NC0024881_SOC (application),_20200508

-�. jReidsviile
NORTH CAROLINA
230 W.Morehead Street • Reidsville,North Carolina 27320 • [phone] • Fax[phone]
May 4, 2020
RECEIVED
Mr.Jeff Poupart MA' p 8 2020
North Carolina Division of Water Resources
Water Permitting Section Chief NCDEQIDWRIN DES
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
32 oo3
R.E. City of Reidsville
Special Order by Consent (SOC)Application
Reduction of 1,4-Dioxane
Reidsville WWTP
NPDES Permit NC0024881
Rockingham County
Dear Mr. Poupart:
The City of Reidsville, in response to written communication, meetings, discussions, communication and
contact with you and others at the Division of Water Resources (DWR) and the Department of
Environmental Quality(DEQ), submits the attached Special Order by Consent Application Package
relative to the goal of reducing 1,4-Dioxane in our WWTP discharge. We have included our application
fee of$400.00 and a resolution, as required,from our City Council authorizing application for an SOC.
As you know, the City, in consultation with DEQ-DWR, has been evaluating a mutually acceptable path
toward the progressive reduction of 1,4-Dioxane in our plant's effluent. The City identified a Judicial
Order by Consent (JOC) as an appropriate instrument and discussed that with DWR and DEQ several
times. The Division and the Department determined that they would not participate in a JOC process.
To reflect our continued interest and good faith commitment in finding mutually acceptable actions and
a timeline for achieving them, we submit this SOC Application for your consideration. However, as
measures addressing the pandemic have deferred and delayed both the City's and the State's activities
to bring this matter to resolution, we believe it may be appropriate to reconsider the value of a JOC as a
vehicle, which will achieve our mutual goals considerably more expeditiously than an SOC.
We have made it clear that the City supports the view that 1,4-Dioxane is a pollutant of concern and
that it should be addressed. We remain committed to reducing 1,4-Dioxane in our WWTP effluent.
"Live Simply. Think Big.

Relative to actions and schedule, the SOC Application provides a slate of milestones we believe to
represent a reasonable set of actions. However, the information that we have sought since our initial
meeting following the November 18, 2019 NOV, and subsequently in a public records request, is critical
to properly assess whether those actions are appropriate and necessary. We appreciate the partial
response to our request for information provided by you via email on March 4, 2020, but we continue to
seek the additional information requested. The request seeks to secure understanding of the
framework and principles that DWR is using to address this chemical. We look forward to receiving this
information and welcome the opportunity to discuss an appropriate list of actions and the timeline
necessary to achieve the actions identified. The requested information and DWR's support and
technical assistance are essential to our being able to effectively achieve reduction goals that will
ultimately be included in an approved order. Because it is not technologically appropriate, feasible, or
economic to address 1,4-Dioxane reduction at the City's WWTP, it is critical to have a clear and well-
established basis for the reduction goals identified so the City can secure appropriate pretreatment
requirements for the industrial users in our system. We continue to seek DWR's support, help and
technical assistance as we work with our industrial users.
The City continues its work to reduce 1,4-Dioxane and to assess the sources and evaluate reduction
option available. The City maintains ongoing engagement with its industrial users that have
demonstrated the potential to contain 1,4-Dioxane in their process and in their wastewater discharges
to the City's collection system. We have and will continue to seek direct actions from our sewer users to
better manage their operations and to reduce 1,4-Dioxane in their wastewater. The City's efforts to find
the most appropriate route to establishing a set of actions and a schedule for completing these actions
reflects our ongoing commitment to making progress on this important issue. The City acknowledges
the concerns of the Division, Department, downstream water users, public interest groups, and the
general public about the potential environmental impacts of this chemical on North Carolina waters.
The City also has communicated the significant technological, practical, and economic challenges faced
in addressing 1,4-Dioxane. In our engagement with the Division, DWR staff have acknowledged these
challenges and has stated that the Division recognizes the considerable effort required to take
comprehensive action to progressively reduce the concentrations of 1,4-Dioxane in our WWTP's
permitted discharge.
Please note that we have made every effort to provide complete and detailed responses to the SOC
application questions. However, the objective of reducing 1,4-Dioxane is significantly different than the
typical WWTP improvements project for addressing conventional pollutants that the form and
application was designed to address. The goals we have outlined in the application are based on making
reductions at the industrial user source. It is our general understanding that DWR is taking a similar
path at other situations involving the reduction of 1,4-Dioxane. As a result, we have not provided a
detailed evaluation of the treatment process at our WWTP. The reduction of 1,4-Dioxane in a municipal
biological treatment facility is not demonstrated or feasible based on the chemical behavior of 1,4-
Dioxane in water. We have provided an abbreviated statement certified by our consulting firm that the
treatment system is not capable of reducing 1,4-Dioxane and that control of this parameter will have to
come through application of the City's approved Pretreatment Program. We have noted that there are
specific implementation issues we will have to deal with in putting pretreatment requirements in the

selected industrial sources. These realities could have significant scheduling impacts as discussed in the
attached application.
We anticipate that we will need to confer and collaborate on the development of a final set of actions
and a schedule that is mutually acceptable. Following your receipt of the application we will be glad to
schedule a conference call to review the material provided and discuss the steps needed to move
toward the development of a draft order the City can review and discuss with DWR.
We appreciate your consideration and time. Please let me know if you have any questions.
Sincerely,
John M. "Jay" Donecker,
Mayor
City of Reidsville
Cc: Mr. Danny Smith, DWR Director, [e-mail]
Mr.Jay Zimmerman, [e-mail]
Mr.John Hennessy, [e-mail]
DEQ General Counsel Office:
Mr. Drew Hargrove, drew.hargrove([e-mail]
Winston-Salem Regional Office Staff:
Mr. Lon Snider, [e-mail]
Ms.Jenny Graznak, [e-mail]
City of Reidsville:
Preston Mitchell, City Manager,[e-mail]
Chuck Smith, [e-mail]
Ben Bani, [e-mail]
Chris Phillips, [e-mail]
Craig Bromby, [e-mail]
Forrest Westall, [e-mail]

