NC0006351_Fact Sheet_20240531

Fact Sheet
NPDES Permit No. NC0006351
Permit Writer/Email Contact Ori Tuvia, [e-mail]:
Date: March 12, 2024,
Division/Branch: NC Division of Water Resources/NPDES Complex Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
❑x Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee
• For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2nd species WET
tests.
• For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based on
industry category.
Complete applicable sections below. If not applicable, enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
Venator Chemicals, LLC/ Venator Chemicals, LLC - Harrisburg Plant
Applicant Address:
P.O. Box 1330, Harrisburg, NC 28075
Facility Address:
5910 Pharr Mill Road
Permitted Flow:
0.025 MGD
Facility Type/Waste:
MAJOR Industrial; 100% industrial
Facility Class:
Grade II Physical/Chemical Water Pollution Control System (PCWPCS)
Treatment Units:
Alkali feed system, solids mixing tank, three (3) reaction tanks for pH adjustment,
two -acre unlined storage lagoon, flow measurement and'/2-acre lined storage lagoon,
2 filter trains, each with 2 filters and flow measurement with a V-notch weir.
Pretreatment Program
(Y/N)
N
County:
Cabarrus
Region
Mooresville
Briefly describe the proposed permitting action and facility background:
The following permitting actions are proposed:
1. Upstream and effluent hardness data quarterly monitoring sampling requirements were added.
2. Increased Effluent BOD and TSS monitoring sampling requirements from monthly to weekly were
added.
3. Schedule of compliance for storage lagoon lining and reconfiguration is added.
Page 1 of 12

4. Selenium monthly average loading limit as calculated in RPA more stringent than BPJ limit changed
to 0.108 lb/day.
5. Copper limit have been updated based on Copper Nitrate production rate under 40 CFR 415 Subpart
AJ. The calculated limits were daily max of 0.11 lbs/day and monthly average of 0.035 lbs./day.
6. Quarterly sampling for toxicity months has been changed to correspond with production of Copper
Nitrate.
7. Annual PFAS sampling was added to the permit
Background information:
Venator Chemicals, LLC has applied for an NPDES permit renewal at 0.025 MGD for its Harrisburg, NC
Plant. The facility has a primary Outfall 001. The DWM incident number for this facility is NCD048467427-
R2. The DEMLR Stormwater permit for this facility is NCS000057. Venator Chemicals, LLC is a
manufacturer of chemicals including pesticides and inorganics which are supplied to wood preserving,
agricultural, and industrial facilities. Products produced at this facility include alkaline copper quat (ACQ),
chromated copper arsenate (CCA), arsenic acid, and other copper -based pesticides. Inorganics produced at
the facility include binary salts of aluminum, copper, magnesium, manganese, calcium, sodium and zinc
(chlorides and nitrates). The facility also manufactures organic -based pesticides, including Ecolife2.
Venator Chemicals, LLC manufactures the following inorganic chemicals:
Lithium Nitrate
Magnesium Acetate
Aluminum Nitrate
Calcium Nitrate
Calcium Nitrite
Copper Nitrate*
Lithium Acetate
Magnesium Chloride
Magnesium Nitrate
Manganese Nitrate
Sodium Nitrate
Zinc Acetate
Zinc Ammonium Carbonate ZAM
Zinc Chloride**
Zinc Nitrate
*Copper nitrate production is the only Copper chemical present at Venator that is expressly covered
by the 40 CFR 415 language. 40 CFR 415 Subpart AJ provides allocations for TSS, Copper, Nickel,
Selenium, and pH. Copper limits were calculated using the production rate of Copper Nitrate,
however, many other species of chemicals are produced on -site, making limit determination for
TSS, Nickel and Selenium complicated as it not reprehensive to only use only the production rate of
Copper Nitrate as a limit basis.
** Zinc Chloride is not produced in the facility however, it is shipped to the facility in totes and is
distributed to regional customers. residues or spills could be flushed to the waste treatment unite.
Zinc chloride is the only Zinc chemical present at Venator that is expressly covered by the 40 CFR
415 language. 40 CFR 415 Subpart BO provides allocations for TSS, zinc, arsenic, lead and pH.
However, many other species of zinc and arsenic are produced on -site, making limit determination
complicated.
Page 2 of 12

In addition Venator Chemicals LLC manufactures the following pesticides and wood preservatives.
Pesticide production wastewaters that at this time are not discharging to nor managed by the WWT
system. These pestcies are contained and are either reused as is back in the process or disposed of
off site. Venator Chemicals, LLC began manufacturing Ecolife 2, an organic -based wood
preservative, in 2010; wastewater from this process is segregated and disposed off -site as non-
hazardous waste
Alkaline Copper Quat (AC , CMCS, CAB
Copper Ammonium Carbonate ACQ-C 1
Arsenic Acid
Borated Diammonium Phosphate DBlaze
Copper Ammonium Acetate CCN
Copper Chromated Arsenate CCA
Ecolife2
Ultrawood (Paraffin Wax and Surfactants)
Although 40 CFR 415 applies to the manufacture of inorganic chemicals, the subparts do not
adequately characterize the process used by Venator Chemicals, LLC.
2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Outfall 001 — Rocky River
Stream Segment:
13-17a
Stream Classification:
C
Drainage Area (mi2):
136
Summer 7Q 10 (cfs)
4
Winter 7Q 10 (cfs):
13
30Q2 (cfs):
Average Flow (cfs):
105
IWC (% effluent):
0.96
303(d) listed/parameter:
Listed/Benthos
Subject to TMDL/parameter:
No
Basin/Subbasin/HUC:
Yadkin -Pee Dee River; 03-07-11; 0304010501
USGS Topo Quad:
F16SE & F16SW
Page 3 of 12

3. Effluent Data Summary
Effluent data for Outfall 001 is summarized below for the period of October 2018 through September 2023.
Table 1. Effluent Data Summary Outfall 001
Parameter
Units
Average
Max
Min
Permit Limit
Flow
MGD
0.019
0.025
0.0003
MA 0.025
BOD
mg/l
12.68
42.72
ND
MA 2.0
TSS
lb/d
0.047
0.184
ND
DM 3.0
MA 2.0
NH3-N
lb/d
0.175
0.621
ND
DM 3.0
MA 0.208
Arsenic
lb/d
ND
ND
ND
DM 0.416
MA 0.104
Total Chromium
lb/d
0.002
0.010
ND
DM 0.200
MA 0.06
Total Copper
lb/d
0.0018
0.0095
ND
DM 0.12
MA 0.208
Total Selenium
lb/d
ND
ND
ND
DM 0.416
MA 0.313
Total Zinc
lb/d
0.0186
0.0249
ND
DM 0.626
MA 0.01
Total Lead
lb/d
ND
ND
ND
DM 0.037
Total Nickel
Ug/L
ND
ND
ND
pH
SM.
7.8
8.7
6.7
6.0 < pH < 9.0
MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA=Daily Average, ND = None Detected (reported as 0)
4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions when
model results for instream DO are within 1 mg/1 of instream standard at full permitted flow; 2) to verify
model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other instream
concerns. Instream monitoring may be conducted by the Permittee, and there are also Monitoring Coalitions
established in several basins that conduct instream sampling for the Permittee (in which case instream
monitoring is waived in the permit as long as coalition membership is maintained).
• If applicable, summarize any instream data and what instream monitoring will be proposed
for this permit action: facility had no instream data sampling requirement in the previous permit.
Upstream hardness data quarterly monitoring sampling requirements were added. The Division has
adopted new dissolved metal standards for the state, and the NPDES branch is required to implement
the standards in all permits advertised for public review after April 6, 2016.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): NO
Name of Monitoring Coalition: NA
Page 4 of 12

5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): The facility reported no limit
violations from October 2018 through September 2023.
Summarize the compliance record with aquatic toxicity test limits and any second species test results (past 5
years): The facility has been complaint in the past 5 years
Summarize the results from the most recent compliance inspection: The last facility inspection conducted in
July 2022, reported that the facility was in compliance, however, compliance inspection conducted on June
2020 indicated the facility was out of compliance with properly operating and maintaining solids in the
lagoon. The solids build up on the lagoon has not been resolved since
The facility's 2-acre lagoon is unlined and filled with sludge. Venator Chemicals is currently working with
DWM to develop a plan for sludge characterization and management. Venator Chemicals, LLC has met with
DWR and DWM to discuss how Venator is addressing their lagoon, with updates on August 19, 2020,
December 17, 2020, June 16, 2021, March 30, 2023, July 27, 2023 and November 30, 2023. Venator has
informed the Division that they will be constructing an on -site landfill to manage solids from their process.
Wastewaters will enter a settling lagoon forebay to remove solids. The balance of the liquid will then enter
the main area of the lagoon. Venator will be extracting the existing solids that fill their lagoon and placing it
in their on -site landfill. It is anticipated that the forebay will be cleaned every 5 years and the main lagoon
every 15 years based on current rates of solids generation. Prior to wastewater being directed back into the
lagoon, the lagoon will be lined to prevent groundwater contamination. The landfill permit application was
submitted to DWM's Solid Waste Section in November of 2023.
6. Schedule of Compliance
Schedule of compliance for corrective action for the reconfiguration of the lagoon is being added to the
permit.
1. Within one year from the effective date of the permit the Permittee shall submit to the Division
of Water Resources and appropriate divisions Corrective Action Plan summarizing the actions
or strategy to be taken to achieve compliance;1) appropriate closure of the existing lagoon, 2)
lining (and possible relocation) of the storage lagoon and place back onto service, in such way
the facility will be able to achieve compliance with proper operation and maintenance.
2. Once the corrective action plan is approved by the appropriate divisions. Implement the
Corrective Action Plan based on the schedule noted on the plan (when completed) and shall be
completed within the Permit Term (5-year).
3. The Division of Water Resources and appropriate divisions will receive annual updates at the
end of each calendar year on the progression of the Corrective Action Plan progress.
4. Final compliance (completion of the lagoon corrective action) will be required prior to, or by
the expiration of the permit (5-years max.).
7. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
Page 5 of 12

In accordance with 15A NCAC 213.0206, the following streamflows are used for dilution considerations for
development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 streamflow (chronic Aquatic Life;
non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): N/A
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B. 0204(b): N/A
Oxvizen-Consumine Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD= 30 mg/1 for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
Ifpermit limits are more stringent than TBELs, describe how limits were developed: N/A
Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of 1.0
mg/1(summer) and 1.8 mg/1(winter). Acute ammonia limits are derived from chronic criteria, utilizing a
multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection of
aquatic life (17 ug/1) and capped at 28 ug/1(acute impacts). Due to analytical issues, all TRC values reported
below 50 ug/1 are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: Total Residual
Chlorine is not limited in the permit. No changes are proposed for TRC.
Ammonia limits have been carried over since before 1998 and are considered to be based on Best
Professional Judgement (BPJ). Calculating allocations based on 40 CFR 415 proved complicated because of
the wide variety of chemicals produced which are not regulated. Ammonia was reviewed in the attached
wasteload allocation (WLA). As the facility has year-round ammonia limits, the more conservative summer
limit calculated in the WLA was compared to the current permit limits and was found to be less stringent. No
changes are proposed for ammonia.
Reasonable Potential Analysis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of/z detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 213.0206. Effective April 6, 2016, NC began implementation of dissolved
metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of Instream
Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between March 2014 and
March 2018. Pollutants of concern included toxicants with positive detections and associated water quality
standards/criteria. Based on this analysis, the following permitting actions are proposed for this permit:
Page 6 of 12

• Effluent Limit with Monitoring. The following parameters will receive a water quality -based
effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable water
quality standards/criteria: NA
• Monitoring. Only. nly. The following parameters will receive a monitor -only requirement since they did
not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but the
maximum predicted concentration was >50% of the allowable concentration: NA
• No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since they
did not demonstrate reasonable potential to exceed applicable water quality standards/criteria and
the maximum predicted concentration was <50% of the allowable concentration: NA
• POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for
additional pollutants of concern.
o The following parameter(s) will receive a water quality -based effluent limit (WQBEL) with
monitoring, since as part of a limited data set, two samples exceeded the allowable discharge
concentration: NA
o The following parameter(s) will receive a monitor -only requirement, since as part of a
limited data set, one sample exceeded the allowable discharge concentration: NA
If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals
Implementation Fact Sheet for freshwater/saltwater to this Fact Sheet. Include a printout of the RPA
Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program.
Toxicitv Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several exceptions.
The State has received prior EPA approval to use an Alternative WET Test Procedure in NPDES permits,
using single concentration screening tests, with multiple dilution follow-up upon a test failure.
Describe proposed toxicity test requirement: This is a Major Industrial facility, and a chronic WET limit at
0.96% effluent will continue on a quarterly frequency, however, will be conducted on days corresponding to
the production of Copper Nitrate.
Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply with
EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will receive
an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a pollutant
of concern. Effluent limits may also be added if annual average effluent concentrations exceed the WQBEL
value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL value of 47 ng/l.
Describe proposed permit actions based on mercury evaluation: The facility is not known to discharge
mercury.
Other TMDL/Nutrient Management Strategy Considerations
Page 7 of 12

If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation within
this permit: N/A
Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: NA
If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with 15A
NCAC 2H. 0107(c) (2) (B), 40CFR 122. 47, and EPA May 2007 Memo: NA
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B.0226 for this permit renewal: NA
8. Technology -Based Effluent Limitations (TBELs)
Industrials
Describe what this facility produces: The facility is a manufacturer of chemicals including pesticides and
inorganics.
List the federal effluent limitations guideline (ELG) for this facility: The facility is subject to 40 CFR 415
Subparts AJ and BO.
If the ELG is based on production or flow, document how the average productionfflow value was calculated:
40 CFR 415 AJ copper limit were calculated based on production rate for the past 5 years
2019
372810 lbs./year
2020
152987 lbs./year
2021
177434 I bs./yea r
2022
114954 lbs./year
2023
242602 I bs./yea r
average
212157.4 lbs./year
The facility indicated that the production is done in batches, and each batch takes a day and produce 40,000
lbs. Based on the production average of 212157.4, would be 5.3 days of production a year, which would be
rounded up to 6 days, and give a daily production average of 35,360 lbs./day.
Calculations were made for lead limits during the 1998 permit renewal in a technical support document in
accordance with 40 CFR 415 Subpart BO based on best available technology (BAT). The calculations
yielded limitations of 0.01 lb/day and 0.37 lb/day for monthly average and daily maximum, respectively.
These limits are based solely on process wasteflow and the federally listed concentration.
For ELG limits, document the calculations used to develop TBEL limits:
Copper daily maximum were calculated using daily production average * 0.003 (40 CFR 415 AJ) = 0.1061
which rounded up to 0.11 lbs/day.
Maximum daily copper limits were previously permitted based on Best Professional Judgment (BPJ) at 0.12
lbs./day. The ELG limit is more stringent therefore it was adapted.
Page 8 of 12

Copper monthly average were calculated using daily production average * 0.001 (40 CFR 415 AJ) = 0.0354
which rounded down to 0.035 lbs/day.
Monthly average copper limits were previously permitted based on Best Professional Judgment (BPJ) at
0.06lbs./day. The ELG limit is more stringent therefore it was adapted.
Consistent with § 122.45(b)(2)(ii)(A)(i), and EPA guidance, 20 percent fluctuation in production is
considered to be within the range of normal variability, while changes in production higher than 20 percent
could warrant consideration tiered or revised effluent limitations.
If any limits are based on best professional judgement (BPJ), describe development: As federal guidelines
did not cover the full suite of compounds manufactured at the facility, limits for total suspended solids
(TSS), ammonia, arsenic, chromium, selenium, and zinc were developed by the division in 1985 based on
BPJ. In a 1998 technical support document, the limits were checked against 40 CFR 415 guidance where
applicable and were found to be more stringent than the calculations based on federal guidelines.
Document any TBELs that are more stringent than WQBELs: NA
Document any TBELs that are less stringent than previous permit: NA
9. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation review
in accordance with 15A NCAC 2B.0201. Each applicant for a new/expanding NPDES permit must
document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105( c)(2). In all cases,
existing instream water uses and the level of water quality necessary to protect the existing use is maintained
and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results: NA
10. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): NO
If YES, confirm that antibacksliding provisions are not violated: NA
11. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following regulations
and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 213.0500; 2) NPDES
Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance, Reduced
Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best Professional
Page 9of12

Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not considered
effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -backsliding prohibitions
would not be triggered by reductions in monitoring frequencies.
For instream monitoring, refer to Section 4.
Currently, monthly monitoring for BOD5 and TSS is required in the permit. The Permittee noted two SIC
codes on their 2018 renewal application: 2819 and 2879. 15A NCAC 2B .0508 requires Class II facilities
with SIC codes ranging from 2800 to 2899 to monitor for BOD5 and TSS at weekly frequencies. As such, the
monitoring frequencies of BOD5 and TSS have been changed from monthly to weekly.
Based on Comments received during public notice, and as the facility has identified Inorganic
Chemical manufacture which is category adjacent to an Organic Chemicals manufacture category
that is on the EPA list for PFAS compounds. Effluent PFAS monitoring has been added to the
permit at an annual frequency. EPA Method 1633 was finalized on January 31, 2024. However, the
methodology has yet to be published in the Federal Register. Sampling using the method shall take
effect the first full calendar quarter following 6 months after the effective date of the permit to
provide the Permittee time to select a laboratory, develop a contract, and begin collecting samples.
Effective 6 months after EPA has the method in 40 CFR 136 published in the Federal Register, the
Permittee shall conduct influent and effluent monitoring using the approved Method 1633.
12. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective December
21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports (DMRs)
electronically. Effective December 21, 2020, NPDES regulated facilities will be required to submit
additional NPDES reports electronically. This permit contains the requirements for electronic reporting,
consistent with Federal requirements.
Page 10 of 12

13.Summary of Proposed Permitting Actions:
Table 2. Current Permit Conditions and Proposed Changes 0.025 MGD
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
MA 0.025 MGD
No change
15A NCAC 213.0505
BOD5
Monthly monitoring
Weekly monitoring
15A NCAC 2B .0505 — Surface Water
Monitoring: Reporting — Minimum
Requirements for SIC 2800-2899
TSS
MA 2.0 lbs/d
Weekly monitoring
BPJ; more stringent than 40 CFR 415
DM 3.0 lbs/d
calculations. Antibacksliding. 15A NCAC
Monthly monitoring
213 .0505 — Surface Water Monitoring:
Reporting — Minimum Requirements for
SIC 2800-2899
NH3-N
MA 2.0 lbs/d
No change
BPJ; more stringent than 40 CFR 415
DM 3.0 lbs/d
calculations. Antibacksliding.
Arsenic
MA 0.2081bs/d
No change
BPJ; more stringent than 40 CFR 415
DM 0.416 lbs/d
calculations. Antibacksliding.
Total Chromium
MA 0.1041bs/d
No change
BPJ; more stringent than 40 CFR 415
DM 0.2001bs/d
calculations. Antibacksliding.
Total Copper
MA 0.061bs/d
MA 0.035 lbs/d
40 CFR 415 AJ calculations.
DM 0.121bs/d
DM 0.11 lbs/d
Total Selenium
MA 0.208 lbs/d
MA 0.108 lb/d
Acute value BPJ; more stringent than 40
DM 0.416 lbs/d
CFR 415 calculations. Antibacksliding.
Chronic value WQBEL. Allowable
Discharge Concentration as calculated in
RPA more stringent than BPJ limit
Total Zinc
MA 0.313 lbs/d
No change
BPJ; more stringent than 40 CFR 415
DM 0.6261bs/d
calculations. Antibacksliding.
Total Lead
MA 0.01 lbs/d
No change
40 CFR 415 Subpart BO; based on process
DM 0.0371bs/d
flow and federally listed concentrations
Total Nickel
Monitor 2/Month
No change
pH
Between 6.0 and 9.0 s.u.
No change
Toxicity Test
Chronic limit, 0.96%
Sampling shall be
WQBEL. No toxics in toxic amounts. 15A
effluent
done to correspond
NCAC 213.0200 and 15A NCAC 213.0500
with days Carbon
Nitrate is produced.
PFAS
No requirement
Annual effluent
Ensure no PFAS in the effluent,
sampling
Total Hardness
No requirement
Quarterly effluent
Required to assess dissolved metal
and upstream
limitations for water quality standards
monitoring
based on the 2016 dissolved metal
standards
Electronic
No requirement
Add Electronic
In accordance with EPA Electronic
Reporting
Reporting Special
Reporting Rule 2015.
Condition
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
Page 11 of 12

14. Public Notice Schedule:
Permit to Public Notice: 1/7/2024
Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the Director
within the 30 days comment period indicating the interest of the party filing such request and the reasons
why a hearing is warranted.
15. NPDES Division Contact:
If you have questions regarding any of the above information or on the attached permit, please contact Ori
Tuvia [phone] [e-mail]
16. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): Yes
If Yes, list changes and their basis below:
Annual effluent PFAS sampling was added based on comments during public comments, Effluent daily
maximum and monthly average for Copper were revised based on ELG 415 AJ calculation due to additional
information from the facility that they are producing Copper Nitrate, and toxicity sampling months were
revised to correspond to production days.
Based on these substantial changes, the revised draft permit has been submitted for a second public notice,
which was published on April/15/2024. The draft was submitted to Venator Chemicals, EPA Region IV, and
the Division's Mooresville Regional Office, Aquatic Toxicology Branch, and to Southern Environmental
Law Center (SELC). Comments were received from the Southern Environmental Law Center (SELC) on
April 11, 2024. In their comments, SELC noted the revisions made to the draft permit based on their
previous comment set, but reiterated their request that Venator's permit reflect that any HAS discharges
would violate the permit and the Clean Water Act. The division add included monitoring for PFAS in the
Permit and reserve the write to re -open the permit if it is determined that PFAS is present in the discharge.
17. Fact Sheet Attachments (if applicable):
RPA Spreadsheet Summary
Affidavit of public notice
Page 12 of 12

(Dhidepwdent Trlbxm+e
See Proof on Next Page
AFFIDAVIT OF PUBLICATION
Concord Independent Tribune
PO Box 968
[phone]
State of Texas. County of Bexar, ss:
Before the undersigned, a Notary Public duly commissioned,
qualified, and authorized by law to administer oaths, personally
appeared the Publisher's Representative, Yuade Moore, who by
being duly sworn deposes and says:, that he/she is authorized to
make this affidavit and sworn statement', that the notice or other
legal advertisement, a copy of which is attached hereto, was
published in the Concord Independent Tribune and that the said
newspaper in which such notice, paper document, or legal
advertisement was published, was at the time of each and every
such publication, a newspaper meeting all the requirements and
qualifications of Section 1-597 of the General Statutes of North
Carolina.
PUBLICATION DATES:
Apr. 12, 2024
NOTICE ID: KeWAabapvdTb5lbFwnhS
PUBLISHER ID: COL-NC-400233
NOTICE NAME: NC0006351
Publication Fee: $139.22
.,�'00, Y
`�.4'OV 1 ,b( Robert Hollle III
VERIFICATION
': r w �' _____
State of Texas
_ t w , N = 10 NUMB! W
M;. + 33567194
County of Bexar
f 0, COMMISSION EXPIQES
",4�01"', FMruay 10, 2026
Subscribed in my presence and sworn to before me on this: 04/12/2024
Notary Public
Electronically signed and notarized online using the Proof platform.
NC0006351 - Page 1 of 2

Notice of Intent to Issue a NPDES
Wastewater Permit NC0006351 Venator
Chemicals, LLC
Public Notice
North Carolina Environmental Management Commission/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
The North Carolina Environmental Management Commission proposes
to issue a NPDES wastewater discharge permit to the person(s) listed
below. Written comments regarding the proposed permit will be accept-
ed until 30 days after the publish date of this notice. The Director of
the NC Division of Water Resources fDWR) may hold a public hearing
should there be a significant degree of public Interest. Please mail com-
ments and/or information requests to DWR at the above address. In-
terested persons may visit the DWR at 512 N. Salisbury Street, Raleigh,
NC 27604 to review the Information on file. Additional information on
NPDES permits and this notice may be found on our website: https://
deq.nc.gov/public-notices-hearings,or by calling [phone], The
Venator Chemicals, LLC 15910 Phan Mill Rd, Harrisburg, NC 280751,
has requested renewal of NPDES permit NCO006351, for its Wastewater
Treatment Plant, located in Cabarrus County. This permitted facility dis-
charges treated industrial wastewater to the Rocky River which is clas-
sified C waters in sub -basin 03-07-1 1 of the Yadkin -Pee Dee River Basin.
Some of the parameters in the permit are water quality limited.
Publication Dates: April 12, 2024. COL-NC-400233
NC0006351 - Page 2 of 2

ATTACHMENT 1

SOUTHERN 601 West Rosemary Street, Suite 220 Telephone [phone]
ENVIRONMENTAL Chapel Hill, NC 27516 Facsimile 919-929-9421
LAW
CENTER
February 2, 2024
VIA Electronic Mail
Ori Tuvia
N.C. Department of Environmental Quality
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
[e-mail]
Re: Southern Environmental Law Center Comments Regarding NPDES Permit
No. NC0006351, Venator Chemicals, LLC
Dear Ori Tuvia:
The Southern Environmental Law Center offers the following comments regarding the
draft renewal National Pollutant Discharge Elimination System ("NPDES") Permit NC0006351,
issued by the North Carolina Department of Environmental Quality ("the Department") to
Venator Chemicals, located in Harrisburg, Cabarrus County, North Carolina.' The draft permit
allows Venator Chemicals to discharge wastewater likely contaminated with toxic per- and
polyfluoroalkyl substances ("PFAS") into the Rocky River.
The U.S. Environmental Protection Agency ("EPA") has made clear that state permitting
agencies have "existing authorit[y]" to control PFAS through NPDES permits and should be
doing so "to the fullest extent available under state and local law."2 In 2022, the Department
followed the law embodied in EPA's guidance when it issued a NPDES permit to The Chemours
Company, FC ("Chemours") that imposed technology -based limits for certain PFAS.3 But, as
evidenced by this permit, the Department continues to treat other sources of toxic PFAS
pollution with leniency. Venator Chemicals is permitted to discharge a monthly average flow of
0.025 million gallons of wastewater per day. At this flow, treatment technology for PFAS would
be both affordable and effective at nearly eliminating the toxic pollution in the wastewater. The
Department must use its existing authority to control Venator Chemicals' pollution with this
renewal permit by requiring comprehensive disclosure and evaluating technology -based (and, if
necessary, water quality -based) limits. Failure to do so violates the law and prolongs North
Carolinians' exposure to toxic chemical pollution.
1 N.C. Dep't of Env't Quality, Draft NPDES Permit NC0006351 (Jan. 3, 2024) [hereinafter "Venator Chemicals
Draft Permit"].
2 Memorandum from Radhika Fox, Assistant Administrator, U.S. Env't Prot. Agency, Addressing PFAS Discharges
in NPDES Permits and Through the Pretreatment Program and Monitoring Programs (December 5, 2022)
(emphasis added) [hereinafter "EPA's PFAS NPDES Guidance"], Attachment 1.
3 N.C. Dep't of Env't Quality, NPDES Permit NCO090042 (Sept. 15, 2022), htt2s://nerma.cc/WQV7-L8C4; N.C.
Dep't of Env't Quality, Fact Sheet NPDES Permit No. NCO090042 (Sept. 15, 2022), at 11-12,
https://perma.cc/EP5R-32A7.
Charlottesville Chapel Hill Atlanta Asheville Birmingham Charleston Nashville Richmond Washington, DC

I. Venator Chemicals likely discharges PFAS, a class of chemicals known to cause
harm to human health and the environment.
As the Department is aware, PFAS are a group of man-made chemicals manufactured and
used broadly by industry since the 1940s.4 Seemingly every day, new data confirms that PFAS
pose a significant threat to human health at extremely low concentrations. Two of the most
studied PFASperfluorooctanoic acid ("PFOA") and perfluorooctane sulfonate ("PFOS")—are
bioaccumulative and highly persistent in humans.5 These chemicals build up in the human body,
and have been shown to cause developmental effects to fetuses and infants, kidney and testicular
cancer, liver malfunction, hypothyroidism, high cholesterol, ulcerative colitis, obesity, decreased
immune response to vaccines, reduced hormone levels, delayed puberty, and lower birth weight
and size.6 Recent literature also confirms PFAS exposure can result in decreased fertility in
women.' And because of their impacts on the immune system, PFAS can also exacerbate the
effects of Covid-19.8 Studies show that exposure to mixtures of different PFAS can worsen these
health effects.' Given these harms, EPA in June 2022 established interim updated lifetime health
advisories for PFOA and PFOS in drinking water of 0.004 parts per trillion ("ppt") and 0.02 ppt,
respectively.lo The health advisories demonstrate that no level of exposure is safe.
Building upon its understanding of the harms caused by PFAS, on March 14, 2023, EPA
proposed national drinking water standards for six PFAS compounds." The drinking water
standards, expected to be published in Spring of 2024, will provide enforceable limits on the
concentration of PFAS that can be present in drinking water systems. As drafted, EPA proposes
to limit concentrations of PFOA and PFOS in drinking water systems to below 4 ppt, with a
public health goal of 0 ppt.12 EPA also proposed to limit perfluorononanoic acid ("PFNA"),
perfluorobutanesulfonic acid ("PFBS"), perfluorohexane sulfonic acid ("PFHxS"), and
hexafluoropropylene oxide dimer acid ("GenX") as a mixture, utilizing a formula called a hazard
4 Lifetime Drinking Water Health Advisories for Four Perfluoroalkyl Substances, 87 Fed. Reg. 36,848, 36,849 (June
21, 2022); Our Current Understanding of the Human Health and Environmental Risks of PFAS, U.S. ENVT PROT.
AGENCY, h11ps://perma.cc/V6PX-2PNK (page saved Mar. 8, 2023).
s 87 Fed. Reg. at 36,849; U.S. Env't Prot. Agency, Interim Drinking Water Health Advisory: Perfluorooctanoic Acid
(PFOA) CASRN 335-67-1 (June 2022), at 3-4, hgps://perma.cc/F89R-PJUV; U.S. Env't Prot. Agency, Interim
Drinking Water Health Advisory: Perfluorooctane Sulfonic Acid (PFOS) CASRN 1763-23-1 (June 2022), at 3-4,
h1t 2s://perma.cc/TQM6-57PZ.
6 Arlene Blum et al., The Madrid Statement on Poly- and Perfluoroalkyl Substances (PFASs), 123 ENVT HEALTH
PERsP. 5, A 107 (May 2015); U.S. Env't Prot. Agency, Drinking Water Health Advisories for PFAS: Fact Sheet for
Communities, at 1-2 (June 2022), available at hgps://perma.cc/T7FQ-EKD6.
I Nathan J. Cohen, Exposure to Perfluoroalkyl Substances and Women's Fertility Outcomes in a Singaporean
Population -Based Preconception Cohort, 873 Sci. TOTAL ENVT 162267 (May 15, 2023).
8 See Lauren Brown, Insight: PFAS, Covid-191 and Immune Response —Connecting the Dots, BLOOMBERG LAW (July
13, 2020, 4:00 AM), https://perma.cc/QM9H-7ZT6.
9 Emma V. Preston et al., Prenatal Exposure to Per- and Polyfluoroalkyl Substances and Maternal and Neonatal
Thyroid Function in the Project Viva Cohort: A Mixtures Approach, 139 ENVT INT'L 1 (2020),
h1t2s://perma.cc/DJK3-87SN.
10 87 Fed. Reg. at 36,848-49.
See Proposed PFAS National Primary Drinking Water Regulation, U. S. Env't Prot. Agency (Mar. 14, 2023); see
also 88 Fed. Reg. at 18,639.
12 88 Fed. Reg. at 18,639.
OA

index.13 In light of the proposed drinking water standards, it is clear we must prevent as much of
this pollution from entering our rivers, creeks, and streams as possible.
While the harms to human health are extreme, PFAS are also detrimental to wildlife and
the environment. The chemicals have been shown to cause damaging effects in fish,14
amphibians,15 reptiles,l6 mollusks,' 7 and other aquatic invertebrates 18resulting in
developmental and reproductive impacts, behavioral changes, adverse effects to livers, disruption
to endocrine systems, and weakened immune systems.19
13Id. at 18,639-40.
" Chen et al., Perfluorobutanesulfonate Exposure Causes Durable and Transgenerational Dysbiosis of Gut
Microbiota in Marine Medaka, 5 ENv'T SCI. & TECH LETTERS 731-38 (2018); Chen et al., Accumulation
of Perfluorobutane Su fonate (PFBS) and Impairment of Visual Function in the Eyes of Marine Medaka After
a LifeCycle Exposure, 201 AQUATIC TOXICOLOGY 1-10 (2018); Du et al., Chronic Effects of Water -Borne PFOS
Exposure on Growth, Survival and Hepatotoxicity in Zebrafish: A Partial Life -Cycle Test, 74 CHEMOSPHERE 723-29
(2009); Hagenaars et al., Structure Activity Relationship Assessment of Four Perfluorinated Chemicals Using a
Prolonged Zebrafish Early Life Stage Test, 82 CHEMOSPHERE 764-72 (2011); Huang et al., Toxicity, Uptake
Kinetics and Behavior Assessment in Zebrafish Embryos Following Exposure
to Perfluorooctanesulphonicacid (PFOS), 98 AQUATIC TOXICOLOGY 139-47 (2010); Jantzen et al., PFOS, PFNA,
and PFOA Sub -Lethal Exposure to Embryonic Zebrafish Have Different Toxicity Profiles in terms of
Morphometrics, Behavior and Gene Expression, 175 AQUATIC TOXICOLOGY 160-70 (2016); Liu et al., The Thyroid -
Disrupting Effects of Long -Term Perfluorononanoate Exposure on Zebrafish (Danio rerio),
20 ECOTOXICOLOGY 47-55 (2011); Chen et al., Multigenerational Disruption of the Thyroid Endocrine System in
Marine Medaka after a Life -Cycle Exposure to Perfluorobutanesulfonate, 52 ENv'T SCI. & TECH. 4432-39
(2018); Rotondo et al., Environmental Doses of Perfluorooctanoic Acid Change the Expression of Genes in Target
Tissues of Common Carp, 37 ENV'T TOXICOLOGY & CHEM. 942-48 (2018).
15 Ankley et al., Partial Life -Cycle Toxicity and Bioconcentration Modeling of Perfluorooctanesulfonate in the
Northern Leopard Frog (Rana Pipiens), 23 ENv'T TOXICOLOGY & CHEM. 2745 (2004); Cheng et al., Thyroid
Disruption Effects of Environmental Level Perfluorooctane Sulfonates (PFOS) in Xenopus Laevis,
20 ECOTOXICOLOGY 2069-78 (2011); Lou et al., Effects of Perfluorooctanesulfonate and Perfluorobutanesulfonate
on the Growth and Sexual Development ofXenopus Laevis, 22 ECOTOXICOLOGY 1133-44 (2013).
16 Guillette et al., Blood Concentrations of Per- and Polyfluoroalkyl Substances Are Associated with Autoimmune-
like Effects in American Alligators From Wilmington, North Carolina, FRONTIER TOXICOLOGY 4:1010185 (Oct. 20,
2022).
17 Liu et al., Oxidative Toxicity of Perfluorinated Chemicals in Green Mussel and Bioaccumulation Factor
Dependent Quantitative Structure -Activity Relationship, 33 ENv'T TOXICOLOGY & CHEM. 2323-32 (2014); Liu et
al., Immunotoxicity in Green Mussels under Perfluoroalkyl Substance (PEAS) Exposure: Reversible Response and
Response Model Development, 37 ENv'T TOXICOLOGY & CHEM. 1138-45 (2018).
18 Houde et al., Endocrine -Disruption Potential of Perfluoroethylcyclohexane Sulfonate (PFECHS) in Chronically
Exposed Daphnia Magna, 218 ENv'T POLLUTION 950-56 (2016); Liang et al., Effects of Perfluorooctane Sulfonate
on Immobilization, Heartbeat, Reproductive and Biochemical Performance of Daphnia Magna,
168 CHEMOSPHERE 1613-18 (2017); Ji et al., Oxicity of Perfluorooctane Sulfonic Acid and Perfluorooctanoic Acid
on Freshwater Macroinvertebrates (Daphnia Magna and Moina Macrocopa) and Fish (Oryzias Latipes), 27 ENV'T
TOXICOLOGY & CHEM. 2159 (2008); MacDonald et al., Toxicity of Perfluorooctane Sulfonic Acid and
Perfluorooctanoic Acid to Chironomus Tentans, 23 ENv'T TOXICOLOGY & CHEM. 2116 (2004).
" See supra notes 14-18.

PFAS are extremely resistant to breaking down in the environment.20 Once released, the
chemicals can travel long distances and bio-accumulate in organisms.21 PFAS have been found
in fish tissue across all 48 continental states, 22 and PFOS—a particularly harmful PFAS
compound —is one of the most prominent PFAS found in freshwater fish.23 As a result, the
primarily low-income and minority communities that rely heavily on subsistence fishing have
been found to have elevated PFAS levels in their blood.24 In fact, researchers conclude that
"[w]idespread PFAS contamination of freshwater fish in surface waters in the U.S. is likely a
significant source of exposure to PFOS and potentially other perfluorinated compounds for all
persons who consume freshwater fish, but especially for high frequency freshwater fish
consumers."25 And communities of color and low income are more likely to bear the burden of
PFAS pollution in their rivers, creeks, and streams.26
Last year, North Carolina joined 14 other states in issuing fish consumption advisories for
PFAS "based on concerns about exposure to [PFOS] found in fish sampled" in the middle and
lower Cape Fear River.2' The advisories recommend that women of childbearing age, pregnant
women, nursing mothers, and children do not eat certain fish from that stretch of the river, while
limiting consumption of other fish to "[n]o more than 1 meal per year."28 For all other North
Carolinians, the advisories recommend limiting consumption to one or seven meals per year,
depending on the species.29 These advisories —like EPA's proposed drinking water standards-
21 Carol F. Kwiatkowski, et al., Scientific Basis for Managing PFAS as a Chemical Class, ENV T SCI. & TECH.
LETTERS 8-9 (2020).
21See What are PFAS?, AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY,
hops://www.atsdr.cdc.gov/pfas/health-effects/overview.html (last visited Jan. 25, 2024); see also Our Current
Understanding of the Human Health and Environmental Risks of PFAS, supra note 4.
22 Nadia Barbo, et al., Locally Caught Freshwater Fish Across the United States Are Likely A Significant Source of
Exposure to PFOS and Other Perfluorinated Compounds, 220 ENV'T RES. 115165 3 (2023), available at
h1!ps://perma.cc/SB8F-C3Y6.
23 Id. at 4.
24 Patricia A. Fair et al., Perfluoralkyl Substances (PFASs) in Edible Fish Species from Charleston Harbor and
Tributaries, South Carolina, United States: Exposure and Risk Assessment, 171 ENVT. RES. 266, 273-75 (April
2019), h11ps://perma.cc/7976-XAVU; Chloe Johnson, Industrial chemicals in Charleston Harbor taint fish — and
those who eat them, POST & COURIER (June 4, 2022), h1!ps://perma.cc/Z5TM-MB83.
21 Barbo, supra note 22, at 9.
26 See Jahred M. Liddie et al., Sociodemographic Factors Are Associated with the Abundance of PFAS Sources and
Detection in U.S. Community Water Systems, 57 ENV'T SCI. & TECH. 7902 (2023), ho2s://perma.cc/74YL-5EPM;
Susan Lee, Dirty Water: Toxic `Forever' PFAS Chemicals Are Prevalent in the Drinking Water of Environmental
Justice Communities (Aug. 2021), h1tps://perma.cc/HPM9-ULDX; Genna Reed, PFAS Contamination Is an Equity
Issue, and President Trump's EPA Is Failing to Fix It, Union of Concerned Scientists (Oct. 30, 2019),
https://perma.cc/9JVE-QSQ4;
27 NCDHHS Recommends Limiting Fish Consumption From the Middle and Lower Cape Fear River Due to
Contamination With "Forever Chemicals ", N.C. DEP'T OF HEALTH AND HUMAN SERvs. (July 13, 2023),
hops://www.ncdhhs. gov/news/press-releases/2023/07/ 13 /ncdhhs-recommends-limiting-fi sh-consumption-middle-
and-lower-cape-fear-river-due-contamination [hereinafter "NCDHHS, Fish Consumption Advisories"]; see also
N.C. Dep't of Health & Human Servs., NCDHHS Middle and Lower Cape Fear River PFOS Fish Consumption
Advisories (Aug. 2, 2023), https://www.ncdhhs.gov/news/press-releases/2023/07/13/ncdhhs-recommends-limiting-
fish -consumption -middle -and -lower -cape -fear -river -due -contamination.
28 NCDHHS, Fish Consumption Advisories, supra note 27.
29 Id.
al

drive home the importance of controlling PFAS at the source before the contamination reaches a
vital food and nourishment supply.
EPA has explained that industries that work with industrial inorganic chemicals (SIC
code 2819), like Venator Chemicals, are likely sources of PFAS pollution.30 Because Venator
Chemicals falls into the category of industries known to be associated with PFAS, it is likely that
the company releases the toxic chemicals into the Rocky River.
II. The Department must control Venator Chemicals' PFAS pollution in its renewal
permit.
Venator Chemicals is not authorized to release PFAS into the Rocky River because the
company did not disclose its PFAS discharges in its NPDES permit application, and the
Department did not consider the PFAS pollution when it issued Venator Chemicals its prior
NPDES permit. The Department must take the following actions to address Venator Chemicals'
pollution before issuing a final permit.
a. The Department must require Venator Chemicals to update its permit application to
disclose its PFAS pollution.
The Clean Water Act prohibits the discharge of any pollutant, including PFAS, without a
NPDES permit .31 The discharge of a specific pollutant (or group of pollutants) cannot be
permitted if it is not disclosed in a NPDES permit application. This has been confirmed by the
EPA Environmental Appeals Board's decision in In re: Ketchikan Pulp Company,32 and that
decision has been adopted by the Fourth Circuit.33 In December 2022, EPA confirmed that these
disclosure requirements apply to PFAS stating that "no permit may be issued to the owner or
operator of a facility unless the owner or operator submits a complete permit application"
providing all information "that the permitting authority may reasonably require to assess the
discharges of the facility" including information regarding PFAS.34
Disclosure is considered adequate under the Clean Water Act when the applicant
provides enough information for a permitting agency to "be[] able to judge whether the discharge
of a particular pollutant constitutes a significant threat to the environment."35 To meet this
burden, an applicant must include all relevant information, including the concentration, volume,
31 U.S. Env't Prot. Agency, Metadata for Data Sources Within HAS Analytic Tools (Dec. 2023), at 38,
https:Hecho.epa. gov/system/files/PFAS%2OAnalytic%2OTools%2OMetadata%202023-12-22-508.pdf
" 33 U.S.C. § 1311(a).
32 See In re Ketchikan Pulp Co., 7 E.A.D. 605.
33 Piney Run Pres. Ass'n v. Cnty. Commis of Carroll Cnty., MD, 268 F.3d. 255, 268 (4th Cir. 2001); S. Appalachian
Mountain Stewards v. A&G Coal Corp., 758 F.3d 560, 567 (4th Cir. 2014).
34 EPA's PFAS NPDES Guidance, supra note 2, at 2.
35 Piney Run, 268 F.3d. at 268 ("Because the permitting scheme is dependent on the permitting authority being able
to judge whether the discharge of a particular pollutant constitutes a significant threat to the environment, discharges
not within the reasonable contemplation of the permitting authority during the permit application process, whether
spills or otherwise, do not come within the protection of the permit shield.").
5

and frequency of the discharge.36 The Clean Water Act places the burden of disclosure on the
permit applicant because they are in the best position to know what is in their discharge.37
Importantly, if a NPDES permit applicant does not adequately disclose its release of a
pollutant, the applicant does not have approval to discharge the pollutant.38 The Department
knows this to be true. In its enforcement action against Chemours for the company's discharge of
PFAS into the Cape Fear River, the agency stated:
Part of the permit applicant's burden in this regard is to disclose all relevant
information, such as the presence of known constituents in a discharge that pose a
potential risk to human health. The permit applicant is required to disclose "all
known toxic components that can be reasonably expected to be in the discharge,
including but not limited to those contained in a priority pollutant analysis." 15A
N.C.A.C. 21-1.01050) (emphasis added). [... ] These disclosure obligations are
critical, in part, because they define the scope of the Clean Water Act's "permit
shield." While compliance with the express terms of an NPDES permit generally
"shields" the permittee from liability for violations of 33 U.S.C. § 1311, the
permit does not shield the permittee from liability where the pollutant being
discharged was not within the "reasonable contemplation" of the permitting
agency when it issued the permit due to nondisclosure by the permittee.39
Other states have reached the same conclusion. For instance, Tennessee has issued at
least one permit stating "[t]he permittee has no permit shield for the discharge of PFAS
compounds because no such chemicals were disclosed in the permit application or otherwise. ,40
South Carolina has recently amended its NPDES permit application form to explicitly require
disclosure and sampling of PFAS in both effluent and sludge (the byproduct of treating industrial
and municipal wastewater).41
As mandated by EPA's PFAS NDPES Guidance and Fourth Circuit precedent, the
Department must require Venator Chemicals to disclose its PFAS pollution before it moves
forward with issuing a final NPDES permit. This information must be incorporated into the
36 See In re Ketchikan Pulp Co., 7 E.A.D. 605 (EPA) (1998) ("In explaining the provisions of 40 C.F.R. §
122.53(d)(7)(iii), which required dischargers to submit quantitative data relating to certain conventional and
nonconventional pollutants that dischargers know or have reason to believe are present in their effluent, the [EPA]
stated: `permit writers need to know what pollutants are present in an effluent to determine appropriate limits in the
absence of effluent guidelines."').
37 S. Appalachian Mountain Stewards, 758 F.3d at 566 ("The statute and regulations purposefully place the burden
of disclosure on the permit applicant.").
38 See In re Ketchikan Pulp Co., 7 E.A.D. 605; Piney Run, 268 F.3d. at 268; S. Appalachian Mountain Stewards, 758
F.3d at 567.
39 Amended Complaint, N.C. Dept. of Environmental Quality v. Chemours, 17 CVS 580, 6-7 (N.C. Super. 2018)
(citing 33 U.S.C. § 1342(k); Piney Run, 268 F.3d at 265), hgps://perma.cc/ZT3U-7QJB.
" TDEC, NPDES Permit NO. TN0002330 (2020), Holliston Holdings, LLC, Addendum to Rationale,
hjt2s://penna.cc/4RKY-PKFG.
41 See Sammy Fretwell, Polluted Fish, Tainted Rivers and Contaminated Drinking Water Prompt State Action in SC,
THE STATE (Dec. 12, 2023), htt2s://www.thestate.com/article282952203.html; S.C. Dep't of Health & Env't
Control, Wastewater Application NPDES Industrial — New (2023), at 10-12; S.C. Dep't of Health & Env't Control,
Wastewater Application NPDES Domestic/Municipal — New (2023), at 22-23.
on

permit application itself because the public relies on the information submitted in the publicly
available application to participate in the permitting process.42
b. The Department must impose effluent limits to control Venator Chemicals' PFAS
pollution.
EPA's PFAS NPDES Guidance instructs state agencies on how to address PFAS through
existing NPDES authorities.43 Federal and state law, as well as EPA's guidance make clear that
the Department must analyze effluent limits to control Venator Chemicals' likely PFAS
pollution. Indeed, and as discussed throughout this letter, the Department has already controlled
PFAS in Chemours' NPDES permit, displaying the agency's understanding of its responsibilities
under the Clean Water Act and signaling that the agency has the tools, authority, and knowledge
of how to handle PFAS discharges through the NPDES permitting scheme. Venator Chemicals
should be treated no differently.
The Clean Water Act requires permitting agencies to, at the very least, incorporate
technology -based effluent limitations on the discharge of pollutants.44 When EPA has not issued
a national effluent limitation guideline for a particular industry,45 permitting agencies must
implement technology -based effluent limits on a case -by -case basis using their "best professional
judgment. ,46 EPA has confirmed that technology -based limits are the "minimum level of control
that must be imposed in NPDES permits" and that they should be calculated for PFAS.47
Effective treatment technologies for PFAS are available. Granular activated carbon is a
cost-effective and efficient technology that can reduce PFAS concentrations to virtually
nondetectable levels. A granular activated carbon treatment system at the Chemours' facility, for
example, has reduced PFAS concentrations as high as 345,000 ppt from a creek contaminated by
groundwater beneath the facility to nearly nondetectable concentrations.48 Similarly, a reverse
osmosis treatment unit at Chemours, coupled with granulated activated carbon and ion exchange,
was also shown in pilot testing to reduce individual PFAS concentrations as high as 10,510,000
ppt and 5,886,000 ppt to at most 35 ppt, and mostly nondetectable levels.49 Other treatment
technologies are effective for certain PFAS waste streams and are increasingly available.
Supercritical water oxidation, for example, is effective at destroying PFAS by transforming the
substance containing the toxic chemicals (whether it be liquid, sludge, or solid material) into
41 See 15A N.C. Admin. Code 211.0109, 2H.0115.
43 EPA's PFAS NPDES Guidance, supra note 2.
44 40 C.F.R. § 125.3(a) ("Technology -based treatment requirements under section 301(b) of the Act represent the
minimum level of control that must be imposed in a permit..." (emphasis added)); see also 33 U.S.C. § 1311; see
also EPA's PFAS NPDES Guidance, supra note 2, at 2.
45 33 U.S.C. § 1314(b).
46 40 C.F.R. § 125.3; see also 33 U.S.C. § 1342(a)(1)(B); 15A N.C. Admin. Code 2B.0406.
41 EPA's PFAS NPDES Guidance, supra note 2, at 3.
46 See Parsons, Engineering Report — Old Outfall 002 GAC Pilot Study Results (Sept. 2019), available at
https://www.chemours.com/j a/-/media/files/corporate/12e-old-outfal1-2-gac-pilot-report-2019-09-
30.pdf?rev=6e1242091aa846f888afa895eff80e2e&hash=040CAA7522E3D64B9E5445ED6F96BOFB; see also
Chemours Outfall 003, NPDES No. NC0089915 Discharge Monitoring Reports (2020-2022), available at
h1�2s://perma.cc/8YND-XT5M.
49 Chemours Co., Attachment J.2 to NPDES Permit No. NC0003573, Reverse Osmosis Engineering Report and
Data Analysis, 4-6 (Nov. 2020), hltps://perma.cc/EW2Y-ARGL.
7

water, oxygen, and inorganic matter.50 Supercritical water oxidation has been demonstrated to
remove 99.99 percent of PFAS in the materials put into the treatment technology.51 The
Department must consider the feasibility of using these or similar technologies to control
Venator Chemicals' PFAS pollution.
Notably, the Department does not have to shoulder the entire responsibility of analyzing
the effectiveness of all treatment options. Much of the information needed to evaluate
technology -based limits can be provided by permittees, and North Carolina law gives the
Department clear authority to demand this information during the permitting process.52 The
Department has required Chemours to analyze different treatment technology options, and
should do the same with other industries across the state.
If technology -based limits are not enough to ensure compliance with water quality
standards, the Department must include water quality -based effluent limits in the permit.53 If the
Department finds there is a "reasonable potential" that water quality standards will be exceeded,
it must include water quality -based effluent limits in the permit.54 This obligation "may not be
waived," and requires the agency to incorporate a permit limit protective of water quality
standards regardless of "treatability" or analytical method detection levels." Additionally,
monitoring or data collection requirements "may not be substituted" for permit limits.56
North Carolina's toxic substances standard protects the public from the harmful effects of
toxic chemicals, like PFAS.57 For instance, the toxic substances standard mandates that the
concentration of cancer -causing chemicals shall not result in "unacceptable health risks," defined
as "more than one case of cancer per one million people exposed."58 As the Department itself
has recognized, PFAS meet the definition of "toxic substance" and the Department should
therefore analyze whether Venator Chemicals' discharge will violate this water quality
standard.59 EPA's health advisories for PFAS and countless toxicity studies indicate that the
51 Christopher G. Scheitlin et al., Application of Supercritical Water Oxidation to Effectively Destroy Per- and
Polyfluoroalkyl Substances in Aqueous Matrices, 3 ENVT SCL & TECH. 2053, 2054 (2023),
hllps://pubs.acs.or /g doi/gpdf/10.1021/acsestwater.2c00548.
51 Id. at 2058.
52 N.C. Gen. Stat. § 143-215.1(c)(1) (authorizing the Department to "require an applicant to submit plans,
specifications, and other information the [Department] considers necessary to evaluate the application").
53 40 C.F.R. § 122.44(d)(1)(i); see also 33 U.S.C. § 1311(b)(1)(C); 15A N.C. Admin. Code 214.0112(c) (stating that
Department must "reasonably ensure compliance with applicable water quality standards and regulations"); EPA's
PFAS NPDES Guidance, supra note 2, at 3-4.
54 40 CFR § 122.44(d)(1)(i), see also 33 U.S.C. § 1311(b)(1)(C); (1)(i); 15A N.C. Admin. Code 211.0112(c) (stating
that the Department must "reasonably ensure compliance with applicable water quality standards and regulations.");
EPA, CENTRAL TENETS OF THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES) PERMITTING PROGRAM 3 (2020), available at hgps://www.epa.gov/npdes/central-tenets-npdes-
permitting-program (emphasis in original) [hereinafter "Central Tenets of NPDES Permitting Program"].
55 Central Tenets of NPDES Permitting Program, supra note 54, at 3.
56 Id.
5' 15A N.C. Admin. Code 213.0208.
58 Id. at 213.0208(a)(2)(13).
59 Amended Complaint, North Carolina v. The Chemours Company, FC, LLC, supra note 39, at ¶ 152 (explaining
that PFAS "meet the definition of `toxic substance' set forth in 15A N.C.A.C. 2B .0202").
N.

chemicals pose unacceptable health risks at extremely low levels, and these health advisories and
toxicity information should inform the Department's effluent limit analysis.
III. Conclusion.
In summary, the Department must require Venator Chemicals to disclose any discharges
of PFAS in its permit application so that the Department and the public have adequate
information to evaluate the toxic pollution and participate in the permitting process. If Venator
Chemicals does not make this disclosure, any discharge of PFAS is illegal and subject to agency
or citizen enforcement. If Venator Chemicals does indeed discharge PFAS, the Department must
evaluate treatment technology and impose limits that ensure compliance with water quality
standards. Because the permit fails to meet the requirements imposed by the Clean Water Act,
Fourth Circuit precedent, and EPA's guidance, it must be withdrawn and revised as noted above.
Thank you for considering these comments. Please contact me at 919-967-1450 or
[e-mail] if you have any questions regarding this letter.
Sincerely,
I?"
Jean Zhuang
4""�-Qow
Hannah M. Nelson
9

ATTACHMENT 1

J��SED STq�s
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
5 w
u
= OFFICE OF WATER
0
1+Tq( PRO s
December 5, 2022
MEMORANDUM
SUBJECT: Addressing PFAS Discharges in NPDES Permits and Through the Pretreatment Program
and Monitoring Programs
FROM: Radhika Fox
Assistant Administrator
TO: EPA Regional Water Division Directors, Regions 1-10
The National Pollutant Discharge Elimination System (NPDES) program is an important tool
established by the Clean Water Act (CWA) to help address water pollution by regulating point sources
that discharge pollutants to waters of the United States. Collectively, the U.S. Environmental Protection
Agency (EPA) and states issue thousands of permits annually, establishing important monitoring and
pollution reduction requirements for Publicly Owned Treatment Works (POTWs), industrial facilities,
and stormwater discharges nationwide. The NPDES program interfaces with many pathways by which
per -and polyfluoroalkyl substances (PFAS) travel and are released into the environment, and ultimately
impact water quality and the health of people and ecosystems. Consistent with the Agency's
commitments in the October 2021 PFAS Strate zic Roadmap: EPA's Commitments to Action 2021-2024
(PFAS Strategic Roadmap), EPA will work in cooperation with our state -authorized permitting
authorities to leverage the NPDES program to restrict the discharge of PFAS at their sources. In addition
to reducing PFAS discharges, this program will enable EPA and the states to obtain comprehensive
information on the sources and quantities of PFAS discharges, which can be used to inform appropriate
next steps to limit the discharges of PFAS.
This memorandum provides EPA's guidance to states and updates the April 28, 2022 guidance' to EPA
Regions for addressing PFAS discharges when they are authorized to administer the NPDES permitting
program and/or pretreatment program. These recommendations reflect the Agency's commitments in the
PFAS Strategic Roadmap, which directs the Office of Water to leverage NPDES permits to reduce
PFAS discharges to waterways "at the source and obtain more comprehensive information through
monitoring on the sources of PFAS and quantity of PFAS discharged by these sources." While the
Office of Water works to revise Effluent Limitation Guidelines (ELGs) and develop water quality
criteria to support technology -based and water quality -based effluent limits for PFAS in NPDES
permits, this memorandum describes steps permit writers can implement under existing authorities to
reduce the discharge of PFAS.
Addressing PFAS Discharges in EPA -Issued NPDES Permits and Expectations Where EPA is the Pretreatment Control
Authority, httns•//www.epa.gov/system/files/documents/2022-04/nt)des pfas-memo.pdf.

This memorandum also provides EPA's guidance for addressing sewage sludge PFAS contamination
more rapidly than possible with monitoring based solely on NPDES permit renewals. States may choose
to monitor the levels of PFAS in sewage sludge across POTWs and then consider mechanisms under
pretreatment program authorities to prevent the introduction of PFAS to POTWs based on the
monitoring results.
EPA recommends that the following array of NPDES and pretreatment provisions and monitoring
programs be implemented by authorized states and POTWs, as appropriate, to the fullest extent available
under state and local law. NPDES and pretreatment provisions may be included when issuing a permit
or by modifying an existing permit pursuant to 40 CFR 122.62.
A. Recommendations for Applicable Industrial Direct DischarP-ers
1. Applicability: Industry categories known or suspected to discharge PFAS as identified on page 14
of the PFAS Strategic Roadmap include: organic chemicals, plastics & synthetic fibers (OCPSF);
metal finishing; electroplating; electric and electronic components; landfills; pulp, paper &
paperboard; leather tanning & finishing; plastics molding & forming; textile mills; paint formulating,
and airports. This is not an exhaustive list and additional industries may also discharge PFAS. For
example, Centralized Waste Treatment (CWT) facilities may receive wastes from the
aforementioned industries and should be considered for monitoring. There may also be categories of
dischargers that do not meet the applicability criteria of any existing ELG; for instance, remediation
sites, chemical manufacturing not covered by OCPSF, and military bases.
EPA notes that no permit may be issued to the owner or operator of a facility unless the owner or
operator submits a complete permit application in accordance with applicable regulations, and
applicants must provide any additional information that the permitting authority may reasonably
require to assess the discharges of the facility (40 CFR 122.21(e), (g)(13)).2 The applicant may be
required to submit additional information under CWA Section 308 or under a similar provision of
state law.
2. Effluent -and wastewater residuals monitoring: In the absence of a final 40 CFR Part 136 method,
EPA recommends using CWA wastewater draft analytical method 1633 (see 40 CFR
122.21(e)(3)(ii) and 40 CFR 122.44(i)(1)(iv)(B)). EPA also recommends that monitoring include
each of the 40 PFAS parameters detectable by draft method 1633 and be conducted at least quarterly
to ensure that there are adequate data to assess the presence and concentration of PFAS in
discharges. All PFAS monitoring data must be reported on Discharge Monitoring Reports (DMRs)
(see 40 CFR 122.41(1)(4)(i)). The draft Adsorbable Organic Fluorine CWA wastewater method 1621
can be used in conjunction with draft method 1633, if appropriate. Certain industrial processes may
generate PFAS-contaminated solid waste or air emissions not covered by NPDES permitting and
permitting agencies should coordinate with appropriate state authorities on proper containment and
disposal to avoid cross -media contamination. EPA's draft analytical method 1633 may be
appropriate to assess the amount and types of PFAS for some of these wastestreams.3
'For more, see NPDES Permit Writer's Manual Section 4.5.1.
s See https://www.epa.gov/water-research/pfas-analytical-methods-development-and-sampling-research for a list of EPA -
approved methods for other media.

