic contaminants was only demonstrated in a
column batch study—the deposited LAC effect treatment from within the sediment.Within the same year of
Georgi'sresearch,a patent on liquid-activated carbon(P1umeStop')was filed49.The patented liquid AC has a dual
function;working like colloids by adsorbing contaminants as it passes through soil and groundwater after injec-
tion and providing a high surface area matrix favorable for microbial colonization and growth.Intrinsic biodegra-
dation can be further enhanced with the proximal co-application of extended oxygen release for enhanced aerobic
biodegradation.Promising results have also been presented by Mackenzie et al.50 developing LAC impregnated
with zero-valent iron(ZVI)(CARBO-IRON')for dechlorination treatment in an aqueous solution.
Nonetheless,in-situ groundwater remediation is more complicated than just injecting an adsorbent.All
contaminated aquifers are not the same.The differences in geology,transport distribution,contaminant types
and mass,and biological activities in the polluted sites could impact any adsorbent's efficiency and effective-
ness during groundwater remediation".For these reasons,some recent studies were conducted to investigate
P1umeStop products'efficacy to remediate per-and polyfluoroalkyl substances(PFAS)in specific aquifer types
in Canada","and Sweden54.So far,this novel liquid AC product's efficiency for in-situ remediation of organic
contaminants in different locations and different contaminants is still poorly documented.No report was found
for the application of liquid or colloidal AC in the Middle East.Also,neither the manufacturer nor any other
researcher has ever reported the liquid adsorbent's performance when there are multiple contaminants,such as
BTEX and MTBE.Therefore,the objectives of this study are;to examine the efficiency of locally synthesized LAC
and iron-modified LAC(LAC-Fe)on the remediation of both MTBE and BTEX in groundwater;to optimize
at laboratory scale,the treatment parameters such as pH,LAC dose,conductivity,contaminants concentration;
and to investigate the role(s)of the tested parameters on the remediation performance of the LAC in MTBE
and BTEX treatment.
Materials and methods
Synthesis of biochar-based liquid activated carbon (LAC). Palm fibers were locally collected,
cleaned,grinded,and then separated by a sieve to a fine-size of 1-2 mm in diameter.The sieved fibers were then
carbonized at 450°C for 300 min under a flow of nitrogen(99.9%)flow in a stainless steel vertical tubular reactor
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Production temperature(°C) 450
Residence time(min) 300
Total C(%) 86
N(%) 2
O(%) 12
O/C ratio 0.14
Ash content(%) 5
PH 6.5
Conductivity(µS cm-1) 38
Surface area(mz g 1) 786
Total pore volume cm'/g 0.68
Table 1. Biochar characteristics.
placed in a tube furnace.5%hydrogen peroxide(H2O2)solution with a ratio 1:10 wt%,char:H2O2 was added
to the prepared char.The mixture was flushed with nitrogen gas(99.9%)to remove the air and oxygen.After
10 h of stirring,the mixture was filtered.Then,the produced carbon black was further modified with oxygen-
containing groups by the treatment with nitric acid(1.0 M HNO3)in a ratio of 20 mL(HNO3)to 1.0 g Carbon.
The mixture was then heated up to 90°C,kept under reflux,and stirred for 3 h after which it was allowed to
cool down to room temperature.After that,it was filtered and washed with distilled water several times.The
synthesized biochar-based activated carbon was then liquefied by mixing with distilled water at a ratio 1:10 wt%,
then it was sonicated for 1 h.After that,0.5%polyethylenimine was added into the mixture,and the system was
further sonicated for 5 h to obtain liquid activated carbon(LAC).Table 1 below shows the main characteristics
of the biochar.
For LAC modification with iron(Fe),around 10 g of carbon was dispersed in a solution of 150 ml of distilled
water,and 100 ml of ethanol,in the presence of 10 ml of diethylene glycol.After that,the components were kept
under stirring for 8 h.Then,3.4 g of hydrous ferrous(II)sulphate heptalrydrate(FeSO4.7H2O)dissolved in 20 ml
water was drop-wise introduced into the system.Then,8.8 g of ferric(III)chloride hexahydrate(FeC13.61-12O)
dissolved in 20 ml water was added.The system was then kept under stirring for 4 h.After that,pH was adjusted
to>7 using 0.1 M ammonia solution.After that,the temperature was adjusted to 100°C with stirring for 8 h.
