NC0024147_Comments_20221021

WADE R. FOWLER, JR., COMMISSIONER��%(fj � FAYETTEVILLE PUBLIC WORKS COMMISSION
EVELYN 0. SHAW, COMMISSIONER �/� 955 OLD WILMINGTON RD
RONNA ROWE GARRETT, COMMISSIONER P.O. BOX 1089
DONALD L. PORTER, COMMISSIONER HWOWN UTILITY FAYETTEVILLE, NORTH CAROLINA 28302-1089
MARION J NOLAND, INTERIM CEO/GENERAL MANAGER TELEPHONE [phone]
WWW.FAYPWC.COM
October 21, 2022
Via US Mail and Email (aarv.nerlmutteranncdenr.aov)
North Carolina Department of Environmental Quality
NPDES Municipal Permitting Unit
Attn: Gary Perlmutter, Environmental Specialist II
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Comments on Draft NPDES Permit NCO024147
Big Buffalo WWTP, Lee County, North Carolina
Facility Grade IV Biological WPC, SIC Code 4952
Dear Mr. Perlmutter:
Fayetteville Public Works Commission (PWC) has reviewed the draft NPDES permit for
Sanford's Big Buffalo WWTP, located in Lee County and discharging into the Deep River within
the Cape Fear River Basin. The Big Buffalo WWTP 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 also notes the planned $20 million expansion of Sanford's Water Filtration Facility
and the fact that the Big Buffalo WWTP's outfall is located approximately fifteen miles upstream
of the intake for Sanford's Water Filtration Facility. As a result, the quality of wastewater from
the Big Buffalo WWTP, and the functioning of Sanford's pretreatment program, has a direct
bearing on the quality of the drinking water that Sanford provides to its growing customer base,
potentially including customers in the Neuse River Basin based upon Sanford's current plans,
and on the rest of the Cape Fear River watershed.
Therefore, PWC offers the following comments on Sanford's draft NPDES permit.
More Frequent Effluent Monitoring for Emerging Contaminants is Necessary
PWC appreciates DWR's efforts to lower the presence of 1,4-dioxane and PFAS
compounds in the Cape Fear River Basin. These 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.
Furthermore, discharges of these substances are not consistent from one day to the
next. As the recent example of 1,4-dioxane discharges from Greensboro's T.Z. Osborne
WWTP demonstrates, discharges of these emerging contaminants are frequently of a periodic
or "slug" nature.
BUILDING COMMUNITY CONNECTIONS SINCE 1905
AN EQUAL EMPLOYMENT OPPORTUNITY EMPLOYER

Therefore, PWC believes that weekly effluent monitoring for 1,4-dioxane and PFAS
(once there is an approved method for sampling PFAS in wastewater) is warranted. Quarterly
sampling for PFAS and monthly sampling for 1,4-dioxane are unlikely to detect the type of "slug
discharge" events observed from Greensboro's WV TP. Weekly sampling also provides a
greater opportunity to notify downstream drinking water utilities of a slug discharge, which will
allow those utilities to alter their operations in a way that could lessen the concentration of PFAS
and 1,4-dioxane ultimately in their customers' drinking water — including Sanford's.
In -Stream Monitoring for PFAS and 1,4-dioxane throughout the Basin is Necessary
As noted above, discharges of PFAS and 1,4-dioxane do not break down in the
environment, and 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 and 1,4-dioxane concentrations change as water
moves downstream in the Cape Fear River Basin.
Thus, PWC believes that DWR should require weekly in -stream monitoring for PFAS
and 1,4-dioxane at Sanford's downstream monitoring point if there is a reasonable potential for
a violation of water quality standards. Continuing to rely on a simple mass -balance calculation
at a permitee's outfall to develop WQBELs for PFAS and 1,4-dioxane 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 and 1,4-dioxane into the Basin.
Again, these data may afford downstream utilities an opportunity to reduce the concentration of
these substances in their customers' drinking water.
The Continued Performance of Sanford's Pretreatment Program is Essential
Sanford's Big Buffalo WWTP is expected to serve the VinFast electric vehicle and
battery manufacturing facility that is now under construction. Once the VinFast facility becomes
operational, it will likely be subject to the categorical pretreatment standards for metal finishing
and battery manufacturing in 40 CFR Parts 433 and 461 respectively. Of particular concern are
heavy metals, including chromium and lead as well as lithium and other hazardous waste
streams that could be passed through the Big Buffalo VWUfP and into downstream water
supplies. PWC expects that the VinFast facility's pretreatment permit will include the minimum
requirements for monthly self -monitoring and that Sanford will also maintain a long-term
monitoring program including, at a minimum, quarterly sampling for pollutants of concern.
Daily Conductivity Monitoring Should Remain in the Permit
PWC requests that DWR keep the daily conductivity monitoring requirement in the
permit. Conductivity data provides a mechanism to detect changes in wastewater quality from
manufacturing operations like the ones that will occur at the VinFast facility and at Sanford's
existing industrial users' facilities. Continuing this monitoring provides a simple "red -flag" test to
alert the Big Buffalo WWTP that other changes in its influent may have occurred.