3. Best Management Practices (BMPs) for discharges of PFAS, including product substitution,
reduction, or elimination of PFAS, as detected by draft method 1633: Pursuant to 40 CFR
122.44(k)(4), EPA recommends that NPDES permits for facilities incorporate the following
conditions when the practices are "reasonably necessary to achieve effluent limitations and standards
or to carry out the purposes and intent of the CWA: i4
a. BMP conditions based on pollution prevention/source reduction opportunities, which may
include:
i. Product elimination or substitution when a reasonable alternative to using PFAS is available
in the industrial process.
ii. Accidental discharge minimization by optimizing operations and good housekeeping
practices.
iii. Equipment decontamination or replacement (such as in metal finishing facilities) where
HAS products have historically been used to prevent discharge of legacy PFAS following
the implementation of product substitution.
b. Example BMP permit special condition language:
i. PFAS pollution prevention/source reduction evaluation: Within 6 months of the effective
date of the permit, the facility shall provide an evaluation of whether the facility uses or has
historically used any products containing PFAS, whether use of those products or legacy
contamination reasonably can be reduced or eliminated, and a plan to implement those steps.
ii. Reduction or Elimination: Within 12 months of the effective date of the permit, the facility
shall implement the plan in accordance with the PFAS pollution prevention/source reduction
evaluation.
iii. Annual Report: An annual status report shall be developed which includes a list of potential
PFAS sources, summary of actions taken to reduce or eliminate PFAS, any applicable source
monitoring results, any applicable effluent results for the previous year, and any relevant
adjustments to the plan, based on the findings.
iv. Reporting: When EPA's electronic reporting tool for DMRs (called "NetDMW) allows for the
permittee to submit the pollution prevention/source reduction evaluation and the annual
report, the example permit language can read, "The pollution prevention/source reduction
evaluation and annual report shall be submitted to EPA via EPA's electronic reporting tool
for DMRs (called "NetDMR" ).
4. BMPs to address PFAS-containing firefighting foams for stmrmwater permits: Pursuant to
122.44(k)(2), where appropriate, EPA recommends that NPDES stormwater permits include BMPs
to address Aqueous Film Forming Foam (AFFF) used for firefighting, such as the following:5
a. Prohibiting the use of AFFFs other than for actual firefighting.
b. Eliminating PFOS and PFOA -containing AFFFs.
c. Requiring immediate clean-up in all situations where AFFFs have been used, including
diversions and other measures that prevent discharges via storm sewer systems.
5. Permit Limits: As specified in 40 CFR 125.3, technology -based treatment requirements under
CWA Section 301(b) represent the minimum level of control that must be imposed in NPDES
permits. Site -specific technology -based effluent limits (TBELs) for PFAS discharges developed on a
best professional judgment (BPJ) basis may be appropriate for facilities for which there are no
applicable effluent guidelines (see 40 CFR 122.44(a), 125.3). Also, NPDES permits must include
water quality -based effluent limits (WQBELs) as derived from state water quality standards, in
4 For more on BMPs, see NPDES Permit Writer's Manual Section 9.1 and EPA Guidance Manual for Developing Best
Management Practices.
s Naval Air Station Whidbey Island MS4 permit incorporates these provisions.

addition to TBELs developed on a BPJ basis, if necessary to achieve water quality standards,
including state narrative criteria for water quality (CWA Section 301(b)(1)(C); 40 CFR 122.22(d)).
If a state has established a numeric criterion or a numeric translation of an existing narrative water
quality standard for PFAS parameters, the permit writer should apply that numeric criterion or
narrative interpretation in permitting decisions, pursuant to 40 CFR 122.44(d)(1)(iii) and
122.44(d)(1)(vi)(A), respectively.
B. Recommendations for Publicly Owned Treatment Works
1. Applicability: All POTWs, including POTWs that do not receive industrial discharges, and
industrial users (IUs) in the industrial categories above.
2. Effluent, influent, and biosolids monitoring: In the absence of a final 40 CFR Part 136 method,
EPA recommends using CWA wastewater draft analytical method 1633 (see 40 CFR
122.21(e)(3)(ii) and 40 CFR 122.44(i)(1)(iv)(B)). EPA also recommends that monitoring include
each of the 40 PFAS parameters detectable by draft method 1633 and be conducted at least quarterly
to ensure that there are adequate data to assess the presence and concentration of PFAS in
discharges. All PFAS monitoring data must be reported on DMRs (see 40 CFR 122.41(1)(4)(i)). The
draft Adsorbable Organic Fluorine CWA wastewater method 1621 can be used in conjunction with
draft method 1633, if appropriate.
3. Pretreatment program activities:
a. Update IU Inventory: Permits to POTWs should contain requirements to identify and locate all
possible IUs that might be subject to the pretreatment program and identify the character and
volume of pollutants contributed to the POTW by the IUs (see 40 CFR 403.8(f)(2)). As EPA
regulations require, this information shall be provided to the pretreatment control authority (see
40 CFR 122.440) and 40 CFR 403.8(f)(6)) within one year. The IU inventory should be revised,
as necessary, to include all Ns in industry categories expected or suspected of PFAS discharges
listed above (see 40 CFR 403.12(i)).6
b. Utilize BMPs and pollution prevention to address PFAS discharges to POTWs. EPA
recommends that POTWs:
i. Update IU permits/control mechanisms to require quarterly monitoring. These IUs should be
input into the Integrated Compliance Information System (ICIS) with appropriate linkage to
their respective receiving POTWs. POTWs and states may also use their available authorities
to conduct quarterly monitoring of the IUs (see 40 CFR 403.8(f)(2), 403.10(e) and (f)(2)).
ii. Where authority exists, develop IU BMPs or local limits. 40 CFR 403.5(c)(4) authorizes
POTWs to develop local limits in the form of BMPs. Such BMPs could be like those for
industrial direct discharges described in A.3 above.
iii. In the absence of local limits and POTW legal authority to issue IU control mechanisms, state
pretreatment coordinators are encouraged to work with the POTWs to encourage pollution
prevention, product substitution, and good housekeeping practices to make meaningful
reductions in HAS introduced to POTWs.
e ELG categories of airport deicing, landfills, textile mills, and plastics molding and forming do not have categorical
pretreatment standards, and therefore small -volume indirect dischargers in those categories would not ordinarily be
considered Significant Industrial Users (SIUs) and may not be captured on an existing IU inventory, IUs under the Paint
Formulating category are only subject to Pretreatment Standards for New Sources (PSNS), and existing sources may need to
be inventoried.

C. Recommended Biosolids Assessment
1. Where appropriate, states may work with their POTWs to reduce the amount of PFAS
chemicals in biosolids, in addition to the NPDES recommendations in Section B above,
following these general steps:7
a. EPA recommends using draft method 1633 to analyze biosolids at POTWs for the presence of 40
PFAS chemicals.8
b. Where monitoring and IU inventory per section B.2 and B.3.a above indicate the presence of
PFAS in biosolids from industrial sources, EPA recommends actions in B.3.b to reduce PFAS
discharges from IUs.
c. EPA recommends validating PFAS reductions with regular monitoring of biosolids. States may
also use their available authorities to conduct quarterly monitoring of the POTWs (see 40 CFR
403.10(t)(2)).
D. Recommended Public Notice for Draft Permits with PFAS-Specific Conditions
1. In addition to the requirements for public notice described in 40 CFR 124.10, EPA
recommends that NPDES permitting authorities provide notification to potentially affected
downstream public water systems (PWS) of draft permits with PFAS-specific monitoring,
BMPs, or other conditions:
a. Public notice of the draft permit would be provided to potentially affected PWS with intakes
located downstream of the NPDES discharge.
b. NPDES permit writers are encouraged to collaborate with their drinking water program
counterparts to determine on a site -specific basis which PWS to notify.
i. EPA's Drinking Water Mapping Application to Protect Source Waters (DWMAPS) tool may
be helpful as a screening tool to identify potentially affected PWS to notify.
c. EPA will provide instructions on how to search for facility -specific discharge monitoring data
in EPA's publicly available search tools.
7 EPA is currently evaluating the potential risk of PFOA and PFOS in biosolids and supporting studies and activities to
evaluate the presence of PFOA and PFOS in biosolids. This recommendation is not meant to supersede the PFOA and PFOS
risk assessment or supporting activities. The conclusions of the risk assessment and supporting studies may indicate that
regulatory actions or more stringent requirements are necessary to protect human health and the environment.
8 While water quality monitoring activities (including monitoring of PFAS associated with NPDES permit or pretreatment
requirements) at POTWs are generally not eligible for Clean Water State Revolving Fund (CWSRF), monitoring for the
specific purpose of project development (planning, design, and construction) is eligible. Monitoring in this capacity, and
within a reasonable timeframe, can be integral to the identification of the best solutions (through an alternatives analysis) for
addressing emerging contaminants and characterizing discharge and point of disposal (e.g., land application of biosolids).
Though ideally the planning and monitoring for project development would result in a CWSRF-eligible capital project, in
some instances, the planning could lead to outcomes other than capital projects to address the emerging contaminants.

ATTACHMENT 2

0
170'dhec
H4�aIthy HIV HaaftFrX Corrmunitk-_
CERTIFIED MAIL/RETURN RECEIPT REQUESTED
November 8, 2022
Gary Bird
Inman Mills -Ramey Plant
PO BOX 158
Enoree, SC 29335
Re: Department Decision
INMAN MILLS/RAMEY PLANT
NPDES/ND Permit # SC0002496
Spartanburg County
Dear Gary Bird:
Enclosed is the modified National Pollution Discharge Elimination System (NPDES) Permit for
the above referenced facility. The permit is issued with the following changes to the draft
permit modification which was public noticed:
Parts 111.A.3.a, b, and c: PFAS monitor and report requirements have been added for the
effluent, source water and calculated difference. Footnote 13 has been also added
addressing PFAS sampling ad reporting.
2. Part V.A.3: The two "one-time" PFAS sampling events for the effluent previously in this
section have been replaced with PFAS differential benchmarks. A requirement to submit in
a PFAS Evaluation and Reduction report if one or both of those benchmarks are exceeded has
also been added to this section. Exceeding the benchmarks is not considered permit
noncompliance or a violation as long as the permittee submits in a timely PFAS Evaluation
and Reduction report.
3. Part V.A.5: The last sentence of this condition has been revised; 'technology -based' has been
removed from the sentence.
4. Part V.A.6: Total PFAS Compounds has been added to this table.
5. Part V.E.6: Permit language has been added to address the permit shield.
S.C. DgPZ3FtM8nt 4F Health a nd Erwimn m9nta I Omtrvl
26M Bull Su**t Cor.mbia, 5C 29201 CBMP BaG-3432 Wrww.s�tlF t.g r

Additionally, the letter of approval on page 2 of the rationale regarding the approved pump and
haul to the Town of Ware Shoals Dairy Street Wastewater Treatment Plant has been updated to
the in -effect LOA-006451.
Please see the enclosed response to public comments received during the public comment
period. Note the modification date on the permit and see the enclosed South Carolina Board of
Health and Environmental Control Guide to Board Review.
If you have any questions about the technical aspects of this permit, please contact Melanie K
Townley at 803-898-4223. Information pertaining to adjudicatory matters may be obtained by
contacting the Legal Office, SCDHEC, 2600 Bull Street, Columbia, SC 29201, or by calling them at
[phone].
Sincerely,
G.,�g D•
Crystal Rippy, Manager
Industrial Wastewater Permitting Section
Enclosures: Permit, Fact Sheet, Attachments, Guide to Board Review, July 1, 2022 Public
Comments, DHEC's Response to Public Comments
cc w/encl and Response to Comments:
Southern Environmental Law Center
Congaree Riverkeeper
Upstate Forever
cc w/encl via email:
EPA Region IV
NPDES Permit Administration
Jacob Oblander, BOW/WPC Enforcement
Natalie Kirkpatrick, Upstate EA Spartanburg
GREENVILLE EQC LAB
Sara Martinez, DHEC Legal Office
Southern Environmental Law Center
Congaree Riverkeeper
Upstate Forever
S.C. Department of Health and Environmental Control
2600 Bull Street. Columbia, SC 29201 (803) 8983432 www.scdho-c.gov

National Pollutant Discharge
Elimination System Permit
(for Discharge to Surface Waters)
This NPDES Permit Authorizes
Inman Mills
Ramey Plant
to discharge from a facility located at
Highway 221
Enoree, SC
Spartanburg County
to receiving waters named
Enoree River
in accordance with limitations, monitoring requirements and other conditions set forth
herein. This permit is issued in accordance with the provisions of the Pollution Control Act of
South Carolina (S.C. Code Sections 48-1-10 et seq., 1976), Regulation 61-9 and with the
provisions of the Federal Clean Water Act (PL 92-500), as amended, 33 U.S.C.1251 etseq., the
"Act."
Shawn M. Clarke, P.E., Director
Water Facilities Permitting Division
Issue Date: April 28, 2021
Modification Issue Date: November 8, 2022
Effective Date: June 1, 2021
Modification Effective Date: January 1, 2023
Expiration Date': May 31, 2026
Permit No.: SCO002496
This permit will continue to be in effect beyond the expiration date if a complete timely re-
application is received pursuant to Regulation 61-9.122.6 and signed per Regulation 61-9.122.22.
Aff
4TO
dhec
S.C. Department of Health and
Environmental Control

Table of Contents
PARTI. Definitions.....................................................................................................................................................3
PARTII. Standard Conditions....................................................................................................................................6
A.
Duty to comply............................................................................................................................................................
6
B.
Duty to reapply...........................................................................................................................................................
6
C.
Need to halt or reduce activity not a defense........................................................................................................
6
D.
Duty to mitigate..........................................................................................................................................................
6
E.
Proper operation and maintenance........................................................................................................................
6
F.
Permit actions.............................................................................................................................................................
7
G.
Property rights............................................................................................................................................................
8
H.
Duty to provide information.....................................................................................................................................
8
I.
Inspection and entry..............................................................................................................................................I...
8
J.
Monitoring and records.............................................................................................................................................
9
K.
Signatory requirement............................................................................................................................................
11
L.
Reporting requirements..........................................................................................................................................
12
M.
Bypass........................................................................................................................................................................18
N.
Upset..........................................................................................................................................................................18
O.
Misrepresentation of Information.........................................................................................................................
19
Part
III. Limitations and Monitoring Requirements.............................................................................................20
A.
Effluent Limitations and Monitoring Requirements............................................................................................
20
B.
Whole Effluent Toxicity and Other Biological Limitations and Monitoring Requirements ............................
28
C.
Groundwater Monitoring Requirements..............................................................................................................
30
D.
Sludge Monitoring Requirements..........................................................................................................................
30
E.
Soil Monitoring Requirements................................................................................................................................
30
PartIV.
Schedule of Compliance.............................................................................................................................31
PartV.
Other Requirements....................................................................................................................................32
A.
Effluent Requirements.............................................................................................................................................
32
B.
Whole Effluent Toxicity and Other Biological Requirements.............................................................................
34
C.
Groundwater Requirements...................................................................................................................................
37
D.
Sludge Requirements...............................................................................................................................................
37
E.
Other Conditions......................................................................................................................................................
37

Part I
Page 3 of 38
Permit No. SC0002496
PART I. Definitions
Any term not defined in this Part has the definition stated in the Pollution Control Actor in "Water Pollution Control
Permits", R.61-9 or its normal meaning.
A. The "Act", or CWA, shall refer to the Clean Water Act (Formerly referred to as the Federal Water Pollution Control
Act) Public Law 92-500, as amended.
B. The "average" or "arithmetic mean" of any set of values is the summation of the individual values divided by the
number of individual values.
C. "Basin" (or "Lagoon") means any in -ground or earthen structure designed to receive, treat, store, temporarily
retain and/or allow for the infiltration/evaporation of wastewater.
D. "Bypass" means the intentional diversion of waste streams from any portion of a treatment facility.
E. A "composite sample" shall be defined as one of the following four types:
1. An influent or effluent portion collected continuously over a specified period of time at a rate proportional
to the flow.
2. A combination of not less than 8 influent or effluent grab samples collected at regular (equal) intervals over
a specified period of time and composited by increasing the volume of each aliquot in proportion to flow.
If continuous flow measurement is not used to composite in proportion to flow, the following method will
be used: An instantaneous flow measurement should be taken each time a grab sample is collected. At
the end of the sampling period, the instantaneous flow measurements should be summed to obtain a total
flow. The instantaneous flow measurement can then be divided by the total flow to determine the
percentage of each grab sample to be combined. These combined samples form the composite sample.
3. A combination of not less than 8 influent or effluent grab samples of equal volume but at variable time
intervals that are inversely proportional to the volume of the flow. In other words, the time interval between
aliquots is reduced as the volume of flow increases.
4. If the effluent flow varies by less than 15 percent, a combination of not less than 8 influent or effluent grab
samples of constant (equal) volume collected at regular (equal) time intervals over a specified period of
time.
All samples shall be properly preserved in accordance with Part II.J.4. Continuous flow or the sum of
instantaneous flows measured and averaged for the specified compositing time period shall be used with
composite results to calculate mass.
F. "Daily discharge" means the discharge of a pollutant measured during a calendar day or any 24-hour period
that reasonably represents the calendar day for purposes of sampling. For pollutants with limitations
expressed in units of mass, the daily discharge is calculated as the total mass of the pollutant discharged over
the day. For pollutants with limitations expressed in other units of measurement, the daily discharge is
calculated as the average measurement of the pollutant over the day.

Part I
Page 4 of 38
Permit No. SC0002496
G. "Daily maximum" is the highest average value recorded of samples collected on any single day during the
calendar month.
H. "Daily minimum" is the lowest average value recorded of samples collected on any single day during the
calendar month.
I. The "Department" or "DHEC" shall refer to the South Carolina Department of Health and Environmental Control.
J. The "geometric mean" of any set of values is the Nth root of the product of the individual values where N is
equal to the number of individual values. The geometric mean is equivalent to the antilog of the arithmetic
mean of the logarithms of the individual values. For purposes of calculating the geometric mean, values of zero
(0) shall be considered to be one (1).
K. A "grab sample" is an individual, discrete or single influent or effluent portion of at least 100 milliliters collected
at a time representative of the discharge and over a period not exceeding 15 minutes and retained separately
for analysis.
L. "Groundwater" means the water below the land surface found in fractured rock or various soil strata.
M. The "maximum or minimum" is the highest or lowest value, respectively, recorded of all samples collected
during the calendar month. These terms may also be known as the instantaneous maximum or minimum.
N. "Monitoring well" means any well used to sample groundwater for water quality analysis or to measure
groundwater levels.
O. The "monthly average", other than for fecal coliform, E. Coli and enterococci, is the arithmetic mean of all
samples collected in a calendar month period. The monthly average for fecal coliform, E. Coli and enterococci
bacteria is the geometric mean of all samples collected in a calendar month period. The monthly average
loading is the arithmetic average of all daily discharges made during the month.
P. The "PCA" shall refer to the Pollution Control Act (Chapter 1, Title 48, Code of Laws of South Carolina).
Q. The "practical quantitation limit" (PQL) is the concentration at which the entire analytical system must give a
recognizable signal and acceptable calibration point. It is the concentration in a sample that is equivalent to
the concentration of the lowest calibration standard analyzed by a specific analytical procedure, assuming that
all the method -specific sample weights, volumes, and processing steps have been followed. It is also referred
to as the reporting limit.
R. "Quarter" is defined as the first three calendar months beginning with the month that this permit becomes
effective and each group of three calendar months thereafter.
S. "Quarterly average" is the arithmetic mean of all samples collected in a quarter.
T. "Severe property damage" means substantial physical damage to property, damage to the treatment facilities
which causes them to become inoperable, or substantial and permanent loss of natural resources which can

Part I
Page 5 of 38
Permit No. SC0002496
reasonably be expected to occur in the absence of a bypass. Severe property damage does not mean economic
loss caused by delays in production.
U. "Sludge" means industrial sludge. Industrial sludge is a solid, semi -solid, or liquid residue generated during the
treatment of industrial wastewater in a treatment works. Industrial sludge includes, but is not limited to,
industrial septage; scum or solids removed in primary, secondary, or advanced wastewater treatment
processes; and a material derived from industrial sludge. Industrial sludge does not include ash generated
during the firing of industrial sludge in an industrial sludge incinerator or grit and screenings generated during
preliminary treatment of industrial wastewater in a treatment works. Industrial sludge by definition does not
include sludge covered under 40 CFR Part 503 or R.61-9.503.
V. "Upset" means an exceptional incident in which there is unintentional and temporary noncompliance with
technology based permit effluent limitations because of factors beyond the reasonable control of the
permittee. An upset does not include noncompliance to the extent caused by operational error, improperly
designed treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or
improper operation.
W. "Wastewater" means industrial wastewater. Industrial wastewater is wastewater generated from a federal
facility, commercial or industrial process, including waste and wastewater from humans when generated at an
industrial facility.
X. "Weekly average" is the arithmetic mean of all the samples collected during a one -week period. For self -
monitoring purposes, weekly periods in a calendar month are defined as three (3) consecutive seven-day
intervals starting with the first day of the calendar month and a fourth interval containing seven (7) days plus
those days beyond the 28th day in a calendar month. The value to be reported is the single highest of the four
(4) weekly averages computed during a calendar month. The weekly average loading is the arithmetic average
of all daily discharges made during the week.

Part II
Page 6 of 38
Permit No. SC0002496
PART II. Standard Conditions
A. Duty to comply
The permittee must comply with all conditions of the permit. Any permit noncompliance constitutes a
violation of the Clean Water Act and the Pollution Control Act and is grounds for enforcement action; for
permit termination, revocation and reissuance, or modification; or denial of a permit renewal application.
The Department's approval of wastewater facility plans and specifications does not relieve the permittee of
responsibility to meet permit limits.
1. The permittee shall comply with effluent standards or prohibitions established under section 307(a) of
the Clean Water Act for toxic pollutants and with standards for sewage sludge use or disposal established
under section 405(d) of the CWA within the time provided in the regulations that establish these
standards or prohibitions or standards for sewage sludge use or disposal, even if the permit has not yet
been modified to incorporate the requirement.
2. Failure to comply with permit conditions or the provisions of this permit may subject the permittee to
civil penalties under S.C. Code Section 48-1-330 or criminal sanctions under S.C. Code Section 48-1-320.
Sanctions for violations of the Federal Clean Water Act may be imposed in accordance with the
provisions of 40 CFR Part 122.41(a)(2) and (3).
3. A person who violates any provision of this permit, a term, condition or schedule of compliance
contained within this NPDES permit, or the State law is subject to the actions defined in the State law.
B. Duty to reapply
If the permittee wishes to continue an activity regulated by this permit after the expiration date of this
permit, the permittee must apply for and obtain a new permit. A permittee with a currently effective permit
shall submit a new application 180 days before the existing permit expires, unless permission for a later
date has been granted by the Department. The Department shall not grant permission for applications to
be submitted later than the expiration date of the existing permit.
C. Need to halt or reduce activity not a defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt
or reduce the permitted activity in order to maintain compliance with the conditions of this permit.
D. Duty to mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal
in violation of this permit which has a reasonable likelihood of adversely affecting human health or the
environment.
E. Proper operation and maintenance

Part II
Page 7 of 38
Permit No. SC0002496
1. The permittee shall at all times properly operate and maintain in good working order and operate as
efficiently as possible all facilities and systems of treatment and control (and related appurtenances)
which are installed or used by the permittee to achieve compliance with the terms and conditions of this
permit. Proper operation and maintenance includes effective performance based on design facility
removals, adequate funding, adequate operator staffing and training and also includes adequate
laboratory controls and appropriate quality assurance procedures. This provision requires the operation
of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the
operation is necessary to achieve compliance with the conditions of the permit.
2. Power Failures. In order to maintain compliance with effluent limitations and prohibitions of this permit,
the permittee shall either:
a. provide an alternative power source sufficient to operate the wastewater control facilities;
b. or have a plan of operation which will halt, reduce, or otherwise control production and/or all
discharges upon the reduction, loss, or failure of the primary source of power to the wastewater
control facilities.
3. The permittee shall develop and maintain atthe facility a complete Operations and Maintenance Manual
for the waste treatment facilities. The manual shall be made available for on -site review during normal
working hours. The manual shall contain operation and maintenance instructions for all equipment and
appurtenances associated with the waste treatment facilities and land application system, if applicable.
The manual shall contain a general description of the treatment process(es), the operational procedures
to meetthe requirements of E.1 above, and the corrective action to be taken should operating difficulties
be encountered.
4. The permittee shall provide for the performance of daily treatment facility inspections by a certified
operator of the appropriate grade as defined in Part V.E of this permit. The Department may make
exceptions to the daily operator requirement in accordance with R.61-9.122.41(e)(3)(ii). The inspections
shall include, but should not necessarily be limited to, areas which require visual observation to
determine efficient operation and for which immediate corrective measures can be taken using the O &
M manual as a guide. All inspections shall be recorded and shall include the date, time, and name of the
person making the inspection, corrective measures taken, and routine equipment maintenance, repair,
or replacement performed. The permittee shall maintain all records of inspections at the permitted
facility as required by the permit, and the records shall be made available for on -site review during
normal working hours.
5. A roster of operators associated with the facility's operation and their certification grades shall be
maintained onsite and be made available to the Department upon request.
6. Wastewater Sewer Systems
a. Purpose. This section establishes rules for governing the operation and maintenance of wastewater
sewer systems, including gravity or pressure interceptor sewers. It is the purpose of this section to
establish standards for the management of sewer systems to prevent and/or minimize system
failures that would lead to public health or environmental impacts.

Part II
Page 8 of 38
Permit No. SC0002496
b. Applicability. This section applies to all sewer systems that have been or would be subject to a DHEC
construction permit under Regulation 61-67 and whose owner owns or operates the wastewater
treatment system to which the sewer discharges.
c. General requirements. The permittee must:
(1) Properly manage, operate, and maintain at all times all parts of its sewer system(s), to include
maintaining contractual operation agreements to provide services, if appropriate;
(2) Provide adequate capacity to convey base flows and peak flows for all parts of the sewer system
or, if capital improvements are necessary to meet this standard, develop a schedule of short and
longterm improvements;
(3) Take all reasonable steps to stop and mitigate the impact of releases of wastewater to the
environment; and
(4) Notify the Department within 30 days of a proposed change in ownership of a sewer system.
F. Permit actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned
changes or anticipated noncompliance does not stay any permit condition.
G. Property rights
This permit does not convey any property rights of any sort, or any exclusive privilege nor does it authorize
any injury to persons or property or invasion of other private rights, or any infringement of State or local law
or regulations.
H. Duty to provide information
The permittee shall furnish to the Department, within a reasonable time, any information which the
Department may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit. The permittee shall also furnish to the
Department upon request, copies of records required to be kept by this permit.
I. Inspection and entry
The permittee shall allow the Department, or an authorized representative (including an authorized
contractor acting as a representative of the Department), upon presentation of credentials and other
documents as may be required by law, to:
1. Enter upon the permittee's premises where a regulated facility or activity is located or conducted, or
where records must be kept under the conditions of this permit;

Part II
Page 9 of 38
Permit No. SC0002496
2. Have access to and copy, at reasonable times, any records that must be kept under the conditions of
this permit;
3. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment),
practices, or operations regulated or required under this permit; and
4. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise
authorized by the Clean Water Act and Pollution Control Act, any substances or parameters at any
location.
�. Monitoring and records
1. a. (1) Samples and measurements taken for the purpose of monitoring shall be representative of the
monitored activity.
(2) Samples shall be reasonably distributed in time, while maintaining representative sampling.
(3) No analysis, which is otherwise valid, shall be terminated for the purpose of preventing the
analysis from showing a permit or water quality violation.
b. Flow Measurements.
(1) Where primary flow meters are required, appropriate flow measurement devices and methods
consistent with accepted scientific practices shall be present and used to ensure the accuracy
and reliability of measurements of the volume of monitored discharges. The devices shall be
installed, calibrated and maintained to ensure that the accuracy of the measurements are
consistent with the accepted capability of that type of device. Devices selected shall be capable
of measuring flows with a maximum deviation of less than 10% from the true discharge rates
throughout the range of expected discharge volumes. The primary flow device, where required,
must be accessible to the use of a continuous flow recorder.
(2) Where permits require an estimate of flow, the permittee shall maintain at the permitted facility
a record of the method(s) used in estimating the discharge flow (e.g., pump curves, production
charts, water use records) for the outfall(s) designated on limits pages to monitor flow by an
estimate.
(3) Records of any necessary calibrations must be kept.
2. Except for records of monitoring information required by this permit related to the permittee's sewage
sludge use and disposal activities, which shall be retained for a period of at least five years (or longer as
required by R.61-9.503 or R.61-9.504), the permittee shall retain records of all monitoring information,
including all calibration and maintenance records and all original strip chart recordings for continuous
monitoring instrumentation, copies of all reports required by this permit, and records of all data used to
complete the application for this permit, for a period of at least 3 years from the date of the sample,

Part II
Page 10 of 38
Permit No. SC0002496
measurement, report or application. This period may be extended by request of the Department at any
time.
3. Records of monitoring information shall include:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
4. a. Analyses for required monitoring must be conducted according to test procedures approved under
40 CFR Part 136, equivalent test procedures approved by the Department or other test procedures
that have been specified in the permit.
In the case of sludge use or disposal, analysis for required monitoring must be conducted according
to test procedures approved under 40 CFR Part 136, test procedures specified in R.61-9.503 or R.61-
9.504, equivalent test procedures approved by the Department or other test procedures that have
been specified in the permit.
b. Unless addressed elsewhere in this permit, the permittee shall use a sufficiently sensitive analytical
method that achieves a value below the derived permit limit stated in Part III. For the purposes of
reporting analytical data on the Discharge Monitoring Report (DMR):
(1) Analytical results below the PQL conducted using a method in accordance with Part II.J.4.a above
shall be reported as zero (0). Zero (0) shall also be used to average results which are below the
PQL. When zero (0) is reported or used to average results, the permittee shall report, in the
"General Report Comments Section" of the DMR, the analytical method used, the PQL achieved,
and the number of times results below the PQL were reported as zero (0).
(2) Analytical results above the PQL conducted using a method in accordance with Part II.J.4.a shall
be reported as the value achieved. When averaging results using a value containing a "less than,"
the average shall be calculated using the value and reported as "less than" the average of all
results collected.
(3)(a) The mass value for a pollutant collected using a grab sample shall be calculated using the 24-
hour totalized flow for the day the sample was collected (if available) or the instantaneous
flow at the time of the sample and either the concentration value actually achieved or the
value as determined from the procedures in (1) or (2) above, as appropriate. Grab samples
should be collected at a time representative of the discharge.

Part II
Page 11 of 38
Permit No. SC0002496
(b) The mass value for a pollutant collected using a composite sample shall be calculated using
the 24-hour totalized flow measured for the day the sample was collected and either the
concentration value actually achieved or the value as determined from the procedures in (1)
or (2) above, as appropriate.
5. The PCA provides that any person who falsifies, tampers with, or knowingly renders inaccurate any
monitoring device or method required to be maintained under this permit shall, upon conviction, be
punished by a fine of not more than $25,000 or by imprisonment for not more than 2 years, or both. If
a conviction of a person is for a violation committed after a first conviction of such person under this
paragraph, punishment provided by the Clean Water Act is also by imprisonment of not more than 4
years.
K. Signatory requirement.
1. All applications, reports, or information submitted to the Department shall be signed and certified.
a. Applications. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this section, a
responsible corporate officer means:
(a) A president, secretary, treasurer, or vice-president of the corporation in charge of a principal
business function, or any other person who performs similar policy or decision -making
functions f or the corporation, or
(b) The manager of one or more manufacturing, production, or operating facilities, provided the
manager is authorized to make management decisions which govern the operation of the
regulated facility including having the explicit or implicit duty of making major capital
investment recommendations, and initiating and directing other comprehensive measures
to assure long term environmental compliance with environmental laws and regulations; the
manager can ensure that the necessary systems are established or actions taken to gather
complete and accurate information for permit application requirements; and where authority
to sign documents has been assigned or delegated to the manager in accordance with
corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or
(3) For a municipality, State, Federal, or other public agency or public facility: By either a principal
executive officer, mayor, or other duly authorized employee or ranking elected official. For
purposes of this section, a principal executive officer of a Federal agency includes:
(a) The chief executive officer of the agency, or
(b) A senior executive officer having responsibility for the overall operations of a principal
geographic unit of the agency (e.g., Regional Administrator, Region 4, EPA).

Part II
Page 12 of 38
Permit No. SC0002496
b. All reports required by permits, and other information requested by the Department, shall be signed
by a person described in Part II.K.1.a of this section, or by a duly authorized representative of that
person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described in Part II.K.1.a of this section;
(2) The authorization specifies either an individual or a position having responsibility for the overall
operation of the regulated facility or activity such as the position of plant manager, operator of a
well or a well field, superintendent, position of equivalent responsibility, or an individual or
position having overall responsibility for environmental matters for the company. (A duly
authorized representative may thus be either a named individual or any individual occupying a
named position.) and,
(3) The written authorization is submitted to the Department.
c. Changes to authorization. If an authorization under Part II.K.1.b of this section is no longer accurate
because a different individual or position has responsibility for the overall operation of the facility, a
new authorization satisfying the requirements of Part II.K.1.b of this section must be submitted to
the Department prior to or together with any reports, information, or applications to be signed by
an authorized representative.
d. Certification. Any person signing a document under Part II.K.1.a or b of this section shall make the
following certification: "I certify under penalty of law that this document and all attachments were
prepared under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information submitted. Based on my inquiry
of the person or persons who manage the system, or those persons directly responsible for
gathering the information, the information submitted is, to the best of my knowledge and belief,
true, accurate, and complete. I am aware that there are significant penalties for submitting false
information, including the possibility of fine and imprisonment for knowing violations."
2. The PCA provides that any person who knowingly makes any false statement, representation, or
certification in any record or other document submitted or required to be maintained under this permit,
including monitoring reports or reports of compliance or non-compliance shall, upon conviction, be
punished by a fine of not more than $25,000 per violation, or by imprisonment for not more than two
years per violation, or by both.
L. Reporting requirements
1. Planned changes.
The permittee shall give written notice to DHEC/Bureau of Water/Water Facilities Permitting Division as
soon as possible of any planned physical alterations or additions to the permitted facility. Notice is
required only when:

Part II
Page 13 of 38
Permit No. SC0002496
a. The alteration or addition to a permitted facility may meet one of the criteria for determining whether
a facility is a new source in R 61-9.122.29(b); or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants which are subject neither to effluent limitations in
the permit, nor to notification requirements under Part II1.8 of this section.
c. The alteration or addition results in a significant change in the permittee's sewage sludge or
industrial sludge use or disposal practices, and such alteration, addition, or change may justify the
application of permit conditions that are different from or absent in the existing permit, including
notification of additional use or disposal sites not reported during the permit application process or
not reported pursuant to an approved land application plan (included in the NPDES permit directly
or by reference);
2. Anticipated noncompliance.
The permittee shall give advance notice to the DHEC/Bureau of Water/Water Pollution Control Division
of any planned changes in the permitted facility or activity which may result in noncompliance with
permit requirements.
3. Transfers.
This permit is not transferable to any person except after written notice to the DHEC/Bureau of
Water/NPDES Administration. The Department may require modification or revocation and reissuance
of the permit to change the name of permittee and incorporate such other requirements as may be
necessary under the Pollution Control Act and the Clean Water Act.
a. Transfers by modification. Except as provided in paragraph b of this section, a permit may be
transferred by the permittee to a new owner or operator only if the permit has been modified or
revoked and reissued (under R.61-9.122.62(e)(2)), or a minor modification made (under R.61-
9.122.63(d)), to identify the new permittee and incorporate such other requirements as may be
necessary under CWA.
b. Other transfers. As an alternative to transfers under paragraph a of this section, any NPDES permit
may be transferred to a new permittee if:
(1) The current permittee notifies the Department at least 30 days in advance of the proposed
transfer date in Part II.L.3.b(2) of this section;
(2) The notice includes U.S. EPA NPDES Application Form 1 and a written agreement between the
existing and new permittee containing a specific date for transfer of permit responsibility,
coverage, and liability between them; and
(3) Permits are non -transferable except with prior consent of the Department. A modification under
this section is a minor modification which does not require public notice.

Part II
Page 14 of 38
Permit No. SC0002496
4. Monitoring reports. Monitoring results shall be reported at the intervals specified elsewhere in this
permit. Monitoring periods are calculated beginning with the permit effective date unless otherwise
stated elsewhere in this permit. If the permit is modified, monitoring periods are calculated beginning
with the modification effective date for those items that are part of the modification unless otherwise
stated elsewhere in this permit.
a. Monitoring results must be reported online via an electronic Discharge Monitoring Report (DMR) or
schedule specified by the Department for reporting results of monitoring of groundwater or sludge
use or disposal practices including the following:
(1) Effluent Monitoring: Effluent monitoring results obtained at the required frequency shall be
reported on a Discharge Monitoring Report Form. The completed DMR must be submitted via
ePermitting no later than 11:59 PM on the 28th day of the month following the end of the
monitoring period.
The permittee shall use the electronic DMR system via ePermitting. If the permittee encounters
technical difficulties using the electronic DMR system, contact DHEC for technical assistance at
[e-mail]. Please contact the Compliance Manager for your permit to obtain
approval to submit paper DMRs until the technical issue is resolved.
(2) Groundwater Monitoring: Groundwater monitoring results obtained at the required frequency
shall be reported on a Groundwater Monitoring Report (GMR). The GMR must be submitted via
ePermitting no later than 11:59 PM on the 28th day of the month following the end of the
monitoring period.
The permittee shall use the electronic GMR schedule via ePermitting. If the permittee encounters
technical difficulties using the electronic DMR schedule, contact DHEC for technical assistance at
[e-mail]. Please contact [e-mail] to obtain approval
to submit paper GMRs until the technical issue is resolved.
(3) Sludge, Biosolids and/or Soil Monitoring: Sludge, biosolids and/or soil monitoring results
obtained at the required frequency shall be reported in a laboratory format on a schedule
submitted via ePermitting no later than 11:59 PM on the 28th day of the month following the end
of the monitoring period
The permittee shall use the electronic reports via ePermitting. If the permittee encounters
technical difficulties using the electronic report schedule, contact DHEC for technical assistance
at [e-mail]. Please contact the Compliance Manager for your permit to
obtain approval to submit paper DMRs until the technical issue is resolved.
(4) All other reports and submissions required by this permit shall be submitted via ePermitting no
later than 11:59 PM on the 28th day of the month following the end of the monitoring period
unless otherwise specified in this permit.

Part II
Page 15 of 38
Permit No. SC0002496
The permittee shall use the electronic reports via ePermitting. If the permittee encounters
technical difficulties using the electronic report schedule, contact DHEC for technical assistance
at [e-mail]. Please contact the Compliance Manager for your permit to
obtain approval to submit paper DMRs until the technical issue is resolved.
b. If the permittee monitors any pollutant more frequently than required by the permit using test
procedures approved under 40 CFR Part 136 or, in the case of sludge use or disposal, approved under
40 CFR Part 136 unless otherwise specified in R.61-9.503 or R.61-9.504, or as specified in the permit,
all valid results of this monitoring shall be included in the calculation and reporting of the data
submitted in the DMR or sludge reporting form specified by the Department. The permittee has sole
responsibility for scheduling analyses, other than for the sample date specified in Part V, so as to
ensure there is sufficient opportunity to complete and report the required number of valid results
for each monitoring period.
c. Calculations for all limitations which require averaging of measurements shall utilize an arithmetic
mean unless otherwise specified by the Department in the permit.
5. Twenty-four hour reporting
a. The permittee/system owner (or applicable representative) (hereafter permittee/system owner) shall
report any non-compliance that meets the criteria in Part II.L.S.b. Any information shall be provided
orally or electronically to the local DHEC office as soon as possible but no later than 24 hours from
the time the permittee/system owner becomes aware of the circumstances. During normal working
hours (8:30 AM - 5:00 PM Eastern Standard Time) call the appropriate regional office in the table
below.
County
DHEC Region
Phone No.
Anderson, Oconee
Upstate Region BEHS Anderson
864-260-5569
Abbeville, Greenwood,
Upstate Region BEHS Greenwood
864-227-5915
Laurens, McCormick
Greenville, Pickens
Upstate Region BEHS Greenville
864-372-3273
Cherokee, Spartanburg, Union
Upstate Region BEHS Spartanburg
864-596-3327
Fairfield, Lexington,
Midlands Region BEHS Columbia
803-896-0620
Newberry, Richland
Chester, Lancaster, York
Midlands Region BEHS Lancaster
803-285-7461
Aiken, Barnwell, Edgefield,
Midlands Region BEHS Aiken
803-642-1637
Saluda
Chesterfield, Darlington, Dillon,
pee Dee Region BEHS Florence
843-661-4825
Florence, Marion, Marlboro
Clarendon, Kershaw, Lee,
Pee Dee Region BEHS Sumter
803-778-6548
Sumter
Georgetown, Horry,
Pee Dee Region BEHS Myrtle Beach
843-238-4378
Williamsburg
Berkeley, Charleston,
Low Country Region BEHS Charleston
843-953-0150

Part II
Page 16 of 38
Permit No. SC0002496
Dorchester
Beaufort, Colleton, Hampton,
Low Country Region BEHS Beaufort
843-846-1030
jasper
Allendale, Bamberg, Calhoun,
Low Country Region BEHS Orangeburg
803-533-5490
Orangeburg
* After hour reporting should be made to the 24-hour Emergency Response telephone number
1-888-481-0125.
A follow-up report shall also be provided to DHEC within 5 days of the time the permittee/system
owner becomes aware of the circumstances. For sanitary sewer overflows (SSOs), the 'WW Sewer
System Overflow or Pump Station Failure Reporting' schedule (in ePermitting) should be used. For
all other non-compliance meeting the criteria of II.L.S.b, the 5-Day Reporting' schedule (in
ePermitting) should be used. If the permittee encounters technical difficulties using the electronic
report schedule in ePermitting, a written submission using DHEC Form 3685 (or submission with
equivalent information) should be submitted to the address below. For ePermitting technical
assistance, contact DHEC at [e-mail]. The written submission shall contain a
description of the noncompliance and its cause; the period of noncompliance, including exact dates
and times, and if the noncompliance has not been corrected, the anticipated time it is expected to
continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance.
S.C. Department of Health and Environmental Control
Bureau of Water/Water Pollution Control Division
Data and Records Management Section
2600 Bull Street
Columbia, South Carolina 29201
b. The following shall be included as information which must be reported within 24 hours under this
paragraph.
(1) Any unanticipated bypass which exceeds any effluent limitation in the permit. (See R.61-
9.122.44(g)).
(2) Any upset which exceeds any effluent limitation in the permit.
(3) Violation of a maximum daily discharge limitation for any of the pollutants listed below (See R 61-
9.122.44(g)):
Total Residual Chlorine Chromium Hydrogen Sulfide
(4) Any non-compliance with the conditions of this permit which may endanger human health or the
environment.
(5) Any spill or release of untreated wastewater that reaches the surface waters of the State.
[Note: When investigating a potential release due to a problem with a pump station, the
investigation should include an evaluation of upstream manholes.]

Part II
Page 17 of 38
Permit No. SC0002496
c. The Department may waive the written report on a case -by -case basis for reports under Part II.L.S.b
of this section if the oral report has been received within 24 hours.
6. Other noncompliance.
The permittee shall report all instances of noncompliance not reported under Part II1.4 and 5 of this
section and Part IV at the time monitoring reports are submitted. The reports shall contain the
information listed in Part 111.5 of this section.
7. Other information.
Where the permittee becomes aware that it failed to submit any relevant facts in a permit application,
or submitted incorrect information in a permit application or in any report to the Department, it shall
promptly submit such facts or information to the Water Facilities Permitting Division. This information
may result in permit modification, revocation and reissuance, or termination in accordance with
Regulation 61-9.
8. Existing manufacturing, commercial, mining, and silvicultural dischargers.
In addition to the reporting requirements under Part II1.1-7 of this section, all existing manufacturing,
commercial, mining, and silvicultural dischargers must notifythe DHEC/Bureau of Water/Water Pollution
Control Division of the Department as soon as they know or have reason to believe:
a. That any activity has occurred or will occur which would result in the discharge on a routine or
frequent basis, of any toxic pollutant which is not limited in the permit, if that discharge will exceed
the highest of the following "notification levels":
(1) One hundred micrograms per liter (100 pg/1);
(2) Two hundred micrograms per liter (200 pg/1) for acrolein and acrylonitrile; five hundred
micrograms per liter (500 pg/1) for 2,4-dinitrophenol and for 2-methyl-4,6-dinitrophenol; and one
milligram per liter (1 mg/1) for antimony;
(3) Five (5) times the maximum concentration value reported for that pollutant in the permit
application; or
(4) The level established by the Department in accordance with section R.61-9.122.44(f).
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine or
infrequent basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed
in the highest of the following "notification levels":
(1) Five hundred micrograms per liter (500 pg/1);
(2) One milligram per liter (1 mg/1) for antimony;

Part II
Page 18 of 38
Permit No. SC0002496
(3) Ten (10) times the maximum concentration value reported for that pollutant in the permit
application in accordance with R.61-9.122.21(g)(7).
(4) The level established by the Department in accordance with section R.61-9.122.44(f).
M. Bypass
1. Bypass not exceeding limitations. The permittee may allow any bypass to occur which does not cause
effluent limitations to be exceeded but only if it also is for essential maintenance to assure efficient
operation. These bypasses are not subject to the provisions of Part II.M.2 and 3 of this section.
2. Notice.
a. Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit prior
notice, if possible, at least ten days before the date of the bypass to the DHEC/Bureau of Water/
Water Facilities Permitting Division.
b. Unanticipated bypass. The permittee shall submit notice of an unanticipated bypass as required in
Part II1.5 of this section.
3. Prohibition of bypass
a. Bypass is prohibited, and the Department may take enforcement action against a permittee for
bypass, unless:
(1) Bypass was unavoidable to prevent loss of life, personal injury, or severe property damage;
(2) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities,
retention of untreated wastes, or maintenance during normal periods of equipment downtime.
This condition is not satisfied if adequate back-up equipment should have been installed in the
exercise of reasonable engineering judgment to prevent a bypass which occurred during normal
periods of equipment downtime or preventive maintenance; and
(3) The permittee submitted notices as required under Part II.M.2 of this section.
b. The Department may approve an anticipated bypass, after considering its adverse effects, if the
Department determines that it will meet the three conditions listed above in Part II.M.3.a of this
section.
N. Upset
1. Effect of an upset. An upset constitutes an affirmative defense to an action brought for noncompliance
with such technology based permit effluent limitations if the requirements of Part II.N.2 of this section
are met. No determination made during administrative review of claims that noncompliance was caused
by upset, and before an action for noncompliance, is final administrative action subject to judicial review.

Part II
Page 19 of 38
Permit No. SC0002496
2. Conditions necessary for a demonstration of upset. A permittee who wishes to establish the affirmative
defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or other
relevant evidence that:
a. An upset occurred and that the permittee can identify the cause(s) of the upset;
b. The permitted facility was at the time being properly operated; and
c. The permittee submitted notice of the upset as required in Part II.L.5.b(2) of this section.
d. The permittee complied with any remedial measures required under Part ILD of this section.
Burden of proof. In any enforcement proceeding, the permittee seeking to establish the occurrence of
an upset has the burden of proof.
O. Misrepresentation of Information
Any person making application for a NPDES discharge permit or filing any record, report, or other
document pursuantto a regulation of the Department, shall certifythat all information contained in such
document is true. All application facts certified to by the applicant shall be considered valid conditions
of the permit issued pursuant to the application.
Any person who knowingly makes any false statement, representation, or certification in any application,
record, report, or other documents filed with the Department pursuant to the State law, and the rules
and regulations pursuant to that law, shall be deemed to have violated a permit condition and shall be
subject to the penalties provided for pursuant to 48-1-320 or 48-1-330.

Part III. Limitations and Monitoring Requirements
A. Effluent Limitations and Monitoring Requirements
1. During the period beginning on the effective date of this permit and lasting through the expiration date, the permittee is authorized to discharge
from outfall serial number 001: Cooling tower blowdown, boiler blowdown, and air conditioning condensate.
Such discharge shall be limited and monitored by the permittee as specified below:
EFFLUENT CHARACTERISTICS
DISCHARGE LIMITATIONS
MONITORING REQUIREMENTS
Mass
Concentration
Monthly
Average
Daily
Maximum
Monthly
Average
Daily
Maximum
Sampling
Frequency
Sample Type
Flow
MR', MGD
MR, MGD
-
-
1/Quarter
Estimate'
pH
-
-
Min 6.0 su, Max 9.0 su3
1 /Quarter
Grab
Biochemical Oxygen Demand
(BODs)
-
-
10 mg/I
20 mg/I
1/Quarter
Grab
Total Suspended Solids (TSS)
-
-
40 mg/I
40 mg/I
1/Quarter
Grab
Temperature
-
-
-
90OF
1/Quarter
Grab
' MR: Monitor and Report
'See Part II.J.1
3See Part I.M.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s): after
treatment but prior to mixing with the receiving stream.
-0 -0 -0
rD Q, Q,
M -
3 m —
N =
Z
O O0
In W
rn 00
0
0
0
N

2. During the period beginning on the effective date of this permit and lasting through the expiration date, the permittee is authorized to discharge
from outfall serial number 002: Sanitary wastewater
Such discharge shall be limited and monitored by the permittee as specified below:
EFFLUENT CHARACTERISTICS
DISCHARGE LIMITATIONS
MONITORING REQUIREMENTS
Mass
Concentration
Monthly
Average
Daily
Maximum
Monthly
Average
Daily
Maximum
Sampling
Frequency
Sample Type
Flow
MR', MGD
MR', MGD
-
-
Daily
ContinUOUS2
pH
-
-
Min 6.0 su, Max 9.0 su3
Weekdays
Grab
Biochemical Oxygen Demand
(BODs)
1.45 Ibs/day
2.9 Ibs/day
30 mg/I
60 mg/I
2/Month
24 Hr. Composite
Total Suspended Solids (TSS)
3.8 Ibs/day
7.5 Ibs/day
30 mg/I
60 mg/I
2/Month
24 Hr. Composite
Dissolved Oxygen
_
1.0 mg/I minimum
at all times
Weekdays
Grab
E. Coli
-
-
126/100 ml
349/100 ml
2/Month
Grab
Total Residual Chlorine
-
-
0.5 mg/I
1.0 mg/1
2/Month
Grab
' MR: Monitor and Report
ZSee Part II.J.1
3See Part I.M.
4TRC shall be monitored after the sanitary wastewater and cooling water combine, but prior to mixing with the receiving stream.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s): after
treatment but prior to mixing with the receiving stream.
-0 -0 -0
rD v v
M -
3 m —
N =
z o
o +,
vi w
rn 00
0
0
0
N

3.a. TIER 1 - Production: 25,000 Ibs/day to 32,142 Ibs/day (midpoint 28,571 Ibs/day)
During the period beginning on the effective date of this permit and lasting through the expiration date or the initiation of an alternate production
level (see Part V.E.5), the permittee is authorized to discharge from outfall serial number 003: process wastewater
Such discharge shall be limited and monitored by the permittee as specified below:
EFFLUENT CHARACTERISTICS
DISCHARGE LIMITATIONS
MONITORING REQUIREMENTS
Mass
Concentration
Monthly
Average
Daily
Maximum
Monthly
Average
Daily
Maximum
Sampling
Frequency
Sample Type
Flow
MR', MGD
MR', MGD
-
-
Daily
Continuous'
pH'
-
-
Min 6.0 su, Max 8.5 su3
2/Month
Grab
Biochemical Oxygen Demand (BODs)
54.3 Ibs/day
105.7 Ibs/day
23.4 mg/I
46.8 mg/I
2/Month
24 Hr. Composite
Chemical Oxygen Demand (COD)
1263 Ibs/day
1963 Ibs/day
-
2/Month
24 Hr. Composite
Total Suspended Solids (TSS)
182.9 Ibs/day
411.4 Ibs/day
-
2/Month
24 Hr. Composite
Dissolved Oxygen
-
1.0 mg/I minimum at all times
2/Month
Grab
Sulfide, Total as S6,'
2.9 Ibs/day
5.7 Ibs/day
MR', mg/I
MR', mg/I
2/Month
Grab
Hydrogen Sulfide, Un-ionizeds,'
-
-
0.1225 mg/I
0.245 mg/I
2/Month
Calculation
Temperatures'
-
-
MR', °C
MR', °C
2/Month
Grab
Phenols, Total
1.4 Ibs/day
2.9 Ibs/day
-
2/Month
Grab
Chromium, Total
1.4 Ibs/day
2.9 Ibs/day
-
2/Month
24 Hr. Composite
Ammonia - Nitrogen, Total as N6
-
-
MR', mg/I
MR', mg/I
1/Month
24 Hr. Composite
Nitrogen, Tota16
MR', Ibs/day
MR', Ibs/day
MR', mg/I
MR', mg/I
1/Month
Calculation
Total Kjeldahl Nitrogen (TKN)6
MR', Ibs/day
MR', Ibs/day
MR', mg/I
MR', mg/I
1/Month
24 Hr. Composite
Nitrate -Nitrite as Nitrogen6
MR', Ibs/day
MR', Ibs/day
MR', mg/I
MR', mg/I
1/Month
24 Hr. Composite
Phosphorus, Total6
-
-
MR', mg/I
MR', mg/I
1/Month
24 Hr. Composite
Color, (Upstream)s,6,a,9,,2
_
-
MR', CU4(Instantaneous max)
1/Month
Grab
Color, (Effluent)5,6.8
-
-
MR', CU4(Instantaneous max)
1/Month
Grab
Color, (Downstream)s,6,a,1o,12
_
-
MR', CU4(Instantaneous max)
1/Month
Grab
Color, (Difference)',6,8,","
_
-
40 CU4(Instantaneous max)
1/Month
Calculation
v v v
rD v v
I O-q
ro
fv =
z rj
o a
v, w
n 00
0
0
0
fv
rn

Total PFAS Compounds, (Effluent)5,13
-
-
MR', ng/I
MR', ng/I
1/Month
Grab
Total PFAS Compounds, (Source
-
-
MR', ng/I
MR', ng/I
1/Month
Grab
Water)1,13
Total PFAS Compounds,
-
-
MR', n /I
g
MR', n /I
g
1/Month
Calculation
(Difference)5,13
'MR: Monitor and Report
2See Part II.J.1
3See Part I.M.
ICU: Color Units
5See V.A.S
6See V.A.6
'pH and Temperature field measurements are to be taken at the same time as the Sulfide sample for use in calculating Un-ionized Hydrogen Sulfide.
$See V.A.7
'The ambient upstream sample point is defined as a point upstream of the discharge away from any possible effect of the discharge.
10The downstream sample shall be representative and taken at point after substantial to complete mixing of the effluent plume with the stream.
"The color difference shall be calculated as Downstream color minus Upstream color.
12Upstream and downstream color samples shall be taken at the same time (within 60 minutes) for use in calculating color difference.
13PFAS compounds shall be sampled by grab sample and analyzed by a certified laboratory (NELAC, EPA, Certified Laboratories in Connecticut, New Hampshire, and New
Jersey or other Lab approved by a State Laboratory Certification Program as approved by the Department). PFAS compounds shall be analyzed using the most recent draft
of EPA Method 1633 until it is finalized, and then the final, published method shall be used. The certified laboratory shall use the lowest PQL they can achieve. The results
of each individual PFAS compound shall be reported using the 'DMR Attachment (Other than Toxicity or Bacteria)' schedule in ePermitting each month when the DMR is
submitted. The effluent sampling shall meet the scheduling requirements of Part V.E.2 of this permit, but to obtain a more accurate calculation of the concentration
difference (effluent - source water), the source water shall be sampled prior to the effluent by an amount of time approximately equal to the time for the water to pass
through the manufacturing processes and the wastewater treatment plant. See also Part V.A.3.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s): after
treatment but prior to mixing with the receiving stream.
-0 -0 -0
rD a) a)
(o
N =
z w
o a
Ul w
n 00
0
0
0
N

3.b. TIER 2 - Production: 32,143 Ibs/day to 39,285 Ibs/day (midpoint 35,714 Ibs/day)
During the period beginning on the effective date of this permit and lasting through the expiration date or the initiation of an alternate production
level (see Part V.E.5), the permittee is authorized to discharge from outfall serial number 003: process wastewater
Such discharge shall be limited and monitored by the permittee as specified below:
EFFLUENT CHARACTERISTICS
DISCHARGE LIMITATIONS
MONITORING REQUIREMENTS
Mass
Concentration
Monthly
Average
Daily
Maximum
Monthly
Average
Daily
Maximum
Sampling
Frequency
Sample Type
Flow
MR', MGD
MR', MGD
-
-
Daily
Continuous'
pH'
-
-
Min 6.0 su, Max 8.5 su3
2/Month
Grab
Biochemical Oxygen Demand (BODs)
67.9 Ibs/day
132.1 Ibs/day
23.4 mg/I
46.8 mg/I
2/Month
24 Hr. Composite
Chemical Oxygen Demand (COD)
1579 Ibs/day
2454 Ibs/day
-
2/Month
24 Hr. Composite
Total Suspended Solids (TSS)
228.6 Ibs/day
514.3 Ibs/day
-
2/Month
24 Hr. Composite
Dissolved Oxygen
-
1.0 mg/I minimum at all times
2/Month
Grab
Sulfide, Total as S6,'
3.6 Ibs/day
7.1 Ibs/day
MR', mg/I
MR', mg/I
2/Month
Grab
Hydrogen Sulfide, Un-ionizeds,'
-
-
0.1225 mg/I
0.245 mg/I
2/Month
Calculation
Temperatures'
-
-
MR', °C
MR', °C
2/Month
Grab
Phenols, Total
1.8 Ibs/day
3.6 Ibs/day
-
2/Month
Grab
Chromium, Total
1.8 Ibs/day
3.6 Ibs/day
-
2/Month
24 Hr. Composite
Ammonia - Nitrogen, Total as N6
-
-
MR', mg/I
MR', mg/I
1/Month
24 Hr. Composite
Nitrogen, Tota16
MR', Ibs/day
MR', Ibs/day
MR', mg/I
MR', mg/I
1/Month
Calculation
Total Kjeldahl Nitrogen (TKN)6
MR', Ibs/day
MR', Ibs/day
MR', mg/I
MR', mg/I
1/Month
24 Hr. Composite
Nitrate -Nitrite as Nitrogen6
MR', Ibs/day
MR', Ibs/day
MR', mg/I
MR', mg/I
1/Month
24 Hr. Composite
Phosphorus, Total6
-
-
MR', mg/I
MR', mg/I
1/month
24 Hr. Composite
Color, (Upstream)s,6,a,9,,z
_
-
MR', CU4(Instantaneous max)
1/Month
Grab
Color, (Effluent)5,6.8
-
-
MR', CU4(Instantaneous max)
1/Month
Grab
Color, (Downstream)s,6,a,1o,1z
_
-
MR', CU4(Instantaneous max)
1/Month
Grab
Color, (Difference)',6,8,","
_
-
40 CU4(Instantaneous max)
1/Month
Calculation
v v v
rD v v
I O-q
ro
fv =
z �
o a
v, w
n 00
0
0
0
fv
rn

Total PFAS Compounds, (Effluent)5,13
-
-
MR', ng/I
MR', ng/I
1/Month
Grab
Total PFAS Compounds, (Source
-
-
MR', ng/I
MR', ng/I
1/Month
Grab
Water)1,13
Total PFAS Compounds,
-
-
MR', n /I
g
MR', n /I
g
1/Month
Calculation
(Difference)5,13
'MR: Monitor and Report
2See Part II.J.1
3See Part I.M.
ICU: Color Units
SSee V.A.S
6See V.A.6
'pH and Temperature field measurements are to be taken at the same time as the Sulfide sample for use in calculating Un-ionized Hydrogen Sulfide.
$See V.A.7
'The ambient upstream sample point is defined as a point upstream of the discharge away from any possible effect of the discharge.
10The downstream sample shall be representative and taken at point after substantial to complete mixing of the effluent plume with the stream.
"The color difference shall be calculated as Downstream color minus Upstream color.
12Upstream and downstream color samples shall be taken at the same time (within 60 minutes) for use in calculating color difference.
13PFAS compounds shall be sampled by grab sample and analyzed by a certified laboratory (NELAC, EPA, Certified Laboratories in Connecticut, New Hampshire, and New
Jersey or other Lab approved by a State Laboratory Certification Program as approved by the Department). PFAS compounds shall be analyzed using the most recent draft
of EPA Method 1633 until it is finalized, and then the final, published method shall be used. The certified laboratory shall use the lowest PQL they can achieve. The results
of each individual PFAS compound shall be reported using the 'DMR Attachment (Other than Toxicity or Bacteria)' schedule in ePermitting each month when the DMR is
submitted. The effluent sampling shall meet the scheduling requirements of Part V.E.2 of this permit, but to obtain a more accurate calculation of the concentration
difference (effluent - source water), the source water shall be sampled prior to the effluent by an amount of time approximately equal to the time for the water to pass
through the manufacturing processes and the wastewater treatment plant. See also Part V.A.3.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s): after
treatment but prior to mixing with the receiving stream.
-0 -0 -0
rD a) a)
(o
N =
z `J'
o a
Ul w
n 00
0
0
0
N

3.c. TIER 3 - Production: 39,286 Ibs/day to 46,428 Ibs/day (midpoint 42,857 Ibs/day)
During the period beginning on the effective date of this permit and lasting through the expiration date or the initiation of an alternate production
level (see Part V.E.5), the permittee is authorized to discharge from outfall serial number 003: process wastewater
Such discharge shall be limited and monitored by the permittee as specified below:
EFFLUENT CHARACTERISTICS
DISCHARGE LIMITATIONS
MONITORING REQUIREMENTS
Mass
Concentration
Monthly
Average
Daily
Maximum
Monthly
Average
Daily
Maximum
Sampling
Frequency
Sample Type
Flow
MR', MGD
MR', MGD
-
-
Daily
Continuous'
pH'
-
-
Min 6.0 su, Max 8.5 su3
2/Month
Grab
Biochemical Oxygen Demand (BODs)
81.4 Ibs/day
158.6 Ibs/day
23.4 mg/I
46.8 mg/I
2/Month
24 Hr. Composite
Chemical Oxygen Demand (COD)
1894 Ibs/day
2944 Ibs/day
-
2/Month
24 Hr. Composite
Total Suspended Solids (TSS)
274.3 Ibs/day
617.1 Ibs/day
-
2/Month
24 Hr. Composite
Dissolved Oxygen
-
1.0 mg/I minimum at all times
2/Month
Grab
Sulfide, Total as S6,'
4.3 Ibs/day
8.6 Ibs/day
MR', mg/I
MR', mg/I
2/Month
Grab
Hydrogen Sulfide, Un-ionizeds,'
-
-
0.1225 mg/I
0.245 mg/I
2/Month
Calculation
Temperatures'
-
-
MR', °C
MR', °C
2/Month
Grab
Phenols, Total
2.1 Ibs/day
4.3 Ibs/day
-
-
2/Month
Grab
Chromium, Total
2.1 Ibs/day
4.3 Ibs/day
-
-
2/Month
24 Hr. Composite
Ammonia - Nitrogen, Total as N6
-
-
MR', mg/I
MR', mg/I
1/Month
24 Hr. Composite
Nitrogen, Tota16
MR', Ibs/day
MR', Ibs/day
MR', mg/I
MR', mg/I
1/Month
Calculation
Total Kjeldahl Nitrogen (TKN)6
MR', Ibs/day
MR', Ibs/day
MR', mg/I
MR', mg/I
1/Month
24 Hr. Composite
Nitrate -Nitrite as Nitrogen6
MR', Ibs/day
MR', Ibs/day
MR', mg/I
MR', mg/I
1/Month
24 Hr. Composite
Phosphorus, Total6
-
-
MR', mg/I
MR', mg/I
1/month
24 Hr. Composite
Color, (Upstream)s,6,a,9,,z
_
-
MR', CU4(Instantaneous max)
1/Month
Grab
Color, (Effluent)5,6.8
-
-
MR', CU4(Instantaneous max)
1/Month
Grab
Color, (Downstream)s,6,a,1o,1z
_
-
MR', CU4(Instantaneous max)
1/Month
Grab
Color, (Difference)',6,8,","
_
-
40 CU4(Instantaneous max)
1/Month
Calculation
v v v
rD v v
I O-q
ro
fv =
z rn
o a
v, w
n 00
0
0
0
fv
rn

Total PFAS Compounds, (Effluent)5,13
-
-
MR', ng/I
MR', ng/I
1/Month
Grab
Total PFAS Compounds, (Source
-
-
MR', ng/I
MR', ng/I
1/Month
Grab
Water)1,13
Total PFAS Compounds,
-
-
MR', n /I
g
MR', n /I
g
1/Month
Calculation
(Difference)5,13
'MR: Monitor and Report
2See Part II.J.1
3See Part I.M.
ICU: Color Units
5See V.A.S
6See V.A.6
'pH and Temperature field measurements are to be taken at the same time as the Sulfide sample for use in calculating Un-ionized Hydrogen Sulfide.
$See V.A.7
'The ambient upstream sample point is defined as a point upstream of the discharge away from any possible effect of the discharge.
10The downstream sample shall be representative and taken at point after substantial to complete mixing of the effluent plume with the stream.
"The color difference shall be calculated as Downstream color minus Upstream color.
12Upstream and downstream color samples shall be taken at the same time (within 60 minutes) for use in calculating color difference.
13PFAS compounds shall be sampled by grab sample and analyzed by a certified laboratory (NELAC, EPA, Certified Laboratories in Connecticut, New Hampshire, and New
Jersey or other Lab approved by a State Laboratory Certification Program as approved by the Department). PFAS compounds shall be analyzed using the most recent draft
of EPA Method 1633 until it is finalized, and then the final, published method shall be used. The certified laboratory shall use the lowest PQL they can achieve. The results
of each individual PFAS compound shall be reported using the 'DMR Attachment (Other than Toxicity or Bacteria)' schedule in ePermitting each month when the DMR is
submitted. The effluent sampling shall meet the scheduling requirements of Part V.E.2 of this permit, but to obtain a more accurate calculation of the concentration
difference (effluent - source water), the source water shall be sampled prior to the effluent by an amount of time approximately equal to the time for the water to pass
through the manufacturing processes and the wastewater treatment plant. See also Part V.A.3.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s): after treatment but prior
to mixing with the receiving stream.
-0 -0 -0
rD a) a)
(o
N =
o a
Ul w
n 00
0
0
0
N

Part III
Page 28 of 38
Permit No. SC0002496
B. Whole Effluent Toxicity and Other Biological Limitations and Monitoring Requirements
1. During the period beginning on the effective date of this permit and lasting until the expiration date of
this permit, the permittee is authorized to discharge from outfall 003 (all tiers): process wastewater.
Such discharge shall be limited and monitored by the permittee as specified below:
EFFLUENT
DISCHARGE
MONITORING
CHARACTERISTICS
LIMITATIONS
REQUIREMENTS
Monthly
Daily
Measurement
Sample
Average
Maximum
Frequency
Type
Ceriodaphnia dubia
Acute Whole Effluent
-
0*
1/month
24-hour
Toxicity
composite
@ATC=7.8%
* See Part V.13.1. Report "0" if test passes or "1" if test fails in accordance with Part V.13.1.
a. Samples taken in compliance with the monitoring requirements specified above shall be taken at the
following locations: at or near the discharge, but prior to mixing with the receiving waters.

