HomeMy WebLinkAboutNC0001899_permit issuance_20070309Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
March 9, 2007
Mr. Don Peterson, Plant Manager
Performance Fibers, Inc.
338 Pea Ridge Road
New Hill, North Carolina 27559
Subject: Issuance of NPDES Permit NC0001899
Performance Fibers WWTP
Chatham County
Dear Mr. Peterson:
Division personnel have reviewed and approved your application for renewal of the subject
permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between North Carolina and the U.S. Environmental Protection Agency dated May 9,1994 (or
as subsequently amended).
This final permit contains the following changes from the draft you were sent on November 21, 2006:
➢ Please note that the Division has added the Cape Fear River (from the confluence of the
Haw and Deep Rivers to Sanford) to the 2006 303(d) list due to chlorophyll a exceedances.
The Modeling Unit expects to initiate stream studies in 2010 and modeling in 2012 to
determine limits for nutrient and oxygen -demanding wastes in these waters. It is possible
that the Division will expect dischargers to conduct supplementary TN and TP monitoring to
support stream studies and modeling beginning around January 2009. Due to the fact that these
efforts are underway, EPA recommended that Performance Fibers not be allowed to increase its
historical nutrient loading until the Division completes a TMDL. However, rather than add a
nutrient limit (narrative or numerical) at this time, the Division agreed to limit future expansions
at this facility to current nutrient loads until the TMDL is completed.
➢ Special Condition A(6) - Sampling Points, was removed from the draft permit. This section
allowed the facility to sample for toxicity and chloroform after the chlorine contact chamber due
to potential chlorine interference. However, since the facility will cease chlorination upon receipt
of this final permit, the potential for chlorine interference will no longer exist.
➢ TRC monitoring was removed from outfall 002 based on information provided by Performance
Fibers indicating that the facility is not equipped to chlorinate at this outfall.
The Division has the following response to comments submitted by Performance Fibers during the draft
period:
➢ Performance Fibers requested that Chronic Toxicity language be changed to remove references to
chlorine since it is no longer used at the facility. This section contains standard boilerplate
language used for all facilities in North Carolina that have WET testing requirements. This
particular section of that language only applies if chlorine is used for disinfection. Since chlorine
is not used for disinfection, those references do not apply to Performance Fibers. Division staff
feels that it is unnecessary to remove this language.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone (919) 733-7015 FAX (919) 733-0719
512 N. Salisbury Street, Raleigh, North Carolina 27604 On the Internet at http://h2o.enr.state.nc.us/
An Equal Opportunity/Affirmative Action Employer
NorthCarolina
Naturally
Mr. Chuck Powell
Performance Fibers, NC0001899
Page 2
➢ Comments requested that Part IV of the boilerplate language (Special Conditions for
Municipal Facilities) be removed. This section contains standard boilerplate language that is
used for all NPDES permits in North Carolina. Since the language in question only applies to
municipal facilities, it does not affect Performance Fibers. Division staff feels that it is
unnecessary to remove this language.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30)
days following receipt of this letter. This request must be in the form of a written petition, conforming to
Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings
(6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this
decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division
may require modification or revocation and reissuance of the permit. This permit does not affect the legal
requirements to obtain other permits which may be required by the Division of Water Quality or permits
required by the Division of Land Resources, the Coastal Area Management Act or any other Federal or
Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Toya Fields at telephone number
(919) 733-5083, extension 551.
Sincerely,
4.6).„
69- AL Alan W. Klimek, P.E.
cc: Central Files
Raleigh Regional Office/Surface Water Protection
NPDES Unit
Marshall Hyatt, EPA Region IV
Aquatic Toxicology Unit
2
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
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,
Performance Fibers, Inc.
is hereby authorized to discharge wastewater from a facility located at the
Performance Fibers, Inc. WWTP
East of Moncure off Pea Ridge Road
Chatham County
to receiving waters designated as the Haw River in the Cape Fear 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 April 1, 2007.
This permit and the authorization to discharge shall expire at midnight on July 31, 2011.
Signed this day March 9, 2006.
IstiA1an W. Klimek, P.E., Director
Division of Water Quality
By the Authority of the Environmental Management Commission
Permit NC0001899
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. - -
Performance Fibers, Inc. is hereby authorized to:
1. Continue to discharge process and domestic effluent at a permitted flow not to exceed
0.244 MGD (outfall 001), from a wastewater treatment facility consisting of the following:
> Sanitary flow bar screen and grinder
> Process wastewater bar screen
➢ Neutralization chamber
> Aeration basin
> Clarifier
➢ Sludge drying bed
> Optional polishing pond
➢ Chlorine gas disinfection (not in service)
> Contact chamber
2. Continue to discharge stormwater, condensate, and firepond overflow (outfall 002) from
facilities located at the Performance Fibers, Inc. Facility, off Pea Ridge Road east of
Moncure in Chatham County.
