NC0002879_More Information Received_20190226

,
James R.Flechtner,PE
Executive Director
MN Cape Fear 235 Government Center Drive
Wilmington,NC 28403
Public Utility Authority 910-332-6625
[e-mail]
Stewardship.Sustainability.Service.
February 26, 2019
NC DEQ Division of Water Resources
Attn: Linda Culpepper, Interim Director
1617 Mail Service Center
Raleigh, NC 27699-1617 RECEIVER/DENRIDWR
SUBJECT: NPDES Permit NC0002879 MAR 0 4 2019
Sweeney Water Treatment Plant Water Resources
Section A. (4)Schedule of Compliance (Outfall 001) E'@rmittin9 Section
Dear Ms. Culpepper:
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. As staff has continued to analyze samples over this last year, it has
become apparent that increased monitoring and a correlation of operational scenarios is
warranted to further understand any variations in discharge.
Recent data indicates the discharge is routinely in compliance. However, this next year will
enable staff to gain a better understanding of the correlation between variations in source
water at the two water intakes,treatment processes, and potential treatment chemical
contributions to any fluctuations in copper concentrations. Below is a proposed Corrective
Action Plan that should allow enough time and data to develop a path forward to consistently
achieve compliance:
• Increase effluent monitoring for copper to monthly for 12 months beginning March
2019.
• Identify and track operational conditions and raw water intakes at the time of
sampling events, beginning March 2019.
• Staff will review chemical certification sheets, investigate with vendors, and, if
necessary, conduct monitoring of the raw chemicals to determine if any of the
chemicals added for treatment of the public water could be causing an increase in
the copper concentration discharged from the facility.
• Correlate additional sampling, operational data and chemical investigations to
evaluate any variations in copper concentrations from the various operating
scenarios by December 2020.
• Determine the next course of action based on results of the data analysis no later
than December 2021.

We believe these action items will give us the information required to adjust plant operations,
which may include chemical suppliers, if necessary,to achieve compliance and be protective of
the receiving water at the outfall,while ensuring continued protection of the Public Water
Supplied to CFPUA customers. If you have any further concerns, please feel free to contact me
at 910-332-6669 or Beth Eckert at 910-332-6646.
Sincerely,
Ja s, R. Flechtner, P.E.
Executive Director
Cape Fear Public Utility Authority
cc: Brianna Young, NCDEQ
�J ilie Gryb, NCDEQ
Frank Styers, Cape Fear Public Utility Authority
Beth Eckert, Cape Fear Public Utility Authority
John Malone, Cape Fear Public Utility Authority
Ben Kearns, Cape Fear Public Utility Authority