As stewards of the Cape Fear River water supply for our customers, PWC appreciates
the opportunity to submit these written comments. PWC believes that a public hearing is
appropriate to fully inform the public and to gather additional public comment before issuance of
a final NPDES permit. PWC therefore requests a public hearing. If additional information is
needed, please contact me at mick.nolandCaD-faypwc.com or 910-223-4733.
Respectfully submitted,
Fayetteville Public Works Commission
By:/r-t�
Micl Nolana, Interim CEO/(',PrYeral Manager

From: Montebello, Michael J
To: Hararove, Andrew D
Cc: Perlmutter, Garv; Gurney, Anna
Subject: Public Hearing Request NPDES NCO024147 Sanford Big Buffalo WWTP
Date: Wednesday, October 5, 2022 11:03:37 AM
Drew,
Request for PH from SELC. No other materials yet. Gary is the permit writer for the PN. The
NPDES permit comment period ends October 22.
Thanks
MikeM
From: Gurney, Anna <[e-mail]>
Sent: Wednesday, October 5, 2022 8:16 AM
To: Grzyb, Julie <[e-mail]>; Rogers, Richard E <richard. [e-mail]>;
Montebello, Michael J <[e-mail]>
Subject: FW: [External] Public Hearing Request NPDES NCO024147
Not sure who this should go to (City of Sanford) ...
From: Hannah Nelson <[e-mail]>
Sent: Tuesday, October 4, 2022 2:35 PM
To: Rodman, Diane <[e-mail]>; [e-mail];
SVC_DEQ.publiccomments <[e-mail]>
Cc: Gurney, Anna <[e-mail]>; Geoff Gisler <[e-mail]>; Jean Zhuang
<[e-mail]>
Subject: [External] Public Hearing Request NPDES NCO024147
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Dear Ms. Rodman and Mr. Perlmutter:
I am writing to request a public hearing on draft NPDES permit NC0024147, Big Buffalo
WWTP. I request a hearing in a location convenient for residents of Lee and Chatham
counties. Please let me know if you need additional information in order to process this
request.
Best,
Hannah
Hannah M. Nelson (she/her)
Associate Attorney

Southern Environmental Law Center
601 West Rosemary Street, Suite 220
Chapel Hill, NC 27516
Office [phone]
Direct [phone]
Mobile [phone]
hnelson&selcnc.org
southernenvironment.ora
PRIVILEGE AND CONFIDENTIALITY NOTICE
This email and any attachments may be protected by the attorney -client privilege, as
attorney work -product, or based on other privileges or provisions of law. If you are not an
intended recipient of this message, do not read, copy, use, forward, or disclose the email or
any of its attachments. Instead, immediately notify the sender by replying to this email and
then delete it from your system. The unauthorized disclosure, copying, distribution, or use
of this email or any attachments is prohibited.