3. Discharge wastewater from said treatment works via outfall 001 at the location specified
on the attached map into the Haw River and via outfall 002 into an unnamed tributary to
Shaddox Creek, both of which are classified WS-IV waters in the Cape Fear River Basin.
NPDES No. NC0001899
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A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (001)
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is
authorized to discharge 0.244 MGD of industrial and domestic wastewater from outfall 001. Such discharges
shall be limited and monitored by the Permittee as specified below:
1
Effluent
Characteristics
Limits
Monitoring Requirements
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location/
Flow
0.244 MGD
Continuous
Recordingwent
Effluent
pH2
Between 6.0 and 9.0 s.u.
Continuous
Recording
Effluent
BOD, 5 day (20°C)
10.4 lbs/day
16.7 lbs/day
Weekly
Composite
Effluent
Total Suspended Solids J
5.0 lbs/day
10.6 lbs/day
Weekly
Composite
Effluent
Oil and Grease '
20.0 lbs/day
30.0 lbs/day
Weekly
Grab
Effluent
d
_ Temperature (°C)
Monthly
Grab
Effluent
Upstream &
Downstream
Conductivity
Monthly
Grab
Effluent
Upstream &
Downstream
f
Dissolved Oxygen
Monthly
Grab
Effluent
Upstream &
Downstream
Total Nitrogen as N ,
(mg/L)3
Quarterly
Composite
Effluent
Total Phosphorus as P
(mg/L)
Quarterly
Composite
Effluent
Chronic Toxicity'
Quarterly
Composite
Effluent
OCPSF5
Annually
Grab
Effluent
Footnotes:
1. Upstream: valve at Permittee's river water pump house. Downstream: nearest accessible point at least 100
yards below the outfall and above the confluence of the Deep and Haw Rivers. Instream monitoring is
provisionally waived due to the permittee's participation in the Lower Cape Fear River Basin Association.
Instream monitoring shall be conducted as stated in this permit should the permittee end its participation
in the Association.
2. The pH shall be monitored continuously at the effluent. In accordance with 40 CFR 401.17, the total time
during which the pH values are allowed to be less than 6.0 standard units or greater than 9.0 standard units
shall not exceed 7 hours and 26 minutes in any calendar month, and no individual excursion outside the 6.0 to
9.0 range shall exceed 60 minutes.
3. TN = TKN + NO3-N + NO2-N, where TN is Total Nitrogen, TKN is Total Kjeldahl Nitrogen, and NO3-N and
NO2-N are Nitrate and Nitrite Nitrogen, respectively.
4. Chronic Toxicity (Ceriodaphnia) Chronic P/F at 0.94%: January, April, July, and October [see Condition A. (3)].
5. Refer to Conditions A. (7) and A. (8) regarding OCPSF monitoring. Where any compound is detected,
quarterly monitoring is required for that compound until not detected in twelve consecutive samples.
Performance Fibers may use EPA test method 524.2 to monitor OCPSF parameters (provided the method
allows a detection level at or below the permitted limit).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
NPDES No. NC0001899
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (002)
During the period beginning on the effective date of the permit and lasting until expiration, the Pennittee is
authorized to discharge stormwater, steam condensate, and firepond overflow wastewater from Outfall 002.
Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent
Characteristics
Limits
Monitoring Requirements
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample Type
Sample
Location
Flow
Weekly
Instantaneous
Effluent
Temperature (°C)1
Weekly
Grab
Effluent
pH
Between 6.0 and 9 0 s.u.
Weekly
Grab
Effluent
Acute Toxicity2
Annually
Grab
Effluent
Footnotes:
1. The temperature of the effluent shall be such as not to cause an increase in the temperature of the receiving
stream of more than 2.8°C and in no case cause the ambient water temperature to exceed 32°C.
2. Acute Toxicity (Fathead Minnow) Annual Monitoring [see Condition A. (4)].
There shall be no discharge of floating solids or visible foam in other than trace amounts.
NPDES No. NC0001899
A. (3) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 0.94%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or
"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or
subsequent versions. The tests will be performed during the months of January, April, July, and October.
Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all
treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the
permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two
following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection
methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the
permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No
Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Section at
the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.
NPDES No. NC0001899
A. (4) ACUTE TOXICITY MONITORING (ANNUAL)
The permittee shall conduct annual toxicity tests using protocols defined as definitive in E.P.A. Document
EPA/600/4-90/027 entitled "Methods for Measuring the Acute Toxicity of Effluents to Freshwater and Marine
Organisms." The monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24-hour static test.