Part III
Page 29 of 38
Permit No. SC0002496
2. During the period beginning on the effective date and lasting through the expiration date, the permittee
is authorized to discharge from outfall 003 (all tiers): process wastewater.
Such discharge shall be limited and monitored by the permittee as specified below:
DISCHARGE
MONITORING
EFFLUENT
LIMITATIONS
REQUIREMENTS
CHARACTERISTICS
Daily
Monthly
Daily
Measurement
Sample Type
Minimum
Average
Maximum
Frequency
Ceriodaphnia dubia
Chronic Whole Effluent
24-hour
Toxicity
25 %
40 %
1/month
composite'
@ CTC = 6.9%
Ceriodaphnia dubia
2
LC50 - 48-hour Acute
MR
-
-
1/month
Calculated
Ceriodaphnia dubia
MR
-
-
1/month
Calculated
IC25 - 7-day Chronic
See Part V.13.2 for additional toxicity reporting requirements.
MR = Monitor and Report.
' See Part 1.E.
2 The permittee shall report the LC50 at 48-hours from the chronic WET test.
The following notes apply only to valid tests. For invalid tests see Part V.13.2.
Note 1: The overall % effect is defined as the larger of the % survival effect or the % reproduction effect.
Note 2: If only one test is conducted during a month, the monthly average and daily maximum are each
equal to the overall % effect.
Note 3: If more than one test is conducted during a month, the monthly average is the arithmetic mean of
the overall % effect values of all tests conducted during the month.
Note 4: The monthly average to be reported on the DMR is the highest monthly average for any month
during the monitoring period. There is no averaging of data from tests from one month to another.
Note 5: The daily maximum to be reported on the DMR is the highest of the % survival effect or
reproduction effect of all tests conducted during the monitoring period.
Note 6: The daily minimum to be reported on the DMR is the minimum IC25 and LC50 of all tests conducted
during the monitoring period.

Part III
Page 30 of 38
Permit No. SC0002496
Note 7: When a sample is collected in one month and the test is completed in the next month, the overall
effect applies to the month in which the sample was collected.
Note 8: Tests must be separated by at least 7 days (from the time the first sample is collected to start one
test until the time the first sample is collected to start a different test). There is no restriction on
when a new test may begin following a failed or invalid test.
Note 9: For any split sample:
a. Determine the % survival effect and % reproduction effect values separately for each test.
b. Determine the arithmetic mean of the % survival effects and of the % reproduction effects for
a I I tests.
c. The monthly average and daily maximum shall be the higher of the % effect values from (b)
above.
d. For the IC25 and the LC50, the daily minimum is the lowest average value recorded of samples
collected on any single day during the calendar month.e. For the purposes of reporting, split
samples are reported as an individual sample regardless of the number of times it is split. All
laboratories used shall be identified on the DMR and each test shall be reported individually on
the DMR Attachment for Whole Effluent Toxicity Results (in ePermitting).
a. Samples used to demonstrate compliance with the discharge limitations and monitoring
requirements specified above shall be taken at or near the final point -of -discharge but prior to mixing
with the receiving waters or other waste streams.
C. Groundwater Monitoring Requirements
Not applicable to this permit.
D. Sludge Monitoring Requirements
Not applicable to this permit.
E. Soil Monitoring Requirements
Not applicable to this permit.

Part IV
Page 31 of 38
Permit No. SC0002496
Part IV. Schedule of Compliance
A. Schedule(s)
Not applicable to this permit.
B. Reports of compliance or noncompliance with, or any progress reports on, interim and final requirements
contained in any compliance schedule of this permit shall be submitted no later than 14 days following
each scheduled date.

Part V
Page 32 of 38
Permit No. SC0002496
Part V. Other Requirements
A. Effluent Requirements
1. There shall be no discharge of floating solids or visible foam in other than trace amounts, nor shall the
effluent cause a visible sheen on the receiving waters.
2. Unless authorized elsewhere in this permit, the permittee must meet the following requirements
concerning maintenance chemicals for the following waste streams: once -through noncontact cooling
water, cooling tower blowdown or recirculated cooling water, boiler blowdown, and air washer water.
Maintenance chemicals shall be defined as any man -induced additives that may be added to the
referenced waste streams.
a. Detectable amounts of any of the one hundred and twenty-six priority pollutants is prohibited in the
discharge, if the pollutants are present due to the use of maintenance chemicals.
b. Slimicides, algicides and biocides are to be used in accordance with registration requirements of the
Federal Insecticides, Fungicide and Rodenticide Act.
c. The use of maintenance chemicals containing bis(tributyltin) oxide is prohibited.
d. Any maintenance chemicals added must degrade rapidly, either due to hydrolytic decomposition or
biodegradation.
e. Discharges of maintenance chemicals added to waste streams must be limited to concentrations
which protect indigenous aquatic populations in the receiving stream.
f. The permittee must keep the following documentation on -site for each maintenance chemical used.
The information shall be made available for on -site review by Department personnel during normal
working hours.
i. Safety Data Sheets (SDS) including name, general composition, and aquatic toxicity information
(i.e., NOEC or LC50) for each chemical used;
ii. Quantity of each chemical used,
iii. Frequency and location of use (including outfall to which it flows), and
iv. Information, samples and/or calculations which demonstrate compliance with items (a) - (e)
above.
g. The permittee shall submit the information in (f) above with each permit renewal application.
h. The Department may request submittal of the information in (f) above at any time to determine
permit compliance and may modify this permit to include additional monitoring and/or limitations
as necessary to protect water quality.

Part V
Page 33 of 38
Permit No. SC0002496
3. The following PFAS benchmark differentials apply to the Outfall 003 discharge:
b. A monthly average effluent PFAS concentration at or above 15 ng/I higher than the corresponding
monthly average source water PFAS concentration for three months in a row will indicate that PFAS
has been discharged above concentrations expected to be in the source water for any specific
compound and/or
c. A daily maximum PFAS concentration difference at or above 30 ng/I higher than the corresponding
daily maximum source water PFAS concentration will indicate PFAS has been discharged above
concentrations expected to be in the source water for any specific compound.
If at any time one or both of the above benchmarks are exceeded, the permittee shall develop and
submit a PFAS Evaluation and Reduction report to the Department within 60 days from the date of the
DMR submittal documenting the exceedance. Exceeding the benchmark differential is not considered
permit noncompliance or a permit violation as long as the permittee submits a timely PFAS Evaluation
and Reduction report.
4. Within 2 years of the commencement of discharge from outfall 003, the permittee must fully complete
and submit Sections 7, 8, 10, and 12, and Tables A, B, C, D, and E of EPA Application Form 2C for outfall
003.
5. If reasonable potential is determined not to exist for hydrogen sulfide and color based on two years of
data collected at the sampling frequency stated in Part III, this permit may be reopened to eliminate
monitoring requirements and/or limitations for hydrogen sulfide, temperature, and color. The permit
may also be reopened to reduce the monitoring frequency for chromium based on two years of data
collected at the sampling frequency specified in Part III. Additional monitoring and/or limitations may
be added to the permit by modification if the discharge causes, has the reasonable potential to cause or
contributes to an instream water quality violation. Additional monitoring and/or limitations for PFAS
may be added to the permit by modification if federal PFAS requirements are promulgated and are
applicable to this facility.
6. Where the permit limitation in Part III is below the practical quantitation limit (PQL), the PQL and
analytical method stated below shall be considered as being in compliance with the permit limit.
Additionally, where the permit requires only monitoring and reporting (MR) in Part III, the PQL and
analytical method stated below shall be used for reporting results.
Parameter
Analytical Method',Z
PQL',3
Ammonia
Sufficiently Sensitive Test Method in 40
100 ug/I
CFR Part 136
Phosphorus, Total
Sufficiently Sensitive Test Method in 40
50 ug/I
CFR Part 136
TKN
Sufficiently Sensitive Test Method in 40
100 u /I
8
CFR Part 136
Nitrate -Nitrite
Sufficiently Sensitive Test Method in 40
20 ug/I
CFR Part 136

Part V
Page 34 of 38
Permit No. SC0002496
Sulfide, Total
Sufficiently Sensitive Test Method in 40
CFR Part 136
100 ug/I
Sufficiently Sensitive Test Method in 40
Color
25 CU
CFR Part 136
The most recent draft of EPA Method 1633
The certified laboratory
Total PFAS
until it is finalized, and then the final,
shall use the lowest
Compounds
published method shall be used.
PQL they can achieve.
Notes:
See Part II.JA.
2The permittee may use another approved analytical method from the most recent version of 40 CFR Part 136
provided the SCDHEC-certified laboratory performing the analysis can achieve a PQL equal to, or lower than, the
PQL listed above. The Permittee must receive written approval from the Department prior to using a method other
than those specified above.
3 If the permittee is using a PQL below the PQL listed above, then for purposes of reporting, the lower PQL shall be
used in accordance with Part II.J.4.b.
4 Since there is no EPA -approved method to directly measure Total Nitrogen, Total Nitrogen should be reported as a
sum of the values of Total Kjeldhal Nitrogen (TKN) and Nitrate -Nitrite Nitrogen analytical results.
7. The most recent version of the American Dye Manufacturers Institute (ADMI) Tristimulus Filter Method,
as identified in 40 CFR Part 136, shall be used in measuring the color levels. Prior to determining the
color, turbidity should be removed by filtration through a membrane filter having a pore size of 0.45
microns. The filter used must be the non -wetted variety. The Department may reopen the permit
anytime during the duration of this permit to include color limitations if the color of the discharge is a
concern to the public and environment.
B. Whole Effluent Toxicity and Other Biological Requirements
1. For the requirements identified in Part III.B.1:
a. A 48-hour static acute toxicity test shall be conducted at the frequency stated in Part III.B Effluent
Toxicity Limitations and Monitoring Requirements using a control and the acute test concentration
(ATC) of 7.8%. The test shall be conducted using Ceriodaphnia dubia as the test organism using EPA
Method 2002.0 in accordance with "Methods for Measuring the Acute Toxicity of Effluents to
Freshwater and Marine Organisms," EPA 821/R-02/012 (October 2002). The test shall be conducted
at 250C ±1 °C.
b. If the test group Ceriodaphnia dubia survival is less than the control group survival at the 0.05a level
of a left -tailed Fisher's exact test, the test shall be deemed a failure.
The permittee must report on the discharge monitoring report (DMR) whether the test passes or fails
at the specified ATC. If the test fails, the number "1" shall be placed on the DMR. If the test passes,
the number "0" shall be placed on the DMR. If more than one test is performed during a monitoring
period (including tests from split samples), the worst -case result shall be reported on the DMR. The
DMR Attachment for Whole Effluent Toxicity Results (in ePermitting) shall also be completed and
submitted concurrently with the DMR.

Part V
Page 35 of 38
Permit No. SC0002496
d. A test shall be invalidated if any part of Method 2002.0 is not followed or if the laboratory is not
certified at the time the test is conducted.
e. All valid toxicity test results shall be submitted on the DMR Attachment for Whole Effluent Toxicity
Results (in ePermitting) in accordance with Part II1.4. In addition, results from all invalid tests must
be included with this DMR Attachment, including lab control data. The permittee has sole
responsibility for scheduling toxicity tests so as to ensure there is sufficient opportunity to
complete and report the required number of valid test results for each monitoring period.
The permittee is responsible for reporting a valid test during each monitoring period. However, the
Department acknowledges that invalid tests may occur. All of the following conditions must be
satisfied for the permittee to be in compliance with Whole Effluent Toxicity (WET) testing
requirements for a particular monitoring period when a valid test was not obtained.
(1) A minimum of five (5) tests have been conducted which were invalid in accordance with Part V.B.1.d
above;
(2) The data and results of all invalid tests are to be submitted via the DMR Attachment for Whole
Effluent Toxicity Results (in ePermitting);
(3) At least one additional State -certified laboratory is used after two (2) consecutive invalid tests were
determined by the first laboratory. The laboratory ID number(s) of the additional lab(s) shall be
reported via the DMR Attachment for Whole Effluent Toxicity Results (in ePermitting) ; and
(4) A valid test was reported during each of the previous three reporting periods.
If these conditions are satisfied, the permittee may enter "*3" in the appropriate boxes on the
toxicity DMR and add the statement to the'General Reports Comments' section of the DMR that
"*3" indicates invalid tests."
g. This permit may be modified based on new information that supports a modification in accordance
with Regulation 61-9.122.62 and Regulation 61-68.D.
2. For the requirements identified in Part III.13.2:
a. A Ceriodaphnia dubia three brood chronic toxicity test shall be conducted at the frequency stated in
Part III.B.2, Effluent Toxicity Limitations and Monitoring Requirements, using the chronic test
concentration (CTC) of 6.9% and the following test concentrations: 0% (control), 2%, 4%, 6.9%, 13%
and 25% effluent. The permittee may add additional test concentrations without prior authorization
from the Department provided that the test begins with at least 10 replicates in each concentration
and all data is used to determine permit compliance.
b. The test shall be conducted using EPA Method 1002.0 in accordance with "Short -Term Methods for
Estimating Chronic Toxicity of Effluents and Receiving Waters to Freshwater Organisms," EPA/821 /R-
02/013 (October 2002).

Part V
Page 36 of 38
Permit No. SC0002496
c. The permittee shall use the linear interpolation method described in "Short -Term Methods for
Estimating Chronic Toxicity of Effluents and Receiving Waters to Freshwater Organisms," EPA/821/R-
02/013 (October 2002), Appendix M to estimate the percent effect at the CTC according to the
equations in d below.
d. The linear interpolation estimate of percent effect is 1— MCTC *100 if the CTC is a tested
M
M _ MJ+1 — Mi. * C + MJ+1 — MJ *CTC
concentration. Otherwise, it is 1— J CJ+1 — CJ J CJ+1 — CJ * 100.
M1
e. A test shall be invalidated if any part of Method 1002.0 is not followed or if the laboratory is not
certified at the time the test is conducted.
f. All valid toxicity test results shall be submitted via the DMR Attachment for Whole Effluent Toxicity
Results (in ePermitting) in accordance with Part II1.4. In addition, results from all invalid tests must
be included with this DMR Attachment, including lab control data. The permittee has sole
responsibility for scheduling toxicity tests so as to ensure there is sufficient opportunity to complete
and report the required number of valid test results for each monitoring period.
g. The permittee is responsible for reporting a valid test during each monitoring period. However, the
Department acknowledges that invalid tests may occur. All of the following conditions must be
satisfied for the permittee to be in compliance with Whole Effluent Toxicity (WET) testing
requirements for a particular monitoring period when a valid test was not obtained.
(1) A minimum of three (3) tests have been conducted which were invalid in accordance with Part
V.B.1.e above;
(2) The data and results of all invalid tests are to be submitted via the DMR Attachment for Whole
Effluent Toxicity Results (in ePermitting);
(3) At least one additional State -certified laboratory was used after two (2) consecutive invalid tests
were determined bythe first laboratory. The laboratory ID number(s) of the additional lab(s) shall
be reported via the DMR Attachment for Whole Effluent Toxicity Results (in ePermitting); and
(4) A valid test was reported during each of the previous three reporting periods.
If these conditions are satisfied, the permittee may enter "*3" in the appropriate boxes on the toxicity
DMR and add the statement to the'General Reports Comments' Section of the DMR that "*3 indicates
invalid tests."

Part V
Page 37 of 38
Permit No. SC0002496
h. This permit may be modified based on new information that supports a modification in accordance
with Regulation 61-9.122.62 and Regulation 61-68.D.
C. Groundwater Requirements
Not applicable to this permit.
D. Sludge Requirements
Sludge shall be disposed of at the Laurens Commission of Public Works (CPW) wastewater treatment
plant in Laurens, SC (NPDES Permit No. SC0020702) in accordance with the July 1, 2019 approval letter
from the CPW. Written approval from the Department must be obtained prior to disposal of other sludge
or use of other sludge disposal methods. The permittee shall apply in writing to the DHEC/Bureau of
Water requesting written approval for sludge disposal. A letter of acceptance from the facility that will
accept the sludge for disposal or reuse shall be included with the request.
E. Other Conditions
The permittee shall maintain an all weather access road to the wastewater treatment plant, land
application areas, and appurtenances at all times.
The permittee shall monitor all parameters consistent with conditions established by this permit on the
1 st Wednesday of every calendar month, unless otherwise approved by this Department. If no discharge
occurs on this day, the permittee shall collect an effluent sample during the reporting period on a day
when there is a discharge or report "no discharge" for the reporting period for all parameters. Additional
monitoring as necessary to meet the frequency requirements of this permit shall be performed by the
permittee.
The wastewater treatment plant shall be assigned a classification of Group III -Biological in the Permit to
Construct which is issued by the Department. This classification corresponds to an operator with a
Grade of B-Biological.
4. The permittee shall notify the affected downstream water treatment plant(s) of any emergency
condition, plant upset, bypass or other system failure which has the potential to affect the quality of
water withdrawn for drinking water purposes. This notification should be made as soon as possible and
in anticipation of such event, if feasible, without taking away from any response time necessary to
attempt to alleviate the situation.
5. Regarding outfall 003, and in accordance with Regulation 61-9.122.45(b)(2)(ii)(B):
a. The permittee must notify the Department at least two business days prior to a month in which the
permittee expects to operate at a production level higher than the lowest production range identified

Part V
Page 38 of 38
Permit No. SC0002496
in the permit. The notice shall specify the anticipated production level and the period during which
the permittee expects to operate at the alternate production level. If the notice covers more than
one month, the notice shall specify the reasons for the anticipated production level increase. New
notice of discharge at alternate production levels is required to cover a period or production level
not covered by prior notice or, if during two consecutive months otherwise covered by a notice, the
production level at the permitted facility does not in fact meet the higher production level designated
in the notice. The notice shall be submitted via the Supplemental Information schedule in
ePermitting.
b. The permittee shall comply with the limitations, standards, or prohibitions that correspond to the
lowest production range specified in the permit, unless the permittee has notified the Department
under Part V.E.5.a of this section, in which case the permittee shall comply with the lower of the
actual production level during each month or the production level specified in the notice.
c. The permittee shall submit with the DMR the production level that actually occurred during each
month and the limitations, standards, or prohibitions applicable to that production level.
d. Unless the Department is notified to the contrary in accordance with V.E.5.a above, the discharge
limitations for outfall 003 (Tier 1) shall be effective upon the effective date of this permit. The
applicable limits pages are listed below with the production ranges that correspond to these limits.
Note that the other limitations pages go into effect based on the conditions in V.E.5.a through V.E.5.c
above. (The limits on pages 25 and 26 apply to all tiers, as do the other requirements of the permit.)
Tier Production Range Permit Pages
1 25,000 Ibs/day to 32,142 Ibs/day 22
2 32,143 Ibs/day to 39,285 Ibs/day 24
3 39,286 Ibs/day to 46,428 Ibs/day 26
If the permittee samples any parameter(s) in this permit less frequently than once per month, the
permittee should use the appropriate DMR form to match the tier which was active when sampling
was conducted.
6. The permittee acknowledges the permit shield only applies where the discharge of pollutants are adequately
disclosed and within the reasonable contemplation of the permitting authority at the time the permit was issued.

FACT SHEET
AND
PERMIT RATIONALE
Inman Mills/Ramey Plant
NPDES Permit No. SCOOO2496
Permitting Engineer: Randy Thompson/Melanie Townley
Facility Rating: ® Major ❑ Minor
❑ Issuance (New) ❑ Reissuance ® Modification
/dhec
❑ Minor Modification
November 8, 2022
****NOTE****The purpose of this rationale is to address a major permit modification to add outfall 003 to the
NPDES permit. Outfall 003 will discharge new process wastewaters resulting from the facility's expansion into the
dyeing and finishing of textiles. The new additional flow from the dyeing and finishing processes will result in the
facility rating changing from minor to major.
If any part of this application is for a new facility or expansion of an existing facility or increase in permitted limits,
an antidegradation review may be required per the requirements of R.61-68.D. If required, the antidegradation
review will be included as part of the permit application.
Site Address: Hwy 221, Enoree, SC 29335
County: Spartanburg
Watershed: Basin 05 (Broad River Basin)
Facility Description (include SIC code): This facility has been a non -finishing textile manufacturer (SIC Code is 2221),
but is now expanding into textile finishing and dyeing (SIC Codes 2261 and 2262).
Receiving Waters and Classification by outfall: 001, 002, and 003 - Enoree River (FW) Is any discharge to Impaired
Waters? Yes (see State 303(d) list for impaired waters)
If Yes, list the monitoring station number(s) and parameter(s) causing impairment: BE-019 Macroinvertebrates
Is any discharge to a waterbody or for a parameter listed in an approved TMDL? Yes
If Yes, list the parameter(s) for which the TMDL is written and the waterbody segments impacted: Fecal coliform on
the Enoree River
Does any discharge have the potential to affect a threatened or endangered species? No
If Yes, list the species and the waterbody in which the species resides: N/A
Outfalls are discussed in Section I of this rationale with a general description of the discharge, treatment system,
stream flows and other pertinent information about each outfall.
EPA review of the draft permit is required if any box below is checked (Mark all that apply)
❑ Permits with discharges which may affect the waters of another State (Coordination with the other State is also
required)
List State and name of waterbody(ies) that reach affected state: N/A
® Major permits
® Permits with any discharge subject to any of the primary industrial categories (see R.61-9.122, Appendix A)
® Permits with any discharge of process wastewater with an average flow exceeding 0.5 MGD
❑ Permits which incorporate pollutant trading
❑ Priority permits

Rationale
Page 2 of 49
Permit No. SC0002496
® Modification(s) to any permit listed above or a mod that changes a permit to put it into one of the above
categories (where it previously was not)
List of Attachments to this Rationale:
Attachment 1
Permit Application
Attachment 2
Water Quality Spreadsheets
Attachment 3
Map of Drinking Water Intake/Source Water Protection Area Relative to Discharge
Attachment 4
Wasteload Allocation
I. PERMIT LIMITATIONS AND MONITORING REQUIREMENTS
Outfall 001/002 (Outfall 003 is addressed separately below.)
Description of outfall, receiving water and wastewater treatment system: Inman Mills/Ramey Plant produces greige
flat fabrics of cotton, polyester, rayon, and blends. Greige goods are materials that are woven or knit, but not
finished. The plant recycles a minimal amount of their slashing/sizing process wastewaters, but pumps and hauls
the bulk of the process wastewater to the Town of Ware Shoals Dairy Street Wastewater Treatment Plant under
LOA-006451. Wastewater covered by this permit includes sanitary wastewater and utility water (boiler blowdown,
cooling tower blowdown and air conditioning condensate). Wastewater treatment consists of an aerated lagoon for
utility wastewater and a small package plant for the sanitary wastewater treatment including one aeration basin,
one clarifier, a chlorine contact chamber, and dechlorination. The treated utility wastewater from Outall 001 is
combined with the treated sanitary wastewater from Outfall 002 prior to discharge to the Enoree River.
Operator requirements: Based on the treatment system described above and the Pollution Control Act (PCA), the
treatment system is classified as Group III -Biological. The Environmental Certification Board Rules require that a
Grade B-Biological operator be assigned to operate this facility. Inspections of the facility will be required on a daily
basis per Regulation 61-9.122.41(e).
40 CFR Part 410 contains the Effluent Limitation Guidelines for the Textile Mills Point Source Category. The
Applicability section, 410.00, states that this part is applicable only to facilities that discharge process wastewater.
Because outfalls 001 and 002 do not discharge process wastewater, the Effluent Limitation Guidelines of 40 CFR
Part 410 do not apply to these outfalls.
Data from Discharge Monitoring Reports (DMRs) and NPDES permit application (including all subsequent data
presented) from 2/1/2015-11/30/2019 has been used to evaluate permit limitations.
These outfalls are within a state -approved source water protection area (SWPA) for a surface water drinking water
intake and has the potential to affect the intake. The affected intake(s) (Intake #530104) is owned by the City of
Clinton. The 7Q10 and AAF to be used for permitting MCL and water/organism criteria are given on the
spreadsheet. Additional information on source water protection is provided in sections III.B and G of this rationale.
Previous permit limits are based on the permit (or modification) effective date of 2/1/2015.
All waterbody data is provided on the attached Water Quality Spreadsheets. This data includes 7Q10, annual
average flow, dilution factors, hardness, TSS and other information as explained in this rationale. Additional
information as necessary to explain the values used will be provided below.

Rationale
Page 3 of 49
Permit No. SC0002496
Outfall 001
The discharge from Outfall 001 consists of utility water including boiler blowdown, cooling tower blowdown, and air
conditioning condensate water. The permittee reported the following flows expected for these wastewaters.
Boiler Blowdown 0.0084 MGD
Air Conditioning condensate 0.0028 MGD
Cooling Tower Blowdown 0.0028 MGD
Information for this outfall is based on NPDES Permit Application: 2C dated 2/11/2020, with additional data
submitted on August 20, 2020.
Flow
1. Previous permit limits:
Monthly average: Monitor and Report (MR), MGD
Daily Maximum: MR, MGD
Sampling Frequency: 1/Quarter
Sample Type: Estimate
2. NPDES Application: (# of analyses: 8)
Maximum Daily Value: 0.03 MGD
Long Term Avg Value: 0.0213 MGD
3. DMR Data: The highest flow was reported in July 2016 as 0.042 MGD.
4. Actual long term average flow (from DMR and/or application): 0.02 MGD
5. Conclusion: Monitoring and reporting requirements shall remain as in the previous permit.
Monthly average: MR, MGD
Daily Maximum: MR, MGD
Sampling Frequency: 1/Quarter
Sample Type: Estimate
Biochemical Oxygen Demand (BODs1
1. Previous permit limits:
Monthly average: 10 mg/I
Daily maximum: 20 mg/I
Sampling frequency: 1 /Quarter
Sample type: Grab
2. NPDES Application: (# of analyses: 8)
Maximum Daily Value: 12 mg/I (2.6 Ib/d)
Long Term Avg Value: 4.5 mg/I (0.8 Ib/d)
3. DMR Data: The highest BOD5 was reported in January 2017 as 10 mg/I.
4. Effluent limitations guidelines: Not applicable to this utility water discharge.
5. PQL: 2.0 mg/I
6. Waste Load Allocation
Monthly Average: 20 mg/I
7. Other information: The NPDES General Permit for Utility Water Discharges has a BOD5 monthly average limit of
10 mg/I and daily maximum limit of 20 mg/I for combined discharges.
8. Conclusion: Due to antibacksliding and consistent with the NPDES General Permit for Utility Water Discharges,
BOD5 limits shall continue as in the previous permit.
Monthly average: 10 mg/I
Daily maximum: 20 mg/I

Rationale
Page 4 of 49
Permit No. SC0002496
Sampling frequency: 1 /Quarter
Sample type: Grab
Total Suspended Solids (TSS)
1. Previous permit limits:
Monthly average: 40 mg/I
Daily Maximum: 40 mg/I
Sampling frequency: 1 /Quarter
Sample Type: Grab
2. NPDES Application: (# of analyses: 8)
Maximum Daily Value: 26.1 mg/I (5.6 Ib/d)
Long Term Avg Value: 8.6 mg/I (1.5 Ib/d)
3. DMR Data: The highest TSS was reported in January 2017 as 26.1 mg/I.
4. Water Quality Data: N/A
5. Effluent Limitation Guidelines: Not applicable to this utility water discharge.
6. Other information: The NPDES General Permit for Utility Water Discharges has a monthly average limit of 40
mg/I and daily max limit of 40 mg/I for combined discharges.
7. PQL: 1000 pg/I
8. Conclusion: Consistent with the NPDES General Permit for Utility Water Discharges and the previous permit, the
TSS limits shall remain as follows:
Monthly average: 40 mg/I
Daily Maximum: 40 mg/I
Sampling frequency: 1 /Quarter
Sample Type: Grab
pH
1. Previous Permit Limits: 6.0 to 9.0 standard units.
Sampling Frequency: 1/Quarter
Sample type: Grab
2. NPDES Application: (# of analyses: 8)
Maximum and Minimum Daily Values: Min: 6.92 su, Max: 8.01 su
3. DMR Data: The highest pH was reported as 8,69 in October 2015 and the lowest pH was reported as 6.92 in April
2017.
4. Water Quality Data: Water quality standards for pH are established in Reg. 61-68.G. For Class Freshwater, this
value is 6.0-8.5 standard units.
5. Effluent limitation guidelines: Not applicable to this utility water discharge.
6. Other information: For Freshwater, the NPDES General Permit for Utility Water Discharges has a minimum limit
of 6.0 and a maximum limit of 8.5 standard units for combined discharges. The critical 7Q10 flow of the Enoree
River is almost 2000 times greater than the long-term average discharge flow of outfall 001.
7. PQL: Not applicable
8. Conclusion: Due to the high dilution available in the Enoree River, the pH limits in the previous permit are
protective. Therefore, the pH limits shall continue to be between 6.0 and 9.0 standard units.
Sampling Frequency: 1/Quarter
Sample type: Grab
Temperature
1. Previous Permit Limits:
Daily Maximum: 90OF

Rationale
Page 5 of 49
Permit No. SC0002496
Sampling Frequency: 1/Quarter
Sample Type: Grab
2. NPDES Application:
No. of analyses: 5
Daily maximum: 24.7°C (76.5°F)
3. DMR Data: The highest temperature was reported in July 2016 as 88.9°F.
4. Water Quality Data: Per Regulation 61-68.E.12.a, the water temperature of all freshwaters which are free
flowing shall not be increased more than 50F (2.8°C) above natural temperature conditions and shall not exceed
a maximum of 90°F (32.2°C) as a result of the discharge of heated liquids unless a different temperature
standard as provided for in C.12 has been established, a mixing zone as provided in C.10 has been established,
or a Section 316(a) determination under the Federal Clean Water Act has been completed.
5. Effluent Limitation Guidelines: Not applicable.
6. Other Information: The critical 7Q10 flow of the Enoree River is almost 2000 times greater than the long-term
average discharge flow of outfall 001. Any temperature increase in the Enoree River as a result of the discharge
from this outfall would be expected to be negligible.
7. PQL: Not applicable
8. Conclusion: The previous effluent limit shall remain in the permit in accordance with Reg. 61-68.E.12.a.
Daily Maximum: 90°F
Sample Frequency: 1/Quarter
Sample Type: Grab
Copper, Total
1. Previous permit limits: N/A
2. NPDES Application: (# of analyses: 1)
Maximum Daily Value: 0.17 mg/I (0.021 Ib/d)
Maximum 30 Day Value: Not reported
Long Term Avg Value: Not reported
3. DMR Data: N/A
4. Water Quality Criterion: see spreadsheet
5. Effluent limitations guidelines (ELGs) and professional judgment -based limits: N/A
6. Does the discharge cause, have the Reasonable Potential to Cause or Contribute: No.
7. Other Information: The NPDES General Permit for Utility Water Discharges (SCG250000) addresses copper and
sets copper limits. However, the previous NPDES permit for this facility found no reasonable potential for
copper based on the monthly copper monitoring that was required by the permit prior to the previous permit.
8. PQL: 10 ug/I
9. Conclusion: Based on there being no reasonable potential, copper limits are not necessary.
Lead, Total
1. Previous permit limits: N/A
2. NPDES Application: (# of analyses: 1)
Maximum Daily Value: < 0.002 mg/I (0 Ib/d)
Maximum 30 Day Value: Not reported
Long Term Avg Value: Not reported
3. DMR Data: N/A
4. Water Quality Criterion: see spreadsheet
5. Effluent limitations guidelines (ELGs) and professional judgment -based limits: N/A
6. Does the discharge cause, have the Reasonable Potential to Cause or Contribute: No
7. Other Information: The NPDES General Permit for Utility Water Discharges (SCG250000) addresses lead, but

Rationale
Page 6 of 49
Permit No. SC0002496
does not impose lead limits if the 7Q10 of the receiving stream is greater than 10 cfs. The 7Q10 of the Enoree
River at the location of the Inman Mills discharge is 60.69 cfs.
8. PQL: 2.0 ug/I
9. Conclusion: Based on there being no reasonable potential, lead limits are not necessary.
Zinc, Total
1. Previous permit limits: N/A
2. NPDES Application: (# of analyses: 1)
Maximum Daily Value: 0.25 mg/I (0.31 Ib/d)
Maximum 30 Day Value: Not reported
Long Term Avg Value: Not reported
3. DMR Data: N/A
4. Water Quality Criterion: see spreadsheet
5. Effluent limitations guidelines (ELGs) and professional judgment -based limits: N/A
6. Does the discharge cause, have the Reasonable Potential to Cause or Contribute: No
7. Other Information: The NPDES General Permit for Utility Water Discharges (SCG250000) addresses zinc, but
does not impose zinc limits if the 7Q10 of the receiving stream is greater than 10 cfs. The 7Q10 of the Enoree
River at the location of the Inman Mills discharge is 60.69 cfs.
8. PQL: 10 ug/I
9. Conclusion: Based on there being no reasonable potential, zinc limits are not necessary.
Other Parameters
Other parameters, such as metals and organics, do not exhibit reasonable potential to cause or contribute to an
excursion of water quality criteria as shown on the attached water quality spreadsheet.
Outfall 002
Outfall 002 consists of sanitary wastewater that is treated in an activated sludge package plant with a dechlorination
system. Sludge is sent to the Laurens Commission of Public Works (CPW) wastewater treatment plant in Laurens, SC
(NPDES Permit No. SC0020702) in accordance with the July 1, 2019 approval letter from the CPW.
Information for this outfall is based on NPDES Permit Application: 2E dated 7/17/2019.
Flow
1. Previous permit limits:
Monthly average: MR, MGD
Daily Maximum: MR, MGD
Sampling Frequency: Daily
Sample Type: Continuous
2. NPDES Application: (# of analyses: 365)
Maximum Daily Value: 0.0139 MGD
Long Term Avg Value: 0.0033 MGD
3. DMR Data: The highest flow was reported in November 2015 as 0.01976 MGD.
4. Actual long term average flow (from DMR data): 0.004 MGD
5. Conclusion: The permit shall continue to require monitor and report of monthly average and daily maximum
flow.
Monthly average: MR, MGD
Daily maximum: MR, MGD

Rationale
Page 7 of 49
Permit No. SC0002496
Sampling Frequency: Daily
Sampling Type: Continuous
pH
1. Previous Permit Limits: 6.0-9.0 standard units.
Sampling Frequency: Daily
Sample type: Grab
2. NPDES Application: (# of analyses: 365)
Maximum Daily Value: 8.9 standard units
Minimum Daily Value 6.07 standard units
3. DMR Data: The highest pH was reported in May 2019 as 8.9 standard units, and the lowest pH in March 2019 as
6.07 standard units.
4. Water Quality Data: Water quality standards for pH are established in Reg. 61-68.G. For Class Freshwater, this
value is 6.0-8.5 standard units.
5. Effluent limitation guidelines: Not applicable to this sanitary wastewater discharge.
6. Other information: Reg. 61-9.133.102(c) for secondary treatment limits for POTWs gives pH limits of between 6.0
and 9.0 standard units. There have been no violations, and the permittee has requested the sampling
frequency be reduced to weekdays.
7. PQL: Not applicable
8. Conclusion: The Department finds the request to reduce the sampling frequency from daily to weekdays
reasonable. Due to the high dilution available in the Enoree River, the pH limits in the previous permit are
protective, and the pH limits shall remain as between 6.0 and 9.0 standard units.
Sampling Frequency: Weekdays
Sample type: Grab
Biochemical Oxygen Demand (BODs)
1. Previous permit limits:
Monthly average: 30 mg/I and 1.45 Ib/d
Daily maximum: 60 mg/I and 2.9 Ib/d
Sampling frequency: 2/Month
Sample type: 24-hour Composite
2. NPDES Application: (# of analyses: 24)
Long Term Average Value: 4 mg/I (0.15 Ib/d)
Maximum Daily Value: 16 mg/I (0.71 Ib/d)
3. DMR Data: The highest BODs concentration was reported in April 2018 as 29 mg/l, and the highest mass
discharge was reported in July 2018 as 0.71 Ib/d.
4. Effluent limitations guidelines: Not applicable to this sanitary wastewater discharge.
5. PQL: 2.0 mg/I
6. Waste Load Allocation
Monthly Average: 30 mg/I
7. Other information: Reg. 61-9.133.102(a) for secondary treatment for POTWs gives a monthly average limit of 30
mg/I for BODs. The daily maximum limit is calculated as twice the monthly average limit.
8. Conclusion: Consistent with the wasteload allocation, the BODs concentration limits shall remain as in the
previous permit. Due to antibacksliding considerations, the mass limits shall remain in the permit.
Monthly average: 30 mg/I and 1.45 Ib/d
Daily maximum: 60 mg/I and 2.9 Ib/d
Sampling frequency: 2/Month
Sample type: 24-hour Composite

Rationale
Page 8 of 49
Permit No. SC0002496
Total Suspended Solids (TSS)
1. Previous permit limits:
Monthly average: 30 mg/I (3.8 Ib/d)
Daily maximum: 60 mg/I (7.5 Ib/d)
Sampling frequency: 2/Month
Sample type: 24-hour Composite
2. NPDES Application: (# of analyses: 24)
Long Term Average Value: 7.7 mg/I (0.29 Ib/d)
Maximum Daily Value: 19.5 mg/I (0.96 Ib/d)
3. DMR Data: The highest TSS concentration was reported in May 2018 as 42.3 mg/I, and the highest mass
discharge was reported in October 2015 as 1.76 Ib/d.
4. Water Quality Data: N/A
5. Effluent Limitation Guidelines: Not applicable to this sanitary wastewater discharge.
6. Other information: Reg. 61-9.133.102(b) for secondary treatment for POTWs gives a monthly average limit of 30
mg/I for TSS. The daily maximum limit is calculated as twice the monthly average limit.
7. PQL: 1000 pg/I
8. Conclusion: Based on best professional judgment, the TSS concentration limits shall remain as in the previous
permit. Due to antibacksliding considerations, the mass limits shall remain in the permit.
Monthly average: 30 mg/I and 3.8 Ib/d
Daily maximum: 60 mg/I and 7.5 Ib/d
Sampling frequency: 2/Month
Sample type: 24-hour Composite
Dissolved Oxygen
1. Previous Permit Limits:
Minimum at all times: 1.0 mg/I
Sampling Frequency: Daily
Sample type: Grab
2. NPDES Application: Not applicable
3. DMR Data: The lowest value was reported in July 2018 as 3.1 mg/I.
4. Water Quality Data: Water quality criteria for DO are established in Regulation 61-68.G for each waterbody
classification. For class Freshwater, the DO criteria are a Daily Average not less than 5.0 mg/I with a low of 4.0
mg/I.
5. Effluent limitation guidelines: Not applicable
6. Other information: The wasteload allocation considered the discharge to have a DO concentration of 1.0 mg/I.
The critical 7Q10 flow of the Enoree River is roughly 10,000 greater than the average flow of this outfall. There
have been no violations, and the permittee has requested the sampling frequency be reduced to weekdays.
7. PQL: 0.1 mg/I
8. Conclusion: The Department finds the request to reduce the sampling frequency from daily to weekdays
reasonable. Due to the high dilution in the Enoree River, the previous DO permit limit is protective. In
accordance with the wasteload allocation and the previous permit, the DO limit shall be as follows:
Minimum at all times: 1.0 mg/I
Sampling Frequency: Weekdays
Sample type: Grab
E. coli
1. Previous Permit Limits:
Monthly average: 126 MPN/100 ml

Rationale
Page 9 of 49
Permit No. SC0002496
Daily maximum: 349 MPN/100 ml
Sampling Frequency: 2/Month
Sample type: Grab
2. NPDES Application: (# of analyses: 24)
Long Term Average Value: 39 MPN/100 ml
Maximum Daily Value: 157.6 MPN/100 ml
3. DMR Data: The highest E. coli value was reported in August 2017 as 214.3 MPN/100 ml.
4. Water Quality Data: E. coli standards in Regulation 61-68.E.14.c(8): In order to protect recreational uses in
freshwaters (including FW, and all types of Trout Waters) of the State, NPDES permit effluent limitations shall be
specified as a monthly average of 126 MPN/100ml and a daily maximum of 349 MPN/100 ml. Provisions for
meeting alternate daily maximum bacteria limits shall be in accordance with R.61-68.E.14.c(12).
5. Effluent limitation guidelines: Not applicable
6. Other information: This discharge includes only sanitary wastewater.
7. PQL: 1/100 ml
8. Conclusion: In accordance with R.61-68.E.14(c)(8), E. coli will continue to be limited as follows:
Monthly average: 126 MPN/100 ml
Daily maximum: 349 MPN/100 ml
Sampling Frequency: 2/Month
Sample type: Grab
Total Residual Chlorine (TRC1
1. Previous Permit Limits:
Monthly average: 0.5 mg/I
Daily Maximum: 1.0 mg/I
Sampling Frequency: 2/Month
Sample type: Grab
2. NPDES Application: (No. of analyses: 24)
Maximum Daily Value: 0.09 mg/I (0.004 Ib/d)
Average Daily Value: 0.0108 mg/I (0.0004 Ib/d)
3. DMR Data: The highest TRC value was reported in May 2018 as 0.7 mg/I.
4. Water Quality Criteria: See attached spreadsheet
5. Effluent limitation guidelines: Not applicable
6. Does the discharge cause, have the Reasonable Potential to Cause or Contribute: No
7. Other information: Since this facility chlorinates and dechlorinates the effluent prior to discharge, permit limits
are necessary. TRC will continue to be monitored after the sanitary wastewater and utility water combine, but
prior to mixing with the receiving stream.
8. PQL: 0.05 mg/I
9. Conclusion: Total Residual Chlorine (TRC) will be limited in accordance with the previous permit limits.
Monthly average: 0.5 mg/I
Daily Maximum: 1.0 mg/I
Sampling Frequency: 2/Month
Sample type: Grab
Ammonia -Nitrogen, Total As N
1. Previous permit limits: None
2. NPDES Application: (# of analyses: 1)
Maximum Daily Value: 1.1 mg/I (0.03 Ib/d)
Average Daily Value: 1.1 mg/I (0.03 Ib/d)

Rationale
Page 10 of 49
Permit No. SC0002496
3. DMR Data: N/A
4. Waste Load Allocation based on dissolved oxygen modeling
Monthly Average: No limit recommended. The wasteload allocation assumed an ammonia discharge
concentration of 20 mg/I for dissolved oxygen modeling purposes.
5. Water Quality Criteria for Protection of Aquatic Life from Reg. 61-68, Appendix, Attachment 3: Freshwater:
In situations where salmonids are absent, the CMC is calculated as:
0.411 58.4
CMC — �1 + 107.204—pH + 1 + 10pH-7.204
Establish the CCC when fish early life stages (ELS) are present:
0.0577 2.487
CCC = �1+ 107.688-pH + 1 + 1 OpH-7.688 x {min�2.85,1.45 x 100 028X(2s r)
�}
Note: The Department always considers fish early life stages to be present unless data is presented which
demonstrates their absence.
Where:
Stream pH = 7.5
Stream temp (critical) = 24.5 °C
Stream temp (seasonal) = 12.9 °C
Upstream flow: 60.69 cfs
Upstream ammonia concentration = 1.4416 mg/I
Critical months are March - October and November - February is seasonal.
CCC (critical) = 2.293 mg/I CCC (seasonal) = 4.364 mg/I
CMC (critical) = 19.89 mg/I CMC (seasonal) = 19.89 mg/I
With dilution:
Monthly average (critical chronic): 7954 mg/I Monthly average(seasonal chronic): 27,298 mg/I
Daily maximum (critical acute): 172,320 mg/I Daily maximum (seasonal acute): 172,320 mg/I
6. Does the discharge cause, have the Reasonable Potential to Cause or Contribute? No
7. Other information:
8. PQL: 100 pg/I
9. Conclusion: Due to the high dilution factor and there being no reasonable potential, ammonia limits are not
necessary.
Outfall 003
Outfall 003 is a new outfall for the purpose of discharging wastewater from the new textile dyeing and finishing
processes. The facility is expected to have an initial production rate 40,000 Ibs/day for five days per week, for an
average initial production rate of 28,571 Ibs/day. The final production rate is expected to be 60,000 Ibs/day for five
days per week, for an average final production rate of 42,857 Ibs/day. The initial wastewater design flow rate is
450,000 gpd, and the final design flow rate is 650,000 gpd. Water quality -based permit limits are based on the final
flow of 650,000 gpd. This is a conservative approach since this flow will be generated over five days per week, and
the average daily flow will be less. Wastewater will be generated over five days but will be discharged over seven
days.

Rationale
Page 11 of 49
Permit No. SC0002496
The permittee has described the initial production processes as including printing, curing/flash aging, finishing, and
sanforizing. The production processes of the final buildout include preparation and dyeing in addition to the initial
production processes.
The wastewater treatment system consists of the following: a rotary drum screen, an aerated equalization basin,
coagulation, flocculation, primary dissolved air flotation, two moving bed biofilm reactors in series, flocculation,
secondary dissolved air flotation, and media filtration.
Operator requirements: Based on the treatment system described above and the Pollution Control Act (PCA), the
treatment system is classified as Group III -Biological. The Environmental Certification Board Rules require that a
Grade B-Biological operator be assigned to operate this facility. Inspections of the facility will be required on a daily
basis per Regulation 61-9.122.41(e).
Sludge will be treated with a flocculant in a sludge conditioning tank prior to dewatering by a belt press and disposal
offsite.
Inman Mills has stated that they will not use chemicals containing PFAS (per- and polyfluoroalkyl substances).
The Department must consider the antidegradation requirements of the South Carolina Water Classifications and
Standards in R.61-68.D because the addition of outfall 003 constitutes an expansion that will result in the lowering
of water quality. The facility submitted a Preliminary Engineering Report that includes in Section 6 an alternatives
analysis study as required by R.61-68.D.2.a. The alternatives analysis demonstrated that none of the alternatives to
this new outfall are economically and technologically feasible. In addition, the Department has determined that the
lowering of water quality is necessary for important economic and social factors. The Appalachian Council of
Governments has also determined that the project is in conformance with their area -wide water quality
management plan required by section 208 of the Clean Water Act and is consistent with antidegradation provisions.
As a result of the industrial production expansion into dyeing and finishing operations, the project is expected to
create 126 new positions at the Inman Mills Ramey Plant and increase the community's tax base due to an
approximate $15 million capital investment in the plant expansion.
The wastewater discharges from the industrial operations that will be added as a result of the plant expansion fall
under the effluent limitation guidelines of 40 CFR Part 410 Textile Mills Point Source Category, Subpart D Woven
Fabric Finishing Category. Since the wastewater discharges from the plant expansion will be a new source, the New
Source Performance Standards of 40 CFR 410.45 will apply. Because the new operations will include printing and
finishing, the facility will meet the definition of "complex manufacturing operation" in 40 CFR 410.41(b).
Due to the anticipated change in production rate for the new operations from 40,000 Ibs/day to 60,000 Ibs/day, the
permit includes production rate tiers for the purpose of applying the production -based effluent limitation guidelines
limits. The tiers will be set as follows (all production values in Ibs/day):
5-Day Daily
Tier Production
1 40,000
2 50,000
3 60,000
Average Daily
Production
28,571
35,714
42,857
Average
Production Range
25,000 - 32,142
32,143 - 39,285
39,286 - 46,428
5-Day Daily
Production Range
35,556 - 44,999
45,000 - 54,999
55,000 - 64,999
The effluent limitation guidelines limits for each tier are based on the average daily production values, which are the
midpoints of the average production ranges.

Rationale
Page 12 of 49
Permit No. SC0002496
Outfall 003 will be within a state -approved source water protection area (SWPA) for a surface water drinking water
intake and has the potential to affect the intake. The affected intake (Intake #S30104) is owned by the City of
Clinton. Outfall 003 is outside the SWPA for the intake (Intake #S36102) owned by the Town of Whitmire, but has
the potential to affect the intake. The 7Q10 and AAF to be used for permitting MCL and water/organism criteria are
given on the spreadsheet. Additional information on source water protection is provided in sections 111.13 and G of
this rationale.
All waterbody data is provided on the attached Water Quality Spreadsheets. This data includes 7Q10, annual
average flow, dilution factors, hardness, TSS and other information as explained in this rationale. Additional
information as necessary to explain the values used will be provided below.
Flow (All tiers)
Previous permit limits: N/A
NPDES Application: The flow is expected to be 450,000 gpd during the initial process when five-day production
is 40,000 Ibs/day and 650,000 gpd when five-day production is 60,000 Ibs/day. These are five-day flows, but the
wastewater will be treated and discharged over seven days, which will result in lower average effluent flow
rates. However, 650,000 gpd will be used as a worst -case scenario for water quality permitting purposes,
DMR Data: N/A
4. Actual long term average flow (from DMR and/or application): 0.65 MGD
5. Conclusion: Monitoring and reporting requirements shall be as follows:
Monthly average: MR, MGD
Daily Maximum: MR, MGD
Sampling Frequency: Daily
Sample Type: Continuous
Biochemical Oxygen Demand (BODs1
1. Previous permit limits: N/A
2. NPDES Application:
Maximum Daily Value: 45.5 mg/I (222 Ibs/day)
Long Term Avg Value: 23.4 mg/I (87.8 Ibs/day)
DMR Data: N/A
4. Effluent limitations guidelines:
40 CFR 410.45 New Source Performance Standards, Complex Manufacturing Operations
Monthly Average: 1.9 Ibs/day per 1000 Ibs of production
Daily Maximum: 3.7 Ibs/day per 1000 Ibs of production
Tier 1
Monthly Average = 1.9 Ibs/day/1000 Ibs production x 28,571 Ibs production = 54.3 Ibs/day
Daily Maximum = 3.7 Ibs/day/1000 Ibs production x 28,571 Ibs production = 105.7 Ibs/day
Tier 2
Monthly Average = 1.9 Ibs/day/1000 Ibs production x 35,714 Ibs production = 67.9 Ibs/day
Daily Maximum = 3.7 Ibs/day/1000 Ibs production x 35,714 Ibs production = 132.1 Ibs/day
Tier 3
Monthly Average = 1.9 Ibs/day/1000 Ibs production x 42,857 Ibs production = 81.4 Ibs/day
Daily Maximum = 3.7 Ibs/day/1000 Ibs production x 42,857 Ibs production = 158.6 Ibs/day

Rationale
Page 13 of 49
Permit No. SC0002496
5. PQL: 2.0 mg/I
6. Waste Load Allocation
Monthly Average: 23.4 mg/I
7. Other information:
8. Conclusion: The monthly average BOD5 concentration limit shall be based on the wasteload allocation. The
daily maximum concentration limit shall be two times the monthly average concentration limit. The mass limits
shall be based on the effluent limitation guidelines.
Tier 1
Monthly average: 23.4 mg/I, 54.3 Ibs/day
Daily maximum: 46.8 mg/I, 105.7 Ibs/day
Sampling frequency: 2/month
Sample type: 24-Hour composite
Tier 2
Monthly average: 23.4 mg/I, 67.9 Ibs/day
Daily maximum: 46.8 mg/I, 132.1 Ibs/day
Sampling frequency: 2/month
Sample type: 24-Hour composite
Tier 3
Monthly average: 23.4 mg/I, 81.4 Ibs/day
Daily maximum: 46.8 mg/I, 158.6 Ibs/day
Sampling frequency: 2/month
Sample type: 24-Hour composite
Chemical Oxygen Demand (COD)
1. Previous permit limits: N/A
2. NPDES Application:
Maximum Daily Value: 844.9 mg/I (4122 Ibs/day)
Long Term Avg Value: 543.6 mg/I (2040 Ibs/day)
3. DMR Data: N/A
4. Effluent limitations guidelines:
40 CFR 410.45 New Source Performance Standards, Complex Manufacturing Operations
Monthly Average: 44.2 Ibs/day per 1000 Ibs of production
Daily Maximum: 68.7 Ibs/day per 1000 Ibs of production
Tier 1
Monthly Average = 44.2 Ibs/day/1000 Ibs production x 28,571 Ibs production = 1263 Ibs/day
Daily Maximum = 68.7 Ibs/day/1000 Ibs production x 28,571 Ibs production = 1963 Ibs/day
Tier 2
Monthly Average = 44.2 Ibs/day/1000 Ibs production x 35,714 Ibs production = 1579 Ibs/day
Daily Maximum = 68.7 Ibs/day/1000 Ibs production x 35,714 Ibs production = 2454 Ibs/day
Tier 3
Monthly Average = 44.2 Ibs/day/1000 Ibs production x 42,857 Ibs production = 1894 Ibs/day
Daily Maximum = 68.7 Ibs/day/1000 Ibs production x 42,857 Ibs production = 2944 Ibs/day

Rationale
Page 14 of 49
Permit No. SC0002496
5. PQL: 20 mg/I
6. Waste Load Allocation: N/A
7. Other information:
8. Conclusion: COD limits shall be based on the effluent limitation guidelines.
Tier 1
Monthly average: 1263 Ibs/day
Daily maximum: 1963 Ibs/day
Sampling frequency: 2/month
Sample type: 24-Hour composite
Tier 2
Monthly average: 1579 Ibs/day
Daily maximum: 2454 Ibs/day
Sampling frequency: 2/month
Sample type: 24-Hour composite
Tier 3
Monthly average: 1894 Ibs/day
Daily maximum: 2944 Ibs/day
Sampling frequency: 2/month
Sample type: 24-Hour composite
Total Suspended Solids (TSS)
1. Previous permit limits: N/A
2. NPDES Application:
Maximum Daily Value: 177.1 mg/I (959.52 Ibs/day)
Long Term Avg Value: 78.7 mg/I (295.36 Ibs/day)
3. DMR Data: N/A
4. Water Quality Data: N/A
5. Effluent Limitation Guidelines:
40 CFR 410.45 New Source Performance Standards, Complex Manufacturing Operations
Monthly Average: 6.4 Ibs/day per 1000 Ibs of production
Daily Maximum: 14.4 Ibs/day per 1000 Ibs of production
Tier 1
Monthly Average = 6.4 Ibs/day/1000 Ibs production x 28,571 Ibs production = 182.9 Ibs/day
Daily Maximum = 14.4 Ibs/day/1000 Ibs production x 28,571 Ibs production = 411.4 Ibs/day
Tier 2
Monthly Average = 6.4 Ibs/day/1000 Ibs production x 35,714 Ibs production = 228.6 Ibs/day
Daily Maximum = 14.4 Ibs/day/1000 Ibs production x 35,714 Ibs production = 514.3 Ibs/day
Tier 3
Monthly Average = 6.4 Ibs/day/1000 Ibs production x 42,857 Ibs production = 274.3 Ibs/day
Daily Maximum =14.4 Ibs/day/1000 Ibs production x 42,857 Ibs production = 617.1 Ibs/day
6. Other information:
7. PQL: 1000 pg/I

Rationale
Page 15 of 49
Permit No. SC0002496
8. Conclusion: TSS limits shall be based on the effluent limitation guidelines:
Tier 1
Monthly average: 182.9 Ibs/day
Daily Maximum: 411.4 Ibs/day
Sampling frequency: 2/month
Sample Type: 24-Hour composite
Tier 2
Monthly average: 228.6 Ibs/day
Daily Maximum: 514.3 Ibs/day
Sampling frequency: 2/month
Sample Type: 24-Hour composite
Tier 3
Monthly average: 274.3 Ibs/day
Daily Maximum: 617.1 Ibs/day
Sampling frequency: 2/month
Sample Type: 24-Hour composite
Sulfide, total as S
1. Previous permit limits: N/A
2. NPDES Application:
Maximum Daily Value: 2.414 mg/I (13.08 Ibs/day)
Long Term Average Value: 1.207 mg/I (4.53 Ibs/day)
3. DMR Data: N/A
4. Water Quality Data: see spreadsheet. Aquatic life criteria are based on the toxicity of H2S. When soluble
sulfides are added to water, they react with hydrogen ions to form hydrosulfide (HS-) and hydrogen sulfide (1-12S),
the proportion depending on the pH. The toxicity of sulfides derives primarily from H2S rather than HS- or
sulfide (S).
5. Other Information:
6. Does the discharge cause, have the Reasonable Potential to Cause or Contribute: Yes, based on the data
provided with the permit application. However, that data does not account for the amount of sulfide that may
be removed by the wastewater treatment process. Also, the reasonable potential is based on the aquatic life
criteria which are based on the toxicity of H2S, as mentioned above.
7. Effluent limitations guidelines:
40 CFR 410.45 New Source Performance Standards, Complex Manufacturing Operations
Monthly Average: 0.1 Ibs/day per 1000 Ibs of production
Daily Maximum: 0.2 Ibs/day per 1000 Ibs of production
Tier 1
Monthly Average = 0.1 Ibs/day/1000 Ibs production x 28,571 Ibs production = 2.9 Ibs/day
Daily Maximum = 0.2 Ibs/day/1000 Ibs production x 28,571 Ibs production = 5.7 Ibs/day
Tier 2
Monthly Average = 0.1 Ibs/day/1000 Ibs production x 35,714 Ibs production = 3.6 Ibs/day
Daily Maximum = 0.2 Ibs/day/1000 Ibs production x 35,714 Ibs production = 7.1 Ibs/day
Tier 3

Rationale
Page 16 of 49
Permit No. SC0002496
Monthly Average = 0.1 Ibs/day/1000 Ibs production x 42,857 Ibs production = 4.3 Ibs/day
Daily Maximum =0.2 Ibs/day/1000 Ibs production x 42,857 Ibs production = 8.6 Ibs/day
8. PQL: 100 pg/I
9. Conclusion: Mass limits shall be based on the effluent limitation guidelines, and monitoring and reporting of
concentration shall be required for water -quality reasonable potential purposes in order to be able to calculate
the concentration of hydrogen sulfide.
Tier 1
Monthly average: MR mg/I, 2.9 Ibs/day
Daily maximum: MR mg/I, 5.7 Ibs/day
Sampling Frequency: 2/month
Sample type: Grab
Tier 2
Monthly average: MR mg/I, 3.6 Ibs/day
Daily maximum: MR mg/I, 7.1 Ibs/day
Sampling Frequency: 2/month
Sample type: Grab
Tier 3
Monthly average: MR mg/I, 4.3 Ibs/day
Daily maximum: MR mg/I, 8.6 Ibs/day
Sampling Frequency: 2/month
Sample type: Grab
Hydrogen Sulfide, Unionized (HzS) (All Tiers)
1. Previous Permit Limits: N/A
2. NPDES Application: Not reported on form 2D.
3. DMR Data: None
4. Water Quality Data: see spreadsheet for sulfide
5. Other Information:
When soluble sulfides are added to water, they react with hydrogen ions to form hydrosulfide (HS-) and
hydrogen sulfide (H2S), the proportion depending on the pH. The toxicity of sulfides drives primarily from H2S
rather than HS- or sulfide (S).
6. Effluent limitations guidelines (ELGs): N/A
7. PQL: Not applicable because the hydrogen sulfide concentration is determined by calculation using the
measured sulfide concentration.
8. Conclusion: H2S is determined by calculation from total sulfides, temperature and pH data. Monitoring for
temperature and pH must be performed at the time the sulfide sample is taken. Limits for H2S shall be as
follows:
Monthly Average: 0.1225 ug/I
Daily Maximum: 0.245 ug/I
Sampling Frequency: 2/month
Sample Type: Calculation
Temperature (All Tiers)
1. Previous permit requirements: N/A
2. DMR Data: NA

