NC0088307_Other Correspondence_20190129

James R.Flechtner,PE
Executive Director
Cape Fear 235 Government Center Drive
Wilmington,NC 28403
Public Utility Authority 910-332-6625
Stewardship.Sustainability.Service.
[e-mail]
January 29, 2019
RECEIVED/DENR/DWR
NC DEQ Division of Water Resources JAN 31 2019-
Attn: Linda Culpepper, Interim Director
1617 Mail Service Center ,v;:roz::•s
•
Raleigh, NC 27699-1617 Rif
SUBJECT: NPDES Permit NC0088307
Ogden Nanofiltration WTP Class PCNC New Hanover County
Section A. (3) Schedule of Compliance (Outfall 001)
Dear Ms. Culpepper:
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. As staff has continued to analyze samples over this last year, it has
become apparent that increased monitoring and a correlation of operational scenarios is
warranted to further understand any variations in discharge.
Recent data indicates the discharge is routinely in compliance. However,this next year will
enable staff to gain a better understanding of the correlation between the various source water
wells and their contributions to any fluctuations in copper concentrations. Below is a proposed
Corrective Action Plan that should allow enough time and data to develop a path forward to
consistently achieve compliance:
• Increase effluent monitoring for copper to bi-monthly for 12 months beginning
January 2019.
• Identify and track operational conditions and_well sources at the-time-of sampling,
beginning January 2019.
• Monitor the Castle Hayne and Pee Dee aquifers independently at incoming sampling
points within the Nanofiltration WTP for Copper during the bi-monthly effluent
sampling events at least quarterly.
• Correlate aquifer contribution and data results to determine copper concentrations
from the various operating scenarios by December 2020.
• Determine the next course of action based on results of the data analysis no later
than January 2022.

January 29, 2019
Page Two
We believe these action items will give us the information required to adjust plant operations,
if necessary,to achieve compliance and be protective of the receiving water at the outfall while
ensuring continued protection of the Public Water supplied to CFPUA customers. If you have
any further concerns, please feel free to contact me at 910-332-6542 or Beth Eckert at 910-332-
6646.
Sincerely,
(- 1....._---R,:-.\--,e,A, ,
James, R. Flechtner, PE
Executive Director
Cape Fear Public Utility Authority
cc: Brianna Young, NCDEQ
Julie Gryb, NCDEQ
Frank Styers, PE, Chief Operations Officer, CFPUA
Beth Eckert, Environmental Management Director, CFPUA
John Malone, Water Resource Manager, CFPUA