NC0089621_Novozymes Addendum to BAT Analysis_20180312

It Dewberry.
Addendum to Best Available
Technology Analysis
Novozymes North America, Inc.
February 26, 2018
SUBMITTED BY:
Dewberry Engineers Inc.
2610 Wycliff Road
Suite 410
Raleigh, NC 27607
SUBMITTED FOR:
Novozymes North America,
Inc.
SUBMITTED TO:
North Carolina Department of
Environmental Quality

TABLE OF CONTENTS
1. Introduction...................................................................................................... 2
2. Alternative Treatment Technologies............................................................... 4
3. Treatability Testing........................................................................................... 5
4. Cost Analysis......................................................................................................8
5. BAT Limit Determination...................................................................................9
6. Conclusion.......................................................................................................12
List of Tables
Table 1. Treatment Alternatives
Table 2. Nitrogen Speciation Parameters
Table 3. 95`h Percentile Reactor Effluent Nitrogen Speciation
Table 4. Equivalent Annual Costs
Table 5. Calculated Effluent Total Nitrogen
Table 6. Equivalent Annual Costs Normalized to Nitrogen Removed
Table 7. North Carolina Municipal Surcharge Rates
Table 8. Proposed Total Nitrogen Effluent Limit
Table 9. Normalized Nitrogen Removal Costs
List of Figures
Figure 1. TN Effluent Results Comparison
List of Appendices
Appendix A. Reactor Effluent Certified Lab Results
Appendix B. Reactor Logs and Internal Lab Analysis
Appendix C. Opinion of Probable Cost for Nitrogen Removal
41 Dewberry February26, 2018 Novozymes Addendum to Best Available Alternatives Analysis 1

1. INTRODUCTION
The Novozymes North America (Novozymes) facility in Franklinton, North Carolina is pursuing a National Pollutant Discharge
Elimination System (NPDES) permit for direct discharge to the Tar River. The NPDES direct discharge permit would serve as a
conjunctive discharge option as Novozymes intends to maintain its existing discharge options: (1) land application through
Non -Discharge Permit (WQ00028o6) and (2) indirect discharge to Franklin County's Wastewater Treatment Plant (WWTP)
via Industrial User Pretreatment (IUP) Permit 0112. As required by the NC Division of Water Resources (Division),
Novozymes has performed an Engineering Alternatives Analysis (EAA) in accordance with 15A NCAC 02H.0105(c)(2). The
EAA and NPDES applications Form 1 and Form 2D were submitted to the Division on May 26, 2o16. The option for
Novozymes to discharge additional wastewater to the Franklin County WWTP was evaluated within the EAA. Novozymes is
seeking the conjuctive discharge option as the Franklin County WWTP does not have the capacity to accept additional flow and
Novozymes is required per a Corrective Action Plan to reduce the volume of wastewater that is land applied.
Based on Novozymes' SIC Code 2869, the facility's industrial discharge is regulated under the Organic Chemicals, Plastics, and
Synthetic Fibers (OCPSF) effluent limits for Subcategory G Bulk Organic Chemicals (40 CFR 414.70). However, Novozymes'
manufacturing process is a fermentation process, and 40 CFR 414.11(e) states the provisions of 40 CFR 414 do not apply to
discharges from the manufacture of organic chemical compounds solely by fermentation processes. It should be noted that
even if the provisions of 40 CFR 414 did apply to the Novozymes facility, BAT limits are not established in 40 CFR 414
Subcategory G for nitrogen. On December 14, 2016, the Division requested that Novozymes conduct a Best Available
Technology Analysis for determination of effluent limits for total nitrogen (TN) and total phosphorus (TP). Best Available
Technology (BAT) Economically Achievable limits represent, in general, the best existing performance of treatment
technologies that are economically achievable within an industrial point source category (EPA NPDES Permit Writers' Manual,
201o, EPA-833-K-io-ooi).
Novozymes submitted a Best Available Technology (BAT) Analysis on February 28, 2017. The BAT Analysis proposed the TN
and TP limits that can be achieved by Novozymes based on an analysis of historical Novozymes wastewater treatment plant
(WWTP) effluent data and anticipated WWTP upgrades. The proposed limits were 8.8 mg/1 TN and 1.o mg/l TP.
Based upon subsequent discussions with the Division regarding the BAT Analysis, Novozymes elected to pursue treatability
testing to support development of the total nitrogen effluent limits. Novozymes and Dewberry developed a treatability testing
protocol and reviewed the protocol with the Division on June 2, 2017. The Division concurred with the proposed approach and
bench scale treatability testing was then performed at Dewberry's Raleigh, NC treatability laboratory from July 12, 2017 —
August 19, 2017.
Pursuant to the agreed upon protocol, treatability testing was performed at three design loading conditions to simulate one
treatment technology (sequencing type reactor). Sequencing continuous reactor technology was utilized as Novozymes is
currently designing a WWTP upgrade to incorporate this treatment approach. Novozymes selected this treatment technology
based on technology evaluations performed historically for the Franklinton site and the success of this treatment technology
employed at other Novozymes facilities worldwide. The technology involves a continuous flow through reactor system which
operates with sequencing aeration/mixing.
During a meeting with the Division on December 14, 2017, the Division requested Novozymes provide a narrative evaluation of
alternative treatment technology to support selection of the sequencing continuous reactor. Section 2 of this report includes a
discussion of treatment alternatives and the considerations that supported Novozymes' selection of the treatment technology
currently being designed.
This report serves as an addendum to the original BAT Analysis submitted on February 28, 2017. Total nitrogen BAT limits
proposed in this report are based on the treatability testing results, water quality standards, and the equivalent annual costs for
each design condition. The general process used to determine the BAT limits is as follows:
1. Identify achievable effluent total nitrogen limits based on water quality standards, technology limits, and treatability
testing.
2. Develop Equivalent Annual Costs for each design loading condition (e.g. alternative).
wor D ewberry February 26, 2018 I Novozymes Addendum to Best Available Alternatives Analysis 12