Then,the system was allowed to cool.The produced iron-modified carbon was collected.
Chemicals and materials. Benzene(anhydrous,99.8%),(MTBE(p.a.,>99.5%GC),toluene(ACS,99.7%)
compounds were purchased from Sigma Aldrich.ACS (American Chemical Society standards) reagent0.1 M
hydrochloric acid and 0.1 M sodium hydroxide solutions were used for pH adjustment.The Millipore Aquinity
P70 Water Purification System prepared distilled water in the lab.A 1000 ppm stock mixture of the three above
compounds were prepared by dissolving 1.0 gm in 1L distilled water and stirring for 3 h until the compounds
were completely dissolved in the solution.The spiked solutions of 2000 µg/L(or 2 ppm)mixture of MTBE,Tolu-
ene,and BTEX were prepared fresh for every batch of treatment runs by diluting the stock mixture in distilled
water at a ratio of 1:500.Other spiked solutions were prepared in water of different salinity(i.e.,5000 and 10,000
µS/cm).
Three(3)types of host porous materials(sand,limestone,and 1:1 mix)were used in the study to represent
the subsurface material that simulates the condition when LAC is injected in the situ-remediation methods.
Test(Ottawa)sand H-3825 purchased from Humboldt Co.,USA.A bulk-size limestone rock collected from a
local site in Dhahran,Saudi Arabia,was crushed into power-size using a crusher.The limestone crushed sample
was sieved to a size of 1.4<_2 mm.The mixture of OS and LS was prepared by mixing 5 g from each material to
obtain a 50/50 mix.Commercial granular activated carbon(GAC)with a 40/60 mesh less than 2 mm size was
purchased fromGharbalah Industrial Co,Riyadh,Saudi Arabia,and used in the study for comparison purposes.
Apparatus and chemical analysis. The water samples were analyzed according to EPA Method 826055
by Trace GC Ultra ISQ Gas Chromatography/Mass Spectrometry(GC/MS)manufactured by Thermo Scientific.
The GC/MS was equipped with a TriPlus HS headspace analyzer.At each sampling interval,1 mL of the solution
was collected in 5 ml vials and transferred to the GC/MS for analysis.The GC/MS is equipped with a headspace
injection unit where solutions were incubated in agitator for 5 min at 90 °C,then volatile components were
directly injected into the GC column by a headspace syringe heated at 120'C.Restek Rtx-502.2 capillary column
60 m x 0.32 mm x 1.8 µm was used for the separation of volatile components.The GC was programmed at an
initial temperature 40°C for 2 min,then raised from 165°C at a rate of 5°C/min,then raised to 250°C at a rate
of 30°C/min,and holding time of 5 min.The total run time on GC is 35 min.Selected ion monitoring(SIM)
mode was used for the identification and quantitations of the analytes.
Experimental work. For each run,100 mL capped conical beakers filled with pollutants-mix spiked solu-
tion.Ten(10)g of material(OS,LS,and 1:1 OS/LS)were mixed thoroughly with 3 g of LAC&LAC-Fe to prepare
the adsorbents.The prepared materials were added to the spiked solution and shacked in a shaker for around
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-mot
LA
Figure 1. SEM images of synthesized carbons(top),and iron-modified carbon(bottom).
2 h at 150 rpm.Then,1 mL samples were taken from each beaker at 0,10,15,30,45,and 60 min,for analysis by
GC/MS.Initially,the treatment runs were carried out using distilled water at pH 7.The spiked samples were first
stirred for about 1 h to ensure the solubility of the organic pollutants in the water.Blank samples(i.e.,materials
without LAC)were included in the test runs to account for any adsorption(loss)due to the earth materials only.
