NC0089834_More Information Received_20181023

9 Woodvale Avenue • Asheville, NC 28804 • 828-768-3335 • [e-mail] • Pisgah-air.com

October 22, 2018
North Carolina Department of Environmental Quality
Division Water Resources
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617

Attn: Derek Denard,
Environmental Specialist
Re: Low and Bonar Inc.
Wastewater Discharge Individual Permit Application
DWR Additional Information Request / L&B Response

Mr. Denard:

The purpose of this letter is for Low & Bonar Inc. to respond to a request for additional
information by DWR staff concerning Low & Bonar’s application for an Individual National
Pollutant Discharge and Elimination System (NPDES) permit for their facility in Enka,
(Buncombe County) North Carolina. This letter addresses non-contact, once-through cooling
waters to an un-named tributary to Hominy Creek and a Present Value Cost Analysis (PVCA)
for maintaining NPDES permits limits. Low & Bonar responses are presented below each DWR
question.

Q1.a The reviewers were considering whether this facility may be Categorical under 40
CFR. The applicable Categories may be 40 CFR 410 Textile Mills or 40 CFR 414
Organic Chemicals, Plastics, and Synthetic Fibers.

The 40 CFR Part 410, “Textile Mills” regulation applies to facilities organized into nine (9)
subcategories:
1. Wool Scouring
2. Wool Finishing
3. Low Water Use Processing
4. Woven Fabric Finishing
5. Knit Fabric Finishing
6. Carpet Finishing
7. Stock and Yarn Finishing
8. Nonwoven Manufacturing
9. Felted Fabric Processing
Of these categories, “nonwoven manufacturing”; which includes “manufacturing of nonwoven
textile products of wool, cotton, or synthetics, or blends of such fabrics” describes Low &
Bonar’s processing units. Low & Bonar produces nonwoven synthetic materials for use as
carpet backing and sound insulation in architectural applications, but mostly for erosion control
as a ‘geosynthetic’ material.

Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 2

40 CFR Part 301, Section 410, Subpart H – Nonwoven manufacturing Subcategory, says:

410.90 Applicability; description of the nonwoven manufacturing subcategory.
The provisions of this subpart are applicable to discharges containing process wastes
that enter the waters of the United States, and introductions of pollutants into publicly
owned treatment works resulting from facilities that primarily manufacture nonwoven
textile products of wool, cotton, or synthetics, singly or as blends, by mechanical.
thermal, and/or adhesive bonding procedures. Nonwoven products produced by fulling
and felting processes are covered in Felted Fabric Processing. Integrated mills that
manufacture a majority of nonwoven textile products along with greige goods
manufacturing or other finishing operations are included in this subpart and total
production (excluding dry web formation, knitting, weaving, or other dry operations)
should be applied to the applicable effluent limitations to calculated discharge
allowances.

A1.a We conclude 40 CFR Part 410, “Textile Mills” regulations are not applicable to Low &
Bonar because no process water is discharged to waters of the State. Figures 2, 3, and
4 provide additional discharged water information.

The 40 CFR Part 414, “Organic Chemicals, Plastics, and Synthetic Fibers” regulation generally
applies to facilities from five (5) Standard Industrial Classification (SIC) subcategories:
1. 2821: Plastic Materials, Synthetic Resins, and Non-vulcanizable Elastomers
2. 2823: Cellulosic Man-Made Fibers
3. 2824: Synthetic Organic Fibers, Except Cellulosic
4. 2865: Cyclic Crudes and Intermediates, Dyes, and Organic Pigments
5. 2869: Industrial Organic Chemicals, Not Elsewhere Classified
Of these SIC categories, “Plastic Materials, Synthetic Resins, and Non-vulcanizable Elastomers”
and “Synthetic Organic Fibers, Except Cellulosic” are closest to Low & Bonar’s processing
units.

