NC0026573_Corrective Action Plan_20230831

August 25, 2023 RECEIVED
AUG 31 2023
NCDEQ/pypDEs
Copper Corrective Action Plan
Catawba River Pollution Control Facility
NC0O26573
PREPARED FOR:
City of Morganton
Catawba River Pollution Control Facility
1000 Vine Arden Road
Morganton, NC 28655
Prepared By:
Rusty Campbell
Garver
10735 David Taylor Drive
Charlotte, NC 28262
GARVER

Introduction and Purpose
The City of Morganton, North Carolina(the City) owns and operates the Catawba River
Pollution Control Facilities(CRPCF) located at 1000 Vine Arden Road, Morganton,NC 28655.
The facility is permitted for flows of 8 MGD, 10.5 MGD, and 13 MGD under the current
National Pollutant Discharge Elimination System(NPDES)permit NC0026573 and discharges
into the Catawba River Basin with the 2022 average flow being 5.35 million gallons per day
(MGD). The most recent approved NPDES permit, effective September 1,2022 through August
30,2027, for the CRPCF requires that the utility submit a Corrective Action Plan(CAP)for
copper due to elevated levels during October, 2017, causing the effluent to exceed the permitted
allowable daily maximum and monthly average maximum of 96.1 µg/L and 85.9 µg/L,
respectively.
History,
The most recent inspection from November 9, 2021,of the CRPCF, conducted by Linda Wiggs
and Stephanie Williams with the North Carolina Department of Environmental Quality
(NCDEQ) Division of Water Resource(DWR), indicated the plant was fully compliant,well
maintained, and had no violations. It was also noted that staff do an exceptional job operating the
facility and maintain a robust pre-treatment program. After much investigation by City staff,
including review of the collections system, including chemicals used in the collection system
maintenance for root management,etc. and CRPCF operations, it was determined the source of
copper did not originate from within the operation of the wastewater treatment facility or the
wastewater collection system. During the investigation, it was determined that the elevated
copper results stemmed from wastewater discharges from two industries, Seiren; (an automotive
interior materials manufacturer)and Leviton Manufacturing Co. (an industrial manufacturer of
plastic products for residential, commercial and industrial use.),into the City's collection system,
which led to the elevated results of the CRPCF discharge for copper in October 2017. The result
of this investigative analysis was subsequently submitted to NCDEQ via emails between Eli Self
with the City and Diana Yitbarek with NCDEQ DWR. One of the impacting industries, Leviton
had its permit discontinued in 2018 and no longer discharges to the City's collection system and
CRPCF,instead opting to have the industrial waste stream collected and removed by a private
contractor for disposal outside of the City. Seiren is closely monitored under the pre-treatment
program and has had no copper discharge issues since 2017.
Steps Taken
November 01,2021. City staff began to investigate possible copper contamination points. Staff
from both distribution and collections were interviewed about possible causes including system
materials, chemicals used during the deployment of JetVac trucks, grease reduction activities,
and root mitigation,as well as other possible contributions to the elevated copper value. The
City's Water Treatment plant staff were consulted to discern a copper baseline that could be
contributed within the City's water distribution system. Results from the 2019 sampling period
within the water distribution system yielded no discernable results that would create elevated
copper levels in the wastewater discharge streams. These results were also mapped via GIS for
record of reference.

February 2022—May 2022.City staff issued Industrial Wastewater Surveys(IWS) to all
businesses inside the City discharging to the City sewer system.
September and October 2022.City staff followed up on several IWS concerns that could be
potential contributors of copper to the waste stream. It was determined that most do not
discharge to the collection system but have third-party contractors collect and haul waste to
disposal sites outside of the City. Others investigated were found to be of little concern after
facility tours and confirming that standard operating procedures(SOPs) were being correctly
followed. Those discharge sites were monitored and continue to be monitored for any future
changes to their discharge streams.
March 31,2022. The City issued a pretreatment permit renewal to Seiren with a reduction of the
copper limit from 0.325 mg/L to 0.250 mg/L.
August 1,2023.City staff updated copper results from the lead/copper testing conducted from
the water distribution system and mapped those results accordingly.
August 7, 2023. City staff issued a letter to Seiren to identify any process components that have
copper and requested a response regarding the substitution or removal of products that can
contribute copper to the wastewater discharge.
August 25,2023, City staff received a response letter from Seiren regarding the copper
concentrations in the materials and chemicals used in their processes indicating regular testing
and continued effort to find safer alternatives.
These actions and Leviton using a third-party hauler of waste have led the City to quickly gain
compliance following the October 2017 elevated readings and remain in compliance since that
time with copper limits as indicated in the NPDES permit for the CRPCF. The copper
exceedance is a result of an industrial discharge anomaly and has not occurred again. There have
been no violations of copper discharge limits from the CRPCF upon completion of investigations
and corrective actions as described above, for industrial discharges to the City's wastewater
collection system.
Ongoing and Actions Moving Forward
The actions listed below describe the steps the City is taking and will continue to take to comply
with the wastewater effluent limits for copper as defined in the City's NPDES permit for the
CRPCF.
• Monitor all septic haulers pump sites and verify residual septic discharges.
• Monitor all new businesses and industries discharging metals to the wastewater system.
• Monitor all industries for process changes that may impact discharge residuals for metals.
• In the last quarter of 2023, City staff will be making non-significant industrial user(NIU)
permit modifications by adding copper limits to all permits.
• Continue to review and revise pre-treatment permits as needed.

• Review and update the City's pretreatment program as needed to meet or exceed
regulatory requirements.
• Adhere to schedules imposed by the City's NPDES permit for the CRPCF and the
Corrective Action Plan for copper reduction in the waste stream including additional
monitoring and reporting requirements to NCDEQ as prescribed in the permit expiring in
2027.
Conclusion
Since 2017 there have been no additional copper exceedances. Regardless, the City of
Morganton has taken steps to decrease the potential for the introduction of copper to the
wastewater discharge stream. The CRPCF and staff are actively monitoring treatment operations,
collection system activities, and the pretreatment program to ensure compliance with the NPDES
permitted discharge limits. Extensive communication and collaboration have been taken to
address copper compliance and will continue going forward. The City of Morganton recognizes
the importance of being a good steward of the environment and meeting exceeding all regulatory
requirements and, as such, will continue to be vigilant monitoring of industrial discharge sources
and CRPCF effluent into the receiving stream to continue meeting NPDES permit limits.
Rusty Campbell
Senior Utility Operations Consultant
Garver
rpcampbellc garverusa.com
704-860-7340
Brad Boris
Water Resources Director
City of Morganton
[e-mail]
828-438-5285
Eli Self
A114
Wastewater Superintendent
City of [e-mail]
828-438-5375