Rationale
Page 17 of 49
Permit No. SC0002496
3. Other Information: Temperature data is necessary to calculate hydrogen sulfide concentrations from measured
sulfide concentrations.
4. Conclusion: Temperature shall be monitored at the time sulfide samples are taken.
Monthly Average: MR, ° C
Daily Maximum: MR, ° C
Sampling Frequency: 2/month
Sample Type: Grab
Phenols, Total
1. Previous permit limits: N/A
2. NPDES Application: Believed absent
3. DMR Data: N/A
4. Water Quality Data: see spreadsheet
5. Other Information:
6. Does the discharge cause, have the Reasonable Potential to Cause or Contribute: No
7. Effluent limitations guidelines:
40 CFR 410.45 New Source Performance Standards, Complex Manufacturing Operations
Monthly Average: 0.05 Ibs/day per 1000 Ibs of production
Daily Maximum: 0.1 Ibs/day per 1000 Ibs of production
Tier 1
Monthly Average = 0.05 Ibs/day/1000 Ibs production x 28,571 Ibs production = 1.4 Ibs/day
Daily Maximum = 0.1 Ibs/day/1000 Ibs production x 28,571 Ibs production = 2.9 Ibs/day
Tier 2
Monthly Average = 0.05 Ibs/day/1000 Ibs production x 35,714 Ibs production = 1.8 Ibs/day
Daily Maximum = 0.1 Ibs/day/1000 Ibs production x 35,714 Ibs production = 3.6 Ibs/day
Tier 3
Monthly Average = 0.05 Ibs/day/1000 Ibs production x 42,857 Ibs production = 2.1 Ibs/day
Daily Maximum =0.1 Ibs/day/1000 Ibs production x 42,857 Ibs production = 4.3 Ibs/day
8. PQL: 5.0 ug/I
9. Conclusion: The limits shall be based on the effluent limitation guidelines.
Tier 1
Monthly average: 1.4 Ibs/day
Daily maximum: 2.9 Ibs/day
Sampling Frequency: 2/month
Sampling Type: Grab
Tier 2
Monthly average: 1.8 Ibs/day
Daily maximum: 3.6 Ibs/day
Sampling Frequency: 2/month
Sampling Type: Grab
Tier 3
Monthly average: 2.1 Ibs/day
Daily maximum: 4.3 Ibs/day

Rationale
Page 18 of 49
Permit No. SC0002496
Sampling Frequency: 2/month
Sampling Type: Grab
Chromium, Total
1. Previous permit limits: N/A
2. NPDES Application: Believed absent
3. DMR Data: N/A
4. Water Quality Data: see spreadsheet
5. Other Information:
6. Does the discharge cause, have the Reasonable Potential to Cause or Contribute: No
7. Effluent limitations guidelines:
40 CFR 410.45 New Source Performance Standards, Complex Manufacturing Operations
Monthly Average: 0.05 Ibs/day per 1000 Ibs of production
Daily Maximum: 0.1 Ibs/day per 1000 Ibs of production
Tier 1
Monthly Average = 0.05 Ibs/day/1000 Ibs production x 28,571 Ibs production = 1.4 Ibs/day
Daily Maximum = 0.1 Ibs/day/1000 Ibs production x 28,571 Ibs production = 2.9 Ibs/day
Tier 2
Monthly Average = 0.05 Ibs/day/1000 Ibs production x 35,714 Ibs production = 1.8 Ibs/day
Daily Maximum = 0.1 Ibs/day/1000 Ibs production x 35,714 Ibs production = 3.6 Ibs/day
Tier 3
Monthly Average = 0.05 Ibs/day/1000 Ibs production x 42,857 Ibs production = 2.1 Ibs/day
Daily Maximum =0.1 Ibs/day/1000 Ibs production x 42,857 Ibs production = 4.3 Ibs/day
8. PQL: 0.0050 mg/I
9. Conclusion: The limits shall be based on the effluent limitation guidelines.
Tier 1
Monthly average: 1.4 Ibs/day
Daily maximum: 2.9 Ibs/day
Sampling Frequency: 2/month
Sampling Type: 24-Hr. Composite
Tier 2
Monthly average: 1.8 Ibs/day
Daily maximum: 3.6 Ibs/day
Sampling Frequency: 2/month
Sampling Type: 24-Hr. Composite
Tier 3
Monthly average: 2.1 Ibs/day
Daily maximum: 4.3 Ibs/day
Sampling Frequency: 2/month
Sampling Type: 24-Hr. Composite

Rationale
Page 19 of 49
Permit No. SC0002496
pH (All tiers)
1. Previous Permit Limits: N/A
2. NPDES Application:
Maximum and Minimum Daily Values: Min: 6.0 su, Max: 8.5 su
3. DMR Data: N/A
4. Water Quality Data: Water quality standards for pH are established in Reg. 61-68.G. For Class Freshwater, this
value is 6.0-8.5 standard units.
5. Effluent limitation guidelines:
40 CFR 410.45 New Source Performance Standards, Complex Manufacturing Operations
pH shall be within the range of 6.0 to 9.0 standard units at all times.
6. Other information: The critical 7Q10 flow of the Enoree River is about 60 times greater than the effluent flow of
650,000 gpd. pH data is necessary to calculate hydrogen sulfide concentrations from measured sulfide
concentrations.
7. PQL: Not applicable
8. Conclusion: pH shall be monitored when sulfide samples are taken. Based on the water quality criteria, pH
limits shall be between 6.0 and 8.5 standard units.
Sampling Frequency: 2/month
Sample type: Grab
Dissolved Oxygen (All Tiers)
1. Previous Permit Limits: N/A
2. NPDES Application: Not applicable
3. DMR Data: N/A
4. Water Quality Data: Water quality criteria for DO are established in Regulation 61-68.G for each waterbody
classification. For class Freshwater, the DO criteria are a Daily Average not less than 5.0 mg/I with a low of 4.0
mg/I.
5. Effluent limitation guidelines: Not applicable
6. Wasteload allocation: 1.0 mg/I
6. Other information: The critical 7Q10 flow of the Enoree River is about 60 times greater than the effluent flow of
650,000 gpd.
7. PQL: 0.1 mg/I
8. Conclusion: Due to the high dilution in the Enoree River, and in accordance with the wasteload allocation, the
DO limit shall be as follows:
Minimum at all times: 1.0 mg/I
Sampling Frequency: 2/month
Sample type: Grab
Ammonia -Nitrogen, Total As N (All Tiersl
1. Previous permit limits: N/A
2. NPDES Application:
Maximum Daily Value: 2.14 mg/I (11.6 Ibs/day)
Average Daily Value: 1.71 mg/I (6.42 Ibs/day)
3. DMR Data: N/A
4. Waste Load Allocation based on dissolved oxygen modeling: Monitor and report
5. Water Quality Criteria for Protection of Aquatic Life from Reg. 61-68, Appendix, Attachment 3: Freshwater:
In situations where salmonids are absent, the CIVIC is calculated as:

Rationale
Page 20 of 49
Permit No. SC0002496
0.411 58.4
CIVIC = �1+107.2o4-pH + 1+10pH-7.2o4
Establish the CCC when fish early life stages (ELS) are present:
0.0577 2.487 r)
CCC = �1 + 107.688-pH + 1 + 10pH-7.688 x {min�2.85,1.45 x 100 028x(2s- �}
Note: The Department always considers fish early life stages to be present unless data is presented which
demonstrates their absence.
Where:
Stream pH = 7.5
Stream temp (critical) = 24.5 °C
Stream temp (seasonal) = 12.9 °C
Upstream flow: 60.69 cfs
Upstream ammonia concentration = 1.4416 mg/I
Critical months are March - October and November - February is seasonal.
CCC (critical) = 2.293 mg/I CCC (seasonal) = 4.364 mg/I
CIVIC (critical) = 19.89 mg/I CIVIC (seasonal) = 19.89 mg/I
With dilution:
Monthly average (critical chronic): 53.67 mg/I Monthly average (seasonal chronic): 180.72 mg/I
Daily maximum (critical acute): 1133.21 mg/I Daily maximum (seasonal acute): 1133.21 mg/I
6. Does the discharge cause, have the Reasonable Potential to Cause or Contribute? No
7. Other information:
8. PQL: 100 pg/I
9. Conclusion: Due to the high dilution factor and there being no reasonable potential, ammonia limits are not
necessary for toxicity purposes. Based on the wasteload allocation, monitor and report shall be required for
ammonia.
Monthly average: MR, mg/I
Daily maximum: MR, mg/I
Sampling Frequency: 1/month
Sampling Type: 24-Hr. Composite
Nitrogen, total (All Tiers)
1. Previous permit limits: N/A
2. NPDES Application:
Maximum Daily Value: 38.9 mg/I (210.88 Ibs/day)
Long Term Avg Value: 29.85 mg/I (112.03 Ibs/day)
3. DMR Data: N/A
4. Water Quality Data: See Section III.G.1.c of this rationale.
5. Effluent limitations guidelines: not applicable
6. Wasteload Allocation: Monitor and report.
7. Conclusion: In accordance with the wasteload allocation, total nitrogen shall be monitored as follows:
Monthly average: MR, mg/I (Ibs/day)

Rationale
Page 21 of 49
Permit No. SC0002496
Daily maximum: MR, mg/I (Ibs/day)
Sampling Frequency: 1/month
Sample type: Calculation (Total Nitrogen should be reported as the sum of TKN and Nitrate/Nitrite
Nitrogen.)
Total Kjeldahl Nitrogen (TKN) (All Tiers)
1. Previous permit limits: N/A
2. NPDES Application: N/A
3. DMR Data: N/A
4. Water Quality Data: N/A
5. Other Information: TKN monitoring is necessary to calculate total nitrogen.
6. Effluent limitations guidelines: N/A
7. PQL: 0.10 mg/I
8. Conclusion: In order to calculate total nitrogen, TKN shall be monitored as follows:
Monthly average: MR, mg/I (Ibs/day)
Daily maximum: MR, mg/I (Ibs/day)
Sampling Frequency: 1/month
Sample type: 24-Hour composite
Nitrate -Nitrite as Nitrogen (All Tiers)
1. Previous permit limits: N/A
2. NPDES Application:
Maximum Daily Value: 172 mg/I (318.264 Ibs/day)
Long Term Avg Value: 125.125 mg/I (234.082 Ibs/day)
3. DMR Data: N/A
4. Water Quality Data: see spreadsheet
5. Other Information: Nitrate -Nitrite monitoring is necessary to calculate total nitrogen.
6. Does the discharge cause, have the Reasonable Potential to Cause or Contribute: No.
7. Effluent limitations guidelines: N/A
8. PQL: 0.020 mg/I
9. Conclusion: In order to calculate total nitrogen, Nitrate -Nitrite shall be monitored as follows:
Monthly average: MR, mg/I (Ibs/day)
Daily maximum: MR, mg/I (Ibs/day)
Sampling Frequency: 1/month
Sample type: 24-Hour composite
Phosphorus, total (All Tiers)
1. Previous permit limits: N/A
2. NPDES Application:
Maximum Daily Value: 21 mg/I, 113.84 Ibs/day
Long Term Avg Value: 15.5 mg/I, 58.27 Ibs/day
3. DMR Data: N/A
4. Water Quality Criterion: See Section III.G.1.c of this rationale.
5. Effluent limitations guidelines (ELGs): N/A
6. Wasteload Allocation: Monitor and report
7. Other Information:
8. PQL: 0.050 mg/I
9. Conclusion: Based on the wasteload allocation, monitor and report shall be required for phosphorus.

Rationale
Page 22 of 49
Permit No. SC0002496
Monthly average: MR, mg/I
Daily maximum: MR, mg/I
Sampling Frequency: 1/month
Sample type: 24-Hr. Composite
Color (All Tiers)
1. Previous permit limits: N/A
2. NPDES Application:
Maximum Daily Value: 540 Platinum -cobalt color units (PCU)
Long Term Avg Value: 451 PCU
3. DMR Data: N/A
4. Water Quality Data: Narrative water quality criteria for color are established as "free -from" criteria in Reg. 61-
68.E.5.c: All ground waters and surface waters of the State shall at all times, regardless of flow, be free from
sewage, industrial, or other waste which produce taste or odor or change the existing color or physical,
chemical, or biological conditions in the receiving waters or aquifers to such a degree as to create a nuisance, or
interfere with classified water uses (except classified uses within mixing zones as described in this regulation) or
existing water uses.
5. Other Information:
6. Effluent limitations guidelines (ELGs) and professional judgment -based limits: N/A
7. PQL: 25 CU (ADMI color units)
8. Conclusion: Based on the information submitted in the permit application, the permit will include limits for
color. The upstream, downstream, and effluent color will be monitored and reported. Upstream samples shall
be representative of background conditions. Downstream samples shall be taken at point after mixing has
occurred. The 40 CU limit on the difference between upstream and downstream color values is based on
previous NPDES permits issued by the Department and to ensure the discharge will not cause a change in color
to such a degree to create a nuisance or interfere with classified uses.
Upstream: MR, CU
Effluent Maximum: MR, CU
Downstream: MR, CU
Difference: 40 CU (Downstream - Upstream)
Sampling frequency: 1/Month
Sample type: Grab (and calculated for the difference)
**Note that color is an instantaneous maximum since the free -from wording in R.61-68.E.5 states "at all times."
Per- and Polyfluoroalkyl Substances (PFAS) (All Tiers)
1. Previous permit limits: N/A
2. NPDES Application: Not sampled, however the permittee has stated the following: "[T]he proposed dyeing and
finishing processes at the Inman Mill - Ramey Plant have been specifically tailored to avoid discharge of any
chemical products that contain any perfluourakyl or polyfluoroakyl, also commonly referred to as PFAS,
chemical compounds. Therefore, to the best of our belief, the proposed processes and resulting treated
wastewater effluent should not contain or increase the concentration of PFAS in the discharge to the Enoree
River."
3. DMR Data: N/A
4. Other Information: Inman Mills receives water from the Woodruff Roebuck Water District. As a part of the
Bureau of Water's "Strategy to Assess the Impact of Per- and Polyfluoroalkyl Substances on Drinking Water in
South Carolina", the Department sampled the Woodruff Roebuck Water District finished water on June 17, 2020,
and analysis by two different methods showed the following PFAS concentrations were present.

Rationale
Page 23 of 49
Permit No. SC0002496
PFAS Chemical
Method 537.1
Concentration, ng/I
Method 533
Concentration, ng/I
PFOA
5.9
7.9
P FO S
5.7
6.0
PFBS
2.9
3.9
PFHxA
3.6
4.8
PFHxS
*
2.0
PFHpA
2.3
2.7
PFBA
Not Analyzed
2.7
PFPeA
Not Analyzed
4.2
PFNA
PFDA
N-EtFOSAA
*
Not Analyzed
PFUnA
N-McFOSAA
*
Not Analyzed
PFDoA
PFTrDA
*
Not Analyzed
PFTA
*
Not Analyzed
HFPO-DA
F53B Major
*
Not Analyzed
F53B Minor
*
Not Analyzed
ADONA
11 CI-PF3OUdS
Not Analyzed
8:2FTS
Not Analyzed
4:2FTS
Not Analyzed
6:2FTS
Not Analyzed
9CL-PF3ONS
Not Analyzed
NFDHA
Not Analyzed
PFEESA
Not Analyzed
PFMPA
Not Analyzed
PFMBA
Not Analyzed
PFHpS
Not Analyzed
PFPeS
Not Analyzed
* = not detected above the detection limit of 2.1 ng/I
5. Does the discharge cause, have the Reasonable Potential to Cause or Contribute: There is no PFAS effluent data
for this proposed discharge, and the permittee has stated they do not expect the proposed manufacturing
processes to increase the amount of PFAS in the discharge. Therefore, there is no reasonable potential for the
discharge to cause or contribute to an excursion of the narrative criteria.
6. Effluent limitations guidelines and best professional judgment: There are no effluent limitations guidelines for
PFAS chemicals discharged from textile finishing plants. The facility is not expected to discharge PFAS above the
amount that is in the source water.
7. PQL: The Department has not yet established PQLs for PFAS chemicals. Limits of quantitation for PFAS
analytical data submitted to the Department are often within the range of single digit nanograms per liter.
8. Conclusion: As discussed above, the following monitoring requirements shall apply to PFAS chemicals using the
most recent draft of EPA Method 1633 until it is finalized, and then using the final, published method.
Effluent:
Monthly average: MR, ng/I
Daily maximum: MR, ng/I

Rationale
Page 24 of 49
Permit No. SC0002496
Sampling Frequency: 1/month
Sample type: Grab
Source Water:
Monthly average: MR, ng/I
Daily maximum: MR, ng/I
Sampling Frequency: 1/month
Sample type: Grab
Difference (effluent concentration - source water concentration):
Monthly average: MR, ng/I
Daily maximum: MR ng/I
Sampling Frequency: 1/month
Sample type: Calculation
The PFAS sampling of the source water will serve as an indication of the amount of PFAS in the source water.
However, due to the variability expected in source water PFAS concentrations, an effluent concentration higher than
the corresponding source water concentration does not necessarily indicate that the concentration has been
increased by the permittee's operations.
The following benchmarks differentials have been set in the permit considering the concentrations in the source
water and travel time through the plant: a monthly average effluent PFAS concentration at or above 15 ng/I higher
than the corresponding monthly average source water PFAS concentration for three months in a row will indicate
that PFAS has been discharged above concentrations expected to be in the source water for any specific compound.
In addition, a daily maximum PFAS concentration difference at or above 30 ng/I higher than the corresponding daily
maximum source water PFAS concentration will indicate PFAS has been discharged above concentrations expected
to be in the source water for any specific compound.
Exceeding one of the above benchmarks will trigger the permittee to develop and submit a PFAS Evaluation and
Reduction report to the Department within 60 days from the date of the DMR submittal documenting the
exceedance. Exceeding the benchmark differential is not considered permit noncompliance or a permit violation as
long as the permittee submits a timely PFAS Evaluation and Reduction report.
Acute Whole Effluent Toxicity (WET) (All Tiers)
1. Previous permit requirements: N/A
2. DMR Data: N/A
3. Mixing Zone and Zone of Initial Dilution (ZID) Information:
The stream at the point of discharge is 34.6 m wide (w in the equation below). The mixing zone and ZID
dimensions are determined as follows using stream width:
Chronic mixing zone
Width:'/z w = 17.3 m
Length: 2w = 69.2 m
Acute ZID
Width: 1/10 w = 3.5 m
Length: 1/3 w = 11.5 m
Using EFDC modeling at the expected final buildout flow of 650,000 gpd, the following dilutions can be

Rationale
Page 25 of 49
Permit No. SC0002496
determined at the boundary conditions given above.
Chronic concentration (CTC): 6.9% at the length boundary.
Acute concentration (ATC): 7.8% at the length boundary.
4. Reasonable potential evaluation: No data.
5. Other information: The permit application package included results of four acute WET tests showing no
reduction in survival of the organisms used in the tests, but the tests were conducted at an ACT of 2%, which is
less than the modeled ACT of 7.8% using the EFDC model.
6. Conclusion: Based on the potential for acute toxicity, acute whole effluent toxicity will be limited. The following
permit requirements are based on an evaluation of the treatment provided, the variability of pollutants in the
discharge, the nature and characteristics of the discharge, and the available dilution in accordance with R.61-
9.122.44(d)(1).
Acute pass/fail testing at an ACT of 7.8%
Sampling Frequency: 1/month
Sample Type: 24-hr. composite
Chronic Whole Effluent Toxicity (WET) (All Tiers)
1. Previous permit requirements: N/A
2. DMR Data: N/A
3. Mixing Zone and Zone of Initial Dilution (ZID) Information:
The stream at the point of discharge is 34.6 m wide (w in the equation below). The mixing zone and ZID
dimensions are determined as follows using stream width:
Chronic mixing zone
Width: '/z w = 17.3 rr
Length: 2w = 69.2 m
Acute ZID
Width: 1/10 w = 3.5 m
Length: 1/3 w = 11.5 m
Using EFDC modeling at the expected final buildout flow of 650,000 gpd, the following dilutions can be
determined at the boundary conditions given above.
Chronic concentration (CTC): 6.9% at the length boundary.
Acute concentration: (ATC): 7.8% at the length boundary.
4. Reasonable potential evaluation: No data.
5. Other information: The permit application package included results of three chronic WET tests conducted at a
CTC of 2%, less than the CTC of 6.9% determined by the EFDC modeling. These tests showed chronic toxicity but
do not reflect any possible reduction in toxicity as a result of the wastewater treatment process.
6. Conclusion: Chronic whole effluent toxicity testing shall be required at a chronic test concentration of 6.9%
using the dilution series 0%, 2%, 4%, 6.9%, 13%, and 25%.
Monthly Average: 25% effect (total, reproduction, & mortality)
Maximum: 40% effect (total, reproduction, & mortality)
Sampling Frequency: 1/month

Rationale
Page 26 of 49
Permit No. SC0002496
Sample Type: 24-Hr. Composite
Biological Monitoring Requirements
Biological monitoring is not necessary for this permit.
Groundwater Monitoring Requirements
Groundwater monitoring is not necessary for this permit.
Threatened and Endangered red Species Information
The discharges from outfalls 001, 002 and 003 are not expected to adversely affect any listed threatened or
endangered species.
Stormwater
Outfalls 001, 002, and 003 do not discharge stormwater associated with industrial activities. The facility is covered
under the NPDES General Permit for Storm Water Discharges Associated with Industrial Activities coverage number
SCR000321.
316b Cooling Water Intake Structure Requirements
The facility does not have a cooling water intake structure but obtains their cooling water from the Woodruff -
Roebuck Water District. The water district withdraws water from both the North Tyger River and the South Tyger
River and processes about 2.6 million gallons of water per day, according to their website (http://wrwd.org/about/).
Based on the estimated discharge amount of cooling tower blowdown, the cooling water used by the Ramey Plant is
less than 1% of the total amount processed by the water district each day. Therefore, cooling water intake
requirements are not required in this permit.
II. GENERAL INFORMATION
A. The effluent from this facility may be subject to the requirements of any of the following regulations: R.61-68,
R.61-69, R.61-9.122, 124, 125, 129, 133, and 403; 40 CFR Part 136; Subchapter N (40 CFR Parts 400 through 402 and
404 through 471); and R.61-9.503, 504 and 505.
B. Authority: This permit is written in accordance with applicable laws and regulations including, but not limited to,
Regulation 61-9, Regulation 61-68, Pollution Control Act and Clean Water Act.
C. Under R.61-9.124.8 (Fact Sheet), a fact sheet shall be prepared for every draft permit for a major NPDES facility or
activity, for every Class I sludge management facility, for every NPDES draft permit that incorporates a variance or
requires an explanation under section 124.56(b), and for every draft permit which the Department finds is the subject
of wide -spread public interest or raises major issues.
D. The conclusions noted in the Rationale establish proposed effluent limitations and permit requirements
addressed in R.61-9.122.43 (Establishing Permit Conditions), R.61-9.122.44 (Establishing Limitations, Standards and
other permit conditions) and other appropriate sections of R.61-9.
III. BACKGROUND AND PROCEDURES FOR PERMIT LIMIT DEVELOPMENT
A. The receiving waterbody 7Q10, annual average flow or other critical flow condition at the discharge point, and
7Q10, annual average flow, or other critical flow condition for source water protection are determined by the
SCDHEC's Wasteload Allocation Section. The 7Q10, Annual Average Flow or other critical flow conditions are based

Rationale
Page 27 of 49
Permit No. SC0002496
on information published or verified by the USGS, an estimate extrapolation from published or verified USGS data
or from data provided by the permittee. These flows may be adjusted by the Wasteload Allocation Section to
account for existing water withdrawals that impact the flow. The 7Q10 (or 30Q5 if provided by the applicant),
annual average flow at the discharge point, or other critical flow condition or 7Q10 (or 30Q5 if provided by the
applicant), annual average flow or other critical flow condition for source water protection for a proposed or
existing surface water drinking water intake will be used to determine dilution factors, as appropriate, in accordance
with R.61-68.C.4.a & 4.b for aquatic life, human health, and organoleptic effects respectively.
B. Water and organism consumption and drinking water MCL criteria will be evaluated for protection of human
health when calculating dilution factors. "The Department may, after Notice of Intent included in a notice of
a proposed NPDES permit in accordance with Regulation 61-9.124.10, determine that drinking water MCLs
or W/O shall not apply to discharges to those waterbodies where there is: no potential to affect an existing
or proposed drinking water source and no state -approved source water protection area." For permitting
purposes, "a proposed drinking water source is one for which a complete permit application, including plans
and specifications for the intake, is on file with the Department at the time of consideration of an NPDES
permit application for a discharge that will affect or has the potential to affect the drinking water source"
(R.61-68.E.14.c(5)).
The Department will implement this protection in NPDES permits using the source water protection
program already developed for the drinking water program. A source water protection program was
developed originally in 1999 to define the source water protection areas for each drinking water intake. The
program was designed to identify source water protection areas (SWPAs) to aid drinking water systems in
identifying sources of potential contamination that could affect their intakes. In September 2009, this
program was modified to redefine the SWPAs as smaller, more manageable areas. The revised document
developed in September 2009 is entitled "South Carolina Drinking Water Source Assessment and Protection
Program." For the purposes of NPDES permitting, the SWPA referred to in Regulation 61-68.E.14.c(5) is the
Primary Protection Area defined in the revised assessment and protection document. More information
regarding the use of these protection areas is provided later in this rationale with the discussion of the
procedure for establishing permit limits in Section G.2.
C. Application of numeric criteria to protect human health: If separate numeric criteria are given for organism
consumption, water and organism consumption (W/O), and drinking water Maximum Contaminant Levels
(MCLs), they shall be applied as appropriate. The most stringent of the criteria shall be applied to protect
the existing and classified uses of the waters of the State (R.61-68.E.14.b(1)).
D. Numeric criteria have been established in R.61-68 based on organoleptic data (prevention of undesirable
taste and odor). For those substances which have aquatic life and/or human health numeric criteria and
organoleptic numeric criteria, the most stringent of the three shall be used for derivation of permit effluent
limitations. See R.61-68.E.13.
E. Sampling Frequency: Samples and measurements taken for the purpose of monitoring shall be
representative of the monitored activity. Monitoring results must be conducted according to test
procedures approved under 40 CFR Part 136, unless other test procedures have been specified in the
permit (R.61-9.122.410)(4)). Typically, requirements to report monitoring results shall be established on a
case -by -case basis with a frequency dependent on the nature and effect of the discharge but in no case less
than once a year (R.61-9.122.44(i)(2)).
F. Compliance Schedules:

Rationale
Page 28 of 49
Permit No. SC0002496
A person issued an NPDES permit by the Department who is not in compliance with applicable effluent
standards and limitations or other requirements contained therein at the time the permit is issued, shall
be required to achieve compliance within a period of time as set forth by the Department, with effluent
standards and limitations, with water quality standards, or with specific requirements or conditions set by
the Department. The Department shall require compliance with terms and conditions of the permit in the
shortest reasonable period of time as determined thereby or within a time schedule for compliance which
shall be specified in the issued permit. (R.61-9.122.47(c)(1))
2. If a time schedule for compliance specified in an NPDES permit which is established by the Department,
exceeds nine (9) months, the time schedule shall provide for interim dates of achievement for compliance
with certain applicable terms and conditions of the permit. (R.61-9.122.47(c)(2))
G. Procedure for establishing effluent limitations:
1. Effluent limits (mass and concentration) for Five day Biochemical Oxygen Demand (BODO, Ultimate
Oxygen Demand (UOD), Dissolved Oxygen (DO), Total Ammonia Nitrogen (as N), and Nutrients (e.g.,
nitrogen and phosphorus) are established by the Wasteload Allocation (WLA) Section, with consideration
given to technology -based limitations.
a. Five day Biochemical Oxygen Demand BOD5, Ultimate Oxygen Demand (UOD), Dissolved Oxygen
(DO):
Effluent limits for conventional oxygen demanding constituents (BOD5, UOD and DO) are established
to protect in -stream water quality, while utilizing a portion of the assimilative capacity of the
receiving water. The ability of a water body to assimilate oxygen -demanding substances is a function
of its physical and chemical characteristics above and below the discharge point. Various
mathematical techniques, called models, have been developed to estimate this capacity. The
Department follows the procedures as outlined in the "State/EPA Region IV Agreement on the
Development of Wasteload Allocations/Total Maximum Daily Loads and NPDES Permit Limitations"
dated October 30, 1991 (as updated) for determining the assimilative capacity of a given water body.
Mathematical models such as QUAL2E and QUAL2E-UNCAS are used in accordance with "Enhanced
Stream Water Quality Models QUAL2E and QUAL2E-UNCAS: Documentation and Users Manual"
(EPA/600/3-87/007; dated May 1987) as updated. BOD5 and UOD values determined from modeling
results will be used in permitting as monthly average derived limits (C,/,). Daily maximum derived
limits will typically be determined by multiplying the monthly average value by two.
For facilities subject to effluent guidelines limitations or other technology -based limitations, BOD5
will also be evaluated in accordance with the applicable industrial categorical guidelines. These
guidelines will be identified in Part I of this rationale when they are applicable to the permit.
b. Total Ammonia Nitrogen (as N):
Ammonia limitations based on oxygen demand will be determined from modeling information as
described above. These values will be used as monthly average derived limits and a daily maximum
will typically be determined by multiplying the monthly average derived limit by two. These values
will be compared with the ammonia water quality criteria for protection of aquatic life from
Regulation 61-68, Attachment 3 and any categorical limitations. The more stringent of the limitations

Rationale
Page 29 of 49
Permit No. SC0002496
will be imposed. Calculations for aquatic life criteria and other wasteload recommendations are
shown in Part I of this rationale when ammonia is a pollutant of concern.
c. Discharges of Nutrients:
In order to protect and maintain lakes and other waters of the State, consideration is given to the
control of nutrients reaching the waters of the State. Therefore, in accordance with regulation R.61-
68.E.11, the Department controls the nutrients as prescribed below. Nutrient limitations will be
determined from the best available information and/or modeling performed by the Wasteload
Allocation Section to meet these water quality standards.
Discharges of nutrients from all sources, including point and nonpoint, to waters of the State
shall be prohibited or limited if the discharge would result in or if the waters experience growths
of microscopic or macroscopic vegetation such that the water quality standards would be
violated or the existing or classified uses of the waters would be impaired. Loading of nutrients
shall be addressed on an individual basis as necessary to ensure compliance with the narrative
and numeric criteria.
Numeric nutrient criteria for lakes are based on an ecoregional approach which takes into
account the geographic location of the lakes within the State and are listed below. These
numeric criteria are applicable to lakes of 40 acres or more. Lakes of less than 40 acres will
continue to be protected by the narrative criteria.
1. For the Blue Ridge Mountains ecoregion of the State, total phosphorus shall not exceed 0.02
mg/I, chlorophyll a shall not exceed 10 ug/I, and total nitrogen shall not exceed 0.35 mg/I
2. For the Piedmont and Southeastern Plains ecoregions of the State, total phosphorus shall
not exceed 0.06 mg/I, chlorophyll a shall not exceed 40 ug/I, and total nitrogen shall not
exceed 1.50 mg/I
3. For the Middle Atlantic Coastal Plains ecoregion of the State, total phosphorus shall not
exceed 0.09 mg/I, chlorophyll a shall not exceed 40 ug/I, and total nitrogen shall not exceed
1.50 mg/I.
iii. In evaluating the effects of nutrients upon the quality of lakes and other waters of the State, the
Department may consider, but not be limited to, such factors as the hydrology and
morphometry of the waterbody, the existing and projected trophic state, characteristics of the
loadings, and other control mechanisms in order to protect the existing and classified uses of
the waters.
iv. The Department shall take appropriate action, to include, but not limited to: establishing
numeric effluent limitations in permits, establishing Total Maximum Daily Loads, establishing
waste load allocations, and establishing load allocations for nutrients to ensure that the lakes
attain and maintain the narrative and numeric criteria and other applicable water quality
standards.
v. The criteria specific to lakes shall be applicable to all portions of the lake. For this purpose, the
Department shall define the applicable area to be that area covered when measured at full pool

Rationale
Page 30 of 49
Permit No. SC0002496
elevation.
2. Effluent concentration limits (Cefflim) for parameters other than the parameters listed in G.1.a-c (except
ammonia toxicity calculations) above are established using the following procedures:
Q7QI0 7Q10 or other critical flow condition of the receiving water at the discharge point in
mgd. (may require adjustment for withdrawals)
AAFd Average Annual Flow (AAF) or other critical flow condition of the receiving water at
the discharge point in mgd. (may require adjustment for withdrawals)
Q7Q10i 7Q10 or other critical flow condition of the receiving water at either the SWP Area 15-
river mile boundary or at the intake, as appropriate, in mgd.
AAFi Average Annual Flow (AAF) of the receiving water at either the SWP Area 15-river mile
boundary or at the intake, as appropriate, in mgd.
Qd Long term average discharge flow in mgd.
a. Determine dilution factors:
The following information is to be used (where applicable) for establishing effluent concentration
limits:
DF,: This dilution factor is based on 7Q10 or other critical flow condition of the receiving water at
the discharge point (Q7Q10). This dilution factor is used to determine the derived limits for
protection of the following aquatic life and human health concerns for the reasons indicated:
i. Aquatic Life (see R.61-68.C.4.a(1)). Protection of aquatic life on a short-term basis is
needed at the point where aquatic organisms become exposed to the discharge.
ii. Human Health - Organism Consumption for parameters identified as non -carcinogens
per R.61-68.C.4.b(1). Protection for human health on a short-term basis for consumption
of aquatic organisms is needed at the point the aquatic organisms become exposed to
the discharge.
DF, = Q7Q10 + Qd
Qd
DF2: This dilution factor is based on the Average Annual Flow or other critical flow of the receiving
water at the discharge point (AAFd). This dilution factor is used to determine the derived
limits for protection of the following human health and organoleptic concerns for the
reasons indicated:
i. Human Health - Organism Consumption for parameters identified as carcinogens per
R.61-68.C.4.b(1). Protection for human health on a long-term basis to prevent cancer due
to consumption of aquatic organisms is needed at the point the aquatic organisms
become exposed to the discharge.
ii. Organoleptic effects per R.61-68.C.4.b(1). Protection for taste and odor issues related to
the discharge is needed at the point where the discharge enters the receiving water.

Rationale
Page 31 of 49
Permit No. SC0002496
(AAF, + Qd
DFz = Qd
DF3: This dilution factor is based on the 7Q10 or other critical flow condition (Q,QIOi) for protection
of a proposed or existing surface water drinking water intake that the discharge has the
potential to affect. This dilution factor is used to determine the derived limits for protection
of the following human health concerns for the reasons indicated:
Human Health - Water and Organism (W/O) Consumption for parameters identified as
non -carcinogens per R.61-68.C.4.b(1) and E.14.c(5) to protect for short-term health
effects when the discharge has the potential to affect a surface water drinking water
intake. Protection of human health relative to drinking the water from the waterbody
and consuming aquatic organisms from the same waterbody is provided by this
criterion, but drinking the water withdrawn from the waterbody may require a higher
level of protection in terms of applicable dilution than consumption of organisms.
ii. Human Health - Drinking Water Maximum Contaminant Level (MCL) for parameters
identified as non -carcinogens per R.61-68.C.4.b(1) and E.14.c(5) to protect for short-term
health effects when the discharge has the potential to affect a surface water drinking
water intake. Protection of human health relative to drinking the water from the
waterbody after conventional treatment per R.61-68.G is provided by this criterion.
DF3 = Q7QIOi + `�'d
Qd
DF4: This dilution factor is based on the Average Annual Flow or other critical flow condition (AAFi)
for protection of a proposed or existing surface water drinking water intake that the
discharge has the potential to affect. This dilution factor is used to determine the derived
limits for protection of the following human health concerns for the reasons indicated:
Human Health -Water and Organism Consumption for parameters identified as
carcinogens per R.61-68.C.4.b(1) and E.14.c(5) to protect for long-term health effects due
to cancer when the discharge has the potential to affect a surface water drinking water
intake. Protection of human health relative to drinking the water from the waterbody
and consuming aquatic organisms from the same waterbody is provided by this
criterion, but drinking the water withdrawn from the waterbody may require a higher
level of protection in terms of applicable dilution than consumption of organisms.
ii. Human Health - Drinking Water Maximum Contaminant Level (MCL) for parameters
identified as carcinogens per R.61-68.C.4.b(1) and E.14.c(5) to protect for long-term
health effects due to cancer when the discharge has the potential to affect a surface
water drinking water intake. Protection of human health relative to drinking the water
from the waterbody after conventional treatment per R.61-68.G is provided by this
criterion.

Rationale
Page 32 of 49
Permit No. SC0002496
DF = AAF. + Qd
4 Qd
For both DF3 and DF4, to satisfy the mixing zone requirements of R.61-68.C.10(a) for both W/O and
MCL criteria, the Department will use the following flows to determine dilution:
1. The following applies to discharges and intakes in flowing rivers:
a. Where the discharge is within the SWPA (15 river miles) of the intake, the flow at the 15-river
mile boundary of the tributary with the largest applicable critical flow will be used.
b. Where the discharge is outside the SWPA (15 river miles) of the intake, the applicable critical
flow at the intake will be used.
2. When the discharge is either in the tributary to a lake or in a lake and the intake is in the same
lake that does not behave as a run -of- river impoundment*, the flow is determined using the
sum of the applicable critical flows of all tributaries entering the lake.
3. The following applies when both the discharge and the intake are in a lake arm that behaves as
a run -of -river impoundment*:
a. Where the discharge is within the SWPA (15-mile buffer which may include both lake and
river miles) of the intake, the flow at the 15-mile boundary of the tributary with the largest
applicable critical flow will be used.
b. Where the discharge is outside the SWPA (15-mile buffer which may include both lake and
river miles) of the intake, the applicable critical flow at the intake will be used.
4. Where the discharge is in the arm of a lake and the intake is in the upper reach of another arm
of the lake, no protection of W/O or MCL criteria is needed because the discharge does not have
the potential to affect the intake,
5. If the discharge has the potential to affect multiple intakes, the SWPA of the intake closest to the
discharge will be protected. However, the permittee may be required to provide notification to
all potentially affected intakes.
* Run -of -river impoundment is defined as a lake or reservoir (or arm of a lake or reservoir) that is
narrow and/or shallow offering little dilution or delay in contaminant flow toward an intake.
b. Determine derived limits using the following procedures:
WQSpi Freshwater Standard (based on an established criteria or other published data per R.61-68)
for protection of Aquatic Life; may be a CCC or CIVIC as defined below
WQSorg Standard (based on an established criteria or other published data per R.61-68) for
protection of Human Health - Organism Consumption
WQSwo Standard (based on an established criteria or other published data per R.61-68) for
protection of Human Health - Water & Organism Consumption.
WQS,,,,i Standard (based on an established criteria or other published data per R.61-68) for Drinking

Rationale
Page 33 of 49
Permit No. SC0002496
Water MCL (Maximum Contaminant Level).
WQSpI: Standard (based on an established criteria or other published data per R.61-68) based on
Organoleptic Data.
Cpglife Concentration limit derived from aquatic life data
CHH Concentration limit derived from human health data as determined from organism (Cprg),
water/organism (Cw,)and MCL (Cn,,l) data
Col Concentration limit derived from organoleptic data
Cb The background concentration of the concerned parameter in mg/I is typically
determined from ambient monitoring data or data provided by applicant. If the waterbody
to which the discharge flows is not on the 303(d) list, the 901" percentile of ambient
monitoring data for aquatic life protection for the parameters identified in the Appendix
(Water Quality Numeric Criteria) to Regulation 61-68 from the last 3 years, or whatever is
available if less than 3 years, will typically be used. If the waterbody to which the discharge
flows is not on the 303(d) list, the median value of ambient monitoring data for human
health protection for the parameters identified in the Appendix (Water Quality Numeric
Criteria) to Regulation 61-68 from the last 3 years, or whatever is available if less than 3
years, will typically be used. The background concentration is assumed to be zero (0) in the
absence of actual data based on Departmental guidance and EPA recommendation.
i. Determine the derived limits for protection of Aquatic Life (Cpglife)
1. The following guidelines apply to determining aquatic life limits using this basic equation:
�
Clgl fe = (DF X WQS,,) _ Cb X Q7g10
Q d
a. Typically, the Criterion Maximum Concentration (CMC) is applied as a daily maximum
derived limit and the Criterion Continuous Concentration (CCC) is applied as a monthly
average derived limit, after consideration of dilution and background concentrations.
The CMC and CCC for specific metals will be adjusted using the procedures in 60 FIR
22229, "Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants; States' Compliance -Revision of Metals Criteria," May 4, 1995 and the
"Technical Guidance on Interpretation and Implementation of Aquatic Life Metals
Criteria," Oct. 1, 1993 and applied as a daily maximum and monthly average,
respectively, after consideration of dilution and background concentrations. For specific
metals, this calculation is explained in detail later in this rationale.
monthly average = Cpglife using CCC as WQSpI
daily maximum = Cpgrfe using CMC as WQSpI
b. If only a CMC exists for a particular parameter, the daily maximum derived permit limit
will be set using that value, after consideration of dilution and background
concentrations. If no other values (e.g., human health) exist for that parameter on which
to base a monthly average limit and the discharge is continuous, the monthly average
will be set equal to the daily maximum to satisfy Regulation 61-9.122.45(d). In no case
shall the monthly average limit be set higher than the daily maximum limit. If only a CCC
is given, it will be used as a monthly average derived limit and the daily maximum

Rationale
Page 34 of 49
Permit No. SC0002496
derived limit will be two (2) times the value obtained for the monthly average based on a
simplified statistical procedure for determining permit limits recommended in Section
5.4.2 of the US EPA's "Technical Support Document for Water Quality -based Toxics
Control", EPA/505/2-90-001, March 1991 (hereafter known as the TSD).
If a CCC exists and no CIVIC exists and no other acute or chronic data exists, the aquatic
life limits are
monthly average = Cpglife using CCC as WQSpI
daily maximum = 2 x Cpglife
If a CMC and no CCC exists, and no other acute or chronic data exists, the aquatic life
limits are
monthly average = Cpglfe using CIVIC as WQSp/
daily maximum = Cpglfe using CIVIC as WQSp/
c. If only an acute toxicity effect concentration for a number of species for a particular
pollutant is given as a LCso, the lowest concentration should be divided by an acute -to -
chronic ratio (ACR) of 10 and a sensitivity factor of 3.3, for an acceptable instream
concentration in order to protect against chronic toxicity effects (R.61-68.E.16.a(1)). Other
acute toxicity data will be handled similarly. The value obtained from this calculation will
be used as a monthly average derived limit after consideration of dilution and
background concentrations. The daily maximum will be two (2) times the value obtained
for the monthly average based on a simplified statistical procedure for determining
permit limits recommended in Section 5.4.2 of the TSD.
monthly average = Cpglfe using other data as WQSpI
daily maximum = 2 x Cpglife
d. If a chronic toxicity effect concentration for a number of species for a particular pollutant
is given as a no observed effect concentration (NOEC), the lowest concentration should
be divided by a sensitivity factor of 3.3 in order to protect against chronic toxicity to the
most sensitive species (R.61-68.E.16.a(2)). Other chronic toxicity data will be handled
similarly. The value obtained from this calculation will be used as a monthly average
derived limit after consideration of dilution and background concentrations. The daily
maximum will be two (2) times the value obtained for the monthly average based on a
simplified statistical procedure for determining permit limits recommended in Section
5.4.2 of the TSD.
monthly average = Cpglife using other data as WQSpI
daily maximum = 2 x Cpglife
e. If both acute and chronic data are available for a particular pollutant, monthly average
derived limit will be calculated as in c and d above for each acute and chronic,
respectively. The more stringent of the monthly average derived limits will be the
monthly average derived limit used after consideration of dilution and background
concentrations. The daily maximum will be two (2) times the value obtained for the

Rationale
Page 35 of 49
Permit No. SC0002496
monthly average based on a simplified statistical procedure for determining permit
limits recommended in Section 5.4.2 of the TSD.
monthly average = Cpglife using other data as WQS,,/
daily maximum = 2 x Caglfe
f. Consider the background concentration (Cb) of the parameter of concern. If the
background concentration is equal to or greater than the applicable standard (WQS, as
defined above) for the parameter of concern, then the derived concentration limit (Cpgl;fe)
for that parameter is established equal to the standard (WQS) so that no additional
amount of that pollutant is added to the waterbody. An exception exists where the
naturally occurring instream concentration for a substance is higher than the derived
permit effluent limitation. In those situations, the Department may establish permit
effluent limitations (Cefflim) at a level higher than the derived limit, but no higher than the
natural background concentration (i.e. a "rise above background" limit). In such cases,
the Department may require biological instream monitoring and/or whole effluent
toxicity (WET) testing (R.61-68.E.14.c(2)).
If Cb is not based on naturally occurring concentrations and
Cb > WQS
Then, generally,
Caglife WQS'
If Cb is based on naturally occurring concentrations and
Cb >_ WQS
Then, generally,
Caglife < Ceff lim G C
2. Metals: Regulation 61-9.122.45(c) requires that permit limits be expressed in terms of total
recoverable metal (with limited exceptions). In order to translate from the water quality
criterion to a total recoverable metal, Regulation R.61-68.E.14.c(4) provides for the use of the
EPA Office of Water Policy and "Technical Guidance on Interpretation and Implementation of
Aquatic Life Metals Criteria", October 1, 1993. A subsequent revision published in the
Federal Register (60 FIR 22229) on May 4, 1995 updated the data in the original report. See
R.61-68 Appendix for CIVIC and CCC values and equations, Attachment 1 for "Conversion
Factors for Dissolved Metals" and Attachment 2 "Parameters for Calculating Freshwater
Dissolved Metals Criteria that are Hardness -Dependent".
Per R.61-68.E.14.a(3), the CIVIC and CCC are based on a hardness of 25 mg/I if the ambient or
mixed stream hardness is equal to or less than 25 mg/I. Concentrations of hardness less
than 400 mg/I may be based on the mixed stream hardness if it is greater than 25 mg/I and
less than 400 mg/I and 400 mg/I if the ambient stream hardness is greater than 400 mg/I.
The ambient stream hardness is assumed to be 25 mg/I in the absence of actual stream
data. Mixed stream hardness may be determined using flow -weighted effluent hardness
and stream hardness.
The following equations and constants will be used to calculate aquatic life metals limits

Rationale
Page 36 of 49
Permit No. SC0002496
based on these documents. The values of the terms referenced in this section and
determined from the equations below are included in the Metals spreadsheet attached to
this rationale. The following metals are subject to this section:
arsenic lead
cadmium mercury
chromium (III & VI) nickel
copper zinc
The equation for Cd below changes the total metal to dissolved metal. From Technical
Guidance Manual for Performing Waste Load Allocations Book II. Rivers and Streams,
E PA/440/484/022,
S = CCC orCMC (adjusted for hardness)
cc, =SxCF
where Cd = Dissolved metal concentration (pg/1)
S = a constant to represent the CCC or CMC (pg/1)
CF = Conversion factor considered most relevant in fresh water for aquatic life
as defined by EPA for each metal
Once the dissolved metal concentration is known, determine Cp using the equation for Cd
above and the following equations.
CP = Cd x { 1 + Kpb x TSS, x 10—' )}
Kpb = Kpa x (TSSb )a
where Cp = Particulate sorbed metal concentration (pg/1). This value
represents the revised water quality criterion for the metal to be used
for ambient data comparison.
Kpb= Linear partition coefficient using the stream TSS (liters/mg)
Kpo= Metal -specific equilibrium constant (liters/mg)
o = Metal -specific constant
TSSb= Background or in -stream Total Suspended Solids (TSS) concentration
(mg/1). The background TSS is assumed to be 1 mg/l in the absence of
actual instream data based on the 5th percentile of ambient TSS data
on South Carolina waterbodies from 1993-2000.
To determine the effluent limit (Cpgrf,), use the following equations to translate the limits into
a total recoverable metal concentration.
TSSavg =
(Qd x TSS, + (Q7Q10 x TSSb
Qd + Q7Q10
where TSS, = Effluent Total Suspended Solids (TSS) concentration (mg/1)

Rationale
Page 37 of 49
Permit No. SC0002496
determined from actual long-term average data or proposed permit
limits if no data available.
TSS,,,g = Average in -stream (mixed) TSS concentration (mg/1)
Cr = Cd x { 1 + (KP x TSSavg x 10-6 )1
Kp = K po x ( TSSavg) a
where Cr = Total metal concentration (pg/1)
Kp = Linear partition coefficient (liters/mg). This is the distribution of metal at
equilibrium between the particulate and dissolved forms.
Once Cr has been calculated, it is multiplied by DF, and background concentrations are
accounted for to obtain the derived limit (max or avg) (Cpglife):
Q7
Cpglife = (C, x DFl) — Cg10
b x Q d
monthly average = Cpglife based on CCC
daily maximum = Cpglife based on CMC
3. Where a Water Effects Ratio (WER) is used to adjust a criterion, derived limits for the
adjusted aquatic life criterion (Cpglife-adj) are calculated as follows. The WER is a type of site -
specific permit effluent limit (as allowed by R.61-68.E.14.c(7)) derived using a ratio
determined from EPA methodology. Both DHEC and EPA must approve the WER prior to
implementation. See EPA's 1994 "Interim Guidance on the Determination and Use of Water -
Effect Ratios (WERs) for Metals." The approved WER will be shown in the water quality
spreadsheets on the Data sheet. The revised aquatic life value will be shown with the WER,
hardness and dissolved metals adjustments, as appropriate, in the aquatic life columns on
the Pollutant spreadsheet.
a. For metals identified in #2 above, revise the equation for S as follows:
S = [CCC or CMC (adjusted for hardness)] x WER
Follow the remaining calculations in #2 above to get an adjusted Cpglife value that will be
used to determine derived limits:
monthly average = Cpglife-adf based on CCC
daily maximum = Cpglife-adf based on CMC
b. For other parameters, use the appropriate equation in #1 above to derive an adjusted
Cpglife value. The monthly average will be calculated as follows using the appropriate
WQS,/ and the daily maximum calculated using the appropriate equations in #1 above.

Rationale
Page 38 of 49
Permit No. SC0002496
Caglife-adj — (DF1 x WQSal x WER) — Cb x Q7Q10
� Q
111 d
4. Where the Recalculation Procedure is used to adjust a criterion, derived limits for the
adjusted aquatic life criterion (Cpgllfe-adj) are calculated as follows. The Recalculation
Procedure is intended to cause a site -specific criterion to appropriately differ from the State -
adopted national aquatic life criterion if justified by demonstrated pertinent toxicological
differences between the aquatic species that occur at the site and those that were used in
the derivation of the criterion. It is important to note that the site (the portion of the
waterbody or watershed being affected) must be clearly defined. This procedure is used to
develop site -specific criteria in accordance with R.61-68.C.12. Both DHEC and EPA must
approve the recalculated criterion prior to implementation. The recalculated criterion will
require an update to the Water Classifications and Standards Regulations, R.61-68 and 61-
69.
The approved recalculated aquatic life criteria (SS-CCC and SS-CMC, as appropriate) will be
shown adjusted for hardness on the Data spreadsheet. The additional dissolved metals
adjustments, as appropriate, will be shown in the aquatic life columns on the Pollutant
spreadsheet. If the parameter being adjusted is one of the metals in #2 above, SS will
include all the appropriate metals adjustments.
_ 1, Q7Q10
aglife-adj — (DF1 x SS — Cb x Q
l d
monthly average = CagGfe-adj based on CCC
daily maximum = Cagfife-adj based on CIVIC
5. Where a WEIR and recalculation procedure are combined to adjust a criterion, derived limits
(Cagl/fe-adj) for aquatic life protection are calculated by combining the calculations in #3 and #4.
C—(DF1 xSSxWER) —�C x Q7Q10
aglife-adj � b Q d
monthly average = Cag;;fe-adj based on CCC
daily maximum = Cagfife-adj based on CIVIC
6. Other scientifically defensible methods for developing site -specific aquatic life effluent limits
or site -specific criterion may be used on a case -by -case basis.
ii. Determine derived limits for protection of Human Health
1. The following guidelines apply to determining human health limits:
a. The human health criterion given by Regulation 61-68 will be applied as a monthly
average derived limit after consideration of dilution and background concentrations (CHH-
Gvg). Exceptions exist based on EPA criteria and are indicated for specific parameters. No
limits on human health based on water and organism consumption or drinking water

Rationale
Page 39 of 49
Permit No. SC0002496
MCLs will be imposed if there is no potential to affect an existing or proposed surface
water drinking water intake and no state -approved source water protection area in
accordance with Regulation 61-68.E.14.c(5).
b. The daily maximum permit limit will be determined from the monthly average value
from (a) above and a multiplier (M) determined using a statistical procedure
recommended in Section 5.5 using average = 951h percentile from Table 5-3 in the TSD.
The permitted or proposed number of samples per month (n) is used with the coefficient
of variation (CV) to determine M.
e(zm6—o.s62 )
M— e(zn6„—o.5,7 2)
where:
�nz =1n CVO +1
n
6 2 =1n(CV z + 1)
CV = coefficient of variation of the effluent concentration. For a data set
where n>10, the CV is calculated as standard deviation divided by mean
for the data set being evaluated. For data set where n<10, the CV is
estimated to equal 0.6. For less than 10 items of data, the uncertainty in
the CV is too large to calculate a standard deviation or mean with
sufficient confidence.
n = the number of effluent samples per month (where frequency is less than
1 /month, n =1)
zn, = the percentile exceedance probability for the daily maximum permit
limit (=2.326 for 99th percentile basis)
z,, = the percentile exceedance probability for the monthly average permit
limit (=1.645 for 95th percentile basis)
CHH-max = M * CHH-avg
c. Consider the background concentration (Cb) of the parameter of concern. If the
background concentration is equal to or greater than the applicable standard (WQS, as
defined above) for the parameter of concern, then the derived concentration limit (CHHO
for that parameter and for the protection of that standard is established equal to the
standard (WQS). An exception exists where the naturally occurring instream
concentration for a substance is higher than the derived permit effluent limitation. In
those situations, the Department may establish permit effluent limitations (Ceffrn,) at a
level higher than the derived limit, but no higher than the natural background
concentration (i.e. a "rise above background" limit). In such cases, the Department may
require biological instream monitoring and/or whole effluent toxicity (WET) testing (See
R.61-68. E.14.c(3)).
If Cb is not based on naturally occurring concentrations and
Cb > WQS

Rationale
Page 40 of 49
Permit No. SC0002496
Then, generally,
Cull = WQS .
If Cb is based on naturally occurring concentrations and
Cb >_ WQS
Then, generally,
CHH < Ceff lien < Cb
2. Human Health - Organism Consumption (Corg).
a. For Carcinogens
The Monthly Average is calculated as follows:
CO, = (DF2 x WQSorg) — Cb X (AAF,
Qd
The Daily Maximum is calculated as
Corg-max = M * Corg
b. For Non -carcinogens
The Monthly Average is calculated as follows:
1, Q7QIo
Corg = (DF, X WQSorg) — I Cb X G d
The Daily Maximum is calculated as
Corg-max = M * Corg
3. Human Health - Water and Organism Consumption (Cwo)
a. For Carcinogens
The Monthly Average is calculated as follows:
C,,o = (DF4 x WQS.o) — I Cl, x AAF
Qa
The Daily Maximum is calculated as
Cwo-max = M * Cwo
b. For Non -carcinogens
The Monthly Average is calculated as follows:

Rationale
Page 41 of 49
Permit No. SC0002496
��++
�
C,,,a = (D- 3 X WQS'J Cb X (g!LL
111 d
The Daily Maximum is calculated as
Cwo-max = M * Cwo
4. Human Health -Drinking Water Maximum Contaminant Level (MCL) (Cmcl).
a. For Carcinogens
The Monthly Average is calculated as follows:
�
Cmcl = (DF4 X WQSrncl) C6 X AAF Q d
The Daily Maximum is calculated as
Cmcl-max = M * Cmcl
b. For Non -carcinogens
The Monthly Average is calculated as follows:
Cmcl = (DF3 X WQSmcl) Cb X(gILILI
Q d
The Daily Maximum is calculated as
Cmcl-max = M * Cmcl
5. Organoleptic criteria (Cal).
The Monthly Average is calculated as follows:
Cal = (DF2 X WQSoI) — Cb X (AAFd
/�
`c'd
The Daily Maximum is calculated as
Col -max = M * Col
iii. Parameters given in a wasteload allocation for oxygen -demanding pollutants and nutrients will
be limited as
monthly average = C,,la
daily maximum = 2 x C,,la

Rationale
Page 42 of 49
Permit No. SC0002496
c. Determine the most stringent of applicable water quality data using the derived limits determined
above:
monthlyaverage Ceffrm= minimum of derived monthly averages (Caplife, Corg, Cwo, Cmd, Cal, Cwla)
daily maximum Cefflim = minimum of derived daily maximums (Cagllfe, Corg-max, Cwo-max, Cmd-max, Col -max,
Cwla-max)
d. Determine whether the discharge causes, has the reasonable potential to cause or contributes to a
water quality violation.
Regulation 61-9.122.44(d)(1)(i) states: "Limitations must control all pollutants or pollutant
parameters (either conventional, nonconventional, or toxic pollutants) which the Department
determines are or may be discharged at a level which will cause, have the reasonable potential to
cause, or contribute to an excursion above any State water quality standard, including State
narrative criteria for water quality."
When determining whether a discharge causes, has the reasonable potential to cause or contributes
to an instream excursion, the Department will use procedures which account for controls on point
and nonpoint sources of pollution, the variability of the pollutant in the effluent, the sensitivity of the
species to toxicity testing (when evaluating whole effluent toxicity), and, where appropriate, the
dilution of the effluent in the receiving water (R.61-9.122.44(d)(1)(ii)).
Based on the above statements, there are three scenarios when limitations are required, as follows:
When data provided by the permit applicant indicates discharge values greater than the
proposed limitation derived above, that discharge may cause an excursion above a narrative or
numeric water quality criterion.
ii. A discharge may be determined to contribute to an excursion of a water quality criterion when
the waterbody is impaired (e.g., on the 303(d) list) for the parameter of concern and that
parameter is also being discharged at levels above the water quality criterion.
iii. Reasonable potential to cause a water quality violation is determined using the following
information:
The Department will primarily use EPA's Technical Support Document (TSD) for determining
reasonable potential using effluent data. Other methods may be used as well to evaluate data
sets. All pollutants given in a wasteload allocation or an effluent limitation guideline will be
limited in the permit.
When effluent data consists of non-quantifiable/non-detectable values or when no effluent data
is available, other factors and information are considered to determine reasonable potential. In
situations where a pollutant is known to be present in the wastestream (due to production data
or other information), we know it is being discharged and has the potential to impact even
though it may not be quantifiable. The fact that it is present will be enough information to say
reasonable potential exists for that pollutant. Therefore, a reasonable potential decision is
based on various data and information, and not just non-quantifiable/non-detectable data.
Consideration is given to existing data, dilution in the waterbody, type of receiving water,

Rationale
Page 43 of 49
Permit No. SC0002496
designated use, type of industry/wastestream, ambient data, history of compliance, and history
of toxic impact. If any source of information indicates reasonable potential to cause or
contribute to an exceedance of the water quality standard, a water quality limit will be
established.
Note: The result of the following calculations may indicate that reasonable potential does not
exist. However, as stated above, other information may "override" this numerical determination
to justify the need for a limit.
The procedure for determining reasonable potential from actual effluent data is explained in
Box 3-2 on page 53 of the TSD. Multiplying factors are determined from Table 3-2 at a 95%
confidence level and 95% probability in Section 3.3.2. The following describes the
procedures used for determining reasonable potential for chemical -specific parameters and
WET, under certain circumstances. More information on determining reasonable potential
for WET is given in Item 2 below.
Step 1: Data Analysis: The statistical calculations involved in the "Reasonable Potential'
analysis require discrete numerical data. The following describes how the effluent
data will be used in determining reasonable potential.
Actual analytical results should be used whenever possible. Results less than
detection and quantification should be used as follows:
a. If the permittee reports results below the practical quantitation limit (PQL) (as
defined by the permit), then the reported "less than PQL" value for a given sample is
generally assumed to be zero.
b. If the permittee uses a detection/quantification level that is greater than the PQL,
then the reported "less than" value for a given sample is generally assumed to be a
discrete value equal to the detection/quantification level used by the permittee.
c. If the reported data consists of both discrete and non -discrete values and/or the
data is reported using varying detection/quantification levels, then, generally, a
combination of the above two approaches is used, or the data is evaluated in a
manner that is most appropriate for that data set.
Note: For information on the acceptable analytical methods and PQLs please refer
to NPDES permit application attachment titled "Practical Quantitation Limits (PQL)
and Approved Test Methods."
Step 2: Using data from the permit application, other data supplied by the applicant and/or
Discharge Monitoring Report (DMR) data, determine the total number of
observations (n) for a particular set of effluent data and determine the highest value
(C,,pX) from that data set. For the monthly average comparison, the data set will
include monthly average results and n will be the number of months in which they
sampled in the time period being evaluated. For the daily maximum comparison,
the data set will include daily maximum results and n will be the total number of
samples in the time period being evaluated. Individual results may not necessarily

Rationale
Page 44 of 49
Permit No. SC0002496
be used in the calculation.
Step 3: Determine the coefficient of variation (CV) for the data set. For a data set where
n>10, the CV is calculated as standard deviation divided by mean for the data set
being evaluated. For data set where n<10, the CV is estimated to equal 0.6. For less
than 10 items of data, the uncertainty in the CV is too large to calculate a standard
deviation or mean with sufficient confidence.
CV=0.6 for n<10
CV=- for n>10
P
where: 6 = Standard Deviation of the samples
p = Mean of the samples
Step 4: Determine the appropriate multiplying factor (MF) from either Table 3-2 or using the
formulae in Section 3.3.2 of the TSD.
a. Determine the percentile represented by the highest concentration in the sample
data.
pn = (1— Confidence Level)'"
where: pn = Percentile represented by the highest concentration in the data
n = number of samples
Confidence Level = 0.95 i.e. 95%
b. Determine the multiplying factor (MF), which is the relationship between the
percentile described above (Cp) and the selected upper bound of the lognormal
effluent distribution, which in this case will be the 95t" percentile (C95).
C e(z95CT+o.5U2)
MF = 9s =
C e(ZpQ+D.SQ2)
P
where: Z95 is the standardized Z-score for the 95t" percentile of the standardized
normal distribution = 1.645
Zp is the standardized Z-score for the pt" percentile of the
standardized normal distribution.(determined in (b) above)
Note: The values of Z-scores are listed in tables for the normal distribution. If using
Microsoft® Excel, this can be calculated using the NORMSINV function.
6' =1n(CV z + 1)

Rationale
Page 45 of 49
Permit No. SC0002496
6 = ln(CV 2 + 1)
Step 5: Multiply the highest value from the data set (Cmax) by the multiplying factor (MF)
determined in Step 4 to obtain the maximum receiving water concentration (RWC).
R WC = Cmax X MF
Step 6: RWC <_ Derived limit (Cefflim) implies that reasonable potential does not exist.
RWC > Derived limit (Ceffiim) implies that reasonable potential exists.
2. Reasonable potential for Whole Effluent Toxicity (WET) may be determined from numerical
data using the following procedure:
a. When the effluent data is given in terms of percent effluent as an IC25, LCso and/or NOEC
values:
Step 1: Convert the given values to toxic units: TUa for acute data and TUc for chronic data,
respectively, using the following formulae. Please note that an NOEC derived using
the IC25 is approximately the analogue of an NOEC derived using hypothesis testing.
The IC25 is the preferred statistical method for determining the NOEC (EPA TSD,
March 1991, p.6).
TUQ = 100
LCso
TU = 100 or TU = 100 if IC2s available
NOEC IC2s
Step 2: Using DMR data or other data provided by the applicant, determine the total number
of observations (n) for a particular set of effluent data and determine the highest
value (TUa, max or TUc, max) from that data set.
Step 3: Determine the coefficient of variation (CV) for the data set. For a data set where
n>10, the CV is calculated as standard deviation divided by mean. For data set where
n<10, the CV is estimated to equal 0.6. For less than 10 items of data, the uncertainty
in the CV is too large to calculate a standard deviation or mean with sufficient
confidence.
Step 4: Determine the appropriate multiplying factor (MF) from either Table 3-2 or using the
formulae in Section 3.3.2. (see iii.1, Step 4 above).
Step 5: Multiply the highest value of TUa, max or TUc, max from the data set by the multiplying
factor (MF) determined in Step 4 and the dilution at the edge of the mixing zone (the
test concentration obtained from mixing zone modeling or demonstration) to obtain
the maximum receiving water concentration (RWC)