To assess the effect of pH and salinity,aset of adsorption runs were done at different pH of 4 and 10 and different
EC(conductivity)of 5000 and 10,000 µS/cm,respectively.The brackish waters were prepared by diluting sea-
water(46,200 µS/cm)in distilled water at specific ratios.On the other hand,waters of different initial pH levels
were prepared by adjusting the pH to approximately 4,7,and 10 with HCl and NaOH.
Results and discussion
Characterization of carbons. Figure 1 displays the SEM images of the synthesized carbon and iron-mod-
ified carbon. SEM images of the carbon designate the slides-like shape of the prepared carbon.The surface is
free of any dots or metal particles compared with the iron-modified carbon shown in the SEM images in Fig. 1.
The increase in surface roughness is expected to change the surface properties after introducing iron oxide par-
ticles.Furthermore,the EDX spectra of the carbon and iron-modified carbon are presented in Fig.2.As shown
in Fig.2,the main elements of the prepared carbon are carbon and oxygen,which indicates the presence of the
oxygen functional groups on the carbon surface.At the same time,the EDX spectra of the iron-modified carbon
are presented in Fig.2.In addition to carbon and oxygen,iron is shown,indicating the formation of iron oxide
on the surface of the prepared carbon.
The FTIR spectra of the synthesized carbon and iron-modified carbon are shown in Fig.3a,b,respectively.
The band located at 1000 to 1100 cm-'can be attributed to(-CO)stretching and(-OH)bending vibrations.
The band at around 1450 cm-'can be attributed to(CH2)bending.The bands at about 2920 and 2850 cm-1 are
attributed to the bonds of C-H in CH and CH2 on the carbon structure.The band at about 2300 cm-'is attrib-
uted to the C=N bonds formed due to the treatment of carbon with nitric acid.The spectrum exhibits a band at
=3400-3550 cm-'attributed to OH stretching vibration.The bands between 1720 and 1600 cm-1 are assigned
to carboxylic acids and carbonyl stretching vibration56.The bands appearing between 1450 and 1600 cm-'are
assigned to C=C aromatic from the carbon structures'.The band at about 1085 cm-'is assigned to the Fe-O-C
bonds58.The bands observed at 770 and 890 cm-1 are attributed to Fe-O bending vibrations.The band at 600 cm-1
is owing to the Fe-O stretching vibrations indicating the possible formation of Fe-O-059
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Spectrum 23
1.5
C
1 Au
C
o.
u
0.5
� Au Au
0
n tkeV
0 2 4 6 8
250 N�
Spectrum 20
C
0.2 P-
>
C
a
u 0 Au Fe �
e Fe Au Au
0
0 2 4 6 8 keV
r —-———
250 pm
Figure 2. EDX spectra of synthesized carbons(top),and synthesized iron modified carbon(bottom).
98 (a)
96
94 C-O
92 (b)
e
90
88
E 86 w C-H
= f Fe-O-C
L 84 C-C
H
82
80 OH
78 i
Fe-0
4000 3500 3000 2500 2000 1500 1000 500
Wavenumber(em-1)
Figure 3. FTIR spectra of(a)liquid carbons and(b)iron-modified liquid carbon.
Removal of MTBE, benzene and toluene by uncoated materials(blank run). Figure 4 shows the
removal of MTBE,Benzene,and Toluene,respectively,using natural uncoated materials(limestone(LS),sand
(OS),and 1:1 LS/OS).In general,the results presented in Fig.4 clearly show that the adsorption of the 3 pol-
lutants by the uncoated materials was very low(<20%) compared to adsorption by GAC which reached 80%
for MTBE,95%for Benzene and 90%for Toluene.The MTBE adsorption by LS shown in Fig.4 showed slightly
better removal than other materials in the first 20 min,after which the removal dropped again.This could be
attributed to MTBE's solubility,which may vary during the stirring.Benzene removal was slightly better than
MTBE,with around 20%removal achieved after 60 min for all three types of materials used.Toluene removal
efficiencies showed similar removal efficiencies of Benzene.
