NC0050342_Comments_20240528

RECEIVED
Winston-Salem/Forsyth County
IiJtiIities MAY 31 2024
• Water•Wastewater•Solid Waste
NC DEQ/DWR
Administration,P.O.Box 2511,Winston-Salem,NC 27102 Central Office
336-727-8000• wsfcutilities.org
May 28, 2024
Mr. Michael Montebello
North Carolina Division of Water Resources
NPDES Permitting Division
1611 Mail Service Center
Raleigh, NC 27699-1611
Subject: NC0050342 - Muddy Creek WWTP
POTW and SIU PFAS Investigative Monitoring
Dear Mr. Montebello,
I have received your draft letter, forwarded by Gary Perlmutter, for review. I am writing to express my
concerns regarding the proposed sampling requirements as these requirements are not included in our
Muddy Creek Wastewater Treatment Plant NPDES permit.We believe the recent North Carolina Court
of Appeals case No. COA22-1072,filed November 7, 2023, involving permit requirements for
concentrated animal feed operations (CAFO), provides our utility with justification for opposing these
sampling requirements.
Currently,the EPA has not officially certified Method 1633.This method should be officially added to 40
CFR Part 136 before certifying and using data to enforce regulatory requirements on our industrial base.
Winston-Salem/Forsyth County Utilities (WSFC Utilities) does not see the necessity for expansive
sampling of our industries, especially when no PFAS criteria has been adopted.
The cost implications of meeting the proposed PFAS monitoring would present a substantial financial
burden to Significant Industrial Users (Sills), Industrials Users(lUs), commercial customers, and our
community. Winston-Salem/Forsyth County Utilities has approximately 300 businesses that discharge
into our collection system that would require sampling under the proposed monitoring request.The cost
to analyze one sample is approximately$600, including shipping, which does not include our staff's time
to collect, prepare, ship, and report the data.
Our current permit states "A special condition to monitor effluent PFAS chemicals quarterly at Outfall
001 has been added to the permit, to be effective six(6) months after EPA has a final wastewater
method in 40 CFR136 method published in the Federal Register to allow for laboratories become NC-
certified in the new method [See Special Condition A. (10.) PFAS Monitoring Requirements]".This
proposed requirement clearly contradicts the language in our permit. We are agreeable to voluntarily
begin sampling of our influent and effluent at both wastewater treatment facilities to gain an
YOUR UNK TO Cm SERVICES City Council:Mayor Allen Joines;Mayor Pro Tempore Denise D.Adams,North Ward;Barbara Hanes Burke,Northeast Ward;Robert C.Clark,West Ward;
John C.Larson,South Ward;Jeff Macintosh,Northwest Ward;Kevin Mundy,Southwest Ward;Annette Scippio,East Ward;James Taylor,Jr.,Southeast Ward;
City Manager W.Patrick Pate
County Commissioners:Chair Don Martin;Vice Chair Gloria D.Whisenhunt;Dan Besse;Richard V.Linville;Tonya D.McDaniel;David R.Plyler;Malishai
CALL 311[336-727-8000] Woodbury;County Manager Dudley Watts,Jr.
TEXT:855-481-LINK[54653 Winston-Salem/Forsyth County Utility Commission:Chair L.Wesley Curtis,Jr.;Vice Chair Chris Parker;Simpson O.Brown,Jr.;Stephen Doughton;Harold
[e-mail] Eustache;Tom Griffin;Yvonne H.Hines;Hugh W.Jernigan;Duane Long;Calvin McRae;Charles Wilson

understanding of the PFAS levels in the wastewater. We will use this data to determine what further
investigation is warranted.
We respectfully object to this request based on the legal, financial and operational reasons stated
above. However, we are willing to begin quarterly sampling of our influent, effluent and residuals to gain
an understanding of PFAS levels in advance of the required sampling schedule stated in our permit.This
demonstrates our commitment to finding a mutually beneficial resolution.
Should you have any questions regarding this matter please feel;free to contact me at 336-747-7315 or
Bill Brewer at 336-727-2161.
Sincerely,
Courtney L. Driver, P.E.
Utilities Director—Winston-Salem/Forsyth County Utilities
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