NC0047384_compliance (settlement of contested SOC)_20211123

STATE OF NORTH CAROLINA
COUNTY OF GUILFORD
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
Haw River Assembly,
Petitioner,
v.
North Carolina Environmental Management,
Respondent,
and
City of Greensboro,
Respondent -Intervenor
21 EHR 01770
STATE OF NORTH CAROLINA
COUNTY OF WAKE
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
Fayetteville Public Works Commission,
Petitioner,
v.
North Carolina Environmental Management
Commission,
Respondent,
and
City of Greensboro,
Respondent -Intervenor
21 EHR 01771

Settlement Agreement
Petitioners Haw River Assembly and Fayetteville Public Works Commission ("FPWC"),
Respondent North Carolina Environmental Management Commission (the "Commission"), and
Respondent -Intervenor City of Greensboro (the "City") (collectively the "Parties") hereby enter
into this Settlement Agreement ("Agreement") in order to resolve a matter in controversy between
them. This matter arose out of the issuance by the Commission of a Special Order by Consent
EMC-SOC-WQ-S19-010 on March 11, 2021 (the "SOC"). The SOC had been agreed to by the
Commission and City. Haw River Assembly and FPWC each filed a Petition for Contested Case
Hearing in 21 EHR 01170 & 01771 challenging the issuance of this SOC (the "Litigation") and
the two contested cases were consolidated.
NOW THEREFORE, for and in consideration of the mutual promises contained herein and
without the adjudication of any findings of fact or conclusions of law set forth herein, the Parties
agree to settle the controversy as follows:
1. In order to avoid the cost and delay of further litigation, the Parties have entered into this
Agreement and have agreed that all Parties have been correctly designated and that there is no
question as to misjoinder or nonjoinder.
2. In order to resolve the Litigation:
a. The Parties other than the Commission agree to the terms of the SOC attached hereto
as Attachment A ("Amended SOC"). To become effective, this Agreement must be
presented to and approved by the Commission as provided hereinafter.
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b Immediately following execution of this Agreement by all Parties other than the
Commission, the City shall request that the Commission amend the SOC as shown in
Attachment A.
c. If the Commission approves the Amended SOC, within seven (7) days of such
approval, the City shall submit to the North Carolina Department of Environmental
Quality ("DEQ"), Division of Water Resources and the Petitioners an amended version
of the City's Sampling/Monitoring Plan (approved by DEQ on September 28, 2021).
The current version of the City's Sampling/Monitoring Plan is attached as Attachment
B. The amended plan shall include the following proposed revisions to the extent not
already included in the Plan:
i. The City shall sample and analyze the discharge of all 29 Significant Industrial
Users (SIUs) (32 sampling sites) for two consecutive quarters, with the first
round of sampling to be completed no later than November 15, 2021. In Years
Two and Three of the Amended SOC the City shall sample and analyze the
discharge of any of the 29 SIUs for which the Year One samples showed
detectable concentrations of 1,4-dioxane in its effluent and which has not
developed a source reduction plan. In the event an SIU exceeds 100 µg/L in
Year One, 31.5 µg/L in Year Two, or 23 µg/L in Year Three, City shall contact
the SIU and require it to respond to the Source Investigation, Evaluation and
Survey according to the procedures specified in the SOC.
ii. To the extent not already included in the Sampling/Monitoring Plan, the City
shall also revise the Plan as follows:
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1. The City shall add two additional surface water sampling sites, one at
the Pittsboro drinking water intake that will be sampled weekly and one
at the Haw River Arm of Jordan Lake that will be sampled twice per
month.
2. The City shall add one daily composite sample of T.Z. Osborne influent
for 1,4-dioxane once per week as an indicator test.
3. If the T.Z. Osborne effluent value exceeds 35 µg/L, the City shall send
the most recent daily and weekly composite samples to a DEQ-approved
laboratory for rush analysis.
4. The City shall post any revisions to the Sampling/Monitoring Plan to
the City's Water Resources Department website within one week of
DEQ's approval of the revised Plan.
d. The Commission agrees to review and consider the City's request made pursuant to
paragraph 2(a). Further, if the Amended SOC is issued, the Commission agrees to take
the actions set forth in Attachment C.
3. The Parties agree that neither this Agreement nor any provision or term of this Agreement
constitutes an admission of any violation of a statute or rule, of non-compliance with any
provision or requirement of the SOC, or of the applicability of any regulation or standard
to the subject matter included in the SOC.
4. In the event a party alleges non-compliance of any provision of this Agreement by another
party, the party alleging the non-compliance shall provide the allegedly non -complying
party written notice which shall include a description of the alleged violation(s). The
4

parties shall meet within a reasonable time to discuss the alleged non-compliance and to
establish a reasonable time period not to exceed fifteen (15) days to achieve compliance
("cure period"). If the Amended SOC is approved by the Commission, nothing in this
Agreement shall be construed to limit the authority of the Commission, either directly or
by virtue of a delegation of authority to the Department, to enforce the terms and conditions
of the Amended SOC. Furthermore, if the Commission approves the Amended SOC, the
Parties expressly recognize and acknowledge that the cure period described in this
paragraph does not apply to any actions taken by the Commission or the Department to
enforce the terms and conditions of the Amended SOC.
5. The Parties agree and acknowledge that this Agreement is only intended to resolve the
Litigation and no other matter.
6. Within five (5) days after the later of (a) the issuance of Amended SOC, (b) the
Commission's vote to initiate the actions described in Attachment C, or (c) the City's
submission of the amended Sampling/Monitoring Plan consistent with paragraph 2(c), each
Petitioner shall file a voluntary dismissal with prejudice of its respective Petition for
Contested Case Hearing in the above captioned matters, 21 EHR 01770 & 01771.
7. The Parties agree and acknowledge that they have reviewed, negotiated and agreed to the
terms herein as a result of an arms' length transaction entered in good faith. No inference
or presumption shall be made against the drafter of this document as to the meaning of any
term herein.
8. The Parties agree and acknowledge that the consideration for this settlement is the promises
and mutual covenants contained herein, the receipt and sufficiency of which the Parties
5

