NC0020338_Pretreatment_CAP_Report_20240126

TOWN OF YADKINVI L1LE
"A TOWN 1N PROGRESS"
January 26, 2024
ATTN: Mike Montebello
NCDEQ—Municipal Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
NPDES Permit NCO020338
Town of Yadkinville WWTP
Section A (5) Schedule of Compliance for Total Copper (Outfall 001)
Mr. Montebello:
Schedule of Compliance of the above referenced NPDES Permit requires submittal within one
year of the effective date a Corrective Action Plan for achieving compliance with the newly issued
copper permit limits.
WWTP staff have completed the required sampling for a Water Effects Ratio (WER) for copper.
On 6/3/2022 a modified permit was issued with an updated effluent limitation for copper from 19.1 ug/1
to 34.5 ug/I monthly average. An updated HWA was submitted on 8/16/2022 to fulfill the Pretreatment
update requirement for the permit modification.
Efforts have been concentrated on working further with the SIU's. B&G Foods Inc. currently is
our largest single source copper contributor. During the past year B&G staff have continued working
internally to trace sources of copper in their discharge to the POTW. The WWTP/PT personnel met with
B&G staff on two occasions to discuss options and assist with possible solutions for copper reduction.
B&G has reduced their copper contribution to the POTW by almost 50% compared to their levels in
2022. During required annual PT inspections with all four of our SIU's copper reduction was discussed at
each of their facilities. Unifi has installed an ion exchange water system at their Plant 5 location to aid
with the reduction of copper. Unifi's Main Street location has reduced staffing and twisting operations.
The twisting process was relocated to another Unifi site.
WWTP/PT staff have revisited the known sites for elevated copper levels and performed testing
for copper. The results reflected that the levels of copper decreased from prior sampling events. One
sample site has as a contributor the YMCA. The YMCA has an indoor pool which was considered a highly
possible source of elevated copper due to previous sampling data. Arrangements were made with
YMCA staff to notify Town staff of their next pool draining to allow for samples to be collected and
analyzed. The data from the YMCA pool discharge did not indicate high levels of copper during the
event.
213 Van Buren Street
Post Office Drawer 816 Telephone [phone]
Yadkinville, North Carolina 27055-0816 Fax [phone]

TOWN OF YAD1[ INVI1L1L1E
"A SOWN 1N PROGRESS"
The Town public works staff have taken copper reduction steps by eliminating all copper
containing material possible used in the installation of new water taps and removing any existing copper
that is currently in place if feasible. The public works staff are also in the process of the lead service line
inventory. They are identifying what line materials are in place on the Town side of the water meter and
on the customers side also. This information is being recorded for future actions that may be required.
This activity will also help identify the location of copper service lines serving all the Towns customers.
If NCDENR feels there are any corrections to be made please advise.
Sincerely,
Grant F. Trivette
WWTP ORC/PT Coordinator
213 Van Buren Street
Post Office Drawer 816 Telephone [phone]
Yadkinville, North Carolina 27055-08W Fax [phone]

Corrective Action Plan
Total Copper
Yadkinville WWTP
NPDES Permit NCO020338
The Yadkinville WWTP was issued NPDES Permit with an effective date of March 1, 2020.
The permit contains effluent monitoring and limitations for Total Copper. This limit is new and
is based on the potential of the WWTP effluent to exceed water quality standards for copper.
— The facility will take a systematic approach to achieving compliance along with a WER
(Water Effects Ratio) to possibly raise the effluent limit.
— Identification and elimination of potential sources of copper.
— Evaluate and implement operational changes if needed.
Schedule of Compliance
03-01-2021 — 03-01-2022
• Testing for Total Copper
o Work with known copper contributors (SIU's) in an effort to reduce copper
loading to the POTW.
o Research and identify other possible sources of copper to the POTW.
o Evaluation of sampling locations within the collection system and sampling
techniques.
03-01-2022 — 03-01-2023
o Identify and compile sample data from uncontrollable sources and other
possible copper contributors in an effort to reduce copper loading to the
POTW.
o Continue researching and identifying other possible sources of copper to
the POTW.

03-01-2023 — 03-01-2024
o Continue to work with the SIU's and newly found copper contributors in an
effort to reduce copper loading to the POTW.
02-28-2025
o Achieve compliance with total copper effluent limit.
Reports
■ The Town of Yadkinville WWTP will submit reports to the Winston-Salem
Regional Office and the NC DWR NPDES Complex Permitting Unit, on a yearly basis, a
summary of the actions that have been taken in accordance with this Corrective Action
Plan.
o NCDEQ / Division of Water Resources
NPDES Complex Permitting
1617 Mail Service Center
Raleigh, NC 27699-1617
o NCDEQ / Division of Water Resources
Winston-Salem Regional Office
450 Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
■ Reports are due:
a. 03-01-2021 - Corrective Action Plan
b. 03-01-2022 - Summary of actions taken
c. 03-01-2023 - Summary of actions taken
d. 03-01-2024 - Summary of actions taken