Rationale
Page 46 of 49
Permit No. SC0002496
RWC for Acute Toxicity = [TU,, max * MF * conc. at MZ boundary]
RWC for Chronic Toxicity = [TUc, max * MF * conc. at MZ boundary]
Step 6: RWC for Acute Toxicity <_ 0.3TUp implies that a reasonable potential does not exist
RWC for Acute Toxicity > 0.3TUp implies that a reasonable potential exists
RWC for Chronic Toxicity <_ 1.OTUc implies that a reasonable potential does not exist
RWC for Chronic Toxicity >1.OTU, implies that a reasonable potential exists
b. Other methods for determining reasonable potential may be used if appropriately
justified.
e. Consider Effluent Limitations Guidelines (ELG or Categorical guidelines)
The more stringent of the effluent limitations guidelines average and maximum derived limits and
water quality -derived average and maximum limits shall be used as permit limits, unless other
information indicates more stringent limits are needed (e.g. previous permit limits due to
backsliding). Categorical limitations based on mass may be converted to concentration using the
long-term average flow of the discharge for comparison to the monthly average and daily maximum
derived limits.
1. For effluent guidelines based on production, limits will be calculated as follows:
ELG lira = Y (ELGprod)(ELG) where
ELGIim: the mass limit, in Ibs/day, for an applicable pollutant based on the production
ELGprod. the production rate, in Ibs, for the applicable guideline(s), usually based on long-term
average data
ELG: the effluent guideline limitation, given as a measure of production (e.g. Ibs/1000 Ibs), for an
applicable pollutant
2. For effluent guidelines based on flow, limits will typically be calculated as follows:
ELG lim = Y (ELGflow)(ELG)(8.345)
ELGIim: the mass limit, in Ibs/day, for the applicable pollutant based on the applicable flow
ELGflow: the long-term average process flow rate, in MGD, for the applicable guideline(s) (unless
otherwise specified in the guideline)
ELG: the concentration limitation, in mg/I, for the applicable pollutant from the applicable
guideline(s)
H. Other considerations
1. When the derived permit effluent limitation based on aquatic life numeric criteria is below the practical
quantitation limit for a substance, the derived permit effluent limitation shall include an accompanying
statement in the permit that the practical quantitation limit using approved analytical methods shall be
considered as being in compliance with the limit. Appropriate biological monitoring requirements shall
be incorporated into the permit to determine compliance with appropriate water quality standards

Rationale
Page 47 of 49
Permit No. SC0002496
(R.61-68.E.14.c(2)).
2. When the derived permit effluent limitation based on human health numeric criteria is below the
practical quantitation limit for a substance, the derived permit effluent limitation shall include an
accompanying statement in the permit that the practical quantitation limit using approved analytical
methods shall be considered as being in compliance with the limit (R.61-68.E.14.c(3)).
3. The effluent concentration limits determined above may not necessarily be the NPDES permit limit.
NPDES Permit limits are determined after a reasonable potential analysis is conducted using these
derived limits and also after evaluating other issues such as anti -backsliding and antidegradation.
4. When mass limits are calculated, the formula to be used is as follows.
Mass (Ib/day) = Flow (mgd) * Concentration (mg/1) * 8.345
5. Per Regulation 61-9.122.45(d), for continuous discharges all permit effluent limitations, standards, and
prohibitions, including those necessary to achieve water quality standards, shall unless impracticable be
stated as maximum daily and average monthly discharge limitations for all dischargers other than
publicly owned treatment works.
6. Anti backsliding: When a permit is reissued, the terms and conditions of the reissued permit must be at
least as stringent as those final limits in the previous permit unless certain exceptions are met (see
Regulation 61-9.122.44.1).
IV. PROCEDURES FOR REACHING A FINAL PERMIT DECISION
A. Comment Period (R.61-9.124.10 and l l)
The Department of Health and Environmental Control proposes to issue an NPDES permit to this applicant
subject to the effluent limitations and special conditions outlined in this document. These determinations
are tentative.
During the public comment period, any interested person may submit written comments on the draft
permit to the following address:
SC Dept. of Health and Environmental Control
Water Facilities Permitting Division
Bureau of Water
2600 Bull Street
Columbia, South Carolina 29201
For additional information, interested persons may contact Randy Thompson at 803-898-4314.
All written comments received during the public comment period shall be considered in making the final
decision and shall be responded to as prescribed below.
Per R.61-9.124.17, the Department is only required to issue a response to comments when a final permit is

Rationale
Page 48 of 49
Permit No. SC0002496
issued. This response shall:
1. Specify which provisions, if any, of the draft permit have been changed in the final permit decision, and
the reasons for the change; and
2. Briefly describe and respond to all significant comments on the draft permit raised during the public
comment period, or during any hearing.
The response to comments shall be available to the public.
B. Public Hearings (R.61-9.124.11 and 12)
During the public comment period, any interested person may request a public hearing, if no hearing has
already been scheduled. A request for a public hearing shall be in writing and shall state the nature of the
issues proposed to be raised in the hearing.
Determinations and Scheduling.
Within the thirty (30) day comment period or other applicable comment period provided after posting or
publishing of a public notice, an applicant, any affected state or interstate agency, the Regional
Administrator or any other interested person or agency may file a petition with the Department for a
public hearing on an application for a permit. A petition for a public hearing shall indicate the specific
reasons why a hearing is requested, the existing or proposed discharge identified therein and
specifically indicate which portions of the application or other permit form or information constitutes
necessity for a public hearing. If the Department determines that a petition constitutes significant cause
or that there is sufficient public interest in an application for a public hearing, it may direct the
scheduling of a hearing thereon.
2. A hearing shall be scheduled not less than four (4) nor more than eight (8) weeks after the Department
determines the necessity of the hearing in the geographical location of the applicant or, at the discretion
of the Department, at another appropriate location, and shall be noticed at least thirty (30) days before
the hearing. The notice of public hearing shall be transmitted to the applicant and shall be published in
at least one (1) newspaper of general circulation in the geographical area of the existing or proposed
discharge identified on the permit application and shall be mailed to any person or group upon request
thereof. Notice shall be mailed to all persons and governmental agencies which received a copy of the
notice or the fact sheet for the permit application.
3. The Department may hold a single public hearing on related groups of permit applications.
4. The Department may also hold a public hearing at its discretion, whenever, for instance, such a hearing
might clarify one or more issues involved in the permit decision;
5. Public notice of the hearing shall be given in accordance with R.61-9.124.10.
Any person may submit oral or written statements and data concerning the draft permit. Reasonable limits
may be set upon the time allowed for oral statements, and the submission of statements in writing may be
required. The public comment period under R.61-9.124.10 shall automatically be extended to the close of
any public hearing under this section. The hearing officer may also extend the comment period by so

Rationale
Page 49 of 49
Permit No. SC0002496
stating at the hearing.
A tape recording or written transcript of the hearing shall be made available to the public.
C. Obligation to raise issues and provide information during the public comment period. (R.61-9.124.13)
All persons, including applicants, who believe any condition of a draft permit is inappropriate or that the
Department's tentative decision to deny an application, terminate a permit, or prepare a draft permit is
inappropriate, must raise all reasonably ascertainable issues and submit all reasonably available arguments
supporting their position by the close of the public comment period (including any public hearing). No issue
shall be raised during an appeal by any party that was not submitted to the administrative record as part of
the preparation and comment on a draft permit, unless good cause is shown for the failure to submit it. Any
supporting materials which are submitted shall be included in full and may not be incorporated by
reference, unless they are already part of the administrative record in the same proceeding, or consist of
State or Federal statutes and regulations, Department and EPA documents of general applicability, or other
generally available reference materials. Commenters shall make supporting materials not already included
in the administrative record available. (A comment period longer than 30 days may be necessary to give
commenters a reasonable opportunity to comply with the requirements of this section. Additional time
shall be granted under R.61-9.124.10 to the extent that a commenter who requests additional time
demonstrates the need for such time).
D. Issuance and Effective Date of the Permit
1. After the close of the public comment period on a draft permit, the Department shall issue a final permit
decision. The Department shall notify the applicant and each person who has submitted written
comments or requested notice of the final permit decision. This notice shall include reference to the
procedures for appealing a decision on a permit. For the purposes of this section, a final permit
decision means a final decision to issue, deny, modify, revoke and reissue, or terminate a permit.
2. A final permit decision shall become effective 30 days after the service of notice of the decision unless:
(a) A later effective date is specified in the decision; or
(b) No comments requested a change in the draft permit, in which case the permit shall become
effective on the effective date shown in the issued permit.
3. Issuance or Denial of Permits. An appeal to a final determination of the Department or to a condition of
a permit issued or the denial of a permit pursuant to the State law and Regulation 61-9, shall be in
accordance with and subject to 48-1-200 of the SC Code (see E below).
E. Adjudicatory Hearings
Please see the Department's Guide to Board Review:
https://www.scdhec.gov/about-dhec/sc-board-health-and-environmental-control/guide-board-review.

ATTACHMENT 3

STATE OF TENNESSEE
DEPARTMENT OF ENVIRONMENT AND CONSERVATION
DIVISION OF WATER RESOURCES
William R. Snodgrass - Tennessee Tower
312 Rosa L. Parks Avenue, iith Floor
Nashville, Tennessee 37243-1102
January 30, 2020
Mr. Sheldon Sillyman
VP of Business Development
e-copy: ssillyman(iDholliston.com
Holliston Holdings, LLC
905 Holliston Mills Road
Church Hill, TN 37642
Subject: NPDES Permit No. TN0002330
Holliston Holdings, LLC
Church Hill, Hawkins County, Tennessee
Dear Mr. Sillyman:
In accordance with the provisions of the Tennessee Water Quality Control Act, Tennessee Code Annotated (T.C.A.),
Sections 69-3-101 through 69-3-120, the Division of Water Resources hereby issues the enclosed NPDES Permit. The
continuance and/or reissuance of this NPDES Permit is contingent upon your meeting the conditions and requirements as
stated therein.
Please be advised that a petition for permit appeal may be filed, pursuant to T.C.A. Section 69-3-105, subsection (i), by
the permit applicant or by any aggrieved person who participated in the public comment period or gave testimony at a
formal public hearing whose appeal is based upon any of the issues that were provided to the commissioner in writing
during the public comment period or in testimony at a formal public hearing on the permit application. Additionally, for
those permits for which the department gives public notice of a draft permit, any permit applicant or aggrieved person
may base a permit appeal on any material change to conditions in the final permit from those in the draft, unless the
material change has been subject to additional opportunity for public comment. Any petition for permit appeal under this
subsection (i) shall be filed with the Technical Secretary of the Water Quality, Oil and Gas Board within thirty (30) days
after public notice of the commissioner's decision to issue or deny the permit. A copy of the filing should also be sent to
TDEC's Office of General Counsel.
If you have questions, please contact the Johnson City Environmental Field Office at 1-888-891-TDEC; or, at this office,
please contact Miss Julie Harse, P.E. at [phone] or by E-mail at [e-mail].
Sincerely,
AK*4,t
ojin Janjis
Manager, Water -Based Systems
Enclosure
cc: Permit File
Johnson City Environmental Field Office
NPDES Permit Section, EPA Region IV, [e-mail]
Mr. Mike Amyx, Water Treatment Technologist, Holliston Holdings, LLC, [e-mail]
Mr. Jack Brown, Environmental Engineer, Holliston Holdings, LLC, [e-mail]

STATE OF TENNESSEE
' FIB'W 1KCU RE jta
• MEN:
•If s•
NPDES PERMIT
No. TNOOO233O
Authorization to discharge under the
National Pollutant Discharge Elimination System (NPDES)
Issued By
STATE OF TENNESSEE
DEPARTMENT OF ENVIRONMENT AND CONSERVATION
DIVISION OF WATER RESOURCES
William R. Snodgrass - Tennessee Tower
312 Rosa L. Parks Avenue, 11th Floor
Nashville, Tennessee 37243-1102
Under authority of the Tennessee Water Quality Control Act of 1977 (T.C.A. 69-3-101 et sec.) and the delegation of
authority from the United States Environmental Protection Agency under the Federal Water Pollution Control Act, as
amended by the Clean Water Act of 1977 (33 U.S.C. 1251, et sec.)
Discharger:
Holliston Holdings, LLC
is authorized to discharge: process wastewater, water treatment wastewater, steam generation
wastewater, domestic wastewater, and storm water runoff from Outfall
001, emergency discharges only of non -contact cooling water from
Outfall 002, and storm water runoff from Outfalls SW2 and SW3
from a facility located at: 905 Holliston Mills Road, Church Hill, Hawkins County, Tennessee
to receiving waters named: Holston River at mile 129.5 (Outfall 001), Sevier Branch at mile 1.0
(Outfalls 002 and SW2) and Holston River at mile 129.5 (Outfall SW3)
in accordance with effluent limitations, monitoring requirements and other conditions set forth herein.
This permit shall become effective on: March 1, 2020
This permit shall expire on: January 31, 2024
Issuance date: February 1, 2020
fo06nnifer Dodd
Director
CN-0759 RDA 2366

TABLE OF CONTENTS
Paqe
Part I
A.
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS........................................................................1
B.
MONITORING PROCEDURES..........................................................................................................................4
1.
REPRESENTATIVE SAMPLING...................................................................................................................................4
2.
SAMPLING FREQUENCY..........................................................................................................................................4
3.
TEST PROCEDURES................................................................................................................................................5
4.
RECORDING OF RESULTS........................................................................................................................................5
5.
RECORDS RETENTION............................................................................................................................................6
C.
DEFINITIONS..................................................................................................................................................6
D.
ACRONYMS AND ABBREVIATIONS.................................................................................................................9
E.
REPORTING.................................................................................................................................................11
1.
MONITORING RESULTS........................................................................................................................................11
2.
ADDITIONAL MONITORING BY PERMITTEE...............................................................................................................11
3.
FALSIFYING RESULTS AND/OR REPORTS...................................................................................................................12
4.
OUTLIER DATA...................................................................................................................................................12
F.
SCHEDULE OF COMPLIANCE........................................................................................................................12
Part II
A. GENERAL PROVISIONS.................................................................................................................................13
1.
DUTY TO REAPPLY..............................................................................................................................................13
2.
RIGHT OF ENTRY................................................................................................................................................13
3.
AVAILABILITY OF REPORTS....................................................................................................................................13
4.
PROPER OPERATION AND MAINTENANCE................................................................................................................13
5.
TREATMENT FACILITY FAILURE..............................................................................................................................14
6.
PROPERTY RIGHTS..............................................................................................................................................14
7.
SEVERABILITY.....................................................................................................................................................14
8.
OTHER INFORMATION.........................................................................................................................................14
B.
CHANGES AFFECTING THE PERMIT..............................................................................................................14
1.
PLANNED CHANGES............................................................................................................................................14
2.
PERMIT MODIFICATION, REVOCATION, OR TERMINATION..........................................................................................15
3.
CHANGE OF OWNERSHIP.....................................................................................................................................15
4.
CHANGE OF MAILING ADDRESS.............................................................................................................................16
C.
NONCOMPLIANCE.......................................................................................................................................16
1.
EFFECT OF NONCOMPLIANCE................................................................................................................................16
2.
REPORTING OF NONCOMPLIANCE..........................................................................................................................16
3.
SANITARY SEWER OVERFLOW...............................................................................................................................17
4.
UPSET..............................................................................................................................................................18

5. ADVERSE IMPACT...............................................................................................................................................18
6. BYPASS.............................................................................................................................................................18
7. WASHOUT........................................................................................................................................................19
D. LIABILITIES...................................................................................................................................................19
1. CIVIL AND CRIMINAL LIABILITY..............................................................................................................................19
2. LIABILITY UNDERSTATE LAW................................................................................................................................20
Part III
A. TOXIC POLLUTANTS.....................................................................................................................................20
B. REOPENER CLAUSE......................................................................................................................................
21
C. PLACEMENT OF SIGNS.................................................................................................................................
21
D. ANTIDEGRADATION.....................................................................................................................................22
E. BIOMONITORING REQUIREMENTS, CHRONIC..............................................................................................22
F. CERTIFIED OPERATOR..................................................................................................................................
24
Part IV
A. PLAN IMPLEMENTATION.............................................................................................................................
24
B. PLAN AVAILABILITY.....................................................................................................................................
25
C. PLAN MODIFICATION..................................................................................................................................25
D. MONITORING PLAN.....................................................................................................................................25
JAH
TN0002330. DOC

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 1
-.-
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Holliston Holdings, LLC is authorized to discharge process wastewater, water treatment
wastewater, steam generation wastewater, domestic wastewater, and storm water runoff from
Outfall 001, emergency discharges only of non -contact cooling water from Outfall 002, and
storm water runoff from Outfalls SW2 and SW3 to Holston River at mile 129.5 (Outfall 001),
Sevier Branch at mile 1.0 (Outfalls 002 and SW2) and Holston River at mile 129.5 (Outfall
SW3).
These discharges shall be limited and monitored by the permittee as specified below:
Description : External Outfall, Number: 001,
Monitoring
: Effluent Gross, Season : All Year
Monitoring
Code
Parameter
Qualifier
Value
Unit
Sample Type
Frequency
Statistical Base
00310
BOD, 5-day, 20 C
<=
480
Ib/d
Composite
Three Per Week
Daily Maximum
00310
BOD, 5-day, 20 C
<=
240
Ib/d
Composite
Three Per Week
Monthly
Average
00340
Oxygen demand, chem.
<=
3768
Ib/d
Composite
Three Per Week
Daily Maximum
00340
Oxygen demand, chem.
<=
1884
Ib/d
Composite
Three Per Week
Monthly
(COD)
Average
00400
pH
>=
6.0
SU
Grab
Three Per Week
Minimum
00400
pH
<=
9.0
sU
Grab
Three Per Week
Maximum
00530
Total Suspended Solids (TSS)
<=
1152
Ib/d
Composite
Three Per Week
Daily Maximum
00530
Total Suspended Solids (TSS)
<=
574
Ib/d
Composite
Three Per Week
Monthly
Average
00556
Oil & Grease
Report
-
mg/L
Composite
Quarterly
Daily Maximum
00745
Sulfide, total (as S)
<=
12
Ib/d
Composite
Monthly
Daily Maximum
00745
Sulfide, total (as S)
<=
6
Ib/d
Composite
Monthly
Monthly
Average
01034
Chromium, total (as Cr)
<=
6
Ib/d
Composite
Monthly
Daily Maximum
01034
Chromium, total (as Cr)
<=
3
Ib/d
Composite
Monthly
Monthly
Average
01042
Copper, total (as Cu)
<=
1
mg/L
Composite
Twice Per
Month
Daily Maximum
01051
Lead, total (as Pb)
<=
.1
mg/L
Composite
Twice Per
Month
Daily Maximum
01067
Nickel, total (as Ni)
<=
3
mg/L
Composite
Twice Per
Month
Daily Maximum
01092
Zinc, total (as Zn)
<=
2
mg/L
Composite
Twice Per
Month
Daily Maximum
50050
Flow
Report
-
Mgal/d
Recorder
Three Per Week
Daily Maximum
50050
Flow
Report
-
Mgal/d
Recorder
Three Per Week
Monthly

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 2
Average
50060
Chlorine, total residual (TRC)
<=
2
mg/L
Grab
Three Per Week Daily Maximum
51040
E. coli
<=
941
MPN/100mL
Grab
Weekly
Daily Maximum
51040
E. coli
<=
126
MPN/100mL
Grab
Weekly
Geometric
Mean
71880
Formaldehyde
Report
-
Ib/d
Composite
Monthly
Daily Maximum
71880
Formaldehyde
Report
Ib/d
Composite
Monthly
Monthly
Average
77001
Acetaldehyde
Report
Ib/d
Composite
Monthly
Daily Maximum
77001
Acetaldehyde
Report
Ib/d
Composite
Monthly
Monthly
Average
77057
Vinyl acetate
Report
Ib/d
Composite
Monthly
Daily Maximum
77057
Vinyl acetate
Report
Ib/d
Composite
Monthly
Monthly
Average
Description : External Outfall, Number: 001, Monitoring
: Effluent Gross,
Season : All Year
Monitoring
Code
Parameter Qualifier
Value
Unit
Sample Type Frequency
Statistical Base
46000
Phenols <=
3
Ib/d
Grab
Annual
Monthly Average
46000
Phenols <=
6
Ib/d
Grab
Annual
Daily Maximum
1. Flow shall be reported in Million Gallons per Day (MGD).
2. The current detection level for Total Residual Chlorine is 0.05 mg/L. The acceptable
methods for detection are specified in 40 CFR Part 136.
3. pH and TRC analyses shall be performed within fifteen (15) minutes of sample collection.
Description : External Outfall, Number: 002, Monitoring : Effluent Gross, Season : All Year
Monitoring Statistical
Code
Parameter
Qualifier
Value
Unit
Sample Type
Frequency
Base
00010
Temperature, water deg. C
Report
-
deg C
Grab
Once Per
Discharge
Daily
Maximum
00400
pH
>=
6.0
su
Grab
Once Per
Minimum
Discharge
00400
pH
<=
9.0
su
Grab
Once Per
Discharge
Maximum
01042
Copper, total (as Cu)
<=
.047
mg/L
Grab
Once Per
Monthly
Discharge
Average
01042
Copper, total (as Cu)
<_
.072
mg/L
Grab
Once Per
Discharge
Daily
Maximum
01067
Nickel, total (as Ni)
<_
.291
mg/L
Grab
Once Per
Monthly
Discharge
Average
01067
Nickel, total (as Ni)
<=
2.612
mg/L
Grab
Once Per
Daily
Discharge
Maximum
01092
Zinc, total (as Zn)
<=
1.078
mg/L
Grab
Once Per
Daily
Discharge
Maximum
01092
Zinc, total (as Zn)
<=
1.087
mg/L
Grab
Once Per
Monthly
Discharge
Average
50050
Flow
Report
-
Mgal/d
Instantaneous
Once Per
Daily
Discharge
Maximum

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 3
50050
Flow
Report
-
Mgal/d
Instantaneous
Once Per
Monthly
Discharge
Average
TRP313
IC25 Static Renewal 7 Day
>=
100
%
Composite
Semiannual
Minimum
Chronic Ceriodaphnia
TRP6C
IC25 Static Renewal 7 Day
>=
100
%
Composite
Semiannual
Minimum
Chronic Pimephales promelas
Description : External Outfall, Number:
002, Monitoring
:
Effluent Gross, Season : Summer
Monitoring
Statistical
Code
Parameter
Qualifier
Value
Unit
Sample Type
Frequency
Base
00610
Nitrogen, Ammonia total (as N)
<=
1.4
mg/L
Grab
Once Per
Monthly
Discharge
Average
00610
Nitrogen, Ammonia total (as N)
<=
2.8
mg/L
Grab
Once Per
Discharge
Daily
Maximum
Description : External Outfall, Number:
002, Monitoring
: Effluent Gross,
Season : Winter
Monitoring
Statistical
Code
Parameter
Qualifier
Value
Unit
Sample Type
Frequency
Base
00610
Nitrogen, Ammonia total (as N)
<=
5.2
mg/L
Grab
Once Per
Discharge
Daily
Maximum
00610
Nitrogen, Ammonia total (as N)
<=
2.6
mg/L
Grab
Once Per
Monthly
Discharge
Average
NOTE: THIS OUTFALL IS ONLY IN SERVICE IN THE EVENT OF A FAILURE OF THE
RECYCLED COOLING WATER SYSTEM. For that reason report "NO DISCHARGE" for
months of no discharge.
1. Flow shall be reported in Million Gallons per Day (MGD).
2. pH analyses shall be performed within fifteen (15) minutes of sample collection.
3. Once Per Month or once per discharge, whichever is less frequent
4. See Part III for methodology.
Description : External Outfall, Number: SW2 and SW3, Monitoring : Effluent Gross, Season : All Year, Limit Set Status
Active
Monitoring
Code
Parameter
Qualifier Value
Unit
Sample Type
Frequency
Statistical Base
00400
pH
Report
SU
Grab
Semiannual
Maximum
00400
pH
Report
SU
Grab
Semiannual
Minimum
00530
Total Suspended Solids (TSS)
Report
mg/L
Grab
Semiannual
Daily Maximum
00556
Oil & Grease
Report
mg/L
Grab
Semiannual
Daily Maximum
50050
Flow
Report
Mgal/d
Estimate
Semiannual
Daily Maximum
50050
Flow
Report
Mgal/d
Estimate
Semiannual
Monthly Average
1. Flow shall be reported in Million Gallons per Day (MGD).
2. pH analyses shall be performed within fifteen (15) minutes of sample collection. The
permittee shall provide the date and duration (in hours) of the qualifying storm event(s)
sampled; rainfall measurements or estimates (in inches) of the storm event that generated
the sampled runoff; the duration between the storm event sampled and the end of the
previous measurable (greater than 0.1 inch rainfall) storm event; and an estimate of the total
volume of the discharge sampled. Flow shall be reported in Million Gallons per Day (MGD).
Provide information as an attachment to the discharge monitoring report.

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 4
Unless elsewhere specified, summer months are May through October; winter months
are November through April. Additional monitoring requirements and conditions applicable to all
outfalls include:
A water supply intake (First Utility District of Hawkins County) that is located
approximately one mile upstream of the facility is operational. The utility shall be notified
of any spills at the facility that have the potential to reach the Holston River.
There shall be no distinctly visible floating solids, scum, foam, oily slick, or the formation
of slimes, bottom deposits or sludge banks of such size or character that may be detrimental to
fish and aquatic life. The wastewater color shall not cause a visible contrast to the natural color
of the receiving stream.
The wastewater discharge shall not contain pollutants in quantities that will be
hazardous or otherwise detrimental to humans, livestock, wildlife, plant life, or fish and aquatic
life in the receiving stream.
Sludge or any other material removed by any treatment works must be disposed of in a
manner, which prevents its entrance into or pollution of any surface or subsurface waters.
Additionally, the disposal of such sludge or other material must be in compliance with the
Tennessee Solid Waste Disposal Act, TCA 68-31-101 et sec. and the Tennessee Hazardous
Waste Management Act, TCA 68-46-101 et sec..
Nothing in this permit authorizes take for the purposes of a facility's compliance with the
Endangered Species Act." (40 C.F.R. 125.98(b)(1))
B. MONITORING PROCEDURES
1. Representative Sampling
Samples and measurements taken in compliance with the monitoring requirements
specified herein shall be representative of the volume and nature of the monitored discharge,
and shall be taken after treatment and prior to mixing with uncontaminated storm water runoff or
the receiving stream. Appropriate flow measurement devices and methods consistent with
accepted scientific practices shall be selected and used to insure the accuracy and reliability of
measurements of the volume of monitored discharges. The devices shall be installed, calibrated
and maintained to insure that the accuracy of the measurements is consistent with accepted
capability of that type of device. Devices selected shall be capable of measuring flows with a
maximum deviation of less than plus or minus 10% from the true discharge rates throughout the
range of expected discharge volumes.
2. Sampling Frequency
If there is a discharge from a permitted outfall on any given day during the monitoring period,
the permittee must sample and report the results of analyses accordingly, and the permittee
should not mark the 'No Discharge' box on the Discharge Monitoring Report form.

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 5
3. Test Procedures
a. Test procedures for the analysis of pollutants shall conform to regulations
published pursuant to Section 304 (h) of the Clean Water Act (the "Act"), as
amended, under which such procedures may be required.
b. Unless otherwise noted in the permit, all pollutant parameters shall be
determined according to methods prescribed in Title 40, CFR Part 136, as
amended, promulgated pursuant to Section 304 (h) of the Act.
C. In instances where permit limits established through implementation of applicable
water criteria are below analytical capabilities, compliance with those limits will
be determined using the detection limits described in the TN Rules, Chapter
0400-40-03-.05(8).
d. The wastewater discharge must be disinfected to the extent that viable coliform
organisms are effectively eliminated. The concentration of the E. coli group after
disinfection shall not exceed 126 cfu per 100 ml as the geometric mean
calculated on the actual number of samples collected and tested for E. coli within
the required reporting period. The permittee may collect more samples than
specified as the monitoring frequency. Samples may not be collected at intervals
of less than 12 hours. For the purpose of determining the geometric mean,
individual samples having an E. coli group concentration of less than one (1) per
100 ml shall be considered as having a concentration of one (1) per 100 ml. In
addition, the concentration of the E. coli group in any individual sample shall not
exceed a specified maximum amount. A maximum daily limit of 487 colonies per
100 ml applies to lakes and exceptional Tennessee waters. A maximum daily
limit of 941 colonies per 100 ml applies to all other recreational waters.
e. All testing for mercury including permit renewal applications shall be
conducted with Method 245.7 (MDL 5.0 ppt), Method 1631E (MDL 0.5 ppt),
or any methods that are approved by EPA with a more sensitive detection
limit.
4. Recording of Results
For each measurement or sample taken pursuant to the requirements of this permit, the
permittee shall record the following information:
a. The exact place, date and time of sampling or measurements;
b. The exact person(s) collecting samples or measurements;
C. The dates and times the analyses were performed;
d. The person(s) or laboratory who performed the analyses;
e. The analytical techniques or methods used, and;

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 6
f. The results of all required analyses.
5. Records Retention
All records and information resulting from the monitoring activities required by this permit
including all records of analyses performed and calibration and maintenance of instrumentation
shall be retained for a minimum of three (3) years, or longer, if requested by the Division of
Water Resources.
C. DEFINITIONS
For the purpose of this permit, Annually is defined as a monitoring frequency of once
every twelve (12) months beginning with the date of issuance of this permit so long as the
following set of measurements for a given 12 month period are made approximately 12 months
subsequent to that time.
A bypass is defined as the intentional diversion of waste streams from any portion of a
treatment facility.
A calendar day is defined as the 24-hour period from midnight to midnight or any other
24-hour period that reasonably approximates the midnight to midnight time period.
For the purposes of this permit, a Composite Sample for non -storm water discharges is
a sample collected continuously over a period of 24-hours at a rate proportional to the flow.
Cooling water means water used for contact or non -contact cooling, including water
used for equipment cooling, evaporative cooling tower makeup, and dilution of effluent heat
content. The intended use of the cooling water is to absorb waste heat rejected from the
process or processes used, or from auxiliary operations on the facility's premises.
Cooling water intake structure means the total physical structure and any associated
constructed waterways used to withdraw cooling water from waters of the United States. The
cooling water intake structure extends from the point at which water is first withdrawn from
waters of the United States up to, and including the intake pumps.
Actual Intake Flow (AIF) means the average volume of water withdrawn on an annual
basis by the cooling water intake structures over the past three years.
Design intake flow (DIF) means the value assigned during the cooling water intake
structure design to the maximum instantaneous rate of flow of water the cooling water intake
system is capable of withdrawing from a source waterbody.
Entrainment- means the incorporation of all life stages of fish and shellfish with intake
water flow entering and passing through a cooling water intake structure and into a cooling
water system.

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 7
Impingement- means the entrapment of all life stages of fish and shellfish on the outer
part of an intake structure or against a screening device during periods of intake water
withdrawal.
The Daily Maximum Amount, is a limitation measured in pounds per day (lb/day), on
the total amount of any pollutant in the discharge by weight during any calendar day.
The Daily Maximum Concentration is a limitation on the average concentration, in
milligrams per liter (mg/L), of the discharge during any calendar day. When a proportional -to -
flow composite sampling device is used, the daily concentration is the concentration of that 24-
hour composite; when other sampling means are used, the daily concentration is the arithmetic
mean of the concentrations of equal volume samples collected during any calendar day or
sampling period.
"Degradation" means the alteration of the properties of waters by the addition of
pollutants, withdrawal of water, or removal of habitat, except those alterations of a short
duration.
"De Minimis" - Degradation of a small magnitude, as provided in this paragraph.
(a) Discharges and withdrawals
1. Subject to the limitation in part 3 of this subparagraph, a single discharge other
than those from new domestic wastewater sources will be considered de minimis if it uses less
than five percent of the available assimilative capacity for the substance being discharged.
2. Subject to the limitation in part 3 of this subparagraph, a single water withdrawal
will be considered de minimis if it removes less than five percent of the 7Q10 flow of the stream.
3. If more than one activity described in part 1 or 2 of this subparagraph has been
authorized in a segment and the total of the authorized and proposed impacts uses no more
than 10% of the assimilative capacity, or 7Q10 low flow, they are presumed to be de minimis.
Where the total of the authorized and proposed impacts uses 10% of the assimilative capacity,
or 7Q10 low flow, additional degradation may only be treated as de minimis if the Division finds
on a scientific basis that the additional degradation has an insignificant effect on the resource.
(b) Habitat alterations authorized by an Aquatic Resource Alteration Permit (ARAP) are
de minimis if the Division finds that the impacts, individually and cumulatively are offset by
impact minimization and/or in -system mitigation, provided however, in ONRWs the mitigation
must occur within the ONRW.
Discharge or "discharge of a pollutant" refers to the addition of pollutants to waters from
a source.
Dry Weather Flow shall be construed to represent discharges consisting of process
and/or non -process wastewater only.
An ecoregion is a relatively homogeneous area defined by similarity of climate,
landform, soil, potential natural vegetation, hydrology, or other ecologically relevant variables.

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 8
The geometric mean of any set of values is the n`" root of the product of the individual
values where "n" is equal to the number of individual values. The geometric mean is equivalent
to the antilog of the arithmetic mean of the logarithms of the individual values. For the purposes
of calculating the geometric mean, values of zero (0) shall be considered to be one (1).
A Grab Sample, for the purposes of this permit, is defined as a single effluent sample of
at least 100 milliliters (sample volumes <100 milliliters are allowed when specified per standard
methods, latest edition) collected at a randomly selected time over a period not exceeding 15
minutes. The sample(s) shall be collected at the period(s) most representative of the total
discharge.
The Instantaneous Concentration is a limitation on the concentration, in milligrams per
liter (mg/L), of any pollutant contained in the discharge determined from a grab sample taken at
any point in time.
The monthly average amount, shall be determined by the summation of all the
measured daily discharges by weight divided by the number of days during the calendar month
when the measurements were made.
The monthly average concentration, other than for E. coli bacteria, is the arithmetic
mean of all the composite or grab samples collected in a one -calendar month period.
A one week period (or calendar -week) is defined as the period from Sunday through
Saturday. For reporting purposes, a calendar week that contains a change of month shall be
considered part of the latter month.
Pollutant means sewage, industrial wastes, or other wastes.
A Qualifying Storm Event is one which is greater than 0.1 inches and that occurs after
a period of at least 72 hours after any previous storm event with rainfall of 0.1 inches or greater.
For the purpose of this permit, a Quarter is defined as any one of the following three
month periods: January 1 through March 31, April 1 through June 30, July 1 through
September 30, or October 1 through December 31.
A rainfall event is defined as any occurrence of rain, preceded by 10 hours without
precipitation that results in an accumulation of 0.01 inches or more. Instances of rainfall
occurring within 10 hours of each other will be considered a single rainfall event.
A rationale (or "fact sheet") is a document that is prepared when drafting an NPDES
permit or permit action. It provides the technical, regulatory and administrative basis for an
agency's permit decision.
A reference site means least impacted waters within an ecoregion that have been
monitored to establish a baseline to which alterations of other waters can be compared.

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 9
A reference condition is a parameter -specific set of data from regional reference sites
that establish the statistical range of values for that particular substance at least -impacted
streams.
For the purpose of this permit, Semi-annually means the same as 'once every six
months." Measurements of the effluent characteristics concentrations may be made anytime
during a 6 month period beginning from the issuance date of this permit so long as the second
set of measurements for a given 12 month period are made approximately 6 months
subsequent to that time, if feasible.
A subecoregion is a smaller, more homogenous area that has been delineated within
an ecoregion.
Upset means an exceptional incident in which there is unintentional and temporary
noncompliance with technology -based effluent limitations because of factors beyond the
reasonable control of the permittee. An upset does not include noncompliance to the extent
caused by operational error, improperly designed treatment facilities, inadequate treatment
facilities, lack of preventive maintenance, or careless or improper operation.
The term, washout is applicable to activated sludge plants and is defined as loss of
mixed liquor suspended solids (MLSS) of 30.00% or more from the aeration basin(s).
Waters means any and all water, public or private, on or beneath the surface of the
ground, which are contained within, flow through, or border upon Tennessee or any portion
thereof except those bodies of water confined to and retained within the limits of private property
in single ownership which do not combine or effect a junction with natural surface or
underground waters.
The weekly average amount, shall be determined by the summation of all the
measured daily discharges by weight divided by the number of days during the calendar week
when the measurements were made.
The weekly average concentration, is the arithmetic mean of all the composite
samples collected in a one -week period. The permittee must report the highest weekly average
in the one -month period.
Wet Weather Flow shall be construed to
combination with all process and/or non -process
discharged during a qualifying storm event.
D. ACRONYMS AND ABBREVIATIONS
represent storm water runoff which, in
wastewater discharges, as applicable, is
1Q10 — 1-day minimum, 10-year recurrence interval
30Q5 — 30-day minimum, 5-year recurrence interval
7Q10 — 7-day minimum, 10-year recurrence interval
BAT — best available technology economically achievable
BCT — best conventional pollutant control technology

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 10
BDL — below detection level
BOD5 — five day biochemical oxygen demand
BPT — best practicable control technology currently available
CBOD5 — five day carbonaceous biochemical oxygen demand
CEI — compliance evaluation inspection
CFR — code of federal regulations
CFS — cubic feet per second
CFU — colony forming units
CIU — categorical industrial user
CSO — combined sewer overflow
DMR — discharge monitoring report
D.O. — dissolved oxygen
E. coli — Escherichia coli
EFO — environmental field office
LB(lb) - pound
IC25 — inhibition concentration causing 25% reduction in survival, reproduction and
growth of the test organisms
IU — industrial user
IWS — industrial waste survey
LC50 — acute test causing 50% lethality
MDL — method detection level
MGD — million gallons per day
MG/L(mg/1) — milligrams per liter
MIL — minimum level of quantification
ml — milliliter
MLSS — mixed liquor suspended solids
MOR — monthly operating report
NODI — no discharge
NPDES — national pollutant discharge elimination system
PL — permit limit
POTW — publicly owned treatment works
RDL — required detection limit
SAR — semi-annual [pretreatment program] report
SIU — significant industrial user
SSO — sanitary sewer overflow
STP — sewage treatment plant
TCA — Tennessee code annotated
TDEC — Tennessee Department of Environment and Conservation
TIE/TRE — toxicity identification evaluation/toxicity reduction evaluation
TMDL — total maximum daily load
TRC — total residual chlorine
TSS — total suspended solids
WQBEL — water quality based effluent limit

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 11
E. REPORTING
Monitoring Results
Monitoring results shall be recorded monthly and submitted monthly using NETDMR.
Submittals shall be no later than 15 days after the completion of the reporting period. If
NETDMR is not functioning, a completed DMR with an original signature shall be submitted to
the following address:
STATE OF TENNESSEE
DEPARTMENT OF ENVIRONMENT AND CONSERVATION
DIVISION OF WATER RESOURCES
COMPLIANCE & ENFORCEMENT SECTION
William R. Snodgrass - Tennessee Tower
312 Rosa L. Parks Avenue, 11th Floor
Nashville, Tennessee 37243-1102
If NETDMR is not functioning, a copy of the completed and signed DMR shall be mailed
to the Johnson City Environmental Field Office (EFO) at the following address:
STATE OF TENNESSEE
DEPARTMENT OF ENVIRONMENT AND CONSERVATION
DIVISION OF WATER RESOURCES
Johnson City Environmental Field Office
2305 Silverdale Road
Johnson City, Tennessee 37601
A copy should be retained for the permittee's files. In addition, any communication
regarding compliance with the conditions of this permit must be sent to the two offices listed
above.
The first DMR is due on the 15th of the month following permit effectiveness.
DMRs and any other information or report must be signed and certified by a responsible
corporate officer as defined in 40 CFR 122.22, a general partner or proprietor, or a principal
municipal executive officer or ranking elected official, or his duly authorized representative.
Such authorization must be submitted in writing and must explain the duties and responsibilities
of the authorized representative.
The electronic submission of DMR data will be accepted only if formally approved
beforehand by the division. For purposes of determining compliance with this permit, data
approved by the division to be submitted electronically is legally equivalent to data submitted on
signed and certified DMR forms.
2. Additional Monitoring by Permittee
If the permittee monitors any pollutant more frequently than required at the location(s)
designated, using approved analytical methods as specified herein, the results of such

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 12
monitoring shall be included in the calculation and reporting of the values required in the DMR
form. Such increased frequency shall also be indicated on the form.
3. Falsifying Results and/or Reports
Knowingly making any false statement on any report required by this permit or falsifying
any result may result in the imposition of criminal penalties as provided for in Section 309 of the
Federal Water Pollution Control Act, as amended, and in Section 69-3-115 of the Tennessee
Water Quality Control Act.
4. Outlier Data
Outlier data include analytical results that are probably false. The validity of results is
based on operational knowledge and a properly implemented quality assurance program. False
results may include laboratory artifacts, potential sample tampering, broken or suspect sample
containers, sample contamination or similar demonstrated quality control flaw.
Outlier data are identified through a properly implemented quality assurance program,
and according to ASTM standards (e.g. Grubbs Test, `h' and `k' statistics). Furthermore, outliers
should be verified, corrected, or removed, based on further inquiries into the matter. If an outlier
was verified (through repeated testing and/or analysis), it should remain in the preliminary data
set. If an outlier resulted from a transcription or similar clerical error, it should be corrected and
subsequently reported.
Therefore, only if an outlier was associated with problems in the collection or analysis of
the samples and as such does not conform with the Guidelines Establishing Test Procedures for
the Analysis of Pollutants (40 CFR §136), it can be removed from the data set and not reported
on the Discharge Monitoring Report forms (DMRs). Otherwise, all results (including monitoring
of pollutants more frequently than required at the location(s) designated, using approved
analytical methods as specified in the permit) should be included in the calculation and reporting
of the values required in the DMR form. You are encouraged to use "comment' section of the
DMR form (or attach additional pages), in order to explain any potential outliers or dubious
results.
F. SCHEDULE OF COMPLIANCE
Full compliance and operational levels shall be attained from the effective date of this
permit.

PART II
A. GENERAL PROVISIONS
1. Duty to Reapply
Holliston Holdings, LLC
NPDES Permit TN0002330
Page 13
Permittee is not authorized to discharge after the expiration date of this permit. In order
to receive authorization to discharge beyond the expiration date, the permittee shall submit such
information and forms as are required to the Director of the Division of Water Resources (the
"Director") no later than 180 days prior to the expiration date. Such applications must be
properly signed and certified.
2. Right of Entry
The permittee shall allow the Director, the Regional Administrator of the U.S.
Environmental Protection Agency, or their authorized representatives, upon the presentation of
credentials:
a. To enter upon the permittee's premises where an effluent source is located or
where records are required to be kept under the terms and conditions of this
permit, and at reasonable times to copy these records;
b. Inspect at reasonable times any facilities, equipment (including monitoring and
control equipment), practices, or operations regulated or required under this
permit; and
C. Sample or monitor at reasonable times, for the purposes of assuring permit
compliance or as otherwise authorized by the Director.
3. Availability of Reports
Except for data determined to be confidential under Section 308 of the Federal Water
Pollution Control Act, as amended, all reports prepared in accordance with the terms of this
permit shall be available for public inspection at the offices of the Division of Water Resources.
As required by the Federal Act, effluent data shall not be considered confidential.
4. Proper Operation and Maintenance
a. The permittee shall at all times properly operate and maintain all facilities and
systems (and related appurtenances) for collection and treatment which are
installed or used by the permittee to achieve compliance with the terms and
conditions of this permit. Proper operation and maintenance also includes
adequate laboratory and process controls and appropriate quality assurance
procedures. This provision requires the operation of backup or auxiliary facilities
or similar systems, which are installed by a permittee only when the operation is

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 14
necessary to achieve compliance with the conditions of the permit. Backup
continuous pH and flow monitoring equipment are not required.
b. Dilution water shall not be added to comply with effluent requirements to achieve
BCT, BPT, BAT and/or other technology -based effluent limitations such as those
in State of Tennessee Rule 0400-40-05-.09.
5. Treatment Facility Failure
The permittee, in order to maintain compliance with this permit, shall control production,
all discharges, or both, upon reduction, loss, or failure of the treatment facility, until the facility is
restored or an alternative method of treatment is provided. This requirement applies in such
situations as the reduction, loss, or failure of the primary source of power.
6. Property Rights
The issuance of this permit does not convey any property rights in either real or personal
property, or any exclusive privileges, nor does it authorize any injury to private property or any
invasion of personal rights, nor any infringement of Federal, State, or local laws or regulations.
7. Severability
The provisions of this permit are severable. If any provision of this permit due to any
circumstance, is held invalid, then the application of such provision to other circumstances and
to the remainder of this permit shall not be affected thereby.
8. Other Information
If the permittee becomes aware that he failed to submit any relevant facts in a permit
application, or submitted incorrect information in a permit application or in any report to the
Director, then he shall promptly submit such facts or information.
B. CHANGES AFFECTING THE PERMIT
Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned
physical alterations or additions to the permitted facility. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for
determining whether a facility is a new source in 40 CFR 122.29(b); or
b. The alteration or addition could significantly change the nature or increase the
quantity of pollutants discharged. This notification applies to pollutants which are
subject neither to effluent limitations in the permit, nor to notification requirements
under 40 CFR 122.42(a)(1).

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 15
C. The alteration or addition results in a significant change in the permittee's sludge
use or disposal practices.
2. Permit Modification, Revocation, or Termination
a. This permit may be modified, revoked and reissued, or terminated for cause as
described in 40 CFR 122.62 and 122.64, Federal Register, Volume 49, No. 188
(Wednesday, September 26, 1984), as amended.
b. The permittee shall furnish to the Director, within a reasonable time, any
information which the Director may request to determine whether cause exists for
modifying, revoking and reissuing, or terminating this permit, or to determine
compliance with this permit. The permittee shall also furnish to the Director, upon
request, copies of records required to be kept by this permit.
C. If any applicable effluent standard or prohibition (including any schedule of
compliance specified in such effluent standard or prohibition) is established for
any toxic pollutant under Section 307(a) of the Federal Water Pollution Control
Act, as amended, the Director shall modify or revoke and reissue the permit to
conform to the prohibition or to the effluent standard, providing that the effluent
standard is more stringent than the limitation in the permit on the toxic pollutant.
The permittee shall comply with these effluent standards or prohibitions within
the time provided in the regulations that establish these standards or prohibitions,
even if the permit has not yet been modified or revoked and reissued to
incorporate the requirement.
d. The filing of a request by the permittee for a modification, revocation, reissuance,
termination, or notification of planned changes or anticipated noncompliance
does not halt any permit condition.
3. Change of Ownership
This permit may be transferred to another party (provided there are neither modifications
to the facility or its operations, nor any other changes which might affect the permit limits and
conditions contained in the permit) by the permittee if:
a. The permittee notifies the Director of the proposed transfer at least 30 days in
advance of the proposed transfer date;
b. The notice includes a written agreement between the existing and new
permittees containing a specified date for transfer of permit responsibility,
coverage, and liability between them; and
C. The Director, within 30 days, does not notify the current permittee and the new
permittee of his intent to modify, revoke or reissue, or terminate the permit and to
require that a new application be filed rather than agreeing to the transfer of the
permit.

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 16
Pursuant to the requirements of 40 CFR 122.61, concerning transfer of ownership, the
permittee must provide the following information to the division in their formal notice of intent to
transfer ownership: 1) the NPDES permit number of the subject permit; 2) the effective date of
the proposed transfer; 3) the name and address of the transferor; 4) the name and address of
the transferee; 5) the names of the responsible parties for both the transferor and transferee; 6)
a statement that the transferee assumes responsibility for the subject NPDES permit; 7) a
statement that the transferor relinquishes responsibility for the subject NPDES permit; 8) the
signatures of the responsible parties for both the transferor and transferee pursuant to the
requirements of 40 CFR 122.22(a), "Signatories to permit applications"; and, 9) a statement
regarding any proposed modifications to the facility, its operations, or any other changes which
might affect the permit limits and conditions contained in the permit.
4. Change of Mailing Address
The permittee shall promptly provide to the Director written notice of any change of
mailing address. In the absence of such notice the original address of the permittee will be
assumed to be correct.
C. NONCOMPLIANCE
1. Effect of Noncompliance
The permittee shall comply with all conditions of this permit. Any permit noncompliance
constitutes a violation of applicable State and Federal laws and is grounds for enforcement
action, permit termination, permit modification, or denial of permit reissuance.
2. Reporting of Noncompliance
a. 24-Hour Reporting
In the case of any noncompliance which could cause a threat to public drinking
supplies, or any other discharge which could constitute a threat to human health or the
environment, the required notice of non-compliance shall be provided to the Division of
Water Resources in the appropriate regional Field Office within 24-hours from the time
the permittee becomes aware of the circumstances. (The regional Field Office should be
contacted for names and phone numbers of environmental response personnel).
A written submission must be provided within five calendar days of the time the
permittee becomes aware of the circumstances, unless this requirement is waived by the
Director on a case -by -case basis. The permittee shall provide the Director with the
following information:
A description of the discharge and cause of noncompliance;
The period of noncompliance, including exact dates and times or, if not
corrected, the anticipated time the noncompliance is expected to
continue; and

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 17
iii. The steps being taken to reduce, eliminate, and prevent recurrence of the
noncomplying discharge.
b. Scheduled Reporting
For instances of noncompliance which do not cause a threat to public drinking
supplies, or any other discharge which could constitute a threat to human health or the
environment, the permittee shall report the noncompliance on the Discharge Monitoring
Report. The report shall contain all information concerning the steps taken, or planned,
to reduce, eliminate, and prevent recurrence of the violation and the anticipated time the
violation is expected to continue.
3. Sanitary Sewer Overflow
a. "Sanitary Sewer Overflow" means the discharge to land or water of wastes from
any portion of the collection, transmission, or treatment system other than
through permitted outfalls.
b. Sanitary Sewer Overflows are prohibited.
C. The permittee shall operate the collection system so as to avoid sanitary sewer
overflows. No new or additional flows shall be added upstream of any point in the
collection system, which experiences chronic sanitary sewer overflows (greater
than 5 overflows per year) or would otherwise overload any portion of the
system.
d. Unless there is specific enforcement action to the contrary, the permittee is
relieved of this requirement after: 1) an authorized representative of the
Commissioner of the Department of Environment and Conservation has
approved an engineering report and construction plans and specifications
prepared in accordance with accepted engineering practices for correction of the
problem; 2) the correction work is underway; and 3) the cumulative, peak -design,
flows potentially added from new connections and line extensions upstream of
any chronic overflow point are less than or proportional to the amount of inflow
and infiltration removal documented upstream of that point. The inflow and
infiltration reduction must be measured by the permittee using practices that are
customary in the environmental engineering field and reported in an attachment
to a Monthly Operating Report submitted to the regional TDEC Field Office. The
data measurement period shall be sufficient to account for seasonal rainfall
patterns and seasonal groundwater table elevations.
e. In the event that more than five (5) sanitary sewer overflows have occurred from
a single point in the collection system for reasons that may not warrant the self-
imposed moratorium or completion of the actions identified in this paragraph, the
permittee may request a meeting with the Division of Water Resources field
office staff to petition for a waiver based on mitigating evidence.

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 18
4. Upset
a. "Upset' means an exceptional incident in which there is unintentional and
temporary noncompliance with technology -based effluent limitations because of
factors beyond the reasonable control of the permittee. An upset does not
include noncompliance to the extent caused by operational error, improperly
designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper operation.
b. An upset shall constitute an affirmative defense to an action brought for
noncompliance with such technology -based permit effluent limitations if the
permittee demonstrates, through properly signed, contemporaneous operating
logs, or other relevant evidence that:
An upset occurred and that the permittee can identify the cause(s) of the
upset;
The permitted facility was at the time being operated in a prudent and
workman -like manner and in compliance with proper operation and
maintenance procedures;
iii. The permittee submitted information required under "Reporting of
Noncompliance" within 24-hours of becoming aware of the upset (if this
information is provided orally, a written submission must be provided
within five days); and
iv. The permittee complied with any remedial measures required under
"Adverse Impact."
5. Adverse Impact
The permittee shall take all reasonable steps to minimize any adverse impact to the
waters of Tennessee resulting from noncompliance with this permit, including such accelerated
or additional monitoring as necessary to determine the nature and impact of the noncomplying
discharge. It shall not be a defense for the permittee in an enforcement action that it would have
been necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit.
6. Bypass
a. "Bypass" is the intentional diversion of wastewater away from any portion of a
treatment facility. "Severe property damage" means substantial physical damage
to property, damage to the treatment facilities, which would cause them to
become inoperable, or substantial and permanent loss of natural resources
which can reasonably be expected to occur in the absence of a bypass. Severe
property damage does not mean economic loss caused by delays in production.
b. Bypasses are prohibited unless the following 3 conditions are met:

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 19
The bypass is unavoidable to prevent loss of life, personal injury, or
severe property damage;
There are not feasible alternatives to bypass, such as the use of auxiliary
treatment facilities, retention of untreated wastes, or maintenance during
normal periods of equipment down -time. This condition is not satisfied if
adequate back-up equipment should have been installed in the exercise
of reasonable engineering judgment to prevent a bypass, which occurred
during normal periods of equipment down -time or preventative
maintenance;
iii. The permittee submits notice of an unanticipated bypass to the Division of
Water Resources in the appropriate environmental assistance center
within 24-hours of becoming aware of the bypass (if this information is
provided orally, a written submission must be provided within five days).
When the need for the bypass is foreseeable, prior notification shall be
submitted to the Director, if possible, at least 10 days before the date of
the bypass.
C. Bypasses not exceeding limitations are allowed only if the bypass is necessary
for essential maintenance to assure efficient operation. All other bypasses are
prohibited. Allowable bypasses not exceeding limitations are not subject to the
reporting requirements of 6.b.iii, above.
7. Washout
a. For domestic wastewater plants only, a "washout" shall be defined as loss of
Mixed Liquor Suspended Solids (MLSS) of 30.00% or more. This refers to the
MLSS in the aeration basin(s) only. This does not include MLSS decrease due to
solids wasting to the sludge disposal system. A washout can be caused by
improper operation or from peak flows due to infiltration and inflow.
b. A washout is prohibited. If a washout occurs the permittee must report the
incident to the Division of Water Resources in the appropriate regional Field
Office within 24-hours by telephone. A written submission must be provided
within 5 days. The washout must be noted on the discharge monitoring report.
Each day of a washout is a separate violation.
D. LIABILITIES
1. Civil and Criminal Liability
Except as provided in permit conditions for "Bypass," "Overflow," and "Upset," nothing
in this permit shall be construed to relieve the permittee from civil or criminal penalties for
noncompliance. Notwithstanding this permit, the permittee shall remain liable for any damages
sustained by the State of Tennessee, including but not limited to fish kills and losses of aquatic
life and/or wildlife, as a result of the discharge of wastewater to any surface or subsurface

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 20
waters. Additionally, notwithstanding this Permit, it shall be the responsibility of the permittee to
conduct its wastewater treatment and/or discharge activities in a manner such that public or
private nuisances or health hazards will not be created.
2. Liability Under State Law
Nothing in this permit shall be construed to preclude the institution of any legal action or
relieve the permittee from any responsibilities, liabilities, or penalties established pursuant to
any applicable State law or the Federal Water Pollution Control Act, as amended.
2_3 A 9111
OTHER REQUIREMENTS
A. TOXIC POLLUTANTS
The permittee shall notify the Division of Water Resources as soon as it knows or has
reason to believe:
That any activity has occurred or will occur which would result in the discharge
on a routine or frequent basis, of any toxic substance(s) (listed at 40 CFR 122,
Appendix D, Table II and III) which is not limited in the permit, if that discharge
will exceed the highest of the following "notification levels":
a. One hundred micrograms per liter (100 ug/1);
Two hundred micrograms per liter (200 ug/1) for acrolein and acrylonitrile;
five hundred micrograms per liter (500 ug/1) for 2,4-dinitrophenol and for
2-methyl-4,6-dinitrophenol; and one milligram per liter (1 mg/L) for
antimony;
C. Five (5) times the maximum concentration value reported for that
pollutant(s) in the permit application in accordance with 122.21(g)(7); or
d. The level established by the Director in accordance with 122.44(f).
2. That any activity has occurred or will occur which would result in any discharge,
on a non -routine or infrequent basis, of a toxic pollutant which is not limited in the
permit, if that discharge will exceed the highest of the following "notification
levels":
a. Five hundred micrograms per liter (500 ug/1);
b. One milligram per liter (1 mg/L) for antimony;

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 21
C. Ten (10) times the maximum concentration value reported for that
pollutant in the permit application in accordance with 122.21(g)(7); or
d. The level established by the Director in accordance with 122.44(f).
B. REOPENER CLAUSE
If an applicable standard or limitation is promulgated under Sections 301(b)(2)(C) and
(D), 304(B)(2), and 307(a)(2) and that effluent standard or limitation is more stringent than any
effluent limitation in the permit or controls a pollutant not limited in the permit, the permit shall be
promptly modified or revoked and reissued to conform to that effluent standard or limitation.
C. PLACEMENT OF SIGNS
Within sixty (60) days of the effective date of this permit, the permittee shall place and
maintain a sign(s) at each outfall and any bypass/overflow point in the collection system. For the
purposes of this requirement, any bypass/overflow point that has discharged five (5) or more
times in the last year must be so posted. The sign(s) should be clearly visible to the public from
the bank and the receiving stream or from the nearest public property/right-of-way, if applicable.
The minimum sign size should be two feet by two feet (2' x 2') with one inch (1 ") letters. The
sign should be made of durable material and have a white background with black letters.
The sign(s) are to provide notice to the public as to the nature of the discharge and, in
the case of the permitted outfalls, that the discharge is regulated by the Tennessee Department
of Environment and Conservation, Division of Water Resources. The following is given as an
example of the minimal amount of information that must be included on the sign:
TREATED INDUSTRIAL WASTEWATER
Holliston Holdings, LLC
(Permittee's Phone Number)
NPDES Permit NO. TN0002330
TENNESSEE DIVISION OF WATER RESOURCES
1-888-891-8332 ENVIRONMENTAL FIELD OFFICE - Johnson City
INDUSTRIAL STORM WATER RUNOFF
Holliston Holdings, LLC
(Permittee's Phone Number)
NPDES Permit NO. TN0002330
TENNESSEE DIVISION OF WATER RESOURCES
1-888-891-8332 ENVIRONMENTAL FIELD OFFICE - Johnson City

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 22
D. ANTIDEGRADATION
Pursuant to the Rules of the Tennessee Department of Environment and Conservation,
Chapter 0400-40-03-.06, titled "Tennessee Antidegradation Statement," which prohibits the
degradation of exceptional Tennessee waters and the increased discharges of substances that
cause or contribute to impairment, the permittee shall further be required, pursuant to the terms
and conditions of this permit, to comply with the effluent limitations and schedules of compliance
required to implement applicable water quality standards, to comply with a State Water Quality
Plan or other state or federal laws or regulations, or where practicable, to comply with a
standard permitting no discharge of pollutants.
E. BIOMONITORING REQUIREMENTS, CHRONIC
The permittee shall conduct a 3-Brood Ceriodaphnia dubia Survival and Reproduction
Test and a 7-Day Fathead Minnow (Pimephales promelas) Larval Survival and Growth Test on
the same samples of final effluent from Outfall 002.
The measured endpoint for toxicity will be the inhibition concentration causing 25%
reduction (IC25) in survival, reproduction, or growth of the test organisms. The IC25 shall be
determined based on a 25% reduction as compared to the controls. The average reproduction
and growth responses will be determined based on the number of Ceriodaphnia dubia or
Pimephales promelas larvae used to initiate the test.
Test shall be conducted and its results reported based on appropriate replicates of a
total of five serial dilutions and a control, using the percent effluent dilutions as presented in the
following table:
Serial Dilutions for Whole Effluent Toxicity (WET) Testing
Permit Limit
(PL)
0.50 X PL
0.25 X PL
0.125 X PL
0.0625 X PL
Control
% effluent
100 50 25 1 12.5 6.25 0
The dilution/control water used will be a moderately hard water as described in Short -
Term Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to
Freshwater Organisms, EPA-821-R-02-013 (or the most current edition). Results from a chronic
standard reference toxicant quality assurance test for each species tested shall be submitted
with the discharge monitoring report. Reference toxicant tests shall be conducted as required in
EPA-821-R-02-013 (or the most current edition). Additionally, the analysis of this multi -
concentration test shall include review of the concentration -response relationship to ensure that
calculated test results are interpreted appropriately.
Toxicity will be demonstrated if the IC25 is less than or equal to the permit limit indicated
for each outfall in the above table(s). Toxicity demonstrated by the tests specified herein
constitutes a violation of this permit.