hereby acknowledge. The Parties agree and acknowledge that this Agreement contains the
whole agreement between them.
9. This Agreement shall be construed and interpreted in accordance with the laws of the State
of North Carolina, without giving effect to North Carolina's rules concerning conflicts of
laws. The exclusive venue for enforcement of this Agreement is North Carolina.
10. This Agreement shall become effective immediately following execution by all the Parties.
In the interests of time and efficiency, the signature pages may be delivered separately to
the Parties. Scanned and e-mailed execution are as valid as original execution. Thereafter,
all copies of the Agreement and executed signature pages shall constitute an original.
11. In the event the Commission votes not to approve the Amended SOC, at the election of
any party and upon notice to the other parties, this Agreement and its requirements, whether
or not already implemented, shall become void and no longer in effect.
12. No supplement, modification, waiver, or amendment of this Agreement shall be binding
unless executed in writing by all the Parties.
13. This Agreement shall be binding upon the Parties, their successors and assigns, upon
execution by the undersigned, who represent and warrant that they are authorized to enter
into this Agreement on behalf of the Parties hereto.
14. This Agreement is entered into knowingly, intelligently, and voluntarily.
[signatures on following page(s)]
6

PETITIONER HAW RIVER ASSEMBLY
By.
Elaine Chiosso
Executive Director
Haw River Assembly
I/ / S/z a.z /
PETITIONER FAYETTEVILLE PUBLIC WORKS COMMISSION
.By:
Date:
Elaina Ball
Chief Executive Officer
Fayetteville Public Works Commission
RESPONDENT NORTH CAROLINA ENVIRONMENTAL MANAGEMENT
COMMISSION
By:
Robin Smith
Chair
North Carolina Environmental Management Commission
Date:
RESPONDENT -INTERVENOR CITY OF GREENSBORO
By
Date:
Michael Borchers
Director of Water Resources
City of Greensboro
7

PETITIONER HAW RIVER ASSEMBLY
By:
Elaine Chiosso
Executive Director
Haw River Assembly
PETITIONER FAYETTEVILLE PUBLIC WORKS COMMISSION
By:
Date:
Elaina Ball
Chief Executive Officer
Fayetteville Public Works Commission
RESPONDENT NORTH CAROLINA ENVIRONMENTAL MANAGEMENT
COMMISSION
By:
Robin Smith
Chair
North Carolina Environmental Management Commission
Date:
RESPONDENT -INTERVENOR CITY OF GREENSBORO
By:
Date:
Michael Borchers
Director of Water Resources
City of Greensboro

PETITIONER HAW RIVER ASSEMBLY
By:
Elaine Chiosso
Executive Director
Haw River Assembly
PETITIONER FAYETTEVILLE PUBLIC WORKS COMMISSION
By:
Date:
Elaina Ball
Chief Executive Officer
Fayetteville Public Works Commission
RESPONDENT NORTH CAROLINA ENVIRONMENTAL MANAGEMENT
COMMISSION
By:
Date:
Robin Smith
Chair
North Carolina Environmental Management Commission
RESPONDENT -INTERVENOR CITY OF GREENSBORO
By:
Michael Borchers
Director of Water Resources
City of Greensboro
Date: November 12, 2021

PETITIONER HAW RIVER ASSEMBLY
By: •
Elaine Chiosso
Executive Director
Haw River Assembly
/ 5/2 /
PETITIONER FAYETTEVILLE PUBLIC WORKS COMMISSION
By
Date:
Elaina Ball
Chief Executive Officer
Fayetteville Public Works Commission
RESPONDENT NORTH CAROLINA ENVIRONMENTAL MANAGEMENT
COMMISSION
By:
Date:
Robin Smith
Chair
North Carolina Environmental Management Commission
I1 /12hd2/
RESPONDENT -INTERVENOR CITY OF GREENSBORO
By.
Date:
Michael Borchers
Director of Water Resources
City of Greensboro
7