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
APPLICATION FOR SPECIAL ORDER BY CONSENT(SOC)
I. PERMIT RELATED INFORMATION:
1. Applicant(corporation, individual, or other): The City of Reidsville
2. Print or Type Owner's or Signing Official's Name and Title:
Preston Mitchell,City Manager
3. Facility Name (as shown on Permit): Reidsville Wastewater Treatment Plant
(WWTP)
4. Owner Phone: [phone] (or)
5. Owner Email: [e-mail]
4. Application Date:
5. NPDES Permit No. (if applicable):_NC0024881
6. Name of the specific wastewater treatment facility(if different from 13. above):
Same as item 3
II. PRE-APPLICATION MEETING:
Prior to submitting this completed application form, applicants must meet with the appropriate
regional office staff to discuss whether or not an Order is appropriate for this situation. Please
note the date this meeting occurred and who represented the permittee: Representative: City
Manager,Staff and Other Representatives— Date: _December 16, 2019, January 8,
2020 (conference call),January 28,2020 and numerous contacts and discussions via phone,
direct contact and email
III. ADDITIONAL FLOW OR FLOW REALLOCATION: City's Response: Not
Applicable(N/A—Not Applicable)
In accordance with NCGS 143-215.67(b), only facilities owned by a unit of government may
request additional flow.
Additional flow may be allowed under an SOC only in specific circumstances. These
circumstances may include eliminating discharges that are not compliant with an NPDES or
Non-discharge permit. These circumstances do not include failure to perform proper

maintenance of treatment systems, collection systems or disposal systems. When requesting
additional flow, the facility must include its justification and supporting documentation.
If the requested additional flow is non-domestic, the facility must be able to demonstrate the
ability to effectively treat the waste and dispose of residuals. The applicant must provide a
detailed analysis of the constituents in the proposed non-domestic wastewater.
The total domestic additional flow requested: gallons per day.
The total non-domestic additional flow requested: gallons per day.
The total additional flow(sum of the above): gallons per day.
Please attach a detailed description or project listing of the proposed allocation for additional
flow, with an explanation of how flow quantities were estimated. Further, any additional flow
requested must be justified by a complete analysis, by the permittee, that additional flow will not
adversely impact wastewater collection/treatment facilities or surface waters.
IV. NECESSITY NARRATIVE:
Please attach a narrative providing a detailed explanation of the circumstances regarding the
necessity of the proposed SOC. Include the following issues: Attached
• Existing and/or unavoidable future violations(s) of , N/A.s permit conditions or limits(s),( )
The City seeks to reach agreement on an order that would set out steps and a
schedule for making reductions in 1,4-Dioxane levels in its WWTP discharge.
There are no permit limits for 1,4-Dioxane in the City's NPDES permit.
• The existing treatment process and any process modifications that have been made to
date to ensure optimum performance of existing facilities, N/A. The Reidsville WWTP
is a standard municipal suspended growth biological treatment system. This
treatment system cannot provide effective treatment of 1,4-Dioxane.
• Collection system rehabilitation work completed or scheduled (including dates), N/A.
Collection system rehabilitation work is not a factor in dealing with this chemical.
• Coordination with industrial users regarding their discharges or pretreatment facilities.
Identify any non-compliant significant industrial users and measure(s) proposed or
already taken to bring the pretreatment facilities back into compliance. If any industrial
facilities are currently under consent agreements, please attach these agreements, The
City has communicated with their industrial users going back to 2015.
Documentation is available showing the City's efforts to notify their users of
concerns about 1,4-Dioxane. The City has identified specific industrial users that
discharge 1,4-Dioxane to the collection system. As the City's NPDES permit doesn't
have limits on this chemical, the identified sewer users do not have limits in their
pretreatment permits. The City is committed to developing appropriate
pretreatment permit limits for 1,4-Dioxane to implement the reduction levels
resulting from an order based on this application.
• Date and outcome of last Industrial Waste Survey. The City of Reidsville submitted an
Industrial Waste Survey (IWS) to NCDEQ-DWR Pretreatment Staff on May 28,
2

2019. Over 9 industrial users were contacted, surveyed, and/or visited during the
process. Five industrial dischargers were identified for further follow-up activities
(Wastewater Permit Application submittal, on-site visits, etc.) to determine if they
meet the EPA definition of a Significant Industrial User.
• Whether or not the facility is acting as a regional facility receiving wastewater from other
municipalities having independent pretreatment programs. N/A.
V. CERTIFICATION:
The applicant must submit a report prepared by an independent professional with expertise in
wastewater treatment. This report must address the following: This provision of the
application was developed for typical municipal biological wastewater treatment systems.
The parameter of concern here, 1,4-Dioxane is not effectively treated by municipal systems.
We have provided a simple statement of this fact and certification from our consultant that
the statement provided reflects the realities of the City's approach to reducing 1,4-Dioxane
in its effluent. See attached statement.
• An evaluation of existing treatment units, operational procedures and recommendations
as to how the efficiencies of these facilities can be maximized. The person in charge of
such evaluation must sign this document.
• A certification that these facilities could not be operated in a manner that would achieve
compliance with final permit limits. The person making such determination must sign
this certification.
• The effluent limits that the facility could be expected to meet if operated at their
maximum efficiency during the term of the requested SOC (be sure to consider interim
construction phases).
• Any other actions taken to correct problems prior to requesting the SOC.
VI. PREDICTED COMPLIANCE SCHEDULE:
The applicant must submit a detailed listing of activities along with time frames that are
necessary to bring the facility into compliance. This schedule should include milestone dates for
beginning construction, ending construction, and achieving final compliance at a minimum. In
determining the milestone dates, the following should be considered: Construction is not a
component of an order to address the issues outlined in this application. See Attached.
• Time for submitting plans, specifications and appropriate engineering reports to DWR for
review and approval. N/A. As noted, 1,4-Dioxane is not a chemical that can be
treated in a standard municipal wastewater treatment system. There are no known
technologies that can be applied at the appropriate scale to treat the entire WWTP
flow level. 1,4-Dioxane must be addressed at the industrial user level. Timelines for
achieving reduction goals must include not only the time for setting pretreatment
requirements, but also the time needed to put them in place and for the collection of
confirmation data.
• Occurrence of major construction activities that are likely to affect facility performance
(units out of service, diversion of flows, etc.)to include a plan of action to minimize
impacts to surface waters. N/A
3

• Infiltration/Inflow work, if necessary. N/A
• Industrial users achieving compliance with their pretreatment permits if applicable. See
attached information addressing a proposed compliance schedule.
• Toxicity Reduction Evaluations(TRE), if necessary.N/A. The potential impacts from
1,4-Dioxane in surface waters include the potential to impact potable water supply
sources and fish tissue. The reduction evaluation is for achieving lower discharge
levels for the City's industrial users.
VII. FUNDING SOURCES IDENTIFICATION:
The applicant must list the sources of funds utilized to complete the work needed to bring the
facility into compliance. Possible funding sources include but are not limited to loan
commitments, bonds, letters of credit,block grants and cash reserves.The applicant must show
that the funds are available, or can be secured in time to meet the schedule outlined as part of this
application. N/A As noted,this order will be based on actions to control the pollutant of
interest through the City's industrial users.
If funding is not available at the beginning of the SOC process,the permittee must submit a copy
of all funding applications to ensure that all efforts are being made to secure such funds.N/A
Note: A copy of the application should be sufficient to demonstrate timeliness unless regional
office has reason to request all information associated with securing funding. N/A
THE DIVISION OF WATER RESOURCES WILL NOT ACCEPT THIS APPLICATION
PACKAGE UNLESS ALL OF THE APPLICABLE ITEMS ARE INCLUDED WITH THE
SUBMITTAL.
Required Items:
a. One original and two copies of the completed and appropriately executed application
form,along with all required attachments.
• If the SOC is for a City / Town, the person signing the SOC must be a ranking
elected official or other duly authorized employee.
• If the SOC is for a Corporation /Company / Industry /Other, the person signing
the SOC must be a principal executive officer of at least the level of vice-
president, or his duly authorized representative.
• If the SOC is for a School District, the person signing the SOC must be the
Superintendent of Schools or other duly authorized employee.
Note: Reference to signatory requirements in SOCs may be found in the North
Carolina Administrative Code [T15A NCAC 2H .1206(a)(3)].
b. The non-refundable Special Order by Consent (SOC) processing fee of$400.00. A
check must be made payable to The Department of Environment and Natural
Resources.
c. An evaluation report prepared by an independent consultant with expertise in
wastewater. (in triplicate)N/A This SOC application addresses actions to control
4