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 23
All tests will be conducted using a minimum of three 24-hour flow -proportionate
composite samples of final effluent (e.g., collected on days 1, 3 and 5). If, in any control more
than 20% of the test organisms die in 7 days, the test (control and effluent) is considered invalid
and the test shall be repeated within 30 days of the date the initial test is invalidated.
Furthermore, if the results do not meet the acceptability criteria of section 4.9.1, EPA-821-R-02-
013 (or the most current edition), or if the required concentration -response review fails to yield a
valid relationship per guidance contained in Method Guidance and Recommendations for Whole
Effluent Toxicity (WET) Testing, EPA-821-B-00-004 (or the most current edition), that test shall
be repeated. Any test initiated but terminated before completion must also be reported along
with a complete explanation for the termination.
The toxicity tests specified herein shall be conducted semi-annually (2Near) for Outfall
002 and begin no later than 90 days from the effective date of this permit.
In the event of a test failure, the permittee must start a follow-up test within 2 weeks
and submit results from a follow-up test within 30 days from obtaining initial WET testing results.
The follow-up test must be conducted using the same serial dilutions as presented in the
corresponding table(s) above. The follow-up test will not negate an initial failed test. In
addition, the failure of a follow-up test will constitute a separate permit violation which
must also be reported.
In the event of 2 consecutive test failures or 3 test failures within a 12 month period for
the same outfall, the permittee must initiate a Toxicity Identification Evaluation/Toxicity
Reduction Evaluation (TIE/TRE) study within 30 days and so notify the division by letter. This
notification shall include a schedule of activities for the initial investigation of that outfall. During
the term of the TIE/TRE study, the frequency of biomonitoring shall be once every three
months. Additionally, the permittee shall submit progress reports once every three months
throughout the term of the TIE/TRE study. The toxicity must be reduced to allowable limits for
that outfall within 2 years of initiation of the TIE/TRE study. Subsequent to the results obtained
from the TIE/TRE studies, the permittee may request an extension of the TIE/TRE study period
if necessary to conduct further analyses. The final determination of any extension period will be
made at the discretion of the division.
The TIE/TRE study may be terminated at any time upon the completion and submission
of 2 consecutive tests (for the same outfall) demonstrating compliance. Following the
completion of TIE/TRE study, the frequency of monitoring will return to a regular schedule, as
defined previously in this section as well in Part I of the permit. During the course of the
TIE/TRE study, the permittee will continue to conduct toxicity testing of the outfall being
investigated at the frequency of once every three months but will not be required to
perform follow-up tests for that outfall during the period of TIE/TRE study.
Test procedures, quality assurance practices, determinations of effluent
survival/reproduction and survival/growth values, and report formats will be made in accordance
with Short -Term Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters
to Freshwater Organisms, EPA-821-R-02-013, or the most current edition.
Results of all tests, reference toxicant information, copies of raw data sheets, statistical
analysis and chemical analyses shall be compiled in a report. The report will be written in

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 24
accordance with Short -Term Methods for Estimating the Chronic Toxicity of Effluents and
Receiving Waters to Freshwater Organisms, EPA-821-R-02-013, or the most current edition.
Two copies of biomonitoring reports (including follow-up reports) shall be submitted to
the division. One copy of the report shall be submitted along with the discharge monitoring
report (DMR). The second copy shall be submitted to the local Division of Water Resources
office address:
Environmental Field Office -Johnson City
Division of Water Resources
2305 Silverdale Road
Johnson City, TN 37601
F. CERTIFIED OPERATOR
The waste treatment facilities shall be operated under the supervision of a wastewater
system certified operator in accordance with the Water Environmental Health Act of 1984.
STORM WATER POLLUTION PREVENTION PLAN
The discharger will develop, document and maintain a storm water pollution prevention
plan (SWPPP) pursuant to the requirements as set forth in the Tennessee Multi -Sector General
Permit for Industrial Activities, Sector V, "Storm Water Discharges Associated With Industrial
Activity From Textile Mills, Apparel, and Other Fabric Product Manufacturing Facilities", Part 3,
"Storm Water Pollution Prevention Plan Requirements", applicable to Textile Mills, Apparel, and
Other Fabric Product Manufacturing Facilities. The plan shall be signed by either a principal
executive officer of a corporation, the owner or proprietor of a sole proprietorship, or a partner or
general partner of a partnership. The SWPPP developed and implemented shall contain, in
addition to the requirements listed in the Tennessee Multi -Sector SWPPP guidelines for Textile
Mills, Apparel, and Other Fabric Product Manufacturing Facilities, the following items:
A. PLAN IMPLEMENTATION
The plan should be developed and available for review within 30 days after permit
coverage. Facilities should implement the management practices as soon as possible, but not
later than one year after permit coverage. Where new construction is necessary to implement
the management plan, a construction schedule should be included. Construction should be
completed as soon as possible.

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 25
B. PLAN AVAILABILITY
The plan will be maintained by the discharger on the site or at a nearby office. Copies of
the plan will be submitted to the Division of Water Resources within ten business days of any
request.
C. PLAN MODIFICATION
The plan will be modified as required by the director of the Division of Water Resources.
D. MONITORING PLAN
The storm water discharges will be monitored as required in Part I. Section A., Effluent
Limits and Monitoring Requirements, applicable to storm water outfalls. For each outfall
monitored, the surface area and type of cover, for example, roof, pavement, grassy areas,
gravel, will be identified.

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 26
ATTACHMENT I
Holliston Holdings, LLC
NPDES Permit TN0002330
Storm Water Pollution Prevention Plan Requirements

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 27
Storm Water Pollution Prevention Plan Requirements
a) Contents of Plan. The plan shall include, at a minimum, the following items:
(1) Pollution Prevention Team. Each plan shall identify a specific individual or individuals
within the facility organization as members of a storm water Pollution Prevention Team who are
responsible for developing the storm water pollution prevention plan and assisting the facility or
plant manager in its implementation, maintenance, and revision. The plan shall clearly identify
the responsibilities of each team member. The activities and responsibilities of the team shall
address all aspects of the facility's storm water pollution prevention plan.
(2) Description of Potential Pollutant Sources. Each plan shall provide a description of
potential sources which may reasonably be expected to add significant amounts of pollutants to
storm water discharges or which may result in the discharge of pollutants during dry weather
from separate storm sewers draining the facility. Each plan shall identify all activities and
significant materials which may potentially be significant pollutant sources. Each plan shall
include, at a minimum:
(a) Drainage
(i) A site map indicating an outline of the portions of the drainage area of each storm water
outfall that are within the facility boundaries, each existing structural control measure to reduce
pollutants in storm water runoff, surface water bodies, locations where significant materials are
exposed to precipitation, locations where major spills or leaks identified under Part a.(2)(c)
(Spills and Leaks) of this permit have occurred, and the locations of the following activities
where such activities are exposed to precipitation: loading/unloading areas, locations used for
the treatment, storage or disposal of wastes, liquid storage tanks or silos, bulk storage areas
that may exist, processing areas and storage areas, fueling stations, vehicle and equipment
maintenance and/or cleaning areas. The map must indicate the outfall locations and the types
of discharges contained in the drainage areas of the outfalls.
(ii) For each area of the facility that generates storm water discharges associated with
industrial activity with a reasonable potential for containing significant amounts of pollutants, a
prediction of the direction of flow, and an identification of the types of pollutants which are likely
to be present in storm water discharges associated with industrial activity. Factors to consider
include the toxicity of chemical; quantity of chemicals used, produced or discharged; the
likelihood of contact with storm water; and history of significant leaks or spills of toxic or
hazardous pollutants. Flows with a significant potential for causing erosion shall be identified.

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 28
(b) Inventory of Exposed Materials — An inventory of the types of materials handled at the
site that potentially may be exposed to precipitation. Such inventory shall include a narrative
description of significant materials that have been handled, treated, stored or disposed in a
manner to allow exposure to storm water between the time of 3 years prior to the date of
issuance of this permit; method and location of onsite storage or disposal; materials
management practices employed to minimize contact of materials with storm water runoff
between the time of 3 years prior to the date of issuance of this permit; the location and a
description of existing structural and nonstructural control measures to reduce pollutants in
storm water runoff; and a description of any treatment the storm water receives.
(c) Spills and Leaks — A list of significant spills and significant leaks of toxic or
hazardous pollutants that occurred at areas that are exposed to precipitation or that otherwise
drain to a storm water conveyance at the facility after the date of 3 years prior to the date of of
issuance of this permit. Such list shall be updated as appropriate during the term of the permit.
(d) Sampling Data — A summary of existing discharge sampling data describing pollutants
in storm water discharges from the facility, including a summary of sampling data collected
during the term of this permit.
(e) Risk Identification and Summary of Potential Pollutant Sources — A narrative description
of the potential pollutant sources from the following activities: loading and unloading operations;
outdoor storage activities; outdoor manufacturing or processing activities; significant dust or
particulate generating processes; onsite waste disposal practices; industry -specific significant
materials and industrial activities (e.g., backwinding, beaming, bleaching, backing, bonding
carbonizing, carding, cut and sew operations, desizing, drawing, dyeing flocking, fulling, knitting,
mercerizing, opening, packing, plying, scouring, slashing, spinning, synthetic -felt processing,
textile waste processing, tufting, turning, weaving, web forming, winging, yarn spinning, and
yarn texturing). The description shall specifically list any significant potential source of
pollutants at the site and for each potential source, any pollutant or pollutant parameter (e.g.,
biochemical oxygen demand, etc.) of concern shall be identified.
(3) Measures and Controls. Each facility covered by this permit shall develop a description
of storm water management controls appropriate for the facility, and implement such controls.
The appropriateness and priorities of controls in a plan shall reflect identified potential sources
of pollutants at the facility. The description of storm water management controls shall address
the following minimum components, including a schedule for implementing such controls:
(a) Good Housekeeping — Good housekeeping requires the maintenance of areas which
may contribute pollutants to storm water discharges in a clean, orderly manner. The following
areas must be specifically addressed, when applicable at the facility:
(i) Material Storage Areas — All stored and containerized materials (fuels, petroleum
products, solvents, dyes, etc.) must be stored in a protected area, away from drains and clearly
labeled. The plan must describe measures that prevent or minimize contamination of storm
water runoff from such storage areas. The facility should specify which materials are stored
indoors and must provide a description of the containment area or enclosure for those materials
which are stored outdoors. Above ground storage tanks, drums, and barrels permanently
stored outside must be delineated on the site map with a description of the appropriated
containment measures in place to prevent leaks and spills. The facility may consider an

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 29
inventory control plan to prevent excessive purchasing, storage, and handling of potentially
hazardous substances. In the case of storage of empty chemical drums and containers,
facilities should employ practices which ensure that barrels are clean and residuals are not
subject to contact with storm water, such practices may include triple -rinsing containers. The
discharge waters from such washings must be collected and disposed of properly.
(ii) Material Handling Area — The plan must describe measures that prevent or
minimize contamination of the storm water runoff from materials handling operations and areas.
The facility may consider the use of spill and overflow protection; covering fueling areas;
covering and enclosing areas where the transfer of materials may occur. Where applicable, the
plan must address the replacement or repair of leaking connections, valves, transfer lines and
pipes that may carry chemicals, dyes, or wastewater.
(iii) Fueling Areas — The plan must describe measures that prevent or minimize
contamination of the storm water runoff from fueling areas. The facility may consider covering
the fueling area, using spill and overflow protection, minimizing runon of storm water to the
fueling area, using dry cleanup methods, and/or collecting the storm water runoff and providing
treatment or recycling.
(iv) Above Ground Storage Tank Areas — The plan must describe measures that
prevent or minimize contamination of the storm water runoff from above ground storage tank
areas. The facility must consider storage tanks and their associated piping and valves. The
facility may consider regular cleanup of these areas, preparation of a spill prevention control and
countermeasure program, provide spill and overflow protection, minimizing runon of storm water
from adjacent areas, restrict access to the area, insertion of filters in adjacent catch basins,
provide absorbent booms in unbermed fueling areas, use of dry cleanup methods, and
permanently sealing drains within critical areas that may discharge to a storm drain.
(b) Preventive Maintenance — A preventive maintenance program shall involve timely
inspection and maintenance of storm water management devices (e.g., cleaning oil/water
separators, sediment traps, catch basins, infiltration devices, ponds) as well as inspecting and
testing facility equipment and systems to uncover conditions that could cause breakdowns or
failures resulting in discharges of pollutants to surface waters, and ensuring appropriate
maintenance of such equipment and systems.
(c) Spill Prevention and Response Procedures — Areas where potential spills which can
contribute pollutants to storm water discharges can occur, and their accompanying drainage
points shall be identified clearly in the storm water pollution prevention plan. Where
appropriate, specifying material handling procedures, storage requirements, and use of
equipment such as diversion valves in the plan should be considered. Procedures for cleaning
up spills shall be identified in the plan and made available to the appropriate personnel. The
necessary equipment to implement a clean up should be available to personnel.
(d) Inspections — Qualified facility personnel shall be identified to inspect designated
equipment and areas of the facility at appropriate intervals specified in the plan. Inspection
intervals are to occur on a monthly basis. Inspections of this nature shall include, but not be
limited to, the following areas: all containment and storage areas, transfer and transmission
lines, spill prevention, good housekeeping practices, management of process waste products,
all structural and nonstructural management practices. A set of tracking or follow-up procedures

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 30
shall be used to ensure that appropriate actions are taken in response to the inspections.
Records of inspections shall be maintained.
(e) Employee Training — Employee training programs shall inform personnel responsible
for implementing activities identified in the storm water pollution prevention plan or otherwise
responsible for storm water management at all levels of responsibility of the components and
goals of the storm water pollution prevention plan. Training should address topics such as spill
response, good housekeeping and material management practices. The pollution prevention
plan shall identify dates for such training to take place at least annually (once per calendar
year). Employee training must, at a minimum address the following areas when applicable to a
facility: use of reused/recycled waters; solvents management; proper disposal of dyes; proper
disposal of petroleum products and spent lubricants; spill prevention and control; fueling
procedures; and general good housekeeping practices. Employees, independent contractors,
and customers must be informed about BMPs and be required to perform in accordance with
these practices. Copies of BMPs and any specific management plans, including emergency
phone numbers, shall be posted in the work areas.
(f) Recordkeeping and Internal Reporting Procedures — A description of incidents (such as
spills, or other discharges), along with other information describing the quality and quantity of
storm water discharges shall be included in the plan required under this part. Inspections and
maintenance activities shall be documented and records of such activities shall be incorporated
into the plan.
(g) Non -storm Water Discharges
(i) The plan shall include a certification that the discharge has been tested or evaluated
for the presence of non -storm water discharges. The certification shall include the identification
of potential significant sources of non -storm water at the site, a description of the results of any
test and/or evaluation for the presence of non -storm water discharges, the evaluation criteria or
testing method used, the date of any testing and/or evaluation, and the onsite drainage points
that were directly observed during the test. Certifications shall be signed in accordance with
Part I.D.1. of this permit. Such certification may not be feasible if the facility operating the storm
water discharge associated with industrial activity does not have access to an outfall, manhole,
or other point of access to the ultimate conduit which receives the discharge. In such cases, the
source identification section of the storm water pollution prevention plan shall indicate why the
certification required by this part was not feasible, along with the identification of potential
significant sources of non -storm water at the site. A discharger that is unable to provide the
certification required by this paragraph must notify the Division of Water Resources in
accordance with paragraph a.(3)(g)(iii) (below).
(ii) Sources of non -storm water that are combined with storm water discharges
associated with industrial activity must be identified in the plan. The plan shall identify and
ensure the implementation of appropriate pollution prevention measures for the non -storm water
component(s) of the discharge. Any non -storm water discharges that are not permitted under
an individual NPDES permit should be brought to the attention of the Division's local
Environmental Field Office.
(iii) Failure to Certify — Any facility that is unable to provide the certification required
(testing for non -storm water discharges), must notify the Division of Water Resources 180 days

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 31
after the date of issuance of this permit. If the failure to certify is caused by the inability to
perform adequate tests or evaluations, such notification shall describe: the procedure of any
test conducted for the presence of non -storm water discharges; the results of such test or other
relevant observations; potential sources of non -storm water discharges to the storm sewer; and
why adequate tests for such storm sewers were not feasible. Non -storm water discharges to
waters of the State which are not authorized by an NPDES permit are unlawful, and must be
terminated.
(h) Sediment and Erosion Control — The plan shall identify areas which, due to topography,
activities, or other factors, have a high potential for significant soil erosion, and identify
structural, vegetative, and/or stabilization measures to be used to limit erosion.
(i) Management of Runoff — The plan shall contain a narrative consideration of the
appropriateness of traditional storm water management practices (practices other than those
which control the generation or source(s) of pollutants) used to divert, infiltrate, reuse, or
otherwise manage storm water runoff in a manner that reduces pollutants in storm water
discharges from the site. The plan shall provide that measures that the permittee determines to
be reasonable and appropriate shall be implemented and maintained. The potential of various
sources at the facility to contribute pollutants to storm water discharges associated with
industrial activity [see paragraph a.(2) of this section (Description of Potential Pollutant
Sources)] shall be considered when determining reasonable and appropriate measures.
Appropriate measures or other equivalent measures may include: vegetative swales and
practices, reuse of collected storm water (such as for a process or as an irrigation source), inlet
controls (such as oil/water separators), snow management activities, infiltration devices, and
wet detention/retention devices.
(4) Comprehensive Site Compliance Evaluation. Qualified personnel shall conduct site
compliance evaluations at appropriate intervals specified in the plan, but in no case less than
once a year. Such evaluations shall provide:
(a) Areas contributing to a storm water discharge associated with industrial activity (storage
tank areas, waste disposal and storage areas, dumpsters and open containers stored outside,
materials storage areas, engine maintenance and repair areas, material handling areas, and
loading dock areas) shall be visually inspected for evidence of, or the potential for, pollutants
entering the drainage system. Measures to reduce pollutant loadings shall be evaluated to
determine whether they are adequate and properly implemented in accordance with the terms
of the permit or whether additional control measures are needed. Structural storm water
management measures, sediment and erosion control measures, and other structural pollution
prevention measures identified in the plan shall be observed to ensure that they are operating
correctly. A visual inspection of equipment needed to implement the plan, such as spill
response equipment, shall be made.
(b) Based on the results of the evaluation, the description of potential pollutant sources
identified in the plan in accordance with paragraph a.(2) of this section (Description of Potential
Pollutant Sources) and pollution prevention measures and controls identified in the plan in
accordance with paragraph a.(3) of this section (Measures and Controls) shall be revised as
appropriate within 2 weeks of such evaluation and shall provide for implementation of any
changes to the plan in a timely manner, but in no case more than 12 weeks after the evaluation.

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 32
(c) A report summarizing the scope of the evaluation, personnel making the evaluation, the
date(s) of the evaluation, major observations relating to the implementation of the storm water
pollution prevention plan, and actions taken in accordance with paragraph a.(4)(b) (above) of
the permit shall be made and retained as part of the storm water pollution prevention plan for at
least 3 years from the date of the evaluation. The report shall identify any incidents of
noncompliance. Where a report does not identify any incidents of noncompliance, the report
shall contain a certification that the facility is in compliance with the storm water pollution
prevention plan and this permit. The report shall be signed in accordance with Part I.D.1. of this
permit.
(d) Where compliance evaluation schedules overlap with inspections required under
3.a.(3)(d), the compliance evaluation may be conducted in place of one such inspection.

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 33
ADDENDUM TO RATIONALE
Holliston Holdings, LLC
PERMIT NO. TN0002330
January 30, 2020
Addendum prepared by: Miss Julie Harse, P.E.
Staff from the Johnson City Environmental Field Office noted a typographical error in the
permit limit tables for the draft permit. The storm water monitoring table on page three should
have both SW2 and SW3.
A comment letter was received from the Southern Environmental Law Center regarding
the potential for Holliston Holdings LLC to discharge chemicals relative to PFAS. The facility's
application did not report any forms of PFAS as chemicals that there was the potential to
discharge. The permittee has no permit shield for the discharge of PFAS compounds because
no such chemicals were disclosed in the permit application or otherwise under TCA 69-3-108(v).
EPA's website state's the following regarding PFAS.
Per- and polyfluoroalkyl substances (PFAS) are a group of man-made
chemicals that includes PFOA, PFOS, GenX, and many other chemicals. PFAS
have been manufactured and used in a variety of industries around the globe,
including in the United States since the 1940s. PFOA and PFOS have been the
most extensively produced and studied of these chemicals. Both chemicals are
very persistent in the environment and in the human body — meaning they don't
break down and they can accumulate over time. There is evidence that exposure
to PFAS can lead to adverse human health effects.PFAS can be found in:
• Food packaged in PFAS-containing materials, processed with equipment
that used PFAS, or grown in PFAS-contaminated soil or water.
• Commercial household products, including stain- and water-repellent
fabrics, nonstick products (e.g., Teflon), polishes, waxes, paints, cleaning
products, and fire -fighting foams (a major source of groundwater
contamination at airports and military bases where firefighting training
occurs).
• Workplace, including production facilities or industries (e.g., chrome
plating, electronics manufacturing or oil recovery) that use PFAS.
• Drinking water, typically localized and associated with a specific facility
(e.g., manufacturer, landfill, wastewater treatment plant, firefighter training
facility).
• Living organisms, including fish, animals and humans, where PFAS
have the ability to build up and persist over time.
Certain PFAS chemicals are no longer manufactured in the United States as a
result of phase outs including the PFOA Stewardship Program in which eight
major chemical manufacturers agreed to eliminate the use of PFOA and PFOA-
related chemicals in their products and as emissions from their facilities.
Although PFOA and PFOS are no longer manufactured in the United States, they
are still produced internationally and can be imported into the United States in
consumer goods such as carpet, leather and apparel, textiles, paper and
packaging, coatings, rubber and plastics.

Holliston Holdings, LLC
NPDES Permit TN0002330
Page 34
EPA conducted from 2012 to 2016 a monitoring program under the unregulated
contaminant monitoring rule that included the sampling of various forms of PFAS. The
data gathered in the study is available to the public on EPA's website. There were three
facilities in Tennessee that pull raw water from the Holston River which participated in
the study: Morristown Water System, First Utility District of Hawkins County #1, and
Kingsport Water Department. The finished water sampling was non -detect for all PFOA
and PFOS samples at these facilities. The division does not believe that there is any
basis for requiring the facility to sample for PFAS in the new permit since they did not
disclose the chemical in their application. There are many sources of PFAS that can
result in an individual being exposed to the chemical.

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-1
RATIONALE
Holliston Holdings, LLC
NPDES PERMIT NO. TN0002330
Church Hill, Hawkins County, Tennessee
Permit Writer: Miss Julie Harse, P.E.
DISCHARGER
Holliston Holdings, LLC
905 Holliston Mills Road
Church Hill, Hawkins County, Tennessee
Site Longitude:-82.758207 Site Latitude: 36.512093
Official Contact Person:
Mr. Sheldon Sillyman
VP of Business Development
[phone]
Nature of Business:
Coated Fabrics, Not Rubberized
SIC Code(s): 2295
Industrial Classification: Primary
Discharger Rating: Major
PRIMARY INDUSTRY CATEGORY means any industry category listed in the
NRDC Settlement Agreement (Natural Resources Defense Council v. Train, 8
ERC 2120 [D.D.C. 19761, modified 12 ERC 1833 [D.D.C. 19791).
PERMIT STATUS
Issued November 01, 2014
Expired October 31, 2019
Application for renewal received
Watershed Scheduling
Environmental Field Office: Johnson City
Hydrocode: 06010104 Watershed Group: 4
Watershed Identification: Holston
Target Reissuance Year: 2024

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-2
III. FACILITY DISCHARGES AND RECEIVING WATERS
Holliston, LLC discharges process wastewater, water treatment wastewater, steam
generation wastewater, domestic wastewater, and storm water runoff from Outfall 001,
emergency discharges only of non -contact cooling water from Outfall 002, and storm water
runoff from Outfalls SW2 and SW3 to Holston River mile 129.5 (Outfall 001), Sevier Branch mile
1.0 (Outfalls 002 and SW2) and Holston River (Outfall SW3). Appendix 1 summarizes facility
discharges and the receiving stream information for Outfall 001. The treatment system consists
of equalization ponds followed by an activated sludge treatment plant.
IV. APPLICABLE EFFLUENT LIMITATIONS GUIDELINES
The Standard Industrial Classification (SIC) codes for Holliston Mills, Inc. are 2295 -
Coated Fabrics, 2261- Broad woven fabrics of Cotton, and 2672 — Coated and laminated Paper.
The process water discharged from Outfall 001 is regulated by 40 CFR Part 410.32 and 40 CFR
410.42. Appendix 2 lists the applicable best available technology (BAT) and best conventional
pollution control technology (BCT) effluent limitations guidelines for Subpart C- Low Water Use
Processing and Subpart D-Woven Fabric Finishing.
V. PREVIOUS PERMIT LIMITS AND MONITORING REQUIREMENTS
Appendix 3 lists the permit limitations and monitoring requirements as defined in the
previous permit.
VI. HISTORICAL MONITORING AND INSPECTION
During the previous permit term, Holliston Holdings, LLC did not have any appreciable
difficulty in meeting effluent limitations as outlined in the previous permit. A summary of the
data reported on Discharge Monitoring Report forms during the previous permit term is
summarized in Appendix 4. During the previous permit term, Sandra Vance from the Johnson
City Environmental Field Office performed compliance evaluation inspections (CEI) of the
Holliston Holdings, LLC. The compliance issues were relative to the permit requirement for
operation and maintenance. A summary of the issues noted by the field office and current status
is provided in Appendix 4.
VII. NEW PERMIT LIMITS AND MONITORING REQUIREMENTS
The proposed new permit limits have been selected by determining a technology -based
limit and evaluating if that limit protects the water quality of the receiving stream. If the
technology -based limit would cause violations of water quality, the water quality -based limit is
chosen. The technology -based limit is determined from EPA effluent limitations guidelines if
applicable (see Part IV); or from State of Tennessee maximum effluent limits for effluent limited
segments per Rule 0400-40-05-.08. Note that in general, the term "anti -backsliding" refers to a
statutory provision that prohibits the renewal, reissuance, or modification of an existing NPDES
permit that contains effluents limits, permit conditions, or standards that are less stringent than
those established in the previous permit.

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-3
Outfall 001
Flow
Monitoring of flow quantifies the load of pollutants to the stream. Flow shall be reported in
Million Gallons per Day (MGD) and monitored at a frequency of 3 times per week (3/week) by
recorder method.
Oil and Grease
The application provided a sampled concentration of 89.1 mg/L. The new permit will
require the quarterly reporting of oil and grease.
pH
According to the State of Tennessee Water Quality Standards [Chapter 0400-40-03-
.03(3) (b)], the pH for the protection of Fish and Aquatic Life shall lie within the range of 6.5 to
9.0 for larger rivers and shall not fluctuate more than 1.0 unit in this range over a period of 24-
hours. The federal effluent guidelines require a pH range of 6.0 to 9.0. Considering that the
receiving stream will provide some buffering capacity, effluent limitation for pH will be retained in
a range 6.0 to 9.0. The sample type will be grab.at a frequency of 3 times per week. The pH
value shall be recorded within fifteen (15) minutes of sample collection.
Total Residual Chlorine (TRC)
Chlorination involves mixing chlorine with water to produce free available chlorine (HOCI
and OCI ). Part of the free available chlorine combines with certain pollutants such as ammonia
to form chloramines. The amount of chlorine converted to chloramines is based on the contact
time, pH and temperature of the wastewater. The continued addition of chlorine will allow the
wastewater to reach the breakpoint or beginning of pathogen destruction. A properly designed
system will maximize the breakdown and disinfection of pollutants and minimize the free
available chlorine at the exit of the treatment system. The total residual chlorine concentration of
2 mg/L at the treatment system exit is an obtainable design parameter that is consistently
applied to NPDES permits. The daily maximum concentration permit limit of 2 mg/L will be
applied based on the permit writer's judgment of reasonable treatment. The TRC value shall be
recorded within fifteen (15) minutes of sample collection.
E.coli
Disinfection of wastewater is required to protect the receiving stream from pathogenic
microorganisms. E. coli is an indicator organism used as a measure of bacteriological health of
a receiving stream and the effectiveness of disinfection. The monthly average limit for the
recreation use of the stream is 126 colonies per 100 ml. The E. coli daily maximum limit of 487
colonies per 100 ml applies to lakes and exceptional Tennessee waters. A maximum daily limit
of 941 colonies per 100 ml applies to all other recreational waters.
BOD5, Sulfides, and COD
Biological oxygen demand, sulfides, and chemical oxygen demand are limited by the
effluent guidelines for the process wastewater. These parameters are utilized to determine the
overall oxygen demand on the receiving stream due to the combined effect of all pollutants in
the effluent. The facility's production based limits are based on 60,000 lb/day.

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-4
Copper, Lead, Nickel, and Zinc
The previous permit limits for these parameters were based on historical sampling data
submitted in the facility's application. The previous permit concentrations account for less than
two percent of the stream loading and do not create the reasonable potential to violate water
quality criteria. The previous permit limits will be retained in the new permit.
Total Suspended Solids, Total Chromium, and Total Phenol
The parameters are limited by the federal effluent guidelines with the calculations
located in Appendix 5a. The facility's production based limits are based on 60,000 lb/day. The
limits for total chromium and total phenol are less than two percent of the stream loading.
Formaldehyde, Vinyl Acetate, and Acetaldehyde
The permit application has indicated residual formaldehyde, vinyl acetate, and
acetaldehyde remains in the pre -manufactured coating resins used in the cloth coating process.
Formaldehyde is a known carcinogen. The division will continue a monitoring frequency of once
per month (1/month) by composite sampling and report only effluent limits for formaldehyde and
vinyl acetate. The sampling data from the previous period was compared to toxicity values in
EPA's ECOTOX database. The maximum sampled value for each parameter was below the
average toxicity concentration.
Effluent
ECOTOX
Flow
Average DMR
Toxicity
Rate
Poundage
Poundage
Chemical
Species
Value m /L)
(MGD)
(Ib/da(lb/day)
Formaldehyde
Daphnia ma na
16.5
0.316
43.5
1.06
Vinyl acetate
Fathead Minnow
14
0.316
36.9
0.01
Acetaldehyde
Fathead Minnow
30.8
0.316
81.2
0.99
Application Data
The application data for metals is listed in the below chart with corresponding portions of
the stream loading. The amount being discharged is a fraction of the stream loading and does
not create the reasonable potential to violate water quality. The application data for non-metals
was non -detect.

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-5
Fish and Aquatic Life I Organisms and DWS
Chronic I Acute I Organisms I Water/Organisms I DWS I Averaqe I Maximum I Application Value I Application Value
PARAMETER
lb/day
lb/day
lb/day
lb/day
lb/day
lb/day
lb/day
ug/L
lb/day
% of Stream Loading
Copper (a,b)
232
353
NA
NA
NA
232
353
130
0.343
0.15
Chromium III
5302
40760
NA
NA
NA
5302
40760
10
0.026
0.00
Chromium VI
54
78
NA
NA
NA
54
78
10
0.026
0.05
Chromium, Total
NA
NA
NA
NA
660
660
1321
10
0.026
0.00
Nickel (a,b)
1424
12819
30377
4028
660
660
1321
10
0.026
0.00
Cadmium (a,b)
21
53
NA
NA
33
21
1 53
10
0.026
0.13
Lead (a,b)
101
2594
NA
NA
33
33
66
10
0.026
0.08
Mercury (T) (c)
4
7
NA
NA
13
4
7
0.45
0.001
0.03
Silver (a,b, e)
NA
21
NA
NA
NA
NA
21
10
0.026
0.13
Zinc (a,b)
5324
5280
171694
48867
NA
5324
5280
20
0.053
0.00
Cyanide (d)
25
108
925
925
1321
25
108
20
0.053
0.21
ANTIMONY
NA
NA
4226
37
40
37
74
10
0.026
0.07
ARSENIC
735
1665
66
66
66
66
1 132
10
0.026
0.04
BERYLLIUM
NA
NA
NA
NA
26
26
53
10
0.026
0.10
SELENIUM (fl
7
98
27735
1123
330
7
98
10
0.026
0.36
THALLIUM
NA
NA
3.1
1.6
13.2
1.6
3.2
10
0.026
1.66
Phenols
NA
NA
5679106.3
66036.1
NA
66036.1
132072.2
100
0.264
0.0004

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-6
Outfalls 002, SW2, and SW3
This facility is one which has storm water runoff associated with industrial activity, as
defined in 40 CFR 122.26 (b)(14). Emergency discharges of non -contact cooling water
discharge through Outfall 002 and storm water runoff discharges through Outfall SW2. In order
to adequately characterize dry weather and wet weather discharges, two sets of effluent
limitations will be established in the new permit. Effluent limitations for the outfalls designated
as SW2 and SW3 will represent wet weather (storm water) discharges from the facility.
It should be noted that Outfalls 002 and SW2 represent the same physical location, and
that the limits in the permit for Outfall 002 are only applied when there is an emergency -dry
weather (i.e., non -contact cooling water) discharge for this outfall. This type of discharge should
only occur when there is a failure of the recycle process cooling water system. The definition of
wet weather flow can be found in Part I., Section C of this permit.
Outfall 002
Flow
Monitoring of flow quantifies the load of pollutants to the stream. Flow shall be reported
in Million Gallons per Day (MGD) and monitored at a frequency of once per discharge
(1/discharge), as an instantaneous sample type.
Ammonia as N
The application sampled value was for 2.04 mg/L. The new permit will contain ammonia
limits based on the below toxicity calculations.
Ammonia as Nitrogen Calculations
The State utilizes the Water Quality Criteria and the EPA document, EPA Ambient water Quality Criteria for Ammonia (htto //www.eoa.eov/wa -criteria-ammonia).c/aauatic-
lifeAmass balance with plant and stream flows and this allowable value determines the monthly aeerage permit limit. Seasonal
limits may also be allowed due to ambient temperature variations between the summer and winter seasons.
A pH value of 8 (instead of historically used 7.5) was chosen for two
East TN- 25'C, 15'C reasons: 1.) ambient monitoring in west TN showed that a pH often
Middle TN- 27'C, 17'C exceeds 7.5, and is up to 8 sometimes 2.) this assumption is more
West TN- 30'C, 20'C conservative.
Winter Summer
Temp 15 Temp ('C)= 25
pH= 7 pH= 7
MAX Expression 15.0000 MAX Expression 25.0000
CCC = 0.8876 x
0.0278 1.1994 0028x(20-MAX(z,7))�
1 + 107-688-pH + 1 + 10T'H-7.688 x 2.126 x 10
Winter CCC= 2.60 Summer CCC= 1.37
CCC - Continuous Chronic Criterion Allowable instream NH3 concentration [mg/1]
(Critical Low Flow [MGD] * Background Ammonia [mg/L]) + (Design Flow [MGD] * Effluent Concentration [mg/L])
CCC=
(Critical Low Flow [MGD] + (Design Flow [MGD])
where: 0 Critical Low Flow [MGD] (7010 value)
0.1 Background Ammonia Concentration [mg/L]
0.27 W WTP Design Flow or long-term average flow [MGD]
Therefore, the Allowable Effluent Concentrations and corresponding Amounts in winter and summer are:
Winter Summer
2.60 Concentration [mg/L] 1.367 Concentration [mg/L]
5.9 Amount [lb/day] 3.1 Amount [lb/day]

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-7
pH
According to the State of Tennessee Water Quality Standards [Chapter 0400-40-03-
.03(3) (b)], the pH for the protection of Fish and Aquatic Life shall lie within the range of 6.0 to
9.0 for wadeable streams and shall not fluctuate more than 1.0 unit in this range over a period of
24-hours. The sample type will be grab monitored at a frequency of once per month (1/month).
Recording of the pH value shall be within fifteen (15) minutes of sample collection.
Effluent Temperature
Temperature will be limited according to the State of Tennessee Water Quality
Standards for the protection of Fish & Aquatic Life [Chapter 0400-40-03-.03(3)(e)]. It is
recognized that the temperature of the non -contact cooling water discharge will be greater than
the temperature of the water prior to its use for cooling or other purposes. This discharge must
not cause the temperature change in receiving stream to exceed 30C relative to an upstream
control point. Also, this discharge must not cause the temperature of receiving stream to
exceed 30.5°C (except as a result of natural causes), and this discharge must not cause the
maximum rate of temperature change in receiving stream to exceed 20C per hour (except as a
result of natural causes).
Considering that Outfall 002 discharges to a receiving stream with a zero critical low flow
there is reasonable potential of exceeding applicable WQ criteria. Therefore, effluent
temperature shall be monitored, but on "report only" basis on the Discharge Monitoring Reports
(DMRs). Any reported effluent temperature with an exceedance of the above mentioned
temperature of 30.5°C (water quality criteria) is not necessarily a permit violation, because the
30.5°C value applies to the receiving stream, not the effluent. However, if the effluent
temperature exceeds 30.5°C, the permittee should note in the "comments" section of the DMR
that this is the temperature of the effluent. A temperature check in the receiving stream below
the discharge point should be performed in order to prove facility's compliance with the
Tennessee Water Quality Standards and should also be noted in the "comments" section of the
DMR (for Outfall 002). The sample type will be grab monitored at a frequency of once per month
(1 /month).
Copper, Nickel, and Zinc
The previous permit was limited for these parameters based on historical monitoring
data. The limits have been updated for the current water quality criteria in the below chart.

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-8
Stream
Stream
Waste
I Sus .
Hardness
Margin of
(1Q10)
3025)
Flow
Solids
as CaCO3)Safely
[MGD]
[MGD]
[MGD]
[mgIll
[m II]
N
0
0
0.01
10
118
100
1
2
1 3
4
5
6
7
8
9
10
11
12
13
14
Stream
Bckgmd,
Conc.
FisNAqua. Life (F & AL) WQC
lab conditions
Fraction
Dissolved
F & AL- insiream allowable
ambient condilions of
Calc. Effluent Concentration
based on F & AL
Human Health Water Quality Cdteda'
In•Siream Criteria
Calc. Effluent Concentration's
Chronic
Acute
Chronic
Acute
Chronic
Acute
Organisms
WaterlOrganisms
DWS
Organisms
Walerlorganisms
DWS
PARAMETER
[ugll]
[ugll]
[ugll]
[Fraction]
[ugll]
[ugll]
[ugll]
[ugll]
NO
[ugll]
[ugll]
[ugll]
[ugll]
NO]
Copper (a,b)
10.316
15.707
0.218
47.331
72.063
47.33
72.06
NIA
NIA
NIA
NA
NA
NA
Nickel (a,b)
59.823
538.613
0.206
290.744
2617.683
290.74
2617.68
1 4600.0
610.0
1 100.0
4600
610
100
Zinc (a,b)
135.925
134.822
0.125
1087.067
1078.247
1087.07
1078.25
1 26000.0
7400.0
NIA
26000
7400
NA

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-9
Chronic Biomonitorinq
The discharge of industrial wastewater from Outfall 002 may contain several different
pollutants, the combined effect of which has a reasonable potential to be detrimental to fish and
aquatic life. The Tennessee Water Quality Standards criteria stipulates that "The waters shall
not contain toxic substances, whether alone or in combination with other substances, which will
produce toxic conditions...".
Since the permittee discharges to a stream with low critical flow conditions, there is a
concern for toxicity effects of the discharge on the receiving stream, which is relatively unknown.
Biomonitoring will provide information relative to the toxicity of the discharge. Calculation of
toxicity limits is as follows:
Qs + Qw
DF =------------------ = Dilution Factor
Qw
where Qw is a wastewater flow (Qw = 0.010 MGD) and Qs is a receiving stream low flow (7Q10
or 1 Q10, estimated at 0 MGD). Please refer to Appendix 1 for details regarding facility discharge
and receiving stream. Therefore,
0 + 0.010
DF = = 1
0.010
Since the calculated dilution factor is less than 100:1, and assuming immediate and
complete mixing, protection of the stream from chronic effects requires:
IWC < 1.0 X IC25; or,
INHIBITION CONCENTRATION, 25% > IWC
Where IWC is Instream Waste Concentration and is calculated using the following formula:
Qw
IWC =
Qs + Qw
0.010
IWC =
0 + 0.010
X 100 = Instream Waste Concentration
X 100 = 100
Therefore, WET testing will be required on 100% effluent. If toxicity is demonstrated in
any of the effluent samples specified above, this will constitute a violation of this permit. The
toxicity tests specified herein shall be conducted semi-annually (2/Year) for Outfall 002 and
begin no later than 90 days from the effective date of this permit.

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-10
Outfalls SW2 and SW3
Flow
The permittee shall provide the date and duration (in hours) of the qualifying storm
event(s) sampled; rainfall measurements or estimates (in inches) of the storm event that
generated the sampled runoff; the duration between the storm event sampled and the end of the
previous measurable (greater than 0.1 inch rainfall) storm event; and an estimate of the total
volume of the discharge sampled. Flow shall be estimated and reported in Million Gallons per
Day (MGD), and monitored at a frequency of once per 6-months (semi-annual).
pH
The pH benchmark for the general storm water permit is 5.0 — 9.0 S.U. The parameter
pH shall be monitored on a semi-annual basis and shall be report only. Recording of the pH
value shall be within fifteen (15) minutes of sample collection.
Total Suspended Solids (TSS) and Oil & Grease
According to the State of Tennessee Water Quality Standards for the protection of Fish
& Aquatic Life [Chapter 0400-40-03-.03(3) (c)], there shall be no distinctly visible solids, scum,
foam, oily slick, or the formation of slimes, bottom deposits or sludge banks of such size or
character that may be detrimental to fish and aquatic life in the receiving stream. The
benchmark parameters for TSS and Oil & Grease are 200 mg/L and 15 mg/L. The parameters
shall be monitored on a semi-annual basis and shall be report only.
Parameters of Concern
Cut -Off Concentration [mg/L]
BOD (5-Day)
30
Total Suspended Solids (TSS)
200
Oil & Grease
15
Ammonia as Nitrogen
4.0
PHOSPHORUS, TOTAL
2.0
ALUMINUM, TOTAL (pH=6.5-9)
0.75
COPPER, TOTAL
0.0636
PHENOLS, TOTAL
1.0
pH (range)
5.0 - 9.0
Total Recoverable Zinc
0.395
Note: Sample values are from the Tennessee Storm Water Multi -Sector General Permit for
Industrial Activities, Rationale, Part III, Table III -A: Parameter Benchmark Values.
IX. ANTIDEGRADATION
Tennessee's Antidegradation Statement is found in the Rules of the Tennessee
Department of Environment and Conservation, Chapter 0400-40-03-.06. It is the purpose of
Tennessee's standards to fully protect existing uses of all surface waters as established under
the Act.Stream determinations for this permit action are associated with the waterbody segment

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-11
identified by the division as segment ID#TN06010104011 2000. The division has made a water
quality assessment of the receiving waters associated with the subject discharge(s) and has
found the receiving stream to be neither an exceptional nor outstanding national resource water.
The Holston River has been assessed as impaired for mercury due to atmospheric deposition.
The application sampling for mercury was less than one percent of the stream loading.,
therefore the facility's wastewater discharge should not be contributing to the mercury loading in
the stream.
TMDLs have been developed and approved for this waterbody segment on the following
parameters and dates:
Parameter
E.coli
TMDL Approval Date
September 30, 2008
The facility's outfall that contains sanitary wastewater is required to meet the division's
coliform standard at the discharge point. The proposed terms and conditions of this permit
comply with the waste load allocations of these TMDLs.

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-12
ID305b (GIS Link) : TN06010104011 2000, Use Desc : Domestic Water Supply
Cause
Attainment
Assmnt
User
Current
Water Name
Location Description
Name Source Name
Desc
Date
Flag
cycle
Holston
Holston River from confluence of Surgoinsville Creek to
Fully
18-
River
confluence of North Fork Holston. Ecoregion 67g Hawkins
Supporting
MAY-17
2017
County
ID305b (GIS Link) : TN06010104011 2000, Use Desc: Fish and Aquatic Life
Cause
Attainment
Assmnt
User
Current
Water Name
Location Description
Name Source Name
Desc
Date
Flag
cycle
Holston
Holston River from confluence of Surgoinsville Creek to
Fully
18-
River
confluence of North Fork Holston. Ecoregion 67g Hawkins
Supporting
MAY-17
2017
County
ID305b (GIS Link) : TN06010104011 2000, Use Desc : Industrial Water Supply
Cause
Attainment
Assmnt
User
Current
Water Name
Location Description
Name Source Name
Desc
Date
Flag
cycle
Holston
Holston River from confluence of Surgoinsville Creek to
Fully
18-
River
confluence of North Fork Holston. Ecoregion 67g Hawkins
-
Supporting
MAY-17
2017
County
ID305b (GIS Link) : TN06010104011 2000, Use Desc : Irrigation
Cause
Attainment
Assmnt
User
Current
Water Name
Location Description
Name Source Name
Desc
Date
Flag
cycle
Holston
Holston River from confluence of Surgoinsville Creek to
Fully
18-
River
confluence of North Fork Holston. Ecoregion 67g Hawkins
Supporting
MAY-17
2017
County
ID305b (GIS Link) : TN06010104011 2000, Use Desc: Livestock Watering and
Wildlife
Cause
Attainment
Assmnt
User
Current
Water Name
Location Description
Name Source Name
Desc
Date
Flag
cycle
Holston
Holston River from confluence of Surgoinsville Creek to
Fully
18-
River
confluence of North Fork Holston. Ecoregion 67g Hawkins
-
Supporting
MAY-17
2017
County
ID305b (GIS Link) : TN06010104011 2000, Use Desc : Recreation
Cause
Attainment
Assmnt
User
Current
Water Name
Location Description
Name Source Name
Desc
Date
Flag
cycle
Holston
Holston River from confluence of Surgoinsville Creek to
Sources outside State
Not
River
confluence of North Fork Holston. Ecoregion 67g Hawkins
Mercury
Jurisdiction or Borders
Supporting
MAY- 17
Partial
2017
County
Holston
Holston River from confluence of Surgoinsville Creek to
Atmospheric Deposition -
Not
River
confluence of North Fork Holston. Ecoregion 67g Hawkins
Mercury
Toxics
Supporting
MMA
MAY- 17
Partial
2017
County

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-13
X. ELECTRONIC REPORTING
Starting on December 21, 2016, all Individual NPDES Permit holders will be required to submit
Discharge Monitoring Reports (DMRs) electronically through NetDMR. Prior to 21 December
2016, the permittee may elect to electronically submit DMRs instead of mailing paper DMRs.
EPA published the National Pollutant Discharge Elimination System (NPDES) Electronic
Reporting Rule, which will modernize Clean Water Act reporting for municipalities, industries
and other facilities. The rule was published in the Federal Register on October 22, 2015 and
became effective on December 22, 2015. The rule replaces most paper -based NPDES
reporting requirements with electronic reporting.
More information is available at http://www.tn.gov/environment/topic/wr-netdmr-and-electronic-
reportinq:
• Getting Started on NetDMR,
• Electronic reporting schedule,
• Training Opportunities,
• NetDMR User Guide and other supporting information
XI. PERMIT DURATION
The proposed limitations meet the requirements of Section 301(b)(2)(A), (C), (D), (E),
and (F) of the Clean Water Act as amended. It is the intent of the division to organize the future
issuance and expiration of this particular permit such that other permits located in the same
watershed and group within the State of Tennessee will be set for issuance and expiration at the
same time. In order to meet the target reissuance date for the Holston watershed and following
the directives for the Watershed Management Program initiated in January, 1996, the permit will
be issued to expire in 2024.

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-14
APPENDIX 1
FACILITY DISCHARGES AND RECEIVING WATERS
FACILITY DISCHARGES AND RECEIVING WATERS
OUTFALL 001
LONGITUDE LATITUDE
8245-10 36-30-20
FLOW
DISCHARGE
SOURCE
(MGD)
0.231
Dyeing and Bleaching
0.040
Water Treatment
0.038
Steam Generation
0.005
Sanitary Wastewater
0.0015
1 Stormwater Runoff
0.316
TOTAL DISCHARGE
Treatment: Activated sludge
RECEIVING STREAM
DISCHARGE ROUTE
Holston Rifler at mile 129.5
STREAM LOW
FLOW CFS
7Q10 1010 30Q5
NA 908.3 1224.7
(MGD)
NA 587.2 791.8
STREAM USE CLASSIFICATIONS WATER QUALITY)
FISH
RECREATION
IRRIGATION
LW&W
DOMESTIC
x
x
x
x
x
INDUSTRIAL
NAVIGATION
x
FACILITY DISCHARGES AND RECEIVING WATERS
OUTFALL 002/SW2
LONGITUDE LATITUDE
82-45-24 36-30-50
FLOW
DISCHARGE
SOURCE
(MGD)
0.041
Emergency discharge only of recycled
non -contact cooling water
0.0100
Stormwater
0.057
TOTAL DISCHARGE
Treatment: None.
RECEIVING STREAM
DISCHARGE ROUTE
Seder Branch at mile 1.0
STREAM LOW 7Q10 1010 30Q5
FLOW CFS 0.0 NA NA
(MGD) 0.0 NA NA
STREAM USE CLASSIFICATIONS WATER QUALITY
FISH
RECREATION
IRRIGATION
LW&W
DOMESTIC
X
X
X
X
INDUSTRIAL
NAVIGATION
FACILITY DISCHARGES AND RECEIVING WATERS
OUTFALL SW3
LONGITUDE LATITUDE
8245-25 36-30-30
FLOW
DISCHARGE
SOURCE
(MGD)
Varies
Storm water runoff
0.0000
TOTAL DISCHARGE
RECEIVING STREAM
DISCHARGE ROUTE
Holston River at mile 129.5 (combines at outfall 001 before
discharge)
STREAM LOW 7Q10 1Q10 30Q5
FLOW CFS NA 908.3 1224.7
MGD NA 587.2 791.8
STREAM USE CLASSIFICATIONS WATER QUALITY)
FISH
RECREATION
IRRIGATION
LW&W
I DOMESTIC
X
X
X
X
X
INDUSTRIAL
NAVIGATION
X
Treatment: None

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-15
1Q10 and 30Q5 Critical Low Flow References
The low flow values at the point of discharge were calculated by:
1. determining the regulated flow coming from the Fort Patrick Henry Dam,
2. calculating the unregulated flow from the ensuing watershed and the North Fork Holston River,
3. and summing these regulated and unregulated 1Q10/30Q5 flow values.
The results are summarized in the following table:
Location
Drainage area
(Sq. mi.)
1Q10 (MGD)
30Q5
MGD
Fort Patrick Henry Dam (South Fork Holston)
19021
517.02
6763
USGS Station 3490000 (North Fork Holston)
6724
53.1
87.5
Holston River at RM 136.5 (excluding dam flows)
889a
70.2
115.8
Holston River at RM 136.5 (including dam flows)
2791
587.2
791.8
Regulated flows
Fort Patrick Henry Dam maintains an agreement with downstream industries to provide a minimum low
flow on the South Fork Holston River year round. The current low flow of 517 MGD was confirmed in an
email from TVA River Operations dated February 26, 2019, and is used as the South Fork Holston 1Q10
for permit calculations.
The 30Q5 was calculated using daily discharge data provided by TVA and analyzing it using USGS SW
Toolbox. Because the river operations of the dam changed in 2012, only flow data from January 2012 to
December 2018 was used, and this yielded a 30Q5 of 676 MGD. The data output from SW Toolbox is in
units of CFS (below).
Unregulated flows
After the dam on the South Fork Holston, the North Fork Holston makes the next largest contribution of
flow to the Holston at the point of discharge. Fortunately USGS Station 3490000 on the North Fork
Holston has produced 20,705 daily discharge measurements from 1931-2018. Based on this data, USGS
has published 1Q10 and 30Q5 statistics on the online StreamStats Data -Collection Station Report for
03490000.d These values were multiplied by the ratio between the remaining "post -dam" drainage area
and the drainage area at the gage station (889 mi2/672 miz), to account for the contribution of
unregulated flows to the flow at the point of discharge.
1 Delineated by USGS Streamstats online application: https://streamstats.usgs.gov/ss/
2 Minimum flow is by TVA and available in the permit record.
3 30Q5 from the dam calculated using USGS SW Toolbox to analyze TVA daily discharge data from 2012-2018
4 Provided by USGS Streamstats gauge page and Data -Collection Station Report:
https://nwis.waterdata.usas.aov/nwis/inventorv/?site no=03490000&aaencv cd=USGS
https://streamstatsags.cr.usqs.qov/qagepages/htm1/03490000.htm

Holliston Holdings, LLC (Rationale)
NPDES Permit TNOOO233O
Page R-16
Program SWStat U.S. GEOLOGICAL SURVEY Seq 00001
Ver. 5.0 Log -Pearson & Pearson Type III Statistics Run Date / Time
03/13/2013 based on USGS Program A193 3/13/2019 12:47 Phi
Notice -- Log -Pearson Type III or Pearson Type III distributions are used
for these computations. Users are responsible for assessment
and interpretation.
Description: N/A
Year Boundaries: January 1 - December 31
Period in report: January 1, 2013 - December 31, 2018
Parameter: 30-d2y low
Non -zero values: 7
Zero values: 0
Negative values: 6 (ignored)
Input time series (zero and negative values not included in listing.)
1482.800 2844.300 940.660 1287.700 951.290 1313.500 1508.800
LOG PEARSON TYPE III Frequency Curve Parameters
(based on logs of the non -zero values)
Mean (logs) 3.120
Variance (logs) 0.01A
Standard Deviation (logs) 0.118
Skewness (logs) 0.176
Standard Error of Skewness (logs) 0.794
Serial Correlation Coefficient (logs) -6.194
Coefficient of Variation (logs) 6.038
Frequency Curve - Parameter values at selected probabilities
Non- Variance 95-Pct Confidence
exceedance Recurrence Parameter of Intervals
Probability Interval Value Estimate Lower Upper
--------------------------------------------------------
0.2680 5.00 1046.100 1.023 751.590 1310.766

Total drainage area at the point of discharge:
StreamStats Report
Region ID: TN
Workspace ID: TN20190221201056139000
Clicked Point (Latitude, Longitude): 36,52323,-82-68116
Time: 2019-02-21 14:1111 -0600
Somerset
� _ P
Corbin
L -
Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-17
14
in9spV
lohns��.
P
4 Morristown
Knoxville
• Lenoir
Mt,�l4dletl Morganton Hicko
Basin Characteristics
Parameter
Code Parameter Description
❑RNAREA Area that drains to a point on a stream
Value Unit
2791-49 square miles
Law, G.S., Tasker, G.D., and Ladd, D.E.,2009, Streamflow-characteristic estimation methods for unregulated streams of Tennessee: U.S. Geological
Survey Scientific Investigations Report 20D9-5159, 212 p., 1 pl.

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-18
APPENDIX 2
APPLICABLE EFFLUENT LIMITATIONS GUIDELINES
Outfall 001
SIC GROUP 2295
40 CFR PART 410
Group Name : Textile Mills Point Source Category
410.32 Subpart C- Low Water Use Processing Subcategory
Production rate - 7, 60,000 lb/day
SUBPART 410.32
CALCULATED LIMITS
MONTHLY
DAILY
MONTHLY
DAILY
EFFLUENT
CHARACTERISTIC
AVG. AMNT.
MAX. AMNT.
AVG. AMNT.
MAX. AMNT.
(Ib/10001b)
(Ib/10001b)
(lb/day)
(lb/day)
BOD5
0.7
1.4
42
84
COD
1.4
2.8
84
168
TSS
0.7
1.4
42
84
pH
Within range 6.0 to 9.0
Within range 6.0 to 9.0
Outfall 001
SIC GROUP 2295
40 CFR PART 410
Group Name : Textile Mills Point Source Category
410.42 Subpart D- Woven Fabric Finishing Subcategory
Production rate - 7, 60,000 lb/day
SUBPART 410.42
CALCULATED LIMITS
MONTHLY
DAILY
MONTHLY
DAILY
EFFLUENT
CHARACTERISTIC
AVG. AMNT.
MAX. AMNT.
AVG. AMNT.
MAX. AMNT.
(Ib/10001b)
(Ib/10001b)
(lb/day)
(lb/day)
BOD5
3.3
6.6
198
396
COD
30
60
1800
3600
TSS
8.9
17.8
534
1068
Sulfide
0.1
0.2
6
12
Phenol
0.05
0.1
3
6
Chromium (Total)
0.05
0.1
3
6
pH
Within range 6.0 to 9.0
Within Range 6.0-9.0

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-19
APPENDIX 3
PREVIOUS PERMIT LIMITS AND MONITORING REQUIREMENTS
Description : External Outfall, Number : 001, Monitoring : Effluent Gross, Season : All Year
Parameter
Qualifier
Value
Unit
Sample Tvpe
Frequency
Statistical Base
Acetaldehyde
Report
-
Ib/d
Composite
Monthly
Daily Maximum
Acetaldehyde
Report
-
Ib/d
Composite
Monthly
Monthly Average
BOD, 5-day, 20 C
<=
480
Ib/d
Composite
Three Per
Week
Daily Maximum
BOD, 5-day, 20 C
<=
240
Ib/d
Composite
Three Per
Week
Monthly Average
Chlorine, total residual
<=
2
mg/L
Grab
Three Per
Daily Maximum
(TRC) (2) (3)
Week
Chromium, total (as Cr)
<=
3
Ib/d
Composite
Monthly
Monthly Average
Chromium, total (as Cr)
<=
6
Ib/d
Composite
Monthly
Daily Maximum
Copper, total (as Cu)
<=
1
mg/L
Composite
Twice Per
Month
Daily Maximum
E. coli
<=
126
#/100ml-
Grab
Weekly
Geometric Mean
E. coli
<=
941
#/100mL
Grab
Weekly
Daily Maximum
Flow (1)
Report
-
Mgal/d
Recorder
Three Per
Week
Daily Maximum
Flow (1)
Report
-
Mgal/d
Recorder
Three Per
Week
Monthly Average
Formaldehyde
Report
-
Ib/d
Composite
Monthly
Daily Maximum
Formaldehyde
Report
-
Ib/d
Composite
Monthly
Monthly Average
Lead, total (as Pb)
<=
.1
mg/L
Composite
Twice Per
Month
Daily Maximum
Nickel, total (as Ni)
<=
3
mg/L
Composite
Twice Per
Month
Daily Maximum
Oxygen demand, chem.
<=
3768
Ib/d
Composite
Three Per
Daily Maximum
(high level) (COD)
Week
Oxygen demand, chem.
<=
1884
Ib/d
Composite
Three Per
Monthly Average
(high level) (COD)
Week
Sulfide, total (as S)
<=
12
Ib/d
Composite
Monthly
Daily Maximum
Sulfide, total (as S)
<=
6
Ib/d
Composite
Monthly
Monthly Average
Total Suspended Solids
<=
574
Ib/d
Composite
Three Per
Monthly Average
(TSS)
Week
Total Suspended Solids
<=
1152
Ib/d
Composite
Three Per
Daily Maximum
(TSS)
Week
Vinyl acetate
Report
-
Ib/d
Composite
Monthly
Monthly Average
Vinyl acetate
Report
-
Ib/d
Composite
Monthly
Daily Maximum
Zinc, total (as Zn)
<=
2
mg/L
Composite
Twice Per
Month
Daily Maximum

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-20
pH (3) >= 6 Su Grab Three Per Minimum
Week
pH (3) <= 9 Su Grab Three Per Maximum
Week
Description : External Outfall, Number : 001, Monitoring : Effluent Gross, Season : All Year
Parameter Qualifier Value Unit Sample Type Frequency Statistical Base
Phenols <= 3 Ib/d Grab Annual Monthly Average
Phenols <= 6 Ib/d Grab Annual Daily Maximum
1. Flow shall be reported in Million Gallons per Day (MGD).
2. The current detection level for Total Residual Chlorine is 0.05 mg/L. The acceptable
methods for detection are specified in 40 CFR Part 136.
3. pH and TRC analyses shall be performed within fifteen (15) minutes of sample collection.
Description : External Outfall, Number : 002, Monitoring : Effluent Gross, Season : All Year
Parameter
Qualifier
Value
Unit
Sample Type
Frequency(3)
Statistical Base
Copper, total (as Cu)
<_
.03
mg/L
Grab
Once Per
Discharge
Monthly Average
Copper, total (as Cu)
<_
.05
mg/L
Grab
Once Per
Discharge
Daily Maximum
Flow (1)
Report
-
Mgal/d
Instantaneous
Once Per
Discharge
Monthly Average
Flow (1)
Report
-
Mgal/d
Instantaneous
Once Per
Discharge
Daily Maximum
IC25 Static Renewal 7
Day Chronic
>=
100
%
Composite
Semiannual
Minimum
Ceriodaphnia (4)
IC25 Static Renewal 7
Day Chronic Pimephales
>=
100
%
Composite
Semiannual
Minimum
(4)
Nickel, total (as Ni)
<=
1.23
mg/L
Grab
Once Per
Discharge
Daily Maximum
Nickel, total (as Ni)
<_
.14
mg/L
Grab
Once Per
Discharge
Monthly Average
Nitrogen, Ammonia total
<_
4.44
mg/L
Grab
Once Per
Daily Maximum
(as N)
Discharge
Nitrogen, Ammonia total
<_
2.22
mg/L
Grab
Once Per
Monthly Average
(as N)
Discharge
Temperature, water deg.
Report
-
deg C
Grab
Once Per
Daily Maximum
C
Discharge
Zinc, total (as Zn)
<_
.47
mg/L
Grab
Once Per
Discharge
Daily Maximum
Zinc, total (as Zn)
<_
.47
mg/L
Grab
Once Per
Discharge
Monthly Average

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-21
pH (2) >= 6 Su Grab Once Per Minimum
Discharge
pH (2) <= 9 Su Grab Once Per Maximum
Discharge
NOTE: THIS OUTFALL IS ONLY IN SERVICE IN THE EVENT OF A FAILURE OF THE
RECYCLED COOLING WATER SYSTEM. For that reason report "NO DISCHARGE" for
months of no discharge.
1. Flow shall be reported in Million Gallons per Day (MGD).
2. pH analyses shall be performed within fifteen (15) minutes of sample collection.
3. Once Per Month or once per discharge, whichever is less frequent
4. See Part III for methodology.
Description : External Outfall, Number : SW2 and SW3, Monitoring : Effluent Gross, Season : All Year
Parameter
Qualifier Value
Unit
Sample Type
Frequency
Statistical Base
Flow
Report -
Mgal/d
Estimate
Semiannual
Daily Maximum
Flow
Report -
Mgal/d
Estimate
Semiannual
Monthly Average
Oil & Grease
Report -
mg/L
Grab
Semiannual
Daily Maximum
Total Suspended Solids
Report -
mg/L
Grab
Semiannual
Daily Maximum
(TSS)
pH
Report -
Su
Grab
Semiannual
Maximum
pH
Report -
Su
Grab
Semiannual
Minimum
1. Flow shall be reported in Million Gallons per Day (MGD).
2. pH analyses shall be performed within fifteen (15) minutes of sample collection. The
permittee shall provide the date and duration (in hours) of the qualifying storm event(s)
sampled; rainfall measurements or estimates (in inches) of the storm event that generated
the sampled runoff; the duration between the storm event sampled and the end of the
previous measurable (greater than 0.1 inch rainfall) storm event; and an estimate of the total
volume of the discharge sampled. Flow shall be reported in Million Gallons per Day (MGD).
Provide information as an attachment to the discharge monitoring report.

