NC0026123_Response to Notice (PC-2022-0064)_20220411

Water Resources Division OTy OF ��= Tel: [phone] Ext. 258
146 N Church Street H�Bo
PO Box 1106 S I. w Fax: [phone]
Asheboro, NC 2'7204-1106 _ 1 -
NORTH CAROLINA
April 5, 2022
RECEIVED
APR 11 2022
John Hennessey NCDEQ/DWRINPDES
NC DEQ—Division of Water Resources
Compliance and Expedited Permitting Supervisor
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Response to NOTICE OF VIOLATION (NOV-2022-PC-0064) & Intent to Assess
CIVIL PENALTIES
Dear Mr. Hennessey:
The City of Asheboro received the Notice of Violation (NOV-2022-PC-0064) & Intent to assess
Civil Penalties. Upon review, the City of Asheboro would like to submit additional information
regarding the NOV as well as request clarification regarding the cited violations of NPDES permit
NC0026123.
In response to the cited Violation of North Carolina Water Quality Standards [15A NCAC
02B .0208 (1)], the City of Asheboro would like to point out that 1,4 Dioxane Water Quality
standards have not been adopted to date, and EPA National Recommended Water Quality Criteria
for Aquatic Life&Human Health excludes 1,4 Dioxane.The NC In-Stream Target Value for Class
C waters references a concentration of 80ug/L based on IRIS 8/10.
Included as an attachment to this letter are email correspondence between the City of Asheboro
and DEQ-DWR Regional Staff, as well as historical data for samples split between the City of
Asheboro and NC DEQ-DWR. Asheboro sends all samples to Meritech, Inc. Laboratory
Certification #165. Since, the state lab is not certified to analyze 1,4 Dioxane, the Asheboro
WWTP has been instructed to exclude all data which is analyzed by the State Lab when reporting
on the NPDES Discharge Monitoring Report. Asheboro lists these results in the comment section
as instructed by NC DEQ-DWR Regional Staff. Asheboro was also advised the state lab results
would not be used for compliance determinations.
[15A NCAC 02B .0505(e)(5)] states:
"Approval of Laboratories. Analytical determinations made pursuant to the requirements of this
Section shall be made in adequately equipped laboratories staffed by person(s) competent to
perform tests. Only monitoring programs that provide for the making of analytical determinations
by qualified employees of the owner or by a laboratory certified by the Division under 15A NCAC
02H.0800 or 15A NCAC 02H.1100 shall be considered adequate. "
Home of the NC Zoological Park

Response to NOTICE OF VIOLATION(NOV-2022-PC-0064)& Intent to Assess CIVIL
PENALTIES
April 5,2022
Page 2 of 3
As shown in the historical data attached,NC DEQ-DWR laboratory and Meritech, Inc. results for
split samples are not reproducible. NC DEQ-DWR has recognized these variances. NC DEQ-
DWR results are consistently higher. Asheboro has also noticed NC DEQ-DWR has experienced
hold time and other quality control issues within the State Lab.
Based on the above information,the City of Asheboro is requesting the state review the laboratory
name and NC laboratory certification number of the lab that was used to analyze the Hasketts
Creek sample collected on October 13t. The City of Asheboro is also requesting a review of all
Chain of Custody records and quality control data as to insure the sample data is correct and
confidence can be placed in the value that was obtained. If the NC DEQ-DWR lab was chosen to
analyze the sample, please provide the legal authority used to validate the result in which the
violation was issued.
In response to the cited Violation of NPDES Permit NC0026123 Conditions, the City of
Asheboro has included a summary timeline of all actions taken during the cited incident as well as
the supporting email documents referenced in the timeline. Investigations into 1,4 Dioxane
discharges to the Asheboro POTW began in March 2015 and have been ongoing to date. This
includes collection system monitoring daily, weekly and/or monthly depending on the site.
Asheboro Pretreatment staff have thoroughly investigated all sources of 1,4 Dioxane and have
continual contact with all known sources. As shown in the timeline attached, Pretreatment staff
continually investigated, worked with industry sources, and provided feedback to NC DEQ-DWR
through the entire cited violation period. Asheboro staff have been prompt with any additional
information requests received by the division.
Asheboro Pretreatment staff contacted NC DEQ-DWR regional office by phone multiple times
during October and November 2021 to alert them to changes to discharges received by the POTW
and relay results received via email from the commercial laboratory, Meritech, Inc. Remedial
actions, timeframes and sampling plans were discussed verbally and via email with NC DEQ-
DWR staff. Asheboro Pretreatment staff emails all results to NC DEQ-DWR staff with
explanations of unusual discharges in under 24 hours.
As noted in the timeline and attached emails,Asheboro WWTP requested guidance from NC DEQ-
DWR in October 2019. Asheboro has very irregular discharges and until a NPDES limit or
directive from NC DEQ-DWR is received by Asheboro WWTP, staff have exhausted legal
authority to regulate discharges of 1,4 Dioxane. No threshold value and/or guidance on how to
alert NC DEQ-DWR and downstream utilities of 1,4 Dioxane discharges have been received to
date.
The City of Asheboro is requesting NC DEQ-DWR review the attached timeline and supporting
emails before issuing civil penalties. Asheboro would also like NC DEQ-DWR to reevaluate the
cited Violation of NPDES Permit NC0026123 Conditions in light of the timeline and emails
submitted. If NC DEQ-DWR still finds Asheboro WWTP to be in Violation of NPDES Permit
NC0026123 Conditions, please provide a written response as to why the violation occurred and
CITY OF
ASHEBORO

Response to NOTICE OF VIOLATION(NOV-2022-PC-0064) & Intent to Assess CIVIL
PENALTIES
April 5, 2022
Page 3 of 3
specific actions and/or requirements that will need to be completed in order to prevent future
violations.
Thank you for the opportunity to provide additional information.The City of Asheboro appreciates
having a working relationship and open communication with NC DEQ-DWR as we face these
challenging environmental concerns. Asheboro is committed to preventing and minimizing
violations and protecting the waters of the state.
Please contact me with any questions, 336-626-1201 ext, 258
Sincerely,
filvap,tta fra'7145/
Michael D. Rhoney, PE
Water Resources Director
City of Asheboro
NPDES Permit NC0026123
Attachments: NOV-2022-PC-0064 NC0026123 Conditions Emails
NOV-2022-PC-0064 NC0026123 Conditions Timeline
NOV-2022-PC-0064 WQ Standards Emails
NOV-2022-PC-0064 WQ Standards Split Sample Comparison
CITY OF
ASHE3OFO

Attachment: NOV-2022-PC-0064 NC0026123 Conditions
Emails
RECEIVED
a�R 11 2022
NCDEQ/DWR/NPDES