Attachment A

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF GUILFORD
IN THE MATTER OF
NORTH CAROLINA
NPDES PERMIT NC0047384
HELD BY
CITY OF GREENSBORO
AMENDED SPECIAL ORDER BY
CONSENT
EMC SOC WQ S19-010
Pursuant to the provisions of North Carolina General Statutes (G.S.) 143-215.2, this Amended
Special Order by Consent is entered into by the City of Greensboro, hereinafter referred to as the
City, and the North Carolina Environmental Management Commission, an agency of the State of
North Carolina created by G.S. 143B-282, and hereinafter referred to as the Commission.
1. The City and the Commission hereby stipulate the following:
a. This Amended Special Order by Consent (Amended SOC or Amended Special Order)
addresses issues related to the discharge of elevated levels of 1,4-dioxane from the T.Z.
Osborne WWTP to South Buffalo Creek. On November 14, 2019, the North Carolina
Department of Environmental Quality (the Department or DEQ) issued a Notice of
Violation (NOV) to the City related to the elevated discharges of 1,4-dioxane.
b. The City holds North Carolina NPDES permit NC0047384 for operation of an existing
wastewater treatment works, and for making an outlet therefrom, for treated wastewater
to South Buffalo Creek, Class WS-V, NSW waters of this State in the Cape Fear River
Basin. NPDES Permit NC0047384 does not currently contain discharge limitations for
1,4-dioxane.
c. In its November 2017 Technical Fact Sheet on 1,4-dioxane, the United States
Environmental Protection Agency (EPA) describes this compound as "a synthetic
industrial chemical that is completely miscible in water." Its primary historical use
was as a stabilizer of chlorinated solvents. The EPA fact sheet states 1,4-dioxane is a
by-product present in many goods, including paint strippers, dyes, greases, antifreeze
and aircraft deicing fluids, and in some consumer and personal care products
(deodorants, shampoos and cosmetics). EPA has classified 1,4-dioxane as a likely
human carcinogen; however, to date no federal maximum contaminant level (MCL)
has been established for 1,4-dioxane in drinking water.
d. The EPA Fact Sheet states "the physical and chemical properties and behavior of 1,4-
dioxane create challenges for its characterization and treatment. It is highly mobile and
does not readily biodegrade in the environment." These properties, plus its widespread
presence in industrial and consumer products, cause the compound to be identifiable in
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reportable concentrations in groundwater, and within surface water downstream of
industrialized and urbanized areas.
e. EPA has issued a health advisory for 1,4-dioxane recommending concentrations not
exceed 35 µg/L in drinking water as protection of a 1 in 10,000 excess estimated
lifetime cancer risk. EPA risk assessments indicate the drinking water concentration
representing a 1 in 1,000,000 cancer risk level for 1,4-dioxane is 0.35 µg/L.
f. 1,4-dioxane can enter a publicly owned treatment works as a constituent of industrial
and domestic wastewater. Most wastewater treatment plants are not currently designed
for the removal of compounds such as 1,4-dioxane; therefore, it can pass through the
treatment system and enter surface waters within the effluent discharge.
g.
The EPA's Third Unregulated Contaminant Monitoring Rule (UCMR 3) required
public water supply systems throughout the United States to monitor for the presence of
contaminants, including 1,4-dioxane, during the years 2013-2015.
h. Results of UCMR 3 monitoring indicated the presence of 1,4-dioxane in North Carolina
was most prevalent within the Cape Fear River Basin. The North Carolina Department
of Environmental Quality conducted follow up stream sampling studies to better
determine the concentrations of 1,4-dioxane, and their potential sources within the
basin. Results of the DEQ studies noted above indicated detectable concentrations of
1,4-dioxane downstream of the discharge from the City of Greensboro's T.Z. Osborne
WWTP.
i. Beginning in 2015, the City of Greensboro voluntarily began a 1,4-dioxane source
identification and reduction plan, which included monitoring of WWTP influent and
effluent and the City's wastewater collection system. The City's efforts included
meetings with industrial users to ask their assistance in identifying potential sources.
Information from the industrial community and collection system monitoring revealed
where to focus reduction efforts. By October 2015, the City's program had identified
one of its Significant Industrial Users (SIU) as a quantifiable source of 1,4-dioxane to
the WWTP. The SIU voluntarily agreed to conduct its own source reduction plan. Since
the implementation of the plan, the discharge of 1,4-dioxane from the T.Z. Osborne
wastewater treatment facility has been reduced by over 50% for the four-year period
from February 2016 to the present.
J.
On October 31, 2017, the Division of Water Resources (DWR), via administrative
letter, required the City to begin monthly monitoring of the effluent from the T.Z.
Osborne WWTP for 1,4-dioxane and to report the results of their analyses on monthly
monitoring reports, beginning with the report for December 2017.
k. Results from T.Z. Osborne WWTP effluent monitoring have routinely indicated the
presence of 1,4-dioxane. On August 7, 2019, an effluent concentration of 957.5 µg/L
was reported. DEQ calculations predict that 1,4-dioxane concentrations of this
magnitude within the T.Z. Osborne WWTP effluent discharge may cause the instream
2

concentration of 1,4-dioxane to exceed the 35 µg/L EPA health advisory level at a
downstream drinking water supply raw water intake location.
1. The Department has instituted a special study of the T.Z. Osborne WWTP effluent,
conducting its own monitoring of the discharge and sharing its data with the City.
m. Sampling of waters downstream of the T.Z. Osborne WWTP discharge has indicated
instances when the EPA health advisory concentration of 35 µg/L for 1,4-dioxane has
been exceeded. The sampling results indicate that Greensboro's discharge contributes
to the exceedances but they do not establish that Greensboro's discharge is the sole
source of the exceedances.
n. The purpose of this Amended Special Order is to reduce the concentrations of 1,4-
dioxane being discharged from the T.Z. Osborne WWTP. It is not intended to resolve,
be applicable to, or encompass all other point and non -point sources that may be
causing or contributing to elevated levels of 1,4-dioxane in the Cape Fear River Basin.
The initial and primary goal of this Amended Special Order is that the City's effluent
discharge will not cause concentrations of 1,4-dioxane in downstream drinking water
supplies to exceed the EPA health advisory concentration of 35 lag/L.
o. The discharge of elevated levels of 1,4-dioxane causes or contributes to pollution of the
waters of this State named above, and the City is within the jurisdiction of the
Commission as set forth in G.S. Chapter 143, Article 21.
p.
q.
The Commission and the City acknowledge that the activities enumerated in this
Amended Special Order are designed to reduce 1,4-dioxane concentrations within the
Cape Fear River Basin, and that significant future reductions will require both
technological advances and the cooperative institutional resolve of all affected parties.
Acknowledging that the physical and chemical properties of 1,4-dioxane create
challenges for its treatment and/or removal from municipal wastewater, and that large
scale treatment technologies for the removal of 1,4-dioxane at municipal WWTPs do
not currently exist, this Amended Special Order recognizes that source reduction will
be the primary and most effective means of reducing 1,4-dioxane concentrations in the
T.Z. Osborne WWTP effluent and the Cape Fear River Basin.
Since this Amended Special Order is by Consent, neither party will file a petition for a
contested case or for judicial review concerning its terms.
2. The City of Greensboro, desiring to significantly reduce its contributions of 1,4-dioxane to
the Cape Fear River Basin, hereby agrees to undertake the following activities in accordance
with the indicated time schedule:
a. Increase T.Z. Osborne's WWTP 1,4-dioxane effluent Electronic Discharge Monitoring
Report (eDMR) monitoring frequency for grab samples to weekly.
3