1,4-Dioxane at the industrial user source. The City's WWTP will not be
modified to achieve the reduction goals that will be established in the SOC.
Information addressing this component of the application is included in the
attachments.
APPLICANT'S CERTIFICATION:
(NO MODIFICATION TO THIS CERTIFICATION IS ACCEPTABLE)
I, "- "lbnager' , attest this application for a Consent Order has
been reviewed by me and is accurate and complete to the best of my knowledge. I understand if
all required parts of this application are not completed and if all required supporting information
and attachments are not included, this application package may be returned as incomplete.
(Please be advised that the return of this application does not prevent DWR from collecting all
outstanding penalties upon request). Furthermore, I attest by my signature that I fully
understand that an upfront penalty, which may satisfy as a full settlement of outstanding
violations, may be imposed. {Note: Reference to upfront penalties in Special Orders by
Consent may be found in the North Carolina Administrative Code [T15A NCAC 2H
.1206(c)(3)].}
� Date 5- t -2.U2..t�
ature of Signing Official
�.Jv�`►l I" 1. I I tt 1D Onager
t4 tr
Printed Name of Signing Official
THE COMPLETED APPLICATION PACKAGE, INCLUDING THE ORIGINAL AND TWO
COPIES OF ALL SUPPORTING INFORMATION AND MATERIALS, SHOULD BE SENT
TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DIVISION OF WATER RESOURCES
POINT SOURCE BRANCH
1617 MAIL SERVICE CENTER
RALEIGH,NORTH CAROLINA 27699-1 6 1 7
IF THIS APPLICATION IS FOR A NON-DISCHARGE SYSTEM, THEN SEND TO:
NORTH CAROLINA DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
1636 MAIL SERVICE CENTER
RALEIGH,NORTH CAROLINA 27699-1636
5

Reidsville SOC Application
Attached Information R.E. Part IV. NECESSITY NARRATIVE
Reidsville SOC Application
Attached Information R.E. Part IV.NECESSITY NARRATIVE
Background
The City of Reidsville was notified of alleged violations by the NC Division of Water Resources
(DWR),within the Department of Environmental Quality(DEQ), in a letter dated November 18,
2019(Corrected Notice of Violation,NOV-2019-PC-0729, attached)) concerning the 1,4-
Dioxane level in its WWTP effluent on June 12,2019. This letter described alleged violations of
NC's Water Quality Standard(15A NCAC 02B .0211(12))and the City's WWTP NPDES
permit. The City responded to this notice via letter dated December 13,2019 (attached).
Subsequent meetings/conference calls occurred on December 16, 2019, January 8,2020 and
January 28, 2020. Additionally, considerable communication with DWR and DEQ, via phone
and email, from the City and its representatives with DWR and DEQ has taken place. An
important part of these discussions has been the need for information from DEQ/DWR to assist
the City's efforts. The City followed-up these several requests with a formal public information
request.
The City has been engaged in evaluation of and monitoring for 1,4-Dioxane for several years.
The City has sought to respond promptly to DWR inquiries and directives on this issue. In
recent months,the City has continued with its sampling effort and has"split"several of those
samples with DWR. The City recognizes the concerns of the Division and downstream
stakeholders and continues to work to reduce 1.4-Dioxane in its discharge. It is the City's
position that reductions in 1,4-Dioxane are in the interest of water quality downstream of our
outfall. We do want to work toward the goal of reducing this pollutant but have noted that the
City considers this desire to be one of mutual interest with DEQ/DWR and not a specific
violation of established regulatory provisions for this parameter. Clearly, 1,4-Dioxane is a
pollutant of concern and warrants efforts toward reduction of its presence in the environment.
The City has discussed with DWR the need for a mutually acceptable path forward for the
stepwise reduction of 1,4-Dioxane in its effluent. The City has described to DWR the difficulties
related to reducing this pollutant. DWR's statements to the City acknowledge these difficulties.
The City's data and evaluation of this issue has identified a few industrial sources within the City
that are predominately responsible for the elevated levels of 1,4-Dioxane. However, 1,4-
Dioxane is used in many manufacturing processes and shows up in a long list of consumer
products. It is likely that the general use of this chemical in all sorts of consumer products would
result in the significant presence of 1,4-Dioxane in the City's discharge from time to time, even
without discharges from the manufacturing users identified. Nevertheless, Reidsville has been
taking steps to address this chemical as discharged by the identified sewer users connected to the
City's sewer collection system and continues to collect data at the plant and within its sewer
system. The City desires to establish, in consultation and cooperation with DWR, an appropriate
Page 1of5

Reidsville SOC Application
Attached Information R.E. Part IV. NECESSITY NARRATIVE
schedule,with established 1,4-Dioxane reduction goals within an appropriate consent order.
This list of actions would include specific timelines for reaching reduction goals that would
include the time necessary for the City to secure necessary regulatory provisions in the industrial
user permits of sources within the collection system. The City is also committed to ongoing
monitoring, including general monitoring within its collection system to provide data on 1,4-
Dioxane contributed by domestic, retail, and non-industrial commercial enterprises. We hope to
get a better handle of the impact of the use of normal consumer and commercial products that
contain 1,4-Dioxane. The City is certainly open to discussing the inclusion of this
monitoring/evaluation effort in an order and will certainly share this data with DWR. We have
made it clear that our desire for the requested information is not to frustrate the agency's efforts
to reduce 1,4-Dioxane forward, but to facilitate it. Included in our information request is copies
of the Division's work with Greensboro in developing a set of actions and a timeline for those
actions. This information will inform the City's efforts to collaborate with DWR in producing an
appropriate set of actions and a schedule for achieving those objectives.
The City has made it clear that there are significant challenges to setting appropriate discharge
levels in the pretreatment permits for users with significant amounts of 1,4-Dioxane. The City
has and will continue to meet and work with our sewer users, evaluate the relative impact of each
discharger's 1,4-Dioxane levels on the City's WWTP discharge, engage with DWR to obtain
critical information, seek technical assistance and support from DWR, and consult and work in
good faith with the Division to establish an appropriate set of reduction targets that can be linked
to NC Rules and Laws. As treatment of 1,4-Dioxane at the City's WWTP is neither technically
feasible,reasonable or cost-effective approach to reduce levels,the key to meeting established
goals is the ability to support, set, and successfully defend pretreatment limits as applied to
specific industrial sources through the City's Division-approved pretreatment program. For the
City to be able to agree to reduction levels in a consent order and establish a reasonable level of
assurance of complying with these levels, we must have the time and support of DWR to
establish,apply and defend pretreatment requirements for 1,4-Dioxane. It is also important to
factor in the reality that our industrial users must accept and not contest the limits/requirements
on 1,4-Dioxane as we move to modify their existing permits. No industrial source in the City
currently has a 1,4-Dioxane limit or requirement in their permit.
Actions Necessary for Establishing Reduction Goals and Schedule
As noted in the Background section of this Necessity Narrative,the City has, since the first
meeting in December 2019, following the November NOV, requested specific information from
the DWR to assist and inform the City as it works to establish the necessary regulatory controls
within its collection system to establish and achieve appropriate levels of reduction for 1,4-
Dioxane in its effluent. Following the December 16, 2019 meeting,the City continued to
request, via additional meetings,phone, email, direct contact and letter,the information sought
from DWR that would allow the development of an appropriate set of actions and timelines for
Page 2 of 5