3. Calculate normalized nitrogen removal costs for each alternative based on the equivalent annual cost and total annual
mass of nitrogen removed.
4. Compile NC municipal TN surcharge rates for industrial discharge to Publicly Owned Treatment Works (POTWs).
5. Compare the normalized nitrogen removal costs for each design condition to NC municipal TN surcharge rates.
6. Propose BAT TN limit.
The following information is contained herein:
oo Evaluation of treatment alternatives,
oo Treatability testing results,
oo Cost analysis, and
ao Proposed BAT limits.
Gor Dewberry- February 26, 2018 I Novozymes Addendum to Best Available Alternatives Analysis 13

2. ALTERNATIVE TREATMENT TECHNOLOGIES
Novozymes has periodically performed technology evaluations to support wastewater treatment plant upgrades for the
Franklinton site. Treatability testing, concept design, and opinions of probable cost have not been completed for each potential
treatment technology. However, desktop evaluations have been performed and the success of treatment technologies at other
Novozymes sites has been considered to support selection of the treatment technology that has been chosen for the
Franklinton site. Table 1 provides a summary of the technologies that have been considered and the advantages and
disadvantages of each technology.
Table 1. Treatment Alternatives
Technology
Advantages
Disadvantages
Sequencing Continuous Flow
cc Proven success at other Novozymes sites
cc Potential for poor settling floc
oo Process flexibility to respond to variable
influent conditions
cc Smaller reactor footprint by utilizing
simultaneous
nitrification/denitrification. Current
concept design requires approximately
3.2 MG of reactor volume for 2 MGD.
oo Potential lower long term operating costs
by utilizing simultaneous
nitrification/denitrification
Multiple Stage Continuous Flow
oo Proven success based on current
oo High recycle rate required to
wastewater treatment system
support denitrification
oc Less process flexibility to adapt
to variable influent
characteristics as aerobic and
anoxic operating volumes are
set
Sequencing Batch Reactor
oo Flexibility to modify reactor phases
oo Larger reactor footprint and
based on influent characteristics
operating volume. A concept
design performed in 2017
indicated the treatment system
would require approximately u
MG of reactor volume for 2
MGD.
Novozymes has successfully operated sequencing continuous flow systems in Kalundborg, Denmark and Tianjin Shi, China.
The sequencing flow system in China has successfully operated for the last 20 years. The WWTP includes reactors which are
continuous flow through; however, the aeration is cycled on and off based on ammonia and nitrate concentrations in the
reactors. When ammonia concentrations decrease to a specific set point, aeration is turned off in order to create anoxic
conditions to support denitrification. Once nitrate concentrations decrease to a specific set point, aeration is turned back on to
support nitrification. Multiple reactors are utilized in parallel, and the reactor effluent discharges to secondary clarifiers. This
treatment technology provides the process flexibility of a sequencing batch reactor while operating at higher loading rates that
result in less reactor volume required. The treatability testing protocol, described in Section 3, was developed to simulate this
full-scale reactor operational strategy.
In addition to the process flexibility and proven success at other Novozymes' facilities, the sequencing continuous reactor
offers other advantages over alternate biological treatment configurations. This reactor configuration requires a smaller
footprint and therefore less greenfield development, so it is an ideal option for a facility with limited space. Novozymes has
observed the sequencing continuous reactor consume less energy than traditional continuous flow systems due to
simultaneous nitrification/denitrification and the lack of internal recycle pumps.
sor Dewberry February 26, 2018 I Novozymes Addendum to Best Available Alternatives Analysis 14

3. TREATABILITY TESTING
3.1 Treatability Testing Approach
The primary objective of performing treatability testing was to establish the soluble refractory organic nitrogen concentration
and nitrate expected to be present in the Novozymes treated effluent using the sequencing type reactor at diffierent design
loading conditions. The ultimate goal of the treatability testing was to determine the effluent refractory organic nitrogen and
nitrate to support establishment of the effluent nitrogen limits for the Novozymes NPDES permit based on analysis of Best
Available Technology.
As discussed above, Novozymes is currently performing preliminary design for a WWTP upgrade to include sequencing
continuous flow treatment reactors. This system offers significant advantages over other treatment configurations and has
proven successful at treating Novozymes wastewater in the Denmark and China facilities. The treatability testing protocol was
developed to simulate this full-scale treatment technology. Bench scale reactors were operated with a distinct aeration phase
which was terminated upon achieving an ammonia -nitrogen concentration less than 1 mg/l. This was to simulate the full-scale
sequence when aeration is activated. The bench scale reactors were then operated with an anoxic phase with supplemental
carbon addition until the nitrate reached a concentration less than 1 mg/l. This was to simulate the full-scale sequence when
the aeration is deactivated and the reactors are in mix phase. This sequence represented one reaction batch in the bench scale
reactors. Full-scale, this sequence would repeat continuously in the continuous flow through reactor. The bench scale reactors
were operated as true batch reactors, without continuous feed/draw and with a clarification phase, due to the challenges
associated with balancing flow rates to maintain continuous flow conditions on a small scale.
3.2 Treatability Testing Protocol
Treatability testing was performed in 2-liter reactors mixed on a Phipps & Bird jar tester. Reactors were aerated with diffuser
stones and miniature air pumps. Each reactor was operated at a different food -to -mass (F:M) loading rate, as follows: Reactor
1 = o.1, Reactor 2 = 0.5, and Reactor 3 = 0.7 (units of mg COD/mg MLVSS*day). These three food -to -mass conditions were
selected to represent the range of historical food -to -mass loading conditions the Novozymes Franklinton WWTP has operated.
Initially, from July 12-July 20, 2017, reactors were operated with a multi -phased nitrification/denitrification by cycling the
aerators on/off in 3o-minute intervals. After running multiple batches under this configuration, effluent data indicated that
sufficient carbon was not remaining during the anoxic cycles to support complete denitrification, so nitrates remained elevated
at the end of a batch. These results were not entirely unexpected, as the reactors were not operated with continuous influent
feed and therefore the rate of denitrification was very low. This differs from the approach that will be implemented full-scale,
which includes continuous feed to provide carbon to support higher denitrification rates. In addition, the aeration/anoxic
phases on the bench scale were operated on a timed basis rather than utilizing real time data (NH3 and NO3) to control as will
be the operational approach full-scale.
For testing performed from July 21 — August 4, 2017, the protocol was modified for each batch to operate with a single aerobic
cycle followed by a single anoxic cycle. Supplemental carbon was added to the reactors at the beginning of the anoxic cycle to
support higher denitrification rates. The final protocol included the following sequence:
1. Feed
a. Feed Novozymes wastewater at volumes required to achieve the three food -to -mass loading conditions
2. Aeration Cycle
a. Aerate the reactor until the reactor ammonia concentration is < 1 mg/1
3. Anoxic Cycle
a. Stop aeration and continue mixing the reactor
b. Dose supplemental carbon (acetic acid) to support denitrification at a Chemical Oxygen Demand (COD) to
Nitrate ratio of 6
c. Mix the reactor until the reactor nitrate is < 1 mg/l
4. Settle
a. Stop mixing and allow biomass to settle
Wor D ewberry February 26, 2018 I Novozymes Addendum to Best Available Alternatives Analysis 15

