NC0004626_Report_20190604

GbNippon Electric Glass
Electric Glass Fiber America, LLC
473 New Jersey Church Road Lexington, NC 27292 [phone]
June 4, 2019
Ms. Julie Grzyb
North Carolina Department of Environmental Quality
NPDES Permitting
1617 Mail Service Center
Raleigh, NC, 27699-1617
Re: Activated Carbon Filtration Test Program
NPDES Permit No. NC0004626
Electric Glass Fiber America, LLC Lexington, NC Facility
Dear Ms. Grzyb:
RBcENED/NCDEQ/DWR
JUN 14 2019
Water Quality
Permitting Section
Electric Glass Fiber America (EGFA) operates a fiberglass manufacturing facility in Lexington, NC with
a wastewater treatment plant (WWTP) and effluent discharge authorized by NPDES Permit No.
NC0004626. One of the limitations in the NPDES permit is a criterion for biomonitoring- a quarterly
Chronic Toxicity Pass/Fail Permit Limit. In order to comply with this limitation, EGFA added an
activated carbon filtration system in the WWTP in 1997. Since that time EGFA has consistently been in
compliance with the NPDES permit criteria.
Over the last several years there have been significant changes in the EGFA production facility. We have
come under new management, eliminated our Fluoride discharge and have made significant changes in
our production. We feel these that these changes have eliminated the need for operation of the activated
carbon filtration system and that EGFA can consistently comply with the biomonitoring criteria without
use of the activated carbon filtration system.
We are proposing to conduct monthly biomonitoring of the secondary clarifier effluent (prior to activated
carbon filtration) for the next three months as a test program to demonstrate that the activated carbon
filtration is not needed to achieve compliance with the biomonitoring criteria. This testing will follow the
protocol in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure." If we pass these
tests, we will be requesting that the Department agree to eliminate the requirement for operation of the
activated carbon filtration system from the NPDES permit. However, we would propose to retain the
activated carbon filtration system equipment in our WWTP and agree to reinitiate the system operation if
required in the future.
We appreciate the Department's assistance in our environmental control program. Please let us know if
this is an acceptable test program, or if you have any suggested changes. In the meantime, please feel free
to call or email me at 336-357-8151 Ext 3317 or brigette.tinsleykEGFA-us.com if you have any
questions or desire any additional information.
SinceLely,
Brigette Tinsley, EHS