NC0024881_Additional Monitoring Requirements_20190923

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Public Works Department s � 'lo�� T I IlTY
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110o Vance St., Reidsville, NC 27320 �' o' iA.tidS\711.iC
Phone: [phone] • Fax: [phone] C_ NORTH C. ROL,LINA
23 September 2019
Deborah Gore
PERCS Supervisor PeCel/ED
NC DEQ, DWR
1617 Mail ServiceCenter SEp 2 61019
Raleigh,NC 27699-1617
NCDEQ/DWR/NPDES
Re: Additional Monitoring Requirements
Reidsville WWTP, NPDES Permit No.NCoo24881
Dear Ms. Gore:
The City of Reidsville shares the Water Resources Division's desire to seek reductions of 1,4-dioxane
discharged from the city's wastewater treatment plant. December 2017, the city has monitored for 1,4
dioxane as part of the North Carolina Department of Environmental Quality (NC DEQ), Division of
Water Resources(DWR)investigation into sources of this compound.
Since December 2017,the City of Reidsville has:
• Complied with monitoring requirements of 1,4 dioxane imposed by NC DEQ, DWR.
• Engaged industry leaders to inform them 1,4 dioxane is included in the third Unregulated
Contaminant Monitoring Rule (UCMR 3) and informed them of the possible implications of strict
regulation to their industry through the city's wastewater treatment plant permit.
• Introduced Terry Albrecht, PE CEM, Director of Waste Reduction Partners, to industry leaders.
We informed them NCDEQ is offering a partnership program, Waste Reduction Partners, to
provide a no-cost, non-regulatory assessment of the city's Significant Industrial Users (SIUs) to
help address cost-effective, source reduction strategies to for any emerging contaminate issues.
• Offered in-depth explanations to industry leaders of strategic considerations the city has explored
and continues to investigate to lessen the potential impact of a low maximum containment level
(MCL).
Since monitoring began in December of 2017, the 1,4 dioxane results at the city's wastewater treatment
plant have drastically fluctuated. The cause for the wide-ranging monitoring results is under
investigation. With limited proven scientific research of 1,4 dioxane as a human carcinogen and possible
means of reduction and/or elimination of the compound,the city will maintain in observance of potential
solutions with the support of NC DEQ. Industries have asked if the NC DEQ will provide financial
support for costs associated with changing processes at their plants.
The city will continue the above-mentioned items with the suggested timelines as detailed below:
• Continue to comply with monitoring requirements of 1,4 dioxane imposed by NC DEQ, DWR -
ongoing.
• Continue to engage industry leaders to inform them of the latest developments of 1,4 dioxane with
NC DEQ and informed them of the possible implications to their industry of strict regulation
through the city's wastewater treatment plant permit—ongoing.

Public Works Department i4 `�°� , THE, CITY T OF
•d110o Vance St.,Reidsville, NC 2732o PexIsvi1' e
Phone: [phone]o7o • Fax: [phone] NORTH CCA R`C! NA
• The city has requested Reidsville industries begin providing regular reports with information
related to improved 1,4 dioxane discharges from the plant and what improvements were
implemented—ongoing.
• Keep NC DEQ informed of progress made on reducing 1,4 dioxane—ongoing.
• Partner with NC DEQ to advocate for advancement in science and technology to identify sources
of 1,4 dioxane and develop reduction solutions without closing industries.
At this time City has requested a report from specific industries that should include identifying and
reducing sources of 1,4-dioxane. The report is expected in early 2020 depending on the extent of the
industry's investigation.
Please contact me at(336) 349-1070, Ben Bani at(336) 349-1102, if you have questions.
Sincerely,
Charles Smith, Director of Public Works
Cc: Preston Mitchell— City Manager
Benjamin A. Bani-WWTP Superintendent
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