5. Decant
a. Decant reactor effluent for analysis
Effluent samples were analyzed both by a certified laboratory and by Dewberry personnel. Dewberry analyzed samples using
Hach test kits in order to identify the end of aeration/anoxic cycles and to assess reactor performance in real time. The results
presented within this report and used to establish effluent limits are based solely on certified laboratory data. Due to large
sample volumes required by the certified laboratory, effluent from approximately 2-3 reactor batches were composited to
create a certified laboratory sample.
The reactors were analyzed weekly for total suspended solids and volatile suspended solids. Reactors were also monitored
regularly for pH and dissolved oxygen. Reactor pH was adjusted as needed to maintain the pH at approximately 7.5-9 s.u.
Reactor batch effluent samples were analyzed by the certified laboratory for the following parameters:
oo Soluble Chemical Oxygen Demand (COD)
oo Soluble Carbonaceous 5-day Biochemical Oxygen Demand (BODO
co Nitrate/nitrite (NO3/NO2)
oo Ammonia (NH3)
oo Soluble Total Kjeldahl Nitrogen (TKN)
oo Soluble Total Kjeldahl Nitrogen (sTKN)
Table 2 presents the nitrogen species evaluated and the source of the results (measured versus calculated). Effluent soluble
total nitrogen (sTN) and soluble organic nitrogen (sOrgN) were calculated using Equation 1 and Equation 2.
Equation 1: sTN(calculated) = STKN(measured) + NO3(measured) + NO2(measured)
Equation 2: SOryN(calculated) = sTKN(measured) - NH3(measured)
Table 2. Nitrogen Speciation Parameters
Parameter
Full Name
Measured Calculated
sTKN
Soluble Total Kjeldahl Nitrogen
Measured
NO3
Nitrate
Measured
NO2
Nitrite
Measured
NH3
Ammonia
Measured
sTN
Soluble Total Nitrogen
Calculated
sOr N
Soluble Organic Nitrogen
Calculated
Particulate nitrogen was not evaluated during this study since Novozymes will be implementing tertiary filtration full-scale.
Effluent particulate nitrogen with tertiary filtration is estimated to be 0.36 mg/L, which is based on assuming a biological
suspended solids filter effluent of 3.0 mg/L.
3.3 Testing Results
Effluent reactor results analyzed by a certified laboratory are presented in Appendix A. Appendix A only includes certified
laboratory effluent results for the modified reactor protocol operated from July 21— August 4, 2017. Reactor logs and process
control laboratory analyses performed by Dewberry are presented in Appendix B. Results in Appendix B were used to aid in
reactor operations (e.g. when to terminate cycles, adjust pH, etc) and were not used in the BAT limit analysis.
Table 3 summarizes the 95th percentile reactor effluent results. The 95th percentile reactor effluent is presented, as that is used
to develop the effluent total nitrogen limit. This is consistent with the EPA's methodology for establishing monthly average
effluent limits. The 95th percentile is the basis for long-term average in order to accommodate reasonably anticipated
variability within the control of the facility (EPA NPDES Permit Writers' Manual, 2010, EPA-833-K-10-o01).
Gor Dewberry February 26, 2018 I Novozymes Addendum to Best Available Alternatives Analysis 16

Table 3. q ,th Percentile Reactor Effluent Nitrogen SDeciation
Units
Reactor i
Food -to -Mass = oa
Reactor 2
Food -to -Mass = 0.5
Reactor 3
Food -to -Mass = 0.7
Nitrate/Nitrite
mg/l
2.2
0.9
0.8
Ammonia
mg/1
0.1
0.9
1.3
Soluble Total Kjeldahl Nitrogen
mg/1
1.4
8.2
12.1
Soluble Organic Nitrogen
mg/l
1.3
7.6
11.6
Data presented in Table 3 is based on certified laboratory data.
With the exception of nitrate, the effluent nitrogen species increased in concentration with increasing food -to -mass, as
expected. The 95th percentile effluent refractory soluble organic nitrogen ranged from 1.3 — 11.6 mg/l, increased with
increasing food -to -mass, and made up 40%-96% of the total nitrogen. The effluent refractory soluble organic nitrogen and
nitrate were then used to develop an effluent total nitrogen limit for each design condition (see Section 5 below).
Wor Dewberry February 26, 2018 I Novozymes Addendum to Best Available Alternatives Analysis 17

