NC0026123_Comments_20230524

ALEXANDER ELKAN
B RO O K S 2000 RENAISSANCE PLAZA
230 NORTH ELM STREET
PIERCEGREENSBORO,NC 27401
AELKAN @ BROOKSPI ERCE.COM
FOUNDED 1897 T336.271.3134
F 336.232.9134
May 24, 2023
VIA EMAIL [publiccomments(�),ncdenngov]
Department of Environmental Quality
Division of Water Resources
Wastewater Permitting
Attn: Asheboro WWTP Permit
1617 Mail Service Center, Raleigh,N.C., 27699-1617
Re: Asheboro WWTP NPDES Permit NCO026123
Dear Staff:
This firm represents the City of Asheboro and the City of Greensboro regarding 1,4-
dioxane regulation and permitting by the North Carolina Department of Environmental Quality
("DEQ") and the North Carolina Environmental Management Commission("EMC").
We are writing again to comment on the 1,4 dioxane provisions of the above-referenced
proposed NPDES Permit NCO026123 (the "Permit"), which DEQ has proposed to issue for the
Asheboro waste water treatment plant. While our clients are aware of concerns associated with 1,4
dioxane, at this time we maintain the positions set forth in our letter dated January 26, 2023
(enclosed), which is incorporated by reference.
We continue to believe there are insufficient legal and factual bases for DEQ to impose the
1,4 dioxane effluent limitations contained in the Permit; and respectfully request that DEQ delete
those requirements from the final NPDES permit that is issued to Asheboro. We respectfully
request that DEQ undertake appropriate cost-benefit analyses and treatment technology
assessments prior to adopting effluent limitation(s) for 1,4 dioxane in NPDES permits.
Our clients reserve all rights.
Respectfully,
s/Alex Elkan s/George W. House
Alexander Elkan George W. House
C: Mr. Michael Rhoney, City of Asheboro
Mr. Michael Borchers, City of Greensboro
Daniel F. E. Smith, Esq.