From: Montebello, Michael J
To: Perlmutter, Gary
Subject: Public Hearing Request NPDES NCO024147 Sanford Big Buffalo WWTP
Date: Wednesday, October 5, 2022 1:20:03 PM
Gary,
2nd comment. Haw Riverkeeper
MikeM
From: Gurney, Anna <[e-mail]>
Sent: Wednesday, October 5, 2022 12:12 PM
To: Montebello, Michael J<[e-mail]>; Hargrove, Andrew D
<d rew. h a rg rove @ n cd e n r. gov>
Subject: FW: [External] Public Hearing Request NPDES NCO024147
Here's another one for same permit.
From: Emily Sutton <[e-mail]>
Sent: Wednesday, October 5, 2022 10:47 AM
To: Rodman, Diane <[e-mail]>; [e-mail];
SVC_DEQ.publiccomments <[e-mail]>; Gurney, Anna
<[e-mail]>
Subject: [External] Public Hearing Request NPDES NCO024147
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Dear Ms. Rodman and Mr. Perlmutter:
I am writing to request a public hearing on draft NPDES permit NC0024147, Big Buffalo
WWTP. I request a hearing in a location convenient for residents of Lee and Chatham
counties. Stakeholders in this process will also include potential drinking water customers
for Sanford, as this discharge outfall is only fifteen miles upstream from the drinking water
intake. With this concern, we would like to ensure that this comment period includes as
much public participation from those stakeholders as possible. Please let me know if you
need additional information in order to process this request.
Emily Sutton
Haw Riverkeeper
she/her/hers : Why pronouns matter: https://www.mypronouns.org//
Haw River Assembly
P.O. Box 187
Bynum NC 27228
0: [phone]
C: [phone]
www.hawriver.org

From:
Tamara Lewis
To:
Perlmutter. Gary
Subject:
[External] NPDES NCO024147
Date:
Wednesday, October 19, 2022 8:47:07 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
I live in Sanford, and I'm worried that the new permit for Sanford's Waste Water Treatment Plant won't be strong
enough. Abundant clean water is the jewel in our area's crown, and like any community, we can't survive without it.
This issue needs to be out in front of all the citizens. We need unbiased, factual information so we (and our elected
representatives) and the NCDEQ can make good long-term, prudent decisions. I look forward to forums and panel
discussions, newspaper articles and commissioner presentations. We definitely need more community input on these
decisions!
Thank you.
Tamara Lewis
418 Arlington Cir
Sanford, NC 27330

From: Dana Griffith
To: Perlmutter, Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:09 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
Dana Griffith
312 Acorn Crossing Road
HOLLY SPRINGS, NC 27540

From: Juneko Grilley-Olson
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:12 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
Juneko Grilley-Olson
152 Roads End
Pittsboro, NC 27312-6541

From:
Debra Hanks
To:
Perlmutter. Gary
Subject:
[External] NPDES NCO024147
Date:
Wednesday, October 19, 2022 8:47:13 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varma, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
Debra Hanks
1703 Farm Lake Dr
Holly Springs, NC 27540

From: Lynette Gilbert
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:16 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
Lynette Gilbert
85 Birchwood Drive
Pittsboro, NC 27599

From: Liz Liepold
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:19 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
I live in Pittsboro and am very concerned about the water safety as it is. We've had to install reverse osmosis to have
water with lower levels of PFAS. Given the City of Sanford's plans to provide water to new communities including
Fuquay-Varina, Pittsboro, and Holly Springs, I am very concerned that my future drinking water could be
contaminated with PFAS and 1,4-dioxane. The current draft permit for Sanford's Waste Water Treatment Plant
allows far too much pollution and I'm urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
Please do something to protect the public. We are vulnerable to whatever choices you make and it's a crime to
continue exposing innocent people, children and families to harmful toxins. Please do the right thing and make
protections to limit the contamination of our water.
Liz Liepold
576 Hudson woods rd
Pittsboro, NC 27312

From: Lynne C.
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:19 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
Lynne C.
6032 Kentworth Dr
Holly Springs, NC 27540

From: Peggy Reinders
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:21 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water. We need clean water for our community adults and
our children. They are our future! Please keep our water supply safe for all!
Peggy Reinders
1008 Bren Arbor Ct
Fuquay Varina, NC 27526-8400

From: Gary Simpson
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:22 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community. Pittsboro has already for far too long suffered from
these same contaminants in it's Haw River water supply. Indeed, this is the exact reason that the Town of Pittsboro
is now considering tapping into Sanford's water resource. However, it makes no sense at all to jump from the "frying
pan into the fire," so to speak.
Sanford could one day provide drinking water to more than 100,000 residents in our region. I want you to ensure
that any permit you issue will protect me from exposure to toxic pollutants. I would also like NCDEQ to hold a
public hearing so that community members like me can speak out to protect our future drinking water.
Gary Simpson
82 Cynthia Ln
Pittsboro, NC 27312-5733

