NC0004626_Comments_20220321

Terry Steinert,Environmental Manager
E Nippon Electric Glass T:704-434-2261 ext.22007
Electric Glass Fiber America,LLC Email: terry.steinert(o neo-us.com
473 New Jersey Church Rd, Lexington, NC 27292
via Federal Express March 16, 2022
Julia Byrd
NC DEQ DWR NPDES Industrial Permitting Unit
512 North Salisbury St.
1617 Mail Service Center RECEIVED
Raleigh, NC 27699-1617
r =‘g212022
Re: Electric Glass Fiber America, LLC
Draft NPDES Permit No. NC0004626 NCDEQIDWRINPDES
Dear Ms. Byrd,
Electric Glass Fiber America, LLC (EGFA) has received a draft NPDES permit for the EGFA facility located
at 473 New Jersey Church Road in Lexington, NC (Davidson County). Thank you for the prompt issuance
of this draft and the opportunity to review. EGFA has these comments on the draft permit:
1. The cover letter and permit are addressed to Ms. Brigette Tinsley. Ms.Tinsley no longer works
at EGFA. Per the permit application, please address future correspondence to me.
2. On the list of equipment comprising the wastewater treatment facility,the dual activated
carbon adsorption units with pH adjustment were taken out of service with DEQ approval prior
to 2021 and so noted on the permit renewal application form.
3. Cadmium is not currently a parameter that is monitored at the EGFA Lexington facility. On the
permit renewal application, EGFA indicated cadmium was "believed absent." The second bullet
of your cover letter indicates there has been previous analysis at a quantitation level of 1.0
mg/L. EGFA does not analyze cadmium in the effluent and does not know what the quantitation
statement is based on. EGFA respectfully requests that cadmium monitoring be eliminated from
the permit as the parameter is not believed to be present.
4. Dissolved Oxygen (DO) monitoring is listed as composite sampling. According to approved
procedures for DO monitoring at
Approved Procedure for the Analysis of Dissolved Oxygen FINAL 04 07 2020.pdf(nc.gov),
the hold time for DO samples is 15 minutes,thereby precluding composite sampling.
5. The footnotes in the table in Part I.A on page 3 indicate that cadmium and copper sampling
should be completed concurrently with hardness sampling. However,the same footnote (4) is
used in reference to chronic toxicity sampling. It appears the footnote for chronic toxicity
sampling should be (5).
6. The cover letter refers to changes in the Chronic Toxicity wording, but no wording changes were
identified in the draft permit. Are changes proposed or will the wording in the draft permit be
used when the permit is issued?
Again,thank you for t is opportunity to comment. If you have any questions abot t these comments or
need additional information, please contact me at 704.434.2261 x22007 or [e-mail].
jdes: R : `
Steinert, Environmental Manager