4. COST ANALYSIS
Capital and operating opinions of probable cost were developed for each food -to -mass design condition identified as the
following alternatives:
00 Alternative 1 — Food -to -Mass o.1
00 Alternative 2 — Food -to -Mass 0.5
00 Alternative 3 — Food -to -Mass 0.7
Capital costs were included for treatment equipment and appurtenances and included estimates for installation costs, with
allocations for contractor overhead, profit, and general conditions, engineering, and construction labor and construction
management. Annual recurring costs were estimated for chemicals, residuals disposal, utilities, sewer use fees, and nutrient
offset fees.
Capital costs were estimated for Alternative 3 based on vendor quotes and installation factors. For Alternatives 1 and 2, the
capital and annual recurring costs for Alternative 3 were scaled when appropriate. For example, the capital costs for the
bioreactors were scaled as the required reactor volume will increase with a decreasing food -to -mass. However, tertiary filter
costs were not scaled for each food -to -mass design condition as the tertiary filter design is not expected to change with varying
the food -to -mass.
Capital and recurring opinions of probable cost for each alternative are presented in Appendix C. The opinions of probable cost
were converted to an equivalent annual cost based on a 5 year period and an annual discount rate of 7.0%, which are the
standard assumptions used by Novozymes to evaluate project financials. Table 4 summarizes the capital, operating, and
equivalent annual costs for each alternative.
Table 4. Equivalent Annual Costs
Alternative 1
Food -to -Mass o.1
Alternative 2
Food -to -Mass o.5
Alternative 3
Food -to -Mass 0.7
Capital Costs
$ 66,700,000
$ 28,400,000
$ 20,100,000
Annual Recurring Costs
$ 2,070,000
$ 1,700,000
$ 1,750,000
Equivalent Annual Cost
$ 18,340,000
$ 8,630,000
$ 6,650,000
Wor Dewberry- February 26, 2018 I Novozymes Addendum to Best Available Alternatives Analysis 18

5. BAT LIMIT DETERMINATION
Novozymes commissioned the treatability testing to further develop BAT TN limits for the proposed NPDES discharge. In
order to determine BAT TN for the discharge,the treatability testing results and cost estimates were used to determine the cost
per pound of TN treatment for each alternative. The cost per pound was then compared to an average cost per pound charged
by municipalities in the state of North Carolina to evaluate if the alternatives were economically achievable. This process is
summarized below:
1. Identify achievable effluent total nitrogen limits for each alternative.
2. Develop Equivalent Annual Costs for each alternative.
3. Calculate normalized nitrogen removal costs for each design condition based on the equivalent annual cost and total
annual mass of nitrogen removed.
4. Compile NC municipal TN surcharge rates for industrial discharge to Publicly Owned Treatment Works(POTWs).
5. Compare the normalized nitrogen removal costs for each design condition to each other and to NC municipal TN
surcharge rates.
The effluent total nitrogen limits presented in Table 5 were developed based on the sum of the soluble organic nitrogen,
nitrate/nitrite,ammonia,and particulate total nitrogen. The effluent soluble organic nitrogen and nitrate components were
based on the 95th percentile treatability testing results for each food-to-mass design condition.The 95th percentile reactor
effluent was used to develop the effluent total nitrogen limit to be consistent with the EPA's methodology for establishing
monthly average effluent limits.The 95th percentile is the basis for long-term average in order to accommodate reasonably
anticipated variability within the control of the facility(EPA NPDES Permit Writers'Manual). The ammonia effluent limit will
be water quality based and is assumed to be 1 mg/1.The particulate total nitrogen is estimated to be o.36 mg/1 for tertiary filter
effluent based on assuming a biological suspended solids filter effluent of 3.o mg/l.
Table 5 presents the calculated effluent total nitrogen proposed for each design condition.Calculated effluent total nitrogen
results are also presented graphically in Figure 1.
Table 5.Calculated Effluent Total Nitrogen Limits
Alternative 1 Alternative 2 Alternative 3
Parameter Units Source Food-to-Mass Food-to-Mass Food-to-Mass
0.1 0.5 0.7
sOrgN mg/1 Treatability Testing 1.3 7.6 11.6
NO3/NO2 mg/1 Treatability Testing 2.2 0.9 o.8
NH3 mg/1 NPDES Limit 1 1 1
Particulate TN mg/1 Performance Estimate* 0.36 0.36 0.36
Effluent TN Limit mg/1 Calculated 4.8 9.8 13.7
*The particulate TN is estimated assuming filter effluent solids are 12%nitrogen and based on tertiary filter performance
estimates from Metcalf&Eddy Inc.(2003)Wastewater Engineering Treatment and Reuse(4th Ed).New York,NY:Mc-
Graw-Hill.
The previous BAT Analysis submitted February 28,2017 proposed a TN limit of 8.8 mg/1 based on based on an analysis of
historical Novozymes wastewater treatment plant(WWTP)effluent data and anticipated WWTP upgrades. It should be noted
that historical soluble organic nitrogen data was not available;therefore soluble organice nitrogen concentrations were
estimated based on available suspended solids and other nitrogen species data.The proposed TN limit included 6.8 mg/1 of
soluble refractory organic nitrogen calculated during a period when Novozymes operated at an average F:M of 0.4.The
calculated soluble refractory organic nitrogen of 6.8 mg/1 at an average F:M of 0.4 agrees well with the treatability testing
results trend(see Figure 1).
Dewberry- February 26,2018 I Novozymes Addendum to Best Available Alternatives Analysis 19

