WQ0002503_GW Report Comments 5-14-19_20190521

NORTH CAROLINA
Environmental quality
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary May 21, 2019
LINDA CULPEPPER
Director
Mr. Chris Barnes
Frit Car, Inc.
Post Office Box 569
Bridgeton, North Carolina 28519
RE: Groundwater Evaluation Report Comments
Frit Car, Inc.
Bridgeton, Craven County, North Carolina
Permit No. WQ0002503
Dear Mr. Barnes:
The Washington Regional Office Water Quality Regional Operations Section has reviewed
the report of groundwater conditions at the above referenced facility, received by this office on
April 29, 2019. The report was prepared in response to an August 25, 2016 Notice of Violation
(NOV) issued to Frit Car, Inc. from this office and to satisfy the requirements of 15A NCAC 2L
.0106(d). Several items in the report require additional clarification or further investigation. They
are as follows:
1. The report presents the groundwater data collected at the facility since 2017; however, no
interpretation of the data was offered. If Frit Car, Inc. wishes this office to consider site
specific groundwater background concentrations, the report should be revised to propose
them accompanied by a discussion supporting the method used to develop the background
concentrations. This work should be performed by a North Carolina licensed geologist.
2. Background values for naturally occurring constituents should be developed using
samples from areas outside any potential impacts or influence from activities at the subject
facility. Based on the potentiometric maps included in the report, the proposed background
locations (Temporary wells 1 through 3) were located down gradient of the wastewater
spray field. Based on their locations, the subject wells may not allow samples to be
collected from areas that would be considered truly representative of background
conditions. The report should be expanded to include justification for the background
locations.
--7
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North Carolina Department of Environmental Quality IDivision of Water Resources - Washington Regional Office
943 Washington Square Mall, Washington, North Carolina 27889
252-946-6481

Mr. Chris Barnes
May 21, 2019
Page 2 of 2
3. The data for Temporary wells I through 3 presented in Table 2 exhibited significant
increases in the concentrations of chromium, iron, and lead during the latter two sampling
events of 2018, when compared to the initial sampling event. Does Frit Car, Inc. have any
explanation of this wide variation in concentrations?
4. Table 1 shows increases in concentrations of chromium detected in monitoring wells MW 1,
MW2, and MW3 generally during the time period from 2013 to 2017 which appears to
correlate with increases in chromium concentrations in the wastewater effluent during the
same time period (see the attached graph). Has Frit Car, Inc. considered this relationship
as part of their groundwater evaluation?
5. The January 30, 2018 report from CFM(POLY) stated that Frit Car, Inc, would collect data
on the iron concentration in the wastewater effluent as part of their investigation. Has this
data been collected? If so, the report should be revised to include it.
Please address the comments above and provide a revised report to this office within 90
days of receipt of this letter. Additionally, please note further action may be required based on
further assessment, findings, and evaluation. Thank you for your continued cooperation. Should
you have any questions concerning the contents of this letter, please contact me at [phone].
cc: WaRO
Sincerely,
DW'Zj' "'` "541
Dwight Randy Sipe P.G., Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality IDivision of Water Resources - Washington Regional Office
943 Washington Square Mall, Washington, North Carolina 27889
252-946-6481