NC0072702_NOV Response_20180720

Town of Beaufort
lox Front St. • P.O. Box 390 • Beaufort, N.C. 28516
252-728-2141.252-728-3982 fax
www.beaufortnc.or
July 18, 2018
Ms. Morella Sanchez -King
NC DEQ/ DWQ
127 Cardinal Drive
Wilmington, North Carolina 28405
RECEIVED/NCDENR/DWR
JUL 2 Q 70 i3
Water Quality Regional
Operations Section
Wilmington Regional Office
RE: Town of Beaufort Glenda Drive WTP \ NPDES Discharge Permit NC 0072702
RESPONSE from the TOWN OF BEAUFORT for NOV by LETTER DATED JULY 9, 2018
Tracking Number: NOV-2018-LV-0490
Dear Ms. King:
In response to your letter dated July 9, 2018, the Town of Beaufort is requesting it not be issued
a civil penalty for discharge in May 2018 being over -the -limit under the above -referenced NPDES
Discharge Permit. Although the reported values of 17.3 maximum and an average of 14.1 for TSS
were not extremely high, they did exceed the permit limits. Based on historical performance of
the Beaufort Glenda Drive WTP, the numbers were higher than expectation; based on
comparison to Beaufort Pine Street WTP the numbers were higher than expectation.
The Glenda Drive WTP and Pine Street WTP utilize much of the same -type equipment in the same
way to soften water prior to distribution. The raw water comes from two (2) different well groups
pumping from the same Castle Hayne Aquifer. Looking at data covering new well inorganic
chemical analysis for the two (2) newer wells (one new well for each plant), we see similar
constituents in the raw water passing through each of the well screens at approximately 250 to
300 VF. Neither data set indicates one should expect to have difficulty with softener backwash
having excess TSS. In May the corresponding numbers for the Pine Street discharge was 9.8
maximum and an average of 8.5 for TSS. Why are the Glenda Drive numbers higher than numbers
for Pine Street?
At this time, we do not know why there is a difference between TSS in discharges from the Glenda
and Pine Street Facilities. Testing in June and July might or might not be over limit. If over limit,
an acceptable modification to operation and maintenance procedure, discharge testing or other
recommendation could remedy the issue. May 2018 was the first month that testing procedure
Mayor Everette S. (Rett) Newton
Commissioner John Hagle • Commissioner Sharon Harker • Commissioner Marianna Hollinshed
Commissioner Ann Carter • Commissioner Charles McDonald
Town Manager John Day

Town of Beaufort
7o1 Front St. • P.O. Box 390 • Beaufort, N.C. 28516
252-728-2141.252-728-3982 fax
www.beaufortnc.or�
associated with the new permit was implemented by the Town. The testing process might
require some acceptable adjustments to ensure test results reflect actual condition of the
discharge. Rivers & Associates and the Town of Beaufort are currently working on an Asset
Inventory Assessment Plan for the Beaufort Water System that includes consideration of
operation and maintenance procedures and other possible recommendations for its water
system.
The Town anticipated it might have difficulty meeting extreme limits of the new permit covering
zinc and copper for discharge from the Glenda Drive WTP. NCDEQ recognized the extreme limits
and made provisions in the permit with a one-year, two-year, three year, four year, five-year step
plan to achieve compliance with new Total Copper and Total Zinc Limits. In fact, the limits in the
permit for zinc and copper at the Glenda Drive WTP are so extreme the Town is currently having
difficulty locating a commercial lab that can perform testing acceptable to NCDEQ. Nevertheless,
resolution of such issues requires time.
The Town reported over -the -limit for TSS within 24 -hours of its being aware and believes a civil
penalty and discussion SOC at this time is pre -mature. Given the relatively small magnitude of
the reported numbers in May 2018 for TSS in discharge from the Glenda Drive WTP, the Town is
asking it be given a reasonable time for more test results and resolution of issues to achieve
compliance with TSS Limits for its Glenda Drive WTP.
Please call if you have any questions.
Sincerely,
v
Donovan H. Willis, Public Utilities Director —ORC
Town of Beaufort
cc: Dean Hunkele — NCDEQ \ Wilmington Region
Gale Smith, P.E. -- Rivers & Associates, Inc
Wade Keeler --Town of Beaufort
John Day —Town of Beaufort
Mayor Everette S. (Rett) Newton
Commissioner John Hagle • Commissioner Sharon Harker • Commissioner Marianna Hollinshed
Commissioner Ann Carter • Commissioner Charles McDonald
Town Manager John Day