NC0026123_Comments_20180608

4 41 s
0®4w ®°% [phone]
P.O. Box 3729 c' TEREDFAX: [phone]
Sanford, NC 27331-3729 Email: [e-mail]
TAN r ofSartforb
Victor I. Czar, P.E.
Public Works Director
June 8, 2018
Julie A. Grzyb
1634 Mail Service Center
Raleigh, NC 27699-1634
Dear Ms. Grzyb,
The following is a statement of our concerns regarding the pending issuance of a discharge permit to the
City of Asheboro, North Carolina.
We received the Asheboro permit that is going to public notice on May 9th, 2019. As we understand it,
the 1,4-dioxane limit of 149 ug/L is based on the 80 ug/L water quality criteria for Class C waters and the
instream dilution factor to which they are entitled. We feel it's important to review this limit to make
sure it is protective of downstream water uses. 15A NCAC 02B .0203 states"Water quality based
effluent limitations or management practices for direct or indirect discharges of waste or for other
sources of water pollution will be developed by the Division such that the water quality standards and
best usage of receiving waters and all downstream waters will not be impaired." In reviewing the NC
Surface Water Classifications map it appears there is a WS1 and WS IV classification just downstream of
the confluence of the Deep River and Big Governors Creek,where the criteria for water supplies is 0.35
ug/L. As such,we feel DEQ should conduct some type of analysis to determine if the 149 ug/L limit is
protective of the 0.35 ug/L criteria at the downstream water supplies.
In developing permit limits to reduce 1,4-Dioxane in the Asheboro discharge,the Division of Water
Resources(DWR) does not appear to have considered downstream water supply use in the river basin.
Thus,the permit limit for 1,4-Dioxane appears to be at least 10 times higher than it should be to protect
downstream water supplies.The calculation of the permit limit also did not consider other sources of
1,4-Dioxane in the river basin.Asheboro's NPDES permit is the first of several to be issued this summer
in the river basin that will address 1,4-Dioxane levels.We believe it is important that DWR address this
issue comprehensively with the perspective of water supply use throughout the Cape Fear River basin,
and not just based on contaminant concerns near the point of discharge. Additionally,since the known
sources of Dioxane have been aware of this problem for a number of years,the City of Sanford believes
that compliance should be achieved in two years given the exposure of citizens located downstream
that are drinking the water.
Ec TVED
JUN 1,1-2018

Thank you for your time concerning this matter.We look forward to your consideration.
'ncerely, '
Victor I.Czar, P.E.
Director of Public Works
Sanford, NC
VC/vrc
Cc: Jessica C. Godreau