NC0025909_corrective action plan_20240216

Rutherfordton
ORIGINALA MINTED
January 28, 2024
NCDEQ / Division of Water Resources
NPDES Permitting
1617 Mail Service Center
Raleigh, NC 27699-1617
NCDEQ / Division of Water Resources
Asheville Regional Office
2090 US 70 Highway
Asheville, NC 28778
Re: NPDES Permit No. NC0025909
Schedule of Compliance
To Whom It May Concern,
The Town of Rutherfordton is the owner of the Town of Rutherfordton Wastewater Treatment.
The recent NPDES Permit issued with an effective date of December 1, 2022 included a
permit limitation for Nitrate Nitrogen. Also, included in the Permit was a Schedule of
Compliance, Section A.(5.) which allowed the Town time to determine how the permit limit
could be met. The first compliance activity required the Town to submit an Action Plan to the
Division summarizing the strategy or actions to be taken to achieve compliance with the permit
limitations for total copper, total silver, and total lead. The Town has included an Action Plan
for review and approval.
In accordance with Section A.(5.) of the Permit, attached for review and approval is an Action
Plan the Town is proposing to achieve compliance with the Nitrate Permit limit. If our proposed
strategy does not provide an acceptable approach, please advise. The Town is available for
discussion at your convenience.

If you have any questions or require additional information, please do not hesitate to contact
me.
Sincerely,
Doug Barrick
Town Manager
Cc: Phillip Reynolds, WVVTP ORCNeolia
Nadine Blackwell, Area ManagerNeolia
Sent Certified Mail, Return Receipt Requested

TOWN OF RUTHERFORDTON
NPDES NCO025909
SCHEDULE OF COMPLIANCE, SECTION A.(5.)
ACTION PLAN TO ACHIEVE COMPLIANCE
WITH NITRATE LIMITATION
Date Developed: December 2023
BACKGROUND
During the 2022 NPDES Permit renewal process, the North Carolina Department of
Environmental Quality provided the Town of Rutherfordton with a draft permit that included
the following limit:
Parameter
Maximum
Monthly
Reasonable Potential Analysis
Reported
Average Limit
(RPA) Decision
Concentration
Nitrate
17 mg/L
22.0 mg/L
RP shown - apply Monthly
Monitoring with Limit
NCDEQ issued the NPDES Permit in final form with the proposed Nitrate limit. This limit was
not included in the previous NPDES Permit which expired July 31, 2020. The effluent DMR
data used by the State for the draft permit development was based on a single value of 17
mg/I.
Strategy/Action To Achieve Compliance
Proposed Completion Date
To determine a representative level of
Ongoing
Nitrate in the effluent, conduct Effluent
monitoring for Nitrate at a monitoring
frequency of twice per month which is
greater than the monthly monitoring
frequency in the Permit.
Evaluate the effluent Nitrate data and
June 30, 2024
determine consistent compliance with the
NPDES Permit limit.
Evaluate treatment alternatives if the effluent
October 31, 2024
Nitrate does not demonstrate consistent
compliance with the monthly average Permit
limitation of 22.0 mg/I
Submit proposed treatment alternatives to
December 1, 2024
NCDEQ