DEQ-CFW_00075290

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FOUNDED 1897
August 4, 2017
Michael S. Regan, Secretary
N.C. Department of Environmental Quality
1601 Mail Service Center
Raleigh, NC 27699-1601
S. Jay Zimmerman, Director
NC DEQ, Division of Water Resources
1611 Mail Service Center
Raleigh, NC 27699-1611
2000 RENAISSANCE PLAZA
230 NORTH ELM STREET
GREENSBORO, NC 27401
T 336.373.8850
F 336.378.1001
WWW.BROOKSPIERCE.COM
Re: Request for Interim Maximum Allowable Concentrations for
Perfluorinated Compounds in Groundwater
Gentlemen:
We are environmental counsel for the Cape Fear Public Utility Authority ("CFPUA").
The discharge of various perfluorinated compounds by the Chemours Fayetteville Works
facility into the Cape Fear River has resulted in those compounds contaminating the source water
that is withdrawn, treated and distributed by several public drinking water supply systems,
including the CFPUA, and various corporate operators over many years. The North Carolina
Department of Health. and Human Services (NCDHHS) continues to review materials and revise
toxicological and epidemiological findings about the effects of those perfluorinated compounds
on the citizens of the State of North Carolina and the natural environment.
In addition to the use of Cape Fear River source for drinking water, those waters distributed
to citizens and industry have been used for agricultural irrigation, car washing, system
maintenance, residential lawn and garden hoses, well drilling fluids, etc. over decades. The many
uses of water have resulted in the natural percolation of water downward to groundwater. In
addition, CFPUA's Aquifer Storage and Recovery Well stores treated drinking water from the
Cape Fear contaminated by the discharges under NPDES NC0003573.
North Carolina Administrative Code (15A NCAC 02L.0202(c) provides for establishment
of health based groundwater Interim Maximum Allowable Concentrations (IMACs). An IMAC
has already been established for PFOA and PFOS compounds that are similar to GenX and'the
other perfluorinated compounds now being found in the Cape Fear. CFPUA requests that the
Secretary and/or the Director prioritize and establish groundwater IMACS for all perfluorinated
compounds discharged under NPDES NC0003573.
DEQ-CFW 00075290

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Sincerely,
orge . House
V. Randall Tinsley
Joseph A. Ponzi
AUG 15 c017
DEQ-CFW 00075291