NC0003816_More Information (Requested)_20190813

ROY COOPER
Governor u' I rI.
MICHAEL S.REGAN
Secretary �!� !
LINDA CULPEPPER
Interim Director NORTH CAROLINA
Environmental Quality
August 13, 2019
Mr. George W. Radford
Environmental Affairs Officer
PSC Box 8006
Cherry Point,NC 28533-0006
Subject: Request for Additional Information
NPDES Application NC003816
MCAS Cherry Point WWTP
Dear Mr. Radford:
The Division has reviewed your application for the subject permit. To enable us to complete our
review in accordance with N.C.G.S. 143-215.1 and 15A NCAC 2H.0105,please provide additional
or revised information to address the following comments:
1. Since your submitted flow diagram dated August 1, 2019 shows that additional pollutants
(PFOS/PFOA) are being discharged to Cherry Point WWTP,the Permittee needs to amend
their NPDES renewal application. The amended application should identify the additional
pollutants discharged from each AFFF Systems and Treated AFFF including CAS No.'s
of each PFOS/PFOA compound detected and the estimated or measured concentrations
being discharged to the WWTP. In addition, the Permittee needs to indicate the estimated
or measured concentrations of such pollutants in the effluent of the WWTP and clarify
whether both locations are connected in series.
2. The amended application should describe the AFFF systems and the treatment provided to
reduce PFOS/PFOA compounds in the discharge including the treatment design capacity
and expected concentration levels to be achieved in the effluent. Also, provide schematic
diagram of the treatment system.
3. All treatment works receiving discharges from RCRA, CERCLA or other remedial wastes
must respond to questions F 13 through F 15 in the renewal application Form 2A under the
Supplement Application Information Part F (Industrial User Discharges and
RCRA/CERCLA Wastes). Submit your response to such questions for each remediation
system in the amended application. Also, provide schematic diagram of each treatment
system.
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North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh,North Carolina 27699-1617
919.707.9000

4. Submit a flow diagram showing all influent flow sources to the WWTP. Influent flow
volumes in Million Gallons per Day(MGD) and percentage of total influent flow of each
source to WWTP shall be identified in the diagram.
5. Part D (Expanded Effluent Testing Data) of the NPDES Form 2A Application states that
"If the treatment works has a design flow greater than or equal to 1.0 MGD or it has (or is
required to have) a pretreatment program, or is otherwise required by the permitting
authority to provide the data, then provide effluent data for the following pollutants.
Provide the indicated effluent testing information and any other information required by
the permitting authority for each outfall through which effluent is discharged". Your
submitted application is only reporting the pretreatment effluent concentrations for
Cadmium, Chromium, Lead, Nickel and Cyanide. Please indicate in your amended
application the effluent data from the WWTP for such pollutants. Also, please note that if
the sample results are below the detection limit,the Permittee is required to report it as Not
Detected (ND) or less than detection level, not as Zero.
Please respond by October 16, 2019 [per 15A NCAC 2H.0107(b)]. If you have any questions,
please contact me at 919-707-3607 or email at [e-mail].
Sincerely,
Qais Banihani, Environmental Engineer
NPDES Complex Unit
Division of Water Resources/NCDENR
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North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh,North Carolina 27699-1617
919.707.9000