Figure 1. TN Effluent Results Comparison
16
14 Q
oa 12 �
E
c 10
L
g
d
r 6
� ♦
U LDS
Z 4
H
2
0
0 0.1 0.2 0.3 0.4 0.5 0.6 0.7
F:M (mg COD/mg MLVSS*day)
$ TN (July 2017 Treatability Testing) ♦ TN (February 2017 BAT Calculation)
0.8
For each design condition, the annual mass of nitrogen removed was calculated based on the design flow rate, the influent TN,
and the effluent total nitrogen limits provided in Table 5. A normalized nitrogen removal cost was then calculated based on the
mass of nitrogen removed and the annual equivalent cost.
Table 6. Equivalent Annual Costs Normalized to Nitrogen Removed
Units
Alternative i
Food -to -Mass
0.1
Alternative 2
Food -to -Mass
0.5
Alternative 3
Food -to -Mass
0.7
Influent Total Nitrogen
mg/l
208
208
208
Effluent Total Nitrogen Limit
mg/l
4.8
9.8
13.7
Flow
MGD
2
2
2
Annual Mass of Nitrogen Removed
lb/yr
1,237,122
1,2o6,681
1,1822937
Equivalent Annual Cost
$
$18,330,000
$ 8,630,000
$ 6,650,000
Normalized Nitrogen Removal Cost
$/lb
$ 14.8o
$ 7.20
$ 5.6o
In order to evaluate economic achievability of the three design alternatives, municipal TN surcharge rates within the State of
North Carolina were compiled and are presented in Table 7. Municipal nitrogen surcharge rates represent the costs
municipalities impose on industrial dischargers to treat nitrogen in excess of typical municipal concentrations within their
POTWs and should represent benchmark reasonable and economically achievable treatment costs. The average total nitrogen
surcharge rate based on 5 municipalities in North Carolina is $1.96/lb of nitrogen. The maximum surcharge rate based on the
5 municipalities is $5.00/lb of nitrogen.
0 Dewberry. February 26, 2018 1 Novozymes Addendum to Best Available Alternatives Analysis 10

Table 7. North Carolina Municipal Total Nitrogen Surcharge Rates
Municipality
Surcharge ($/lb)
Town of Cary
$1.30
Franklin County
$5.00
City of Raleigh
$1.85
Town of Conover
$ o.63
City of Greenville
$1.04
Maximum
$ 5.00
Average
$ 1.96
Factors considered in assessing BAT include the cost of achieving BAT effluent concentrations, the age of equipment and
facilities involved, the processes employed, engineering aspects of the control technology, potential process changes, non -
water quality environmental impacts (including energy requirements), and economic achievability. Comparison of the
normalized nitrogen removal costs for the three alternatives to the average municipal nitrogen surcharge rate indicates
nitrogen removal costs for all alternatives exceed the average municipal rate, but Alternative 3 is the closest to the average
municipal rate and on par with the highest municipal rate considered. As set forth in Appendix C, Alternative 1 is estimated to
consume nearly 3.5 times as much power to operate annually as Alternative 3 and estimated to require approximately 1.75
times as much acetic acid use. Alternative i is estimated to generate less sludge annually than Alternatives 2 and 3. Based on
the relevant factor, the effluent total nitrogen that can be achieved at the F:M of 0.7 design condition (Alternative 3) is deemed
the Best Available Technology Economically Achievable limit. The proposal monthly average total nitrogen limit is provided in
Table 8.
Table 8. Proposed Nitrogen Limit
Monthly Average
Proposed Limit
Total Nitrogen 13.7 mg/1
0 Dewberry. February 26, 2018 1 Novozymes Addendum to Best Available Alternatives Analysis 11

6. CONCLUSION
The Division requested that Novozymes perform a BAT Analysis to determine TN limits for the Franklinton, NC facility to
support the NPDES permitting process. Novozymes elected to pursue treatability testing to simulate the full-scale system
under design to support establishing the achievable effluent total nitrogen for three food -to -mass design conditions, food -to -
mass of o.1, 0.5, and 0.7. Treatability testing was performed to determine the effluent soluble refractory organic nitrogen and
nitrate at each design condition. The technically achievable effluent total nitrogen concentrations were calculated from the sum
of the 95th percentile effluent soluble refractory organic nitrogen for each reactor, the 95th percentile effluent nitrate from each
reactor, the ammonia monthly average limit of 1 mg/l, and the estimated particulate total nitrogen of 0.36 mg/l. The
technically achievable effluent total nitrogen concentration for the three design conditions were determined to be 4.8 mg/l, 9.8
mg/l and 13.7 mg/l.
The EPA definition of a BAT limit requires it be both technically and economically achievable. Capital and annual recurring
costs were estimated for each of the three design conditions and were used to determine annual equivalent costs. The annual
equivalent costs were normalized per pound of nitrogen removed for each design condition and summarized in Table 9.
Table 9. Normalized Nitrogen Removal Costs
Alternative i
Alternative 2
Alternative 3
Food -to -Mass o.1
Food -to -Mass o.5
Food -to -Mass 0.7
Normalized Nitrogen
$ 14.80
$ 7.20
$ 5.60
Removal Cost
The average and maximum total nitrogen surcharge rate for 5 municipalities in North Carolina are $1.96/lb N and $5.00/lb N,
respectively. All three design conditions for the selected technology exceed the average municipal nitrogen surcharge rate.
Alternative 3, the food -to -mass design condition of 0.7, is deemed the Best Available Technology Economically Achievable as
the normalized cost is closest to the average, but still exceeds the highest municipal rate considered. Based on this and the
other factors noted above, Alternative 3 represents BAT. Therefore, Novozymes proposes an effluent monthly average total
nitrogen limit of 13.7 mg/l.
0 Dewberry. February 26, 2018 1 Novozymes Addendum to Best Available Alternatives Analysis 12