Effluent samples for self -monitoring purposes must be obtained below all waste treatment. The permittee will
conduct one test annually, with the annual period beginning in January of the calendar year of the effective date
of the permit:
The annual toxicity test must be performed by Tune 30. Should there be no discharge of flow from the facility
during the six month period January 1-June 30, the permittee will complete the information located at the top of
the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county and in the
comments section indicate "No Flow for January 1-June 30, {calendar year}." The report must be signed and
submitted to the Environmental Sciences Section at the address noted below.
If no discharge event occurs from Tanuary 1-Tune 30, yet a discharge event occurs from July 1-December 31, then
the facility must perform toxicity monitoring and report the data as noted below.
The parameter code for this test is TAE6C. All toxicity testing results required as part of this permit condition will
be entered on the Effluent Discharge Form (MR-1) for the month in which it was performed, using the appropriate
parameter code. Additionally, DWQ Form AT-1 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, N.C. 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed
in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent
toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should any test data from either these monitoring requirements or tests performed by the North Carolina Division
of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival and appropriate environmental controls, shall constitute an invalid test and will require immediate
follow-up testing to be completed no later than the last day of the month following the month of the initial
monitoring.
A. (5) WASTEWATER TREATMENT PONDS
The wastewater treatment ponds at the facility shall maintain a freeboard height of 2 feet.
A. (6) PERMIT REOPENER: SUPPLEMENTARY NUTRIENT MONITORING
Pursuant to N.C. General Statutes Section 143-215.1 and the implementing rules found in Title 15A of the North
Carolina Administrative Code, Subchapter 02H, specifically, 15A NCAC 02H.0112(b)(1) and 02H.0114(a), and
Part lI,Sections B12. and B.13. of this Permit, the Director .of.DWQ .may reopen this permit to require
supplemental nutrient monitoring of the discharge. The additional monitoring will be to support water quality
modeling efforts within the Cape Fear River Basin, and shall be consistent with a monitoring plan developed
jointly by the Division and affected stakeholders.
NPDES No. NC0001899
A. (7) ANALYTICAL DETECTION LEVELS
When an approved analytical protocol with the appropriate minimum detection level is followed and a result of
"non -detectable" or "below quantitation limit" is obtained, the permittee will be considered to be in compliance
with the numerical permit limit for that pollutant.
[This condition is inserted to acknowledge that the low equivalent concentration limits imposed by the OCPSF
guidelines, combined with the additional non-OCPSF process flows, will result in situations where the detection
limit of the EPA approved analytical protocols will not be sufficiently low enough to verify that a particular
pollutant is in compliance with the permit limits.]
NPDES No. NC0001899
A(8) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (001/OCPSF)
During the period beginning on the effective date of the permit and Lasting until expiration, the Permittee is authorized to
discharge OCPSF related process wastewater from outfall serial number 001. Such discharges shall be limited and monitored
by the Permittee as specified below:
2
Effluent Characteristic
cenaphthene
cenaphthylene
crylonitrile
nthracene
nzene
enzo(a)anthracenel
,4-Benzofluoranthene
nzo(k)fluoranthenel
nzo(a)pyrene'
is (2-ethylhexyl) phthalate
rbon Tetrachloride
lorobenzene
hloroethane
hloroform
Chlorophenol
rysene'
■i-n-bury! phthalate
,2-Dichlorobenzene
,3-Dichlorobenzene
1,4-Dichlorobenzene
1,1-Dichloroethane
2-Dichloroethane
1,1-Dichloroethylene
,2-trans-Dichloroethylene
,4-Dichlorophenol
1,2-Dichloropropane
,3-Dichloropropylene
+iethyl phthalate
2,4-Dimethylphenol
methyl phthalate
,6-Dinitro-o-cresol
,4-Dinitrophenol
,4-Dinitrotoluene
,6-Dinitrotoluene
Daily Maximum
pounds/day
0.004
0.004
0.015
0.004
0.008
0.004
0.004
0.004
0.004
0.017
