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NORTH CAROLINA
Environmental Quality
August 21, 2019
Mr. John B. Cates, President
Addis Cates Co., Inc.
PO Box 146
Parkton,NC 28371-0146
Subject: Draft NPDES Permit NC0089451
Former Cates Brinery
Grade I Physical Chemical WPCS
Robeson County
Dear Mr. Cates:
The Division has reviewed your request to renew the subject permit. Please review this draft carefully
to ensure your thorough understanding of the information, conditions, and requirements it contains.
The draft permit includes the following significant changes from the existing permit:
1. Language has been updated in Section A. (1) and Section A. (2)to require electronic submission
of effluent data. Federal regulations require electronic submittal of all discharge monitoring
reports (DMRs).
2. Regulatory citations have been added to the permit.
3. Outfall map has been updated.
4. Receiving stream characteristics have been updated on the Supplement to Permit Cover Sheet.
5. Units of measure and the facility grade have been added in Section A. (1).
6. Monitoring has been decreased to 2/Month for turbidity and pH.
7. Chloride and Mercury daily limits have been removed and monthly averages have been added,
and monitoring has been reduced for chloride, per the reasonable potential analysis.
8. Limits have been added for Total Copper, Selenium, and Silver in Section A. (1)based on a
reasonable potential to exceed water quality standards.
9. Monitoring for Total Zinc has been removed in Section A. (1)based on the reasonable potential
analysis.
10. Quarterly Total Hardness monitoring has been added in Section A. (1).
11. Footnotes in Section A. (1)have been updated.
12. Special conditions in Section A. (1) have been updated.
13. Toxicity monitoring has been removed in Section A. (1) and the associated Section A. (2) has
been removed as this will no longer be required.
D.95\
North Carolina Department of Environmental Quality I Division of Water Resources
1617 Mail Service Center I Raleigh,North Carolina 27699-1617
919-707-9000
Please note that the practical quantitation limits (PQLs) for Total Copper is 2.0 µg/L, Mercury is 1.0
ng/L, Selenium is 1.0 ug/L, and Silver is 1.0 µg/L(per the Inorganic Chemistry Branch of the Division
of Water Resources Water Sciences Section)and monitoring data should be reportable down to these
levels. Per North Carolina 15A NCAC 02B Water Quality Standards for Surface Waters,the current
limits for class C waters for copper are 10.47 µg/L(acute) and 7.88 µg/L(chronic), for mercury are 12
ng/L(chronic), selenium are 56.0µg/L(acute) and 5.0µg/L(chronic), and silver are 0.296 µg/L(acute)
and 0.060 µg/L(chronic). Limits are determined by evaluating DMR data submitted to the Division,
along with a dilution factor(if applicable) and the maximum monthly average flow reported in the
previous 3 years at the time the review is completed. Please also note that parameters should be
reported in the units specified in the permit.
Concerning your request for a reduction in monitoring for metals, chloride, turbidity,pH, and salinity, as
well as the removal of WET testing,monitoring for several metals cannot be reduced due to a reasonable
potential to exceed water quality standards. Monitoring for chloride has been reduced to monthly per the
reasonable potential analysis, and monitoring for turbidity, and pH has been reduced. Whole effluent
toxicity testing has been removed from the permit.
With this notification, the Division will solicit public comment on this draft permit by publishing a
notice in newspapers having circulation in the general Robeson County area,per EPA requirements.
Please provide your comments,if any,to me no later than 30 days after receiving this draft
permit.
Following the 30-day public comment period,the Division will review all pertinent comments and take
appropriate action prior to issuing a final permit. If you have questions concerning the draft,please
contact me at 919-707-3619, or via e-mail [Brianna.Young@ncdenr.gov].
Sincerely,
Brianna Young
Compliance and Expedited Permitting Unit
cc: NPDES Files
Fayetteville Regional Office
WSS/Aquatic Toxicology Branch
Permit NC0089451
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Water Quality Commission, and the
Federal Water Pollution Control Act, as amended,
Addis Cates Company, Inc.
is hereby authorized to discharge wastewater from a facility located at
Former Cates Brinery Groundwater Remediation Site
2640 McIver Road
Parkton
Robeson County
to receiving waters designated as Dunns Marsh (Hughes Mill Pond) in the Lumber River Basin in
accordance with the discharge limitations, monitoring requirements, and other conditions set forth in
Parts I, II, III, and IV hereof.
This permit shall become effective
This permit and the authorization to discharge shall expire at midnight on July 31, 2024.
Signed this day
Linda Culpepper
Director, Division of Water Resources
By the Authority of the Environmental Management Commission
Page 1 of 7
Permit NC0089451
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore,the exclusive authority to operate and discharge from this facility arises under the
permit conditions,requirements,terms, and provisions included herein.
Addis Cates Company, Inc.
is hereby authorized to:
1. Construct and operate a treatment system to remediate groundwater contaminated with sodium
chloride(NaCl) and other parameters of concern from facilities located at the Former Cates Brinery,
located at Addis Cates Company, Inc., 2640 McIver Road in Parkton in Robeson County.
2. Discharge from the said treatment works at a location specified on the attached map into Dunns
Marsh(Hughes Mill Pond) [Stream Segment: 14-22-1-3-2], a waterbody currently classified C; Sw
waters in subbasin 03-07-53 [HUC: 0304020306] in the Lumber River Basin.
Page 2 of 7
Permit NC0089451
PART I.
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
Grade I Physical Chemical WPCS [15A NCAC 08G .0302]
Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to
discharge via Outfall 001. Such discharges shall be limited and monitored' by the Permittee as specified
below: I
EFFLUENT LIMITS MONITORING REQUIREMENTS
CHARACTERISTICS Monthly Daily Measurement Sample Sample
Parameter Codes Average Maximum Frequency Type Location 2
Flow 50050 0.025 MGD Continuous Recording Effluent
pH 00400 Not<6.0 s.u. nor> 9.0 s.u. 2/Month Grab Effluent
Turbidity(NTU) 00070 2/Month Grab Effluent
Salinity(ppt) 00480 Weekly Grab Effluent
Salinity(ppt) 00480 Monthly Grab U &D
Chloride 00940 230 mg/L Monthly Grab Effluent
Chloride(mg/L) 00940 Monthly Grab U &D
Total Copper 01042 7.88 pg/L 10.47 pg/L Monthly Grab Effluent
Total Mercury COMER 12 ng/L Monthly Grab Effluent
Total Selenium 01147 5.0 pg/L 56.0 pg/L Monthly Grab Effluent
Total Silver 01077 0.060 pg/L 0.296 pg/L Monthly Grab Effluent
Hardness—Total as 00900 Quarterly Grab Effluent
[CaCO3 or(Ca+ Mg)]3(mg/L)
Hardness—Total as 00900 Quarterly Grab Upstream
[CaCO3 or(Ca+Mg)]4(mg/L)
Footnotes:
1. The permittee shall submit discharge monitoring reports electronically using the NC DWR's eDMR
application system [see Section A. (2)].
2. U=upstream—100 feet from the outfall; D=Downstream—100 feet.
3. Effluent hardness sampling should be performed in conjunction with testing for hardness dependent
metals(copper and silver).
4. The Permittee shall sample instream hardness, upstream of the facility's discharge. The sample shall be
representative of the hardness in the receiving stream. If the Permittee is a member of the Monitoring
Coalition Program, sampling for instream hardness may be waived as long as the Monitoring coalition
agrees to sample hardness at the nearest upstream location, at a minimum frequency of quarterly, and the
Permittee has obtained approval from DWR-NPDES Permitting Unit that the upstream station being
monitored by the Coalition is representative of the receiving stream for this discharge. The Permittee is
responsible for submitting instream hardness test results with its permit renewal application package. If
Coalition membership is cancelled or the Coalition terminates instream hardness sampling at the
approved station, the Permittee will immediately notify the Division and resume sampling for instream
hardness,upstream of its discharge.
Page 3 of 7
Permit NC0089451
All samples collected should be from a representative discharge event.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 4 of 7
Permit NC0089451
A. (2) ELECTRONIC REPORTING OF MONITORING REPORTS
[NCGS 143-215.1 (b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program
reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December
21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this
li permit(Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)1
The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report(eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring
data and submit DMRs electronically using the internet. Until such time that the state's eDMR
application is compliant with EPA's Cross-Media Electronic Reporting Regulation(CROMERR),
permittees will be required to submit all discharge monitoring data to the state electronically using
eDMR and will be required to complete the eDMR submission by printing, signing, and submitting one
signed original and a copy of the computer printed eDMR to the following address:
NC DEQ/Division of Water Resources /Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an area where less than 10 percent of the households have broadband access,
then a temporary waiver from the NPDES electronic reporting requirements may be granted and
discharge monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3)or alternative forms
approved by the Director. Duplicate signed copies shall be submitted to the mailing address above. See
"How to Request a Waiver from Electronic Reporting" section below.
Regardless of the submission method,the first DMR is due on the last day of the month following the
issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
Starting on December 21,2020, the permittee must electronically report the following compliance
monitoring data and reports,when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
Page 5 of 7
Permit NC0089451
• Clean Water Act(CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division(see"How to Request a
Waiver from Electronic Reporting"section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9),the permittee must identify the initial recipient at the time of
each electronic submission. The permittee should use the EPA's website resources to identify the initial
recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity
(EPA or the state authorized by EPA to implement the NPDES program)that is the designated entity for
receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each
type of electronic submission and for each state. Instructions on how to access and use the appropriate
electronic reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting
Rule is found at: https://www.federalregister.gov/documents/2015/10/22/2015-24954/national-pollutant-
discharge-elimination-system-npdes-electronic-reporting-rule.
Electronic submissions must start by the dates listed in the"Reporting Requirements" section above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an
electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to the
Division. Requests for temporary electronic reporting waivers must be submitted in writing to the
Division for written approval at least sixty(60) days prior to the date the facility would be required
under this permit to begin submitting monitoring data and reports. The duration of a temporary waiver
shall not exceed 5 years and shall thereupon expire. At such time,monitoring data and reports shall be
submitted electronically to the Division unless the permittee re-applies for and is granted a new
temporary electronic reporting waiver by the Division. Approved electronic reporting waivers are not
transferrable. Only permittees with an approved reporting waiver request may submit monitoring data
and reports on paper to the Division for the period that the approved reporting waiver request is
effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on the
following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)1
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II,
Section B. (11.)(a)or by a duly authorized representative of that person as described in Part II, Section
B. (11.)(b). A person, and not a position,must be delegated signatory authority for eDMR reporting
purposes.
Page 6 of 7
Permit NC0089451
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account
and login credentials to access the eDMR system. For more information on North Carolina's eDMR
system, registering for eDMR and obtaining an eDMR user account, please visit the following web
page:
http://deq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the
following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE
ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or persons
who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief true, accurate, and complete. I am
aware that there are significant penalties for submitting false information, including the possibility of
fines and imprisonment for knowing violations."
5. Records Retention [Supplements Section D. (6.)1
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions.
These records or copies shall be maintained for a period of at least 3 years from the date of the report.
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Thisperiod maybe extended byrequest of the Director at anytime [40 CFR 122.41 .
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Page 7 of 7
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