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Home My WebLink AboutNC0004685_Comments_20210520 E Nippon Electric Glass Electric Glass Fiber America, LLC 940 Washburn Switch Road, Shelby, NC 28150 Telephone Number: 704-434-2261 Via Certified Mail Return Receipt Requested RECEIVED MAY 2 0 2021 May 19, 2021 NCDEQ/DWR/NPDES Ms. Julia Byrd NC DEQ Division of Water Resources WQ Permitting Section—NPDES Industrial Permitting, Wastewater Branch 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: Draft NPDES Permit Renewal Comments Permit NC0004685 Electric Glass Fiber America, LLC, Shelby,N.C. Facility Cleveland County Dear Ms. Byrd: Electric Glass Fiber America (EGFA) received the draft NPDES permit and fact sheet on April 29, 2021 for the facility located at 940 Washburn Switch Road, near Shelby in Cleveland County. After review of the Draft Permit package, EGFA has the following questions or comments: 1. On Page 2 of 9 of the Draft Permit, the listed wastewater treatment facility component description has a few components either missing or incorrect. There have been no component changes from the current permit, so we respectfully request Item 1 on Page 2 of 9 to read as follows (changes are shown in Italics): "Item 1. Continue operation of a 1.3 MGD wastewater treatment facility consisting of the following components: • An overflow/storage basin[add component]; • Bar screen and grinder; • An influent wet well with lime addition[Component name change]; • Influent pumps; • A surge tank[add component]; Page 113 Nippon Electric Glass Electric Glass Fiber America, LLC 940 Washburn Switch Road, Shelby, NC 28150 Telephone Number: 704-434-2261 • One (1) load equalization tank with aluminum chloride addition["and coagulant" removed]; • One (l)primary flash mix tank with polymer addition; • Two (2)primary clarifiers; • Two (2) aeration basins with lime, bentonite clay and defoamer addition ["hydrogen phosphate" removed, "bentonite clay"added]; • One (1) Secondary Flash Mix Tank with ferric chloride and polymer addition [component added] • Three (3) secondary clarifiers ["with ferric chloride and polymer addition" removed]; • One (1)Aeration Splitter Box for Return Activated Sludge[`flow splitter for waste and return activated sludge"removed]; • One (1) sand filter["with defoamer addition"removed]; • One (1) effluent holding tank[`for reuse/cooling water"removed]; • One (1) sludge thickener tank; and • One (1) sludge belt press with polymer addition." 2. EGFA respectfully requests justification for leaving the fluoride-monitoring requirement in the permit. Use of fluoride as an ingredient was discontinued at this facility circa 2003. Fluoride is still occasionally detected in the wastewater discharge,as it is present as a trace contaminant in the facility raw materials (dolomitic limestone), and in city water used in plant operations, but at a much lower level than historical records indicate, when it was a formulation component. Over the last two years (2019 -2020), fluoride in the effluent has been well below 1.0 mg/L and was typically near non-detect concentrations. 3. As discussed on Thursday, May 6, 2021, EGFA believes there is a typographic error by omission on Part IA.(1.)a, Footnote 3 regarding Total Residual Chloride (TRC) monitoring. Page 6 on the Draft Permit Fact Sheet indicates no planned changes to the TRC limits for this permit renewal, however in the draft permit at Part IA.(1.)a Effluent Limitations and Monitoring Requirements the wording of Footnote 3 regarding TRC has been modified by omission of one sentence. EGFA respectfully requests reinstating the missing sentence into the new permit. For your convenience,this revises Footnote 3 in the above referenced table to read as follows: "The Division shall consider all effluent Total Residual Chlorine values reported below 50 ug/L to be in compliance with the permit. However, the permittee shall continue to record and submit all values reported by a North Carolina certified laboratory (including field certified), even if these values fall below 50 ug/L. Monitoring and Page 213 • Nippon Electric Glass Electric Glass Fiber America, LLC 940 Washburn Switch Road, Shelby, NC 28150 Telephone Number: 704-434-2261 effluent limitation for TRC apply only if chlorine is added for disinfection." (Italics show the omitted sentence). 