From:
Kicab Castaneda-Mendez
To:
Perlmutter. Gary
Subject:
[External] NPDES NCO024147
Date:
Wednesday, October 19, 2022 8:47:25 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
Kicab Castaneda-Mendez
878 Fearrington Post
Pittsboro, NC 27312-5037

From: Susan Clayton
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:25 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
Susan Clayton
101 W Smith Rd
Pittsboro, NC 27312-7987

From: Nili Clifford
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:27 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
Nili Clifford
9 Bridle Path
Pittsboro, NC 27312

From: Jacqueline Katz
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:29 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
Jacqueline Katz
270 Singing Hills Dr
Pittsboro, NC 27312-7817

From: Michael Lewandowski
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:30 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
Michael Lewandowski
3049 Willow Ranch Dr
Fuquay Varina, NC 27526-3961

From:
Ellen Cohen
To:
Perlmutter. Gary
Subject:
[External] NPDES NCO024147
Date:
Wednesday, October 19, 2022 8:47:32 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
Ellen Cohen
363 Fearrington Post
Pittsboro, NC 27312-8517

From: Thelma Sharon Garbutt
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:34 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
The city of Sanford may in the future provide drinking water to my community of Pittsboro. The current draft
permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm urging you to require a
stronger permit.
As you are well aware, for years Pittsboro residents have been drinking water contaminated with PFAS and 1,4
Dioxane which comes down the Haw River from Greensboro and Burlington. Our town has spent millions of $$$ to
put in more effective water treatment in order to protect our community from contaminated water. We do not want
a new source of contaminated water.
I want you to hold Sanford to the highest standards so that they do not profit by selling contaminated water.
Thank you!
Thelma Sharon Garbutt
595 Pokeberry Ln
Pittsboro, NC 27312

From: Bill Tarplev
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:35 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
Bill Tarpley
171 Cedar Grove Rd
Pittsboro, NC 27312-6779

From:
Jennifer Galicia McDaniel
To:
Perlmutter, Gary
Subject:
[External] NPDES NCO024147
Date:
Wednesday, October 19, 2022 8:47:36 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
I'm concerned that the draft permit for Sanford's Waste Water Treatment Plant is not protective and could lead to
continued pollution in drinking water for my community. Past testing has shown staggering levels of PFAS and 1,4-
dioxane pollution coming from the facility. These chemicals are likely ending up in the water I drink, and this
womes me.
With so much growth in our region and Sanford's plans to provide drinking water to surrounding communities, it's
very important that NCDEQ get this right. Please strengthen the permit to protect us from these dangerous
chemicals. I also call on you to hold a public hearing to allow for better public participation, so that community
members can be better informed and speak out to protect our own drinking water. And the tiny signs that advertise
the hearings are not sufficient notice for most people. For one thing, you can't even read them as you drive by in
your car!
We need a mailed notice or an email. Everyone who has a water bill could get a notice in that envelope or even on
the bill itself! We need to know when and where we can properly express ourselves in a timely manner that will
count so that we don't end up protesting and dealing with consequences down the line... or downstream, if you like!
Thank you.
Jennifer Galicia McDaniel
2203 Longwood Ave
Sanford, NC 27330

From: Brady Kleaveland
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:38 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
My family and I strongly oppose the city of Sanford's plan to provide water to new communities including Fuquay-
Varina, Pittsboro, and Holly Springs. We live in Pittsboro, and we don't want to consume water future drinking
water contaminated with PFAS and 1,4-dioxane., as Sanford's water currently contains. The existing draft permit
for Sanford's Waste Water Treatment Plant allows WAY too much pollution! We beg you to create a stronger
permit that protects this community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and that of my neighbors. PLEASE ensure that any permit you issue protects our family from exposure
to toxic pollutants. All of us want NCDEQ to call a public hearing to allow residents of the towns affected to support
greatly improved and protected future drinking water.
Brady Kleaveland
495 Buck Branch Rd
Pittsboro, NC 27312