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1001,
D
N
50
w
Co
0
0 10 20 30 40 50 60
Time(min)
10D.
v
N
N
50
c
N
N
c
Co 0
0 10 20 30 40 50 60
Time(min)
a
=1
m
v
m
rc 50
m
c
m
0 0
0 10 20 30 40 50 60
Time(min)
0 Blank+GAC 0 Limestone 0 Ottawa 0 Ottawa:Limestone
Figure 4. Removal of 2 ppm MTBE(top),benzene(middle)and toluene(bottom)using 10 gm uncoated
materials and GAC at pH 7,and 150 rpm.
Removal of benzene, MTBE and toluene by different host materials coated with LAC. The
results of MTBE,benzene,and toluene removal efficiencies using unmodified LAC-coated materials(limestone
(LS),sand(OS),and 1:1 LS/OS)are shown in Fig.5.The results presented in Fig.5 clearly show that adsorption
of the three pollutants by the LAC-coated materials were generally low,compared to GAC,but slightly better
(<30%)than the uncoated materials.The main observation from Fig.5 showed that LAC-coated limestoneen-
hancedthe adsorption for MTBE and Benzene.This maybe explains why more LAC has been adsorbed on the
surface of the limestone compared to the solid impervious surface of the sand.On the other hand,the toluene
removal pattern was different than both MTBE and benzene. In fact,the results shown in Fig. 5 revealed an
improved removal efficiency of Toluene when the 3 materials were coated with LAC compared to the uncoated
materials.For example,limestone coated with unmodified LAC increased the removal efficiency of Toluene to
around 62%within 60 min,compared to only 18%when uncoated limestone materials were used,as shown in
Fig.4.
Removal of benzene, MTBE and toluene by earth materials coated with LAC-Fe. Figure 6
shows the removal of MTBE,Benzene,and Toluene,respectively,using LAC-Fe coated materials,limestone(LS),
sand(OS),and 1:1 LS/OS.The results presented in Fig.6 clearly show that the adsorption of the three pollutants
by the LAC-Fe coated materials was generally low(30-40%) compared to adsorption by GAC which reached
80-95%.On contrary to what has been observed in Fig.5,the MTBE adsorption by sand(Fig.6)showed slightly
better removal than other materials. The results indicated that the removal of MTBE slightly increased using
either limestone coated with unmodified LAC or sand coated with LAC-Fe.This behavior could be explained by
the fact that sand has a solid impervious surface compared to the permeable surface of limestone.The surface
charges also play a role in this regard.Similarly,comparing the results of Figs.5 and 6,the benzene removal is
significantly enhanced when limestone is coated with unmodified LAC and when sand is coated with LAC-Fe.
Additionally,Fig.6 showed a higher removal rate of Toluene when using sand coated with LAC-Fe compared to
limestone coated with LAC-Fe,despite that both coated materials reached a similar removal efficiency of 40%
after 60 min.Moreover,results indicated that,in general,a better removal efficiency of Toluene is achieved when
using unmodified LAC-coated materials compared to when using materials coated with Fe-modified LAC.
The effect of pH on adsorption by LAC-Fe coated on mix bed of limestone and sand. In an
attempt to assess the effect of pH on the removal efficiency of the pollutants,several treatment runs at pH 4,and
10 were carried out using the mixture of limestone and sand of ratio 1:1 coated with Fe-modified LAC(i.e.,LAC-
Fe).The results are shown in Fig.7.The results indicate thatchanging the pH from acid to alkaline conditions did
not have a major effect on the performance of the LAC-Fe materials in the adsorption of any of the 3 compounds
(i.e.,MTBE,Benzene,or Toluene),similar with previous studies33,6'-62 The small differences in removal efficien-
cies of the 3 pollutants maybe considered within the experimental error.In general,the mixed material coated
with LAC-Fe achieved higher removal of Toluene(40%)followed by Benzene(30%),and followed by MTBE
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10
m
a
N
50
w
CO
2 0
0 10 20 30 40 50 60
Time(min)
�10
N
0
w 50
C
w
N
C
Co 0
0 10 20 30 40 50 60
Time(min)
UV
�1
a
q
m
rc 50
m
c
m
3
H Q
0 10 20 30 40 50 60
Time(min)
+Blank 0 GAC t Limestone t Ottawa I Ottawa:Limestone
Figure 5. Removal of 2 ppm MTBE(top),benzene(middle)and toluene(bottom)using 10 g materials coated
with 3 g LAC and GAC at pH 7,and 150 rpm.