The 40 CFR Part 414, regulation applies to facilities organized into 11 subparts:
A. General Requirements
B. Rayon Fibers
C. Other Fibers
D. Thermoplastic Resins
E. Thermosetting Resins
F. Commodity Organic Chemicals
G. Bulk Organic Chemicals
H. Specialty Organic Chemicals
I. Direct Discharge Point Sources That Use End-of-Pipe Biological Treatment
J. Direct Discharge Point Sources That Do Not Use End-of-Pipe Biological Treatment
K. Indirect Discharge Point Sources

Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 3

414.30 Applicability; description of the other fibers subcategory. The provisions of this
subpart are applicable to the process wastewater discharges resulting from the
manufacture of products classified under SIC 2823 cellulosic man-made fibers, except
Rayon, and SIC 2824 synthetic organic fibers including those fibers and fiber groups
listed below. Product groups are indicated with an asterisk (*).
*Acrylic Fibers (85% Polyacrylonitrile)
*Cellulose Acetate Fibers
*Fluorocarbon (Teflon) Fibers
*Modacrylic Fibers
*Nylon 6 Fibers
Nylon 6 Monofilament
*Nylon 66 Fibers
Nylon 66 Monofilament
*Polyamide Fibers (Quiana)
*Polyaramid (Kevlar) Resin-Fibers
*Polyaramid (Nomex) Resin-Fibers
*Polyester Fibers
*Polyethylene Fibers
*Polypropylene Fibers
*Polyurethane Fibers (Spandex)

The applicability of Part 414 to plastics production rather than plastics processing is often
confused. Plastic products reported under SIC 2821 involve the polymerization of various liquid
or gaseous monomers (reactive organic chemicals) into a solid polymeric material, which is
typically shipped off-site as pellets or other form. The manufacture of synthetic fibers reported
under SIC 2823 involves extruding a melt of such a polymeric material through a spinneret.
Cellulosic synthetic fibers, also reported under SIC 2823, are derived by physically modifying
cellulose, a naturally occurring polymeric material, through chemical processing.
The manufacture of plastic processing products involves melting the solid polymeric material
received from the plastic producer and using mechanical techniques (injection molding,
calendering, extrusion, etc.) to reform it into sheets, film, tubes, rods, or special shapes. Part
414 is not applicable to process wastewater associated with plastic processing products
previously reported under SIC 3081-3089 (formerly SIC 3079), which are regulated by Part 463.
These distinctions are illustrated in Figure 1.
Figure 1. Products Regulated by the Plastics Molding & Forming Category
Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 4

A1.a. We conclude 40 CFR Part 414, “Plastics Molding and Forming” regulations are not
applicable to Low & Bonar because no process water is discharged to waters of the
State. Figures 2, 3, and 4 provide additional discharged water information. Even
were process wastewater associated with Low & Bonar processes – it is not – it would
not be subject to 40 CFR Part 414.
Q1.b Are the plastic extruders cooled by “non-contact cooling” water? I looked back at the
application for the general permit and I believe you covered this description under
application question C (What type of wastewater is discharged?).

Below is Low & Bonar’s General Permit application description of extruder cooling water
discharges:

7) Description of Discharge:

Non-contact cooling waters from extruders and cooling towers.

a) Is the discharge directly to the receiving water?

No, discharges from extruders and cooling towers are routed to the Slim Tank (equipped with a
flow measuring sensor and datalogger system) and then to the combined stormwater piping
system; which conveys them to an un-named tributary to Hominy Creek. Exhibit 2 is a
photograph of the Slim Tank.

A1.b. We describe discharges to waters of the State in the General Permit Application –
Figures 2 and 3 – filed with DWR in December 2017, and included here, that once-
through, non-contact cooling water cooling waters from extruders are acceptable
discharges because they are not process waters.

Q1.c You may also want to include Figure 1. (Process Flow Diagram – Yarn Production)
from the general permit application in your response. I believe a simple diagram of
the extruder process may help determine if we are looking at a Categorical industry or
not.

Figures 2 and 3 show non-contact, once-through waters from Extruders M-1 to M-5 that are
discharged – with condensates from air handlers and compressors, blow-down waters from
cooling towers, and the stormwater system – to an un-named tributary to Hominy Creek. No
process water is discharged.

Very little ‘process water’ is generated at Low & Bonar. That ‘process water’ which is produced
is discharged to the Metropolitan Sewerage District system.

Figure 4 shows the manufacturing portion of the Low & Bonar facility that discharges cooling
waters and process waters to Hominy Creek and the Metropolitan Sewerage District respectively.

