NC0063029_Comments_20230628

Baker, Caroline D
From: Chernikov, Sergei
Sent: Wednesday, June 28, 2023 1:20 PM
To: Lopez, Leann
Cc: Holliman, Daniel; Wahlstrom-Ramler, Meghan
Subject: RE: [External] Camp Lejeune (NC0063029) Comment Letter
Attachments: BOILER PLATE 11-9-2011.pdf
Leann,
Thank you for comments! Please see my responses below:
1. The DWR has no institutional capacity to develop robust legally defensible TBELS in accordance with the EPA
Guidance. The TBEL limits developed for Chemours used a very simplified procedure that omits numerous
components that are necessary for an appropriate BPJ BAT and it is not likely to be defensible in court.
Chemours has decided not to challenge the simplified TBEL procedure for a variety of political and legal reasons.
However, these reasons are not applicable to other permittees.
2. The DWR already has the authority to re -open any permit and implement more stringent limits, this is specified
in the attached Standard Conditions (please see attached) , which are included in every permit we issue. There is
no need to reiterate this provision in the permit. When EPA promulgates national criteria for any of the PFAS
compounds, the Division will implement these criteria. At this point, the EPA has not issued any legally -
enforceable criteria for surface waters.
3. The Division would also greatly appreciate if EPA promulgate PFAS TBELS for OCPSF facilities.
Best regards,
Sergei
Sergei Chernikov, Ph.D.
Environmental Engineer III
Industrial NPDES Permitting Unit
NEW Tel. [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617
Express Mail: 512 N. Salisbury St., Raleigh, NC 27604
NEW E-MAIL:[e-mail]
From: Lopez, Leann <Lopez.Leann @epa.gov>
Sent: Wednesday, June 28, 2023 1:06 PM
To: Chernikov, Sergei <[e-mail]>
Cc: Holliman, Daniel <Holliman.Daniel @epa.gov>; Wahlstrom-Ramler, Meghan <[e-mail]>
Subject: [External] Camp Lejeune (NC0063029) Comment Letter
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Good Afternoon Mr. Chernikov,

Region 4 appreciates the opportunity to review the draft modification to the Camp Lejeune (NC0063029) National
Pollutant Discharge Elimination System (NPDES) permit. Please see our questions and comments below:
1. In a previous NPDES permit, North Carolina used a 99% removal efficiency to determine the limits for several
different PFAS compounds. North Carolina could consider determining the removal capabilities of the Camp
Lejeune treatment system and then ultimately explore the possibility of a Technology Based Effluent Limit
(TBEL). Depending on the removal efficiency, North Carolina should compare this to the proposed limit of 70
ng/L (drinking water health advisory) and implement whichever is more stringent.
2. EPA is committed to advancing science to protect public health from the risks of exposure to certain PFAS. As
such, EPA could publish new health advisories or promulgate new limits in the future based on updated
information. NC should include language in the permit that states that they will update the PFAS limits to reflect
EPA's new advisories or limits, if that new criteria is more stringent than what is implemented in this permit.
If you have any questions about the comments, I can be reached via email at [e-mail] or by phone at (404)
562-9288.
Thank you,
LeAnn Lopez Life Scientist
EPA Region 4 Water Division I NPDES Permitting Section
61 Forsyth Street I Atlanta, Georgia 30303
[phone] 1 [e-mail]