Reidsville SOC Application
Attached Information R.E. Part IV. NECESSITY NARRATIVE
moving the efforts for 1,4-Dioxane reduction forward. The information requested is public
record pursuant to Chapter 132 of the General Statutes.
DWR provided a portion of the requested information via email on March 3, 2020. This
information provided some of the supporting basis for the Division's stated levels of reduction.
We appreciate receiving that information. However,as noted above,the availability of all of the
information requested is essential to the reduction effort. This information will greatly assist the
City and allow Reidsville to better support the actions it is developing to address the discharge of
1,4-Dioxane into our collection system. Even with this information in hand,we must direct the
specific industrial users within our collection system to initiate and achieve appropriate
conditions that must be added to their permits.
In submitting this SOC application,we note that it is not yet entirely clear how long it will
require to put in place pretreatment requirements necessary to meet our effluent goals and that
will be implemented and not contested. As the Division knows,the permitting procedures for
pretreatment permits also include appeal rights. Unless and until a user's modified permit is"in
effect"with the necessary 1,4-Dioxane requirements,the City doesn't have an enforceable basis
to compel a user to meet the limits. Without the control of this chemical at the source,the
effluent level in our discharge will continue to reflect the levels discharged to our system. The
City's WWTP cannot reduce 1,4-Dioxane in our influent. As a result, in this application we will
only be able to provide general comments on a proposed timeline. Our ability to establish a
specific timeline will require collaboration and coordination with our industrial users and a solid
technical basis for the requirements we propose to set in their permits. Our position with our
industrial users is strengthened by the availability of all of the information we have requested.
While the City continues to work with its industrial users and seek actions to reduce levels of
1,4-Dioxane,we cannot effectively interact with our sewer users, reach agreement on the goals,
establish a schedule for the user to meet the requirements, and develop and incorporate final
pretreatment requirements in to their permits,without the information requested and the
assistance of DWR. We continue to press for reductions now, but without defensible
pretreatment requirements it will not be possible to secure sustainable actions that will result in
consistent reduction of 1,4-Dioxane in the discharges of the target industrial users. It is likely
that our users will request time to meet their pretreatment requirements. This could result in
needing to establish schedules within the users' modified pretreatment permits to allow
reasonable time to the users to achieve their reduction goals. Therefore, adequate time in an
consent order must be included in the order timeline that factors in the time needed to secure the
information needed to support our work to establish sewer user requirements, coordinate
assistance from DWR, work through the process of modifying pretreatment permits and
providing sufficient confirmation monitoring to demonstrate that pretreatment permit levels are
being met.
Page 3 of 5

Reidsville SOC Application
Attached Information R.E. Part IV. NECESSITY NARRATIVE
Reduction Level Goals
DWR has stated to us that they seek progressive reduction in effluent 1,4-Dioxane levels in
Reidsville's WWTP and in other sources within the upper Haw River drainage. Specifically,
DWR has identified and provided some supporting information for the two following progressive
goals:
Stage 1: Effluent levels for summer and winter for 1,4-Dioxane that will, in conjunction
with other source reduction efforts,reduce discharges of 1,4-Dioxane in the WWTP to
keep instream levels at the Town of Pittsboro's raw water intake on the Haw River below
35 ug/1. The information provided by the Division, identifies goals for Reidsville's
WWTP effluent of 1,4-Dioxane of 163 ug/1 during the winter months(November 1
through March 31)and 74 ug/1 for summer months (April 1 through October 31).
Stage 2: An end-of-pipe effluent level that will demonstrate additional progress in further
reducing the level of 1,4-Dioxane in Reidsville's permitted discharge.
The specific regulatory components of these goals, limit value,monitoring frequency and
applicable achievement standard specifications(i.e. daily maximum,weekly average, monthly
average, etc.)have not been formally established or agreed to. The verification of these details
by the Division is needed to support an appropriate consent order. The City requested the
background information,references and specific agency statement that the Stage 1 levels are
appropriate and supportable under Federal and State water quality law and regulation. DWR has
stated that the initial goal is to provide reductions that would result in less than 35 ug/1 of 1,4-
Dioxane at the location of the Pittsboro raw water supply on the Haw River. This has been cited
by DWR as based on a public health advisory. The Division provided the supporting
calculations and basis for the levels identified. The Division identified 35 ug/1 through
discussions and other non-formal communication as an appropriate effluent level of 1,4-Dioxane
for stage 2. No specific regulatory basis for this number has been provided.
The City believes that the reduction objectives, for Stage 1 are levels it can work toward and
meet,pending the ability to establish appropriate pretreatment requirements and a timeline that
will allow these requirements to be met. The Stage 2 level based on discussions with DWR is
considered in their view a level that reflects significant additional reduction. This level is based
on agency judgement. Whereas the Stage 1 goals are directed at what DWR has characterized as
a health advisory(no formal documentation has been provided that this is an advisory issued by a
public health authority),the stage 2 level is a judgement. Based on the City's evaluation of the
general level sought by DWR,the City believes it would be better to relate this level to some
established 1,4-Dioxane water quality requirement. Within DWR's groundwater quality
standards(rules under 15A,NCAC 02L 0202(h)(66)),the 1,4-Dioxane standard established for
human consumption of groundwaters is 3 ug/l. Under the 15A NCAC 02B .0206, flow criteria
for setting effluent limits for human health standards for water supply surface waters as applied
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Reidsville SOC Application
Attached Information R.E. Part IV. NECESSITY NARRATIVE
to parameters identified as carcinogens(EPA documentation identifies 1,4-Dioxane and a likely
carcinogen),the flow statistic is the mean annual average flow. On the basis of this information,
an appropriate level for Stage 2 would be approximately 40 ug/1,based on the stream flow
characteristics at the City's outfall point. This level relates well to the proposed value of 35 ug/1
and reflects the application of an established requirement for the pollutant of interest that was
adopted by the EMC and that was recently readopted.
Ongoing Efforts and Actions by Our Industrial Users
Beginning in October 2019,the 1,4-Dioxane measurements in the WWTP effluent have, in
general, dropped. Recently, some increased discharge levels have been observed. This general
trend, while good news, represents a need to establish enforceable pretreatment requirements.
As noted, even if the City establishes pretreatment requirements that,based on headworks
evaluation, would allow it to meet the Stage 1 and Stage 2 goals, it is essential to secure
commitment from our users to meet these levels and to allow for collection of confirmation data
before the pretreatment requirements go into effect. The order schedule for meeting the two
stages needs to reflect an appropriate timeline to allow confirmation data to be collected and for
any operational adjustments to be made at the industrial users' facilities.
Page 5 of 5