A1.c. We conclude no process water is discharged to waters of the State.
Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 5 Figure 2. Non-Contact Extruder Cooling Waters Discharge to Surface Water [from General Permit Application]
Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 6 Figure 3. Non-Contact Cooling Waters Discharge to Surface Water [from General Permit Application and from Individual Permit Application]Groundwater Infiltration (23,304 gal/d) Flood Gate to East Ditch (45,054 gal/d) Slim Tank – Compliance Point (15,384 gal/d) Figure 3.
Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 7

Figure 4. Piping Diagram of Non-Contact Cooling Waters Discharge to Surface Water
Flood Gate Combined Discharge COOLING WATER
and Infiltration
GROUNDWATER
45,054 gal/d
COMBINED DISCHARGED WATER
SUMMARY
Flood Gate 45,054 gal/d
Slim Tank 15,384 gal/d
Pumped Groundwater 6,366 gal/d
Infiltration Groundwater 23,304 gal/d
Slim Tank
COOLING WATER
15,384 gal/d
Manhole 3
INFILTRATION
GROUNDWATER
? gal/d
Phase 7 Pumped GROUND WATER 6,366 gal/d
Path of Combined Wastewater and Stormwater
Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 8

b) Number of discharge points.

All Surface Water discharges are from the tank system in Exhibit 2; which includes it’s
downstream secondary ‘mixing tank’. This is the only water discharge from the L&B
process. Note that these non-contact cooling waters are combined with stormwater and
infiltration groundwater in the discharge piping. Figure 3 is a diagram of L&B inputs to
waters of the State.

However, other wastewaters (e.g., boiler blowdowns and domestic wastewater) are
discharged to the Buncombe County Metropolitan Sewerage District (MSD) system.
L&B has a permit for this discharge, a copy of the MSD permit was included in the
General Permit application.

c) What type of wastewater is discharged?

L&B has determined that discharged waters to Hominy Creek are primarily “non-contact
cooling water” and “once-through cooling water”, primarily from cooling tower
blowdowns and plastic extruders. “Air condensates” from creature comfort, room
cooling for heat/moisture sensitive electronics equipment, or oil-less air compressor
systems are also included in the discharged water. Each type of discharged water is
discussed below.
At L&B, extruders are an example of once-through cooling water. City Water is piped
through a heated polymer material extruder head or its gear box to cool the mechanism or
to prevent the product from becoming too hot. This is a type of non-contact cooling
water. Water used in cooling the extruder throat and gear boxes is ‘once-through cooling
water’ (i.e., it discharges indirectly to Hominy Creek after dechlorination). Its residual
chlorine is equal to that of City Water and its other chemical characteristics are the same.
L&B has installed a dechlorination system to convert free and residual chlorine to
chlorides. That system is described in Attachment C of the Individual Permit application.
Supporting dose rate and retention time calculations are included in Attachment C.
Condensates from compressed air systems are classified as non-process water. Although
compressed air is used, for example, to move thread through tubing or to spread thread on
the Fleecing table, the condensed water in the pressurized lines is never in contact with
product(s) or raw materials. Moreover, this air is produced by “oil-less” compressors;
thus, no oil can be in the water. Therefore, condensate from these lines is considered
“non-contact” and is permitted to be discharged to surface waters. Compressed air
system water is directed to the dechlorination/flow measuring tank (see Exhibit 2) and
hence to Hominy Creek.
In this evaluation, yarn quench and room cooling air condensates in the Spinning Room
were classified as “process water”. This single process area – of the entire Low & Bonar
production facility - produces water that has been in contact with a product. In the
Spinning Room quenching the recently formed yarn strands with cool air releases nylon
or PET monomers to room air. This air is then mixed with room cooling air and
condensates from that air could be classified as process water. These monomers are not
in concentrations high enough to be detected as total suspended solids but we still
consider them “process water”. Consequently, these waters are discharged to MSD
rather than to surface waters.
Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 9