0.002
0.002
0.016
0.003
0.006
0.004
0.003
0.010
0.003
0.002
0.004
0.013
0.002
0.003
0.007
0.014
0.003
0.012
0.002
0.003
0.017
0.007
0.017
0.039
Monthly Average
pounds/day
0.001
0.001
0.006
0.001
0.002
0.001
0.001
0.001
0.001
0.006
0.001
0.001
0.006
0.001
0.002
0.001
0.002
0.005
0.002
0.001
0.001
0.004
0.001
0.001
0.002
0.009
0.002
0.005
0.001
0.001
0.005
0.004
0.007
0.016
Measurement
Frequency
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Sample
Type
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Sample
Location'
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
thylbenzene
Fluoranthene
luorene
exachlorobenzene
- Hexachlorobutadiene
Hexachloroethane
-Methyl Chloride
Methylene Chloride
Naphthalene
Nitrobenzene
•2-Nitrophenol
4-Nitrophenol
Phenanthrene
Phenol
Pyrene
Tetrachloroethylene
Toluene
2, 4-Trichlorobenzene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethylene
Vinyl Chloride
Total PAH'
0.007
0.004
0.004
0.002
0.003
0.003
0.012
0.005
0.004
0.004
0.004
0.008
0.004
0.002
0.004
0.003
0.005
0.009
0.003
0.003
0.003
0.016
0.002
0.002
0.001
0.001
0.001
0.001
0.005
0.002
0.001
0.002
0.002
0.004
0.001
0.001
0.002
0.001
0.002
0.004
0.001
0.001
0.001
0.006
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Annually
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
PAH1 = Polynuclear aromatic hydrocarbons; benzo(a)anthracene, benzo(a)pyrene, 3,4-benzofluoranthene, benzo(k)fluoranthene,
chrysene, dibenz(a,h)anthracene, indeno(1,2,3 - cd)pyrene
Permit NC0001899
NCDENR/DWQ
AMENDED FACT SHEET FOR NPDES PERMIT DEVELOPMENT
Performance Fibers, Inc
NC0001899
Facility Information
(1.) Facility Name:
(2.) Permitted Flow MGD):
(3.) Facility Class:
(4_) Pretreatment Program_
(5.) Permit Status:
Performance Fibers Inc WWTP
0.244
i
•i N/A _ _
Existing
(6.) County: ;Chatham
(7T) Regional Office:..__._._._._._._.._Raleigh
(8.) USGS TooQuad: E22SE
(9.) USGS Quad Name: ;_
StreamChaia ristics
(1.) Receiving Stream:
(2.) Sub -basin:
(3.) Stream Assessment Unit:
(4.) Stream Classification:
(5.) 303(d) Status:
(6.) 305(b) Status:
i Haw River (001)
i UT to Shaddox Creek (002)
(7.) Drainage Area (mi2): 980 (001)
(8.) Summer 7Q10 (cfs): j 40 (min release)
(9.) Winter 7Q10 (cfs):
Average Flow (cfs): 1848
•._._._{_.._....._......_._._..�...................
(12.)IWC%: i 0.94(001)
I. Proposed Changes Incorporated into Permit Renewal
• EPA recommended that the facility not be allowed to increase its historical loading of TN and TP until
modeling is performed on this section of the Cape Fear (due to its 303(d) listing for chlorophyll -a). Rather
than add a nutrient limit (narrative or numerical) at this time, the Division agreed to limit future
expansions to their current loading until the TMDL is completed.
• The TRC monitoring requirement was removed from outfall 002 due to the fact that the facility is not
equipped to chlorinate at that location.
• Special Condition A(6) - Sampling Points was removed from the draft permit. This section allowed the facility
to sample for toxicity and chloroform after the chlorine contact chamber due to potential chlorine
interference. However, since the facility will cease chlorination upon receipt of this final permit, the
potential for chlorine interference will no longer exist.
Performance F • Fibers
December 19, 2006
Ms. Toya Fields
Environmental Engineer
Division of Water Quality
NC Department of Environment & Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27604
Subject:
Dear Ms. Fields:
Draft NPDES Permit Review
Performance Fibers, Inc., Chatham County
NPDES Permit No. NC0001899
After careful review of the Draft NPDES permit that was dated November 21, 2006 and received by
Performance Fibers, Inc., on November 27, 2006, the following comments are provided for your
consideration in finalizing our permit renewal.
NDPES Draft Permit Cover Sheet:
Second paragraph- Sentence "This permit shall become effective". —No Date established
Supplement to Permit Cover Sheet:
leteth Number 2: sentence reads..... "Performance Fibers, Inc., facility off Pea Ridge Road east of Moncure
in Chatham County, and -" Sentence is fragmented and not complete.
Section A (1)-Effluent Limitations and Monitoring Requirements (001):
t/ Footnote Number 5: HONEYWELL should be changed to PERFORMANCE FIBERS.
Section A (2). Effluent Limitations and Monitoring Requirements (002).