From: deborah shantzek
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:39 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
I've been informed that Sanford will be supplying water for Pittsboro as well as other communities nearby. I'm very
concerned about the level of pollutants that Pittsboro residents will continue to be exposed to. As it is at this time,
we can't drink our water or cook with it and I had to get a filter for my shower because of the level of pollutants. I
implore you to address the impurities in the water that is and will be serving our communities.
It's horrible that our environment has been so poisoned that our resources are this contaminated and can cause so
many health issues to consumers. NC is such a beautiful state and yet is so polluted and contaminated because of
lack of environmental protections and that the water is a danger to our residents. If this is not addressed anyone
involved will be responsible for the disease it is and will be causing in the future.
Thank you,
Deborah Shantzek
deborah shantzek
321 Rectory St Apt 479
Pittsboro, NC 27312-5645

From: Kathleen Morris
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:42 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. (AND fluoride is actually a toxic pollutant because we have been lied to about it) I would also like
NCDEQ to hold a public hearing so that community members like me can speak out to protect our future drinking
water.
I know that clean drinking water IS possible but probably more expensive. North Carolinians are already run down
from poor food quality. For instance buying food with Glyphosate in it which is a pesticide as well as an antibiotic
which kills their vital gut biome.
Please listen to the good people who made this petition possible.
Thank you,
Kathleen Morris
39 Robins Nest Ln
Pittsboro, NC 27312-9526

From: Robert Popchak
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:42 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
Robert Popchak
3374 Old Graham Rd
Pittsboro, NC 27312-6588

From: Henry B Kennedy Jr
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 8:47:46 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
I'm concerned that the draft permit for Sanford's Waste Water Treatment Plant is not protective and could lead to
continued pollution in drinking water for my community. Past testing has shown staggering levels of PFAS and 1,4-
dioxane pollution coming from the facility. These chemicals are likely ending up in the water I drink, and this
womes me.
With so much growth in our region and Sanford's plans to provide drinking water to surrounding communities, it's
very important that NCDEQ get this right. Please strengthen the permit to protect us from these dangerous
chemicals. I also call on you to hold a public hearing to allow for better public participation, so that community
members can be better informed and speak out to protect our own drinking water.
Thank you.
Henry B Kennedy Jr
564 Chelsea Drive
Sanford, NC 27330

From:
ELLEN PEARSON
To:
Perlmutter. Gary
Subject:
[External] NPDES NCO024147
Date:
Wednesday, October 19, 2022 8:52:06 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
I live 10 minutes from the Haw River, in which my neighbors, my grandchildren and I swim. My family also enjoys
swimming in Jordan Lake. We are dismayed to know of the toxic industrial effluents pouring into the Haw river
upstream.
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
ELLEN PEARSON
246 Indian Orchard Rd
Pittsboro, NC 27312

From: Helen Salvia
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 1:54:05 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
Helen Salvia
123 Burnice PI
Pittsboro, NC 27312

JOHN D. RUNKLE
ATTORNEY AT LAW
2121 DAMASCUS CHURCH ROAD
CHAPEL HILL, NC 27516
919-942-0600
jrunkle@)pricecreek.com
COMMENTS TO NC DEQ REGARDING DRAFT NPDES PERMIT
FOR CITY OF SANFORD WWTP — NPDES NCO024147
I have reviewed numerous applications and draft NPDES for municipal wastewater
treatment plants (WWTPs) and am familiar with discharges into the Deep River. I have
the following concerns about the draft permit for the City of Sanford.
The comment period should be extended, and a public hearing held. To date,
serious concerns have been raised about the draft permit which need to be
resolved by the Division. A revised draft permit that addresses these concerns
should be published for additional comments.
2. 1 was surprised to discover Sanford discharges its wastewater approximately 15
miles upstream from its own water intake. The concentration of untreated
pollutants, and of particular concern, toxic industrial pollutants, can only increase
overtime as water from this15-mile stretch of river is reused and reused. This is
compounded in that the Deep River is a flashy river with rapid fluctuations of
stream flow, from rapid increases during storm events to extreme low flow
conditions. For the summer months of the year the 7Q10 of the river borders on
zero flow.
3. The draft permit allows Sanford to increase the pollutants in its own drinking
water. It is my understanding Sanford plans to sell drinking water to other
municipalities. The minimal monitoring and minimal treatment of harmful
chemicals such as the PFAS and 1,4-dioxane in the draft permit mean that these
chemicals could be spread widely throughout the watershed.
4. The application for the WWTP does not address the environmental impacts of
Sanford exporting its potentially contaminated water to the other communities.