Appendix A
Treatability Testing Reactor Effluent
Certified Laboratory Results
Reactor 1 (Food -to -Mass = 0.1)
Batches Composited7,3
Nitrate/
Nitrite
Ammonia
Soluble
Total
Kjeldahl
Nitrogen
Soluble
Organic
Nitrogen
(Calculated)
Soluble
Total
Nitrogen
Soluble
Chemical
Oxygen
Demands
Soluble
Biochemical
Oxygen
Demands
Total
Suspended
Solids
Total Volatile
Solids
M1,M2
0.95
<0.10
1.3
1.2
2.3
<25.0
<2.0
14.2
39
M3, M4, M5
2.2
< 0.10
< 0.50
0.4
2.7
25.0
2.2
37.2
54
M6, M8, M9
2.2
< 0.10
1 < 0.50
1 0.4
1 2.7
1 < 25.0
< 2.2
1 11.2
86
M7,M10,M11
0.64
<0.10
0.95
0.9
1.6
<25.0
<2.0
<7.1
111
M12, M13
1.8
<0.10
1.4
1.3
3.3
<25.0
<2.0
12.8
142
M14,M15,M16
<0.02
<0.10
<0.50
0.4
0.42
1 <25.0
<2.0
11.8
1 75
Reactor 2 (Food -to -Mass = 0.5)
Batches Composited2,3
Nitrate/
Nitrite
Ammonia
Soluble
Total
Kjeldahl
Nitrogen
Soluble
Organic
Nitrogen
(Calculated)
Soluble
Total
Nitrogen
Soluble
Chemical
Oxygen
Demands
Soluble
Biochemical
Oxygen
Demands
Total
Suspended
Solids
Total Volatile
Solids
M1, M2
0.13
<0.10
3.2
3.1
3.3
118
17.7
20.1
200
M3, M4, M5
0.42
1 0.87
3.5
2.6
3.9
1 88
3.4
22.0
168
M6, M8, M9
0.49
0.87
6.8
5.9
7.2
121
22.5
120
570
M7, M10, M11
0.15
0.55
8.7
8.2
8.9
107
9.0
19.3
400
M12, M13, M14
0.17
0.39
5.5
5.1
5.7
112
< 2.0
72
592
M15, M16, M17
0.99
0.44
4.7
4.3
5.7
95
7.8
<20
286
Reactor 3 (Food -to -Mass = 0.7)
Batches Composited7,3
Nitrate/
Nitrite
Ammonia
Soluble
Total
Kjeldahl
Nitrogen
Soluble
Organic
Nitrogen
(Calculated)
Soluble
Total
Nitrogen
Soluble
Chemical
Oxygen
Demands
Soluble
Biochemical
Oxygen
Demands
Total
Suspended
Solids
Total Volatile
Solids
M1, M2
0.87
<0.10
5.6
5.5
6.5
232
38.6
20.0
148
M3, M4, M5
0.19
1.4
6.8
5.4
7.0
97.0
10.6
23.2
150
M6, M7, M84
0.28
1 12.2
1 23.4
1 11.2
1 23.7
1 226
1 85.2
1 121
588
M9, M10, M114
0.36
20.5
33.7
13.2
34.1
714
14.3
74.7
478
M12
0.23
0.35
13.0
12.7
13.3
115
-
-
-
M13, M14, M15
0.04
0.4
4.8
4.4
4.9
110
11.8
25.7
764
Notes
1. Results above are in mg/L
2. The M in the batch number denotes the batch was operated with the modified protocol initiated on July 21, 2017.
3. Certified lab samples are composite samples of multiple cycles in order to provide laboratory with adequate volume
4. Effluent results for Reactor 3 batches M6 through M11 will be excluded from the BAT limit analysis. These results are not consistent with the analysis performed by
and are not consistent with the performance of other Reactor 3 batches.
5. Reactors were not operated in a manner to optimize for chemical oxygen demand or biochemical oxygen demand removal.
2/26/2018 0 Dewberry

Appentli, 8
Table B.1
R...-Operation Log antl Internal Lab Results
Reactor1R dA. Mau=0.1
Wast�r Fe
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2/26/2018

Appentlix 8
Table B.2
R...-Operation Log,td Internal Lab Results
Reactor 2 Food -to -Mass =0.5
Batch Decapt/Fill
Data
Date&Time
Novagwoes
Wastewater Batch
Reactor Batch
Dacapt Volume
(L)
Nmmry..a
Wastewater Feed(L)
Ulculated
Food -to-
Mass
7121/176:00 PM
WW3
M1
1.1
0.84
0.52
7/22/175:00 PM
WW3
M2
1
0.84
0.52
7/23/173:W PM
WW3
M3
1
0.84
0.52
7/24/174:25 PM
WW3
M4
0.92
0.84
0.52
7/26/1711:30 AM
WW4
M5
0.86
0.84
0.20
7/28/1711:33 AM
WWS
M6
0.86
0.84
0.52
7/29/172:W PM
WW5
M]
1 0.7
0.911
0.50
7/31/176:00 PM
WWS
M8
0.73
0.84
0.52
8/1/1712:30 PM
WW5
M9
0.656
0.81
0.50
8/2/176:00 PM
WWS
MIO
0.66
0.81
0.50
8/3/1710:00 PM
WW5
M31
0.85
0.81
0.50
8/4/174:00 PM
WWS
M12
0.7
0.81
0.50
8/5/17 2:30 PM
WW6
M13
0.66
0.79
0.48
8/6/17 1:15 PM
WW6
M14
0.71
0.65
0.39
8/7/176:00 PM
WW6
M15
0.7
0.81
0.49
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2/26/2018 4 D&Wberm