ION
W
a
50
w
m
F
0
0 10 20 30 40 50 60
Time(min)
a
W1
O �
m
m
50
C
m
N
C
(a 0
0 10 20 30 40 50 60
Time(min)
0
j 10
Nv
m
50
C
v
-
r 0
0 10 20 30 40 50 60
Time(min)
+Blank+GAC+Limestone Ottawa 0 Ottawa1imestone
Figure 6. Removal of 2 ppm MTBE(top),benzene(middle),and toluene(bottom)using 10 gm materials
coated with 3 g LAC-Fe and GAC at pH 7,and 150 rpm.
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45
40 PH 10
PH 4
35 PH 7
30
25
O
E 20
12
is
10
s
0
MTBE Benzene Toluene
Figure 7. Effect of pH on the removal of MTBE,benzene and toluene using LAC-Fe coated mixed bed.
40
35 0 Ns/cm
- 5000 Ns/cm
30 10,000 PS/CM
25
0
20
E
15
10
5
0
MTBE Benzene Toluene
Figure 8. Effect of conductivity on removing MTBE,benzene,and toluene using LAC-Fe coated mixed bed.
with the least removal efficiency of less than 20%.MTBE is less sorptive than Toluene and Benzene,leading to
being less competitive to the sorption sites,and requiring longer treatment time.It should be mentioned that,
unlike Pump&Treat systems,employing AC in real field applications requires longer residence time(weeks-
months).The additional removal of pollutants may have occurred due to the adsorption by LAC-Fe.
The effect of salinity on adsorption by LAC-Fe coated on mix bed of limestone and sand. Fig-
ure 8 presents the results of the treatment runs using spiked water of different salinities.Similar to the treatment
runs done in"The effect of pH on adsorption By LAC-Fe coated on mix bed of limestone and sand"section,the
2 ppm spiked samples were treated with a mix of limestone and sand at a ratio of 1:1 coated with LAC-Fe.The
results showed a slight decrease in the MTBE,Benzene,and Toluene removal efficiency when the water conduc-
tivity was increased from 5000 to 10,000 VS/cm.Nourmoradi et al.33 also reported insignificant effect of salinity
in BTEX adsortion by modifed montmorillonite.This is expected since the increase in salt loading in the brack-
ish water will occupy some of the voids of the particles of the mix and reduces the chances of target compounds
to be adsorped on the surface.
Langmuir and Freundlich isotherm models for selected samples on Benzne and MTBE calculated to test
the efficiency of the adsorbent materials and presented on Table 2.Even though,only five points were used for
each sample,the experimental data were fitted in the Langmuir(monolayer)and Freundlich(heterogeneous
multi-layer)process models.The data were fitted into the Temkin and Dubinin-Radushkevich,however the R2
obtained were both<0.8.