b. The City's SIU Wastewater Discharge Permit Application shall include 1,4-dioxane as
a site -specific Pollutant of Concern in the Priority Pollutant Checklist section requiring
applicant to certify if 1,4-dioxane is: Present at Facility, Absent at Facility, Present in
Discharge, Absent in Discharge. If the applicant indicates 1,4-dioxane is present at the
facility or present in its discharge, the City will require the discharger to submit a
description of the amount and concentration and how the applicant plans to reduce,
eliminate, treat, or manage it, and, as appropriate, require analyses of all potential (new)
industrial flows to the collection system for the presence of 1,4-dioxane prior to the
City's approval or acceptance of the wastewater. The City may require the same or
similar analyses of new commercial flows at its discretion. The City shall also obtain a
description of the character of any new discharge, its estimated volume, and its location
within the collection system.
c. Special Order Year One [to be required upon the execution date of this Amended
SOC and continued until April 30, 2022]:
1) Provide the Department with a copy of the City's existing 1,4-dioxane monitoring
plan (Sampling/Monitoring Plan), and implement the following:
i. Resample, analyze, and report at previously identified junction locations,
including North Buffalo Transfer Pump Station (1650 miles of sewer line as
of January 10, 2020).
ii. Determine trunkline and industrial contributions and investigate further as
concentrations or loadings warrant.
iii. Investigate and determine background levels of 1,4-dioxane that shall
include the following: 1) industrial contributions, 2) domestic contributions,
3) commercial contributions, 4) all drinking water contributions, and 5)
surface intake water contributions.
iv. Meet with the Department's Winston-Salem Regional Office (WSRO) on a
quarterly basis to present progress updates and provide a written meeting
summary.
v. As circumstances warrant, review and modify the 1,4-dioxane
Sampling/Monitoring Plan. Provide the Department a copy of proposed
changes prior to their implementation.
vi. Post reports generated under this section (i.e., 2(c)(1)) to the City's Water
Resources Department website within one week of sending such reports to
the Department.
2) Contact, interview, and survey indirect dischargers with identifiable, contributing,
1,4-dioxane concentrations of greater than 100 µg/L.
3) For any industrial user (including any SIU) with a discharge of 1-4-dioxane at
concentrations greater than 100 µg/L, the City will continue collaboration and
oversight regarding industrial dischargers of 1,4-dioxane to the WWTP.
i. Identify any industrial user (including any SIU) that is an indirect source of
1,4-dioxane at concentrations greater than 100 µg/L.
ii. Develop source reduction program.
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iii. Review adequacy of slug control plans and update if necessary.
iv. Increase inspection of selected SIU sources to three (3) times per year [per
2(c)(2)].
v. Submit summary of oversight activities in the Year One Report.
4) The City shall not exceed the Department's calculated effluent Year One daily
maximum grab sample SOC compliance value of 35 µg/L (Year One SOC
Compliance Value) to protect downstream drinking water intakes.
5) Develop and implement an ongoing 1,4-dioxane public education outreach plan
with applicability toward individual, commercial and industrial users of City Water
Resources Department services. Submit a summary of the plan in Year One Report
and post on the City's Water Resources Department website.
6) Report all T.Z. Osborne WWTP effluent 1,4-dioxane sampling results monthly by
email to the Department (in a format acceptable to DEQ) no later than the last
calendar day of the month following the completed reporting period and post on the
City's Water Resources Department website.
7) Report by telephone within 24 hours to the WSRO after receiving any data
(including any individual result from a grab, composite, or split sample if taken)
indicating a T.Z. Osborne WWTP effluent 1,4-dioxane concentration greater than
35 µg/L. The City will also provide email notification to downstream drinking
water utilities as soon as possible after the DEQ 24-hour notification is triggered,
but no more than 24 hours after Greensboro receives data showing an exceedance of
35 lug/L. The City is also required to submit a written report on any finalized data
regarding the exceedance, its cause, effects, and its duration to the WSRO within 5
business days by email of the City's first knowledge of the exceedance. The City
will post this written report on the City's Water Resources Department website.
8) Modify SIU permits or develop other pretreatment program mechanisms as
necessary.
9) In addition to any other reporting required by the Department, no later than forty-
five (45) calendar days after the end of Year One, the City shall submit to the
Department a written report on the Year One activities and post on the City's Water
Resources Department website. The report may be submitted by hard copy or
electronic means and must contain the following (at a minimum):
i. Summary of the City's investigation results [outlined in 2(c)(1)].
ii. Summary of any potential (new) industrial or commercial flows to the
collection system [outlined in 2(b)].
iii. Any oversight activities [outlined in 2(c)(2), 2(c)(3) and 2(c)(8)].
iv. Public education outreach plan [outlined in 2(c)(5)].
v. A table of all monitoring results for 1,4-dioxane collected during the SOC
Year One.
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vi. In the case of noncompliance with the Year One SOC Compliance Value, a
statement of the reason(s) for noncompliance, remedial action(s) taken, and
a statement on the extent to which subsequent dates or times for
accomplishment of listed activities may be affected.
vii. Based on Year One data and any follow-up monitoring activities, including
IU inspections and oversight and City of Greensboro split sample data,
determine the following and provide a summary to the Department:
o Long-term achievable effectiveness of source reduction efforts and
resulting T.Z. Osborne WWTP effluent reductions
o Industrial contributions
o Domestic contributions
o Commercial contributions
o Surface and drinking water contributions
d. Special Order Year Two FMay 1, 2022 through April 30, 20231:
1) Continue investigating industrial sources and engage with sources not defined as
SIUs that have 1,4-dioxane concentrations above 31.5 µg/L to reduce or eliminate
1,4-dioxane discharges.
2) Meet with the Department's WSRO on a quarterly basis to present progress updates
and provide a written meeting summary.
3) Report all T.Z. Osborne WWTP effluent 1,4-dioxane sampling results monthly by
email to the Department (in a format acceptable to DEQ) no later than the last
calendar day of the month following the completed reporting period and post on the
City's Water Resources Department website.
4) For any industrial user (including any SIU) that is determined to have a detectable
concentration of 1,4-dioxane in its discharge in Year One and that does not have a
source reduction plan in place, the City will sample and analyze the industrial user's
discharge and engage with the industrial user. The City will require a "Source
Investigation, Evaluation and Survey" (an example of which is attached as Exhibit
1) from those SNs that have 1,4-dioxane concentrations above 31.5 lag/L. After
receiving the results of the "Source Investigation, Evaluation and Survey," the City
will determine appropriate next steps, including a source reduction program if
appropriate, based on the investigation results and the SIU loading to the T.Z.
Osborne WWTP.
5) The City shall not exceed the Department's calculated effluent Year Two daily
maximum grab sample SOC compliance value of 31.5 µg/L (Year Two SOC
Compliance Value) to protect downstream drinking water intakes based on EPA's
drinking water health advisory.
6) Report by telephone within 24 hours to the Department's WSRO after receiving any
data (including any individual result from a grab, composite, or split sample if
6