Footnote Number 2 and Effluent Monitoring Chart: Footnote Number 2 refers to Chlorine monitoring
being required if chlorine is added to the wastewater contributors stated above. Fecal Coliform monitoring
requirement is being removed from this permit and Total Residual Chlorine monitoring requirement is
being removed from Outfall 001 as well as the need for Performance Fibers to continue to chlorinate at the
wastewater treatment plant. With that being the case, then shouldn't we also have the Total Residual
t J`
10\ Chlorine monitoring requirement and reference removed from this section too?
\ Section A (3) Chronic Toxicity Permit Limit (Quarterly):
The seventh paragraph makes reference to total residual chlorine of the effluent toxicity sample being
measured and reported if chlorine is being employed for disinfection of the waste stream. The same j\,il
question applies to this section as with Section A (2); that is, if chlorine will no longer be used for t �a
disinfection at the wastewater treatment plant, then should this sentence be removed from the permit? i -
338 PEA RIDGE ROAD I NEW HILL, NC 27562 I TEL 919 542 2200
www.performancefibers.com
cOk
Section A (6) Sampling Points:
The first paragraph states that "the permittee may perform sampling after the chlorine contact chamber, for
all parameters except those listed below• in order to avoid interference with chlorine addition,
sampling for chloroform may be collected after the clarifier." Performance Fibers will cease chlorination
at the chlorine contact chamber once the final permit is received, and henceforth the chlorine contact
chamber can be referred to as the contact chamber. Additionally, since chlorine will no longer be
employed, there should be no need to take the sample for chloroform, (which is one of the component
requirements for the annual OCPSF sampling requirements), at the clarifier to avoid interferences.
Part IV -Special Conditions for Municipal Facilities:
t'C y This section appears to apply only to those municipal wastewater treatment facilities and Performance
1k. Fibers recommends that pages 13-16 be deleted from this permit.
oP9,p
Performance Fibers wishes to express appreciation to Ms. Fields and the Division of Water Quality, for the
opportunity to have met with you to discuss specifics of the permit renewal and for the numerous telephone
conversations that have taken place during this renewal process. If there are any questions regarding these
comments, please do not hesitate to contact me at (919) 545-3154.
Sincerely,
harles E. Powell, Jr., REM
Environmental & Industrial Hygiene Leader
cc: B. Ferree
G. Gardner
D. Peterson
D. Stidham
NORTH CAROLINA
CHATHAM COUNTY
Tie Chatham News
AFFIDAVIT OF PUBLICATION
Before the undersigned, a Notary Public of said County and State, duly
commissioned, qualified, and authorized by law to administer oaths, person-
ally appeared
Florence Turner
first duly sworn, deposes and says: that he (she) is
Accounts Receivable Clerk
who being
(Owner, partner, publisher, or other officer or employee
authorized to make this affidavit)
of The Chatham News Publishing Co., Inc., engaged in the publication of a
newspaper known as, The Chatham News, published, issued, and entered as
second class mail in the Town of Siler City, in said County and State; that
he (she) is authorized to make this affidavit and sworn statement; that the
notice or legal advertisement, a true copy of which is attached hereto, was
published in The Chatham News on the following dates:
n
and that the said newspaper in which such notice, paper, document, or
legal advertisement was published was, at the time of each and every such
publication, a newspaper meeting all of the requirements and qualifications
of Section 1-597 of the General Statutes of North Carolina and was a quali-
fied newspaper within the meaning of Section 1-597 of the General Statues
of North Carolina.
This -.3 0 day of
• "
(Signature of person making affidavit)
Sworn to and subscribed before me, this 6-c-
day of
moo..-L-��
Notary Public
aoa
�$},ePUBLIC NOTICE'. s
? :STATE OF NORTH CAROLINA."
' ENVIRONMENTAL MANAGEMENT
COMMISSION/NPDES UNIT r
1617 MAIL SERVICE CENTER,,-
g RALEIGH NC'27699-1617
NOTIFICATION OF INTENT TO,.;
ISSUE A'NPDES WASTEWATER'.
PERMIT-
On the basis : of thorough staff
l review and' application of. "'NC
General Statute 143.21, Public.law,
92-500 and other lawfulstandards
and regulations, the North Carolina
Environmental. Management Com-
mission proposes to issue a'
National Pollutant: Discharge
Elimination System (NPDES),
wastewater discharge permit to the
person(s) listed below effective 451
days from the publish date of this
notice.
Written comments regarding the
proposed permit will be ;accepted
until 30 days after the publish date
of this notice.All comments
received prior to that ,,date are,,
considered in the final
;determinations regarding the.,
proposed permit. The Director of the
NC Division of Water Quality may,
decide to hold a public meeting foil.
the proposed permit should the
Division receive a significant degree`
of public interest.