From: Teresa Ladd
To: Perlmutter. Gary
Subject: [External] NPDES NCO024147
Date: Wednesday, October 19, 2022 4:44:10 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
Teresa Ladd
601 Jamestown Rd
Pittsboro, NC 27312

From:
Frances Brett Pesce
To:
Perlmutter. Gary
Subject:
[External] NPDES NCO024147
Date:
Wednesday, October 19, 2022 5:30:06 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spamnnc.gov>
Dear NC Department of Quailty,
Given the City of Sanford's plans to provide water to new communities including Fuquay-Varina, Pittsboro, and
Holly Springs, I am very concerned that my future drinking water could be contaminated with PFAS and 1,4-
dioxane. The current draft permit for Sanford's Waste Water Treatment Plant allows far too much pollution and I'm
urging you write a stronger permit that protects my community.
Sanford could one day provide drinking water to more than 100,000 residents in our region — including my
household and my neighbors'. I want you to ensure that any permit you issue will protect me from exposure to toxic
pollutants. I would also like NCDEQ to hold a public hearing so that community members like me can speak out to
protect our future drinking water.
Frances Brett Pesce
121 Redhill Rd
Holly Springs, NC 27540

Perlmutter, Gary
From: Keely Wood < [e-mail] >
Sent: Thursday, October 20, 2022 10:59 AM
To: SVC_DEQ.publiccomments
Cc: Rodman, Diane; Perlmutter, Gary; SVC_DEQ.publiccomments; Gurney, Anna
Subject: [External] NPDES NCO024147 - Draft permit for Sanford WWTP
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Good Morning,
I have been involved in many environmental issues in Lee County over the years, the threat of Fracking, Coal Ash Dump,
water pollution from a retired brick plant.
The new updated interim health advisory for two PFAS, PFOA and PFOS, are 0.004 ppt and 0.02 ppt
respectively. However Sanford's Testing conducted on the influent of the wastewater treatment showed levels
of 1,4-dioxane at 13ug/L and levels of total PFAS at 4,026 ppt. They have still not alerted the public.
The drinking water intake for Sanford is located only 15 miles downstream of their wastewater treatment plant
outfall. This wastewater permit . There has to be some changes made to help protect the citizens of Lee County
and other counties they plan on selling water to. Sanford is poised to become a drinking water supplier for
Pittsboro, Fuquay-Varina, and Holly Springs. This is addition to their own city, Goldston, and several
areas of Chatham County. Sanford needs to hold upstream industry, their own back yard industry,
accountable for what they are drawing out of the water and producing to be sold.
Currently, this draft has no limitations for 1,4-dioxane, or requirements to minimize PFAS levels within their
system. These level exceed the healthy advisory #'s a filtration system needs implemented , regular testing
implemented and published results need to be communicated to the residents.
Lee county is booming with added industry and homes as part of the NC Core program. A public
hearing should be planned for all communities that are being affected.
Keely Wood
Lee County Resident
919-708-5221

From: Mike Martin
To: Rodman, Diane; Perlmutter, Garv; SVC DEO.Dubliccomments; Gurney, Anna
Subject: [External] Sanford Wastewater Plant Permit Extreme Concerns
Date: Friday, October 21, 2022 8:36:13 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Officials,
Testing conducted on the influence of the wastewater treatment showed levels of 1,4-
dioxane at 13ug/L and levels of total PFAS at 4,026 ppt. For reference, the water quality
standard of 1,4-dioxane is 0.35ug/L. The updated interim health advisory for two PFAS,
PFOA and PFOS, are 0.004 ppt and 0.02 ppt respectively.
These compounds are not removed in traditional drinking water processes. Sanford currently
has no treatment processes in place to minimize these levels from the Significant Industrial
Users through their pretreatment program, or through treatment at either wastewater or
drinking water facility.
These facts are "EXTREMELY" alarming and there should be, at a minimum, additional
requirements put on the Sanford WWTP to take corrective measures to stop this pollution.
Do we want to be another Flint, Michigan?? None of us want that but that is exactly where this
is heading.
You have the ability to stop this and I implore you take the necessary measures to get this
under control.
Respectfully,
Mike Martin
Concerned Citizen in Pittsboro

