NC0026123_Comments_20230111

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Water Resources Division CITY OF �. � . ;
146 N Church Street
PO Box 1106 AsHEBolu Fax: [phone]
Asheboro, NC 27204-1106
NORTH . CAROLINA
January 9, 2023
RECEIVED
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NCDEQ/DWR/NPDES NCDEQIDWRINPDES
Water Quality Permitting Section
Attention: Mr. Nick Coco
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Comments for Draft NPDES Permit NC0026123
Mr. Coco and whom it may concern:
The City of Asheboro (Asheboro) would like to offer the following comments on the draft permit
referenced above. Staff has thoroughly reviewed the permit and would like clarification on the
new limits for total silver. We would also like consideration of a review of the determination of
the NH3 limits and the frequency of monitoring for PFAS.
Asheboro would like to request clarification on the Silver compliance schedule A.(4.) 1 c. If
Asheboro were to perform a WER and a higher limit is determined, Asheboro will accept this
higher value. However, A.(4.) 1 c states the remaining compliance schedule will be removed. We
are concerned because our current domestic concentration is still greater than the limit in the above
referenced permit. The WER may result in a higher permit limit that is still lower than our
uncontrollable concentration. How will NCDEQ address this? Asheboro would still need time to
research and investigate treatment at our treatment plant. Will an additional compliance schedule
be granted at the time of the WER submittal if requested? According to the Fact Sheet, Asheboro
is 92.1% Domestic and only 7.9% Industrial. With such a low NPDES permit limit and high
percentage domestic flow, complete reduction of all industrial contributions through the
pretreatment program may not be enough to meet such restrictive limits.
Thank you for the comment addressing our ammonia mass limit request. The response states the
EPA water quality criteria is 1.0 mg/L summer and 1.8 mg/L winter. However, these are not EPA
water quality criteria. EPA uses the EPA 2015 NH3 criteria which are temperature and pH based.
This criteria has been applied in other state issued NPDES permits.Asheboro would like to request
our ammonia limits be calculated using this criteria to see if it results in a different limit.
Asheboro is requesting a reduction in the PFAS monitoring. We would like to propose a quarterly
testing for two years and then once per six months thereafter. This request is due to the economic
burden quarterly sampling for the life of the permit causes Asheboro. It is our understanding the
PFAS sampling is very expensive, upwards of$1000 a sample. This equates to roughly$20,000
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Comments for Draft NPDES Permit NC0026123
1/9/2023
Page 2 of 2
for quarterly effluent sampling over the life of the permit. If Asheboro voluntarily and/or DEQ
imposes any additional sampling locations or frequencies, this cost will increase.
As noted, the City of Asheboro Wastewater Treatment Plant is an exceptionally performing
facility. This is because we take great pride in doing all we can to protect the environment and
will continue to provide the best available treatment. Please consider our concerns with the above
referenced permit as you issue the final permit.
Please feel free to notify me at(336) 626-1201 Ext. 258 if you have any further questions.
Sincerely,
i tir&A,\/
Michael D. Rhoney, PE
Water Resources Director
RECENED
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NCDEQIDINRINPDES
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