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-22
APPENDIX 4
HISTORICAL MONITORING AND INSPECTION RESULTS
Tota I
Outfall 001
Residual
Flow
pH
BOD5
TSS
Chlorine
COD
Ecoli
Sulfide
Monthly
Average
Daily
Max.
Daily
Min.
Daily
Max.
Monthly
Average
Daily
Max.
Monthly
Average
Daily Max.
Daily Max.
Monthly
Average
Daily Max.
Monthly
Daily Max.
Monthly
Average
Daily
Max.
Date
Amount
Amount
Cone.
Cone.
Amount
Amount
Amount
Amount
Cone.
Amount
Amount
Average Cone.
Cone.
Amount
Amount
MGD
MGD
SU
SU
lb/clay
lb/day 1
lb/day
lb/day
mg/L
lb/day
lb/day
#/100ml-
#1100mL
lb/day
lb/day
01/31/2015
0.109
0.265
6.7
7.0
32
68
177
327
1.9
663
1361
10
10
1.03
1.03
02/28/2015
0.124
0.238
6.7
6.9
39
56
251
493
1.9
634
928
24
45
1.78
1.78
03/31/2015
0.113
0.215
6.5
7.0
29
54
145
285
1.9
578
832
27
70
1.72
1.72
04/30/2015
0.113
0.227
6.6
6.8
40
55
245
466
1.9
645
977
26
60
1.48
1.48
05/31/2015
0.078
0.164
6.7
6.9
14
39
178
325
1.9
386
6.2
15
55
0.53
0.53
06/30/2015
0.100
0.203
6.6
7.0
28
48
159
283
1.9
403
615
11
20
1.48
1.48
07/31/2015
0.091
0.227
6.5
7.0
28
82
161
371
2.0
450
870
14
40
1.89
1.89
08/31/2015
0.111
0.262
6.5
7.0
19
70
149
551
1.9
437
1606
16
60
1.03
1.03
09/30/2015
0.087
0.145
6.7
6.9
12
35
120
363
2.0
317
925
21
60
1.16
1.16
10/31/2015
0.138
0.217
6.7
7.2
60
90
220
355
2.0
970
1302
11
15
0.98
0.98
11/30/2015
0.107
0.258
6.7
7.1
40
93
156
402
1.9
673
1372
37
70
1.68
1.68
12/31/2015
0.103
0.262
6.4
7.1
72
76
127
454
1.9
710
1200
21
35
2.19
2.19
01/31/2016
0.109
0.273
6.9
7.1
41
100
223
410
1.9
829
1623
19
70
0.98
0.98
02/29/2016
0.140
0.264
6.6
7.1
54
97
246
572
1.9
933
1382
28
55
2.20
2.20
03/31/2016
0.093
0.178
6.8
7.0
27
40
173
408
1.9
520
770
20
85
1.11
1.11
04/30/2016
0.104
0.207
6.7
7.0
24
52
180
285
1.9
549
963
15
30
1.62
1.62
05/31/2016
0.079
0.194
6.7
7.1
39
78
239
682
1.9
680
1427
14
30
0.83
0.83
06/30/2016
0.092
0.188
6.4
7.0
37
78
164
303
1.9
672
1212
19
60
0.85
0.85
07/31/2016
0.083
0.206
6.8
7.0
36
58
222
412
1.9
663
995
29
50
0.86
0.86
08/31/2016
0.100
0.184
6.8
6.9
26
55
151
254
1.9
319
670
16
30
1.50
1.50
09/30/2016
0.085
0.167
6.4
7.0
31
61
126
259
1.9
440
952
20
50
1.03
1.03
10/31/2016
0.084
0.191
6.8
7.1
37
70
175
363
1.9
596
1051
26
70
1.42
1.42
11/30/2016
0.084
0.215
6.7
7.0
31
77
348
932
1.9
683
1217
33
90
1.14
1.14
12/31/2016
0.098
0.216
6.9
7.3
39
70
260
948
1.9
722
1206
43
90
1.51
1.51
01/31/2017
0.106
0.168
6.9
7.2
42
71
211
364
1.9
595
1077
29
60
1.04
1.04
02/28/2017
0.093
0.201
6.7
7.2
44
71
265
667
1.9
732
1134
31
40
1.54
1.54
03/31/2017
0.102
0.241
6.7
7.1
46
76
229
440
2.0
753
1242
36
50
0.95
0.95
04/30/2017
0.089
0.204
6.7
7.2
39
80
321
803
1.9
765
1102
14
30
1.11
1.11
05/31/2017
0.086
0.144
6.6
7.1
44
133
272
468
1.9
749
1013
24
60
0.79
0.79
06/30/2017
0.093
0.174
6.7
7.0
43
64
310
524
1.9
793
1139
38
64
0.99
0.99
07/31/2017
0.074
0.153
6.6
7.1
29
55
139
310
2.0
479
935
33
60
1.14
1.14
08/31/2017
0.107
0.155
6.4
7.0
47
64
311
463
1.9
738
976
25
40
1.16
1.16
09/30/2017
0.083
0.230
6.7
7.4
34
55
219
476
1.9
684
1251
14
20
1.92
1.92
10/31/2017
0.093
0.202
6.1
7.2
29
63
297
512
1.9
756
1318
25
60
0.60
0.60
11/30/2017
0.081
0.180
6.8
7.8
36
51
350
601
1.9
755
1192
30
50
1.11
1.11
12/31/2017
0.067
0.166
6.7
7.1
35
63
278
433
1.9
760
1153
19
80
1.15
1.15
01/31/2018
0.088
0.173
6.3
7.4
37
61
264
497
1.9
705
925
24
80
0.92
0.92
02/28/2018
0.113
0.197
6.8
7.3
44
68
240
338
1.9
799
1027
24
40
1.24
1.24
03/31/2018
0.108
0.203
6.8
7.3
44
85
244
537
1.9
696
1211
29
40
1.10
1.10
04/30/2018
0.075
0.186
6.7
7.4
39
68
249
393
1.9
581
713
30
75
1.55
1.55
05/31/2018
0.078
0.188
6.8
7.0
33
75
245
563
1.9
555
1249
27
70
1.40
1.40
06/30/2018
0.075
0.233
6.5
7.2
34
111
255
684
1.9
559
1326
24
80
1.20
1.20
07/31/2018
0.057
0.126
6.3
7.1
19
40
175
363
1.9
375
750
33
70
0.68
0.68
08/31/2018
0.085
0.152
6.4
7.4
33
55
374
538
1.9
683
1022
26
60
1.09
1.09
09/30/2018
0.118
0.211
6.4
7.1
72
118
343
607
1.9
915
1461
27
45
1.33
1.33
10/31/2018
0.106
0.167
6.2
7.0
23
50
301
495
1.9
772
1001
16
40
0.70
0.70
11/30/2018
0.125
0.216
6.8
7.1
21
61
266
599
1.9
805
1526
19
40
1.23
1.23
12/31/2018
0.121
0.194
6.7
7.1
44
78
304
478
1.9
699
997
16
30
1.12
1.12
01/31/2019
0.118
0.186
6.7
7.0
30
78
290
544
1.9
672
1132
10
10
0.96
0.96
02/28/2019
0.160
0.319
6.9
7.1
42
73
287
536
1.9
700
1304
12
20
1.27
1.27
03/31/2019
0.119
0.182
6.7
7.0
41
63
244
413
1.9
725
1150
10
10
1.52
1.52
04/30/2019
0.106
0.154
6.4
7.1
42
57
315
536
1.9
685
960
13
20
0.95
0.95
05/31/2019
0.113
0.176
6.6
7.3
40
64
350
593
1.9
718
992
17
40
1.28
1.28
06/30/2019
0.116
0.192
6.6
7.1
38
70
218
416
1.9
534
831
13
25
0.94
0.94
07/31/2019
0.110
0.234
6.5
7.1
29
72
241
527
2.0
479
845
15
20
1.59
1.59
08/31/2019
0.114
0.248
6.4
7.0
22
52
254
447
1.9
615
883
12
20
1.23
1.23
09/30/2019
0.059
0.143
6.4
7.1
13
27
52
145
1.9
100
217
19
85
0.36
0.36
10/31/2019
0.091
0.199
6.8
7.2
12
28
51
81
1.9
158
304
16
30
1.05
1.05
Standard Dev.
0.020 0.038
0.2 0.2
12 20
73 161
0.0
173 306
8 22
0.38 0.38
Minimum
0.057 0.126
6.1 6.8
12 27
51 81
1.9
100 6.2
10 10
0.36 0.36
Maximum
0.160 0.319
6.9 7.8
72 133
374 948
2.0
970 1623
43 90
2.20 2.20
Average
0.099 0.201
6.6 7.1
35 67
230 464
1.9
630 1048.6241
22 49
1.21 1.21
Permit Limit
Report Report
6.0 9.0
240 480
574 1152
2.0
1884 3768
200/100 ml 1000/100 ml
6.0 12.0
Count
58 58
58 58
58 58
58 58
58
58 58
58 58
58 58

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-23
Outfa 11001
Chromium
Copper
Lead
Nickel
Zinc
Total Phenol
Formaldehyde
Vinyl Acetate
Acetaldehyde
Monthly
Average
Daily
Max.
Daily Max.
Daily Max.
Daily Max.
Daily Max.
Monthly
Average
Daily
Max.
Monthly
Average
Daily
Max.
Monthly
Average
Daily
Max.
Monthly
Average
Daily
Max.
Amount
Amount
Conc.
Conc.
Conc.
Conc.
Amount
Amount
Amount
Amount
Amount
Amount
Amount
Amount
Date
lb/day
lb/day
mg/L
mg/L
mg/L
mg/L
lb/day
lb/day
lb/day
lb/day
lb/day
lb/day
lb/day
lb/day
01/31/2015
0.01
0.01
0.04
0.01
0.01
0.02
0.52
0.52
0.01
0.01
0.52
0.52
02/28/2015
0.01
0.1
0.01
0.01
0.01
0.01
0.45
0.45
0.02
0.02
0.45
0.45
03/31/2015
0.02
0.02
0.06
0.01
0.06
0.03
0.86
0.86
0.02
0.02
0.86
0.86
04/30/2015
0.02
0.02
0.02
0.01
0.01
0.01
0.74
0.74
0.01
0.01
0.74
0.74
05/31/2015
0.01
0.01
0.02
BDL
BDL
BDL
0.05
0.05
0.01
0.01
0.05
0.05
06/30/2015
0.01
0.01
0.03
BDL
BDL
0.01
2.85
2.85
0.01
0.01
0.24
0.24
07/31/2015
0.01
0.01
0.07
BDL
BDL
BDL
0.95
0.95
0.02
0.02
0.95
0.95
08/31/2015
0.01
0.01
0.03
BDL
0.02
BDL
1.03
1.03
0.01
0.01
1.03
1.03
09/30/2015
0.01
0.01
0.03
BDL
BDL
0.03
0.35
0.35
0.01
0.01
0.35
0.35
10/31/2015
0.02
0.02
0.13
BDL
BDL
BDL
1.37
1.37
0.01
0.01
0.98
0.98
11/30/2015
0.02
0.02
BDL
BDL
BDL
BDL
1.68
1.68
0.02
0.02
1.68
1.68
12/31/2015
0.02
0.02
0.05
BDL
BDL
BDL
0.03
0.03
0.22
0.22
0.02
0.02
0.22
0.22
01/31/2016
0.01
0.01
0.06
0.02
BDL
BDL
0.98
0.98
0.01
0.01
0.98
0.98
02/29/2016
0.02
0.02
0.07
BDL
BDL
0.05
2.20
2.20
0.02
0.02
2.20
2.20
03/31/2016
0.01
0.01
0.09
0.01
0.02
0.17
1.11
1.11
0.01
0.01
1.11
1.11
04/30/2016
0.01
0.01
0.05
BDL
BDL
0.06
1.62
1.62
0.02
0.02
1.62
1.00
05/31/2016
0.01
0.01
0.08
0.01
0.01
0.02
0.41
0.41
0.01
0.01
0.41
0.41
O6/30/2016
0.01
0.01
0.01
0.01
0.01
0.01
0.85
0.85
0.01
0.01
0.85
0.85
07/31/2016
0.01
0.01
0.07
0.01
0.01
0.04
0.73
0.73
0.01
0.01
0.73
0.73
08/31/2016
0.01
0.01
0.06
0.01
0.01
0.05
1.50
1.50
0.02
0.02
1.50
1.50
09/30/2016
0.01
0.01
0.06
0.01
0.01
0.03
0.10
0.10
0.01
0.01
0.10
0.10
10/31/2016
0.01
0.01
0.01
0.01
0.01
0.01
1.42
1.42
0.01
0.01
1.42
1.42
11/30/2016
0.01
0.01
0.13
0.01
0.07
0.02
1.14
1.14
0.01
0.01
1.14
1.14
12/31/2016
0.01
0.01
0.17
0.01
0.01
0.06
0.11
0.11
1.51
1.50
0.02
0.02
1.51
1.51
01/31/2017
0.01
0.01
0.05
0.01
0.01
0.03
1.04
1.04
0.01
0.01
1.04
1.04
02/28/2017
0.02
0.02
0.16
0.01
0.26
0.01
0.68
0.68
0.02
0.02
0.68
0.68
03/31/2017
0.01
0.01
0.03
0.01
0.01
0.01
0.95
0.95
0.01
0.01
0.95
0.95
04/30/2017
0.03
0.03
0.08
0.02
0.02
0.02
1.11
1.11
0.01
0.01
0.11
0.11
05/31/2017
0.01
0.01
0.02
0.01
0.01
0.01
0.79
0.79
0.01
0.01
0.79
0.79
O6/30/2017
0.01
0.01
0.02
0.01
0.01
0.01
0.99
0.99
0.01
0.01
0.99
0.99
07/31/2017
0.01
0.01
0.03
0.01
0.01
0.01
1.14
1.14
0.01
0.01
1.14
1.14
08/31/2017
0.01
0.01
0.07
0.01
0.01
0.05
1.16
1.16
0.01
0.01
1.16
1.16
09/30/2017
0.01
0.01
0.05
0.01
0.01
0.02
1.92
1.92
0.02
0.02
1.92
1.92
10/31/2017
0.01
0.01
0.09
0.01
0.01
0.17
0.60
0.60
0.01
0.01
0.60
0.60
11/30/2017
0.02
0.02
0.18
0.01
0.01
0.01
1.11
1.11
0.01
0.01
1.11
1.11
12/31/2017
0.04
0.04
0.17
0.01
0.01
0.02
0.39
0.39
1.15
1.15
0.01
0.01
1.15
1.15
01/31/2018
0.01
0.01
0.08
0.01
0.01
0.01
0.92
0.92
0.01
0.01
0.92
0.92
02/28/2018
0.01
0.01
0.12
0.01
0.01
0.01
1.24
1.24
0.01
0.01
1.24
1.24
03/31/2018
0.01
0.01
0.03
0.01
0.01
0.01
1.10
1.10
0.01
0.01
1.10
1.10
04/30/2018
0.01
0.01
0.01
0.01
0.01
0.01
1.55
1.55
0.02
0.02
1.55
1.55
05/31/2018
0.01
0.01
0.04
0.01
0.01
0.03
0.14
0.14
0.01
0.01
0.14
0.14
O6/30/2018
0.01
0.01
0.07
0.01
0.01
0.03
1.20
1.20
0.01
0.01
1.20
1.20
07/31/2018
0.01
0.01
0.02
0.01
0.01
0.03
0.68
0.68
0.01
0.01
0.68
0.68
08/31/2018
0.01
0.01
0.13
0.01
0.01
0.11
1.09
1.09
0.01
0.01
1.09
1.09
09/30/2018
0.01
0.01
0.06
0.01
0.04
0.02
1.33
1.33
0.01
0.01
1.33
1.33
10/31/2018
0.01
0.01
0.12
0.01
0.01
0.05
0.70
0.70
0.01
0.01
0.70
0.70
11/30/2018
0.16
0.16
0.17
0.1
0.1
0.1
1.23
1.23
0.01
0.01
1.23
1.23
12/31/2018
0.01
0.01
0.18
0.01
0.01
0.03
0.16
0.16
1.12
1.12
0.01
0.01
1.12
1.12
01/31/2019
0.01
0.01
0.01
0.01
0.01
0.02
0.96
0.96
0.01
0.01
0.96
0.96
02/28/2019
0.01
0.01
0.1
0.01
0.01
0.05
1.27
1.27
0.01
0.01
1.27
1.27
03/31/2019
0.01
0.01
0.18
0.01
0.01
0.05
1.52
1.52
0.02
0.02
1.52
1.52
04/30/2019
0.01
0.01
0.11
0.01
0.01
0.05
0.95
0.95
0.01
0.01
0.95
0.95
05/31/2019
0.01
0.01
0.23
0.01
0.01
0.09
1.28
1.28
0.01
0.01
1.28
1.28
O6/30/2019
0.01
0.01
0.12
0.01
0.06
0.02
1.88
1.88
0.00
0.00
1.88
1.88
07/31/2019
0.01
0.01
0.04
0.01
0.01
0.04
1.59
1.59
0.02
0.02
1.59
1.59
08/31/2019
0.01
0.01
0.03
0.01
0.01
0.02
1.23
1.23
0.01
0.01
1.23
1.23
09/30/2019
0.004
0.004
0.01
0.03
0.01
0.03
0.36
0.36
0.00
0.00
0.36
0.36
10/31/2019
0.01
0.01
0.01
0.01
0.01
0.02
1.05
1.05
0.01
0.01
1.05
1.05
Standard Dev.
0.020 0.023
0.06
0.013
0.040
0.036
0.15 0.15
0.51 0.51
0.00 0.00
0.48 0.47
Minimum
0.004 0.004
0.01
0.010
0.010
0.010
0.03 0.03
0.05 0.05
0.00 0.00
0.05 0.05
Maximum
0.160 0.160
0.23
0.100
0.260
0.170
0.39 0.39
2.85 2.85
0.02 0.02
2.20 2.20
Average
0.015 0.016
0.07
0.013
0.022
0.036
0.17 0.17
1.06 1.06
0.01 0.01
0.99 0.98
Permit Limit
3.0 6.0
1.0
0.1
3.0
2.0
3.0 6.0
Report Report
Report Report
Report Report
Count
58 58
58
58
58
58
4 4
58 58
58 58
58 58

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-24
Outfall SW2
Flow
pH
O&G
TSS
Daily
Daily
Max.
Max.
Daily Max.
Daily Max.
Date
Amount
Conc.
Conc.
Conc.
MGD
SU
mg/L
mg/L
06/30/2015
0.082
6.8
5
2
12/31 /2015
0.093
6.7
B DL
7
06/30/2016
0.011
7.0
5
6
12/31 /2016
0.090
7.0
5
1
06/30/2017
0.033
7.1
5
3
12/31 /2017
0.052
6.8
5
3
06/30/2018
0.023
7.4
5
2
12/31 /2018
0.075
7.3
5
3
06/30/2019
0.039
7.2
5
4
Standard Dev.
0.031
0.2
0
2
Minimum
0.011
6.7
5
1
Maximum
0.093
7.4
5
7
Average
0.055
7.0
5
3
Permit Limit
Report
Report
Report
Report
Count
9
9
9
9
Outfall SW3
Flow
pH
O&G
TSS
Daily
Daily
Max.
Max.
Daily Max.
Daily Max.
Date
Amount
Conc.
Conc.
Conc.
MGD
SU
mg/L
mg/L
06/30/2015
0.041
6.7
5.0
4
12/31 /2015
0.048
7.0
12.7
77
06/30/2016
0.008
6.8
5.0
5
12/31 /2016
0.014
7.6
6.7
36
06/30/2017
0.015
6.9
5.0
9
12/31 /2017
0.006
7.0
6.2
47
06/30/2018
0.01
7.3
5.0
3
12/31 /2018
0.008
7.4
5.0
17
06/30/2019
0.008
7.5
6.2
5
Standard Dev.
0.016
0.3
2.5
26
Minimum
0.006
6.7
5.0
3
Maximum
0.048
7.6
12.7
77
Average
0.018
7.1
6.3
23
Permit Limit
Report
Report
Report
Report
Count
9
9
9
9

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-25
Compliance Inspection Results
Description of Issue
Current Status
1
Sample collection times/locations not recorded
Issue Resolved
2
COD original analytical records not maintained
Issue Resolved
3
Storm water monitoring not meeting
sampling criteria
Issue Resolved
4
Failure to maintain lagoons for proper treatment
In progress
5
No chlorine scales
Issue Resolved
6
Buildup of solids in wastewater treatment units affects treatment
Issue Resolved
7
Hole in aerator line to wastewater treatment units affects treatment
In progress
8
Visible color, turbidity, and foam in Outfall 001 discharge and
Holston River, Mile 129.5
In progress
9
No annual effluent flow meter calibration record
Issue Resolved
10
Lab quality control/quality assurance deficiencies
Issue Resolved
11
Storm water pollution prevention Ian/outfall areas stabilization
Issue Resolved
12
Latex unloading area containment improvements
Project
Completed
13
Storm drain identification improvements
Project
Completed

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-26
APPENDIX 5
NEW PERMIT LIMITS AND MONITORING REQUIREMENTS
Description : External Outfall, Number: 001, Monitoring: Effluent Gross, Season : All Year, Limit Set Status: Active
Monitoring
Code
Parameter
Qualifier
Value
Unit
Sample Type
Frequency
Statistical Base
00310
BOD, 5-day, 20 C
<=
480
Ib/d
Composite
Three Per
Daily
Week
Maximum
00310
BOD, 5-day, 20 C
<=
240
Ib/d
Composite
Three Per
Monthly
Week
Average
00340
Oxygen demand, chem. (high
<_
3768
Ib/d
Composite
Three Per
Daily
level) (COD)
Week
Maximum
00340
Oxygen demand, chem. (high
<_
1884
Ib/d
Composite
Three Per
Monthly
level) (COD)
Week
Average
00400
pH
>=
6.0
Su
Grab
Three Per
Minimum
Week
00400
pH
<=
9.0
Su
Grab
Three Per
Week
Maximum
00530
Total Suspended Solids (TSS)
<=
1152
Ib/d
Composite
Three Per
Daily
Week
Maximum
00530
Total Suspended Solids (TSS)
<=
574
Ib/d
Composite
Three Per
Week
Monthly
Average
00556
Oil & Grease
Report
-
mg/L
Composite
Quarterly
Daily
Maximum
00745
Sulfide, total (as S)
<=
12
Ib/d
Composite
Monthly
Daily
Maximum
00745
Sulfide, total (as S)
<=
6
Ib/d
Composite
Monthly
Monthly
Average
01034
Chromium, total (as Cr)
<=
6
Ib/d
Composite
Monthly
Daily
Maximum
01034
Chromium, total (as Cr)
<=
3
Ib/d
Composite
Monthly
Monthly
Average
01042
Copper, total (as Cu)
<=
1
mg/L
Composite
Twice Per
Daily
Month
Maximum
01051
Lead, total (as Pb)
<_
.1
mg/L
Composite
Twice Per
Daily
Month
Maximum
01067
Nickel, total (as Ni)
<=
3
mg/L
Composite
Twice Per
Daily
Month
Maximum
01092
Zinc, total (as Zn)
<=
2
mg/L
Composite
Twice Per
Month
Daily
Maximum
50050
Flow
Report
-
Mgal/d
Recorder
Three Per
Daily
Week
Maximum
50050
Flow
Report
-
Mgal/d
Recorder
Three Per
Monthly
Week
Average
50060
Chlorine, total residual (TRC)
<=
2
mg/L
Grab
Three Per
Daily
Week
Maximum
51040
E. coli
<=
941
MPN/100mL
Grab
Weekly
Daily

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-27
Maximum
51040
E. coli
<= 126 MPN/100ml- Grab
Weekly
Geometric
Mean
71880
Formaldehyde
Report - Ib/d Composite
Monthly
Daily
Maximum
71880
Formaldehyde
Report Ib/d Composite
Monthly
Monthly
Average
77001
Acetaldehyde
Report Ib/d Composite
Monthly
Daily
Maximum
77001
Acetaldehyde
Report Ib/d Composite
Monthly
Monthly
Average
77057
Vinyl acetate
Report Ib/d Composite
Monthly
Daily
Maximum
77057
Vinyl acetate
Report Ib/d Composite
Monthly
Monthly
Average
Description : External Outfall, Number: 001, Monitoring: Effluent Gross, Season : All Year, Limit Set
Status: Active
Monitoring
Code
Parameter Qualifier
Value Unit Sample Type Frequency Statistical Base
46000
Phenols <=
3 Ib/d Grab Annual
Monthly
Average
46000
Phenols <=
6 Ib/d Grab Annual
Daily Maximum
4. Flow shall be reported in Million
Gallons per Day (MGD).
5. The
current detection level
for Total Residual Chlorine is 0.05 mg/L.
The acceptable
methods for detection are specified
in 40 CFR Part 136.
6. pH and TRC analyses shall be performed within fifteen (15) minutes
of sample collection.
Description
: External Outfall, Number: 002, Monitoring : Effluent Gross, Season : All Year, Limit Set
Status : Active
Monitoring
Statistical
Code
Parameter
Qualifier Value Unit Sample Type
Frequency
Base
00010
Temperature, water deg. C
Report - deg C Grab
Once Per
Discharge
Daily
Maximum
00400
pH
>= 6.0 su Grab
Once Per
Discharge
Minimum
00400
pH
<= 9.0 su Grab
Once Per
Discharge
Maximum
01042
Copper, total (as Cu)
<= .047 mg/L Grab
Once Per
Discharge
Monthly
Average
01042
Copper, total (as Cu)
<= .072 mg/L Grab
Once Per
Discharge
Daily
Maximum
01067
Nickel, total (as Ni)
<= .291 mg/L Grab
Once Per
Discharge
Monthly
Average
01067
Nickel, total (as Ni)
<= 2.612 mg/L Grab
Once Per
Discharge
Daily
Maximum
01092
Zinc, total (as Zn)
<= 1.078 mg/L Grab
Once Per
Daily
Discharge
Maximum
01092
Zinc, total (as Zn)
<= 1.087 mg/L Grab
Once Per
Discharge
Monthly
Average
50050
Flow
Report - Mgal/d Instantaneous
Once Per
Discharge
Daily
Maximum

Holliston Holdings, LLC (Rationale)
NPDES Permit TN0002330
Page R-28
50050
Flow
Report
-
Mgal/d
Instantaneous
Once Per
Discharge
Monthly
Average
TRP313
IC25 Static Renewal 7 Day
>=
100
%
Composite
Semiannual
Minimum
Chronic Ceriodaphnia
TRP6C
IC25 Static Renewal 7 Day
>=
100
%
Composite
Semiannual
Minimum
Chronic Pimephales promelas
Description
: External Outfall, Number:
002, Monitoring: Effluent Gross, Season : Summer, Limit Set
Status : Active
Monitoring
Statistical
Code
Parameter
Qualifier
Value
Unit
Sample Type
Frequency
Base
00610
Nitrogen, Ammonia total (as N)
<=
1.4
mg/L
Grab
Once Per
Monthly
Discharge
Average
00610
Nitrogen, Ammonia total (as N)
<=
2.8
mg/L
Grab
Once Per
Discharge
Daily
Maximum
Description : External Outfall, Number:
002, Monitoring: Effluent Gross, Season : Winter, Limit Set Status : Active
Monitoring
Statistical
Code
Parameter
Qualifier
Value
Unit
Sample Type
Frequency
Base
00610
Nitrogen, Ammonia total (as N)
<=
5.2
mg/L
Grab
Once Per
Daily
Discharge
Maximum
00610
Nitrogen, Ammonia total (as N)
<=
2.6
mg/L
Grab
Once Per
Discharge
Monthly
Average
NOTE: THIS OUTFALL IS ONLY IN SERVICE IN THE EVENT OF A FAILURE OF THE
RECYCLED COOLING WATER SYSTEM. For that reason report "NO DISCHARGE" for
months of no discharge.
5. Flow shall be reported in Million Gallons per Day (MGD).
6. pH analyses shall be performed within fifteen (15) minutes of sample collection.
7. Once Per Month or once per discharge, whichever is less frequent
8. See Part III for methodology.
Description : External Outfall, Number: SW2, Monitoring : Effluent Gross, Season : All Year, Limit Set Status : Active
Monitoring
Code
Parameter
Qualifier Value
Unit
Sample Type
Frequency
Statistical Base
00400
pH
Report
SU
Grab
Semiannual
Maximum
00400
pH
Report
SU
Grab
Semiannual
Minimum
00530
Total Suspended Solids (TSS)
Report
mg/L
Grab
Semiannual
Daily Maximum
00556
Oil & Grease
Report
mg/L
Grab
Semiannual
Daily Maximum
50050
Flow
Report
Mgal/d
Estimate
Semiannual
Daily Maximum
50050
Flow
Report
Mgal/d
Estimate
Semiannual
Monthly Average
3. Flow shall be reported in Million Gallons per Day (MGD).
pH analyses shall be performed within fifteen (15) minutes of sample collection. The permittee
shall provide the date and duration (in hours) of the qualifying storm event(s) sampled; rainfall
measurements or estimates (in inches) of the storm event that generated the sampled runoff;
the duration between the storm event sampled and the end of the previous measurable (greater
than 0.1 inch rainfall) storm event; and an estimate of the total volume of the discharge
sampled. Flow shall be reported in Million Gallons per Day (MGD). Provide information as an
attachment to the discharge monitoring report.

SOUTHERN 601 West Rosemary Street, Suite 220 Telephone [phone]
ENVIRONMENTAL Chapel Hill, NC 27516 Facsimile 919-929-9421
LAW
CENTER
April 11, 2024
VIA Electronic Mail
Ori Tuvia, Environmental Engineer
Doug Dowden, Supervisor, Industrial Permitting
N.C. Department of Environmental Quality
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
ori. tuviakdey. nc.g
doug. dowdenkdeq. nc.gov
Re: Southern Environmental Law Center Supplemental Comments Regarding
NPDES Permit No. NC0006351, Venator Chemicals
Dear Ori Tuvia and Doug Dowden:
The Southern Environmental Law Center offers the following supplemental comments
regarding the draft renewal National Pollutant Discharge Elimination System ("NPDES") Permit
NC0006351, issued on March 13, 2024, by the North Carolina Department of Environmental
Quality ("the Department") to Venator Chemicals, located in Harrisburg, Cabarrus County,
North Carolina.' This letter supplements our previous letter sent on February 2, 2024,2 regarding
the draft permit issued January 3, 2024.
As explained in our prior letter, failure to include effluent limits in a NPDES permit for
an entity that does, in fact, discharge per- and polyfluoroalkyl substances ("PFAS") violates the
Clean Water Act. Following our submission of that letter, you disclosed that Venator completed
a PFAS questionnaire indicating that the company does not use any PFAS and therefore that
"effluents, wastes and sludges are not expected to contain PFAS chemicals. "3 Given that Venator
has indicated it does not discharge any PFAS, if the permit is finalized as drafted, the company
would not have authority to release any PFAS. To make this clear to the industry, the
Department should revise Venator's permit to reflect that any PFAS discharges would violate the
permit and the Clean Water Act.
1 N.C. Dep't of Env't Quality, Draft NPDES Permit NC0006351 (Mar. 13, 2024) [hereinafter "Venator Chemicals
Draft Permit"].
2 Letter from Jean Zhuang et al., S. Env't L. Ctr., to Ori Tuvia, N.C. Dep't of Env't Quality (Feb. 2, 2024),
Attachment 1.
3 Letter from Jonna Stein, Venator Chemicals, to Ori Tuvia, N.C. Dep't of Env't Quality (May 29, 2023) [hereinafter
"Venator, Response to PFAS Questionnaire"].
Charlottesville Chapel Hill Atlanta Asheville Birmingham Charleston Nashville Richmond Washington, DC

Venator explicitly denied that it would discharge any PFAS.4 And as written, the draft
permit does not authorize the discharge of any PFAS.S Therefore, any future discharges of PFAS
would be in violation of Venator's NPDES permit and the Clean Water Act. This is because our
courts have established that, under the Act, if "a permit holder discharges a pollutant that it did
not disclose, it violates the NPDES permit and the [Clean Water Act]."6
The draft permit contains a provision requiring Venator to monitor and report any PFAS
discharges that do occur.' While we appreciate the Department's effort to ensure that Venator
does not release any PFAS, nothing in the draft permit makes clear that the company is banned
from releasing the chemicals. The only statement to this effect is in a table tucked away in the
fact sheet, stating that the basis for PFAS monitoring is to "[e]nsure no PFAS" is "in the
effluent."8 The prohibition on PFAS discharges must be clearly stated in the permit itself in order
to fully safeguard any agency and/or citizen enforcement actions.
To plainly establish that Venator may only release pollutants that are disclosed in its
permit application, the Department should add language to the permit stating that any discharges
of undisclosed pollutants are unlawful. The Department would not be the first permitting agency
to add such language to a NPDES permit. South Carolina's Department of Health and
Environmental Control includes language in its NPDES permits stating that "[t]he permiee
acknowledges that the permit shield only applies where the discharge of pollutants are
adequately disclosed and within the reasonable contemplation of the permitting authority at the
time the permit was issued."9 And Tennessee's Department of Environment and Conservation
has included similar language in a NDPES permit, stating that the discharge of undisclosed
pollutants is not authorized under the permit: "[t]he permitee has no permit shield for the
discharge of PFAS compounds because no such chemicals were disclosed in the permit
application or otherwise."'0 The Department should follow the lead of these states and make it
clear that Venator would be liable for the release of any undisclosed pollutants, including PFAS.
We therefore urge the Department to modify Venator's draft permit to include language
explicitly stating that the discharge of pollutants not disclosed in the permitting process —
including PFAS—would violate Venator's permit and the Clean Water Act. Thank you for
a Id. at 1 ("Because the site does not purchase raw materials or manufacture finished goods that contain PFAS
chemicals, the effluents, wastes and sludges are not expected to contain PFAS chemicals."); id. ("There are no
known PFAS chemicals on site.").
s Venator Chemicals Draft Permit, supra note 1.
6 Piney Run Preservation Ass'n a Cnty. Commis of Carroll Cnty., 268 F.3d 255, 268 (4th Cir. 2001) (citing In re
Ketchikan Pulp Co., 7 E.A.D. 605, at *13 (1998)).
7 Venator Chemicals Draft Permit, supra note 1, at 5.
a N.C. Dep't of Env't Quality, Fact Sheet for NDPES Permit Development NDPES Permit No. NC0006351 at 11
(Mar. 13, 2024).
9 S.C. Dep't of Health and Env't Control, NPDES Permit SC0002496 at 38 (Nov. 8, 2022), Attachment 2.
10 Tenn. Dep't of Env't and Conservation, NPDES Permit TN0002330 at 33 (Jan. 30, 2020), Attachment 3.
N

considering these comments. Please contact me at 919-967-1450 [e-mail] if you
have any questions regarding this letter.
Sincerely,
Jean Zhuang
Dakota Foard Loveland

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
Table 1. Project Information
❑ CHECK IF HQW OR ORW WQS
Facility Name
WWTP/WTP Class
NPDES Permit
Outfal I
Flow, Qw (MGD)
Receiving Stream
HUC Number
Stream Class
Venator Chemicals, LLC - Harrisburg Plant
II
NC0006351
001
0.025
Rocky River
C
❑ Apply WS Hardness WQC
7Q1Os (cfs)
7011Ow (cfs)
30Q2 (cfs)
QA (cfs)
1 Q10s (cfs)
4.00
13.00
105.00
3.34 JL
Effluent Hardness
- - - - - - - - - - - -
Upstream Hardness
------------
Combined Hardness Chronic
Combined Hardness Acute
5666 mg/L (Avg)
- - - - - - - - - - - - - - - - - -
100.42 mg/L (Avg)
------------------
153.82 m g/L
164.25 m /L
- - - - - - - - - - - - - - -
Data Source(s)
❑ CHECK TO APPLY MODEL
REQUIRED DATA ENTRY
Par01
Par02
Par03
Par04
Par05
Par06111111
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Par23
Par24
Table 2. Parameters of Concern
Name WQs Type Chronic Modifier Acute PQL Units
Arsenic
Aquactic Life
C
150
FW
340
ug/L
Arsenic
Human Health
Water Supply
C
10
HH/WS
N/A
ug/L
Beryllium
Aquatic Life
NC
6.5
FW
65
ug/L
Cadmium
Aquatic Life
NC
2.3244
FW
16.7145
ug/L
Chlorides
Aquatic Life
NC
230
FW
Chlorinated Phenolic Compounds
Water supply
NC
1
A
ug/L
Total Phenolic Compounds
Aquatic Life
NC
300
A
ug/L
Chromium III
Aquatic Life
NC
521.3693
FW
4229.3561
ug/L
Chromium VI
Aquatic Life
NC
11
FW
16
pg/L
Chromium, Total
Aquatic Life
NC
N/A
FW
N/A
pg/L
Copper
Aquatic Life
NC
37.2239
FW
61.7078
ug/L
Cyanide
Aquatic Life
NC
5
FW
22
10
ug/L
Fluoride
Aquatic Life
NC
1,800
FW
ug/L
Lead
Aquatic Life
NC
21.7976
FW
600.1083
ug/L
Mercury
Aquatic Life
NC
12
FW
0.5
ng/L
Molybdenum
Human Health
NC
2000
HH
ug/L
Nickel
Aquatic Life
NC
173.1659
FW
1648.0713
pg/L
Nickel
Water Supply
NC
25.0000
WS
N/A
pg/L
Selenium
Aquatic Life
NC
5
FW
56
ug/L
Silver
Aquatic Life
NC
0.06
FW
7.5525
ug/L
Zinc
Aquatic Life
NC
590.8414
FW
619.5507
ug/L
RPA Venator, input
5/29/2024

RPA Venator, input
5/29/2024

1.2
0.8
10x.
0.4
0.2
Chart Title
■ ■

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
REASONABLE POTENTIAL ANALYSIS
H2
Use "PASTE SPECIAL
Effluent Hardness Values" then "COPY" Upstream Hardness
. Maximum data
points = 58
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
Date
Data
BDL=1/2DL
Results I
Date
Data
BDL=1/2DL
Results 1
5/22/2023
1980
1980
Std Dev.
8141.5680
1
5/22/2023
98
98
Std Dev.
2.5675
5/23/2023
2030
2030
Mean
5666.0000
2
5/23/2023
98.2
98.2
Mean
100.4200
5/24/2023
20230
20230
C.V. (default)
0.6000
3
5/24/2023
99.9
99.9
C.V. (default)
0.6000
5/25/2023
2050
2050
n
5
4
5/25/2023
104
104
n
5
5/26/2023
2040
2040
10th Per value
2000.00 mg/L
5
5/26/2023
102
102
10th Per value
98.08 mg/L
Average Value
5666.00 mg/L
6
Average Value
100.42 mg/L
Max. Value
20230.00 mg/L
7
Max. Value
104.00 mg/L
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
RPA Venator, data
-4- 5/29/2024

REASONABLE POTENTIAL ANALYSIS
Par01 & Par02
Arsenic
Date
Data
BDL=1/2DL
1
2
3
11 /1 /2018
< 10.00
5.00068998
4
11/12/2018
25.99
25.9885258
5
12/7/2018
< 9.97
4.98260188
6
12/13/2018
21.04
21.0408698
7
12/ 18/2018
12.99
12.9946149
8
1 /7/2019
98.93
98.9291913
9
1 /23/2019
< 9.99
4.99668831
10
2/7/2019
< 10.00
4.99930865
11
2/19/2019
21.96
21.9606015
12
3/4/2019
6.00
6.00139406
13
3/25/2019
< 9.99
4.99659411
14
4/11/2019
55.02
55.0208548
15
4/24/2019
< 10.03
5.01274599
16
5/6/2019
< 10.03
5.01274599
17
5/22/2019
< 9.99
4.99701001
18
1 / 10/2020
12.99
12.9865007
19
1/27/2020
< 10.03
5.01274599
20
2/10/2020
16.96
16.9647527
21
2/24/2020
< 9.99
4.99648267
22
3/9/2020
< 10.01
5.00615069
23
3/23/2020
< 10.01
5.00615069
24
6/1/2020
38.04
38.0351157
25
6/15/2020
< 10.01
5.00448475
26
7/15/2020
< 10.08
5.03824373
27
7/27/2020
< 10.03
5.01274599
28
3/2/2021
< 10.03
5.01607672
29
3/22/2021
< 10.01
5.00281992
30
4/12/2021
23.00
23.0010127
31
4/26/2021
9.95
9.94576545
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
Results
Std Dev.
20.0544
Mean
14.7574
C.V.
1.3589
n
29
Mult Factor =
1.43
Max. Value
98.9 ug/L
Max. Pred Cw
141.5 ug/L
-5-
RPA Venator, data
5/29/2024

REASONABLE POTENTIAL ANALYSIS
Par03
Beryllium
Date Data
BDL=1/2DL Results
1
Std Dev.
2
Mean
3
C.V.
4
n
5
6
Mult Factor =
7
Max. Value
8
Max. Fred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL17
Values" then "COPY"
. Maximum data
points = 58
Date Data
NO DATA 1
NO DATA 2
NO DATA 3
0 4
5
N/A 6
N/A ug/L 7
N/A ug/L 8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use"PASTE SPECIAL
Cadmium
Values" then "COPY"
. Maximum data
points = 58
BDL=1/2DL Results
Std Dev.
NO DATA
Mean
NO DATA
C.V.
NO DATA
n
0
Mult Factor =
N/A
Max. Value
N/A ug/L
Max. Fred Cw
N/A ug/L
RPA Venator, data
-6- 5/29/2024

REASONABLE POTENTIAL ANALYSIS
Par07
Use"PASTE
SPECIAL -Values"
Total Phenolic Compounds
then "COPY".
Maximum data
points = 58
Date
Data BDL=II2DL Results
1
Std Dev.
NO DATA
2
Mean
NO DATA
3
C.V.
NO DATA
4
n
0
5
6
Mull Factor =
N/A
7
Max. Value
N/A ug/L
8
Max. Fred Cw
N/A ug/L
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Par10
Chromium, Total
Date Data BDL=II2DL Results
1 Std Dev.
2 Mean
3 C.V.
4 n
5
6 Mull Factor =
7 Max. Value
8 Max. Fred Cw
9
10
11
12 11 /1 /2018 < 10.7 5.35116569
13 11/12/2018 < 8.753 4.37630617
14 12/7/2018 < 82.18 41.0910871
15 12/13/2018 < 60.59 30.2928834
16 12/18/2018 < 1.294 0.64683447
17 1/7/2019 < 11.27 5.6325919
18 1/23/2019 < 8.466 4.23292196
19 2/7/2019 < 7.647 3.82341492
20 2/19/2019 < 84.74 42.3696387
21 3/4/2019 1.675 1.67480765
22 3/25/2019 < 3.755 1.87746276
23 4/11/2019 < 79.73 39.8632657
24 4/24/2019 < 10.03 5.01274599
25 5/6/2019 < 10.03 5.01274599
26 5/22/2019 < 1.676 0.83782204
27 1/10/2020 < 5.454 2.72683858
28 1/27/2020 < 109.6 54.7821526
29 2/10/2020 < 10.04 5.01774374
30 2/24/2020 < 0.914 0.45719449
31 3/9/2020 < 36.62 18.3093479
32 3/23/2020 < 10.01 5.00615069
33 6/1/2020 < 29.93 14.9636584
34 6/15/2020 3.35 3.34961529
35 7/15/2020 < 81.97 40.9867936
36 7/27/2020 < 4.416 2.20799526
37 3/2/2021 < 6.688 3.34405115
38 3/22/2021 < 5.023 2.51137574
39 4/12/2021 < 10.01 5.00281992
40 4/26/2021 < 30.08 15.0384767
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL Pall
Values" then "COPY"
. Maximum data
points = 58
15.9562 1
12.6138 2
1.2650 3
29 4
5
1.41 6
54.8 ug/L 7
77.2 ug/L 8
-7-
RPA Venator, data
5/29/2024

REASONABLE POTENTIAL ANALYSIS
Date Data
11/1/2018
11/12/2018
12/7/2018
12/ 13/2018
12/ 18/2018
1 /7/2019
1 /23/2019
2/7/2019
2/ 19/2019
3/4/2019
3/25/2019
4/ 11 /2019
4/24/2019
5/6/2019
5/22/2019
1 / 10/2020
1 /27/2020
2/10/2020
2/24/2020
3/9/2020
3/23/2020
6/ 1 /2020
6/15/2020
7/15/2020
7/27/2020
3/2/2021
3/22/2021
4/12/2021
4/26/2021
Par12
Use "PASTE SPECIAL
Copper
values" then "COPY"
. Maximum data
points = 58
BDL=1/2DL Results
Std Dev.
186.5977
1
Mean
106.2072
2
C.V.
1.7569
3
n
29
4
5
Mult Factor =
1.52
6
Max. Value
1008.04 ug/L
7
Max. Pred Cw
1532.22 ug/L
8
121.26 121.264595
45.48 45.4836607
197.21 197.212612
59.39 59.3919586
3.22 3.22451811
15.77 15.7669078
41.45 41.4458272
61.17 61.1746388
203.25 203.254915
3.51 3.50912078
47.96 47.9613195
159.45 159.453063
37.00 36.9988395
59.91 59.9142497
12.87 12.8665527
12.54 12.5401918
1008.04 1008.03935
131.06 131.058688
12.47 12.4748783
168.45 168.453979
46.99 46.9900041
95.62 95.6243349
12.04 12.0426645
245.65 245.648424
13.96 13.9640781
28.03 28.0263334
24.00 23.9975904
55.97 55.9678021
156.26 156.256363
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Date Data
Cyanide
BDL=1/2DL Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
Part:
Use"PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
NO DATA
1
NO DATA
2
NO DATA
3
0
4
5
N/A
6
N/A ug/L 7
N/A ug/L 1 8
RPA Venator, data
8 5/29/2024

REASONABLE POTENTIAL ANALYSIS
3
Date Data
Fluoride
BDL=1/2DL Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL Par14
Values" then "COPY"
. Maximum data
points = 58
NO DATA
NO DATA
0
N/A
N/A ug/L
N/A ug/L
Use"PASTE SPECIAL
Lead Values" then "COPY"
. Maximum data
points = 58
Date BDL=1/2DL Results
1
Std Dev.
14.4542
2
Mean
9.6602
3
C.V.
1.4963
4
n
29
5
6
Mult Factor =
1.47
7
Max. Value
54.782 ug/L
8
Max. Pred Cw
80.530 ug/L
9
10
11
12
11 /1 /2018
< 7.13
3.5645944
13
11/12/2018
< 8.75
4.37630617
14
12/7/2018
< 82.18
41.0910871
15
12/13/2018
< 12.09
6.04365408
16
12/18/2018
< 1.29
0.64683447
17
1 /7/2019
< 11.27
5.6325919
18
1 /23/2019
< 8.47
4.23292196
19
2/7/2019
< 7.65
3.82341492
20
2/19/2019
< 84.74
42.3696387
21
3/4/2019
< 1.67
0.83740382
22
3/25/2019
< 7.49
3.74744558
23
4/11/2019
< 79.73
39.8632657
24
4/24/2019
< 10.03
5.01274599
25
5/6/2019
< 10.03
5.01274599
26
5/22/2019
< 1.68
0.83782204
27
1/10/2020
< 5.45
2.72683858
28
1 /27/2020
< 109.56
54.7821526
29
2/10/2020
< 10.04
5.01774374
30
2/24/2020
< 0.91
0.45719449
31
3/9/2020
< 10.01
5.00615069
32
3/23/2020
< 10.01
5.00615069
33
6/1/2020
< 10.02
5.00775818
34
6/15/2020
< 10.01
5.00448475
35
7/15/2020
< 10.08
5.03824373
36
7/27/2020
< 10.03
5.01274599
37
3/2/2021
< 10.03
5.01607672
38
3/22/2021
< 10.01
5.00281992
39
4/12/2021
< 10.01
5.00281992
40
4/26/2021
< 9.95
4.97288273
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
RPA Venator, data
- 9 - 5/29/2024

REASONABLE POTENTIAL ANALYSIS
Par17 & Par18
Date
Data
1
2
3
4
5
6
7
8
9
10
11/1/2018
< 50
11
11/12/2018
< 50
12
12/7/2018
< 50
13
12/13/2018
< 50
14
12/18/2018
< 25
15
1/7/2019
< 25
16
1/23/2019
< 25
17
2/7/2019
< 25
18
2/19/2019
< 25
19
3/4/2019
< 25
20
3/25/2019
< 25
21
4/11/2019
< 25
22
4/24/2019
< 25
23
5/6/2019
< 25
24
5/22/2019
< 25
25
1/10/2020
< 25
26
1/27/2020
< 25
27
2/10/2020
< 25
28
2/24/2020
< 25
29
3/9/2020
< 25
30
3/23/2020
< 25
31
6/1/2020
< 25
32
6/15/2020
< 25
33
7/15/2020
< 25
34
7/27/2020
< 25
35
3/2/2021
< 25
36
3/22/2021
< 25
37
4/12/2021
< 25
38
4/26/2021
< 25
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Nickel
BDL=1/2DL Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
25
25
25
25
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
Use"PASTE Par19
SPECIAL -Values"
then "COPY". Selenium
Maximum data
points = 58
Date Data BDL=1/2DL Results
4.3866
1
Std Dev.
14.2241
2
Mean
0.3084
3
C.V.
29
4
n
5
1.11
6
Mult Factor =
25.0 Ng/L
7
Max. Value
27.8 Ng/L
8
Max. Pred Cw
9
10 10/13/2017 < 9.99 4.99285414
11 10/25/2017 9.99 9.98770423
12 11/1/2018 < 14.28 7.13773698
13 11/12/2018 < 8.75 4.37630617
14 12/7/2018 < 82.18 41.0910871
15 12/13/2018 < 12.09 6.04365408
16 12/18/2018 < 1.29 0.64683447
17 1/7/2019 < 11.27 5.6325919
18 1/23/2019 < 8.47 4.23292196
19 2/7/2019 < 7.65 3.82341492
20 2/19/2019 < 84.74 42.3696387
21 3/4/2019 < 1.67 0.83740382
22 3/25/2019 < 7.49 3.74744558
23 4/11/2019 < 79.73 39.8632657
24 4/24/2019 < 10.03 5.01274599
25 5/6/2019 < 10.03 5.01274599
26 5/22/2019 < 1.68 0.83782204
27 1/10/2020 < 5.45 2.72683858
28 1/27/2020 < 109.56 54.7821526
29 2/10/2020 < 10.04 5.01774374
30 2/24/2020 < 0.91 0.45719449
31 3/9/2020 < 36.62 18.3093479
32 3/23/2020 < 10.01 5.00615069
33 6/1/2020 < 29.93 14.9636584
34 6/15/2020 < 3.35 1.67480765
35 7/15/2020 < 68.36 34.1783561
36 7/27/2020 < 4.42 2.20799526
37 3/2/2021 < 6.69 3.34405115
38 3/22/2021 < 5.02 2.51137574
39 4/12/2021 < 10.01 5.00281992
40 4/26/2021 < 30.08 15.0384767
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use"PASTE
SPECIAL -Values"
then "COPY".
Maximum data
points = 58
14.7488
11.3183
1.3031
31
1.37
54.8 ug/L
75.1 ug/L
-10-
RPA Venator, data
5/29/2024

REASONABLE POTENTIAL ANALYSIS
Par20
Silver
Date Data
BDL=1/2DL Results
1
Std Dev.
2
Mean
3
C.V.
4
n
5
6
Mult Factor =
7
Max. Value
8
Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use"PASTE Par21
SPECIAL -Values"
then "COPY".
Maximum data
points = 58
Date Data
NO DATA
1
NO DATA
2
NO DATA
3
0
4
5
N/A
6
N/A ug/L 7
N/A ug/L 8
9
10
11
12 11/1/2018
13 11/12/2018
14 12/7/2018
15 12/13/2018
16 12/18/2018
17 1/7/2019
18 1 /23/2019
19 2/7/2019
20 2/19/2019
21 3/4/2019
22 3/25/2019
23 4/11/2019
24 4/24/2019
25 5/6/2019
26 5/22/2019
27 1/10/2020
28 1 /27/2020
29 2/10/2020
30 2/24/2020
31 3/9/2020
32 3/23/2020
33 6/1/2020
34 6/15/2020
35 7/15/2020
36 7/27/2020
37 3/2/2021
38 3/22/2021
39 4/12/2021
40 4/26/2021
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use"PASTE
SPECIAL -
Values" then
"COPY...
Maximum data
BDL=1/2DL Results
points =58
Std Dev.
Mean
946.8446
C.V.
1.4953
n
29
Mult Factor =
1.47
Max. Value
6080.4 ug/
979.23 979.229128
211.65 211.648639
2925.46 2925.46395
6080.36 6080.36368
511.29 511.28886
2313.12 2313.12499
190.30 190.297448
103.24 103.239244
304.94 304.942048
19.86 19.8584335
48.74 48.7392323
956.72 956.718378
179.86 179.8621
1079.29 1079.29195
262.74 262.737001
123.25 123.246573
3572.06 3572.05892
463.19 463.185536
46.25 46.2528428
1138.93 1138.9292
385.77 385.772776
492.91 492.906484
50.12 50.1246003
873.66 873.658696
33.78 33.7763599
65.37 65.3682379
395.76 395.760926
183.89 183.888512
3466.76 3466.75832
Max. Pred Cw 8938.1 ug/
RPA Venator, data
11 - 5/29/2024

Venator Chemicals, LLC - Harrisburg Plant
NC0006351 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
Qw (MGD) =
0.0250
1Q10S (cfs) =
3.34
7Q10S (cfs) =
4.00
7Q10W (cfs) =
13.00
30Q2 (cfs) =
NO 3002 DATA
Avg. Stream Flow, QA (cfs) =
105.00
Receiving Stream: Rocky River
MAXIMUM DATA POINTS = 58
WWTP/WTP Class: II
IWC% @ 1Q10S =
1.146873844
IWC% @ 7Q10S =
0.959455277
IWC% @ 7Q10W =
0.297191065
IWC% @ 30Q2 =
N/A
IW%C @ QA =
0.036891147
Stream Class:
C
Outfall 001
Qw = 0.025 MGD
COMBINED HARDNESS (me/L)
Acute = 164.25 mg/L
Chronic = 153.82 mg/L
PARAMETER
NC STANDARDS OR EPA CRITERIA
y
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
TYPE
J
a
F
Chronic Applied
Acute
ri # Det. Max Pred Cw Allowable Cw
Standard
Acute (FW): 29,645.8
Arsenic
C
150 FW(7Q10s) 340
ug/L
29 12
141.5
Chronic (FW): 15,633.9
No RP -maintain ELG requirements
No_value>Allowable _Cw_ _
_________________________
Arsenic
C
10 HH/WS(Qavg)
ug/L
Chronic (HH): 27,106.8
No value > Allowable Cw
Tot Cr value(s) > 5 but < Cr VI Allowable Cw
Chromium, Total
NC
µg/L
29 2 77.2 reported value = 54.782152624
No RP, max values were at below detect samples -
maintain ELG requirements
Acute: 5,380.52
Copper
NC
37.2239 FW(7Q10s) 61.7078
ug/L
29 29
1,532.22
_
Chronic: 3,879.70
_
No RP , Predicted Max a 50 % of Allowable Cw
No value > Allowable Cw
apply Quarterly Monitoring
Acute: 52,325.574
Lead
NC
21.7976 FW(7Q1Os) 600.1083
ug/L
29 0
80.530
Chronic: 2,271.873
No RP - maintain ELG requirements
NO DETECTS
Max MDL = 109.56430524911
Acute (FW): 143,701.2
Nickel
NC
173.1659 FW(7Q10s) 1648.0713
µg/L
29 0
27.8
Chronic (FW): 18,048.4—
— — — — — — — — — — — — — —
Max M_DL_= 50
Nickel
NC
25.0000 WS(7Q10s)
µg/L
NO DETECTS
Chronic (WS): 2,605.6
No RP - maintain ELG monitoring requirements
Max MDL = 50
Acute: 4,882.8
Selenium
NC
5 FW(7Q10s) 56
ug/L
31 1
75.1
Chronic: 521.1
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required; WQBEL more stringent than
No value > Allowable Cw
ELG limit - apply WQBEL
Acute: 54,020.8
Zinc
NC
590.8414 FW(7Q10s) 619.5507
ug/L
29 29
8,938.1
_ _
Chronic: 61,580.9 No RP , Predicted Max >_ 50% of Allowable Cw
No value > Allowable Cw lapply Quarterly Monitoring
RPA Venator, rpa
Page 12 of 57 5/29/2024

Monitoring Frequencies
2B .0500 Effluent Limited
pH E 2/Month 1/Week 3/Week
Daily
Temp, C E 1/Week 1/Week 3/Week
Daily
BOD5 I, E 2/Month 1/Week 3/Week
Daily
TSS I, E 2/Month 1/Week 3/Week
Daily
NH3-N E 1/Month 2/Month 1/Week
3/Week
Fecal Col. E 2/Month 1/Week 3/Week
Daily
TN E See notes below.
TP E See notes below.
Water Quality Limited
Frequency
Parameter Location Class I Class II Class III
Class IV
D.O. E 1/Week 1/Week 3/Week
Daily
D.O. U, D 1/Week 1/Week 3/Week*
3/Week*
pH E 2/Month 1/Week 3/Week
Daily
Temp, C E Daily Daily Daily
Daily
Temp, C U, D 1/Week 1/Week 3/Week*
3/Week*
BOD5 I, E 2/Month 1/Week 3/Week
Daily
TSS I, E 2/Month 1/Week 3/Week
Daily
NH3-N E 1/Month 2/Month 1/Week
3/Week
TRC E 2/Week 2/Week 3/Week
Daily
Fecal Col. E 2/Month 1/Week 3/Week
Daily
Fecal Col. U, D 2/Month 1/Week 3/Week*
3/Week*
Conductivii E 1/Week 1/Week 3/Week
Daily
Conductivii U, D 1/Week 1/Week 3/Week*
3/Week*
TN E See notes below.
TP E See notes below.
Notes:
* Upstream and downstream monitoring in WQ-limited waters is to be conducted
3/Week during Jun, Jul, Aug, and Sep; and 1/Week during
the rest of the year.
TN, TP Monitoring
All facilities >= 0.05 MGD will monitor TN and TP
Those < 0.05 MGD will monitor if discharging to NSW
For the Neuse, Tar -Pamlico, and any other river basins classified as NSW, use limits
and monitoring requirements according to the basin's
permitting strategy.
For French Broad, Broad, Savannah, New Watauga, Little Tennessee, and Hiwassee:
- >= 0.05 MC - monitor semi-annually
- >= 1.0 MGI - monitor quarterly
For all other river basins:
- >= 0.05 MC - monitor quarterly
- >= 1.0 MG - monitor monthly
Sam le recommendati
Msg00 < No Data Entered > NO DATA I Daily max limit

Msg01
MaxPredCw < Acute
MONITOR?
Monitor 1/month
Msg02
MaxPredCw < Chronic
MONITOR?
Monitor 1/week
Msg03
MaxPredCw << Acute
REMOVE?
Monitor 2/month
Msg04
MaxPredCw << Chronic
REMOVE?
Monitoring not necess�
Msg05
MaxPredCw > Acute
DAILY MAX LIMIT?
No limit
Msg06
MaxPredCw > Chronic
MO AVG LIMIT?
No limit - assuming no
Msg07
MaxPredCw» Acute
DAILY MAX LIMIT?
No limit (Action Level r
Msg08
MaxPredCw» Chronic
MO AVG LIMIT?
Continue to monitor at
Msg09
No acute standard or 1/2 FAV
N/A
Mo. avg. limit (keep wk
Msg10
No chronic standard or criterion
N/A
Revise daily max. limit

Per Memo Dated 7-15-2010
RPA Condition
Permit Monitoring Frequency
1.RPA Exists
Monitor Monthly and add Permit Limit
IRPA Exists but Action Levels (Cu. Zn, Ag ,Fe, Cl)
Monitor Quarterly in conjunction with T
3a.RPA Exists but Dataset Limited (n< 8 samples)
3b. RPA exists, dataset limited, but 2 values >
allo%vable C",
Monitor Quarterly
Monitor Monthly and add Permit Limit
4. o RPA (Predicted M x > 0% of Allo%vable)
Monitor Quan5 I�� (or defer to Pretreat �
5, o RPA (Predicted Max < 50% Allo"-able)
No Monitorin
6a,No Data (New Permit, Ne%v Waste Stream)
6b. New Greensand or Conventional IX7?
Monitor Monthly for Toxic Pollutants o
Monitor Quarterl for Toxic Pollutants c
password all sheets = rpa2017
4/28/16: Note Action Level designation no longer allowed per EPA.
11/20/17 Chlorides still listed as have action levels but will be coorected at next EPA review