Sarah Laughlin
From: Sarah Laughlin
Sent Thursday, October 24, 2019 11:52 AM
To: Grzyb,Julie; Poupart,Jeff
Cc: Michele Dawes; Michael Rhoney
Subject: 1,4 Dioxane Asheboro Threshold Value
Attachments: Asheboro 1,4 Dioxane Data Summary.xlsx
NCDEQ DWR Staff,
In light of all the concern surrounding 1,4 Dioxane levels in the Cape Fear River, Asheboro would like
to request some guidance on a threshold value to notify DEQ Staff and downstream users of an elevated
discharge. As you are aware, Asheboro is a unique situation in which our industry, Starpet Inc., produces 1,4
Dioxane as a by-product of their EPA regulated 40 CFR 414.40 PET plastics manufacturing process. They
have found a treatment technology they believe will work and was issued an Authorization to Construct on
April 15, 2019. The treatment unit is on schedule to be installed December 2019. Asheboro believes after the
unit is operational there will be a significant decrease in 1,4 Dioxane effluent levels.
I have provided a spreadsheet summarizing Asheboro's data for your convenience. Asheboro 1,4
Dioxane levels have fluctuated since sampling began in December 2017. Please provide a threshold value in
which Asheboro should begin notifying DEQ and downstream utilities of an elevated discharge.
Thank you,
Sarah W. Laughlin
Technical Services Specialist
Water Resources Division
City of Asheboro
[phone] ext. 218
SIuUi�i"liill�a'i .d,[�CUO .RC.US
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
1

Sarah Laughlin
From: Meritech Reports <[e-mail]>
Sent: Tuesday, October 12, 2021 12:14 PM
To: Sarah Laughlin
Subject: [External Sender] Meritech Data
Attachments: 10012172-Asheboro 1,4 Dioxane- LMC.pdf
Thank you,
Lindsey Corbett
Administrative Assistant
Meritech, Inc.,
Office: 336-342-4748
Fax: [phone]
report; : meritechlabs.com

From:Will Norton [mailto:[e-mail]]
Sent:Tuesday,October 12, 2021 2:31 PM
To:Sarah Laughlin<[e-mail]>
Cc: Katrina Harris<[e-mail]>;Jason Greenwood<[e-mail]>
Subject:RE: [External Sender]Treatment System
Good Afternoon Sarah,
water treatment
There was nothing unusual reported with thesystem on or near the 1st of October. I reviewed the
process condition readings for the month of September through the 12th of October and all were normal. I believe that
the sample on the 15th will indicate that the sample collect on the 1"was an anomaly. Please let us know if you need
additional information.
Thanks,
Will Norton
Safety Officer
StarPet Inc.
801 Pineview Rd.
Asheboro, NC 27203
Phone: [phone] ext. 357
Fax: [phone]
Mobile: [phone]
gin` i
Our vision: To be a world-class chemical company making great products for society.
From:Sarah Laughlin< [e-mail].0 >
Sent:Tuesday, October 12, 2021 13:20
To:Will Norton< ama.net>
Subject:Treatment System
[External Email
Wilt,
The 1,4 dioxane results collected on Oct. 15i were elevated. Do you know if there was anything going on with
the treatment system during that time? I will be resampling this Friday Oct. 15th
Thanks,
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
[e-mail]
2

Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
Important:This email and any files transmitted with it are confidential and may be privileged or otherwise protected from disclosure;
they are intended solely for the use of the individual or entity to whom they are addressed. If you are not the intended recipient or have
received this email or attachment in error,you must not read, copy, store, use,forward or disclose the email or attachment to any other
person. Please return the message to the sender and delete it from your system immediately thereafter
3

Sarah Laughlin
From: Sarah Laughlin
Sent: Tuesday, October 12, 2021 1:28 PM
To: 'Grzyb, Julie'; 'Graznak,Jenny'; Montebello, Michael J
Subject: Asheboro 1,4 Dioxane Data
Attachments: 10012172-Asheboro 1,4 Dioxane- LMC.pdf
Hi,
Attached are the Asheboro 1,4 Dioxane results collected on Oct. 15c
Thanks,
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
[e-mail]
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
1

Sarah Laughlin
From: Sarah Laughlin
Sent: Tuesday, October 12, 2021 3:37 PM
To: 'Graznak,Jenny'
Cc: Michael Rhoney
Subject: Asheboro 1,4 Dioxane
Attachments: 1,4 Results.xlsx
Jenny,
In response to our phone call earlier, here is some of the information you requested. Please let me know if i
o wantadditional inf rm left anything out or if you a information in preparation to your meeting.
I spoke with Starpet on the phone after I received the high results. My contact was not aware of any issues
and investigated the issue further. Below is the email he sent confirming this.
The system has been performing extremely well, and much better than was ever expected. The multi-million
dollar system was only designed to remove the 1,4 Dioxane to a level of 1,000 ug/L. The results we have
been seeing have been exceptional. The October 1st results were what we had anticipated. The system has
been performing well above and beyond its design.
I have attached all the sample results for Pineview since the treatment system went online and we began
sampling. Please remember, Starpet is permitted to discharge 0.070MGD and our wastewater plant
averages 3.5MGD. Starpet discharged an average of 0.065MGD in the month of September (the highest
MGD so far this year). Mass balance still puts Asheboro effluent below 25ug/L even with the 1,220ug/L
Starpet discharge.
I recently switched to every other week sampling for Pineview starting in September. I am scheduled to
sample Pineview this Friday Oct. 15m. Please let me know if I should go back to weekly sampling at that site.
Thanks!
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
slaughlincwci.asheboro.nc.us
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
1

Pineview
Date Result ug/L Date Result ug/L
11/24/2020 69.0 1/7/2021 35.8
12/7/2020 16.3 1/13/2021 66.0
12/21/2020 46.7 1/21/2021 29.9
12/30/2020 23.5 2/2/2021 16.2
2/10/2021 186
2/16/2021 337
3/10/2021 12.5
3/16/2021 32.5
3/25/2021 432
4/7/2021 32.2
4/15/2021 13.5
4/22/2021 32.3
4/28/2021 13.7
5/5/2021 25.1
5/13/2021 15.7
5/19/2021 26.0
5/24/2021 62.8
6/2/2021 14.3
6/9/2021 42.0
6/17/2021 568
6/22/2021 261
6/29/2021 94.9
7/8/2021 307
7/16/2021 182
7/23/2021 118
7/30/2021 208
8/6/2021 198
8/13/2021 279
8/20/2021 106
8/27/2021 128
9/1/2021 74.2
9/17/2021 212
10/1/2021 1,220