taken) indicating a T.Z. Osborne WWTP effluent 1,4-dioxane concentration greater
than 31.5 µg/L. The City will also provide email notification to downstream
drinking water utilities as soon as possible after the DEQ 24-hour notification is
triggered, but no more than 24 hours after Greensboro receives data showing an
exceedance of 31.5 µg/L. The City is also required to submit a written report on any
finalized data regarding the exceedance, its cause, effects, and its duration to the
WSRO within 5 business days by email of the City's first knowledge of the
exceedance. The City will post this written report on the City's Water Resources
Department website.
7) Modify SIU permits or develop other pretreatment program mechanisms as
necessary.
8) Calculate a T.Z. Osborne WWTP effluent 1,4-dioxane mass balance using all data
(industrial, domestic, commercial, drinking water, and collection system data) and
submit to the Department in the Year Two Report.
9) In addition to any other reporting required by the Department, no later than forty-
five (45) calendar days after the end of Year Two, the City shall submit to the
Department a written report on the Year Two activities and post on the City's Water
Resources Department website. The report may be submitted by hard copy or
electronic means and must contain the following (at a minimum):
i. Summary of the City's oversight activities [outlined in 2(d)(1), 2(d)(4) and
2(d)(7)].
ii. Public education outreach plan update [outlined in 2(c)(5)].
iii. 1,4-dioxane mass balance [outlined in 2(d)(8)].
iv. A table of all monitoring results for 1,4-dioxane collected during the SOC
Year Two.
v. In the case of noncompliance with the Year Two SOC Compliance Value, a
statement of the reason(s) for noncompliance, remedial action(s) taken, and
a statement on the extent to which subsequent dates or times for
accomplishment of listed activities may be affected.
e. Special Order Year Three [May 1, 2023 through April 30, 20241:
1) Continue investigating industrial sources and engage with sources not defined as
SIUs that have 1,4-dioxane concentrations above 23 µg/L to reduce or eliminate
1,4-dioxane discharges.
2) Meet with the Department's WSRO on a quarterly basis to present progress updates
and provide a written meeting summary.
3) Report all T.Z. Osborne WWTP effluent 1,4-dioxane sampling results monthly by
email to the Department (in a format acceptable to DEQ) no later than the last
calendar day of the month following the completed reporting period and post on the
City's Water Resources Department website.
7

4) For any industrial user (including any SIU) that is determined to have a detectable
concentration of 1,4-dioxane in its discharge in Year Two and that does not have a
source reduction plan in place, the City will sample and analyze the industrial user's
discharge and engage with the industrial user. The City will require a "Source
Investigation, Evaluation and Survey" (an example of which is attached as Exhibit
1) from those SIUs that have 1,4-dioxane concentrations above 23 µg/L. After
receiving the results of the "Source Investigation, Evaluation and Survey," the City
will determine appropriate next steps, including a source reduction program if
appropriate, based on the investigation results and the SIU loading to the T.Z.
Osborne WWTP.
5) The City shall not exceed the Department's calculated effluent Year Three daily
maximum grab sample SOC compliance value of 23 µg/L (Year Three SOC
Compliance Value) to protect downstream drinking water intakes based on EPA's
drinking water health advisory.
6) Report by telephone within 24 hours to the Department's WSRO after receiving any
data (including any individual result from a grab, composite, or split sample if
taken) indicating a T.Z. Osborne WWTP effluent 1,4-dioxane concentration greater
than 23 µg/L. The City will also provide email notification to downstream drinking
water utilities as soon as possible after the DEQ 24-hour notification is triggered,
but no more than 24 hours after Greensboro receives data showing an exceedance of
23 lug/L. The City is also required to submit a written report on any finalized data
regarding the exceedance, its cause, effects, and its duration to the WSRO within 5
business days by email of the City's first knowledge of the exceedance. The City
will post this report on the City's Water Resources Department website.
7) Modify SIU permits or develop other pretreatment program mechanisms as
necessary.
8) In addition to any other reporting required by the Department, no later than forty-
five (45) calendar days after April 30, 2024, the City shall submit to the Department
a written report on the Year Three activities and post on the City's Water Resources
Department website. The report may be submitted by hard copy or electronic means
and must contain the following (at a minimum):
i. Summary of the City's oversight activities [outlined in 2(e)(1), 2(e)(4) and
2(e)(7)].
ii. A table of all monitoring results for 1,4-dioxane collected during the SOC
Year Three.
iii. Public education outreach plan update [outlined in 2(c)(5)].
iv. In the case of noncompliance with the Year Three SOC Compliance Value,
a statement of the reason(s) for noncompliance, remedial action(s) taken,
and a statement on the extent to which subsequent dates or times for
accomplishment of listed activities may be affected.
8