Reidsville SOC Application
Attached Information R.E.Part V.CERTIFICATION
Reidsville SOC Application
Attached Information R.E. Part V. CERTIFICATION
Summary
A consent order is needed in this instance because efforts to reduce 1,4-Dioxane in the City of
Reidsville's WWTP P
discharge is contingent upon reduction of this
nu checal at the user source in
g
the City's collection system. 1,4-Dioxane is extremely miscible in water. The addition of this
chemical compound to water results in chemical conditions of the 1,4-Dioxane present in the
wastewater that makeitsremoval
emo al roblematic. The generally identified methods are expensive
and there is limited data on their use as a treatment approach on a municipal level. It is widely
agreed within the wastewater management field that chemicals behaving similarly to 1,4-
Dioxane can only be effectively and reasonably dealt with at the source. In the case of the City
of Reidsville,the 1,4-Dioxane is the result of industrial user discharges into their system and the
general use of 1,4-Dioxane in consumer products. Modification of the City's WWTP is not
appropriate and is therefore not proposed for this SOC. The approach described in this
application is development, application and implementation of pretreatment requirements.
Sewer user notification and education may also have some benefits related to making domestic
and commercial users of consumer products more aware of the potential for this pollutant to be
in the products they are using. Obviously, since consumer product producers are using this
chemical,there is the need for more attention at a national level to address these sources. This
issue is well beyond the scope of this application. Standard physical and biological treatment
steps in the City's WWTP will have no significant impact on the base concentrations of 1,4-
Dioxane entering the plant in the facility's influent.
The certification portion of this application requires addressing the following:
An evaluation of existing treatment units, operational procedures and recommendations as
to how the efficiencies of these facilities can be maximized. The person in charge of such
evaluation must sign this document.
Response: The City of Reidsville's WWTP is a 7.5 MGD suspended growth biological
municipal treatment system. It consists of screening, grit removal, influent pump station,
aeration basins with mechanical aeration, final clarifiers, single media shallow sand filtration,
chlorine disinfection,dechlorination,flow measurement and effluent pump station. The WWTP
discharge is regulated through its NPDES Permit,NC 0024881. Waste biological sludge is
processed by sludge thickening, aerobic digestion and sludge storage. Sludge is land applied
through an approved land application permit issued by DWR(NC 0002376). The operation of
this suspended growth(biological solids)follows standard operating procedures for this type of
treatment plant.
Page 1 of 3

Reidsville SOC Application
Attached Information R.E.Part V.CERTIFICATION
The presence of 1,4-Dioxane in the raw wastewater entering the treatment system is not
significantly impacted by the treatment steps summarized here. No feasible,reasonable,or cost-
effective treatment approach or plant modification at the WWTP level is demonstrated or
recommended to address this chemical and significantly reduce its content in the final effluent of
this facility.
A certification that these facilities could not be operated in a manner that would achieve
compliance with final permit limits. The person making such determination must sign this
certification.
Response: McGill Associates has reviewed the existing treatment system employed by the City
of Reidsville and the issues related to the need for this SOC and concludes that the treatment
system is incapable of reducing the 1,4-Dioxane that enters the plant from the collection system.
McGill Associates further doesn't recommend addressing the objective of reducing 1,4-Dioxane
in the plant's effluent by modification of the WWTP. Management of 1,4-Dioxane must be
focused on control at the source through the City's Pretreatment Program. A certification on
behalf of McGill Associates is provided at the end of this attached information concerning
paragraph V of the SOC application. This conclusion is also based on the limited information
available to the City on DWR's efforts to reduce this chemical in other municipal wastewater
treatment facilities. The efforts of DWR and the facility managers have focused on control at
the industrial sources level within the collection system.
The effluent limits that the facility could be expected to meet if operated at their maximum
efficiency during the term of the requested SOC (be sure to consider interim construction
phases).
Response: As noted,the objective of reducing 1,4-Dioxane in the Reidsville discharge is not
effectively addressed at the WWTP level. There are no feasible or cost-effective modification of
this treatment system to reduce 1,4-Dioxane. Efforts for reduction must be focused on the
sources of the chemical in the City's collection system. Management of 1,4-Dioxane must be
done through the pretreatment program. The City is seeking support, guidance, information, and
technical assistance from DWR to effectively interact with its users and establish pretreatment
requirements consistent with the regulatory requirements applicable to 1,4-Dioxane under
existing law and regulations.
Any other actions taken to correct problems prior to requesting a consent order.
Response: The City continues to engage its industrial users and to develop preliminary
pretreatment requirements based on our understanding of the goals DWR would like to see
included in an order. The City maintains monitoring to characterize the levels of 1,4-Dioxane
coming to the facility,levels in the wastewater discharge, levels in the collection system, and
requiring monitoring of its target industrial sewer users. The City continues to work with its
sewer users and to seek commitments from these indirect discharges to reduce 1,4-Dioxane. The
requested provisions of this consent order will provide an expanded framework for establishing
target levels of 1,4-Dioxane that will support the City's efforts to establish specific reduction
Page 2 of 3

Reidsville SOC Application
Attached Information R.E.Part V.CERTIFICATION
goals for the industrial users identified as the primary sources of this chemical. Through the
effective exchange of information with DWR, technical assistance and support from the
Division,the City will continue its efforts to set appropriate pretreatment requirements that will
allow for consistent and ongoing reductions of 1,4-Dioxane in its permitted discharge.
CERTIFICATION:
I have reviewed the information provided in the City of Reidsville's SOC application and the
conclusions stated relative to the most appropriate way to address the goal of reducing 1,4-
Dioxane in the effluent of the Reidsville WWTP. McGill Associates concur with the
conclusions summarized in the application and the statements provided by the City in response to
paragraph V.
orrest R. Westall, Sr., PE
McGill Associates, Inc.
Page 3 of 3
1