Copies of the draft permit and other
,supporting information on file used
to determine conditions present in
the draftpermit are available upon
request and payment of the costs cif
reproduction. Mail comments and/or
requests for information to the NC
Division of Water Quality at the
above address or call the Point
Source Branch at (919) 733-5083;
extension 363. Comments can.alsol
be email d to .�
Carolyn.Bryant@ncmail.net. Please
include the NPDES permit number
(attached) in any communication.
4lnterested personsmay also visit
the Division of Water Quality at'5"12
N. Salisbury StreetFaleigh, NC'
27604-1148 between the hours of
8:00 a.m. and 5:00 p m., to review
information on file.
,Performance Fibers, Inc. (338 Pea
Ridge Road, Moncure, Nc 27559)
,has applied for renewal of NPDES
permit;.,.. NC0001899 for the
Performance ' Fibers '" WWTP ' in:;
Chatham County. This permitted
facility discharges 0.244 MGD of
treatedwastewaterto the Haw Rivera
and Shaddox Creek, in the Cape
Fear ' River Basin. ;'Although no,
parameters are water quality limited
this discharge; ..may, affect future"'.
allocations in this portion' of the
Cape FearRiver Basin.
N30 itc
My Commission expires. //. 0 -7 - e.al d
MEMORANDUM
To:
From:
Subject:
November 22, 2006
Michael Douglas
NC DENR / DEH / Regional Engineer
Raleigh Regional Office
Toya Fields
Western NPDES Program
Review of NPDES Permit NC0001899
Performance Fibers, Inc
Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
1 i
DENR RALEIGH REGIONAL OFFICE
sor %ems
Please indicate below your agency's position or viewpoint on the proposed permit modification
and return this form as soon as possible. If you have any questions on the proposed
modification, please contact me at the telephone number or e-mail address listed at the bottom
of this page.
RESPONSE: (Check one)
Concur with the issuance of this permit provided the facility is operated and maintained
properly, the stated effluent limits are met prior to discharge, and the discharge does not
contravene the designated water quality standards.
Concurs with issuance of the above permit, provided the following conditions are met:
Opposes the issuance of the above permit, based on reasons stated below, or attached:
SignedlAsit'(._
Date:
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
tova.fields@ncmail.net - (919) 733-5083 x551
FAX (919) 733-0719
On the Internet at http://h2o.enr.state.nc.us/
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
DEC 1 3 2006
Ms. LeToya Fields
North Carolina Department of Environment and
Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
SUBJ: Draft NPDES Permit
Performance Fibers WWTP
Permit No. NC0001899
�
DEL
_'•
DEN ' '3?liir.v : ,;., \!CH
pOINT
Dear Ms. Fields:
In accordance with the EPA/NCDENR MOA, we have completed review of the draft
permit referenced above and have no comments. We request that we be afforded an additional
review opportunity only if significant changes are made to the draft permit prior to issuance or if
significant comments objecting to the draft permit are received. Otherwise, please send us one
copy of the final permit when issued.
Sincerely,
Marshall Hyatt, Environmental Scientist
Permits, Grants, and Technical Assistance Branch
Water Management Division
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)
Re: onequestion re NC0001899, Performance Fibers
Subject: Re: one question re NC0001899, Performance Fibers
From: Hyatt.Marshall@epamail.epa.gov
Date: Wed, 13 Dec 2006 16:10:13 -0500
To: Toya Fields <toya.fields@ncmail.net>
I agree with your suggestion. thanks for your patience and thoughtful
consideration of my concerns. will send a no comment letter. Marshall
1 of 1 2/15/2007 1:01 PM
Re: one -question re NC0001899, Performance Fibers
Subject: Re: one question re NC0001899, Performance Fibers
From: Toya Fields <toya.fields@ncmail.net>
Date: Wed, 13 Dec 2006 13:45:27 -0500
To: Hyatt.Marshall@epamail.epa.gov
Why don't we just limit any future expansions to their current loading until the TMDL
is completed. Right now if there is no change in the manufacturing process and no
plans to expand then there is no reason to presume that there would be a significant
change in the nutrient load. We could also add additional language to the cover
letter notifying the facility about the status of the Cape Fear and what this might
mean to them down the road (potential nutrient reductions).
Hyatt.Marshall@epamail.epa.gov wrote:
thanks for the quick response. certainly don't want this to be the only
facility to have such a condition. NC was the only state not to give us
a permitting strategy for discharges to impaired waters prior to a TMDL.