From: Lib Hutchbv
To: SVC DEO.publiccomments; Rodman, Diane; Gurney, Anna; Perlmutter, Gary
Subject: [External] NPDES NCO024147
Date: Friday, October 21, 2022 2:39:28 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Public Comment:
Do NOT renew the permit for Sandford, NC,'s waste water treatment plant, knowing that
industrial toxins are being discharged into the rivers. The Big Buffalo Waste Water treatment
plant is not prepared to handle industrial toxins being discharged 15 miles from the intake
plant..
A public hearing needs to be held to address this issue. Lee County does NOT need to suffer
further from the multiple kinds of PFAS and it's for sure the Deep River and the Cape Fear
Rivers are impaired by these toxins, as are those who participated in the blood serum study,
since most were found to have four types of PFAS.
This serious issue requires more study and a public hearing.
Thank you,
Lib Hutchby
108 Standish Dr.
Chapel Hill, NC
27517
919-606-8280

From:
Cheri Weaver
To:
Perlmutter, Gary
Subject:
[External] "NPDESNC0024147 - Draft permit for Sanford WWTP"
Date:
Friday, October 21, 2022 4:52:24 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
As a resident of the Chapel Ridge Community in Pittsboro, NC, I would request that Sanford
be denied the permit to dump chemicals into our water supply that are dangerous to the health
of all residents.
Thank You,
Cheri Weaver
369 Autumn Chase, Pittsboro, NC 27312

From: Kelly Dalton
To: Rodman, Diane; Perlmutter, Garv; SVC DEQ.publiccomments; Gurney, Anna
Subject: [External] NPDES NCO024147 - Draft permit for Sanford WWTP
Date: Friday, October 21, 2022 4:56:28 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
I am writing to you all regarding the draft permit for Sanford's Big Buffalo
Wastewater Treatment Plant. If approved AS WRITTEN, this permit would allow
industrial toxins like 1,4-dioxane and PFAS to be discharged into drinking water
supplies. If you approve this permit, you are responsible and liable for threatening the
lives, health, and wellness of Sanford residents, and those in other towns of Chatham
County. Not only would this permit allow industrial toxins to be dumped into
drinking water sources, it would allow them at levels that are not only unacceptable,
but criminal. Damning to the life, health, wellness of human citizens, animals,
ecosystems, crops.
It's maddening but not all too surprising to yet again be having to fight for a basic
right to safe, clean water in our towns, coming into our homes. But here we are again.
When will there be protections and prevention rather than reactionary response or
none at all? I am writing to you in expectation that you have this knowledge and will
not approve this permit as it is written currently.
I hope you know people are paying attention. In Sanford. In Pittsboro, Fuquay-
Varina, Holly Springs, Goldston. Residents in Chatham county poised to begin
accepting drinking water from Sanford. Activists in North Carolina and outside of
North Carolina.
When will Sanford start going after industries causing harm and toxins to the people
who live here? When will it go after polluters dumping harmful 1,4-dioxane, PFAS,
PFOAs into our water sources? Both 14-dioxane and total PFAS have been detected in
water coming into the treatment plant in Sanford. Specifically, levels of 14-dioxane at
13ug/L and levels of total PFAS at 4,026 ppt have been documented. For reference,
the water quality standard of 14-dioxane is 0.35ug/L. The updated health advisory
limits for PFOA and PFOS are 0.004 ppt and 0.02 ppt respectively. The levels being
detected in Sanford are BEYOND unacceptable. They. are. criminal. Sanford currently
has NO treatment processes in place to minimize these levels before they reach our
taps. I'll be sure to see where each of you land and pursue this issue going forward and
look forward to you making the right decision/s.
Thank you for your time,
Kelly Dalton
Pittsboro, NC