NC0026123_Comments_20230119

Kenneth Waldroup,PE
Executive Director
235 Government Center Drive
MI Cape Fear Wilmington,NC 28403
910-332-6669
Public Utility Authority [e-mail]
Stewardship.Sustainability.Service.
Via US Mail and Email (nick.cocoCa�ncdenr.gov) y'.ECEIVER
North Carolina Department of Environmental Quality JAN 1 9 2023
NPDES Municipal Permitting Unit
Attn: Nick Coco, PE 1617 NCDEQ!f WR/NPDEs
Mail Service Center
Raleigh, NC 27699-1617
Re: Comments on Draft NPDES Permit NC0026123
Asheboro WWTP, Lee County, North Carolina Facility Grade IV
Biological WPCS, SIC Code 4952
Dear Mr. Coco:
Cape Fear Public Utility Authority (CFPUA) provides drinking water to approximately 200,000 people in
the City of Wilmington and greater New Hanover County region. CFPUA maintains and operates three
drinking water systems, the largest of which uses the Cape Fear River as its source water. Following a
review of the draft NPDES permit for the Asheboro WWTP (the "Draft Permit"), which discharges into the
Deep River within the Cape Fear River Basin (the"Basin"), we have determined it is in the best interest of
our customers to actively participate in this process by providing the following comments.
Monitoring and Limitations for 1,4-Dioxane and PFAS
CFPUA appreciates the efforts of DWR to address emerging contaminants such as 1,4-Dioxane and
PFAS in the NPDES permits within the Cape Fear River Basin, our customers' water source. Neither the
environment nor traditional treatment technologies have been proven capable of breaking down these
compounds, indicating continued exposure of both pollutants to downstream consumers through drinking
water for an unknown time, presenting a concern for every water consumer downstream of each
discharger within the Basin.
CFPUA, unlike the other utilities in the Middle and Lower Cape Fear River Basin, can treat approximately
two-thirds of the 1,4-Dioxane that is received into its intake. Due to past financial investments made in
previous upgrades into advanced treatment technologies, CFPUA has been able to minimize exposure to
its customers from this compound. However, CFPUA is unable to achieve 100% removal efficiency. For
this reason, the loadings that are allowed upstream are of concern to CFPUA and our customers. Our
proactive planning downstream has improved our treatment processes, but ineffective management of
loadings within the Basin can negate their benefits. CFPUA is in support of weekly monitoring and
requests assurance that the levels established in the Draft is protective of the water supply criterion and
EPA-IRIS cancer risk of 0.35 ug/L at the downstream source water intakes.
CFPUA currently treats for PFAS due to other dischargers further downstream of Asheboro. CFPUA has
invested millions of dollars to treat PFAS from the source at Chemours — Fayetteville works site. The
continued success of the treatment technology is susceptible to the concentration of PFAS discharged to
the Basin. Increased loadings from any upstream dischargers have the potential to impact CFPUA's, and
other utilities', treatment efficiencies. The legacy PFAS compounds have not been a significant source of
concern at CFPUA's intake, and we would like to ensure it does not become one in the future. To
adequately monitor the discharge from Asheboro and the discharges to their system, more frequent
monitoring is needed and should be required to establish adequate baselines for continued protection of

the Cape Fear River Basin.
As these contaminants (1,4-Dioxane and PFAS), as well as future emerging contaminants, have lower
detection values and potentially pose long-term health impacts, it is important for DWR to protect
designated uses with a Basin-wide approach. Technology is improving, and regulations must expand
protection of the Basin with parts per trillion and parts per billion limitations from the headwaters to the
last user of the Basin. Routine monitoring is necessary for effluent locations and should coincide with the
regular instream monitoring for such pollutants. Routine monitoring will enable improved modeling of the
Basin and result in better data to support decision making for protections of our downstream customers
and the environment, and provide object evidence for the basis of the Water Quality Based Effluent limits
DWR establishes within the Basin.
Downstream Notifications to Utilities
CFPUA agrees with the downstream utility notification in Section A. (5.) (g.). However, the contact listed
in the cover letter for CFPUA is no longer with the organization and should be changed to: Ben Kearns,
Office - 910-332-6577; Cell - 910-398-4311, ben.kearnscfpua.orq. As staff changes occur often and
designated staff are away from the office for leaves of absence at times, it is suggested that there be at
least two points of contact for each of the downstream utilities.
The data may provide downstream utilities an opportunity to reduce the concentration of these
substances in their customers' drinking water. To facilitate these efforts, CFPUA suggests that DWR
provide all drinking water utilities in the Basin with expected travel times between each permitted outfall
subject 1,4-dioxane and PFAS monitoring and each drinking water intake within the Basin.
Schedule of Compliance for 1,4-Dioxane Limits is Too Lenient
As noted in the Fact Sheet that accompanies the Draft, the existence of 1,4-Dioxane in Asheboro's
WWTP effluent has been known since at least 2018. Five years have passed since the identification and
presence of this carcinogenic compound has been known to Asheboro and DWR. Given the time that
already passed, and the continuing impact on downstream water suppliers and their customers, CFPUA
requests the compliance schedule be shortened for both the NPDES and Industrial Dischargers to no
more than three years.
CFPUA appreciates the efforts of DWR to communicate with the downstream users of the within the
Basin, and to act on compounds such as 1,4-Dioxane and PFAS. It is CFPUA's firm belief that costs to
control such compounds should be borne by their source and any other benefiting parties of the
discharges, not the unsuspecting downstream users of the river. Thank you for the opportunity to
comment and be heard on such an important permit to the health of the Basin and for your continued
support of all designated uses.
Respectfully submitted,
enneth Waldroup, P.E.
Cape Fear Public Utility Authority
Executive Director