We understand the difficulty in enforcing such a narrative limit, but we
were trying to give states flexibility if they didn't want to require
numeric limits based on historical loading prior to the TMDL. Since
there may be many similar situations in NC, we would be comfortable with
either a narrative limit or a numeric one, but it's difficult for us to
allow a permit w/ nothing. will be glad to discuss further with you
and/or Mike if needed.
Toya Fields - toya.fields@ncmail.net
Environmental Engineer I
Western NPDES Program
Division of Water Quality
Tel: 919-733-5083 x 551
Fax: 919-733-0719
1 of 1 2/15/2007 1:02 PM
Re: one tluestion re NC0001899, Performance Fibers
Subject: Re: one question re NC0001899, Performance Fibers
From: Toya Fields <toya.fields@ncmail.net>
Date: Tue, 12 Dec 2006 13:39:04 -0500
To: Hyatt.Marshall@epamail.epa.gov
Thanks Marshall,
I'll pass your suggestion on to Mike who's been working on the permitting strategy
for the Cape Fear basin. I wouldn't want to single out this permit, butit may be
something that he'd want to consider for permits across the basin. If we added that
condition then it would be the only permit in the basin to have that requirement.
Also this is an industrial facility with no plans to increase production (no reason
to expect a change in the discharge composition). Also, there would be no way for us
to enforce (or even define) that requirement without adding a limit.
I didn't forget about your other comments. I'm ok with specifying pH as 6.0 to 9.0
and nutrients as TN and TP. But I'm trying to look into how the footnote on ambient
temperature got into the permit so that I know what to do with it.
Toya
Hyatt.Marshall@epamail.epa.gov wrote:
saw that the downstream segment of the Cape Fear from the discharge is
303(d) listed for chl a. The current and draft permits both require TN
and TP monitoring. Until modeling is conducted during the next permit
cycle to develop limits, would you consider adding a narrative
requirement that the facility not increase its historical loading of TN
and TP? that would be consistent with our view of how to address
impaired waters prior to establishment of a TMDL (or WQBEL) - don't want
the existing situation to become worse. thanks.
Toya Fields - toya.fields@ncmail.net
Environmental Engineer I
Western NPDES Program
Division of Water Quality
Tel: 919-733-5083 x 551
Fax: 919-733-0719
1 of 1 2/15/2007 1:02 P1\4
comments on NC0001899 - Performance Fibers
•
Subject: comments on NC0001899 - Performance Fibers
From: Hyatt.Marshall@epamail.epa.gov
Date: Thu, 7 Dec 2006 09:20:02 -0500
To: toya.fields@ncmail.net
sorry I didnt get these to you sooner. hope you can reply by Dec 15.
thanks Marshall
. re footnote 2 in part A.1 of the permit, in the next to last line,
recommend changing "the 6 to 9 range" to "the 6.0 to 9.0 range" so there
is absolutely no conflict or confusion with the pH limit in the table
above.
2. recommend specifying total nitrogen "as N" and total phosphorus "as
3. footnote 1 in part A.2 contains ambient requirements, but no ambient
monitoring is specified. If only effluent sampling is required, how is
compliance with footnote 1 assessed?
1 of 1 2/15/2007 1:01 PM
NCDENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
Performance Fibers, Inc
NC0001899
Information
(1.) Facility Name:
(2.) Permitted Flow MGD):
..............................
(3.) Facility Class:
(4.) Pretreatment Program:
(5.) Permit Status:
Performance Fibers Inc WWTP
,0.244
N/A
Existing
(6.) County:
(7.) Regional Office:
(8.) USGS Topo Quad:
(9.) USGS Quad Name:
Chatham
Raleigh
E22SE
C
(1.) Receiving Stream:
(2.) Sub -basin:
(3.) Stream Assessment Unit:
(4.) Stream Classification:
(5.) 303(d) Status:
(6.) 305(b) Status:
Haw River (001)
UT to Shaddox Creek (002
03-06-07
16-(42)......................_._._._._......._._._.......................................
WS-IV (001)
(7.) Drainage Area (mi2):
(8.) Summer 7Q10 (cfs):
(9.) Winter 7Q10 (cfs):
(10.) 30Q2 (cfs):
(11.) Average Flow (cfs): ` 1848
980 (001)
40 (min release)
(12.) IWC %: 0.94 (001)
I. Proposed Changes Incorporated into Permit Renewal
• Remove fecal coliform and TRC monitoring from outfall 001.
• Remove zinc and fluoride monitoring from outfall 002.
• Reduce nutrient monitoring to quarterly and add nutrient reopener as recommended in the Middle Cape
Fear permitting strategy.
II. Summary
Performance Fibers (formerly Honeywell) manufactures polyester/synthetic fibers to be used in automobile
seatbelts.
