NC0044423_20180329_Corrective Action Plan

Appa1achtn
STATE UNIVERSITY
BOONE, NORTH CAROLINA 28608
March 29,2018
Physical Plant
Joe R Corporon, L G. RECEIVE®/®EMRII I ID [phone]
Water Quality Permitting Section-NPDES Fax [phone]
Division of Water Resources, NCDEQ APR ® 3 2018
512 N Salisbury Street
Raleigh, NC 27604 Water Resources
Permitting Section
Re• Corrective Action Plan
NPDES Permit No NC0044423
Appalachian State University WTP
Dear Mr.Corporon,
Per Condition A(3)of NPDES Permit No NC0044423,Appalachian State University(ASU)Water Treatment Plant
(WTP)is required to submit a Corrective Action Plan (CAP)by April 1,2018 "summarizing actions to be taken to
achieve compliance with Total Copper, Total Zinc, and Turbidity at Outfall 001 "Enclosed herein is the Corrective
Action Plan and the proposed schedule for implementation
Total Copper and Total Zinc
NC0044423 includes the following numerical effluent limits for total copper and total zinc which become effective
January 1,2021
Monthly Average,ughl Daily Maximum,ugh'
Total Copper 4 5 2 p
Total Zinc 63 I 63
Monthly effluent monitoring conducted in accordance with the requirements of this permit indicate the effluent
concentrations exceed the numerical limits at times Total copper monthly monitoring results have ranged from
<1 micrograms per liter(ugh')to 93 ug/I and have exceeded the daily maximum and monthly average limits in 8 of
13 samples Total zinc monthly monitoring results have ranged from< 1 ug/I to 169 ug/I and have exceeded the
daily maximum and monthly average limit in 5 of 13 samples. (This data is based on the DMRs from October 2016
to October 2017 )
As a first step to achieve compliance by January 1, 2021,ASU proposes to monitor the raw water influent for total
copper and total zinc to characterize background concentrations ASU proposes to sample the raw water influent
monthly for the next 12 months
In addition,ASU proposes monitoring the Clean In Place(CIP)backwash effluent monthly for the next 12 months
prior to discharging the CIP effluent to the containment facility where it mixes with the daily effluent to determine
if the background Total Copper and Total Zinc are concentrated in that portion of the total effluent
The next steps to achieve compliance with effluent total copper and total zinc limits will be determined based
upon review of the raw water influent and effluent data
A SIESIBFR INSTITUTION OF THE UNIVERS1T1 OF NORTH CAROLIN 1 1N EQU 1L OPPORTUNITI EMPLOYER

Turbidity
NC0044423 includes a numerical effluent limit for turbidity not to exceed 10 Nephelometric Turbidity Units(NTU)
which becomes effective July 1,2019. Effluent monitoring data collected in accordance with the permit indicates
the effluent turbidity at times exceeds the numerical limit ASU and our consultant Dewberry met with Sherri
Knight and Mike Mickey at the Winston-Salem Regional Office on March 14,2018 to discuss the turbidity limit We
understand the effluent numerical limit was established to be protective of water quality The effluent numerical
limit was established to be equivalent to the instream water quality standard of 10 NTU for Trout waters.We also
understand the NC DEQ Changes to Water Treatment Plant Strategy(October 2009)states that "turbidity will not
be limited except for facilities that discharge to a receiving stream which is impaired for turbidity". Norris Branch
Reservoir is not included in the 303d Impaired Water Bodies List and historical and recent data collected within
Norris Branch Reservoir indicate the water quality within the reservoir is below the 10 NTU stream standard for
Trout waters Based on this recent data, it appears the ASU WTP discharge is not increasing the instream turbidity
above natural background conditions or the instream water quality standard.ASU wishes to meet with the NPDES
Central Office to share the water quality data referenced herein and discuss options to address turbidity
Dissolved Oxygen
Dissolved oxygen is not a parameter required to be addressed by the CAP;however, recent effluent dissolved
oxygen noncompliance events warrant evaluation of this parameter We understand the effluent numerical limit
was established to be protective of water quality.The effluent numerical limit was established to be equivalent to
the instream minimum of 6 mg/I for Trout waters. In February 2018 ASU collected dissolved oxygen data at
multiple locations within Norris Branch Reservoir, upstream and downstream of the ASU discharge.The data
indicates the dissolved oxygen concentrations within the reservoir are above the 6 mg/I minimum stream standard
and the ASU WTP discharge is not decreasing the instream dissolved oxygen below the instream minimum of 6
mg/I ASU wishes to present the monitoring data and discuss options for the dissolved oxygen limit at the
proposed meeting
We look forward to meeting with NCDEQ to review this Corrective Action Plan and to discuss items herein. We
wish to hold this meeting within the next 30 days, if stakeholder schedules allow
Should you have any comments or questions or require additional information, please feel free to contact me at
828 262.3190 ext 109.
Sincerely,
Patrick S. Brittain, PE
License No.022085
Asst. Director Facilities Operation and Maintenance
Cc Sherri Knight, PE, Environmental Regional Supervisor, NCDEQ
Mike Mickey, Environmental Program Consultant, NCDEQ
Jeff Pierce, PE, Director Physical Plant,ASU
Katie Jones, PE, Engineering Consultant, Dewberry
Leigh-Ann Dudley, PE, Engineering Consultant, Dewberry