Conclusions
This study demonstrated the utilization of raw and Fe-modified biochar-based liquid activated carbon in remov-
ing selected organic water pollutants(MTBE,benzene,and toluene)coated on different solid materials.Overall,
the removal efficiencies of these compounds using LAC were lower than that achieved by GAC with benzene
and toluene were better removed by LAC and LAC-Fe(—40%)than MTBE(-20%).Moreover,results revealed
that the type of solid materials had a noticeable effect on the removal efficiency of benzene and toluene due to
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Langmuir FIEW
Adsorbent Qm(mg/g) KL(L g') RZ gKr.(mg' g'L")
GAC 0.881 0.023 0.701 17.85 0.005 0.908
Benzene GAC LAC 2.79 0.104 0.479 2.87 1.49 0.829
GAC LAC-Fe 1.841 0.044 0.446 2.28 1.59 0.826
MT 0.0306 8.06.10-7 0.942 0.32 9.57 0.984
Benzene MT LAC 0.355 8.85.10-s 0.919 0.322 10.36 0.979
MT LAC-Fe 0.135 9.53.10-6 0.927 0.17 19.54 0.981
GAC 0.65 1.029 0.548 1.06 2.66 0.856
MTBE GAC LAC 1.12 0.0047 0.591 1.18 2.74 0.871
GAC LAC-Fe 0.838 0.0027 0.595 1.06 2.87 0.879
MT N/A N/A N/A N/A N/A N/A
MTBE MT LAC N/A N/A N/A N/A N/A N/A
MT LAC-Fe 0.017 1.82.10-7 0.992 0.065 49.28 0.998
Table 2. Parameters of the Langmuir and Freundlich isotherm models on benzenze and MTBE.
the low affiinity of MTBE to adsorption.Water salinity and pH effect on the removal efficiency was marginal
and probably within the experimental error.In conclusion,the adsorption by liquid activated carbon need to be
further investigated in terms of enhancing the coating of LAC on the soild substrate,increasing the adsorption
time,varying the concentration for adsorbent and de-sorbent,reusability,and long term performance of the
prepared LAC.Furthermore,the porosity of adsorbent should be identified in order to determined the exact
effect of the porosity size.On sites that have very high contaminat concentrations or where high groundwater
flow velocities may"wash out"LAC,carbon size and concentration should be optimized.These parameters are
currently investigated aiming to enhance the adsorption of benzene,toluene and MTBE using column adsorption
study.It is expected that results of these studies will lead to improve the utilization of liquid activated carbon for
the in-situ remediation of contaminated groundwaters and address a number of challenges in the groundwater
clean-up sector.
Data availability
The datasets used and/or analyzed during the current study are available from the corresponding author on
reasonable request.
Received:21 July 2022;Accepted: 14 November 2022
Published online: 16 November 2022
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Author contributions
Conceptualization,B.T.;methodology,B.S.,T.S.;validation,B.T.,and T.S.;formal analysis,F.A.,T.O.,and E.S.;
investigation,F.A.;resources,B.T.,and T.S.;data curation,F.A.;writing-original draft preparation,F.A.,B.T.,S.T.,
P.S.,P.K.;writing-review and editing,F.A.,B.T.,S.T.,M.A.,S.A.,R.N.,P.S.,P.K.,and M.M.;visualization,F.A.,
B.T.,S.T.and,P.K.;supervision,B.T.;project administration,B.T.;funding acquisition,B.T.All authors have read
and agreed to the published version of the manuscript.
Funding
This research was funded by King Fand University of Petroleum and Minerals(KFUPM)and Saudi Aramco,
grant number CIPR2354.
Competing interests
The authors declare no competing interests.
Additional information
Correspondence and requests for materials should be addressed to B.T.
Reprints and permissions information is available at www.nature.com/reprints.
Publisher's note Springer Nature remains neutral with regard to jurisdictional claims in published maps and
institutional affiliations.
pc Open Access This article is licensed under a Creative Commons Attribution 4.0 International
License,which permits use,sharing,adaptation,distribution and reproduction in any medium or
format, as long as you give appropriate credit to the original author(s) and the source,provide a link to the
Creative Commons licence,and indicate if changes were made.The images or other third party material in this
article are included in the article's Creative Commons licence,unless indicated otherwise in a credit line to the
material. If material is not included in the article's Creative Commons licence and your intended use is not
permitted by statutory regulation or exceeds the permitted use,you will need to obtain permission directly from
the copyright holder.To view a copy of this licence,visit http://creativecommons.org/licenses/by/4.0/.
