NC0044423_202101VRR_20210414

DMR REVIEW RECORD
Winston-Salem Regional Office
Facility Name: Appalachian State WTP Permit Number: NCO044423
Report Period: January 2021 Prior Assessments: 0 Enforcement Factor: 1.00
Waterbody
Outfall # Outfall Description
Waterbody Name
Classification
001 Membrane/filter backwash to Norris
Brch
Norris Branch, including the raw water holding
WS-II;Tr,HQW,CA
reservoir below normal reservoir elevation
Monthly Average Limit Violations
Sample Location: Outfall 001 - Effluent
Violation
Unit of Limit
Calculated % Over
Date Parameter
Frequency
Measure Value
Value Limit
Action
1/31/2021 Copper, Total (as Cu)
Monthly
ug/I 4
65 1,525.0
Daily Limit Violations
Sample Location: Outfall 001 - Effluent
Violation
Unit of Limit
Calculated % Over
Date Parameter
Frequency
Measure Value
Value Limit
Action
1/27/2021 Chlorine, Total Residual
2 X month
ug/I 28
48 71.4
No Action, BPJ
1/13/2021 Copper, Total (as Cu)
Monthly
ug/I 5.20
65 1,150.0
Other Violations/Staff Remarks:
Spoke with ORC to confirm Cu value of 65 ug/I, and it is correct. According to permit, limits on Cu began Jan. 1, 2021. Other
stipulations in the permit required them to complete a (CAP) Corrective Action Plan within one year, submit a report outlining
corrective actions taken to remedy matters summarized in CAP (at year 2, 3 & 4). They did complete CAP, however, did not
report yearly (not that I found). Held meeting on 4/12/21 to discuss situation at facility and concluded with requiring facility to
submit remedial strategy to DWR. (ie: moving discharge point, different filtration system).
**CAP summary concerning Cu: "The ASU WTP is not a generator of copper and zinc and the WTP is not discharging metals from
another source. The parameters are present in the source water withdrawn from the same water body they are being
discharged back into."
Possibly start with NOD, however due to high Cu reading, NOV??
Attached below are conversation notes-
4/6/2021 @ 9:45am
Re: Copper = 65 ug/l on 1-2021 DMR (Cu limit: Monthly avg 4.0 ug/l ;Daily max 5.2 ug/1)
•Value is confirmed, no typo/error in reporting.
•Cu get `trapped' onto the membrane and during CIP backwash, the citric acid removes Cu from membranes and creates a `slug' going to
wash basin.
•Mr. Johnson stated high value is possible result of road salt over winter and CIP backwashes of plant.
•Proposal has been made to increase frequency of backwashes, so Cu does not build up on the membranes.
•Polymers and/or chemical treatments are avoided as not to complicate issues there.
•Trying everything to come up with best route to keep this from occurring.
•Stated another issue is ... discharge point (outfall) is 75-100 yards from plant intake. (Mr. Johnson's opinion is) - More Cu coming into
plant than being discharge.

Supervisor Remarks:
Jenny — NOV
Lon-NOV
Completed by: Tricia Lowery
Assistant Regional
Supervisor Sign -off: Jenny
Regional
Supervisor Sign -off: LTS
Date: 4/14/2021
Date: 4/19/2021
Date: 4/19/2021

Prior 12-Month Enforcement Histor
Permit Number: NCO044423
Report Period: January 2021
Limit Violation
Sample Location:
Outfall 001 - Effluent
Violation Report
Violation
Date Period
Parameter
Type
NOD NOV CPA
1/29/2020 1-2020
Turbidity
Daily Maximum
NOV-2020-LV-0205
Exceeded
2/12/2020 2-2020
Turbidity
Daily Maximum
NOV-2020-LV-0294
Exceeded
2/26/2020 2-2020
Turbidity
Daily Maximum
NOV-2020-LV-0294
Exceeded
3/11/2020 3-2020
Turbidity
Daily Maximum
NOV-2020-LV-0411
Exceeded
3/25/2020 3-2020
Turbidity
Daily Maximum
NOV-2020-LV-0411
Exceeded
5/13/2020 5-2020
Turbidity
Daily Maximum
NOV-2020-LV-0568
Exceeded
5/27/2020 5-2020
Turbidity
Daily Maximum
NOV-2020-LV-0568
Exceeded
6/10/2020 6-2020
Turbidity
Daily Maximum
NOV-2020-LV-0712
Exceeded
Other Violation
Violation Report
Violation
Date Period
Parameter
Type
NOD NOV CPA
1/9/2020
Violation detected
NOD-2020-PC-0011
during inspection
1/9/2020
Violation detected
NOD-2020-PC-0011
during inspection