Reidsville SOC Application
Attached Information, R.E. Part VI. PREDICTED COMPLIANCE SCHEDULE
Reidsville SOC Application
Attached Information, R.E.Part VI.PREDICTED COMPLIANCE SCHEDULE
Reduction Goals
The City of Reidsville is committed to working with DWR to establish a mutually acceptable set
of actions and a schedule that would effectively address 1,4-Dioxane reduction targets for its
WWTP. Based on the information provided by DWR and the evaluation in the Necessity
Narrative Section of this application,the following target goals are identified below:
Stage 1: Working toward effluent levels that would,coupled with DWR actions on
identified sources in the watershed,prevent the concentration of 1,4-Dioxane from
exceeding 35 ug/1 at the Town of Pittsboro's raw water intake on the Haw River. DWR
has provided calculations and a written summary of the distribution of discharge goals
that taken together would meet the objective of not exceeding 35 ug/1 at Pittsboro's
intake. These levels,as understood by the City, are discussed in the City's responses to
Part IV,Necessity Statement. In summary,the effluent goals proposed by DWR for
Stage I are 163 ug/1 during the winter months and 74 ug/1 for summer months.
Stage 2: Taking additional actions to further reduce 1,4-Dioxane in the City's effluent to
a target level established in the consent order. In Part IV,Necessity Statement portion of
this application,the City recommends setting the goal at 40 ug/l. The discussion there
provides an analysis of the basis for working toward this level of reduction.
Schedule
The City remains committed to working with DWR to reach agreement on the schedule and
levels established for Stage 1 and Stage 2 for inclusion in the consent order. As we have
discussed in the application package submitted,the City must secure agreements with its
industrial users. Reaching agreement is dependent on receiving the requested information and
securing technical assistance from DWR to establish realistic timelines for putting pretreatment
requirements in place, monitoring to verify compliance and setting specific deadlines for
pretreatment compliance.
The City proposes the following actions and schedule for consideration:
• Submit for review and approval, a 1,4-Dioxane Monitoring Plan for characterization of
the background level of this chemical in its collection system. --60 days following the
issuance of the SOC.
• Provide for review and approval a monitoring plan for continued assessment of 1,4-
Dioxane in the industrial users identified by the City as Industry 1 and Industry 2,
contribution from other industrial sources on the collection system, and levels in the
WWTP.—30 days following the issuance of the SOC

Reidsville SOC Application
Attached Information, R.E. Part VI. PREDICTED COMPLIANCE SCHEDULE
• Assess the actions needed by their industrial users,numbers 1 and 2, and develop the
appropriate pretreatment permit requirements and schedule to meet the 1,4-Dioxane to
levels established for Stage 1.—Schedule to be established following receipt of the
additional information requested from DWR,coordination with our industrial users, and
further discussions with DWR.
• Demonstrate consistent achievement of Stage 1 target levels of 1-4-Dioxane in the
WWTP effluent.—Schedule be established following receipt of the additional
information requested from DWR, coordination with our industrial users,and further
discussions with DWR.
• Engage with the City's Industries, numbers 1 and 2,to establish in the user permits the
industrial user levels requirements and a schedule for meeting the Stage 2 target levels,
and modify the pretreatment permit to include these requirements.-- Schedule be
established following receipt of the additional information requested from DWR,
coordination with our industrial users, and further discussions with DWR.
• Demonstrate consistent achievement of Stage 2 target levels of 1-4-Dioxane in the
WWTP effluent.—Schedule to be established following receipt of the additional
information requested from DWR,coordination with our industrial users, and further
discussions with DWR.
• Develop sewer user educational notices about 1,4-Dioxane for inclusion in the City's
water and sewer billing statements and provide for other user education actions that will
communicate the importance of reducing levels of 1,4-Dioxane in the City's collection
system.—120 days following issuance of the SOC
• Provide quarterly progress reports.—submitted within 30 days of the end of each
calendar quarter
The City looks forward to the opportunity to collaborate with DWR on this prospective set of
actions and to establish an appropriate schedule.

s4`
ROY COOPER 1
Governor e
MICHAEL S.REGAN
Secretory *� �«
LINDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
November 18,2019
CERTIFIED MAIL 7018 1830 0001 8037 0274
RETURN RECEIPT REQUESTED
Charles Smith,Public Works Director
City of Reidsville
407 Broad Street
Reidsville,NC 27310
Subject: CORRECTED NOTICE OF VIOLATION(NOV-2019-
PC-0729)&Intent to Assess CIVIL PENALTIES
Reidsville WWTP
NPDES Permit NC0024881
Rockingham County
Dear Mr. Smith:
The North Carolina Division of Water Resources has reviewed data submitted on your Discharge Monitoring
Report(DMR)dated June 2019.The data indicates that on June 12,2019,the City of Reidsville had a discharge
of 1,4 Dioxane of 367.0 ug/L. This discharge represents a violation of North Carolina water quality standards as
well as conditions of NPDES WW Permit No.NC0024881. The violations are enumerated below.
Violations of North Carolina Water Quality Standards
Based on the review of the provided DMR data,a violation of North Carolina regulation 15A NCAC 02B
.0211(12)has occurred,which states: _
"Oils, deleterious substances, colored, or other wastes: only such amounts as shall not render the waters
injurious to public health, secondary recreation, or to aquatic life and wildlife, or adversely affect the palatability
offish, aesthetic quality, or impair the waters for any designated uses."
Violations of NPDES Permit NC0024881 Conditions
Review of the discharge data for June 12,2019 also indicates a violation of NPDES permit NC0024881 Part II
Section E,condition(9)(a)and Part IV, Section C(2)(c)listed below.
D E Qom,- North Carolina Depar Invent of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1165U Mail Service Center I Raleigh,North Carolina 27,99 1650
r .. /'• 919.707.9000

City of Reidsville—NPDES Permit NC0024881
November 18,2019
Page 2 of 3
Part II, Section E(9)(a),Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of the
Division as soon as possible, but in no case more than 24 hours or on the next working day following the
occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence at the water pollution control facility which results in the discharge of significant amounts of
wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a sludge
digester; the known passage of a slug of hazardous substance through the facility; or any other unusual
circumstances.
Part IV, Section C(2)(c),Municipal Control of Pollutants from Industrial Users
The Permittee shall investigate the source of all discharges into the POTW, including slug loads and other
unusual discharges, which have the potential to adversely impact the Permittee's Pretreatment Program and/or
the operation of the POTW.
The Permittee shall report such discharges into the POTW to the Director or the appropriate Regional Office.
Any information shall be provided orally within 24 hours from the time the Permittee became aware of the
circumstances.A written submission shall also be provided within 5 days of the time the Permittee becomes
aware of the circumstances. The written submission shall contain a description of the discharge; the investigation
into possible sources; the period of the discharge, including exact dates and times; if the discharge has not
ceased, the anticipated time it is expected to continue;and steps taken or planned to reduce, eliminate, and
prevent reoccurrence of the noncompliance
This Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violations of North Carolina
water quality standards(15A NCAC 2B .0100 and .0200)and the facility's NPDES WW Permit. Pursuant to G.S.
143-215.6A, a civil penalty of not more than twenty-five thousand dollars($25,000.00)may be assessed against
any person who:
(1) Violates any classification, standard, limitation, or management practice established pursuant to G.S. 143-
214.1, 143-214.2, or 143-215, or
(2)Is required but fails to apply for or to secure a permit required by G.S. 143-215.1, or who violates or fails to
act in accordance with the terms, conditions, or requirements of such permit or any other permit or certification
issued pursuant to authority conferred by this Part, including pretreatment permits issued by local governments
and laboratory certifications.
If you wish to provide additional information regarding the noted violations,request technical assistance,or
discuss overall compliance please respond in writing within thirty 30 calendar days after receipt of this Notice. A
review of your response will be considered along with any additional information provided when determining
whether a civil penalty may be assessed.

