NC0024201_plan of action_20100202

Roanoke Rapids Sanitary District
February 2, 2010
Mr. Jeff Poupart
Point Source Branch, NPDES Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina, 27699-1617
RE: Plan of Action for Mercury Source Identification
NPDES Permit No. NC0024201
P.O. Box 308
1000 Jackson Street
Roanoke Rapids, NC 27870
[phone]
Fax: [phone]
www.rrsd.org
Dear Mr. Poupart,
The Roanoke Rapids Sanitary District (District) received an outlier effluent mercury result as part of
the November 2, 2009 sampling event. The District is currently sampling monthly for mercury as a
requirement of the Industrial Pretreatment program Long Term Monitoring Plan and Headworks
Analysis for our upcoming permit renewal process. The District requested that the commercial
laboratory originally performing the analysis, re -analyze the sample and return any remaining sample
portion to the District. This unused portion was then sent to another commercial laboratory for
analysis. The District requested that both commercial laboratories performing the analyses review
their quality control and quality assurance procedures (QA/QC) as related to these particular mercury
results and provide the District with a copy of the QA/QC. The effluent sample results have been
verified for mercury concentration.
Past analysis for mercury shows that the effluent results are not typical of our wastewater collection
and treatment system. The District has decided to take a pro -active approach in identifying the
potential source of mercury that resulted in a detectable mercury concentration. The District is
currently preparing a Plan of Action for source identification which will include rigorous sampling of
the wastewater treatment plant to include rainwater and groundwater, possible collection system
sampling, and if required a modified Industrial Waste Survey.
The District will submit this Plan of Action to the Division of Water Quality (DWQ) for review and
comment. The District would like concurrence from DWQ on the Plan prior to beginning this effort.
The District would like to meet with you at your convenience to discuss any issues that arise during
your review. The District appreciates the time and effort of the NPDES Unit to work with us pro-
actively on this issue. Please do not hesitate to call myself or Mary Sadler with Hazen and Sawyer
(919-755-8650) if you have any questions.
Sincerely,
Roanoke Rapids Sanitary District
.�o
R. Danieley Br n, P.E.
Chief Executiv Officer
Cc: Gregg Camp, ORC RRSD Wastewater Treatment Plant
Gil Vinzani, P.E., Division of Water Quality
Mary Sadler, P.E., Hazen and Sawyer
File
VE@ENI21)
FEB - 9 2010
DENR-WATER QUALITY
POINT SOURCE BRANCH