NC0020338_Corrective_Action_Plan_Letter_20220224

February 24, 2022
ATTN: Mike Montebello
NCDEQ— Municipal Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
NPDES Permit NC0020338
Town of Yadkinville WWTP
Section A (5) Schedule of Compliance for Total Copper (Outfall 001)
Dear 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. These actions have already been completed.
WWTP staff have completed the required sampling for a Water Effects Ratio (WER) for copper. The
completed WER was submitted 4/21/2021 to NC DEQ (Cassidy Kurtz). NC DEQ is actively working on
possibly modifying our NPDES Permit.
We have collected copper samples from throughout points of the collection system to identify possible
sources. For Example:
• Water Treatment Plant lift station Process waste and domestic waste (10.4 ug/L avg.)
• North Gate Lift station all residential (17.2 ug/L avg.)
• Lamplighter lift station 7 contributing lift stations (26.5 ug/L avg.)
- These few examples constitute 50% of our uncontrollable source flow.
• YMCA Lift station DOT maintenance, YMCA, Hair salon, Church (464.9 ug/L avg.)
Due to above average copper levels in samples collected from the DOT discharge. Contact
was made with DOT representatives and after several in person meetings, actions were
taken by both sides (i.e., repair of numerous broken clean outs, used our camera to inspect
specific lines that connects to the lift station.)
Due to above average copper levels in samples collected from the YMCA discharge. Contact
was made YMCA personnel along with an on -site visit to observe pool maintenance
procedures. Came to an agreement that pool water would be discharged at a lower
frequency and contact the WWTP prior to pool discharges.
Hair salon and Church showed normal to average copper levels.

During required annual inspections with our SIU's copper reduction was discussed at each of their
facilities.
2 SIU permits Unifi Permit 0002 and Permit 0005 were previously modified (2020) to reduce allocated
copper. Unifi has also installed an ion exchange water softener to assist with metals reduction at the
Permit 0005 site.
All future equipment orders will be non -copper if available (Stainless Steel for condensate coils).
If NCDENR feels there are any corrections to be made please advise.
Sincerely,
Grant F. Trivette
WWTP ORC

Corrective Action Plan
Total Copper
Yadkinville WWTP
NPDES Permit NC0020338
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 —
b. 03-01-2022 —
c. 03-01-2023
d. 03-01-2024 —
Corrective Action Plan
Summary of actions taken
- Summary of actions taken
Summary of actions taken