NC0063029_Correspondence_20230714

From: Chernikov, Sergei
To: "Voorhees CIV Travis P"; King, Morella s
Cc: Richard CIV Thomas S; Straub CIV Daniel R; Towler CIV David W; Whited CIV Steven J; Turner CIV Misha G;
Lowder CIV Robert A; Williams CIV Scott R
Subject: RE: [External] RE: Draft Major Modification NCO063029
Date: Friday, July 14, 2023 2:12:00 PM
Travis,
Please see my responses below.
Thank you!
Sergei
Good afternoon Mr. Chernikov,
Please see our comments and questions on the draft NPDES Permit Mod (NC0063029) and Fact Sheet below and
attached. If you could confirm receipt of this email once you receive it that would be greatly appreciated. Please let
us know if you have any questions. Thank you.
Fact Sheet:
1. Page 2, 1st paragraph: Change sentence to "The modification is necessary to incorporate a waste stream from
two (2) mobile PFAS treatment systems." - I will make a correction.
2. Page 2, 4th paragraph: Change "MCP CAMLEJ" to "MCB CAMLEJ". - I will make a correction.
3. Page 3, Table 2: Remove or add missing portion "(On" from "Basis for Condition/Change" column. - I will
make a correction.
Draft Permit:
1. Page 10, Section A(8):
a. We request that this restriction be removed or revised to address the systems established under A (9) and
A(12), as it contradicts these sections. Groundwater remediation wastewaters will be treated for PFAS to below 70
parts per trillion (ppt) in batches and discharged finally through Outfall 001. - I will remove this restriction.
2. Page 10, Section A(9):
a. We request that the 60 day notification period be reduced to 15 or 30 days to minimize the delay of
remediation activities. I will make a change to 30 days.
b. What entities does "... or any other Local, State or Federal regulatory established level" refer to? Onslow
County, the State of North Carolina, and the US EPA? Can specific entities be listed here? - This is a standard
language that we use in all our permits, it refers to all state, local, and federal authorities.
3. Page 13, Section A(12):
a. There are two separate PFAS treatment systems and therefore two internal outfalls that will be going through
Outfall 001. Language throughout the permit should be adjusted to reflect this, unless "Internal Outfall 002" is
meant to represent multiple internal outfalls. - I will make a correction.
b. We request that the "40 Applicable PFAS compounds" be individually identified, with their full name,
abbreviation, and CAS# listed to reduce ambiguity. - This is a standard language that we use in all our permits. The
EPA already published this rule that lists all 40 compounds and laboratories are familiar with this rule.

C. Request changing Measurement Frequency from "Quarterly" to either "Intermittently" or "Prior to batch
discharge" for PFOA + PFOS and the other applicable PFAS compounds, as these discharges will be in batches and
not continuous. There may be quarters where no discharging is going to occur. - This frequency is recommended by
EPA. If the system does discharge during a given quarter, you will report "no flow" on the DMR. This is a standard
procedure for all facilities that discharge intermittently.
d. Request changing the Sample Locations for PFOA + PFOS and the other applicable PFAS compounds from
"Effluent" to "Internal Outfall 002". We were unsure if "Effluent" referred to effluent from the PFAS treatment
systems or effluent from the WWTP. - Effluent in this case is Outfall 001 effluent, I will transfer this requirement
for 40 PFAS compounds analysis to Outfall 001. The Division needs information on the external outfall.
e. Request changing Footnote #2 to read "The analysis shall be conducted prior to discharging from Internal
Outfall 002." - The footnote will be eliminated since the requirement will be transferred to Outfall 001.
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]
-----Original Message -----
From: Voorhees CIV Travis P <travis.voorhees(i�usmc.mil>
Sent: Friday, July 14, 2023 1:45 PM
To: Chernikov, Sergei <sergei.chemikov(i�deq.nc.gov>; r4npdespermits (r4npdespermits(i�epa.gov)
<r4npdespermits(i�epa.gov>; King, Morella s <morella.sanchez-king�deq.nc.gov>; Kinney, Maureen
<[e-mail]>; Meadows, Susan <[e-mail]>; Thedford, Wren
<wren.thedford(adeq.nc. gov>
Cc: Richard CIV Thomas S <thomas.richard(i�usmc.mil>; Straub CIV Daniel R <daniel.straub(i�usmc.mil>; Towler
CIV David W <david.towler(i�usmc.mil>; Whited CIV Steven J <steven.whited(i�usmc.mil>; Turner CIV Misha G
<misha.tumer(i�usmc.mil>., Lowder CIV Robert A <robert.a.lowder(i�usmc.mil>; Williams CIV Scott R
<scott.r.williamsl (i�usmc.mil>
Subject: [External] RE: Draft Major Modification NC0063029
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