Sarah Laughlin
From: Sarah Laughlin
Sent: Thursday, October 14, 2021 3:57 PM
To: 'Graznak,Jenny'
Subject 1,4 Asheboro Data
Attachments: 1,4 Results.xlsx
Jenny,
Attached is all of the data we have collected in Asheboro.
We will start sampling Pineview Street weekly again starting tomorrow (10/15). I will continue to try and
collect a sample at Great Oak Landfill according to their discharge.
Let me know if you need anything else,
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
iciugniifilu'U.dsi ieui i u.tic.us
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
1

Sarah Laughlin
From: Meritech Reports <[e-mail]>
Sent: Wednesday, October 20, 2021 1:01 PM
To: Sarah Laughlin
Subject: [External Sender] Meritech Data
Attachments: 10082154-Asheboro 1,4 Dioxane- LMC.pdf
Follow Up Flag: Follow up
Flag Status: Completed
Thank you,
Lindsey Corbett
Administrative Assistant
Meritech, Inc.,
Office: 336-342-4748
Fax: [phone]
,abs.com

Sarah Laughlin
From: Sarah Laughlin
Sent: Thursday, October 21, 2021 11:34 AM
To: 'Grzyb, Julie'; 'Graznak,Jenny'; Montebello, Michael J
Subject: FW: Meritech Data
Attachments: 10082154-Asheboro 1,4 Dioxane- LMC.pdf
Hi,
Attached is the Asheboro Effluent 1,4 Dioxane Results for Oct. 8th
Thanks,
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
slauyhlin@)ci.asheboro.nc.us
Email correspondence to and from this sender is subject to the North Carolina Public Records Low and may be disclosed to third
parties.
1

Sarah Laughlin
From: Amanda Hancock <[e-mail]>
Sent: Monday, October 25,2021 12:18 PM
To: Sarah Laughlin
Cc: David Merritt
Subject: [External Sender] Meritech Data
Attachments: 10152128-Asheboro 1,4 Dioxane-AH.pdf
Follow Up Flag: Follow up
Flag Status: Completed
Sarah,
The result for Pineview is extremely high, but it has been reviewed and is correct.
Regards,
Amanda Hancock
Technical Services Supervisor
Meritech Labs,Inc
[e-mail]
336-342-4748
1

Sarah Laughlin
From: Sarah Laughlin
Sent Tuesday, October 26, 2021 11:25 AM
To: 'Will Norton'
Cc Jason Greenwood
Subject RE: [External Sender] Treatment System
Thank you Will.
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
[e-mail]
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
From:Will Norton[mailto:[e-mail]]
Sent:Tuesday, October 26, 2021 11:21 AM
To:Sarah Laughlin<[e-mail]>
Cc:Jason Greenwood<[e-mail]>
Subject:RE: [External Sender]Treatment System
I have reported the issue to site management and the engineering staff along with the treatment system is
investigating. I will keep you informed as to the status of the investigation as information is made available.
Thanks,
Will Norton
Safety Officer
StarPet Inc.
801 Pineview Rd.
Asheboro, NC 27203
Phone: [phone] ext. 357
Fax: [phone]
Mobile: [phone]
www.indc ntu�
Our vision:To be a world-class chemical company making great products for society.
From:Sarah Laughlin< to hlin@ci,asheboro.nc >
Sent: Monday,October 25, 2021 14:50
To:Will Norton< >
Subject: RE: [External Sender]Treatment System

(External Email)
Attached is all our data collected since the treatment system was installed, with the sample Temp and pH at
collection.
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
slaughlinPci.asheboro.nc.us
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
From:Will Norton [ °t^`^F'l'_mr,[e-mail]]
Sent: Monday,October 25,2021 2:47 PM
To:Sarah Laughlin< '[e-mail]>
Subject: Re: [External Sender]Treatment System
Can you send the results from one back in August or September when it was lower?
From:Sarah Laughlin c:aueh';n(i.p—;!'^�� >
Sent: Monday,October 25,2021 12:46:31 PM
To:Will Norton<Nill.Norton(us.indorama.r >
Subject: RE: [External Sender]Treatment System
gtxwrnai Email]
Will,
(just received the Lab Data. Pineview was 15,900ug/L for Oct. 15th. The lab re-ran and confirmed the result
is correct. Can you please check and see if there is an issue with the treatment system? Attached is the
report.
Let me know what you find out,
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
[e-mail]
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
2

From:Will Norton [^'m ilto:Will.Norton(aus.indorama.net]
Sent: Monday,October 25,202111:41 AM
To:Sarah Laughlin< [e-mail]>
Subject: RE: [External Sender]Treatment System
Good Morning Sarah,
How was the result from the 15th?
Will Norton
Safety Officer
StarPet Inc.
801 Pineview Rd.
Asheboro, NC 27203
Phone: [phone] ext. 357
Fax: [phone]
Mobile: [phone]
con.
Our vision: To be a world-class chemical company making great products for society.
From:Sarah Laughlin< aug linOci.asheboro.nc.us>
Sent:Tuesday, October 12, 2021 13:20
To:Will Norton<irui.ivurtuntwu:,.,,,,.u, rna.net>
Subject:Treatment System
[External Email]
Wilt,
The 1,4 dioxane results collected on Oct. 1st were elevated. Do you know if there was anything going on with
the treatment system during that time? I will be resampling this Friday Oct. 15th
Thanks,
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
k rn nr t lc
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
Important:This email and any files transmitted with it are confidential and may be privileged or otherwise protected from disclosure;
they are intended solely for the use of the individual or entity to whom they are addressed. If you are not the intended recipient or have
3

received this email or attachment in error,you must not read,copy,store, use,forward or disclose the email or attachment to any other
person. Please return the message to the sender and delete it from your system immediately thereafter.
4

Sarah Laughlin
From: Sarah Laughlin
Sent: Tuesday,October 26, 2021 11:43 AM
To: 'Grzyb,Julie'; 'Graznak,Jenny'; Montebello, Michael J
Cc: Michael Rhoney
Subject: Asheboro 1,4 Data
Attachments: 10152128- Asheboro 1,4 Dioxane-AH.pdf
Good Morning,
Attached is the Asheboro 1,4 Dioxane Results from October 15th
Pineview Street is elevated. I have been in contact with my industry and they were not aware of a problem
with the treatment system at the time of sample collection. All of their reports show it to be working
however, they have launched a full investigation and have involved their upper staff as well as the engineers
of the treatment system to troubleshoot and identify the problem. We know the system is still working,just
not optimally. They will keep me updated as they learn more. No production/process changes have
occurred. 1,4 Dioxane is produced as a byproduct during Esterification.
m osite sampler setupwhich we split each week, so we
r has the weeklycop
In the meantime, Asheborop p
should know how long the issue lasts and how it affects Asheboro WWTP Effluent results. We also collect
weekly grab Pineview Street and WWTP Effluent samples.
Feel free to contact me with any questions,
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
slau.jhlino)ci.asheboro.nc.us
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
1