4. In the NPDES permit application filed in 2017, EGFA requested deletion of the PC2 operator requirement, which was granted in the draft permit. Based on the discussions on May 6,2021,EGFA understands that the DWQ received a comment that this determination is made by the NC DEQ Regional Office. EGFA will proceed with making this request to the Regional Office by May 19, 2021. Please note that DWQ rescinded the PC2 classification in 2015 for the EGFA, Lexington,NC wastewater treatment plant, which is comparable to this plant. EGFA respectfully requests that DWQ not issue the new NPDES permit until this matter has been addressed with the Regional Office. 5. In the NPDES- Fact sheet there is a typographic error on Page 7 of 12. EGFA requests deletion of"and 002" describing the current toxicity testing requirement. The fact sheet indicates no changes are proposed to the current permit. The current permit requires chronic toxicity testing only at outfall 001 @ 33%effluent concentration. Please feel free to contact Terry Steinert at 704-434-2261 x22007 if you need any additional information or if you have any questions regarding this submittal. Sincerel , G9�'1 Alan Toney Manufacturing Manager Electric Glass Fiber America, LLC. Attachment cc: Richard Young, EGFA Terry Steinert, EGFA File Page 313 3 Nippon Electric Glass Electric Glass Fiber America, LLC 940 Washburn Switch Road,Shelby, NC 28150 Telephone Number: 704-434-2261 Via Certified Mail Return Receipt Requested May 19, 2021 Mr. Ori Aharon Tuvia NC DEQ Division of Water Resources 610 East Center Ave, Suite 301 Mooresville,NC 28115 Subject: PC2 Treatment Plant Rating Electric Glass Fiber America,LLC, Shelby,N.C. Facility Cleveland County Permit NC0004685 Electric Glass Fiber America, LLC, Shelby,N.C. Facility Cleveland County Dear Ms. Tuvia: Electric Glass Fiber America (EGFA) received a draft NPDES permit and fact sheet on April 29, 2021 for the facility located at 940 Washburn Switch Road, near Shelby in Cleveland County. After review of the Draft Permit package, EGFA had the following comment back to Ms. Byrd: 1. In the NPDES permit application filed in 2017, EGFA requested deletion of the PC2 operator requirement, which was granted in the draft permit. Based on the discussions on May 6, 2021, EGFA understands that the DWQ received a comment that this determination is made by the NC DEQ Regional Office. EGFA will proceed with making this request to the Regional Office by May 19, 2021. Please note that DWQ rescinded the PC2 classification in 2015 for the EGFA, Lexington, NC wastewater treatment plant, which is comparable to this plant. EGFA respectfully requests that DWQ not issue the new NPDES permit until this matter has been addressed with the Regional Office. The treatment facility is currently classified as Biological III, and Physical Chemical II (PCII). EGFA respectfully requests the regional office to remove the PCII classification on the EGFA Page 112 4 Nippon Electric Glass Electric Glass Fiber America, LLC 940 Washburn Switch Road,Shelby, NC 28150 Telephone Number: 704-434-2261 Shelby treatment plant while the draft permit is currently open for review at NCDEQ. This request is made ri p manly to help reduce the burden on the facility operating staff to training and maintain dually certified personnel. The primary treatment process is Biological Activated Sludge, with assistance from physical/chemical operations. Upon a review of 15 NCAC 08G.0306(d): d. "any water pollution control system subject to classification under Rule .0302 of this section, utilizing a physical or chemical process to enhance an activated sludge or fixed growth process, is not subject to additional classification under this rule." Based on our review of the regulations, we feel that the Physical Chemical II classification can be deleted from our draft NPDES permit currently under review. Please note that NCDEQ rescinded the PC2 classification in 2015 from the EGFA Lexington, NC wastewater treatment plant, which is comparable to the EGFA Shelby facility (both Biological III classified facilities). Find in attachment with this letter the Permit Renewal Comments submitted to Ms. Byrd. Please feel free to contact Terry Steinert at 704-434-2261 x22007 if you need any additional information or if you have any questions regarding this submittal. Sincerely, / 44'16771- Alan Toney Manufacturing Manager Electric Glass Fiber America, LLC. Attachment cc: Richard Young, EGFA Terry Steinert, EGFA File Page 212