NC0072702_Corrective Action Plan_20190412

Town of Beaufort
7oi Front St. • P.O. Box 390 • Beaufort,
N.C. 28516
252-728-2141.252-728-3982 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
Glenda Drive Water Treatment Plant
NPDES Permit NCo072702
Town of Beaufort, Carteret County, NC
Dear Mr. Hennessy:
RECEr4Ea' SNRlDWR
APR 2 3 2019
Water € Q&ounce&
PormiUlg Sections
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
Turner Creek of water softener regeneration backwash from ion exchange units at the Glenda
Drive 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,
Ix,f /< AJ­�
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
poi Front St. • P.O. Box 390 • Beaufort,
N.C.28516
252-728-2141.252-728-3982 fax
www.beaufortnc.ore
Corrective Action Plan
Location: Glenda Drive Water Treatment Plant
NPDES Permit NCo072702
Beaufort, Carteret County
Date: March 1, 2019
a ° n
12345 °
Gr6ts aw, PE
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 two metals with limitations as follows:
Monthly ,Average Limit Daily Maximum Limit
Total Copper 1.85 µg/L 2.90 µg/L
Total Zinc 42.8 µg/L 47.6 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 and total zinc limits.
With issuance of the permit, once -a -month sampling for the regulated metals was begun by
the Town. This sampling revealed the presence of zinc above its stipulated limits for the
period between and including March 2o18 through February 2019 only once when it was
detected at 255 µg/1 during August 2018. On the other hand, copper has been detected
above its stipulated limits five times. The concentrations detected ranged from 3 µg/l to 16
µg/l with four of the five results ranging between 7 µg/l and 3 µ9/1.
Given the single exceedance of the total zinc limit over the past year along with the multiple
exceedances of the limits for total copper, the Town of Beaufort proposes to institute the
actions described in the section below titled "Proposed Actions."
Proposed Actions:
The following are actions proposed by the Town of Beaufort to assure compliance with the
permit limitations for total copper and total zinc by March 1, 2023.
The Glenda Drive discharge was redirected to the Town's sanitary sewer collection system
via a new service line installed subsequent to the sampling conducted during February 2019.
This action was taken in response to difficulties over the past year in achieving compliance
with the monthly average and daily maximum limits of 10 mg/1 and 15 mg/l, respectively for
total suspended solids.
Page 1 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

Although the discharge of water softener regeneration backwash from ion exchange units to
an unnamed tributary to Turner Creek has ceased, the Town plans to continue gathering
data from the backwash as it is discharged to the sewer collection system. The Town will
also begin examining sampling data at its wastewater treatment facility. Both types of
sampling are planned so that the technical and monetary feasibilities of one or more
treatment technologies designed to achieve compliance with the permit limits can be
evaluated against continued redirection of the discharge to the Town's sanitary sewer
collection system.
Results for the metals, suspended solids, and other parameters as deemed appropriate will
continue to be obtained and inventoried on a quarterly basis in an effort to better ascertain
the range of concentrations that the Town could expect to see for each constituent if
discharges were left untreated. The Town will also track the levels of copper and zinc in the
sludge from the treatment process to see if any noticeable change in concentrations of these
metals occurs pursuant to redirection of the backwash to the collection system. The Town
proposes to continue this effort until March 1, 2021 whereupon the engineering alternatives
analysis will be undertaken.
The engineering alternatives analysis is expected to yield 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.
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 zinc, total
suspended solids, and other parameters as deemed
appropriate.
March 1, 2021— July 31, 2021
Conduct engineering analysis of alternatives that will
result in compliance.
August 1, 2o21 — February 28,
Prepare plans and specifications and procure the
2022
necessary permit(s) thereafter for any alternative that
involves treating the water softener regeneration
backwash and reestablishing its discharge to the
watercourse. Plans, specifications, and permit(s) will
not be necessary if continued diversion to the Town's
sewer collection system is deemed appropriate.
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) and reestablish
discharge to the tributary. Alternatively, continue
discharge to the collection system and do not apply for a
NPDES permit renewal if discharge to the collection
system is deemed the appropriate corrective action.
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