-c.;. T�:
f concem
A Concem

Reasonable Potential Multiplying Factors - Calculator
95.0%
Confidence Level
Upper Boundary of the Effluent Distribution (Percentile Value Not To Exceed)
95.0%
Coefficient of Variation
n
0.0
0.1
0.2
0.3
0.4
0.5
0.6
0.7
0.8
0.9
1.0
1.1
1.2
1.3
1.4
1
1.00
1.39
1.92
2.63
3.55
4.7D
6.20
7.98
10.11
12.60
15.47
lo.iz
zz.35
26.38
30.78
2
1.00
1.27
1.61
2.03
2.53
3.11
3.79
4.57
5.43
6.38
7.41
8.51
9.69
10.94
12.25
3
1.00
1.22
1.48
1.79
2.15
2.55
3.00
3.49
4.03
4.60
5.20
5.84
6.49
7.17
7.87
4
1.00
1.19
1.40
1.65
1.93
2.25
2.59
2.95
3.34
3.74
4.16
4.60
5.04
5.50
5.96
5
1.00
1.16
1.35
1.56
1.80
2.05
2.32
2.61
2.91
3.23
3.55
3.87
4.21
4.54
4.88
6
1.00
1.15
1.31
1.50
1.70
_._ _
2.14
2.38
2.63
2.88
3.14
3.40
3.66
3.92
4.18
7
1.00
1.13
1.28
1.45
1.62
1.81
2.01
2.21
2.42
2.63
2.84
3.06
3.27
3.48
3.69
8
1.00
1.12
1.26
1.40
1.56
1.73
1.90
2.07
2.25
2.44
2.62
2.80
2.98
3.16
3.33
9
1.00
1.11
1.24
1.37
1.51
1.66
1.81
1.97
2.12
2.28
2.44
2.60
2.75
2.90
3.05
10
1.00
1.10
1.22
1.34
1.47
1.60
1.74
1.88
2.02
2.16
2.30
2.43
2.57
2.70
2.83
11
1.00
1.10
1.20
1.32
1.43
1.55
1.68
1.80
1.93
2.05
2.18
2.30
2.41
2.53
2.64
12
1.00
1.09
1.19
1.29
1.40
1.51
1.63
1.74
1.85
1.96
2.07
2.18
2.29
2.39
2.49
13
1.00
1.09
1.18
1.27
1.37
1.48
1.58
1.68
1.79
1.89
1.99
2.08
2.18
2.27
2.36
14
1.00
1.08
1.17
1.26
1.35
1.44
1.54
1.63
1.73
1.82
1.91
2.00
2.08
2.17
2.25
15
1.00
1.08
1.16
1.24
1.33
1.41
1.50
1.59
1.68
1.76
1.84
1.92
2.00
2.07
2.15
16
1.00
1.07
1.15
1.23
1.31
1.39
1.47
1.55
1.63
1.71
1.78
1.85
1.93
1.99
2.06
17
1.00
1.07
1.14
1.21
1.29
1.36
1.44
1.51
1.59
1.66
1.73
1.79
1.86
1.92
1.98
18
1.00
1.06
1.13
1.20
1.27
1.34
1.41
1.48
1.55
1.62
1.68
1.74
1.80
1.86
1.91
19
1.00
1.06
1.12
1.19
1.26
1.32
1.39
1.45
1.51
1.58
1.64
1.69
1.75
1.80
1.85
20
1.00
1.06
1.12
1.18
1.24
1.30
1.36
1.42
1.48
1.54
1.59
1.65
1.70
1.75
1.79
21
1.00
1.05
1.11
1.17
1.23
1.29
1.34
1.40
1.45
1.51
1.56
1.61
1.65
1.70
1.74
22
1.00
1.05
1.11
1.16
1.22
1.27
1.32
1.38
1.43
1.48
1.52
1.57
1.61
1.65
1.69
23
1.00
1.05
1.10
1.15
1.20
1.25
1.31
1.35
1.40
1.45
1.49
1.53
1.57
1.61
1.65
24
1.00
1.05
1.09
1.14
1.19
1.24
1.29
1.33
1.38
1.42
1.46
1.50
1.54
1.57
1.61
25
1.00
1.04
1.09
1.14
1.18
1.23
1.27
1.32
1.36
1.40
1.43
1.47
1.51
1.54
1.57
26
1.00
1.04
1.09
1.13
1.17
1.21
1.26
1.30
1.34
1.37
1.41
1.44
1.48
1.51
1.54
27
1.00
1.04
1.08
1.12
1.16
1.20
1.24
1.28
1.32
1.35
1.39
1.42
1.45
1.48
1.50
28
1.00
1.04
1.08
1.12
1.15
1.19
1.23
1.26
1.30
1.33
1.36
1.39
1.42
1.45
1.47
29
1.00
1.04
1.07
1.11
1.15
1.18
1.22
1.25
1.28
1.31
1.34
1.37
1.40
1.42
1.44
30
1.00
1.03
1.07
1.10
1.14
1.17
1.20
1.24
1.27
1.29
1.32
1.35
1.37
1.39
1.42
31
1.00
1.03
1.06
1.10
1.13
1.16
1.19
1.22
1.25
1.28
1.30
1.33
1.35
1.37
1.39
32
1.00
1.03
1.06
1.09
1.12
1.15
1.18
1.21
1.24
1.26
1.28
1.31
1.33
1.35
1.37
33
1.00
1.03
1.06
1.09
1.12
1.14
1.17
1.20
1.22
1.24
1.27
1.29
1.31
1.33
1.34
34
1.00
1.03
1.05
1.08
1.11
1.14
1.16
1.18
1.21
1.23
1.25
1.27
1.29
1.31
1.32
35
1.00
1.03
1.05
1.08
1.10
1.13
1.15
1.17
1.20
1.22
1.23
1.25
1.27
1.29
1.30
36
1.00
1.02
1.05
1.07
1.10
1.12
1.14
1.16
1.18
1.20
1.22
1.24
1.25
1.27
1.28
37
1.00
1.02
1.05
1.07
1.09
1.11
1.13
1.15
1.17
1.19
1.21
1.22
1.24
1.25
1.26
38
1.00
1.02
1.04
1.06
1.08
1.10
1.12
1.14
1.16
1.18
1.19
1.21
1.22
1.23
1.25
39
1.00
1.02
1.04
1.06
1.08
1.10
1.12
1.13
1.15
1.16
1.18
1.19
1.21
1.22
1.23
40
1.00
1.02
1.04
1.06
1.07
1.09
1.11
1.12
1.14
1.15
1.17
1.18
1.19
1.20
1.21

41
1.00
1.02
1.03
1.05
1.07
1.08
1.10
1.12
1.13
1.14
1.15
1.17
1.18
1.19
1.20
42
1.00
1.02
1.03
1.05
1.06
1.08
1.09
1.11
1.12
1.13
1.14
1.15
1.16
1.17
1.18
43
1.00
1.01
1.03
1.04
1.06
1.07
1.09
1.10
1.11
1.12
1.13
1.14
1.15
1.16
1.17
44
1.00
1.01
1.03
1.04
1.05
1.07
1.08
1.09
1.10
1.11
1.12
1.13
1.14
1.15
1.15
45
1 1.00
1.01
1.03
1.04
1.05
1.06
1.07
1.08
1.09
1.10
1.11
1.12
1.13
1.13
1.14
46
1.00
1.01
1.02
1.03
1.05
1.06
1.07
1.08
1.08
1.09
1.10
1.11
1.11
1.12
1.13
47
1.00
1.01
1.02
1.03
1.04
1.05
1.06
1.07
1.08
1.08
1.09
1.10
1.10
1.11
1.12
48
1.00
1.01
1.02
1.03
1.04
1.05
1.05
1.06
1.07
1.08
1.08
1.09
1.09
1.10
1.10
49
1.00
1.01
1.02
1.03
1.03
1.04
1.05
1.05
1.06
1.07
1.07
1.08
1.08
1.09
1.09
50
1 1.00
1.01
1.01
1.02
1.03
1.04
1.04
1.05
1.05
1.06
1.06
1.07
1.07
1.08
1.08
51
1.00
1.01
1.01
1.02
1.03
1.03
1.04
1.04
1.05
1.05
1.06
1.06
1.06
1.07
1.07
52
1.00
1.01
1.01
1.02
1.02
1.03
1.03
1.04
1.04
1.04
1.05
1.05
1.05
1.06
1.06
53
1.00
1.00
1.01
1.01
1.02
1.02
1.03
1.03
1.03
1.04
1.04
1.04
1.04
1.05
1.05
54
1.00
1.00
1.01
1.01
1.01
1.02
1.02
1.02
1.03
1.03
1.03
1.03
1.04
1.04
1.04
55
1 1.00
1.00
1.01
1.01
1.01
1.01
1.02
1.02
1.02
1.02
1.02
1.03
1.03
1.03
1.03
56
1.00
1.00
1.00
1.01
1.01
1.01
1.01
1.01
1.01
1.02
1.02
1.02
1.02
1.02
1.02
57
1.00
1.00
1.00
1.00
1.00
1.01
1.01
1.01
1.01
1.01
1.01
1.01
1.01
1.01
1.01
58
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
0.0
0.1
0.2
0.3
0.4
0.5
0.6
0.7
0.8
0.9
1.0
1.1
1.2
1.3
1.4
RPMFs as
f(n,CV,Confidence,Upper6ound)
400.00
350.00
300.00
0
250.00
c
0
a 200.00
u
a
3 150.00
3 16 19 22 25
❑ 350.00-400.00
❑ 300.00-350.00
❑ 250.00-300.00
❑ 200.00-250.00
❑ 150.00-200.00
❑ 100.00-150.00
❑ 50.00-100.00
❑ 0.00-50.00

1.5
1.6
1.7
1.8
1.9
2.0
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
35.57
40.73
46.26
52.14
58.37
64.94
71.84
79.06
86.58
94.41
102.53
110.94 119.62
128.56
13.61
15.03
16.49
18.00
19.55
21.14
22.75
24.40
26.08
27.79
29.51
31.26
33.03
34.82
8.59
9.32
10.06
10.81
11.58
12.34
13.12
13.90
14.68
15.46
16.25
17.04
17.83
18.62
6.42
6.89
7.36
7.84
8.31
8.79
9.26
9.73
10.20
10.68
11.14
11.61
12.07
12.54
5.21
5.55
5.89
6.22
6.56
6.89
7.22
7.54
7.87
8.19
8.51
8.82
9.13
9.44
4.44
4.70
4.96
5.21
5.46
5.71
5.96
6.20
6.44
6.68
6.91
7.14
7.37
7.60
3.90
4.11
4.32
4.52
4.72
4.91
5.10
5.29
5.48
5.67
5.85
6.02
6.20
6.37
3.51
3.68
3.85
4.01
4.17
4.33
4.49
4.64
4.79
4.94
5.09
5.23
5.37
5.51
3.20
3.34
3.49
3.62
3.76
3.89
4.02
4.15
4.27
4.40
4.52
4.63
4.75
4.86
2.95
3.08
3.20
3.32
3.43
3.55
3.66
3.77
3.87
3.97
4.07
4.17
4.27
4.36
2.75
2.86
2.97
3.07
3.17
3.27
3.36
3.46
3.55
3.63
3.72
3.80
3.89
3.97
2.59
2.68
2.78
2.87
2.95
3.04
3.12
3.20
3.28
3.36
3.43
3.50
3.57
3.64
2.45
2.53
2.61
2.69
2.77
2.84
2.92
2.99
3.06
3.12
3.19
3.25
3.31
3.37
2.32
2.40
2.47
2.54
2.61
2.68
2.74
2.81
2.87
2.93
2.98
3.04
3.09
3.15
2.22
2.29
2.35
2.41
2.48
2.54
2.59
2.65
2.70
2.76
2.81
2.86
2.91
2.95
2.12
2.19
2.24
2.30
2.36
2.41
2.46
2.51
2.56
2.61
2.65
2.70
2.74
2.78
2.04
2.10
2.15
2.20
2.25
2.30
2.35
2.39
2.44
2.48
2.52
2.56
2.60
2.64
1.97
2.02
2.07
2.11
2.16
2.20
2.25
2.29
2.33
2.36
2.40
2.44
2.47
2.51
1.90
1.95
1.99
2.03
2.08
2.12
2.15
2.19
2.23
2.26
2.30
2.33
2.36
2.39
1.84
1.88
1.92
1.96
2.00
2.04
2.07
2.11
2.14
2.17
2.20
2.23
2.26
2.29
1.78
1.82
1.86
1.90
1.93
1.96
2.00
2.03
2.06
2.09
2.12
2.14
2.17
2.19
1.73
1.77
1.80
1.84
1.87
1.90
1.93
1.96
1.99
2.01
2.04
2.06
2.09
2.11
1.68
1.72
1.75
1.78
1.81
1.84
1.87
1.89
1.92
1.94
1.97
1.99
2.01
2.03
1.64
1.67
1.70
1.73
1.76
1.78
1.81
1.83
1.86
1.88
1.90
1.92
1.94
1.96
1.60
1.63
1.66
1.68
1.71
1.73
1.76
1.78
1.80
1.82
1.84
1.86
1.88
1.90
1.56
1.59
1.62
1.64
1.66
1.69
1.71
1.73
1.75
1.77
1.79
1.80
1.82
1.84
1.53
1.55
1.58
1.60
1.62
1.64
1.66
1.68
1.70
1.72
1.73
1.75
1.77
1.78
1.50
1.52
1.54
1.56
1.58
1.60
1.62
1.64
1.66
1.67
1.69
1.70
1.72
1.73
1.47
1.49
1.51
1.53
1.55
1.56
1.58
1.60
1.61
1.63
1.64
1.66
1.67
1.68
1.44
1.46
1.48
1.49
1.51
1.53
1.54
1.56
1.57
1.59
1.60
1.61
1.63
1.64
1.41
1.43
1.45
1.46
1.48
1.50
1.51
1.52
1.54
1.55
1.56
1.57
1.59
1.60
1.39
1.40
1.42
1.43
1.45
1.46
1.48
1.49
1.50
1.51
1.53
1.54
1.55
1.56
1.36
1.38
1.39
1.41
1.42
1.43
1.45
1.46
1.47
1.48
1.49
1.50
1.51
1.52
1.34
1.35
1.37
1.38
1.39
1.41
1.42
1.43
1.44
1.45
1.46
1.47
1.48
1.49
1.32
1.33
1.34
1.36
1.37
1.38
1.39
1.40
1.41
1.42
1.43
1.44
1.45
1.45
1.30
1.31
1.32
1.33
1.34
1.35
1.36
1.37
1.38
1.39
1.40
1.41
1.42
1.42
1.28
1.29
1.30
1.31
1.32
1.33
1.34
1.35
1.36
1.36
1.37
1.38
1.39
1.39
1.26
1.27
1.28
1.29
1.30
1.31
1.32
1.32
1.33
1.34
1.35
1.35
1.36
1.37
1.24
1.25
1.26
1.27
1.28
1.29
1.29
1.30
1.31
1.31
1.32
1.33
1.33
1.34
1.22
1.23
1.24
1.25
1.26
1.26
1.27
1.28
1.29
1.29
1.30
1.30
1.31
1.31

1.21
1.21
1.22
1.23
1.24
1.24
1.25
1.26
1.26
1.27
1.27
1.28
1.29
1.29
1.19
1.20
1.21
1.21
1.22
1.23
1.23
1.24
1.24
1.25
1.25
1.26
1.26
1.27
1.18
1.18
1.19
1.20
1.20
1.21
1.21
1.22
1.22
1.23
1.23
1.24
1.24
1.25
1.16
1.17
1.17
1.18
1.18
1.19
1.20
1.20
1.20
1.21
1.21
1.22
1.22
1.22
1.15
1.15
1.16
1.16
1.17
1.17
1.18
1.18
1.19
1.19
1.19
1.20
1.20
1.20
1.13
1.14
1.14
1.15
1.15
1.16
1.16
1.17
1.17
1.17
1.18
1.18
1.18
1.19
1.12
1.13
1.13
1.13
1.14
1.14
1.15
1.15
1.15
1.16
1.16
1.16
1.16
1.17
1.11
1.11
1.12
1.12
1.12
1.13
1.13
1.13
1.14
1.14
1.14
1.14
1.15
1.15
1.10
1.10
1.10
1.11
1.11
1.11
1.12
1.12
1.12
1.12
1.13
1.13
1.13
1.13
1.08
1.09
1.09
1.09
1.10
1.10
1.10
1.10
1.11
1.11
1.11
1.11
1.11
1.12
1.07
1.08
1.08
1.08
1.08
1.09
1.09
1.09
1.09
1.09
1.10
1.10
1.10
1.10
1.06
1.06
1.07
1.07
1.07
1.07
1.07
1.08
1.08
1.08
1.08
1.08
1.08
1.09
1.05
1.05
1.06
1.06
1.06
1.06
1.06
1.06
1.06
1.07
1.07
1.07
1.07
1.07
1.04
1.04
1.04
1.05
1.05
1.05
1.05
1.05
1.05
1.05
1.05
1.05
1.06
1.06
1.03
1.03
1.03
1.03
1.04
1.04
1.04
1.04
1.04
1.04
1.04
1.04
1.04
1.04
1.02
1.02
1.02
1.02
1.02
1.03
1.03
1.03
1.03
1.03
1.03
1.03
1.03
1.03
1.01
1.01
1.01
1.01
1.01
1.01
1.02
1.02
1.02
1.02
1.02
1.02
1.02
1.02
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.5
1.6
1.7
1.8
1.9
2.0
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8

Coefficient of Variation
2.9 3.0 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 4.0
137.76
147.21
156.91
166.84
177.00
187.38
197.98
208.78
219.79
231.00
242.40
253.99
36.63
38.45
40.28
42.13
43.99
45.86
47.74
49.64
51.54
53.44
55.36
57.28
19.41
20.21
21.00
21.79
22.58
23.36
24.15
24.94
25.72
26.50
27.28
28.06
13.00
13.45
13.91
14.36
14.81
15.25
15.70
16.14
16.58
17.01
17.44
17.87
9.75
10.05
10.36
10.65
10.95
11.24
11.53
11.82
12.10
12.38
12.66
12.94
7.82
8.04
8.25
8.47
8.68
8.89
9.10
9.30
9.50
9.70
9.90
10.09
6.54
6.71
6.88
7.04
7.20
7.36
7.51
7.67
7.82
7.97
8.12
8.26
5.64
5.78
5.91
6.03
6.16
6.29
6.41
6.53
6.65
6.77
6.88
6.99
4.97
5.08
5.19
5.29
5.40
5.50
5.60
5.69
5.79
5.88
5.98
6.07
4.46
4.55
4.64
4.72
4.81
4.89
4.97
5.06
5.13
5.21
5.29
5.36
4.05
4.12
4.20
4.27
4.34
4.41
4.48
4.55
4.62
4.68
4.75
4.81
3.71
3.78
3.84
3.90
3.97
4.03
4.09
4.15
4.20
4.26
4.31
4.37
3.43
3.49
3.55
3.60
3.66
3.71
3.76
3.81
3.86
3.91
3.96
4.00
3.20
3.25
3.30
3.35
3.39
3.44
3.48
3.53
3.57
3.61
3.66
3.70
3.00
3.04
3.09
3.13
3.17
3.21
3.25
3.29
3.33
3.36
3.40
3.44
2.83
2.86
2.90
2.94
2.98
3.01
3.05
3.08
3.12
3.15
3.18
3.21
2.67
2.71
2.74
2.78
2.81
2.84
2.87
2.90
2.93
2.96
2.99
3.02
2.54
2.57
2.60
2.63
2.66
2.69
2.72
2.75
2.77
2.80
2.83
2.85
2.42
2.45
2.48
2.51
2.53
2.56
2.58
2.61
2.63
2.66
2.68
2.70
2.31
2.34
2.37
2.39
2.42
2.44
2.46
2.48
2.51
2.53
2.55
2.57
2.22
2.24
2.27
2.29
2.31
2.33
2.35
2.37
2.39
2.41
2.43
2.45
2.13
2.15
2.18
2.20
2.22
2.24
2.25
2.27
2.29
2.31
2.33
2.34
2.05
2.07
2.09
2.11
2.13
2.15
2.16
2.18
2.20
2.21
2.23
2.24
1.98
2.00
2.02
2.03
2.05
2.07
2.08
2.10
2.11
2.13
2.14
2.16
1.91
1.93
1.95
1.96
1.98
1.99
2.01
2.02
2.04
2.05
2.06
2.08
1.85
1.87
1.88
1.90
1.91
1.93
1.94
1.95
1.97
1.98
1.99
2.00
1.80
1.81
1.82
1.84
1.85
1.86
1.88
1.89
1.90
1.91
1.92
1.93
1.74
1.76
1.77
1.78
1.79
1.81
1.82
1.83
1.84
1.85
1.86
1.87
1.70
1.71
1.72
1.73
1.74
1.75
1.76
1.77
1.78
1.79
1.80
1.81
1.65
1.66
1.67
1.68
1.69
1.70
1.71
1.72
1.73
1.74
1.75
1.76
1.61
1.62
1.63
1.64
1.65
1.66
1.66
1.67
1.68
1.69
1.70
1.71
1.57
1.58
1.59
1.60
1.60
1.61
1.62
1.63
1.64
1.64
1.65
1.66
1.53
1.54
1.55
1.56
1.56
1.57
1.58
1.59
1.59
1.60
1.61
1.61
1.49
1.50
1.51
1.52
1.53
1.53
1.54
1.55
1.55
1.56
1.57
1.57
1.46
1.47
1.48
1.48
1.49
1.50
1.50
1.51
1.51
1.52
1.53
1.53
1.43
1.44
1.44
1.45
1.46
1.46
1.47
1.47
1.48
1.48
1.49
1.49
1.40
1.41
1.41
1.42
1.42
1.43
1.43
1.44
1.45
1.45
1.45
1.46
1.37
1.38
1.38
1.39
1.39
1.40
1.40
1.41
1.41
1.42
1.42
1.43
1.34
1.35
1.36
1.36
1.37
1.37
1.37
1.38
1.38
1.39
1.39
1.40
1.32
1.32
1.33
1.33
1.34
1.34
1.35
1.35
1.35
1.36
1.36
1.37

1.29
1.30
1.30
1.31
1.31
1.32
1.32
1.32
1.33
1.33
1.33
1.34
1.27
1.28
1.28
1.28
1.29
1.29
1.29
1.30
1.30
1.30
1.31
1.31
1.25
1.25
1.26
1.26
1.26
1.27
1.27
1.27
1.28
1.28
1.28
1.28
1.23
1.23
1.23
1.24
1.24
1.24
1.25
1.25
1.25
1.25
1.26
1.26
1.21
1.21
1.21
1.22
1.22
1.22
1.22
1.23
1.23
1.23
1.23
1.24
1.19
1.19
1.19
1.20
1.20
1.20
1.20
1.21
1.21
1.21
1.21
1.21
1.17
1.17
1.17
1.18
1.18
1.18
1.18
1.19
1.19
1.19
1.19
1.19
1.15
1.15
1.16
1.16
1.16
1.16
1.16
1.17
1.17
1.17
1.17
1.17
1.13
1.14
1.14
1.14
1.14
1.14
1.14
1.15
1.15
1.15
1.15
1.15
1.12
1.12
1.12
1.12
1.12
1.13
1.13
1.13
1.13
1.13
1.13
1.13
1.10
1.10
1.10
1.11
1.11
1.11
1.11
1.11
1.11
1.11
1.11
1.12
1.09
1.09
1.09
1.09
1.09
1.09
1.09
1.09
1.10
1.10
1.10
1.10
1.07
1.07
1.07
1.07
1.08
1.08
1.08
1.08
1.08
1.08
1.08
1.08
1.06
1.06
1.06
1.06
1.06
1.06
1.06
1.06
1.06
1.06
1.06
1.06
1.04
1.04
1.04
1.05
1.05
1.05
1.05
1.05
1.05
1.05
1.05
1.05
1.03
1.03
1.03
1.03
1.03
1.03
1.03
1.03
1.03
1.03
1.03
1.03
1.02
1.02
1.02
1.02
1.02
1.02
1.02
1.02
1.02
1.02
1.02
1.02
1.00
1.00
1.01
1.01
1.01
1.01
1.01
1.01
1.01
1.01
1.01
1.01
2.9 3.0 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 4.0

Coefficient of Variation
4.1 4.2 4.3 4.4 4.5 4.6 4.7 4.8 4.9 5.0 5.1 5.2
265.76
277.71
289.83
302.12
314.57
327.19
339.96
352.88
365.95
379.17
392.53
406.03
59.21
61.15
63.09
65.03
66.98
68.93
70.89
72.85
74.81
76.78
78.75
80.72
28.84
29.61
30.38
31.15
31.92
32.68
33.44
34.20
34.96
35.72
36.47
37.22
18.30
18.72
19.14
19.56
19.98
20.39
20.80
21.21
21.61
22.02
22.42
22.82
13.21
13.48
13.75
14.02
14.28
14.55
14.81
15.06
15.32
15.57
15.82
16.07
10.29
10.48
10.66
10.85
11.04
11.22
11.40
11.58
11.76
11.93
12.10
12.28
8.41
8.55
8.69
8.83
8.96
9.10
9.23
9.37
9.50
9.63
9.75
9.88
7.11
7.22
7.33
7.43
7.54
7.65
7.75
7.85
7.95
8.05
8.15
8.25
6.16
6.25
6.34
6.42
6.51
6.59
6.67
6.76
6.84
6.91
6.99
7.07
5.44
5.51
5.58
5.65
5.72
5.79
5.86
5.93
5.99
6.06
6.12
6.19
4.87
4.94
5.00
5.05
5.11
5.17
5.23
5.28
5.34
5.39
5.44
5.50
4.42
4.47
4.52
4.57
4.62
4.67
4.72
4.77
4.81
4.86
4.90
4.95
4.05
4.09
4.14
4.18
4.22
4.26
4.30
4.35
4.38
4.42
4.46
4.50
3.74
3.77
3.81
3.85
3.89
3.92
3.96
3.99
4.03
4.06
4.10
4.13
3.47
3.51
3.54
3.57
3.60
3.64
3.67
3.70
3.73
3.76
3.79
3.82
3.24
3.28
3.30
3.33
3.36
3.39
3.42
3.44
3.47
3.50
3.52
3.55
3.05
3.08
3.10
3.13
3.15
3.18
3.20
3.23
3.25
3.27
3.30
3.32
2.88
2.90
2.92
2.95
2.97
2.99
3.01
3.03
3.06
3.08
3.10
3.12
2.72
2.75
2.77
2.79
2.81
2.83
2.85
2.87
2.89
2.90
2.92
2.94
2.59
2.61
2.63
2.65
2.66
2.68
2.70
2.72
2.73
2.75
2.77
2.78
2.47
2.49
2.50
2.52
2.54
2.55
2.57
2.58
2.60
2.61
2.63
2.64
2.36
2.37
2.39
2.41
2.42
2.44
2.45
2.46
2.48
2.49
2.50
2.52
2.26
2.27
2.29
2.30
2.32
2.33
2.34
2.36
2.37
2.38
2.39
2.40
2.17
2.18
2.20
2.21
2.22
2.23
2.25
2.26
2.27
2.28
2.29
2.30
2.09
2.10
2.11
2.12
2.13
2.15
2.16
2.17
2.18
2.19
2.20
2.21
2.01
2.02
2.03
2.04
2.06
2.07
2.08
2.09
2.09
2.10
2.11
2.12
1.94
1.95
1.96
1.97
1.98
1.99
2.00
2.01
2.02
2.03
2.04
2.04
1.88
1.89
1.90
1.91
1.91
1.92
1.93
1.94
1.95
1.96
1.96
1.97
1.82
1.83
1.84
1.84
1.85
1.86
1.87
1.88
1.88
1.89
1.90
1.90
1.76
1.77
1.78
1.79
1.79
1.80
1.81
1.82
1.82
1.83
1.84
1.84
1.71
1.72
1.73
1.73
1.74
1.75
1.75
1.76
1.77
1.77
1.78
1.78
1.66
1.67
1.68
1.68
1.69
1.70
1.70
1.71
1.71
1.72
1.72
1.73
1.62
1.63
1.63
1.64
1.64
1.65
1.65
1.66
1.66
1.67
1.67
1.68
1.58
1.58
1.59
1.59
1.60
1.60
1.61
1.61
1.62
1.62
1.63
1.63
1.54
1.54
1.55
1.55
1.56
1.56
1.57
1.57
1.58
1.58
1.58
1.59
1.50
1.50
1.51
1.51
1.52
1.52
1.53
1.53
1.53
1.54
1.54
1.55
1.46
1.47
1.47
1.48
1.48
1.49
1.49
1.49
1.50
1.50
1.50
1.51
1.43
1.43
1.44
1.44
1.45
1.45
1.45
1.46
1.46
1.46
1.47
1.47
1.40
1.40
1.41
1.41
1.41
1.42
1.42
1.42
1.43
1.43
1.43
1.43
1.37
1.37
1.38
1.38
1.38
1.38
1.39
1.39
1.39
1.40
1.40
1.40

1.34
1.34
1.35
1.35
1.35
1.35
1.36
1.36
1.36
1.37
1.37
1.37
1.31
1.32
1.32
1.32
1.32
1.33
1.33
1.33
1.33
1.34
1.34
1.34
1.29
1.29
1.29
1.29
1.30
1.30
1.30
1.30
1.31
1.31
1.31
1.31
1.26
1.26
1.27
1.27
1.27
1.27
1.28
1.28
1.28
1.28
1.28
1.28
1.24
1.24
1.24
1.24
1.25
1.25
1.25
1.25
1.25
1.26
1.26
1.26
1.22
1.22
1.22
1.22
1.22
1.22
1.23
1.23
1.23
1.23
1.23
1.23
1.19
1.20
1.20
1.20
1.20
1.20
1.20
1.21
1.21
1.21
1.21
1.21
1.17
1.18
1.18
1.18
1.18
1.18
1.18
1.18
1.18
1.19
1.19
1.19
1.15
1.15
1.16
1.16
1.16
1.16
1.16
1.16
1.16
1.16
1.17
1.17
1.13
1.14
1.14
1.14
1.14
1.14
1.14
1.14
1.14
1.14
1.14
1.15
1.12
1.12
1.12
1.12
1.12
1.12
1.12
1.12
1.12
1.12
1.12
1.13
1.10
1.10
1.10
1.10
1.10
1.10
1.10
1.10
1.10
1.11
1.11
1.11
1.08
1.08
1.08
1.08
1.08
1.08
1.09
1.09
1.09
1.09
1.09
1.09
1.07
1.07
1.07
1.07
1.07
1.07
1.07
1.07
1.07
1.07
1.07
1.07
1.05
1.05
1.05
1.05
1.05
1.05
1.05
1.05
1.05
1.05
1.05
1.05
1.03
1.03
1.03
1.04
1.04
1.04
1.04
1.04
1.04
1.04
1.04
1.04
1.02
1.02
1.02
1.02
1.02
1.02
1.02
1.02
1.02
1.02
1.02
1.02
1.01
1.01
1.01
1.01
1.01
1.01
1.01
1.01
1.01
1.01
1.01
1.01
4.1 4.2 4.3 4.4 4.5 4.6 4.7 4.8 4.9 5.0 5.1 5.2

5.3
5.4
5.5
5.6
5.7
5.8
5.9
6.0
6.1
n
419.66
433.43
447.33
461.35
475.50
489.76
504.15
518.65
533.27
1
82.69
84.67
86.64
88.62
90.60
92.58
94.56
96.54
98.52
2
37.97
38.71
39.46
40.20
40.93
41.67
42.40
43.13
43.86
3
23.21
23.61
24.00
24.39
24.77
25.16
25.54
25.92
26.30
4
16.32
16.56
16.81
17.05
17.29
17.53
17.76
18.00
18.23
5
12.45
12.62
12.78
12.95
13.11
13.28
13.44
13.60
13.76
6
10.01
10.13
10.25
10.37
10.49
10.61
10.73
10.85
10.96
7
8.34
8.44
8.53
8.63
8.72
8.81
8.90
8.99
9.08
8
7.15
7.22
7.30
7.37
7.44
7.52
7.59
7.66
7.73
9
6.25
6.31
6.37
6.43
6.49
6.55
6.61
6.66
6.72
10
5.55
5.60
5.65
5.70
5.75
5.80
5.85
5.89
5.94
11
4.99
5.03
5.08
5.12
5.16
5.20
5.24
5.28
5.32
12
4.54
4.57
4.61
4.65
4.68
4.72
4.75
4.78
4.82
13
4.16
4.19
4.22
4.26
4.29
4.32
4.35
4.37
4.40
14
3.84
3.87
3.90
3.93
3.95
3.98
4.00
4.03
4.05
15
3.57
3.60
3.62
3.65
3.67
3.69
3.71
3.74
3.76
16
3.34
3.36
3.38
3.40
3.42
3.44
3.46
3.48
3.50
17
3.14
3.16
3.17
3.19
3.21
3.23
3.25
3.26
3.28
18
2.96
2.97
2.99
3.01
3.02
3.04
3.06
3.07
3.09
19
2.80
2.81
2.83
2.84
2.86
2.87
2.89
2.90
2.91
20
2.66
2.67
2.68
2.70
2.71
2.72
2.74
2.75
2.76
21
2.53
2.54
2.56
2.57
2.58
2.59
2.60
2.61
2.63
22
2.42
2.43
2.44
2.45
2.46
2.47
2.48
2.49
2.50
23
2.31
2.32
2.33
2.34
2.35
2.36
2.37
2.38
2.39
24
2.22
2.23
2.24
2.25
2.25
2.26
2.27
2.28
2.29
25
2.13
2.14
2.15
2.16
2.16
2.17
2.18
2.19
2.20
26
2.05
2.06
2.07
2.07
2.08
2.09
2.10
2.10
2.11
27
1.98
1.99
1.99
2.00
2.01
2.01
2.02
2.03
2.03
28
1.91
1.92
1.92
1.93
1.94
1.94
1.95
1.95
1.96
29
1.85
1.85
1.86
1.87
1.87
1.88
1.88
1.89
1.89
30
1.79
1.80
1.80
1.81
1.81
1.82
1.82
1.83
1.83
31
1.74
1.74
1.75
1.75
1.76
1.76
1.76
1.77
1.77
32
1.68
1.69
1.69
1.70
1.70
1.71
1.71
1.72
1.72
33
1.64
1.64
1.65
1.65
1.65
1.66
1.66
1.67
1.67
34
1.59
1.60
1.60
1.60
1.61
1.61
1.61
1.62
1.62
35
1.55
1.55
1.56
1.56
1.56
1.57
1.57
1.57
1.58
36
1.51
1.51
1.52
1.52
1.52
1.53
1.53
1.53
1.54
37
1.47
1.48
1.48
1.48
1.48
1.49
1.49
1.49
1.50
38
1.44
1.44
1.44
1.45
1.45
1.45
1.45
1.46
1.46
39
1.40
1.41
1.41
1.41
1.41
1.42
1.42
1.42
1.42
40

1.37
1.37
1.38
1.38
1.38
1.38
1.39
1.39
1.39
41
1.34
1.34
1.35
1.35
1.35
1.35
1.35
1.36
1.36
42
1.31
1.32
1.32
1.32
1.32
1.32
1.32
1.33
1.33
43
1.29
1.29
1.29
1.29
1.29
1.29
1.30
1.30
1.30
44
1.26
1.26
1.26
1.26
1.27
1.27
1.27
1.27
1.27
45
1.24
1.24
1.24
1.24
1.24
1.24
1.24
1.24
1.25
46
1.21
1.21
1.21
1.22
1.22
1.22
1.22
1.22
1.22
47
1.19
1.19
1.19
1.19
1.19
1.19
1.20
1.20
1.20
48
1.17
1.17
1.17
1.17
1.17
1.17
1.17
1.17
1.17
49
1.15
1.15
1.15
1.15
1.15
1.15
1.15
1.15
1.15
50
1.13
1.13
1.13
1.13
1.13
1.13
1.13
1.13
1.13
51
1.11
1.11
1.11
1.11
1.11
1.11
1.11
1.11
1.11
52
1.09
1.09
1.09
1.09
1.09
1.09
1.09
1.09
1.09
53
1.07
1.07
1.07
1.07
1.07
1.07
1.07
1.07
1.07
54
1.05
1.05
1.05
1.05
1.05
1.06
1.06
1.06
1.06
55
1.04
1.04
1.04
1.04
1.04
1.04
1.04
1.04
1.04
56
1.02
1.02
1.02
1.02
1.02
1.02
1.02
1.02
1.02
57
1.01
1.01
1.01
1.01
1.01
1.01
1.01
1.01
1.01
58
5.3
5.4
5.5
5.6
5.7
5.8
5.9
6.0
6.1

9/11/2013 rdb
New freshwater RPA based on 95% probability/95% confidence
Statistically 58 points are the maximum number of points allowed under this RPA program. Data fields w
Additional messages will appear to alert user if more than 58 data points were enter and no predicted val
All worksheets are "Protected"
The "mf calculator" is password "Protected"
OTHER CHANGES FROM PREVIOUS RPA PROGRAM:
A. When Model is applied (Check box activated):
1) assumes only chroinc dilution known
2) assumes user will insert appropriate flow values for "7Q10s (cfs)", " 7Q10w (cfs)", "30Q
3) automatically assigns the entered chronic IWC % to the "IWC @ 7Q10s", "IWC @ 7Q10,
3) "1Q10s (cfs)" automatically defaults to no acute dilution, acute IWC = 100% ,"IWC @ 1C
B. When Model is not applied (Check box NOT activated):
1) assumes user will insert appropriate flow values for "7Q10s (cfs)", "7Q10w (cfs)", "30Q
3) automatically calculates chronic -based IWC % for the "IWC @ 7Q10s", "IWC @ 7Q10w
3) "1 Q10s (cfs)" is automatically calculated bases on entered " 7Q10s (cfs)" flow
4) automatically calculates acute -based IWC% for the "IWC @ 1Q1Os" value used in acute
C. When paremeter's "Impaired?" check box is activated:
1) automtically activtes the "IMPAIRED" message alert on the "RPA" page for that paramet(
2) does NOT make any automatic adjustements to WQS calculations
NOTE: If new or expanding discharge and receiving stream impaired, will need to evaluate i
10/30/2013 rdb
1) Amended "ERR" alert on data sets entreies to activate if "<" entered but no value entered, does not E
2) Added new calculation feature to count nondetects when both "<" and a value are entered for each da
3) Amended "Comments" drop down menu - per Juile
4) Turned the Chronic toxicity concentration message off on the RPA page - per Julie
2/10/14:
ON "data" page changed highlighted area from blue shades to gray
5/2/14 rdb
1) Increased rounding factor on all calculated IWC% to 7 decimals
2) Increased display for all calkculated to 6 decimals places.
5/5/14 rdb
Increased rounding factor on all calculated IWC% to 9 decimals
5/21/14 rdb
Removed ROUND function from all IWC% calculations
7/31/14 rdb
Moved RPA page tile blocks down one row so header text was separated
9/9/15: COMPLETED REVISIONS FOR METAL TRANSLATOR FEATURE
1) Added tabs for "HUC Hardness" (lookup table for HUC hardness values), "Hardness Equations" (sums
(calcution sheet for metal translator, impacted chronic and acute wqs)
2) Revised "Input" page Table 1:
- New user input for "8 Digit HUC Number" uisng drop down menu for lookup HUC Hardness, required ei
- New display only for calculated "Effluent Hardness (Median)" including conditional method for info displ�
- New display only for designed "HUC Hardness (Median)" incuding conditionla method for info display, b
- New display only for calculated "Combined Hardness Chronic" for metal translator application, brown h
- New display only for calculated "Combined Hardness Acute" for metal translator application, brown higl-
- Assigned name for "HUC Number"
3) Revised "Input" pade Table 2:
- Removed "Impaired 7' column, conditional display, references
- Added new column for "WQS" designation incuding assigning applicable WQS where fixed
- Added new error message "CHECK WQS", conditonal control based on "WQS" entry for Cadmium, Ch
- Revised text in error message
- Added new brown highlight "Metal Translator Data Entry" label box
- Removed Par01 "Arsenic" line

- Revised Par02 " Arsenic" line to reflect Human Health and Water Supply criterion, Chronic = 10 mg/L, E
- Revised Par04 "Cadmium" line:
a) "WQS" input with drop down menu to select applicable criterion
b) "Chronic" and "Acute" inputs to display calculated metal translator values including condit
c) "Modifier" input display only based on "WQS" selection including conditional method for it
d) Conditonal controls to activate error nessages, brown highlight
- Revised Par05 "Chloride (AL)" line:
a) "WQS" input with drop down menu to select applicable criterion
b) "Chronic" display only for applicable value including conditional method for info display ba
c) "Modifier" input display only based on "WQS" selection including conditional method for it
d) "Name" display only based on "WQS" selection including conditional metdod fro info displ
e) Conditonal controls to activate error nessages
- Revised "Chromium, Total" line:
a) Removed Par08 label
b) "Chronic" and "Acute" inputs to display calculated metal translator values, no rounding
c) brown highlight
- Added new "Chromium III" line:
a) Assigned applicable text in "WQS', "Type", Modifier", Units"
b) "Chronic" and "Acute" inputs to display calculated metal translator values, no rounding
c) brown highlight
- Added new Par08 "Chromium VI" line:
a) Assigned Par08 label, applicable text in "WQS', "Type", Modifier", Units"
b) "Chronic" and "Acute" inputs to display calculated metal translator values, no rounding
c) brown highlight
- Revised Par09 "Copper (AL)" line:
a) "Chronic" and "Acute" inputs to display calculated metal translator values, no rounding
b) brown highlight
- Revisd Par12 "Lead" line:
a) "Chronic" and "Acute" inputs to display calculated metal translator values, no rounding
b) brown highlight
- Revised Par14 "Molybdenum" lime:
a) "WQS' input with drop down menu to select applicable criterion
b) "Chronic" display only for applicable value including conditional method for info display ba
c) "Modifier" input display only based on "WQS' selection including conditional method for it
d) Conditonal controls to activate error nessages
- Revised Par15 "Nickel" line:
a) "WQS' input with drop down menu to select applicable criterion
b) "Chronic" and "Acute" inputs to display calculated metal translator values including condit
c) "Modifier" input display only based on "WQS" selection including conditional method for it
d) Conditonal controls to activate error nessages, brown highlight
- Revised Par17 "Silver (AL)" line:
a) "Chronic" and "Acute" inputs to display calculated metal translator values, no rounding
b) brown highlight
- Revised Par18 "Zinc (AL)" line:
a) "Chronic" and "Acute" inputs to display calculated metal translator values, no rounding
b) brown highlight
3) Revised "Data" page:
- Revised Par01 "Arsenic" entry, text, and calculations ("V) - all effluent hardness data to be entered in t
a) Reference to Par01 "Arsenic" removed
b) New label "Effluent Hardness (monthly average)" added
c) "Mult Factor =" and "Max. Pred Cw" removed, text and calcuation
d) "10% value" and "Median value" added, text and calculation including conditional method
e) Assigned name "Effluent —Median" and "effluent _10" to calculated values
f) PQL condition removed from calculation method for data displayed
4) Revised "RPA" page:

- Removed all features assocaited with "Impairment"
- Added new display only for calculated "COMBINED HARDNESS (mg/L)", Chonic and Acute, conditiona
- Revised "Receiving Stream" display to include selected HUC Number in text
- Removed unused display features for WET % (previouly hidden)
- Revised "Arsenic" lines:
a) Par01 "Arsenic" line removed
b) Par02 "Arsenic" references used for display to calculate "Acute" and Chronic" allowable
- Revised "Cadmium", "Chromium VI", "Copper (AL)", "Lead", "Nickel", "Silver (AL)", "Zinc (AL)" Ilines:
a) "NC WQS/Chronic" and 1/2 FAV/Acute" conditional method revised for info display, no ro
b) "Allowable Cw" Acute" and "Chronic" conditional metfhod revised fro info display inculdinc
5) Revised "Dss to Total Metal Hardness Calculator" page
- Assigned names for:
a) "CdMAE_AC" - Cadmium calculated metal translator Acute value
b) "CdMAE_CH" - Cadmium calculated metal translator Chronic value
c) "CuMAE_AC" - Copper calculatd metal translator Acute value
d) "CuMAE_CH" - Copper calculated metal translator Chronic value
e) "Cr—Total—AC" - Total Chromium calculated meatl translator Acute value
f) "Cr—Total—CH" - Total Chromium calculated metal translator Chronic value
g) "CrIIIMAE_AC" - Chromium III calculated metal translator Acute value.
h) "CrIIIMAE_CH" - Chromium III calculated metal translator Chronic value
i) "CrVIMAE_AC" - Chromium VI calculated metal translator Acute value
j) "CrVINAE_CH" - Chromium VI calculatd metal translator Chronic value
k) "PbMAE_AC" - Lead calculated metal translator Acute value
m) "PbMAE_CH" - Lead calculated metal translator Chronic value
n) "NiMAE_AC" - Nickel calculated metal translator Acute value
o) "NiMAE_CH" - Nickel calculated metal translator Chroniv value
p) "AuMAE_AC" - Silver calculated metal translator Acute value
q) "AuMAE_CH" - Silver calculated metal translator Chronic value
r) "ZnMAE-AC" - Zinc calculated metal translator Acute value
s) "ZnMAE_CH" - Zinc calculated metal translator Chronic value
t) "tss" - assigned TSS harness factor
u) "CHA" - calculated combined acute hardness value
v) "CHC" - calculated combined chronic hardness value
- Added conditional methods to formulas for info display and to incorporate names, no rounding
6) Set up passwortd to protect all pages 'rpa2015'
1/12/16 ADDED ARSENIC AQUATIC LIFE PARAMETER BACK TO ACTIVE RPA EVALUATION
1) Inserted "Aresenic, Aquatic Life, C, 50, FW, N/A, pg/L" in first row "INPUT" Table 2, Par01
2) Updated program names to reflect addition of new Arsenic Aquatic Life parameter
3) Inserted "Arsenic" Aquatic Life parameter and cell programming in Arsenic section "RPA" as Chronic
4) Amended labels on "Data" to show H for hardnes and Par01-Par22 for paremeters
1/12/16 REVISED IWC CALCULATIONS TO SHOW FULL DISPLAY on "RPA"
1) Reformatted IWC calculation cells to show caculated value as general (number value will always be di
2) Revised IWC calculation formula to x by 100 to mimic %
3) Revised IWC calculation labels to include "%"
4) Revised all calculations using IWC values "Acute", "Chronic" to divide by 100 to correct for IWC % val
1/12/16 REVISED SPREADSHEET TO INDICATE NO DETECT AND MDL
1) Revised "Data" Par01-Par22 Max Value cell conditional statement to display "NO DETECTS" when do
2) Revised "RPA" all parameters Max Pred CW cell formatting to display "NO DETECTS" when require
3) Revised "RPA" alert message (under Chronic labels) conditional statement to display "Max MDL = <2
4) Revised "RPA" drop menu to add "No detects" to list and display
1/12/16:

Corrected formula error in mf formula Par01 to use corrected data set ("Data")
Revised "RPA" Cadmium, Copper, Lead, Nickel, Silver, Zinc Acute and Chronic cell conditional statemer
1 /21-29/16:
1) Expanded parameter list and program features to add two additional parameters, (Par08) "Chromium
new corresponding RPA evalutaion, non -detect evaluation, formulas for each new data input section; a
to new assigned name (Par10 - Par24), data set (_Data08 - _Data24), non -detects (_ND08 - _ND24).
2) For consistency rearranged display, "Input" & "RPA" tabs, to be "Chromium III", "Chromium VI", "Chroi
3) Corrected Arsenic - Aquatic Life, Berylium Chronic and Acute values on "Input" tab to be exported fror
4) Revised "Input' tab HUC Hardness (median) display conditional formula to display "default 25 mg/L (H
5) Revised combined hardness acute (CHA) and combined hardness chronic (CHC) conditional formula:
6) Revised "RPA" tab Chromium, Total Reasonable Potential Results section to remove Acute and Chroi
7) Revised "RPA" tab Chromium III and Chromium VI Reasonable Potential Results sectons to remove c
formulas that reference Chromium, Total display and data.
NOTE: All RPA evaluation data is generated on each parameter "Data" section and imported to that pare
8) Revised "RPA" tab Acute and Chronic conditional formulas for active parameters to display either "IW
9) Removed label from "Input' tab.
10) Corrected chlorinated list ("Input' & "Data" tabs) lists, now shows correct 2,4,6-trichlorophenol for Me
See task notes
2/3/1 6:
Revised "input'page model feature to
a- Add new model 1 Q10S input cell that is visible on;y when model feature is activated
b- Revise cell formula 1 Q10s (cfs) to display 1 Q10s flow when model feature activated or calculate from
c- Revised instructions narrartive that is visible only when model feature is activated
2/9/1 6:
Revised "input' page Effluent Hardness (Median) cell formula to display "default 99 mg/L (Efflunet Hard r
Revised "data" page Effluent Hardness (Median) cell formula to display 99 whenstream class is WS and
Added new display messages to "rpa" page that are visible only when the steam class is water supply
2/16/16:
1) Revised "Diss to Total Metal Calculator" page:
added new cells to display actual calculated Effluent & HUC Median values and to display "Apply Water
exceeds 99.999 mg/L)
revised the existing calculation input/display cells for Effluent & HUC Hardness Median to show the applii
a- If HUC Hard Med = NA or less than 25 mg/L then default HUC Hard Med to 25 mg/L
b- If Effluent Hard Med less than 25 then default Effluent Hard Med to 25 mg/L
c- If stream class is WS and Effluent Hard Med is greater than 99.9999 mg/L then default El
2) Revised "input' page dipplay HUC Hardness (Median) to show NA when HUC table value is NA.
2/19/16:
Added new WS WQC button to "input' page, activates effluent hardness to apply WS WQC standards, d
Added Nickel WS parameter to "input' page
Added Nichel WS to "rpa" page, revised both Nickel parametesr to share commom data, Nickel WS has
Set up both Nickel Par17 & Par18 to use same data entries
Changed Par22-25 modifier cells to be set automtically based on WQS entry.
Changed display font color phenols, chlorinared phenols menus
2/22/16:
Make text changes per Julie direction.
2/24/16:
Added to " Diss to Total Metal Calculator" page:

1) Comment section for PERCS info or other to allow user to add commentary
2) Added Facility name to display based on input page
3) Added NPDES permit# to display based on input page
4) Set up new Name "PERCS_page" as print area for table and other PERCS info for GOTO use.
NOTE: User can either highlight desire print area or use GOTO feature to set up desired print arae. Whe
3/18/16:
Removed HUC table and HUC hardness lookup features from calculations and program.
Note: HUC number is an available option on the INPUT as an informational input only to use as a display
Added Upstream Hardness calculation feature using measured upstream data:
1) INPUT display shows "Upstream Hardess" status and how upstream data is applied
2) DATA has new Upstream Hardness input sheet to accept upstream hardness data used to calculate r
3) Diss to Total Metal Calculator determines which upstream hardness to apply, if the number of data en
10th percentile value is used. Anytime the applied upstream hardness is less than 25 mg/L then a defa
4/26/16:
Per Julia want to use average values for both the effluent and upstream hardness calculations. Defaults
1) Changed all upstream hardness median calculations to average calculations.
2) Removed any greater than 99.999 defaults from upstream hardness conditional statements. Upstrean
3) Changed all effluent hardness median calculations to average calculations. Conditional statements for
4) Any conditional statement referring to median hardness were revised.
5) Removed "(AL)" from parameter labels as no longer applicable.
6) Renamed RPA to describe features
4/27/16:
Per Julia when WS is being applied, the combined acute and chroinc hardness needs to default to 100 if
1) Set up new cells to calculate combined acute and chronic hardness, defined cells as program names,
2) Revised the conditional statemenst for CHC and CHA to default to 100 if ACCH & ACAH exceed 100 �
3) Revised INPUT page Combined Acute and Chronic display condtitional statements to indicate default:
4) Revised RPA page Combined Hardness Acut and Chronic displays conditional statemenst to indicate
4/28/16:
Fixed programming errors so "NO DETECTS" display feature on RPA page for Nickel and Chromium VI
Revised RPA page drop menu 'Recommended Action" list to remove RP Action Level text and change "I
Added statement to 2B .0500 RULES page "4/28/16: Note Action Level designation no long allowed per 1
4/29/16:
Added ROUND function to conditional statements on INPUT page hardess displays to limit hardness vale
Revised upstream default conditional factor to 24.9999 on INPUT page to allow actual upstream hardne:
5/6/1 6:
Removed less than 25 mg/L default from all effluent and upstream hardness conditional programming
5/11/16:
Added new conditional display to Total Chromium Pred Cw box RPA page to compare Total Chromium c
Added new conditional display to Total Chromium Allowable Cw box RPA page to indicate maximum Tot
6/13/16:
Revised title block text RPA tab to state "NC STANDARDS OR EPA CRITERIA", removed "NC WQS" frc
Corrected INPUT tab to align Dats Source(s) text box at top.
6/14/16:
Revised conditions for calculated combined hardness acute and chroinc to default to 400 mg/L if calculal
Revised conditions for INPUT page display combined hardness acute and chroinc to indicate when defaL
Corrected label on DISS ... page to indicate average for effluent and upstream hardness

7/13/16:
Revised Model input feature when activated to calculate Model 7Q10s (cfs) flow based on entry of Qw, IV
User will need to enter calculated 7Q10s displayed in Model narrative box to Table 1 7Q10s, (cfs) entry I:
Revised narrative in Model narrative box with new instructions, new messages to alert user on actions nE
Remove conditions and features assocaited with entry of Model Acute IWC % .
8/30/16:
Revised conditional note statement on RPA tab for Total Chromium to correct program error.
10/20/16:
Revised label display for Fcailty discripition on "Diss to Total Metal Calculator".sheet to list Outfall #.
9/7/2017
Revised chromium drop down to reflect new < 5ug/L PQL.
11/21/17:
(1) Revised RPA evaluation to assign C.V. (default) = 0.6 when only a sinlgle data entry inade for any pai
(2) Revised RPA evaluation to always calculate and display "Max Pred Cw" value whenever there are 1 t
(3) Revised rpa page to show each parameters automatic display message "NO DETECTS" independen
(4) Revised Total Chromium < 50 data counter to start count when the entered data point < 4.9999. (hidc
11 /29/17:
(1) Revised RPA page (C.V. (default? Message to
(2) Corrected DATA page H2 message to show ... UPSTREAM...
(3) Removed (1) from RPA page Type label
11 /30/17:
Revised Dissolved Metals and Total Metals Table label descriptions on "DSS to Total Metal Calculator" 1
12/12/17:
Revised conditional statements DATA tab to allow appllication C.V. (default) for number of data values 1
1 /20/18:
1) Revised "RPA" Receiving Stream display to only show the Stream name and if entered the HUC numk
2) Increased RPA page Qw display decimal places

2 (cfs)", "QA (cfs)" to define chronic dilution in terms of "IWC %", "IWC %" is the same for all stream flows
2 (cfs)", "QA (cfs)" , "Flow Qw (MGD)" for chronic IWC % calculations, IWC % will vary according to flows

lisplay of values for n, #Det, Max Pred Cw, area blank except for display features from added condtional
Vled = <actual value> mg/L)" when stream class is WS and Effluent Hard Med is greater than 99.999 mg/L

tries exceed 30 then the average value is used, if the number of data enties are less than 30 then the

rameter (see data page). On data page the parameter will diplay Std..Dev. = "N/A" when only a single data entry m;
len column of data page). Revised Total Chromium automatic diplay message on rpa page to reflect new 5 pg/I crib

ade
aria

Date: 5/29/2024
Enter data onto "Table 1" under the Input Sheet and enter
"Effluent Hardness" under the Data Sheet.
In accordance with 40 CFR 122.45 (c ), permits are, have and
must be written as total metals.
This calculator has been inserted into the RPA to calculate Total
Metal allowable allocations once Table 1 has been completed
(Input Sheet) and Effluent hardness has been entered (Data
Sheet).
1) Following the spreadsheet from left to right. First
the allowable allocations for the dissolved metals will
appear for all the metals listed once Table 1 is complete and
effluent hardness entered. Use a default value of 25 mg/L if
no hardness data is available. Second, the
Dissolved Metal allocations are divided by the Translators to
determine the Total Metals that can be allocated to the
Permittee. These Total Metals values are automatically
inserted into Table 2 and are the allowable Total Metal
allocations determined for the Permittee prior to allowing
for dilution. See Input sheet Table 2. The final acute and
chronic values shown under the RPA sheet are the Total
Metal values listed in Table 2 divided by the acute and
chronic IWC, respectively.
2) The Translators used in the freshwater RPA are the Partition
Coefficients published by US EPA in 1984. They are TSS
dependent equations and can be found listed with the WQS
hardness dependent equations under the sheet labeled
Equations. A fixed TSS value of 30 mg/L is used to calculate
the Translator values.
3) Pretreatment Facilities— PERCS will need a copy of the
Dissolved to Total Metal Calculator spreadsheet and the
RPA sheet along with the Final Permit. Pretreatment
Facilities are required to renew their Headwords Analysis
after renewal of their permits. Since all their metal
allocations are likely to change PERCS needs to see any new
metal permit limits and the allowable allocations for the
dissolved metals to assess Maximum Allowable Headworks
Loading (MAHL) numbers for each metal based on the
Combined Hardness values used in the permit writers RPA
calculations.
4) For Cadmium, Lead, Nickel, Chromium and Beryllium, if all
the effluent sampling data for the last three to five years
shows the pollutant at concentrations less than the Practical
Quantitative Level (PQL), it is not likely a limit or monitoring
will be put in the permit. However, if the estimated NPDES
permit limit is less than the Practical Quantitative Limit
(particularly, Cadmium and Lead) and the pollutant is
believed to be present, to assess compliance with the new
standards and for future permit limit development,
monitoring for the pollutant will be required. If the facility is
monitoring for the pollutant in its Pretreatment LTMP, no
monitoring is needed in the permit.
5) For monitoring and compliance purposes if Total Chromium
'Y: Venator Chemicals, LLC - Harrisburg Plant Outfall
PERMIT: NC0006351 Dissolved to Total Metal Calculator
In accordance with Federal Regulations, permit limitations must be written as Total Metals per 40 CFR 122.45(c)
Recaiving
Stream Stream
Hec. Jtream
NHUtJ
Total Suspende0
Sdids
ComDlnetl
Hardness
ComDlnetl
Hardness
Instream
Wastexater
Instmem
Wastewater Upstream
Hartlness
��Reci
su mer 7Q10
1010
FlowLimn
-FNetl Value-
chronic
Acute
Concentration
ConcenVatlon Hartlness
Average(mg4)
Average
7010(CFS) (MGD)
MGD
MGD
(mg/L)
(mg/L)
(mg/L)
(Chronic)
(Acute)
(mi
4.0000 1 2.5806
2.1548
0.0250
10
153.819
164.250
0.9595
1.1469 100.42
5666
Upstream Hard Avg (mg/L) =
100.42
EFF Hard Avg (mg/L) =
5666
Dissolved Metals Criteria
Total Metal Criteria
Total Metal=
COMMENTS (identify parameters to PERCS Branch to maintain in facility's LTMP/STMP):
PARAMETER
after applying hartlness
naron
Translators- using
Default Partition
Olssolved Mesl+Tan1—
Chranic Acute
Coefficients
I Chmoi,
I Acute
0.202 521.37
1.000 11.00
N/A
0.348 37.22
0.184 21.80
0.432 173.17
25
1.000 0.06
0.2881 590.84
-di ... 1,,d metal standard. See 15A NCAC 0211.0211 for more information.
= hardness -dependent dissolved metal standard. See 15A NCAC 02B .0211 for more information.
= based upon measurement of total recaveable metal. See 15A NCAC 028 .0211 far mare informadon.
The Human Health standard for Nickel in Water Supply Streams is 25 ni which is Toml Recoverable metal standard.
The Human Health standard for Arsenic is 30 pg/L which is Total Recoverable metal standard.
ACAH 164.2502
ACCH 153.8193

Dissolved Metals & H
I. How to Determine Hardness for use
HARDNESS - Use 25 mg/L, expressed as C
OR
To determine a Hardness value for permit
Hardness - (Hardness instream(a)I IT
(mass balance)
(a) Use the median instream Hardness ve
(b) For the purpose of this estimation, use the
II. To Develon Dissolved Metal con
Table A: Dissolved Freshwater Standards for Hat
Metal
Cadmium, Acute
Cadmium, Acute (Trout Waters)
Cadmium, Chronic
Chromium III, Acute
Chromium III, Chronic
Copper, Acute
Copper, Chronic
Lead, Acute
Lead, Chronic
Nickel, Acute
Nickel, Chronic
Silver, Acute
Silver, Chronic
Zinc, Acute
Zinc, Chronic
Complete information on all the proposed S
US EPA Translators
using Default Partition I
Translator equation using Default Partition Coeff
Kpo and (X are constants that express the equili
A default value of 10 mg/L Total Suspended S
Table A contains the Default Partition Coef
Table B contains the calculated translators
TABLE A. Default Partition Coefficients
Metal (1
Cu
Zn
Pb
Cr (III) 1

Cd
Ni
(1) Delos, C.G., et al. Technical Guidance for Perfor
(2) Linear partition coefficients shall not apply to thi
TABLE B. US EPA Translators
PARAMETER
Cadmium
Chromium III
Chromium VI
Chromium, Total
Copper
Lead
Nickel
Silver
Zinc

ardness Determination
v. 5/ 27/ 2010
with Dissolved Freshwater Standards for Permitting Purposes
aCO3 or Ca+Mg, as the default Hardness
limit development, use the following equation:
is/L * 7Q10, MGD)+(Hardness effluent(b), mg/L* Plant flow, MGD)
(7Q10, MGD + Plant flow, MGD)
flue of the ambient 8-digit HUC data collected by the Division of Water Quality. To find the 8-digit HUC h:
facility's median effluent Hardness value, if available. The Division will request the permittee to sample effluent har
Icentrations for permitting purposes use the Freshwater Standards for Hardness De
-dness Dependent Metals
Ng/L
{1.136672-[In hardness](0.041838)} eA{0.9151 [In hardness]-3.1485}
{1.136672-[In hardness] (0.041838)} eA{0.9151[ln hardness]-3.6236}
{1.101672-[In hardness](0.041838)} e^{0.7998[ln hardness]-4.4451}
0.316 - e^{0.8190[ln hardness]+3.7256}
0.860 • e^{0.8190[ln hardness]+0.6848}
0.960 - e^{0.9422[ln hardness]-1.7001
0.960 • e^{0.8545[ln hardness]-1.702}
{1.46203-[In hardness] (0.145712)} • e^{1.273[ln hardness]-1.460}
{1.46203-[In hardness] (0.145712)} • e^{1.273[ln hardness]-4.705}
0.998 - e^{0.8460[ln hardness]+2.255}
0.997 • e^{0.8460[ln hardness]+0.0584}
0.85 - eA{1.72[ln hardness]-6.59}
Not applicable
0.978 - e^{0.8473[ln hardness]+0.884}
0.986 • e^{0.8473[ln hardness]+0.884}
urface Water Quality Standards can be viewed at: http://h2o.enr.state.nc.us/csu/trirev SW.html.
Coefficients (DPQ
v. 6/2/2010
Icients = 1
[1 + (Kpo * TSS (1+a) * 10-6)]
brium relationship between dissolved and adsorbed forms of metals.
olids (TSS) will be used.
ficients for the equation.
using the default partition coefficients for streams.
STREAMS
Kpo
a
1.04E+06
-0.7436
1.25E+06
-0.7038
2.80E+06
-0.8
3.36E+06
-0.09304

4.00E+06-1.1307
4.90E+05-0.5719
ming Waste Load Allocations. Book II: Streams and Rivers. Chapter 3: Toxic Substances, For the U.S. EPA. (EPA-440/4-84-022)
e Chromium VI numerical criterion. The approved analytical method for Chromium VI measures only the dissolved form. Therefore
US EPA Translators
Using stream Default Partition Coefficients
T55 = 10 mg/L
0.252
0.202
1
N/A
0.348
0.184
0.432
1
0.288

dness once/month and submit one to two years of data with the permit renewal application. If no effluent hardness data is subr

Example for Cadmium (streams)
Given:
TSS = 10 mg/L
Kpo = 4.00E + 06
a =-1.1307
Translator = 1
[1 + (Kpo * TSS 10-6)]
[1 + (4.00X106 * 101-1.1307) * 10-6)]
— 1
[1+2.960465]
= 0.252

nitted, a default of 25 mg/L will be applied.

Copper nitrate annual production rate Ib/s year
2019
372810
2020
152987
2021
177434
2022
114954
2023
242602
average
212157.4
days of prudction
9.32025
3.824675
4.43585
2.87385
6.06505
5.303935 rounded up to 6 days

daily average
35359.56667
daily max Monthly Average
Copper 0.11 0.035