3. In case source reduction alone does not lead to the effluent SOC Compliance Value being
achieved consistently, the following shall apply:
a. If greater than or equal to 30% of eDMR data exceed the Year One SOC Compliance
Value of 35 µg/L at the end of SOC Year One, the City shall address 1,4-dioxane in the
T.Z. Osborne WWTP effluent by performing the following:
1) Submit to the Division for approval within 45 calendar days of the end of SOC Year
One a report that considers the items below:
- Investigation of alternate/additional treatment processes for removal of 1,4-
dioxane at major industrial sources.
- Investigation of the technical and economic feasibility of treatment
technologies for the removal of 1,4-dioxane at wastewater treatment plants.
- Investigation of the technical and economic feasibility of treatment
technologies for removal of 1,4-dioxane at drinking water treatment facilities.
2) Following the investigations in 3(a)(1), submit to the Division within 180 calendar
days of the end of SOC Year One a draft Best Management Practices/1,4-dioxane
Minimization Plan, which will include an implementation schedule that must be
approved by the Division before proceeding.
3) Upon Division approval of Items 1 and 2 above, post both items on the City's
Water Resources Department website.
4. The City of Greensboro, desiring to resolve the matters contributing to alleged water quality
standard violations associated with its discharge of 1,4-dioxane from the T.Z. Osborne
WWTP, has paid an upfront penalty in the amount of $5,000.00 as settlement of the alleged
violations noted in the November 14, 2019 NOV correspondence as well as any and all other
alleged violations related to 1,4-dioxane beginning December 1, 2017 through the execution
date of the original SOC, effective May 1, 2021.
a. Stipulated Penalties. The City agrees that unless excused under Paragraph 5, the City
will pay the Director of DWR, by check payable to the North Carolina Department of
Environmental Quality, stipulated penalties according to the following schedule for
failure to meet the deadlines and requirements set out in Section 2.
Description
Stipulated Penalty
Failure to provide 24-hour notice to
WSRO of elevated discharge levels
specified in Sections 2(c)(7), 2(d)(6), and
2(e)(6) of this Amended Special Order
$1 000 per event; $100/day thereafter
'
Failure to submit to WSRO complete
Annual Reports in Sections 2(c)(9),
2(d)(9) and 2(e)(8) of this Amended
Special Order by specified date
$1,000 per event; $100/day thereafter
9

Exceedance > applicable Compliance
Value and < 105 pg/L:
• Exceedance 1-5 per SOC year:
$1,000 per event, per SOC year
• Exceedance 6-10 per SOC year:
$2,000 per event, per SOC year
• Exceedance 11 and up per SOC
Failure to meet the grab sample effluent
year: $3,000 per event, per SOC
daily maximum SOC Compliance Value
year
in SOC Year One, Year Two, or Year
Exceedance > 105 pg/L:
Three
• Exceedance 1-5 per SOC year:
$5,000 per event, per SOC year
• Exceedance 6 or more per SOC
year: $10,000 per event, per SOC
year
Exceedance > 500 pg/L:
• $5,000 per event in addition to any
stipulated penalty listed above
Failure to achieve any other requirement
of this Amended Special Order
$1,000 per event
5. The City and the Commission agree that the stipulated penalties are not due if the City
satisfies DWR that noncompliance was caused solely by:
a. An act of God;
b. An act of war;
c. An intentional act or omission of a third party, but this defense shall not be available if
the act or omission is that of an employee or agent of the defendant or if the act or
omission occurs in connection with a contractual relationship with the permittee;
d. An extraordinary event beyond the permittee's control. Contractor delays or failure to
obtain funding will not be considered as events beyond the permittee's control; or
e. Any combination of the above causes.
Failure by the City to within thirty (30) calendar days of receipt of a written demand either to
pay the penalties, or challenge them by a contested case petition pursuant to G.S. 150B-23,
will be grounds for a collection action, which the Attorney General is hereby authorized to
initiate. The only issue in such an action will be whether the thirty (30) calendar days has
elapsed.
6. This Amended Special Order by Consent and any terms and/or conditions contained herein,
hereby supersede any and all previous Special Orders, Enforcement Compliance Schedule
Letters, terms, conditions, and limits contained therein issued in connection with NPDES
permit NC0047384.
7. Noncompliance with the terms of this Amended Special Order by Consent is subject to
enforcement action in addition to the above stipulated penalties, including injunctive relief
10

pursuant to G.S. 143-215.6.C. Noncompliance with the terms of this Amended Special Order
will not be subject to civil penalties in addition to the above stipulated penalties'
8. This Amended Special Order by Consent may be modified at the Commission's discretion,
provided the Commission is satisfied that the City has made good faith efforts to complete
the Compliance Schedule activities specified herein.
9. The permittee, upon complete execution but no earlier than December 1, 2021 of this
Amended Special Order by Consent, will be expected to comply with all schedule dates,
terms, and conditions of this document.
10. This Amended Special Order by Consent shall expire on July 15, 2024.
For City of Greensboro Water Resources Department:
Date: November 12, 2021
Michael Borchers, Director of Water Resources
City of Greensboro
For the North Carolina Environmental Management Commission:
Date /1 / .z /2O21
Robin Smith
Chair of the Commission
11