Sarah Laughlin
From: Graznak,Jenny <[e-mail]>
Sent: Wednesday, October 27, 2021 2:53 PM
To: Sarah Laughlin
Cc: Mcgee, Keyes
Subject RE: [External Sender] [External] Asheboro 1,4 Data
Thank you,Sarah. Keyes and I will meet you at Starpet at 10am on Tuesday November 2.
Jenny Graznak
Assistant Regional Supervisor
Winston Salem Regional Office
Division of Water Resources
Department of Environmental Quality
450 West Hanes Mill Road,Suite 300
Winston Salem NC 27105
336-776-9695 office
336-403-7388 mobile
[e-mail]
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
p
to third parties.
From:Sarah Laughlin<[e-mail]>
Sent:Wednesday,October 27, 2021 2:08 PM
To:Graznak,Jenny<[e-mail]>
Subject: RE: [External Sender] [External]Asheboro 1,4 Data
CAUTK.: External email.Do not dick links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Yes, Tuesday November 2nd 10a. 801 Pineview Street Asheboro, NC 27203. I am planning to have Starpet
staff collect a sample for me from the treatment system during that inspection. They have suspicions on
what happened but they are still trying to confirm.
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
slaughlin(iici.asheboro.nc.us
1

Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
From: Graznak,Jenny [ ail: 'ncdenr.gc ]
Sent:Wednesday,October 27,2021 1:51 PM
To:Sarah Laughlin< ` ->
Subject: RE: [External Sender] [External] Asheboro 1,4 Data
Hey Sarah,
Central Office does want me to come along to your site visit to Starpet on Tuesday if that is still agreeable with you.
Keyes Mcgee from the Central Office will also be accompanying me. He is in the pretreatment section.You are planning
to be there at 10am?
Thanks,
Jenny Graznak
Assistant Regional Supervisor
Winston Salem Regional Office
Division of Water Resources
Department of Environmental Quality
450 West Hanes Mill Road,Suite 300
Winston Salem NC 27105
336-776-9695 office
336-403-7388 mobile
[e-mail]
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From:Sarah Laughlin<- Pt- .. ,, M nc.-- ->
Sent:Tuesday, October 26,2021 11:43 AM
To:Grzyb,Julie<;:ulie.grzvb@ncdenr.g >;Graznak,Jenny<.ennv.eraznak@ncdenr4 >; Montebello, Michael J
< [e-mail]>
Cc: mrhoney<[e-mail].t >
Subject: [External]Asheboro 1,4 Data
CAUTIrr External email. Do not click links or open attachments unless you verify.Send all suspidous email as an attachment to
Report
Good Morning,
Attached is the Asheboro 1,4 Dioxane Results from October 15th
Pineview Street is elevated. I have been in contact with my industry and they were not aware of a problem
with the treatment system at the time of sample collection. All of their reports show it to be working
2

investigation and have involved their upper staff as well as the engineers
however, theyhave launched a fullesti atio a pp g
9
of the treatment system to troubleshoot and identify the problem. We know the system is still working,just
not optimally. They will keep me updated as they learn more. No production/process changes have
occurred. 1,4 Dioxane is produced as a byproduct during Esterification.
In the meantime, Asheboro has the weekly composite sampler setup which we split each week, so we
should know how long the issue lasts and how it affects Asheboro WWTP Effluent results. We also collect
weekly grab Pineview Street and WWTP Effluent samples.
Feel free to contact me with any questions,
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
slain jhlin(coci.asheboro.nc.us
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
3

Sarah Laughlin
From: Meritech Reports <[e-mail]>
Sent: Friday, October 29, 2021 12:13 PM
To: Sarah Laughlin
Subject [External Sender] Meritech Data
Attachments: 10222168-Asheboro 1,4 Dioxane- LMC..pdf
Thank you,
Lindsey Corbett
Administrative Assistant
Meritech, Inc.,
Office: 336-342-4748
Fax: [phone]
_j)t)Tts(a r en eciiiaus. .oiY
1

Sarah Laughlin
From: Sarah Laughlin
Sent: Friday,October 29, 2021 1:16 PM
To: 'Grzyb,Julie'; Montebello, Michael J; 'Graznak,Jenny'
Cc: Michael Rhoney
Subject: Asheboro 1,4 Dioxane Results
Attachments: 10222168-Asheboro 1,4 Dioxane- LMC..pdf
Hi,
Attached are the Asheboro 1,4 Dioxane results for October 21`t
Pineview and our Effluent are elevated, as expected. We were not fully aware of a problem with the
treatment system at Starpet when this sample was collected. Starpet has identified a potential issue with the
treatment system and they have shut it down today (10/29) in order to try and correct the issue. They are
holding back as much discharge water as possible during this time. Their hope is this change will correct the
problem but we will not know for a few days. Unfortunately, it takes time and there is no quick in house lab
test to use to help troubleshoot. I will be collecting another sample during my inspection on Tuesday (11/2)
directly from the treatment system. This will give them time to correct the problem and get the system back
online and operating within their standards. I collected a sample this morning (10/29) at Pineview Street and
our WWTP
Effluent— I anticipate those results to be elevated as well as they continue to work on the
identifying the issue.
I have been in close contact with Starpet through this process and I assure you, they are being very
a p 9
attentive and have been in contact with the treatment system engineers, designers, and installers to try and
solve this issue. This is a never before used, multi-million dollar, high tech, one of a kind technology and
everyone is working around the clock to make sure it returns to its much better than expected or designed
function. Please remember, Starpet has installed this treatment of their own accord in order to be good
environmental stewards. They continue to cooperate with me and Asheboro's pretreatment program. The
treatment system began full 24 hour operation on 11/20/2020 and this is the first time they have had any
issue.
Feel free to contact me with any questions,
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
slaughlinoi)ci.asheboro.nc.us
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
1

Sarah Laughlin
From: Sarah Laughlin
Sent: Wednesday, November 3, 2021 2:10 PM
To: 'Mcgee, Keyes'
Cc: Graznak,Jenny
Subject: RE:StarPet
Attachments: 1A Mass Discharges.xlsx
From: Mcgee, Keyes [mailto:[e-mail]]
Sent:Wednesday, November 3, 2021 11:59 AM
To:Sarah Laughlin<[e-mail]>
Cc: Graznak,Jenny<[e-mail]>
Subject: [External Sender]StarPet
Sarah,
Thank you again for inviting us to be there yesterday to learn more about StarPet.This was very helpful for
understanding the recent high level 1.4-D discharges.
i

