NC0072699_NOV-2019-LV-0510 Response_20190812

Town of Beaufort
701 Front St. • P.O. Box 390 • Beaufort, N.C. 28516
252-728-2141. 252-728-3982 fax
www.beaufortnc.org
August 12, 2019
Mrs. Morella Sanchez -King
NC Department of Environmental Quality/DWR
127 Cardinal Drive Extension
Wilmington, NC 28405
RE: Response to Notice of Violation
Pine Street WTP
Tracking No. NOV-2019-LV-0510
Permit No. NCD072699
Dear Mrs. King:
We are writing in response to your letter dated July 24, 2019. The letter noted that the daily
maximum and monthly average concentrations for total suspended solids (TSS) during the
month of June exceed the concentrations allowed by the permit for the discharge from the Pine
Street Water Treatment Plant (WTP). The daily and monthly limited values of 45 mg/l and 30
mg/l respectively, were exceeded due to the 78.5 mg/1 TSS concentration detected in the June
4th sample.
Please be advised that we are convinced that the higher than usual June 4th concentration is
attributable to a malfunctioning flow recording device which controls when softener #1
regenerates. The malfunction meant that the softener had not regenerated at periodic intervals
during the time between occurrence of the malfunction and discovery of the issue on June 6th.
The June 4th sample was collected during this period and from the discharge of the softener
during a manually activated regeneration cycle. We are confident that the manually -induced
discharge contained higher than normal suspended solids because of the length of time that had
transpired between the last automatic regeneration cycle and the manually activated cycle. In
fact, the results for the next sampling episode of June 18th showed a return to a typical TSS
concentration.
We think it worth noting that prior to the unusual occurrence described above, the TSS limited
values have not been exceeded since the March 1, 2018 effective date of the NPDES permit
covering the Pine Street WTP discharge. Nonetheless, the Town is now planning to move
forward with redirecting the Pine Street discharge to the sanitary sewer collection system. To
this end, we added a tap to the nearby sanitary sewer several months ago. As such, redirection
of the discharge can be accomplished by merely installing a service line between the plant and
the tap.
Mayor Everette S. (Rett) Newton
Commissioner John Hagle • Commissioner Sharon Harker • Commissioner Marianna Hollinshed
Commissioner Ann Carter • Commissioner Charles McDonald
Town Manager John Day

Mrs. Morella Sanchez -King
August 12, 2019
Page 2
Although we are planning to redirect the discharge, Town staff intends to continue collecting
and analyzing effluent samples on a quarterly basis. This ongoing data, prior discharge data,
and our capital planning forecasting relative to upgrades to or replacement of the Pine Street
WTP will be used to determine whether to continue discharge to the sanitary sewer system
versus reestablishing the discharge to the receiving stream (while the permit is still in place).
While we realize that your letter noted that the Division may issue a civil penalty, we ask that the
Division forego such penalty. We make this request given our history to this point in complying
with the TSS limited values and our planning to mitigate future violations.
Your cooperation in this matter is greatly appreciated. As such, please do not hesitate to contact
me by phone [phone]) or by email (g.meshaw(&beaufortnc.org) should you have
questions or be in need of additional information.
Sincerely,
TOWN OF BEAUFORT
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Gregory K. Meshaw, PE
Town Engineer
Mayor Everette S. (Rett) Newton
Commissioner John Hagle • Commissioner Sharon Harker • Commissioner Marianna Hollinshed
Commissioner Ann Carter • Commissioner Charles McDonald
Town Manager John Day