Appendix B
Table tI3
Rt-Operation Wg and Internal lab Results
Reactor 3 FoodA,Mass = 0.7
Batch Decant/Fill Data
Date &Time
Nworymes
Wastewater Balch
Reactor Batch
Dec-01olume
(L)
N-yrnes
Wastewater Feed)L)
Calculated
Food-W
Mass
7/21/176:00 PM
WW3
Ml
1.1
1.1
0.69
7/22/17 5:00 PM
WW3
M2
1.1
1.1
0.69
7/23/17 3:00 PM
WW3
M3
1.1
1.1
0.69
7/24/174:25 PM
WW3
M4
1.02
1.1
0.66
7/26/1711:30 AM
WW4
M5
1.02
1.1
0.33
7/28/1711:38 AM
WW5
M6
0.91
1.1
0.86
7/30/1712:00 AM
WWS
M7
0.91
0.9
0.71
7/31/176:00 PM
WW5
M8
0.81
1.0
0.78
8/1/1712:21 PM
WW5
M9
0.87
1.1
0.86
8/2/17 6:00 PM
WWS
M10
0.86
1.1
0.88
8/3/178:08 PM
WWS
M31
0.75
0.9
0.71
8/5/17 2:30 PM
WW6
M12
0.64
0.7
0.54
8/6/171:15 PM
WW6
M13
0.82
0.9
0.66
8/7/178:20 PM
WW6
M14
1.0
0.9
0.70
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n
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2/26/2018 9 I]uwborry

Appendix C
Table C.1
Alternative 1 Opinion of Probable Cost
Food -to -Mass 0.1
CAPITAL COSTS:
Item
Description
Estimated Cost
Installed Equipment Costs
Bioreactor Tanks
$
17,850,000
Bioreactor Pumps
$
98,400
Jet aeration equipment
$
2,073,400
Heat Exchanger
$
130,000
Tertiary Filter Package
$
250,000
Primary Clarifier
$
382,000
Carbon dosing pumps
$
24,000
Carbon storage tanks
$
57,200
Effluent pumps
$
84,600
Blower building
$
146,250
Electrical building
$
504,000
Piping
$
1,222,285
Concrete
$
3,844,400
Structural Steel
$
376,740
Power Distribution
$
999,706
Instrumentation and Controls
$
949,546
Site Work
$
1,400,000
Installed Equipment Subtotal
$
30,392,527
Overhead and Profit
15%
$
4,559,000
Contractor General Conditions:
$
600,000
Sub -Total:
$
35,551,527
Contingency:
50%
$
17,775,763.50
Sub -Total:
$
53,327,291
Construction management
10%
$
5,333,000
Construction management Mark-up
5%
$
2,666,000
Engineering Design Fees:
10%
$
5,333,000
Sub -Total:
$
66,659,291
TOTAL ESTIMATED PROJECT COST:
$
66,700,000
ANNUAL RECURRING COST ESTIMATES:
Chemical Costs
Acetic Acid Needed
350
gpd
Unit Cost
$
1.11
$/gal acetic acid
Annual Acetic Acid Cost
$
141,294
Total Chemical Costs
$
141,000
Utility Costs
Annual Power Draw
14,374,935
kW-hr
Unit Cost
$
0.060
$/kW-hr
Total Utility Costs
$
862,000
Residual Disposal Costs
Sludge Dewatered Cake
61
cubic meters/day
Sludge Disposal Unit Cost
$
12.43
$/cubic meter
Total Disposal Costs
$
277,000
Sewer Use Fees
Monthly Town of Louisburg Fee
$
35,179
/month
Annual Town of Louisburg Sewer Use Fee
$
422,000
Franklin County Hydraulic Surcharge
$
5.5
/1,000 gallons
Discharge to Franklin County
130,000
gpd
Annual Franklin County Sewer Use Fee
$
261,000
Nutrient Offset Fee
Flow
2
MGD
Total Nitrogen
4.8
mg/I
Total Phosphorus
1
mg/I
TN BMPc
29.00
$/kg
Nutrient Offset Fee
$
512,135
per 5 yr permit cycle
Total Annual Recurring Cost
$
2,065,000
Notes:
1. Red text indicates the equipment/recurring cost was scaled from Alternative 3.
2. Required acetic acid volume calculated based on polishing 10 mg/I of nitrate -nitrogen.
3. Acetic acid unit cost based on agreement between Novozymes and acetic acid supplier.
4. Sludge disposal rate estimated based on assumed yield of 0.38 lb VSS/lb bCOD and 18% centrifuge cake.
5. Sludge disposal unit cost based on historical Novozymes sludge disposal costs.
6. Discharge flow to Franklin County based on minimum agreed upon flow between Novozymes and Franklin County.
7. Nutrient offset fee calculated per the requirements in 15A NCAC 0213.0229(c) and 15A NCAC 0213.0237.
2/26/2018 Dewberry

