NC0089621_Comments_20181113

novozymes®
Rethink Tomorrow
November 13, 2018
Via U.S. Mail and E-Mail
Jeffrey Poupart
Water Quality Permitting Section Chief
NCDEQ - Division of Water Resources
1611 Mail Service Center
Raleigh, North Carolina 27699-1611
[e-mail]
Julie Grzyb
Supervisor, Complex Permitting Unit
NCDEQ - Division of Water Resources
1611 Mail Service Center
Raleigh, North Carolina 27699-1611
[e-mail]
Teresa Rodriguez RECEIVED/DENRJDWR
Complex Permitting Unit
NCDEQ - Division of Water Resources NOV 2 6 2018
1611 Mail Service Center
Raleigh, North Carolina 27699-1611
Water Resources
[e-mail] Permitting Section
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 provides a status update regarding progress on the referenced permit application
and outstanding action items. As you recall, in May 2016, Novozymes North America, Inc.
("Novozymes") submitted NPDES Permit Application NC0089621 (the "Permit Application")
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for authorization to treat and discharge to surface waters up to two million gallons of
wastewater per day (2 MGD). On August 24, 2018, representatives of Novozymes and the
Division of Water Resources (the "Division") met and agreed on next steps and action items
toward issuance of a draft NPDES permit, which action items were set forth in my letter to
you dated August 30, 2018. Substantial progress has been made on these items since
August as described below, and the Division should have all of the outstanding information
upon which to finalize a draft permit in the next thirty (30) days.
Status of Action Items from Meeting on August 24
1. Potassium Aquatic Life Values
The first action item was for Ramboll Group and Novozymes to finalize and submit a report to
the DWR-Standards Branch that provides acute and chronic aquatic life standards for
potassium. Novozymes submitted Ramboll Group's Potassium Aquatic Life Values Study
Report(September 2018) to the Standards Branch on September 24, 2018. We received the
Standards Branch's comments on the Study Report that were included with Ms. Rodriguez's
letter to me dated November 6, 2018. As requested by the Division, within thirty (30) days,
we will submit a revised Study Report that addresses the comments. Submission of the
revised Study Report should close this issue.
2. Pilot Testing and Feasibility Review of Reverse Osmosis Treatment
Novozymes has completed the pilot testing and feasibility review of a reverse osmosis ("RO")
wastewater treatment system and has determined that such a system is technically feasible
for this project. Discussion of this technology will be included in the updated analysis of best
available technology economically achievable ("BAT") and the updated Engineering
Alternatives Analysis noted below. This action item is complete.
3. Revised BAT Analysis
As agreed at the August 24 meeting, representatives of Novozymes and Dewberry
Engineering, Inc. met with Teresa Rodriguez, Mike Templeton, and Bing Bai of the Division
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on September 5, 2018 and agreed on a protocol and parameters for a revised BAT analysis.
The agreed-upon protocol and parameters were detailed in my letter to the Division dated
September 7, 2018. The revised BAT analysis report remains in process and is scheduled to
be submitted to the Division on or before November 30. Submission of the revised BAT
analysis report should close this issue.
4. Cedar Creek Water Quality Modeling
As agreed at the August 24 meeting, representatives of Novozymes and Dewberry
Engineering, Inc. met with Teresa Rodriguez, Bing Bai, and Adugna Kebede of the Division
on September 26, 2018 and agreed on a protocol to address the Division's comments
regarding the Cedar Creek water quality model. The agreed-upon protocol was detailed in
my letter to the Division dated October 1, 2018. Dewberry completed the revised QUAL2K
Cedar Creek Model (October 2018) in accordance with the agreed-upon protocol, and the
model was submitted to the Division on October 26, 2018. This issue should now be closed.
5. Revised Engineering Alternatives Analysis Report
As agreed at the August 24 meeting, Novozymes is preparing revisions to the Engineering
Alternatives Analysis ("EAA") report and will include a discussion of RO as part of a
technically feasible wastewater treatment system and discharge to Cedar Creek. The
revised EAA report remains in process and is scheduled to be submitted to the Division on or
before November 30. Submission of the revised EAA report should close this issue.
6. New Application Package
As agreed at the August 24 meeting, for simplicity and ease of final review by the Division,
Novozymes is preparing a new application package that will replace the original Permit
Application submitted in May 2016, with the agreement that the Division will consider the new
application package as submitted on the date of the original Permit Application and that the
Application will maintain its same order of priority. The new application package will be
submitted with the revised BAT report and the revised EAA report on or before November 30.
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,
novozymes®
Rethink Tomorrow
Thank you again for your time and efforts regarding review and processing of the Permit
Application. We look forward to working with the Division toward issuance of a draft NPDES
permit.
Sincerely,
)//
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
Adugna Kebede, Modelling &Assessment Branch
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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