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Home My WebLink AboutNC0003719_Monitoring (Information)_20201026 DocuSign Envelope ID:694410C2-774A-40B5-A8B4-F08CD16C72EF STATE ,4, „.. ROY COOPER 5� n Governor .a• MICHAEL S.REGAN a`�.b Secretary °" "�a�_ S.DANIEL SMITH NORTH CAROLINA Director Environmental Quality October 26,2020 Mr.Matthew Hendrickson DAK Americas,LLS 3216 Cedar Creek Road Fayetteville,NC 28301 Subject: Additional Monitoring Requirement Cedar Creek Site NPDES Permit No.NC0003719 Dear Mr. Hendrickson: As you are aware,the State has been sampling and investigating sources of 1,4 dioxane as a parameter of concern in the Cape Fear River Basin. Due to the levels reported and downstream water supply usage at the Cedar Creek Site,the State requests additional 1,4 dioxane sampling at this facility. Pursuant to 15A NCAC 02B .0505 and .0508,the Division is requiring several industrial facilities in the Cape Fear River Basin to sample for 1,4 dioxane in the plant's effluent once per month using EPA Test Method 624.1 promulgated in the 2017 Methods Update Rule: Monthly effluent sampling for the DAK Americas Cedar Creek Site facility shall commence in December 2020 and results shall be submitted on the facility's Electronic Discharge Monitoring Reports(eDMRs)using parameter code 82388. Sampling is to be continued until permit renewal at which time the Division will determine if 1,4 dioxane will be added to your effluent sampling page. To discuss test procedures and fmd a lab certified to perform this updated test method please contact Todd Crawford, Laboratory Certification Branch Supervisor,at(919)733-3908 ext.251 or via email at todd.crawford@ncdenr.gov. If you have any questions,please contact me at(919) 707-3600 or at my email address i eff.poupart Mncdenr.gov. D E T North Carolina Department of Environmental Quality ( Division of Water Resources -;) 512 North Salisbury Street 11617 Mail Service Center I Raleigh.North Carolina 27699-1617 NORTH ro"r ...i 919.707.9000 DocuSign Envelope ID:694410C2-774A-40B5-A8B4-F08CD16C72EF Sincerely, DocuSigned by: Pbar6Uet 8FB19B649DD2478... Jeff Poupart Water Quality Permitting Section Chief Division of Water Resources/NCDENR cc: S. Daniel Smith,Director,DWR danny.smith@ncdenr.gov Sergei Chernikov,NPDES Industrial Permitting,DWR sergei.chernikovAncdenr.gov David Hill,NPDES Industrial Permitting,DWR david.hill@ncdenr.gov Todd Crawford,Laboratory Certification Branch Supervisor,DWR todd.crawford@ncdenr.gov Chris Johnson,Water Sciences Section, DWR chris johnson(a,ncdenr.gov Mark Brantley, Supervisor, DWR FRO mark.brantley(a,ncdenr.gov Kim Nimmer, EC Coordinator, DWR kim.nimmer( ncdenr.gov James R.Perez, Safety, Health and Environmental Supervisor,DAK, inerezAalpekpolyester.com Pre-public notice draft-NPDES Permit Renewal Permit NC0024881 Reidsville WWTP Rockingham County Grade IV Biological WPCS-SIC Code 4952 As a preliminary copy of the 5.5 MG D and 7.5 MG D permit renewal the following items have been brought to your attention.Please note these are the significant items only(See Fact Sheet for all items and further clarification): • Limits and a Compliance Schedule has been added for 1,4-Dioxane with a three phased implementation process.Phase I-initial daily maximum limits at 65 ug/I at 5.5. MGDand 57 ug/I at 7.5 MGDwith instream upstream&downstream sampling for 1,4-Dioxane;Phase II— Assessment of 1,4 Dioxane sources,Engineering&Cost Analysis including BAT;and Phase III- either meet effluent limit of 6.3 ug/I at 5.5 MG D and 4.7 ug/I at 7.5 MG D(based on a mixed instream concentration such that the 1,4-Dioxane concentration does not exceed 0.35 ughI at Average Annual Flow)or meet the BAT limitations (to be determined for eitherthe wastewater facility and/orthe SIU's).Afourand one-half(4%)year compliance schedule is provided to meet Phase III limits.Monitoring frequency of two perweek(grab)and once perweek (composite)collected on random days throughout the week.See Fact Sheet and permit for more details. • As part of this review a comprehensive evaluation of the pretreatment program,1,4-Dioxane loadings from all sources and documentation of this loadings and actions to be taken. In addition,the SIU pretreatment permits are to be revised,reissued or new permits issued within one year from the permit effective date.However,a pretreatment compliance schedule of up to three and one-half(3%)years can be provided for SIU's that need construction to meet the Phase III limit. In a slug control plan must be developed and maintained for 1,4-dioxane sources. • N H3-N limits have been reduced,and monitoring frequencies have been increased to daily.[See A.(1.)]. • At 5.5 MG D,Total Copper limits have been added to the permit,and the monitoring requirement has been added ata monthly frequency[See A.(1.)].To provide an opportunity for the City to develop a plan to assess sources of Total Copper for 5.5 MG D in orderto come in compliance with the limits in Section A. (1.),a 3-year schedule of compliance has been added to the permit[See A.(10.)]. • Since the effective date for Total Nitrogen Load limits have passed,the effective date has been removed from the permit[See A.(1.)].Also,the Nitrogen Optimization special condition has been removed from the permit. • Based on the reasonable potential analysis(RPA),the monitoring requirements for fluoride, silver and zinc have been removed from the permit[See A.(1.)]. • Based on the RPA predicting a maximum effluent nitrate-nitrogen(NO3-N)concentration that is greaterthan half of the allowable discharge concentration based on state water quality standards,quarterly monitoring for NO3-N has been added to the permit[See A.(1.)]. • Based on NPDES guidance regarding the reduction of monitoring frequencies in NPDES permits for exceptionally performing facilities,monitoring requirements for CBODS have been reduced to twice perweek,while monitoring requirements for Total Suspended Solids and Fecal Coliform are maintained at twice per week. • Site-specific effluent hardness data and instream hardness data,upstream of the discharge, is needed in orderto calculate permit limitations in the future.Effluent hardness and instream hardness sampling,upstream of the discharge,have been added to the permit at a monitoring frequency of quarterly[See A.(1.)and A.(2.)]. • Based on Mercury TMDL evaluation showing mercury values reported at levels>1 ng/L and since the permitted flow is greaterthan 2 MG D,wording in Special Condition A.(9.)Mercury Minimization Plan has been modified to reflect the plan's maintenance. • Special Condition A. (4.)has been modified to include the specific three years in which the Effluent Pollutant Scan shall be performed(2022,2023, and 2024). In addition,at the end of the Special Condition,2nd species Toxicity Testing Requirements for major municipal permits have been added.