NC0072699_Corrective Action Plan_20190412

Town of Beaufort
701 Front St. • P.O. Box 390 • Beaufort,
N.C. 28516
252-728-21419252-728-3982 fax
www.beaufortnc.org
April 12, 2019
Mr. John Hennessy
Division of Water Resources
Water Quality Permitting Section — NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Corrective Action Plan
Pine Street Water Treatment Plant
NPDES Permit NCo072699
Town of Beaufort, Carteret County, NC
Dear Mr. Hennessy:
RECElVEDDEENR E)WR
APR 23 2019
Water Rezource
P81mit3ng Section
Please find enclosed a single copy of a document titled "Corrective Action Plan." This plan is
being provided in accordance with a requirement contained within the National Pollutant
Discharge Elimination System permit issued for the discharge to an unnamed tributary of Town
Creek of water softener regeneration backwash from ion exchange units at the Pine Street Water
Treatment Plant. An electronic copy of this plan was sent to you as an email attachment on
April 15th.
We ask that you advise us as to your Division's concurrence with the actions set forth by the plan
as we intend to carry them out unless and until advised otherwise.
Your cooperation in this matter is greatly appreciate. Please therefore, do not hesitate to contact
us if you have questions or are in need of additional information.
Sincerely,
r>
1
Gregory K. Meshaw, PE
Town Engineer
Encl.
CC: Morella Sanchez -King, Environmental Program Supervisor III, DWR-WiRO
Dean Hunkele, Senior Environmental Specialist, DWR-WiRO
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
col Front St. • P.O. Box 390 • Beaufort,
N.C. 28516
252-728-21410252-728-3982 fax
www.beaufortnc.org
Corrective Action Plan
Location: Pine Street Water Treatment Plant
NPDES Permit NCo072699
Beaufort, Carteret County
Date: March 1, 2019
Town Engineer
Background:
A National Pollutant Discharge Elimination System (NPDES) permit with an effective date
of March 1, 2o18 was issued for the discharge of water softener regeneration backwash from
ion exchange units. Among the thirteen (13) effluent characteristics to be limited and/or
monitored included three metals with limitations as follows:
Monthly Average Limit Daily_Maximum Limit
Total Copper 3.70 µg/L 5.8o µg/L
Total Lead 8.50 µg/L 220.8o µg/L
Total Zinc 85.6 µg/L 95.1 µg/L
The permit called for compliance with the above limitations within five years of the effective
date of the permit which will be 2023. To that end, the permit also required the submission
of a Corrective Action Plan (CAP) to the Division of Water Resources (DWR) within the first
year of the permit. The stated purpose of the CAP is to summarize the actions or strategy to
be taken to achieve compliance with the total copper, total lead, and total zinc limits.
With issuance of the permit, once -a -month sampling for the regulated metals was begun by
the Town. This sampling has not revealed the presence of zinc above its stipulated limits for
the period between and including March 2018 through February 2019. On the other hand,
copper has been detected above its stipulated limits albeit only once, when it was detected at
14 µg/l during August 2018.
Two of the monthly results for lead over the same period are of interest. Lead
concentrations of 12 and 14 µg/1 were detected during May 2o18 and August 2o18,
respectively. Even though these two concentrations were well below the stipulated daily
maximum, they are likely considered to have "tripped" the stipulated monthly average since
both exceed the monthly average limit by more than 20 percent. It is understood that DWR
typically considers the monthly average to have been exceeded when only one result has
been obtained for the month and that result exceeds the monthly average limit by more than
20 percent.
Given the single exceedance of the total copper limit for the past year along with the
theoretical exceedance of the monthly average limit for lead, the Town of Beaufort proposes
to institute the actions described in the section below titled "Proposed Actions."
Page 1 of 2
Mayor Everette S. (Rett) Newton
Commissioner John Hagle • Commissioner Sharon Harker • Commissioner Marianna Hollinshed
Commissioner Am Carter • Commissioner Charles McDonald
Town Manager John Day

Proposed Actions:
The following are actions proposed by the Town of Beaufort to assure compliance with the
permit limitations for total copper, total lead and total zinc by March 1, 2023.
Results for the metals will continue to be obtained and inventoried in an effort to ascertain
the range of concentrations that the Town could expect to see for each metal if discharges
were left untreated. The Town proposes to continue this effort until March 1, 2021 to see if
sporadic exceedances of one or more of the limitations continue. If continued exceedances
have occurred, then sufficient laboratory data will have been generated for use in an
engineering alternatives analysis. It is likely that this analysis will examine the technical and
monetary feasibilities of one or more treatment technologies along with the option of
redirecting the discharge to the Town's sanitary sewer collection system. This analysis will
result in a recommendation of a preferred alternative for achieving compliance. Thereafter,
DWR's concurrence regarding the preferred alternative will be sought. This will of course,
be followed by implementation of corrective action to included related tasks such as design
and permitting.
It is worth noting that a point of connection to the Town's sewer collection system in
proximity to the Pine Street Water Treatment Plant has already been made. The connecting
point was made in the event it is ultimately determined that discharge to collection system is
the most feasible alternative. This connecting point will also allow the Town to easily divert
the plant's discharge prior to March 1, 2021 should limits be consistently exceeded at
concentrations deemed by the Town and DWR to be excessive.
The proposed timeline for monitoring, performing the alternatives analysis, and
implementing corrective action is as follows:
Date/Timeframe
Task/Action
March 1, 2019 — February 29, Continue procurement, review, and inventorying of
2021 laboratory results for total copper, total lead and total
zinc.
March 1, 2021— July 31, 2021 Conduct engineering analysis of alternatives that will
result in compliance if prior monitoring shows
exceedances of the permit limits.
August 1, 2021— February 28, Prepare plans and specifications and procure the
2022 necessary permit(s) thereafter for any alternative that
involves treatment of the discharges. (Plans,
specifications, and permit(s) will not be necessary if
diversion to the Town's sewer collection system is
deemed the appropriate alternative.)
March 1, 2022 — January 31, Bid and award a contract to construct the treatment
2023 additions. Thereafter, construct, start-up, test and
place into service the treatment unit(s). (Diversion of
the water treatment plant's discharge to the collection
system can be made by Town staff within 3o days
should such diversion be deemed the appropriate
corrective action instead of treatment.)
Page 2 of 2
Mayor Everette S. (Rett) Newton
Commissioner John Hagle • Commissioner Sharon Harker • Commissioner Marianna Hollinshed
Commissioner Ann Carter . Commissioner Charles McDonald
Town Manager John Day