Over the years the L&B Boiler Condensate System developed many connections and
discharges to the stormwater system that flows to Hominy Creek via the East Ditch or to
the Metropolitan Sewerage District (MSD) system. Neither discharge reflects the
condensate system’s initial design. The Boiler Condensate System was designed to
capture and recycle all boiler steam condensate. To this end 10 condensate receivers
were installed around the facility.
The system was originally designed to work in the following manner: Boiler steam
condenses in transfer piping and flows via gravity to a receiver. These receivers store the
condensate until the container is full and then pump the liquid to a height that allows it to
flow by gravity to the boiler condensate storage in the boiler room. The condensate is
heated again in the boiler and the process repeats.
Process and plumbing changes over the last 13 months has returned the boiler
condensates to the condensate storage system. This is a cost savings for L&B and a
reduction of wastewater discharges.
Some boiler blowdown water – approximately 685 gallons per day – are discharged to
MSD.
d) Volume of discharge per each discharge point (GPD – Gallons Per Day):
Flow sensors were recently installed in the dechlorination/flow measuring tank and in the
discharge of the combined wastewater/stormwater piping that goes to Hominy Creek.
Flow sensor data show that the dechlorination/flow measuring tank discharges – on
average – 15,384 gallons per day to the wastewater/stormwater piping and 45,054 gallons
per day into the un-named tributary to Hominy Creek. The difference – 23,304 gallons
per day is assumed to be groundwater infiltration. Included in that 23,304 gallons per
day is 6,366 gallons per day of pumped groundwater. Table 3 and Figure 4 describe
wastewater discharges to surface water.
Discharges to MSD total – on average during 2017 – 36,100 gallons per day. This
discharge stream is permitted by MSD and is not the subject of this discharge permit
application. For perspective, Table 2 and Figure 5 describe wastewater discharges to
MSD.
e) Please describe the type of process (i.e., compressor, A/C unit, chiller, boiler, etc.)
the wastewater is being discharged from, per each separate discharge point (if
applicable, use separate sheet):
Figure 2 shows all the L&B processes that contribute to wastewater discharges. Table 1
lists and describes all the process.

Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 10

Table 1. L&B Approximate Wastewater Discharge Source Volumes
Source
Number of
Processes
Discharge Volume1
(gal/day)
Chiller Water Cooling Towers 3 5,100
Compressor Cooling Towers 3 4,300
Cooper Cooling Tower 1 2,100
Polymer Extruders M1-M5 (21 lines) 5 3,400
Air Handling Units 7 200
Condensers 6 400
TOTAL -- 15,5002
1 Actual discharge volumes fluctuate significantly throughout each production day.
2 Total discharge volume is the monthly average of November 2017.

9) Is there any type of treatment being provided to the wastewater before discharge
(i.e., retention ponds, settling ponds, etc.)?
Yes.
Non-contact cooling waters and condensates are all routed through a dechlorination/flow
measurement tank system prior to discharge to the stormwater system (see Exhibits 1 and 2).
The system consists of a 160-gallon tank equipped with a flow meter, chlorine sensor, and
sodium bisulfite (NaHSO3) dosing. The second tank is a 500-gallon contact chamber that allows
all free chlorine to react with the NaHSO3 prior to discharging to the combined
wastewater/stormwater system. Attachment C of the Individual Permit application includes
descriptions and calculations for the dechlorination system.
This system was designed and installed by Garrett-Callahan, Inc. [http://garrattcallahan.com/].

Exhibit 1. Dechlorination Controls, Datalogger, Sensors, and Sodium Bisulfite Tank

Chlorine Inlet
and Outlet
Sensors
Dechlorination
System
Datalogger
Sodium
Bisulfite Flow
Controller
Sodium
Bisulfite
Tank
Sodium
Bisulfite
Pump
Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 11

Exhibit 2. Dechlorination and Flow Tank (Slim Tank)
Table 2. Low & Bonar Water Use
Month
Purchased
City Water
(gal/mo)
Discharged Water
(gal/mo) Cooling Tower
Evaporation
(gal/mo)
Un-Named
Tributary to
Hominy Creek
Metropolitan
Sewerage
District
Oct 3,255,296 619,971 1,033,736 1,601,589
Nov 2,232,780 461,057 961,928 809,795
Dec 2,180,420 501,771 1,015,784 662,865
Jan 3,364,504 805,176 1,329,944 1,229,384
Feb 2,822,204 735,225 1,334,620 752,359
Mar 2,941,884 596,627 1,406,486 938,771
Apr1 2,947,120

Not Available

1,340,761
Not Available
May1 3,446,784 1,477,708
Jun1 3,004,716 1,493,634
Jul1 3,040,620 1,317,827
Aug1 3,225,376 1,302,871
Sep Not Yet
Available 1,093,839
1 New data. Not included in previous reports.