©The Author(s)2022
Scientific Reports (2022)12:19651 1 https://doi.org/10.1038/s41598-022-24283-6 natureportfolio

Denard, Derek
From: Nikhil Singh <[e-mail]>
Sent: Friday, March 17, 2023 4:57 PM
To: SVC_DEQ.publiccomments
Subject: [External] Colonial Pipeline
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
I am writing this email to place my opinion into public record regarding the permit request from Colonial Pipeline to add a
treatment center to their spill site, clean the fuel from the ground and then deposit the remaining water into our creek
system at the North Prong of Clark Creek. After looking at the permit request, I am very concerned that Colonial Pipeline
will not meet current state standards of water quality for chemicals allowed in our drinking water.
Colonial Pipeline should NOT be allowed to conduct the monitoring. We have seen failures from their ability to monitor the
pipeline itself leading to this massive spill. I reside very close to the spill site and have faced the consequences of the
negligence; Colonial Pipeline is fully responsible for. Colonial Pipeline's lack of urgency and planning has taken years to
remediate the issue, which is still ongoing.
Thank you
Nik
1

Denard, Derek
From: Kathy Stuart <[e-mail]>
Sent: Friday, March 17, 2023 3:11 PM
To: SVC_DEQ.publiccomments
Subject: [External] Colonial Pipeline
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
To Whom It May Concern,
We want DEQ to
•increase the fine for the spill
•lower the acceptable amount of benzene allowed
•have a separate group carefully monitor the spill
•be aware that blasting in granite is happening near the pipeline leak and could cause more damage
•improve Colonial's monitoring of all pipelines
Respectfully,
Kathy Stuart
Sent from Yahoo Mail for iPhone
i

Denard, Derek
From: Juliana Victorine <julianavictorine1 @icloud.com>
Sent: Friday, March 17, 2023 10:39 AM
To: SVC_DEQ.publiccomments
Subject: [External] Pipeline
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
I am writing this email to place my opinion into public record regarding the permit request from Colonial
Pipeline to add a treatment center to their spill site, clean the fuel from the ground and then deposit the
remaining water into our creek system at the North Prong of Clark Creek. After looking at the permit
request, I am very concerned that Colonial Pipeline will not meet current state standards of water quality
for chemicals allowed in our drinking water. Also, I am concerned that the amount of water and
particulate will add a significant volume to the creek system. We have not been given an explanation of
the size and scope of the treatment building on site and what sound and eye sore issues may arise. At a
minimum the permit should not be granted without the following improvements to the permit requirements
1. Add technology based discharged limits to the wastewater permit. Particularly for the
known carcinogen benzene found in gasoline. The current effluent limitation in the draft is 5 times higher
than the water quality standard for benzene.
2. Reduce the daily flow limit. The proposed flow limit of 500,000 gallons per day is almost 20
percent of the natural flow of the receiving stream, the North Prong of Clark Creek.
3. Strengthen water quality based limits
4. Account for background levels of contamination when developing permit limits.
5. Require monitoring, disclosure and treatment of PFAS
6. Require instream monitoring for hazardous constituents in gasoline downstream from the
discharge outfall.
I also feel there should be independent company that over sees the Colonial Pipeline through the process to make sure
they are meeting all proper procedure and to do all the testing. Colonial Pipeline should not be allowed to conduct the
monitoring. We have seen failures from their ability to monitor the pipeline itself leading to this massive spill.
Juliana Victorine
Sent from my iPhone
i

Denard, Derek
From: Scott Woodbury <[e-mail]>
Sent: Friday, March 17, 2023 4:37 PM
To: SVC_DEQ.publiccomments
Cc: Hennessy, John; Denard, Derek; Sen. Natasha Marcus; Lisa Woodbury
Subject: [External] COLONIAL PIPELINE NPDES Permit#NC0090000
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
To Whom It May Concern -
My family and I live in the Mirabella neighborhood, less than a half a mile west of the spill site along Huntersville-
Concord Road. I attended the public hearing last night and I am writing to place my opinion into the public record and
echo the sentiments of Senator Marcus,the Southern Environmental Law Center, the Yadkin Riverkeeper, and other
members of the community who have expressed concerns that Colonial Pipeline will not meet current state standards of
water quality for chemicals allowed in our drinking water based on the language in the draft permit. At a minimum the
final permit requirements should not be granted without the following improvements to the draft permit:
1. Add technology based discharged limits to the wastewater permit, particularly for benzene.The current effluent
limitation in the draft permit is 5 times higher than the water quality standard for benzene.
