NC0089621_Comments_20181001

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novozymes®
Rethink Tomorrow
October 1, 2018
Via U.S. Mail and E-Mail
Jeffrey Poupart
Water Quality Permitting Section Chief RECEIVED/DENR/DWR
NCDEQ - Division of Water Resources
1611 Mail Service Center OCT 08 2018
Raleigh, North Carolina 27699-1611
[e-mail] Water Resources
Permitting Section
Julie Grzyb
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]
Adugna Kebede
Modeling and Assessment Branch
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. Kebede:
This letter follows up on the meeting on Friday, August 24, 2018 among representatives of
Novozymes North America, Inc. ("Novozymes") and the Department of Environmental Quality
and my letter to the Division of Water Resources (the "Division") dated August 30, 2018 that
recounted the meeting. As forecast in my August 30 letter, on September 26, 2018,
representatives of Novozymes North America, Inc. ("Novozymes") and Dewberry Engineering,
Inc. ("Dewberry") met with Teresa Rodriguez, Bing Bai, and Adugna Kebele of the Division of
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Water Resources (the "Division") to discuss water quality modeling for Cedar Creek as the
proposed receiving stream related to NPDES Permit Application NC0089621 (the "Permit
Application").
Prior to the meeting, Division representatives were provided with Dewberry's QUAL2K Cedar
Creek model for review. The objective of the September 26 meeting was to resolve any
outstanding comments from the Division regarding the Cedar Creek model. Accordingly, with
regard to the Cedar Creek model, the Division, Novozymes, and Dewberry agreed that
Novozymes will:
1. Field calibrate the base line model, including information from the Franklinton Branch
tributary;
2. Use the field calibrated base line model to perform a sensitivity analysis on
parameters that affect the DO recovery profile. Parameters discussed will include
temperature, in-stream headwater nutrient concentrations, point sources, and
reaeration methods, i.e. USGS Channel Control or constant aeration method. The
analysis will be included in a revised model report;
3. Provide a new low flow 7Q10 model using both the field calibrated model and the
Cedar Creek 7Q10 as calculated and provided by the USGS; and
4. Submit to the Division a revised QUAL2K model report for discharge to Cedar Creek.
Novozymes will submit the revised QUAL2K model to the Division on an expedited basis and
requests an expedited review by the Division. 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 26, 2018. We look forward to working with the Division toward issuance of a
draft NPDES permit.
Sincerely,
(7/11 a144
Angela J. Walsh
Novozymes North America, Inc.
cc: Bill Lane, DEQ General Counsel
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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
Mike Templeton, Complex Permitting Unit
Bing Bai, Complex Permitting Unit
Rick Bolich, DWR- Raleigh Regional Office
Steve Tedder, Tedderfarm Consulting
Katie Jones, Dewberry
Mike Poulios, Dewberry
(all via e-mail only)
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