Please send us the calculations you made for mass of 1,4-D discharged during the recent high-concentration events.
Appreciatively,
Keyes
Keyes McGee
Municipal Permitting Unit-NPDES, Pretreatment and Collection Systems
Division of Water Resources
Department of Environmental Quality
[phone] Office
[phone] Cell
Working in the office and at home due to the State of Emergency and DWR policy for Covid-19. '"Email
is preferred but we are available to talk by phone or meet via Microsoft Teams or WebEx"*
BE SAFE AND BE WELL!
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
2

Sarah Laughlin
From: Meritech Reports <[e-mail]>
Sent: Thursday, November 4, 2021 2:03 PM
To: Sarah Laughlin
Subject: [External Sender] Meritech Data
Attachments: 10292131-Asheboro 1,4 Dioxane- LMC.pdf
Thank you,
Lindsey Corbett
Administrative Assistant
Meritech, Inc.,
Office: 336-342-4748
Fax: [phone]
eports(,1 merttechlabs.com

Sarah Laughlin
From: Sarah Laughlin
Sent: Thursday, November 4, 2021 2:32 PM
To: 'Grzyb,Julie';Graznak,Jenny; Montebello, Michael J
Subject: Asheboro 1,4 Dioxane Data
Attachments: 1 02921 31-Asheboro 1,4 Dioxane- LMC.pdf
Hi,
Attached is the Asheboro 1,4 Dioxane Results from Oct. 29t"
These results are high as expected. StarPet had the treatment system offline for a few hours on Oct. 29th in
order to perform necessary maintenance and troubleshoot the system. They cleaned the heat exchanger
which was fouled and would have had the system back online in under 2 hours however the gaskets had
deteriorated and would not seal. StarPet made the decision to remove a heat exchanger from another
location on site and install it in the treatment system in order to get it online. This allowed them to get the
treatment system back online in around 4-6 hours instead of waiting 4 days for new gaskets to arrive.
StarPet was able to hold back water and no untreated water was discharged during the downtime.
We are hopeful this has fixed the issue and the results will be back to normal going forward.
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
slaughlinc< ci.asheboro.nc.us
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
1

Sarah Laughlin
From: Sarah Laughlin
Sent: Friday, November 5, 2021 10:22 AM
To: 'Graznak,Jenny'; Montebello, Michael J
Cc: Michael Rhoney
Subject RE: [External Sender] [External] Asheboro 1,4 Dioxane Data
Jenny—3 hours is from that lift station to the WWTP influent— I read your question wrong before. Our
detention time varies with our flow but it's around 36 hours. So, StarPet to Effluent might be approximately
40 hours? Again, these are all rough estimates.
We have not contacted anyone downstream. When Greensboro and Reidsville got a violation issued in
November of 2019 for not notifying the state and downstream users of high discharges, Asheboro
contacted the State for guidance on what was considered a high discharge concentration for Asheboro and
thus warrant a notification. I know Michele spoke on the phone with Julie Gryzb about this issue at that time
and she requested that we send an email asking for a formal response. She would not tell us a number over
the phone. Asheboro never got a response. Asheboro began sending all 1,4 Dioxane data to the State upon
receipt at that time but it has not been our practice to notify downstream users as we never received any
guidance or requirements from the State.
Let me know if you need anything else,
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
[e-mail]
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
From:Graznak,Jenny [mailto:[e-mail]]
Sent: Friday, November 5, 20219:16 AM
To:Sarah Laughlin<[e-mail]>; Montebello, Michael 1<[e-mail]>
Subject: RE: [External Sender] [External]Asheboro 1,4 Dioxane Data
Sarah—is that 3 hours from lift station to effluent pipe? How long is detention time in the WWTP from influent to
effluent?
Also, have you guys had any contact with Sanford regarding your high effluent numbers the past few weeks?
Jenny Graznak
Assistant Regional Supervisor

Winston Salem Regional Office
Division of Water Resources
Department of Environmental Quality
450 West Hanes Mill Road,Suite 300
Winston Salem NC 27105
336-776-9695 office
336-403-7388 mobile
;cuenr.gov
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From:Sarah Laughlin< [e-mail] >
Sent:Thursday, November 4,2021 3:56 PM
To:Graznak,Jenny< raznakPncdenr.gov>; Grzyb,Julie< •,laa [e-mail]' >; Montebello, Michael J
< "r Pr!r.goy>
Subject: RE: [External Sender] [External] Asheboro 1,4 Dioxane Data
CAUTION: External email.Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Span;.
3 hours is a very rough estimate. That number is from a 2007 study on a Lift Station across the street. I
don't have any newer data.
rpet:
Date Result GPD T1 LS Reading Lbs Discharged to POTW
ug/L
10/29/2021 76,200 60,580 38.4991
VTA TP Fffluen+
Date Result ug/L MGD Lbs Discharged to Hasketts
10/29/2021 636 4.978 26.405
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
slaughlin(�ci.asheboro.nc.us
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
2

From:Graznak,Jenny [ ailto:ienny.graznak [e-mail] ]
Sent:Thursday, November 4, 2021 3:33 PM
To:Sarah Laughlin< aughiin@:Jci.asnevuru.nc.us>;Grzyb,Julie<iulie.grzvb(ancdenr.go\ >; Montebello, Michael 1
<av�icnae�. • >
Subject: RE: [External Sender] [External]Asheboro 1,4 Dioxane Data
Sarah,what is typical detention time from Pineview outfall to Asheboro effluent pipe—do you have an estimate?
Also, can you tell us what the flow was for the WWTP on Oct 29?
Much appreciated,
Jenny Graznak
Assistant Regional Supervisor
Winston Salem Regional Office
g
Division of Water Resources
Department of Environmental Quality
450 West Hanes Mill Road,Suite 300
Winston Salem NC 27105
336-776-9695 office
336-403-7388 mobile
ipnnv.graznak@t
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From:Sarah Laughlin< 'l!.+ghlinnci,!shebrro.nc.us>
Sent:Thursday, November 4, 2021 2:32 PM
To:Grzyb,Julie<iuiie.grzyb/cOncdenr.gav>; Graznak,Jenny<[e-mail]\>; Montebello, Michael J
< [e-mail]>
Subject: [External)Asheboro 1,4 Dioxane Data
CAUTION External email.Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Sl.
Hi,
Attached is the Asheboro 1,4 Dioxane Results from Oct. 29`h
These results are high as expected. StarPet had the treatment system offline for a few hours on Oct. 29th in
order to perform necessary maintenance and troubleshoot the system. They cleaned the heat exchanger
which was fouled and would have had the system back online in under 2 hours however the gaskets had
deteriorated and would not seal. StarPet made the decision to remove a heat exchanger from another
location on site and install it in the treatment system in order to get it online. This allowed them to get the
3

treatment system back online in around 4-6 hours instead of waiting 4 days for new gaskets to arrive.
StarPet was able to hold back water and no untreated water was discharged during the downtime.
We are hopeful this has fixed the issue and the results will be back to normal going forward.
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
slaujhlin i'ci.asheboro.nc.us
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
4

