NC0089621_Comments_20180724

novozymes®
Rethink Tomorrow
July 24, 2018
Via U.S. Mail and E-Mail RECEIVED/rPyR/DWR
Jeffrey Poupart AUG 0 2 2018
Water Quality Permitting Section Chief Water Resources
NCDEQ - Division of Water Resources Permitting Section
1611 Mail Service Center
Raleigh, North Carolina 27699-1611
[e-mail]
Julie Grzyb
Supervisor, NPDES Complex Unit
NCDEQ - Division of Water Resources
1611 Mail Service Center
Raleigh, North Carolina 27699-1611
[e-mail]
Teresa Rodriquez
NPDES Complex Unit
NCDEQ - Division of Water Resources
1611 Mail Service Center
Raleigh, North Carolina 27699-1611
[e-mail]
RE: NPDES Permit Application NC0089621
Novozymes North America, Inc.
Franklin County
Dear Mr. Poupart, Ms. Grzyb, and Ms. Rodriguez:
Novozymes North America, Inc. ("Novozymes") has received Ms. Rodriguez's letter dated June
19, 2018 (the "DWR Letter") regarding Novozymes' NPDES Permit Application NC0089621 (the
"Permit Application"), by which Novozymes seeks authorization to treat and then discharge to
surface waters up to two million gallons of wastewater per day (2 MGD). This letter responds to
the DWR Letter, requests an extension of time for action items outlined in the DWR Letter, and
requests a meeting to discuss important issues related to the Permit Application.
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Potassium
Novozymes understands the Division's concerns regarding potential impacts to aquatic species
based on the highest level of potassium in Novozymes effluent as originally reported in the
Permit Application in 2016 and as referenced in the DWR Letter. In an effort to address the
Division's concerns and in an on-going effort to improve its wastewater discharge, Novozymes
is evaluating reverse osmosis ("RO") wastewater treatment technology as a solution.
Novozymes has just initiated a pilot test of an RO system, the results of which will not be
available for approximately eight (8) weeks. However, Novozymes believes that if RO is
feasible for its facility, this would be a game-changer for its wastewater profile and for the Permit
Application as well. We look forward to getting the results of the pilot test and reviewing those
results with the Division.
The DWR Letter suggested that Novozymes work with DWR's Standards Branch to perform
toxicity testing on aquatic species (including mussels) in order to provide a colorable basis for a
potassium limit in a draft NPDES permit. This week, Novozymes will be in touch with Jeff
Manning, Connie Brower, and Chris Ventaloro in the Standards Branch to discuss a process to
develop preliminary water quality criteria for potassium as related to the Permit Application and
a draft permit. However, recent discussions with Rambo!! Environ indicate that additional
toxicity testing may not be necessary, and a proper analysis of existing data and recent studies
may be sufficient to develop the water quality criteria. Novozymes will review this with the
Standards Branch as soon as possible and report back to you on the agreed-upon approach.
Engineering Alternatives Analysis
The Division suggested that the EAA should be updated to reflect the final project description
and treatment methodology. This update will need to occur after completion of the RO pilot
testing and analysis, and Novozymes proposes to update the EAA at that time.
Analysis of Best Available Technology Economically Achievable for Nutrients
The DWR Letter requests a bullet-point list of additional information items and analyses as well
as paperwork reorganization of the BAT Analysis for nutrients. Because Novozymes believes
that RO treatment also has the potential to remove additional amounts of nutrients from
Novozymes wastewater, it would be best to incorporate the results of the RO testing in an
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update to the BAT analysis. Accordingly, Novozymes hereby requests the Division for an
extension of time to complete the RO testing and update the BAT analysis. In the meantime,
however, based on the DWR Letter, past discussions with the Division, and the BAT
documentation submitted by Novozymes thus far, Novozymes would like to discuss with the
Division its criteria and standards for review of BAT analyses to be sure there is a complete
understanding of the Division's expectations.
Alternate Discharge Point
As you may recall, earlier this year, Novozymes undertook an analysis of the feasibility of
discharging at an outfall on Cedar Creek rather than the Tar River. Modeling for dissolved
oxygen indicates that Cedar Creek is a viable receiving stream for Novozymes effluent. Based
on this and other factors favoring Cedar Creek, we would like to discuss with you an
amendment to the Permit Application to designate the outfall location at Cedar Creek.
Meeting to Discuss the Permit Application and Request for Extension of Time
As you can see, there are a number of significant developments and issues regarding the
Permit Application that would be appropriate and most efficient to discuss in a meeting.
Additionally, Novozymes has certain questions and concerns regarding the Division's review
and processing of the Permit Application that would best be discussed in person in a meeting
including Division management at DEQ headquarters. We will follow up with you to coordinate
a time that would work for your schedules.
Given the time necessary to (i) complete the RO pilot testing and evaluation, (ii) coordinate with
the DWR Standards branch on an approach to development of water quality criteria, and (iii)
update the EAA and BAT Analysis after completion of the RO evaluation, and given that
Novozymes has questions for the Division regarding its evaluation of BAT, we request an
extension of time regarding the action items noted in the DWR Letter. Once we have the
meeting with the Division as noted above and have completed the RO evaluation, Novozymes
should be in a position to provide you with the requested information within sixty (60) days
thereafter. Accordingly, Novozymes respectfully requests that additional time.
Thank you for your consideration of these points, and we look forward to hearing from you and
working with you toward issuance of a draft permit in the coming months.
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Sincerel ,
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Angela Walsh, PE
Manager, Environmental and Utilities Operations
Novozymes North America, Inc.
cc: Bill Lane, DEQ General Counsel
Andrew Hargrove, DEQ Assistant General Counsel
Jeff Manning, Classifications, Standards and Rules Review Branch
Connie Brower, Classifications, Standards and Rules Review Branch
Chris Ventaloro, Classifications, Standards and Rules Review Branch
Steve Tedder, Tedderfarm Consulting
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