Attachment B

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NPDES PERMIT #NC0047384
CITY OF GREENSBORO
SUBMITTAL DATE: 9-27-2021 (Approved 9-28-21 by NCDEQ WSRO)
TABLE OF CONTENTS —CITY OF GREENSBORO 1,4-DIOXANE SOC SAMPLING/MONITORING PLAN
I. Background and Pur
II. T. Z. Osborne (TZO) POTW Information
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NPDES PERMIT #NC0047384
II. T. Z. OSBORNE POTW INFORMATION
The following criteria characterize the TZO Wastewater Treatment Facility
NC0047384 Issued July 1, 2014
June 30, 2019 (Administratively Extended by NCDEQ)
56 Million Gallons Per Day (as of 8-1-2021) [Permit Tier 2-Part I, pg 5]
Entire City of Greensboro; parts of Guilford County NC
28
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2019 = 35.5 MGD 2020 = 36.2 MGD
South Buffalo Creek WS-V/NSW Cape Fear River Basin
97% [calculated by DEQ]
NPDES Permit Number and Issue Date:
NPDES Permit Expiration Date:
Design Capacity:
Service Area:
Total Number of Significant Industrial Users:
Number of Categorical Silts:
Number of SIUs due to flow only:
Average Flow CY 2019 and CY 2020:
Receiving Waters:
Effluent Contribution at 7Q10 Flow:
The following process descriptions characterize the T. Z. Osborne Water Reclamation Facility treatment train:

NPDES PERMIT #NC0047384
CITY OF GREENSBORO
The following process descriptions characterize the TZO solids treatment and disposal train:
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1I1. GENERAL INFORMATION
Pollutant of Concern (POC): 1,4-dioxane
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IV. SAMPLING POINTS (Sf AND DESCRIPTIONS
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1. TZO Water Reclamation Facility Locations
• T. Z. Osborne POTW Influent (TZO NPDES Influent Sample)
■ North Buffalo Influent (North Buffalo NPDES Influent Sample)
■ T. Z. Osborne POTW Effluent (after chlorination/dechlorination) eDMR GRAB (52 samples/year)
■ T. Z. Osborne POTW Effluent Weekly Volumetric Composite (from NPDES Effluent samples)
■ T. Z. Osborne Aeration Tank
■ Dewatered Sludge Cake
■ Sludge Dewatering and Incinerator Scrubber discharge (to influent wet well)
SP#s 1, 2, 3 used to correlate trunkline results and loading/discharge/compliance values at TZO.
SP #3COMP is also the weekly composite the City agreed to retain for potential use by NCDEQ.
SP#s 4, 5, 6 used to confirm results of initial study that indicated 1,4-dioxane does not partition to solids/sludge.
4*
2. TZO Collection System Industrial (Sites 7-12A)
■ Industrial Trunkline Site 1 Patton: Includes 7 SIU wastestreams (SIUs: 0, T, W, AA, AE, AG, AH)
• Industrial Trunkline Site 2 Arlington: Includes 6 SIU wastestreams (SIUs: 1, L, P, Q, Y, AF)
■ Industrial Trunkline Site 3 Reedy Fork: Includes 4 SIU wastestreams (SIUs: E, F, G, H)
■ Industrial Trunkline Site 4 Airport: Includes 5 SIU wastestreams (SIUs: N, R, V, AC, AD)
■ Industrial Trunkline Site 5 Whitsett: Includes 4 SIU wastestreams (SIUs: X, AB, J, Al)
• Industrial Trunkline Site 6 North Buffalo: Includes 3 S1U wastestreams (SIUs: A, B, D)
■ Industrial Trunkline Site 7 Radar Road: Includes 2 SIU wastestreams (SIUs: S, U)
SP#s 7-12A used to conduct source identification and generate mass -balance data for the industrial sector,
includes smaller industrial users as well as SIUs as defined by EPA. SIUs include those that discharge>25,000 gpd
of process wastewater as well as SIUs subject to Categorical standards (who may or may not meet the EPA flow
criteria). SIU Total Permitted flow = 3.67 MGD.
If SIU results or trunkline results are >100 ug/I in Year One (or>33 ug/I in Year Two), City will immediately begin
source investigation/tracking/identification via additional sampling, evaluation and source notification.
Beginning August 2021- SIU composite samples routinely collected for Pretreatment Program monitoring will be
analyzed for 1,4-dioxane for initial screening purposes -Results will be provided to NCDEQ at quarterly meetings.