Appendix C
Table C.2
Alternative 2 Opinion of Probable Cost
Food -to -Mass 0.5
CAPITAL COSTS:
Item
Description
Estimated Cost
Installed Equipment Costs
Bioreactor Tanks
$
3,570,000
Bioreactor Pumps
$
68,880
Jet aeration equipment
$
1,451,380
Heat Exchanger
$
91,000
Tertiary Filter Package
$
250,000
Primary Clarifier
$
382,000
Carbon dosing pumps
$
16,800
Carbon storage tanks
$
40,040
Effluent pumps
$
84,600
Blower building
$
102,375
Electrical building
$
504,000
Piping
$
820,045
Concrete
$
2,691,080
Structural Steel
$
263,718
Power Distribution
$
789,601
Instrumentation and Controls
$
664,682
Site Work
$
980,000
Installed Equipment Subtotal
$
12,770,201
Overhead and Profit
15%
$
1,916,000
Contractor General Conditions:
$
450,000
Sub -Total:
$
15,136,201
Contingency:
50%
$
7,568,101
Sub -Total:
$
22,704,302
Construction management
10%
$
2,270,000
Construction management Mark-up
5%
$
1,135,000
Engineering Design Fees:
10%
$
2,270,000
Sub -Total:
$
28,379,302
TOTAL ESTIMATED PROJECT COST:
$
28,400,000
ANNUAL RECURRING COST ESTIMATES:
Chemical Costs
Acetic Acid Needed
240
gpd
Unit Cost
$
1.11
$/gal acetic acid
Annual Acetic Acid Cost
$
96,887
Total Chemical Costs
$
97,000
Utility Costs
Annual Power Draw
5,522,795
kW-hr
Unit Cost
$
0.060
$/kW-hr
Total Utility Costs
$
331,000
Residual Disposal Costs
Sludge Dewatered Cake
88
cubic meters/day
Sludge Disposal Unit Cost
$
12.43
$/cubic meter
Total Disposal Costs
$
401,000
Sewer Use Fees
Monthly Town of Louisburg Fee
$
35,179
/month
Annual Town of Louisburg Sewer Use Fee
$
422,000
Franklin County Hydraulic Surcharge
$
5.5
/1,000 gallons
Discharge to Franklin County
130,000
gpd
Annual Franklin County Sewer Use Fee
$
261,000
Nutrient Offset Fee
Flow
2
MGD
Total Nitrogen
9.8
mg/I
Total Phosphorus
1
mg/I
TN BMPc
29.00
$/kg
Nutrient Offset Fee
$
953,631
per 5 yr permit cycle
Total Annual Recurring Cost
$
1,703,000
Notes:
1. Red text indicates the equipment/recurring cost was scaled from Alternative 3.
2. Required acetic acid volume calculated based on polishing 7 mg/I of nitrate -nitrogen.
3. Acetic acid unit cost based on agreement between Novozymes and acetic acid supplier.
4. Sludge disposal rate estimated based on assumed yield of 0.55 lb VSS/lb bCOD and 18% centrifuge cake.
5. Sludge disposal unit cost based on historical Novozymes sludge disposal costs.
6. Discharge flow to Franklin County based on minimum agreed upon flow between Novozymes and Franklin County.
7. Nutrient offset fee calculated per the requirements in 15A NCAC 0213.0229(c) and 15A NCAC 0213.0237.
2/26/2018 Dewberry

Appendix C
Table C.3
Alternative 3 Opinion of Probable Cost
Food -to -Mass 0.7
CAPITAL COSTS:
Item
Description
Estimated Cost
Installed Equipment Costs
Bioreactor Tanks
$
2,550,000
Bioreactor Pumps
$
49,200
Jet aeration equipment
$
1,036,700
Heat Exchanger
$
65,000
Tertiary Filter Package
$
250,000
Primary Clarifier
$
382,000
Carbon dosing pumps
$
12,000
Carbon storage tanks
$
28,600
Effluent pumps
$
84,600
Blower building
$
73,125
Electrical building
$
504,000
Piping
$
769,765
Concrete
$
1,922,200
Structural Steel
$
188,370
Power Distribution
$
649,531
Instrumentation and Controls
$
474,773
Site Work
$
700,000
Installed Equipment Subtotal
$
9,739,864
Overhead and Profit
15%
$
1,461,000
Contractor General Conditions:
$
300,000
Sub -Total:
$
11,500,864
Contingency:
40%
$
4,600,346
Sub -Total:
$
16,101,210
Construction management
10%
$
1,610,000
Construction management Mark-up
5%
$
805,000
Engineering Design Fees:
10%
$
1,610,000
Sub -Total:
$
20,126,210
TOTAL ESTIMATED PROJECT COST:
$
20,100,000
ANNUAL RECURRING COST ESTIMATES:
Chemical Costs
Acetic Acid Needed
200
gpd
Unit Cost
$
1.11
$/gal acetic acid
Annual Acetic Acid Cost
$
80,739
Total Chemical Costs
$
81,000
Utility Costs
Annual Power Draw
4,153,926
kW-hr
Unit Cost
$
0.060
$/kW-hr
Total Utility Costs
$
249,000
Residual Disposal Costs
Sludge Dewatered Cake
105
cubic meters/day
Sludge Disposal Unit Cost
$
12.43
$/cubic meter
Total Disposal Costs
$
474,000
Sewer Use Fees
Monthly Town of Louisburg Fee
$
35,179
/month
Annual Town of Louisburg Sewer Use Fee
$
422,000
Franklin County Hydraulic Surcharge
$
5.5
/1,000 gallons
Discharge to Franklin County
130,000
gpd
Annual Franklin County Sewer Use Fee
$
261,000
Nutrient Offset Fee
Flow
2
MGD
Total Nitrogen
13.7
mg/I
Total Phosphorus
1
mg/I
TN BMPc
29.00
$/kg
Nutrient Offset Fee
$
1,297,998
per 5 yr permit cycle
Total Annual Recurring Cost
$
1,747,000
Notes:
1. Red text indicates the equipment/recurring cost will be scaled for Alternatives 1 and 2.
2. Required acetic acid volume calculated based on polishing 6 mg/I of nitrate -nitrogen.
3. Acetic acid unit cost based on agreement between Novozymes and acetic acid supplier.
4. Sludge disposal rate estimated based on assumed yield of 0.65 lb VSS/lb bCOD and 18% centrifuge cake.
5. Sludge disposal unit cost based on historical Novozymes sludge disposal costs.
6. Discharge flow to Franklin County based on minimum agreed upon flow between Novozymes and Franklin County.
7. Nutrient offset fee calculated per the requirements in 15A NCAC 0213.0229(c) and 15A NCAC 0213.0237.
2/26/2018 Dewberry