Sarah Laughlin
From: Meritech Reports <[e-mail]>
Sent: Wednesday, November 10, 2021 10:57 AM
To: Sarah Laughlin
Subject: [External Sender] Meritech Data
Attachments: 11052164-Asheboro 1,4 Dioxane- LMC.pdf, 110321100-Asheboro 1,4 Dioxane- LMC.pdf
Thank you,
Lindsey Corbett
Administrative Assistant
Meritech, Inc.,
Office: 336-342-4748
Fax: [phone]
ea>ok r'iueritechlabs.com

Sarah Laughlin
From: Sarah Laughlin
Sent: Wednesday, November 10, 2021 11:31 AM
To: 'Graznak,Jenny; Grzyb,Julie; Montebello, Michael J
Subject: Asheboro 1,4 Data
Attachments: 11052164-Asheboro 1,4 Dioxane- LMC.pdf; 110321100-Asheboro 1,4 Dioxane- LMC.pdf
Good Morning,
Attached are Asheboro 1,4 results from November 5th
The sample titled Pineview Treatment Grab was collected during the StarPet inspection on 11/2 from the
effluent side of the treatment unit as a process control sample.
The numbers have returned to normal and the treatment system is now operating as expected. StarPet has
put measures in place to prevent this from happening in the future. As stated previously, this is a brand new
system with no established O&M schedules or known problems. StarPet was simply going off the
manufacturer and Engineer guidance on maintenance and performance expectations. Now that they are
aware this is an issue, they have added this as a maintenance item and will monitor more closely the need
for scheduled O&M on the heat exchanger to prevent it from fouling in the future. This technology is the
first of its kind so unfortunately, they are the guinea pigs to find out what maintenance is required and the
frequency. According to the Manufacturer, the heat exchanger was not expected to foul.
Please contact me with questions,
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
slaughlin(wci.asheboro.nc.us
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1

Attachment: NOV-2022-PC-0064 NC0026123 Conditions
Timeline

1,4 Dioxane October/November 2021 Timeline
All Effluent and Pineview 1,4 Dioxane results are emailed to Jenny Graznak, Julie
Grzyb, and Michael Montebello within 24 hours of receipt.
10/24/2019:S. Laughlin sent an email to Julie Grzyb and Jeff Poupart requesting a threshold value and
procedure for notifying DEQ and downstream utilities of 1,4 Dioxane Effluent discharges. No response
has been received to date (March 2022).Asheboro began submitting all valid 1,4 Dioxane data to DEQ
upon receipt at that time as a standard practice.
10/12/2021: 10/1 results received 10/12 at 12:14,S. Laughlin spoke with Will Norton (Starpet) on the
phone immediately asking him to check the treatment system.A follow up email was sent on 10/12 at
13:20 to request the phone conversation be documented. Email from W. Norton was received at 14:31.
S. Laughlin emailed results to J.Graznak,J. Grzyb,and M. Montebello on 10/12 at 13:28.S. Laughlin
spoke with J.Graznak on the phone at approximately 14:00 about the elevated numbers and Starpet's
investigation.A follow-up email was sent to J. Graznak on 10/12 at 15:37 detailing the phone
conversation and what was being done to correct the issue as well as Asheboro's current sampling plan
and past 1,4 Dioxane results.
10/14/2021:J. Graznak called S. Laughlin at approximately 15:30 on 10/14 to request additional data,
discuss the elevated Pineview discharge and ask we increase monitoring at Pineview Street sampling
site.S. Laughlin sent an email to J.Graznak on 10/14 at 15:57 with the requested data and updated
sampling plan.
10/20/2021: 10/8/21 results received on 10/20 at 13:01. Effluent only sample, results 44.5ug/L.S.
Laughlin emailed results to state on 10/21 at 11:34.
10/25/2021: Results received at 12:18.S. Laughlin notified W. Norton(Starpet)of the results at 12:46.
W. Norton requested additional information at 14:47 and S. Laughlin provided the data at 14:50. S.
Laughlin spoke on the phone with J. Graznak to alert her to the elevated Pineview result and make J.
Graznak aware S. Laughlin was waiting for a response from Starpet before sending the results to the
state so they would have the most recent information.J.Granzak found this agreeable. It was also
discussed that J.Graznak as well as a central office employee may want to conduct a site visit to Starpet
to view the process and treatment system.S. Laughlin said an inspection was already scheduled for
November 2"d and if that would be acceptable DEQ could accompany S. Laughlin at that time.J. Graznak
said she would be in touch to confirm.
10/26/2021:On 10/26 at 11:21 S. Laughlin was emailed by W. Norton that site management,
engineering staff and treatment system engineers were involved for a full investigation and he would
keep sending updates as they were available.S. Laughlin emailed results to the State on 10/26 at 11:43
along with a status update,Starpet's investigation efforts, Asheboro sampling plan and the plan to
monitor now long the elevated discharges would last.
10/27/2021:J. Graznak emailed S. Laughlin to confirm she and Keyes McGee from the central office
would be present on Nov 2nd for the site inspection at Starpet. Emails confirming this date and time
were exchanged.

