NC0000892_Comments_20230213

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WADE R.FOWLER,JR.,COMMISSIONER "g 1 nHt i 25 FAYETTEVILLE PUBLIC WORKS COMMISSION
EVELYN O.SHAW,COMMISSIONER V 1► GL 955 OLD WILMINGTON RD
RONNA ROWE GARRETT,COMMISSIONER P.O.BOX 1089
DONALD L.PORTER,COMMISSIONER H• OWN UTILITY FAYETTEVILLE,NORTH CAROLINA 28302-1089
MARION J NOLAND,INTERIM CEO/GENERAL MANAGER TELEPHONE[phone]
WWW.FAYPWC.COM
February 10, 2023
Via US Mail and Email (publiccommentsCc�ncdenr.govRE EIVED
North Carolina Department of Environmental Quality
Wastewater Permitting
Attn: Sergei Chernikov, PhD FEB 13 2023
1617 Mail Service Center
Raleigh, NC 27699-1617 NCDEQ/DWR/NPDES
Subject: Comments on Draft NPDES Permit NC0000892
Arclin USA WWTP, Chatham County, North Carolina
Facility Class II
Dear Dr. Chernikov:
Fayetteville Public Works Commission (PWC) has reviewed the draft NPDES
permit for the Arclin USA, located in Chatham County and discharging into the Haw
River within the Cape Fear River Basin. Arclin USA's WWTP discharge is upstream of
PWC's drinking water intake, and as such, it is in PWC's customers' best interests for
PWC to take an active role in protecting water quality throughout the Basin.
PWC notes the facility discharges a category of effluent referred to as Organic
Chemicals, Plastics and Synthetic Fibers (OCPSF) and therefore is subject to the
OCPSF effluent guidelines and standards in 40 CRF Part 414. PWC also notes the
addition of a Polyaromatic Hydrocarbons limit to the permit, reflecting DWR's
Reasonable Potential Analysis results. This compound is known to be detrimental to
human health. The facility discharges into WS-IV waters.
Therefore, PWC is focusing these draft permit comments on its expectation that
more frequent effluent monitoring for emerging contaminants will begin to occur in the
Cape Fear River Basin. PFAS compounds do not break down once discharged into the
environment, and each upstream discharge increases the mass of those compounds
present in the river downstream. Because these substances are not removed through
the normal drinking water treatment process, upstream discharges typically end up in
the drinking water of downstream customers. Even though the discharge from the
Arclin USA facility is smaller in volume, it is a concentrated wastestream and PWC
objects to the reintroduction of concentrated reverse osmosis (RO) discharge to the
watershed.
The draft permit requires PFAS monitoring on an annual basis only. PWC
believes that DWR should require quarterly in-stream monitoring for PFAS at Arclin
USA's downstream monitoring point if there is a reasonable potential for a violation of
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water quality standards. If there is a reasonable potential for 1,4-dioxane to also be
present in the effluent, sampling for this parameter should also be required. Annual
sampling for PFAS is unlikely to reliably detect the presence of PFAS in the
wastestream or allow for the understanding of annual loading of this "forever"
contaminant. PWC requests that each facility in the Cape Fear River Basin, POTVV and
industry, be required to sample for PFAS at a minimum of monthly.
Overall loading into the watershed needs to be understood and addressed in a
comprehensive manner. PWC understands that each source of these discharges
contributes to an overall higher downstream concentration. Pursuant to 15A NCAC
02B.0203, DWR "shall" develop Water Quality Based Effluent Limits (WQBEL) such that
downstream water quality and usage "will not be impaired." (emphasis added). The key
to satisfying DWR's obligation in this regard is developing the data set that is necessary
to understand how PFAS concentrations change as water moves downstream in the
Cape Fear River Basin.
Continuing to rely on a simple mass-balance calculation at a permitee's outfall to
develop WQBELs for PFAS is inconsistent with how they are known to behave in the
environment as well as the requirements of 15A NCAC 02B.0203. DWR must begin the
process of addressing these substances in a manner that is consistent with the science.
Regular and frequent in-stream monitoring for them is the first step.
PWC also notes that a network of ongoing in-stream monitoring points will
provide an additional opportunity to detect "slug discharges" of PFAS into the Basin.
Again, these data may afford downstream utilities an opportunity to reduce the
concentration of these substances in their customers' drinking water.
PWC appreciates the opportunity to comment as stewards of the Cape Fear
River water supply for our customers. If additional information is needed, please contact
me at [e-mail] or 910-223-4733.
Respectfully submitted,
Fayetteville Public Works Commission
By: (1
Mic Noland, Interim CE /General Manager