The new data presented above were not part of the Individual Permit application. These
and previous data are presented graphically in Figure 5. This figure shows the reductions
in purchased water use from October 2017 onward; which is when Low & Bonar water
conservation efforts began to show an impact. This is a very large advance in water
conservation and a large reduction in potential impacts to Hominy Creek. Low & Bonar
has made significant investments and changes to their production facility to get to this
point.
Dechlorination
Solution
(NaHSO3)
Feed Line
Tank
Flow
Sensor
Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 12 TABLE 1. L&B - Average Purchased Water: January 2012 to March 20184,1454,3295,0234,7466,0485,7646,0136,1375,4404,3522,9852,9154,4985,1103,9333,9404,6084,0174,0654,3124,759 4,735 5,097 5,246 5,150 5,703 6,219 5,859 5,150 5,212 4,688 4,934 2,0003,0004,0005,0006,0007,000Jan Feb Mar Apr May Jun Ju; Aug Sep Oct Nov DecPurchased City Water (100 cubic feet [ccf])20172018AVERAGENote the reduction in 2017purchased City Water for October Through December.Note the reduction in 2018purchased City Water throughout 2018!Average purchased City Water  ccf/mo 2012 -2016. Figure 5. Low & Bonar – Monthly Purchased Water: 2012 to 2018 Note that on average, Low & Bonar purchased 6,219 hundred cubic feet (ccf) of water during July in 2012 to 2016. This amount is equal to 4,651,812 gallons of water. For comparison, in July 2018, purchased water was only 4,065 ccf (i.e., 3,040,620 gallons). Thus, this is a 34.6 percent reduction during the hottest month of the year from the average of the preceding five years! This reduction is part of Low & Bonar’s investment in new equipment and monitoring devices.
Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 13

A secondary effect is that less water volume discharged from the extruders is
significantly warmer than when the flow rate was higher. This is a basic temperature
transference principle; less water volume through the system results in warmer water.
Chlorine’s solubility in water drops dramatically as water temperature increases. Figure
6 shows this effect.

Figure 6. Chlorine Solubility in Water as a Function of Temperature

We estimate the average extruder water has increased from an initial temperature at the
inlet to the Low & Bonar property of about 15̊ C (60º F) to a final temperature of about
38̊ C (100̊ F). Despite extruder water being about 75 percent of the total discharge water
to Hominy Creek:

[(15,500 gal/d x 30.4 d/mo) / 619,971 gal/mo] x 100 = 75 percent – Equation 1

(i.e., average extruder water + groundwater + stormwater for the period October 2017 to
March 2017) the discharge water temperature is relatively unchanged. The combined
piping system lies in groundwater moving through the site; which chills the water.

From Figure 6, the solubility of chlorine in water decreased by about 50 percent. City
Water; which contains about 1.4 parts per million (ppm) chlorine (1.4 milligrams chlorine
per million milligrams water plus chlorine) at 60̊ F; can contain the same amount of
chlorine 100̊ F – the maximum chlorine gas in water at 38̊ C is 5,000 ppm. Overall, the
temperature difference has made little difference in chlorine concentration – City Water
chlorine concentration of 1.4 ppm is well below saturation at 38º C (5,000 ppm).

15 38 Solubility (mg Cl2 Gas per Liter Water) [parts per million] Water Temperature (̊ C)
10,000
9,000
8,000
7,000
6,000
5,000
4,000
3,000
2,000
1,000
0
Initial
Temperature
Final
Temperature
Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 14

Figure 3. Extruder Cooling Water Break/Air Gap

Tests conducted of extruder water at the final extruder temperature show that about 85
percent of the chlorine has off-gassed. Chlorine gas escapes from the water break. This
is a true reduction of chlorine and water.

Water Break: Extruder water
Discharge to Wastewater
System
Extruder Water
Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 15

Q2.a The reviewers were looking for the cost of maintaining NPDES permit limits in in the
Present Value of Costs Analysis (PVCA). This should be included for the discharge
alternative under recurring costs (Table 6.).

The EAA guidance suggests including laboratory costs for monitoring. Additionally,
permit and compliance fees should also be included. Please update the PVCA to
include this information for maintaining a permit with limited parameters.

A2.a A revised summary of all Present Value Cost Analysis (PVCA) for Discharge Dechlorinated
Water to Hominy Creek is included in Table 3. This summary includes the following cost items
from the Engineering Alternatives Analysis:

1. Weekly laboratory costs plus reporting costs by a contractor.
2. Annual operation of the discharge system by L&B Environmental Staff.
3. No residuals are produced by the system!
4. Application fee is calculated separately from the annual fee.
5. Annual compliance fee is calculated separately from the application fee.
6. Utility costs are for electricity only.
7. Weekly maintenance of the system by L&B Maintenance Staff.
8. Initial set-up of datalogging system by L&B IT Staff plus Annual Review of software.
A2.a A revised summary of all Present Value Cost Analysis (PVCA) for all NPDES
options is included in Table 4.

Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 16 Table 3. Present Value Cost Analysis (PVCA) for Low & Bonar – Maintaining NPDES Permit Limits ComponentCapital Cost ($)Recurring Cost ($)Period (yr)Annualized Recurring Cost ($/yr)Total Capital + Recurring Cost ($)Total Cost ($)Probes (4)2000 2,000 1 2000 4,000 50,381Datalogger4200 4,500 5 900 5,100 64,236Bisulfite Pump1100 1,300 10 130 1,230 15,492Bisulfite Tank800 0 1 0 800 2,073Installation3260 0 1 0 3,260 41,061Bisulfite Formula 66001270 2,540 1 2540 3,810 47,988Maintenance Monthly0 120 1 120 120 1,511Weekly Laboratory Costs + Reporting (Pisgah Enviro.)0 550 1 550 550 6,927Annual Operator and Support 0 1200 11200 1,200 15,114Residual Disposal 0 0 1000Initial Permit Application Fee 860 0 10 860 2,228Annual Compliance Fee 0 860 1860 860 10,832Annual Utility Costs 0 336 1336 336 4,232Weekly Maintenance0 120 1 120 120 1,511Lost Opportunity Costs001000Integrate Into L&B IT System 3000 300 1 300 3,30041,565305,154Garratt-CallahanLow & BonarTOTAL
Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 17 Table 4. Present Value Cost Analysis (PVCA) for Low & Bonar – Summary of All Options ComponentCapital Cost ($)Recurring Cost ($)Period (yr)Annualized Recurring Cost ($/yr)Total Capital + Recurring Cost ($)Total Cost ($)Extruder Water Cooling Tower 12,600 250 1 250 12,850 161,850Re-Use Boiler Condensate 33,600 1,900 1 1,900 35,500 450,586Discharge to Hominy Creek 13,490 13,526 1 13,526 27,016 305,154Ship Wastewater for Disposal 0 2,970,000 1 2,970,000 2,970,000 37,408,219Extruder Water Cooling Chiller 54,200 30,634 1 30,634 84,834 878,740Wastewater Reductions 469,625 70,0251 70,025 539,650 6,260,524Wastewater Evaporator 37,100 2,796,300 1 2,796,300 2,833,400 35,670,941
Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 18

We assure you that Low & Bonar is completely committed to resolving our permitting issue and
to protecting water quality in Hominy Creek. Low & Bonar will work with your staff to ensure
continuous compliance.

Please contact Steve Jenkins at 828-665-3544 or via email at [e-mail]
with questions or comments on the contents of this letter.

Best Regards,
Pisgah Environmental Services, LLC

Daniel J. March
Principal

CC: Juan Carlos Maldonado, L&B, Manufacturing/Site Manager
Clive Macro, L&B, HSE Director, London
Steven Meun, L&B, HSE Manager, London
Stephen C. Jenkins, L&B, HSE Manager North America
Low & Bonar Inc. – Wastewater Discharge Permit Application – Additional Information 19

ATTACHMENT A
Communications
Derek Denard, NC DEQ/DWR
10/23/2018 Virginia Tech Mail - EAA Review for NPDES application for Low & Bonar
https://mail.google.com/mail/u/0?ik=a59e07b8d8&view=pt&search=all&permmsgid=msg-f%3A1613137775413410427&simpl=msg-f%3A16131377754…1/2
Daniel March <[e-mail]>
EAA Review for NPDES application for Low & Bonar
Denard, Derek <[e-mail]>Mon, Oct 1, 2018 at 11:34 AM
To: Daniel March <[e-mail]>
Dan,

We need two more adjustments to the EAA.

1. The reviewers were considering whether this facility may be Categorical under 40
CFR. The applicable Categories may be 40 CFR 410 Textile Mills or 40 CFR 414
Organic Chemicals, Plastics, and Synthetic Fibers. Are the plastic extruders cooled
by “non-contact cooling” water? I looked back at the application for the general
permit and I believe you covered this description under application question C
(What type of wastewater is discharged?). You may also want to include Figure 1.
(Process Flow Diagram – Yarn Production) from the general permit application in
your response. I believe a simple diagram of the extruder process may help
determine if we are looking at a Categorical industry or not.
2. The reviewers were looking for the cost of maintaining NPDES permit limits in in
the Present Value of Costs Analysis (PVCA). This should be included for the
discharge alternative under recurring costs (Table 6.). The EAA guidance suggests
including laboratory costs for monitoring. Additionally, permit and compliance fees
should also be included. Please update the PVCA to include this information for
maintaining a permit with limited parameters.

Thanks,

Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources