NCG500608_Regional Office Physical File Scan Up To 6/1/2020

DISCHARGED WATER STUDY
REPORT 3
FOR
LOW&
Bonar
Low & Bonar Inc.
1302 Sandhill Road
Enka, North Carolina 27105
Prepared For:
Landon Davidson, Regional Supervisor, Division of Water Resources
Linda Wiggs, Environmental Senior Specialist, Division of Water Resources
North Carolina Department of Environmental Quality
Water Quality Regional Operations Section
2090 US Highway 70
Swannanoa,NC 28778
Date:
November 29, 2017

Low& Low&Bonar Inc.
i PO Box 1057
Bonar JAN 1 6 2018 e kaNcz37za
T 828 665 5000
� ilm'a F 828 665 3737
lowandbonaccom
January 10, 2018
RE: Change of Low& Boner's Responsible Official for Regulatory Purposes
VIA Certified Return Receipt Mail
G. Landon Davidson, P.G.
Regional Supervisor Water Quality Regional Operations
NCDEQ Division of Water Quality
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
Dear Mr. Davidson:
This letter is to inform you that Wayne Merritt has left the company and will no longer
serve as the Responsible Official for the Low& Bonar Inc. Asheville site.
Effective immediately, I will be your contact as the Responsible Official for Low & Bonar
Inc., Asheville. Steve Jenkins will continue to serve as the Technical and Inspection
contact for the site.
If you have questions or concerns, please let me know.
Sincerely,
Rick Wagner
Site Manager/Manufacturing Manager, Low & Bonar Inc.
cc: Steve Jenkins, Low& Bonar Inc.
Herman Pluimers, Low & Bonar PLC
Clive Macro, Low & Bonar PLC

i
Low& Low&Bonar Inc.
PO Box 1057
Bonar
1 6 2013 Enka, NC 28728
Q T 828 665 5000
F 828 665 3737
lowandbonarcom
January 10, 2018
RE: Change of Low& Bonar's Responsible Official for Regulatory Purposes
VIA Certified Return Receipt Mail
Ms. Linda Wiggs, Environmental Senior Specialist
NCDEQ Division of Water Quality
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
Dear Ms. Wiggs:
This letter is to inform you that Wayne Merritt has left the company and will no longer
serve as the Responsible Official for the Low & Bonar Inc. Asheville site.
Effective immediately, I will be your contact as the Responsible Official for Low& Bonar
Inc., Asheville. Steve Jenkins will continue to serve as the Technical and Inspection
contact for the site.
If you have questions or concerns, please let me know.
Sincerely,
Rick Wagner
Site Manager/Manufacturing Manager, Low & Bonar Inc.
cc: Steve Jenkins, Low& Bonar Inc.
Herman Pluimers, Low & Bonar PLC
Clive Macro, Low & Bonar PLC

Low& Law&Bonar Inc.
PO Box 1057
Bonar Enka, 66 2
8728
T 828 665 5000000
November 29, 2017 F 828 665 3737
lowandbonar.com
North Carolina Department of Environmental Quality
Division Water Resources
2028 US Highway 70
Swannanoa,NC 28787
Attn: Landon Davidson
Regional Supervisor
Re: Low and Bonar Inc.
Discharged Water Permit Application Report 3
Mr. Davidson:
The purpose of this letter is to present the results of Low&Bonar Inc.'s fourth discharged water sampling and
analysis event. This effort was completed to demonstrate the effects of actions taken to mitigate and address
discharges of cooling tower blowdowns, condensate waters,and once-through cooling waters to Hominy
Creek.
Over the past six months Low&.Bonar has made significant infrastructure changes to reduce impacts to
surface waters. These changes include:
1. Reduced non-contact cooling water through Cooling Towers.
2. Reduced non-contact cooling water through Extruders.
3. Recycled non-contact boiler condensate water.
4. Installed water flow meters.
5. Installed a dechlorination system.
We believe that this report—and the reports for the three previous sampling events— demonstrates that Low
and Bonar is now and has been substantially in compliance with North Carolina Surface Water Pollutant
Discharge Limits. Moreover,this report shows that Low&Bonar has,based upon preliminary data,reduced
its purchased water and discharged water.
Please review the results of our infrastructure and operational changes. We believe that you will agree that a
General Permit is appropriate for our facility.
Contact me Steve.JenlcinsLtLowandBonar.com or at 828-707-5805 with questions or comments.
Sincerely,
Stephe�,HSE .. anager,North America
CC: Wayne Merritt, L&B,Manufacturing/Site Manager
Clive Macro, L&B, HSE Director, London

PUGA 11
ENMONMENT& SERVICE!, LLC
9 W04DOELE AOENVE 4 NHEOILLE,NC 28804 4 828.766.3335 ¢ PI1G9M-dIRWOT.EDO
January 18,2018
North Carolina Department of Environmental Quality
Division Water Resources
2028 US Highway 70
Swannanoa,NC 28787
Ulvicion of Waier ftesourcm
Attn: Landon Davidson
Regional Supervisor JAN 19 2018
Linda Wiggs
Permit Engineer Water Qmonv noglonal Operations
f h .tJr(ico
Re: Low& Bonar Inc. -
Discharge Water Study-Report 4
The purpose of this letter is to present Low&Bonu's fourth report of sampling and analysis
activities undertaken to complete a Notice of Intent to the Division of Water Resources. This
report is of wastewater discharge pollutant concentrations in the compliance point and of the
impact of those waters on an un-named tributary to Hominy Creek in Enka,NC.
The information contained in this report supplements Table 4 in Attachment D of the Notice
of Intent that was filed with your office on December 18,2017. That document contained
preliminary data only-we had not yet received the final laboratory analysis report when it
was filed.
Thank you and Ms. Wiggs for your time and input during the past several months. We assure
you that Low&Bonar is completely committed to resolving our permitting issue and to
protecting water quality in Hominy Creek. We will work with your staff to ensure continuous
compliance.
Please contact me with questions or comments.
Regards,
Pisgah Environmental Services,LLC
Daniel J.March
Principal