City of Reidsville—NPDES Permit NC0024881
November 18,2019
Page 3 of 3
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future.The Division of Water Resources may pursue enforcement action for this and any additional violations of
' State law.
If you should have any questions,please do not hesitate to contact me at 919-707-3615.
Sincerel ,
(1/V
John Hennessy
Compliance and Expedited Permitting Supervisor
cc: Lon Snider
Jenny Graznak

9 THr Pr TV (),.
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fJ4
_
NORTH CAROT IN A
230 W.Morehead Street • Reidsville,North Carolina 27320 • [phone] • Fax[phone]
December 13, 2019
Mr.John Hennessy
Compliance and Expedited Permitting Supervisor
Water Quality Permitting Section
Division of Water Resources
Department of Environmental Quality
1650 Mail Service Center
Raleigh, North Carolina 27699-1650
R.E. Corrected Notice of Violation(NOV-2019-PC-0729) &
Intent to Assess Civil Penalties
City of Reidsville WWTP
NPDES Permit NC0024881
Rockingham County
Dear Mr. Hennessy,
The City of Reidsville received the subject NOV and Intent to Assess Civil Penalties dated November 18,
2019. At the very outset of our response,the City wants to acknowledge that the issue of 1,4-Dioxane in
North Carolina waters may be an important water quality concern. The City shares this concern and
remains committed to addressing this chemical in our wastewater collection and treatment system. The
City, as the scope of this concern emerged several years ago, began to evaluate the potential for this
chemical to be present in our wastewater. Prior to DWR's completion of its initial monitoring study of
1,4-Dioxane in the Cape Fear River Basin,the City began the process of reaching out to our
manufacturing sewer users to assess the potential for their wastewater to contain this chemical. We
have continued our efforts and have worked diligently to respond in a cooperative and collaborative
way with DWR.
Request for Consultation with DWR
We believe that the most productive path to making progress on reducing this chemical in our
wastewater is to continue our consultation with the Division and work toward the adoption of a
regulatory plan to achieve and document progress. As a result,our City Manager, Mr. Preston Mitchell,
has reached out to you to arrange a meeting to discuss the regulatory status of the City, review the NOV
and plot out a mutually acceptable process toward effective reduction of 1,4-Dioxane in our NPDES
discharge. It is our objective in this meeting to discuss all of the regulatory options available for
addressing this issue, including special orders and other appropriate approaches. We hope we will be
"Live Simply. Think Big."

able to have this meeting soon. We request that DWR reserve its decision on civil penalties until we
have had the opportunity to review with you the specifics of the potential violations noted in your letter
and to recount the significant efforts the City has completed and undertaken to address this pollutant.
This request is consistent with your NOV,which states on page 2, "If you wish to provide additional
information regarding the noted violations, request technical assistance,or discuss overall compliance
please respond in writing within 30 calendar days after receipt of this Notice." In keeping with that
invitation,we request a meeting with the Division to address these topics before any additional
regulatory action is initiated.
Review of the Potential Violations
While we are committed to making additional progress through consultation and cooperation,the City is
concerned about the specifics of the violations cited in your letter. We want to keep the regulatory
process moving toward improving water quality, but we are somewhat dismayed by the framing of the
alleged violations.
Alleged Violations of NC's Water Quality Standards
The NOV references the data provided by the City in its June 2019 monthly monitoring report,
specifically the detection of 1,4-Dioxane on June 12, 2019 at 367 ug/I. This value was measured in a
grab sample data collected from our effluent as requested by DWR. The City has and continues to
monitor for this parameter as directed by the Division. The Water Quality Standard allegedly violated is
found at 15A NCAC 02B .0211(12). The full wording of this standard:
(12) Oils, deleterious substances,or colored or other wastes:only such amounts as shall not render
the waters injurious to public health, secondary recreation, or to aquatic life and wildlife,or
adversely affect the palatability of fish,aesthetic quality, or impair the waters for any designated
uses. For the purpose of implementing this Rule,oils, deleterious substances,or colored or
other wastes shall include substances that cause a film or sheen upon or discoloration of the
surface of the water or adjoining shorelines,as described in 40 CFR 110.3(a)-(b), incorporated by
reference including subsequent amendments and editions.This material is available,free of
charge,at: http://www.ecfr.gov/;
This narrative standard was developed by EPA as part of the implementation of the Federal Water
Pollution Control Act Amendments of 1972. It was developed to capture the various, undefined (no
numeric water quality standard available at that time)components of petroleum products and
byproducts. For that reason,the narrative rule further defines the term as"substances that cause a film
or sheen upon or discoloration of the surface water or adjoining shorelines." The parameter of concern
here, 1,4-Dioxane, is a specific compound and not a generalized pollutant of concern. Its chemical
properties in water do not fit within the context of this standard. The EPA and DWR have characterized
1,4-Dioxane as an "emerging contaminant." EPA published levels that are considered risk assessment
values for certain surface water uses. EPA has not developed a Water Quality Criterion for this chemical
nor a finished water standard (MCL) under the Safe Drinking Water Act. The information provided by

EPA is clearlyidentified as advisory. The EMC has not y established a water quality standard for 1,4-
Dioxane nor has one been proposed. It is fair to say that the regulatory status of 1,4-Dioxane is not well
established at this point.
Further, the narrative standard's measure for determining a violation is that the instream concentration
"shall not render the waters injurious to public health, secondary recreation, or to aquatic life and
wildlife,or adversely affect the palatability of fish,aesthetic quality,or impair the waters for any
designated uses." The NOV references an effluent value in Reidsville's NPDES-permitted discharge, No
analysis of the potential impacts to downstream uses was provided. The City doesn't have an NPDES
discharge permit limit for this parameter. Additional information that would indicate a specific water
quality impact was not provided and the City knows of no reported issue downstream of its discharge on
the date the grab sample was taken.
As the City has stated, we acknowledge that there are concerns related to the presence of this chemical
in our discharge. We are proceeding with efforts to address this and to secure progress on reducing the
concentrations of 1,4-Dioxane in our discharge and seek to work with the Division to accomplish this
goal. However, we do not believe that our discharge level on the date referenced constitutes a violation
of the cited narrative standard.
Alleged Violations of NPDES Permit NC0024881 Conditions
The NOV also alleges potential violations under the NPDES permit, Part II Section E,condition (9)(a) and
Part IV, Section (C)(2)(c). Those conditions are reviewed separately below:
Part II Section E, condition (9)(a), Non-Compliance Notification
This permit language is reproduced as follows:
"9. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate
regional office of the Division as soon as possible, but in no case more than 24 hours or
on the next working day following the occurrence or first knowledge of the occurrence
of any of the following:
a. Any occurrence at the water pollution control facility which results in the discharge of
significant amounts of wastes which are abnormal in quantity or characteristic, such as
the dumping of the contents of a sludge digester;the known passage of a slug of
hazardous substance through the facility;or any other unusual circumstances.
b. Any process unit failure,due to known or unknown reasons,that render the facility
incapable of adequate wastewater treatment such as mechanical or electrical failures of
pumps, aerators, compressors,etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass
without treatment of all or any portion of the influent to such station or facility.