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NPDES PERMIT #NC0047384
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3. TZO Collection System Domestic/Commercial (Sites 13-17) ["Uncontrollable" Sources]
• Domestic/Commercial Trunkline Site 1 Wesley Long (Hospital)
■ Domestic/Commercial Trunkline Site 2 A&T University
© Domestic/Commercial Trunkline Site 3 Huffine at Wendover (Bessemer)
© Domestic Trunkline Site 4 Willoughby Boulevard
■ Domestic Trunkline Site 5 Shelby Drive
SPs #13-17 are considered uncontrollable/uncontrolled sources and used to determine typical concentrations of
1,4-dioxane in various commercial and domestic/residential areas. Loadings will be used in mass -balance and
HWA uncontrollable/uncontrolled calculations. SPs #13-15 are commercial while SPs #16-17 are considered
domestic wastewater. The majority of the flow (90%) to TZO is considered uncontrollable/uncontrolled
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4. Drinking Water Sources to Greensboro POTW (Sites 18-22)
■ Drinking Water Site 1 Townsend Plant
• Drinking Water Site 2 Mitchell Plant
• Drinking. Water Site 3 PTRWA: Holden & Bishop Rd
• Drinking Water Site 4 Burlington: Burlington Rd.
■ Drinking Water Site 5 Reidsville: Chickasha & Summit Ave
SPs #18-22 include all drinking water sources to TZO.
UCMR3 data: SPs #18, #19, #21, #22 did not have UCMR3 detections while SP #20 did have UCMR3 detections.
Loading calculations from this sector will be used in mass -balance and HWA calculations.
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5. Other Sampling Sites (Sites 23-26)
• City Landfill Leachate Discharge
■ Domestic Septage Hauler Discharge
• HaW River Arm of Jordan Lake (CPF055C) — Below Pittsboro (Note: includes all Upper Cape Fear NPDES dischargers)
I• Pittsboro Haw River Raw Water Intake (Note: Includes all Upper Cape Fear NPDES dischargers)
SP#23 had detectable values in previous 2015 study. SP#24 will be used to calculate loading from —4 MG per year
of domestic septage received at TZO. SPs#25/26 will be used to provide data for downstream utilities and
monitor goal of SOC.
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VI. SAMPLING PLAN
Comments
Based on results
Based on results
For eDMR reporting
Retain samples for NCDEQ
Samples taken on same day
Use Solid Waste Lab Method
*Duplicate at least 2 samples
Sampling with Water Division
Sampling with Water Division
*Duplicate at least 2 samples
4 Different companies
Collected by Meritech
Includes all HR dischargers
Minimum Sampling Frequency/
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BPJ - TBD
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Quarterly + Tracking
Quarterly + Tracking
Quarterly + Tracking
Quarterly + Tracking
Quarterly + Tracking
Quarterly + Tracking
Quarterly + Tracking
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TZO Aeration Tank
Sludge Cake
Solids Handling Bldg
IND 1 Patton
IND 2 Arlington
IND 3 Reedy Fork
IND 4 Airport
IND 5 Whitsett
IND 6 NB Trunkline
IND 7 Radar
COM 1 Wesley Long
COM 2 A&T Univ
COM 3 Bessemer
DOM 4 Willoughby
DOM 5 Shelby
DW 1 Townsend
DW 2 Mitchell
DW 3 PTRWA
DW 4 Burlington
DW 5 Reidsville
GSO Landfill
Domestic Septage
HR Arm Jordan Lake
Pittsboro DW Intake
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NPDES PERMIT #NC0047384
VII. FACILITY DIAGRAM - T. Z. Osborne POTW Sampling Points
Disinfection
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Regarding all data generated and submitted in response to the SOC requirements:
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SOC 1,4-DIOXANE SIU SAMPLING PLAN (and TZO Loading Estimates @100 ug/I)
1 ug/I at TZO effluent = 0.2919 pounds (using 35 MGD)
MAP
Significant Industrial User (SIU)
CY 2021
Potential
Jan -Jun average
Pounds/day
FLOW in MGD
at 100 ug/I
E
P&G Brown Summit 01
0.3542
0.295
0
Elastic Fabrics
0.1676
0.140
B
ITG (Lorillard)
0.1310
0.109
H
Shamrock BS 02
0.1290
0.108
AA
Precision Fabrics
0.1196
0.100
Aramark
0.1167
0.097
AD
QORVO
0.1140
0.095
G
Shamrock BS 01
0.0890
0.074
AH
Vertellus
0.0874
0.073
AC
P&G Swing
0.0664
0.055
N
Ecolab
0.0609
0.051
W
Lanxess
0.0586
0.049
P
Evonik 02
0.0547
0.046
Al
ZINK
0.0546
0.046
J
Qualicaps
0.0407
0.034
F
P&G Brown Summit 02
0.0405
0.034
AF
Solenis
0.0398
0.033
AE
Shamrock Patton
0.0343
0.029
L
Chemol
0.0328
0.027
Z
Piedmont Plating
0.0216
0.018
R
Express Container
0.0170
0.014
Q
Evonik 01
0.0166
0.014
S
GILBARCO
0.0112
0.009
AB
PRECOR
0.0078
0.007
Y
Parker Metal Finishing
0.0076
0.006
X
Machine Specialities
0.0055
0.005
T
Greensboro Industrial 02
0.0050
0.004
AG
United Metal
0.0046
0.004
A
Greensboro Industrial 01
0.0032
0.003
V
IQE
0.0014
0.001
D
Triad Anoding 02
0.0014
0.001
U
HAECO
0.0008
0.001
August 2021 - GSO commits to sampling/analysis of all 29 SIUs once for at least 2
quarters. (32 sampling locations since 3 S!Us have more than one discharge pipe.)
SIU sampling has already been initiated as show of good faith.
Initial focus on SIUs with highest flows, Sills with more potential to generate
1,4-dioxane, TZO SIUs, and SIUs with on -site sampling equipment.
Data from 2 quarters will be reviewed to prioritize next steps.
GSO proposes to have all Aug -Oct quarter samples to commercial lab by
November 15.

Attachment C

Within 10 days of the adoption of any revised SOC for Greensboro by Environmental
Management Commission (Commission), the Commission shall direct the North Carolina
Department of Environmental Quality (DEQ) to refine and supplement its 2016 and 2017
studies of point source dischargers in the Cape Fear River basin (the Basin) for a period of
three years. This supplement of DEQ's study will include semi-annual progress reports
(with a written progress report submitted at least annually) by DEQ for a period of three
years to the Commission's Water Quality Committee describing (at a minimum):
a. Ongoing and planned surface water and discharge sampling efforts, including
the results of such sampling;
b. Identification of point sources dischargers of 1,4-dioxane in the Basin
upstream of any drinking water intake;
c. Public update on the actions DEQ is taking to reduce 1,4-dioxane
concentrations in the Basin from sources identified under paragraph (b),
including incorporation of 1,4-dioxane limits into the NPDES permits if the
agency determines that the discharger has a reasonable potential to violate
applicable water quality standards;
d. A brief explanation of DEQ's reasoning regarding the foregoing and the
expected time for completion.
No later than three years from the date of the Commission's adoption of the revised SOC for
Greensboro, DEQ is to issue a report to the Water Quality Committee of the Commission
that makes recommendations for additional steps to be taken by DEQ and/or the
Commission in order to achieve compliance with the water quality standard for 1,4-dioxane
if any classified surface waters within the Basin have not yet achieved compliance.