2. Reduce the daily flow limit.The proposed flow limit of 500,000 gallons per day is almost 20 percent of the
natural flow of the receiving stream,the North Prong of Clark Creek.
3. Strengthen water quality based limits in the final permit.
4. Account for background levels of contamination when developing final permit limits.
5. Require monitoring, disclosure and treatment of PFAS
6. Require instream monitoring for hazardous constituents found in gasoline downstream from the discharge
outfall. A pre-discharge test should be conducted for a baseline so future test values can be compared to the
baseline once the discharging begins.
7. Require additional controls and maintenance conditions to the installed equipment to ensure the equipment is
always operating at optimal levels.
While I understand the proposed limits for testing, concentrations of pollutants in the water, etc. meet the existing state
requirements,this is a historical spill that should require additional testing and requirements much more than the
minimum standards. In addition, if the spill and clean-up process has taught us anything, it's that Colonial Pipeline is not
to be trusted to adequately oversee and report on the extended cleanup operations. There should be an independent
company that oversees through the process to make sure Colonial is performing all the testing, appropriately following
the testing procedures, and reporting the raw results of the testing. Furthermore, so as to not burden the state with
more unexpected costs, Colonial should be required to pay for this additional oversight and testing based on their
inability to meet previous testing requirements during the clean-up process.
I attended the public hearing last night and was appalled to hear during the brief presentation done by NCDENR, the
state was concerned about the amount of money Colonial would have to spend by doing an option different than the
one proposed in the permit. While I understand the method selected is preferred and the "best" of the options to clean-
up the spill, state officials should not be deterred from imposing additional requirements based on potential financial
implications to Colonial -that is irresponsible and immoral as a state official.
i

As a neighbor to the spill site, it is concerning that the public has not been given any idea of what the system will look
like other than it will be contained in a 9,000sf footprint. This is something we will be living next to and we have not
seen any drawing or rendering of what this system will look like, sound like, or any other physical properties of the
system. Additionally, during the presentation the presenter indicated that Colonial proposed a landscaping buffer to
hide the structures that will be installed and a computer generated graphic was depicted showing the initial plantings
and another image depicting what the plantings would look like in 5 years. I encourage NCDENR to require as a
condition of the permit a significant evergreen buffer, of particular diameter and growth when installed,to shield the
structures from the roadway and neighboring homes. The plantings should be mature enough so as to shield the
structures from day 1, not 5 years down the road as was the insinuation during the presentation.
From the beginning, Colonial Pipeline has been dictating the narrative and yet to be held fully accountable for the
spill. They have failed to adequately quantify the extent of the spill, mitigate its effects, and perform their duties under
the requirements of the law, as evidenced by the numerous Notice of Violations. As such, Colonial Pipeline should not
be given any further reprieve through what is generally an insufficient draft permit. The civil penalties levied against
Colonial were far too lenient and they should not be given a similar slap on the wrist in regards to permit requirements;
they should be held to much higher standards than the ones currently contained in the draft permit. Not only has this
spill done irreparable damage to the ecosystem, but it has also affected many other facets of life for neighbors in the
area, including health concerns, property values, etc. As a member of the public stated last night, I encourage the
NCDENR staff members reviewing and approving the final permit to look at this through the lens of the neighbors who
have been living next to this disaster for the last 3 years; put yourself in our shoes when considering the requirements of
the final permit and levy much stricter requirements on Colonial.
Thank you for your time and I strongly urge you to hold Colonial to much higher requirements than what is contained in
the draft permit.
Stephen "Scott" Woodbury
Scott Woodbury
Ph: 678.521.6567
E-mail: [e-mail]
z