Persons reporting such occurrences by telephone shall also file a written report within 5
days following first knowledge of the occurrence.Also see reporting requirements for
municipalities in Part IV.C.2.c.of this permit."
The City knows of no "occurrence at the water pollution control facility which"on June 12, 2019 that
resulted in an abnormal discharge. The WWTP was operating normally. We have been monitoring the
level of 1,4-Dioxane in our wastewaters for several years now. We have consulted with our industrial
users and identified to a reasonable degree the potential of each of our manufacturing facilities that
discharge process wastewater to the treatment facility to have 1,4-Dioxane in their wastewater. We
have provided DWR with our data and consulted and discussed the characteristics of our facility and the
general production activities at identified industrial sewer users in the City's service area. We have
monitored our target industrial users and required them to provide monitoring of their discharges. We
have collected a considerable amount of data and documentation on our efforts and believe that DWR
at the regional and central office level are well aware of Reidsville's efforts. The use of 1,4-Dioxane at
each of our targeted industrial users follows an established production procedure, using raw materials
and processes that follow normal steps. We have pretreatment permits for our significant industrial
users under a DWR-approved Pretreatment Program that include notification requirements similar to
those in our NPDES permit. We have no notification or information that anything unusual occurred on
June 12, 2019.
Part IV, Section(C)(2)(c), Municipal Control of Pollutants from Industrial Uses
The permit language is reproduced below:
"c. The Permittee shall investigate the source of all discharges into the POTW, including
slug loads and other unusual discharges,which have the potential to adversely impact
the Permittee's Pretreatment Program and/or the operation of the POTW.
The Permittee shall report such discharges into the POTW to the Director or the
appropriate Regional Office. Any information shall be provided orally within 24 hours
from the time the Permittee became aware of the circumstances. A written submission
shall also be provided within 5 days of the time the Permittee becomes aware of the
circumstances.The written submission shall contain a description of the discharge;the
investigation into possible sources; the period of the discharge, including exact dates
and times; if the discharge has not ceased,the anticipated time it is expected to
continue; and steps taken or planned to reduce,eliminate, and prevent reoccurrence of
the noncompliance"
My previous response to the other referenced permit condition also speaks to this cited condition. The
City has consistently provided DWR with data and information related to the industrial contributors of
1,4-Dioxane. All significant industrial users to our treatment system hold pretreatment permits
developed under the City's approved Pretreatment Program and have been provided to DWR. We have
investigated all of the sources of discharges into our treatment system and discussed and evaluated the
production practices at the facilities. We have required our target industrial users to monitor for 1,4-
Dioxane, and we have been receiving and evaluating that data. Because there are no effluent limits in

our permit for 1,4-Dioxane, this parameter is not a limited pollutant under our pretreatment program.
DWR is aware of the City's efforts to engage its industrial users and we have been seeking actions that
will reduce the levels of 1,4-Dioxane in their wastewater. We have documented these efforts and are
continuing to make progress.
The City continues to investigate the industrial sources of 1,4-Dioxane and to take actions that will
contribute to improving the quality of our effluent. There have not been any unusual activities outside
of those that have been regularly documented and managed by our industrial users. The City has been
reporting and communicating with DWR from the outset about the nature of its industrial customers
and providing the data requested by the Division. We do not have any information that would indicate
that a notification to DWR under this condition was required on June 12, 2019. The City does not
believe it is in non-compliance with this permit condition.
The review is not intended to suggest resistance to working with DWR to develop a plan for addressing
1,4-Dioxane. Rather, it identifies issues raised by the NOV. It is our preference to consult with the
Division in an effort to cooperatively and productively work toward reducing 1,4-Dioxane levels in our
discharge. We welcome the opportunity to create a process to document progress and to reach
agreement on the appropriate steps toward improving water quality.
The City has promptly responded to the directives from DWR to monitor and report 1,4-Dioxane levels
p ,
in our discharge. We have also undertaken actions to require our industrial users to evaluate their
operations and to monitor their discharges. Prior to receiving the NOV, the City had not received any
notices or letters from DWR suggesting that our response to the actions required by DWR to address
1,4-Dioxane have been in any way inadequate. We believe our documented efforts represent a good-
faith commitment to finding solutions to this issue.
We look forward to meeting with you and others in the Division as soon as possible. Please let me know
if you have any questions.
Sincerely,
Charles Smith
Cc Reidsville City Council
Preston Mitchell
Chris Phillips
Andy Lovingood
Ben Bani
Doug Chapman
Forrest Westall

CITY OF
•
Reidsville
., ". NORTf-1 CAROLINA
230 W.Morehead Street • Reidsville,North Carolina 27320 • [phone] • Fax[phone]
CITY OF REIDSVILLE,NORTH CAROLINA
RESOLUTION FOR SEEKING A SPECIAL ORDER BY CONSENT WITH THE
NORTH CAROLINA DIVISION OF WATER RESOURCES
WHEREAS: The City of Reidsville's(City) Wastewater Treatment Plant(WWTP) has
a permit to discharge treated wastewater to the Haw River, classified WS-
5 -NSW waters in North Carolina's Schedule of Classification for the
Cape Fear River Basin; and
WHEREAS: This discharge is allowed under an NPDES Permit,Number NC0024881,
issued by the North Carolina Division of Water Resources (DWR),
effective June 1, 2013 and with an expiration date of April 30, 2016; and
WHEREAS: The City timely applied to the DWR for renewal of NPDES Permit
NC0024881, such that the permit remains in force pursuant to N.C. Gen.
Stat. §150B-3(a); and
WHEREAS: NPDES permit NC0024881 contains no effluent limit for 1,4-Dioxane, but
the City understands that 1,4-Dioxane is a pollutant of concern that is
present in various amounts in the discharge of treated wastewater from
their WWTP; and
WHEREAS: The City desires to work cooperatively with DWR to establish reasonable
reduction goals for 1,4-Dioxane in their WWTP's discharge and to reach
agreement with DWR on such reduction goals and other appropriate
conditions in a Special Order by Consent (SOC), as authorized by N.C.
Gen. Stat. §143-215.2 and 15A NCAC 2H .1201-.1206; and
WHEREAS: The City hereby authorizes John M. "Jay"Donecker, Mayor, to negotiate
and execute the Special Order by Consent on behalf of the City.
THEREFORE,BE IT RESOLVED that the City requests a Special Order by Consent under
the authority of the Environmental Management Commission and the City hereby authorizes
John M. "Jay"Donecker, Mayor,to negotiate and execute this document on behalf of the City.
ohn M. "Jay"Done er, ayor, City of Rei 'lle
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