10/29/2021: Early morning,W. Norton (Starpet) called S. Laughlin to let her know the treatment system
will be taken offline later today in order to clean and service the heat exchanger.They are unsure if this
will fix the problem and Starpet will hold as much water back as possible without discharging. 12:13
Results were received.13:16 results were emailed to DEQ and a status update was provided which
included, remedial actions being done by Starpet,the current treatment system shutdown and cleaning
which was to be completed that day, Asheboro's sampling plan,and more information regarding the
treatment system.
11/1/2021:Will Norton called S. Laughlin. The treatment system was offline for a few hours.The heat
exchanger was taken out,cleaned and when they went to re-install the gaskets wouldn't seal.The
gaskets had not held up well to the heat and needed replaced. Will said they brought an extra heat
exchanger from another part of the plant in order to get the treatment system up and running instead
of waiting for new gaskets to come in which were expected on 11/2 sometime.They sent samples to
their sister plant to be analyzed down to 0.5ppm.
11/2/2021:S. Laughlin, Keyes McGee,Jenny Graznak, Michael Rhoney did a site visit.Treatment system
was viewed,the state got questions answered. S. Laughlin did annual site inspection. Grab sample from
the treatment system effluent was collected.
11/3/2021: 11:59 Keyes McGee emailed for additional information regarding Starpet and 1,4 Dioxane
discharges.S. Laughlin emailed the requested information at 14:10
11/4/2021: 14:03 Oct. 29th results received.S. Laughlin sent results by email to the state and outlined
the remedial efforts completed thus far, let the state know exactly what Starpet has done and that the
discharge is expected to return to normal going forward but the pending results from 11/2 samples will
be the confirmation.
11/4-5/2021: Emails exchanged between S. Laughlin,J.Graznak and M. Montebello requesting
detention time information,travel time from Starpet to WWTP influent/Effluent.J.Graznak inquired if
Asheboro had notified or had any contact with Sanford (First downstream drinking water user).S.
Laughlin confirmed Asheboro had not contacted any downstream user and quoted the email sent
10/24/2019 requesting state guidance on when to notify downstream user which was never responded
to.S. Laughlin also mentioned Asheboro's Standard Practice of emailing results to DEQ immediately
upon receipt.This was not requested or required by DEQ just a practice Asheboro adopted voluntarily. It
was noted in the 2019 email that Asheboro discharge fluctuates so an unusual or high discharge was
hard to define.
11/10/2021: Results received 10:57.S. Laughlin emailed results to DEQ at 11:31. Email included that the
treatment system has returned to normal operation,the action taken,and future actions that will put in
place. It was detailed that this is a new system and the O&M schedules and Manufacturers
recommendations were being followed previously.According to the manufacturer and engineers of the
system,the heat exchanger was not supposed to foul however, it did.Starpet has now added the heat
exchanger maintenance to the scheduled routine O&M to prevent future issues.
November 2021:Results return to normal.

Attachment: NOV-2022-PC-0064 WQ Standards Emails

Sarah Laughlin
From: Michele Dawes
Sent Saturday, August 21, 2021 2:18 PM
To: Sarah Laughlin
Subject: FW: [External Sender] [External] State Lab
Michele H. Dawes
Technical Services Manager
Water Resources Division
City of Asheboro
336-672-0892 x 217
Original Message
From: Graznak, Jenny [[e-mail]]
Sent: Tuesday, February 9, 2021 3:26 PM
To: Michele Dawes <[e-mail]>
Subject: RE: [External Sender] [External] State Lab
It is not incorrect, per se. However, the lab suggests not averaging results. You can put the DWR result in
the comments section. I know Martie only averages the Meritech and Pace sample results for her DMR.
Jenny Graznak
Assistant Regional Supervisor
Winston Salem Regional Office
Division of Water Resources
Department of Environmental Quality
450 West Hanes Mill Road, Suite 300
Winston Salem NC 27105
336-776-9695 office
336-403-7388 mobile
[e-mail]
Email correspondence to and from this address is subject to the North Carolina Public Records Law and
may be disclosed to third parties.
Original Message

From: Michele Dawes <[e-mail]>
Sent: Tuesday, February 9, 2021 3:00 PM
To: Graznak, Jenny <https://urldefense.proofpoint.com/v2/url?u=http-3A jenny.graznak-
40ncdenr.gov&d=DwIFAg&c=euGZstcaTDllvimEN8b7jXrwgOf-v5A_CdpgnVfiiMM&r=tWelK-
Iz8wYSmErIyA3FeudFP--
oTB1wLCRYZMv0fUg&m=TPIQXd0cJO19_fnBm9s3hu6utiuXtMogfbMXJVEzzMM&s=260xbcmHt9cUMTOOM
MDazs2u9MMNnObsnhtkUVRx2qo&e=>
Subject: RE: [External Sender] [External] State Lab
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email
as an attachment to Report Spam.<mailto:[e-mail]>
I averaged the samples that were split with the state on our DMR. Is this correct or incorrect?
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From: "Graznak, Jenny" <https://urldefense.proofpoint.com/v2/url?u=http-3A_jenny.graznak-
40ncdenr.gov&d=DwIFAg&c=euGZstcaTDllvimEN8b7jXrwgOf-v5A_CdpgnVfiiMM&r=tWelK-
Iz8wYSmErIyA3FeudFP--
oTB1wLCRYZMv0fUg&m=TPIQXd0cJO19_fnBm9s3hu6utiuXtMogfbMXJVEzzMM&s=260xbcmHt9cUMTOOM
MDazs2u9MMNnObsnhtkUVRx2qo&e=>
Date: 2/9/21 2:55 PM (GMT-05:00)
To: Michele Dawes <[e-mail]>
Subject: RE: [External Sender] [External] State Lab
The response from our lab is this:
"Correct. Since the certification group works with / for us it would be a conflict of interest for them to certify
our laboratory. We are not certified for any parameter, but we follow the same guidelines/ audit schedules
/ procedures/ proficiency testing schedule that the certified laboratories follow."
Jenny Graznak
Assistant Regional Supervisor
Winston Salem Regional Office
Division of Water Resources
Department of Environmental Quality
450 West Hanes Mill Road, Suite 300
2

Winston Salem NC 27105
336-776-9695 office
336-403-7388 mobile
[e-mail]<[e-mail]>
Email correspondence to and from this address is subject to the North Carolina Public Records Law and
may be disclosed to third parties.
From: Michele Dawes <[e-mail]>
Sent: Tuesday, February 9, 2021 2:26 PM
To: Graznak, Jenny <https://urldefense.proofpoint.com/v2/url?u=http-3A_jenny.graznak-
40ncdenr.gov&d=DwIFAg&c=euGZstcaTDllvimEN8b7jXrwgOf-v5A_CdpgnVfiiMM&r=tWelK-
Iz8wYSmErIyA3FeudFP--
oTB1wLCRYZMv0fUg&m=TPIQXd0cJO19_fnBm9s3hu6utiuXtMogfbMXJVEzzM M&s=260xbcmHt9cUMTOOM
MDazs2u9MMNnObsnhtkUVRx2qo&e=>
Subject: [External] State Lab
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email
as an attachment to Report Spam.<mailto:[e-mail]>
Jenny,
Hi! Hope all is well. I was looking at the Greensboro 1,4 report that Martie sends out.
The spreadsheet states that the NC lab is not certified for 1,4. Is this true?
-lave a great evening!
Michele H. Dawes
Technical Services Manager
Water Resources Division
City of Asheboro
336-672-0892 x 217
3

