NC0026000_Corrective Action Plan_20170608

Ehilfron.%tl ental
Quality
Al J. Leonard
Town of Tabor City
PO Box 655
Tabor City, NC 28463
June 8, 2017
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
RECEIVED/NCDEQ/DWR
JUN 14 2011
Water Quality
Permitting Section
Ref: Compliance Evaluation of the Mercury Minimization Plan, Facility Evaluation, and
Corrective Action Plan
Town of Tabor City WWTP; Permit No. NCO026000
Columbus County
Dear Mr. Leonard,
The Water Quality Regional Operations Section (WQROS) appreciates the submittal of the
assessments conducted by WK Dickson on behalf to the Town of Tabor City WWTP. A first (draft)
including a Facility Assessment and Corrective Action Plan was received in August 2016, and
WQROS provided comments on January 30, 2017. A second submittal consisting of a Mercury
Minimization Plan, Facility Assessment, and Corrective Action Plan was received on May 23, 2017.
The development of a mercury minimization plan is required by permit condition A.(4.) while the
evaluation of the facility operational conditions and the implementation of a corrective action plan
are required by permit condition A. (6.). This letter is the compliance evaluation of the documents
submitted.
FACILITY ASSESSMENT (FA)
The FA was conducted on December 8-9, 2015, to evaluate the physical and operating conditions of
the triplex influent pumping station, flow equalization basin, headworks, upper aeration basin and
clarifier #1, lower aeration basin and clarifier #2, aerobic digester and chlorine contact chamber.
It seems that the WWTP physical and operational constraints have been determined.
For the preparation of a cost-effective corrective action plan, the WQROS encourages that other
constraints contributing to the plant high inflows are considered. The implementation of wet weather
surveys looking for flooded system areas and a Sanitary Sewer Evaluation Study (SSSS) to
evaluate/rank/prioritize sewer basins for M would help to get the most benefit from limited funds.
The CAP indicates that "Efforts are being made to identify and address UI sources in the collection
system". Please provide WQROS with a description of the efforts made to identify and address 1/I
sources in the collection system; a sewershed ranking is expected within that report.
Cor pares-'—_—.
State of North Carolina I Environmental Quality
127 Cardinal Drive Extension I Wilmington, North Carolina 28405
910-796-7215

MERCURY MINIMIZATION PLAN (MMP)
Permit condition A. (4.) requires the development of the MMP within 180 days of the NPDES permit
effective date and be available at the site for inspection. The MMP should have been available at
the site for inspection by April 2016. However, it was received for review by WiRO in May 2017.
The MMP would be designed to guide the Town of Tabor City in its efforts to control mercury
discharges into its wastewater treatment plant by users of its sewer collection system. The proposed
MMP follows the format recommended on our website(httDs://deq.nc.gov/about/divisions/water-
resources/water-resources-permit-guidance/pretreatment-guide/mercury-guidancg).
Now that the Town has identified the potential non-domestic sources of mercury, the next
appropriate step to meet the schedule in Permit condition A. (4.), is to implement the Program Plan
described in Section III. Please provide supporting documentation to accomplish the efforts
described in Section III (A, B, and Q. A summary and supporting documentation of the activities
listed in the MMP should be submitted as part of the NPDES permit renewal, expected to be received
in Spring 2019. If the mercury levels would continue to create compliance issues, a pre-treatment
program would be required to be implemented.
CORRECTIVE ACTION PLAN (CAP)
The CAP version received on May 23, 2017 is similar to the draft version dated August 17, 2016.
As explained in our letter on January �0, 2017, the proposed CAP looks reasonable and it seems to
target the plant's operational problems. The main concern is the strategy for the implementation of
the CAP which would require an evaluation of priorities and a plan of action to accomplish them.
Please provide a priority list to accomplish the actions proposed in the CAP.
SCHEDULE
A schedule as required by A. (6.) has not been submitted. Provide a tabulated schedule with itemized
corrective actions and their specific (vet realistic) dates of implementation and completion. The
schedule should:
• Show the duration and projected dates for the implementation and completion of the
activities (start and end), even in the absence of funding (grants, loans, etc.) availability.
• Factor permit approval timeframes (notice that not all proposed activities would require a
permit approval). We understand that funding may influence project scheduling. Therefore,
the schedule should include a contingency plan for lack of funding.
• Coordinate the efforts between the consultant companies that are preparing the facility's
Corrective Action Plan (WK Dickson) and the Engineering Report, ER (Municipal
Engineering). The list of corrective actions and their priorities should be the same in the
documents provided by both consultant companies. Prioritization of corrective actions is
crucial: both documents should align the priority activities to arrive at a meaningful schedule.
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PENDING ITEMS
It is in our best interest to help the Town to comply with the timely implementation of the
activities required by enforceable permit conditions A.(4.) and A. (6.). To that end, please provide
the following information within 60 days:
1. A priority list to accomplish the activities described in the CAP. The list should reflect
coordination between the consultant companies preparmg the CAP and ER.
2. A tabulated schedule (based on the priority list, in item 1) with itemized corrective actions
and realistic dates of implementation and completion. The schedule should include a
contingency plan for lack of funding, or lack of adequate funding.
3. Supporting documentation showing the progress and status of the activities listed in Section
III of the MMP. For example, it is expected that the Town is surveying and evaluating
common sources of mercury in its service area; making available educational information
regarding sources of household mercury and appropriate use/disposal practices through the
Town's website, etc.
4. Supporting documentation of the UI evaluations made (or in progress), including sewershed
ranking and prioritization.
5. An operation and maintenance plan should be on site at all times and should be updated as
rehabilitation and improvements are implemented. Upon completion of the corrective
actions, and operation and maintenance plan should be developed and submitted to the
WQROS for approval.
Please contact me at morella.sanchez-kinggncdenr.gov if you would like to discuss the content of
this letter. We can set up a meeting as needed.
Sincerely,
More 1ez King, PhD, PE
Environmental Program Supervisor III
Water Quality Regional Operation Section
Wihnington Regional Office: 127 Cardinal Drive Extension; Wilmington, NC 28405
cc. WK Dickson & Co, Inc 616 Colonnade Drive Charlotte, NC 28205 IlAtt Jimmy Holland
Municipal Engineering Service Company, P A PO Box 97, Garner, NC 2752911 Att: Ben Clawson
Central Office File- Compliance and Expedited Permitting Unit 11 Attention. John Hennessy
Division Water Infrastructure- Attention Ken PohhgWiRO/WQROS file NCO026000
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