NC0089834_More Information Received_20180615

9 WOM96LE AVE NSE § AJHEQILLE. NC 18804 § PHONE [phone] § FAX [phone] § [e-mail]
May 29, 2018
North Carolina Department of Environmental Quality
Division Water Resources
Water Quality Permitting Section — NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Attn: Derek Denard, Environmental Specialist
Re: Low & Bonar, Inc.
Individual NPDES Permit Application
Dear Mr. Denard:
RECEIVED/DENR/DWR
JUN 0 6 2018
Water Resources
Permitting Section
Attached with this letter is an application from Low & Bonar, Inc. (L&B) to request an Individual Permit
under the National Pollutant Discharge and Elimination System (NPDES) permitting system to discharge
non -contact and once -through cooling waters and condensates to surface waters.
L&B is a non -woven fabric manufacturing facility that uses relatively inert materials (i.e., polypropylene,
nylon, and polyethylene terephthalate (PET)) to make filaments and yams that are fashioned into
geosynthetic fabrics and carpet backing.
This permit application describes actions L&B has taken to reduce the amount of cooling water used
daily. The application also describes actions to ensure that only non -contact and once -through cooling
waters and condensates are discharged to surface waters. We also evaluated the impacts of cooling tower
water treatment chemicals have upon surface water biota. Contained in Attachments to the application
are EPA Forms I and 2C and the North Carolina Division of Water Resources Engineering Alternatives
Analysis. Other supporting information is also included.
This letter does not contain the full $860 application fee. L&B paid $100 for the General Permit
application; which was returned. The balance — $760 — will be sent to DWR by June 4.
Finally, included with this letter is the Buncombe County zoning consistency letter.
Please contact me at 828-768-3335 or via email at Pisgah-airCd!vt.edu with questions or comments.
Process questions should be directed to Mr. Steve Jenkins at 828-665-3544 or via mail at
Steve.Jenkinsc a=LowandBonar.com.
In advance, thank you for your assistance.
Regards,
Pis ah vironmental S -i es, LLC
Daniel J. March
Principal

Low&
Bonar
April 30, 2018
Buncombe County Planning and Development Department
46 Valley Street
Asheville, NC 28801
Attn: Nathan Pennington,
Planning Director
Re: Low & Bonar Inc. Wastewater Discharge Permit
Mr. Pennington:
Low & Bonar Inc.
PO Box 1057
Enka, NC 28728
T 828 665 5000
F 828 665 3737
lowandbonar.com
Buncombe County
Planning and Development
Received
MAY 18 2018
46 Valley Street
Asheville, NC 28801
828-250-4830
Low & Bonar Inc. plans to apply to the NC Department of Environmental Quality, Division of Water Resources
for an Individual National Pollutant Discharge and Elimination System (NPDES) permit for their non -woven
textile manufacturing facility in Enka (Buncombe County), North Carolina. This planned discharge consists of
non -contact cooling waters, cooling tower blowdowns, condensate waters, and once -through cooling waters to
an un -named tributary to Hominy Creek. Figure 1 (attached as an over -sized supplement) is a diagram of the
Low & Bonar process. Figure 2 is a Buncombe County aerial view of the site that shows property lines.
The un -named tributary that receives Low & Bonar's discharged waters has a continuous flow — it is not an
ephemeral stream. The USGS estimates the base flow is 0.45 cubic feet per second (ft;/s); about 291,000
gallons per day.
We estimate — based on water flow sensors — that about 20,856 gaud of cooling waters and condensates are
discharged to the creek. Another 29,500 gaud of groundwater that infiltrates our stormwater collection system
are also discharged to the creek. Thus, the cooling waters and condensates will make up about 6.1 percent of the
volume of the un -named tributary to Hominy Creek.
Our application — see attached — makes it clear that Low & Bonar has made significant effort to reduce
wastewater discharges. Our investigations and calculations show that the impacts of cooling water treatment
chemicals will have no discernable impact on the biota of Hominy Creek and that our wastewater will be in
compliance with all NC DEQ effluent limitations but two — copper and zinc. Copper is in the piping of our 1928
facility. Zinc is in the drinking water we purchase from the City of Asheville, and it will make up about half the
amount of zinc that is discharged to Hominy Creek.
We need your department to evaluate the information contained in our attached NPDES permit application to
determine whether Buncombe County considers that activities conducted by the existing Low & Bonar
manufacturing facility are in compliance with zoning regulations.
Background (provided by the Division of Water Resources):
North Carolina General Statute 143-215.1 (c)(6) allows input from local governments in the issuance of NPDES
Permits for non -municipal domestic wastewater treatment facilities. Specifically, the Environmental
Management Commission (EMC) may not act on an application for a new non -municipal domestic wastewater
discharge facility until it has received a written statement from each city and county government having
jurisdiction over any part of the lands on which the proposed facility and its appurtenances are to be located.
Low & Bonar Inc. — Wastewater Discharge Permit Application — Engineering Alternatives Analysis

The written statement shall document whether the city or county has a zoning or subdivision ordinance in effect
and (if such an ordinance is in effect) whether the proposed facility is consistent with the ordinance. The EMC
shall not approve a permit application for any facility which a city or county has determined to be inconsistent
with zoning or subdivision ordinances unless the approval of such application is determined to have statewide
significance and is in the best interest of the State.
Instructions to the Applicant:
Prior to submitting an application for a NPDES Permit for a proposed facility, the applicant shall request that
both the nearby city and county government complete this form. The applicant must:
Submit a copy of the permit application (with a written request for this form to be completed) to
the clerk of the city and the county by certified mail, return receipt requested.
If either (or both) local government(s) fail(s) to mail the completed form, as evidenced by the
postmark on the certified mail card(s), within 15 days after receiving and signing for the
certified mail, the applicant may submit the application to the NPDES Unit.
As evidence to the Commission that the local government(s) failed to respond within 15 days,
the applicant shall submit a copy of the certified mail card along with a notarized letter stating
that the local government(s) failed to respond within the 15 -day period.
Instructions to the Local Government:
The nearby city and/or county government which may have or has jurisdiction over any part of the land on
which the proposed facility or its appurtenances are to be located is required to complete and return this form to
the applicant within 15 days of receipt. The form must be signed and notarized.
Buncombe County
Planning & Development Department
Does the city/county have jurisdiction ove any part of the land on which the proposed facility and its
appurtenances are to be located? Yes [ No [ ]
If no, please sign this form, have it notarized, and return it to the applicant.
Does the city/county have in effect a zoning or subdivision ordinance? Yes [ to [ ]
If there is a zoning , �or �bdivision ordinance in effect, is the plan for the proposed facility consistent with the
ordinance? Yes 011 L ]
Date Signau e ( , Planning and Development)
State of North Carolina, County of Buncombe
.6t
On this a r day of (c/ 2018, personally appeared before me, the said name
'h 10to me known and known to me to be the person described in and
who executed the foregoing document and he (or she) acknowledged that he (or she) executed the same and
being duly sworn by me, made oath that the statements in the foregoing document are true.
My Commission expires Aare% 1 °l ,20 \0 \�JLA'W�
0 MYCRAA4IR EXXPIR
(Signature of Notary Public) - 2 G
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Low & Bonar Inc. —Wastewater Discharge Permit Application —Engineering ,\Ite'tiV sow f ���