NC0026123_Comments_20230526

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EVELYN O.SHAW,COMMISSIONER
/! f ni"��J FAYETTEVILLE PUBLIC WORKS COMMISSION
RONNA ROWE GARRETT,COMMISSIONER ► G((�� 955 OLD WILMINGTON RD
DONALD L.PORTER,COMMISSIONER P.O.BOX 1089
CHRISTOPHER DAVIS,COMMISSIONER H 0 OWN UTILITY FAYETTEVILLE,NORTH CAROLINA 28302-1089
MARION J NOLAND,INTERIM CEO/GENERAL MANAGER TELEPHONE[phone]
WWW.FAYPWC.COM
May 24, 2023
RECE BY EMAIL/US MAIL •"
Wastewater Permitting MAY 26 _023
Attn: Asheboro WWTP Permit
Division of Water Resources
NCDEQ NNCDEQID R/NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
[e-mail]
Re: Supplemental Comments regarding Draft NPDES Permit for Asheboro WWTP
To Whom It May Concern:
The Fayetteville Public Works Commission("PWC") appreciates the opportunity to
provide these supplemental comments regarding the Draft NPDES Permit for the City of
Asheboro's ("Asheboro")wastewater treatment plant(the"Plant").
PWC supplies drinking water to over 225,000 customers in southeastern North Carolina.
We source that water from the Cape Fear River Basin, downstream of Asheboro's Plant.
Therefore, the requirements of the Plant's NPDES permit have a direct effect on our ability to
provide clean drinking water to our community.
PWC supports DEQ's requirement for weekly effluent sampling for 1,4-dioxane but
believes more frequent effluent monitoring for PFAS is necessary. During 2019, Asheboro
performed three rounds of PFAS effluent sampling. Each sampling event identified
concentrations of PFOA more than three orders of magnitude higher than EPA's drinking water
health advisory standard. In addition, each sampling event found concentrations of PFOS that
were more than four orders of magnitude higher than EPA's health advisory standard.
PFAS does not break down once released into the environment. Instead, it builds with
each new discharge into the surface waters of the Cape Fear River Basin. In order to understand
how PFAS loading into the Cape Fear basin is really happening, DEQ needs a large, reliable set
of effluent monitoring data from all of the significant, known sources. Increasing the frequency
of sampling for PFAS in Asheboro's effluent is an important part of accomplishing this
objective.
Furthermore, recent data for emerging contaminants like 1,4-dioxane and PFAS show
they are often discharged in large concentrations, or"slugs," at irregular times. Quarterly or
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Wastewater Permitting
May 24,2023
Page 2
even monthly monitoring is not sufficient to catch these slugs. Given the concentrations of
PFAS compounds previously found in Asheboro's effluent, weekly monitoring for PFAS, in
addition to 1,4-dioxane, is justified.
In light of DEQ's obligation to set effluent limits that are protective of downstream water
quality, PWC requests that if Asheboro's discharges of 1,4-dioxane and PFAS have a reasonable
potential to impair downstream water quality in the Gulf-Goldston water supply watershed,
Asheboro should be required to perform weekly in-stream monitoring for those substances as
well. For DEQ to establish meaningful effluent limits for 1,4-dioxane and PFAS in the Cape
Fear River Basin, it first needs to know the existing concentrations of these chemicals in the
Basin.
Requiring those dischargers who have a reasonable potential to impair downstream water
quality to conduct weekly in-stream monitoring for 1,4-dioxane and PFAS will help collect the
basin-wide data that DEQ needs to solve this basin-wide problem.
With respect to the proposed schedule of compliance for 1,4-dioxane, PWC is deeply
troubled by the amount of time DEQ proposes to give Asheboro to improve. Asheboro has
known about its 1,4-dioxane problem since 2018. Despite the fact that there are obviously still
significant,unidentified discharges of 1,4-dioxane into Asheboro's collection system, during the
last five years, Asheboro has only sampled two potential sources. PWC believes the Department
should not reward Asheboro for its lack of diligence by giving it five more years (ten in total)to
do what it should have already done. The people who live downstream of this Plant expect
Asheboro—and the Department—to do better.
Finally, regarding two other pollutants: First, DEQ should maintain the draft permit's
requirement for daily conductivity monitoring. Conductivity monitoring provides a simple, red-
flag test for detecting larger changes in wastewater quality caused by manufacturing operations.
Second,based on Asheboro's representation to the Department that it can comply with a
bromodichloromethane limit, PWC believes the permit should include one. This chemical is not
easily removed through standard drinking water treatment processes. PWC strives to keep
disinfection byproducts in its water system low as THMs, including bromodichloromethane, can
pose public health risks.
Thank you again for your careful consideration of PWC's comments and for the
Department's efforts to protect water quality in our state.
Respectfully submitted,
Fayetteville Public Works Commission
By: �olte
Mick Noland, Interim CEO/General Manager