DISCHARGED WATER STUDY
REPORT 4
FOR
Low&
Bonar
Low & Bonar Inc.
1302 Sandhill Road
Enka, North Carolina 27105
Prepared For:
Landon Davidson, Regional Supervisor, Division of Water Resources
Linda Wiggs, Environmental Senior Specialist, Division of Water Resources
North Carolina Department of Environmental Quality
Water Quality Regional Operations Section
2090 US Highway 70
Swannanoa,NC 28778
Uivi Cti io(W i�i����u�rco5 ®_
JAN 19 2018
Date:
WatL"Ouollly ReQlan91 Operatlona
January 16, 2018 nsp Off o

Table of Contents
EXECUTIVE SUMMARY—DISCHARGED WATER STUDY..............................................1
CHRONOLOGY............................................................................................................................3
CONTACT VS.NON-CONTACT COOLING WATER...........................................................4
DISCHARGED WATER FLOW RATES...................................................................................5
FACILITY IMPROVEMENTS...................................................................................................8
DISCHARGED WATER SAMPLING RESULTS.....................................................................9
SCOPE OF FUTURE TESTING...............................................................................................10
CONCLUSION............................................................................................................................10
Figures
1. Combined Cooling Water and Groundwater Discharge
2. Dechlorination System Process Flow Diagram
Tables
1. Discharged Water:Process Cooling Water and Groundwater Infiltration
2. Discharge Water Sampling Analytical Results—December 5,2017
Attachments
A. Pace Analytical Laboratory Analysis Report
B. Discharge Water and Groundwater Infiltration Flow Measurements and Calculations
C. Sampling Records/Weather Station Records/Purchased Water Records
D. North Carolina Surface Water Standards
JAN 1 9 2018
- W i rn� ip 1 r�..�ior I Il�omtlons
Low&Bonarlac.—NPDESDischarged Water Report3 i

EXECUTIVE SUMMARY-DISCHARGED WATER STUDY
Low&Bonar Inc.has compiled additional information regarding water discharges to surface waters of
the State for review by the North Carolina Department of Environmental Quality's Water Resources
Section. The information contained in this and four previous sampling and reporting campaigns
comprises a comprehensive water discharge evaluation.
This report is of a sampling and analysis campaign on December 5,2017,is preceded by four other
sampling and reporting campaigns. Reports of July 6,July 13,August 2,and October 19 campaigns were
previously reported to the Water Resources Section.
This report provides discharge water pollutant concentrations from two(2)sources or intermediate points.
These discharge water sample locations are the same as in all previous campaigns: Slim Tank and the
East Ditch. The East Ditch—an unnamed tributary to Hominy Crock—had been the wastewater sampling
location(i.e.,compliance point)for several years of reporting under a National Pollutant Discharge and
Elimination System permit.
However,this and previous reports recommend the`Slim Tank' as the future wastewater sampling
location. The Slim Tank is inside the processing building and is the confluence of all wastewater before
any mixing with groundwater infiltration or stormwater in the combined discharge water piping system.
Over the course of all our activities over the last six months the relative pollutant concentrations at these
locations have not substantially changed.
This report includes two important equipment additions at the Slim Tank—the new discharged water
permit compliance point—and the Flood Gate—the new stormwater permit compliance point:
1. Flow Meter Installation in the Slim Tank and the Flood Gate.
2. De Chlorination System Installation in the Slim Tank.
This report—as with three previous reports—demonstrates that water discharges from the Low&Bonar
Inc.facility substantially comply with North Carolina 15A NCAC 02B Surface Water Standards and
Protective Values. Exceptions and clarifications of this statement are addressed below.
1. Two metals—copper and zinc—are discharged at values exceeding regulatory limits.
Copper and zinc concentrations in the new discharge compliance point(i.e.,Slim Tank)are at
concentrations of 0.0308 and 0.156 milligrams per liter(mg/L)respectively;the acute regulatory
limits are 0.0036 and 0.036 mg/L respectively. Table 2 lists all analytical results.
To put copper and zinc concentrations into perspective,City Water was tested at the entrance to
the property (i.e,the security office)and at an interior location(i.e.,the maintenance restroom)
approximately at the center of the manufacturing process. Copper concentrations at the property
water inlet point were less than(<)0.005 mg/L and zinc were 0.112 mg/L. Copper
concentrations at the center of the manufacturing process were less than(<)0.005 mg/L and zinc
were 0.287 mg/L.
Of note are that average City Water copper and zinc concentrations of North Fork reservoir water are
0.007 and 0.2 mg/L respectively. Thus,City Water supplied to Low&Bonar exceeds the State
regulatory discharge limits.
Low&Bonar Inc.—NPDBS Discharged Water Report4 1