Sarah Laughlin
From: Graznak,Jenny <[e-mail]>
Sent: Thursday, September 16, 2021 12:05 PM
To: Sarah Laughlin
Subject: RE: [External Sender] [External] RE: Final Reports
You are reporting the result correctly, and your sample from your lab would be the one used for compliance purposes.
No need to average results unless you are splitting between two commercial labs.
We have noticed some variation in our results numbers.
Jenny Graznak
Assistant Regional Supervisor
Winston Salem Regional Office
Division of Water Resources
Department of Environmental Quality
450 West Hanes Mill Road,Suite 300
Winston Salem NC 27105
336-776-9695 office
336-403-7388 mobile
jeriny.grazriah�uJiicuenr.gov
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From:Sarah Laughlin<[e-mail]>
Sent:Thursday,September 16, 2021 12:00 PM
To:Graznak,Jenny<[e-mail]>
Subject: [External) RE: Final Reports
CAUTIC External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Thanks Jenny,
Meritech reported 58.9 ug/L for our grab split sample on 9/1. That's a pretty big difference from 120 ug/L
reported by the state lab. When we get a permit and/or limit, which result would be used for compliance?
Would we need to average those results —we have been reporting Meritech numbers on the DMR and
listing State results in the comments due to the state lab not being certified. Split samples are supposed to
be reproducible, any idea why the state lab always reports much higher than what we get from Meritech?
Thanks!
Sarah W. Laughlin

Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
slaughlin@ ci.asheboro.nc.us
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
From:Graznak,Jenny [ ailto [e-mail]]
Sent:Thursday,September 16,2021 11:44 AM
To:Sarah Laughlin< [e-mail]>
Subject: [External Sender] FW: Final Reports
Jenny Graznak
Assistant Regional Supervisor
Winston Salem Regional Office
Division of Water Resources
Department of Environmental Quality
450 West Hanes Mill Road,Suite 300
Winston Salem NC 27105
336-776-9695 office
336-403-7388 mobile
[e-mail]
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From:Johnson,Chris<chri �� .Rov>
Sent:Thursday,September 16,202111:10 AM
To:Graznak,Jenny< nny.Rraznak@ncd . ov>
Subject: Final Reports
Attached.
Chris Johnson
Environmental Program Manager
Water Sciences Section
North Carolina Department of Environmental Quality
Division of Water Resources
4405 Reedy Creek Road
Raleigh, NC 27607
Office: 919-733-3908
2

Email correspondence with this address is subject to North Carolina
public record regulations and may be disclosed to third parties.
3

Sarah Laughlin
From: Graznak,Jenny <[e-mail]>
Sent: Monday, November 29, 2021 3:35 PM
To: Sarah Laughlin
Subject: RE: [External Sender] [External] Asheboro 1,4 Data
Yes. Because Mike was out of town and the fill in person missed the day to turn in the samples prior to the Veterans Day
restrictions.
Jenny Graznak
Assistant Regional Supervisor
Winston Salem Regional Office
Division of Water Resources
Department of Environmental Quality
450 West Hanes Mill Road,Suite 300
Winston Salem NC 27105
336-776-9695 office
336-403-7388 mobile
[e-mail]
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From:Sarah Laughlin<[e-mail]>
Sent: Monday, November 29, 2021 3:33 PM
To: Graznak,Jenny<[e-mail]>
Subject: RE: [External]Asheboro 1,4 Data
CAUTIC External email.Do not dick links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Thanks Jenny— Do you know why the 5th samples were not submitted to the lab till the 16th which was out
of hold time?
Hope your Thanksgiving was relaxing!
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
slaughlince ci.asheboro.nc.us
1

Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
From:Graznak,Jenny [ lailto:][e-mail]]
Sent: Monday, November 29,2021 2:50 PM
To:Sarah Laughlin< .aun,,,,wci.asheboro.nc >
Subject: [External Sender] RE: [External]Asheboro 1,4 Data
Jenny Graznak
Assistant Regional Supervisor
Winston Salem Regional Office
Division of Water Resources
Department of Environmental Quality
450 West Hanes Mill Road,Suite 300
Winston Salem NC 27105
336-776-9695 office
336-403-7388 mobile
yciit,y.14 aLi,dk@riu n.pv
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to third parties.
From:Sarah Laughlin< [e-mail]>
Sent: Monday, November 29,2021 2:49 PM
To:Grzyb,Julie<[e-mail]>; Graznak, Jenny<[e-mail]' >; Montebello, Michael J
MontebelloPncdenr.gov>
Subject: [External]Asheboro 1,4 Data
CAUTIOI'-i. External email.Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spi ,;
Please find attached the following Asheboro 1,4 Dioxane Results:
Effluent and Pineview Grab samples from November 19th and November 22nd
The Effluent Weekly Composite sample from November 1st— 5t" Asheboro sent their split to Meritech after
the State Lab received a preliminary high result. These samples were analyzed out of hold time. Asheboro
has an extended retention time at our WWTP — over 54 hours. This result was high due to residual Starpet
WW working through our plant. The problem has been fixed and the more recent results prove this.
The N. Fay Comp November 1st— 5th sample is a sampler Asheboro has downstream of our CWT. We
collect weekly composites and hold the samples until we receive the results of our Effluent weekly
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composite and grab. This was sent off as a precaution due to the high state Effluent weekly comp results.
Our CWT averages around 20,000gpd discharge.
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
[e-mail]
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
3

Attachment: NOV-2022-PC-0064 WQ Standards Split
Sample Comparisons
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Asheboro WWTP Effluent Grab Split Sample Results
Date Meritech, Inc. (ug/L) NC DEQ-DWR Lab (ug/L) Relative Percent Difference (%)
11/17/2020 72.6 110 41
12/15/2020 1.23 3.3 91.4
1/13/2021 3.05 3.6 16.5
2/16/2021 20.5 46 76.7
3/16/2021 145 200 31.9
4/22/2021 14.1 15 6.2
5/24/2021 147 290 65.4
6/22/2021 88.8 130 37.7
7/16/2021 153 240 44.3
7/23/2021 55.7 82 38.2
7/30/2021 115 220 62.7
8/6/2021 34.4 64 60.2
8/13/2021 25.2 25 0.8
8/20/2021 55.6 82 38.4
8/27/2021 64.6 96 39.1
9/1/2021 58.9 120 68.3
9/10/2021 70.2 100 35
9/17/2021 63.9 83 26
9/24/2021 98.6 140 34.7
10/1/2021 37.5 38 1.3
10/8/2021 44.5 68 41.8
10/15/2021 114 270 81.3
10/21/2021 548 920 50.7
10/29/2021 636 940 38.6
11/5/2021 75.3 130 53.3
11/12/2021 3.82 6 44.4
11/19/2021 5.04 7.2 35.3
12/3/2021 59.7 65 8.5
12/10/2021 2.7 4.1 41.2
12/17/2021 11.3 17 40.3
1/7/2022 102 130 _ 24.1
1/14/2022 26.9 22 20
1/28/2022 25.2 22 13.6
1 2/4/2022 74.7 110 38.2
2/11/2022 107 180 50.9
2/18/2022 34.6 74 72.6
2/25/2022 133 190 35.3
3/4/2022 25 33 27.6
3/11/2022 136 190 33.1