NC0089621_Comments_20180907

novozymes-
Rethink Tomorrow
September 7, 2018
Via U.S. Mail and E-Mail
Jeffrey Poupart
Water Quality Permitting Section Chief
NCDEQ - Division of Water Resources RECEBVEDlENR/®WR
1611 Mail Service Center
Raleigh, North Carolina 27699-1611 SEP 12 2018
[e-mail]
Water Resources
Julie Grzyb Permitting Section
Supervisor, Complex Permitting Unit
• NCDEQ - Division of Water Resources
1611 Mail Service Center
Raleigh, North Carolina 27699-1611
[e-mail]
Teresa Rodriguez
Complex Permitting Unit
NCDEQ - Division of Water Resources
1611 Mail Service Center
Raleigh, North Carolina 27699-1611
[e-mail]
Mike Templeton
Water Quality Permitting Section
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, Ms. Rodriguez, and Mr. Templeton:
This letter follows up on our meeting that was held on Friday, August 24, 2018 and my letter to
you dated August 30, 2018 that memorialized the meeting. As forecast in my August 30 letter,
on September 5, 2018, representatives of Novozymes North America, Inc. ("Novozymes") and
Dewberry Engineering, Inc. ("Dewberry") met with Teresa Rodriguez, Mike Templeton, and Bing
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Bai of the Division of Water Resources (the "Division") to discuss the analysis of best available
technology economically achievable ("BAT") for nutrients related to NPDES Permit Application
NC0089621 (the "Permit Application"). Specifically, the objective of the September 5 meeting
was to fully and finally agree upon the protocol and parameters for the BAT analysis and to
clarify the information requested by the Division in its letter dated June 19, 2018. Accordingly,
with regard to the BAT analysis, the Division, Novozymes, and Dewberry agreed as follows:
1. Novozymes will prepare and submit to the Division an updated, revised, and
compiled BAT analysis document ("Revised BAT Analysis") that incorporates and
replaces the previously submitted Best Available Technology Analysis dated
February 28, 2017 and Addendum to Best Available Technology Analysis dated
February 26, 2018.
2. The Revised BAT Analysis will focus on three different food-to-mass ratios (F:M) that
represent the typical operation of three different treatment technologies; extended
aeration (F:M = 0.1), conventional aeration (F:M = 0.5), and high-rate aeration (F:M =
0.7).
3. The Revised BAT Analysis will include:
a. a clarification of the interpretation of treatability study data
i. Novozymes will calculate and present effluent total nitrogen limits
based on both maximum and 95th percentile data analysis for the
three technologies.
ii. After review of the data set, the Division agreed that data from
treatability study reactors M6-M11 should be eliminated from the data
set used to evaluate a BAT total nitrogen limit. For completeness,
data from reactors M6-M11 will be included in the raw data appendix.
b. a description of (i) the current wastewater treatment system at the
Novozymes facility; and (ii) the proposed new wastewater treatment system
to be installed in conjunction with the NPDES permit, and a discussion of the
performance of the current system and its inability to achieve enhanced
nitrogen removal;
c. updated effluent data for the purpose of describing current system
performance;
d. a discussion of treatability testing results with regards to effluent ammonia
(NH3) concentrations given that the permit limit for NH3 is expected to be 1.0
mg/L;
e. a discussion of the food-to-mass ratios as the design basis for treatability
scale up for each of the three technologies;
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f. spreadsheet model outputs for each of the three technologies; and
g. Proposal of a BAT Total Nitrogen (TN) limit based on the technology
represented by F:M of 0.5.
4. The comparative cost analysis in the Revised BAT Analysis will compare the costs of
the three technologies and will include graphical analysis.
5. The reduction of the proposed BAT permit limit for TN by 1.0 mg/L would be
appropriate if reverse osmosis (RO) treatment is determined to be feasible by
Novozymes and proposed for the NPDES permit.
6. Novozymes will submit the Revised BAT Analysis to the Division on an expedited
basis.
Thank you again for your time and efforts regarding review and processing of the Permit
Application. Please let us know if there is anything you would like to add or clarify regarding the
contents of this summary of the meeting from September 5, 2018. We look forward to working
with the Division toward issuance of a draft NPDES permit.
Sincerely,
apax
Angela J. Walsh
Novozymes North America, Inc.
cc: Bill Lane, DEQ General Counsel
Linda Culpepper, Division of Water Resources Director
Mary Penny Kelley, Special Advisor, Office of the Governor
Andrew Hargrove, DEQ Assistant General Counsel
Jeff Manning, Classifications, Standards & Rules Review Branch
Connie Brower, Classifications, Standards & Rules Review Branch
Chris Ventaloro, Classifications, Standards & Rules Review Branch
Bing Bai, Complex Permitting Unit
Rick Bolich, DWR- Raleigh Regional Office
Steve Tedder, Tedderfarm Consulting
(all via e-mail only)
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