Outfall 001 consists of process wastewater and sanitary wastewater. Process wastewater is generated from non -
process cooling tower blowdown, steam condensate, regenerated water from water softeners, demineralizer
blowdown, water rinse from polyester parts cleaning operations, stormwater from raw material handling areas,
finish oil pretreatment (ultrafiltration permeate), beam cleaning and floor drains. Sanitary wastewater is estimated
as 10,000 gpd. Performance Fibers recycles process wastewater and reclaims oil from the process.
Outfall 002 consists of stormwater, steam condensate, air dryer condensate, and fire pond overflow water.
The facility falls under the OCPSF guidelines for Other Fibers (40 CFR 414 Subpart C) and direct discharge, end of
pipe biological treatment. Performance Fibers has no guideline -defined metal bearing waste streams.
This portion of the Haw River is below the dam at Lake Jordan and prior to the confluence of the Cape Fear River.
Although this particular portion is not classified NSW, the Middle Cape Fear permitting strategy applies. The
modeling unit expects to conduct streams studies and modeling in the next permit cycle to determine limits for
nutrients and oxygen demanding wastes in these waters. The strategy recommends quarterly TP and TN
monitoring and the addition of a reopener clause for additional nutrient monitoring in the future.
WPDES Permit Fact Sheet - 11/21/06 Performance Fibers
Page 2
NC0001899
Limit Development
Process and non -process wasteflows have been historically difficult to characterize at this facility. In 1995 a
monitoring study was conducted to characterize wastewater sources and their contribution to the total BOD
loading. Based on that study it was determined that non -process flows contribute a significant BOD load (unlike
typical OCPSF facilities) and that an additional allowance should be granted. The existing BOD and TSS limits are
therefore based on effluent guidelines for OCPSF process wastewater (40 CFR 414.30), non -process wastewater and
sanitary wastes. No change to these calculated limits is recommended for his renewal.
III. Compliance Summary
DMR Data Review
Monthly average flows are at 33% capacity with maximum monthly average flows at 45% capacity. This is a slight
decrease from the previous renewal. All limited parameters are well within permit requirements. The facility does
currently chlorinate and past permits did include a fecal coliform limit. That limit was removed in the previous
permit on the basis that the dilution ratio for the 0.01 MGD sanitary flow is approximately 2500:1 based on a 40 cfs
7Q10 flow in the Haw River. Current policy requires a fecal coliform limit for facilities with a dilution ratio of less
than 331:1 (unless the discharge is to a class B or a coliform impaired waterbody). Performance Fibers chlorinates
the entire wasteflow (process, non -process, and sanitary) in order to comply with the fecal coliform limit, and has
indicated that they would have no reason to add chlorine to the wastestream if there were no fecal coliform
requirement. Therefore both fecal coliform and chlorine monitoring will be removed from the draft permit.
Table 1. Summary of 2004-2006 Monthly Average DMR Data
Flow
(MGD)
Temp.
(deg C)
TRC
(mg/L)
BOD
(#/day)
TSS
(#/day)
D.O.
(mg/L)
TN
(#/day)
TP
(#/day)
Specific
Conductance
pH
O&G
(#/day)
3.21
Avg
0.08
18.77
0.14
1.29
2.94
9.05
4.48
1.00
949.07
7.37
Max
0.11
26.29
0.2
2.00
4.46
12.60
10.25
2.00
1440.00
7.70
5.50
Min
0.05
9.69
0.08
0.22
1.48
6.00
1.25
0.35
0.00
7.13
0.60
Limit
0.244
10.4
5.0
6-9
_
20
Instream Data Review
The permit requires temperature, conductivity, and DO monitoring instream, however these requirements are
waived while the facility is a member of the Lower Cape Fear River Basin Association. Currently there is a
downstream coalition monitoring station, but no upstream station to provide comparative data. Therefore instream
data was not reviewed for this renewal. However the 2005 Cape Fear Basin Plan lists this segment of Haw River as
supporting for its aquatic life and recreational uses.
RPA Analysis
The facility does not currently have monitoring for toxicants (other than OCPSF requirements) at outfall 001.
Although several metals were present in the pollutant scan submitted as part of the permit application, none existed
in concentrations that could be expected to cause an exceedance of water quality standards. Also, no parameters
were detected as part of the yearly OCPSF scans.
The facility currently has annual monitoring for zinc and fluoride at outfall 002. Based on the low levels of these
pollutants present in the discharge and the high dilution instream, an RPA was not conducted for these parameters.
Table 2 summarizes fluoride and zinc data. Since there are so few data points, values from the previous renewal
were reviewed as well, but are not included in the table. Based on the data, fluoride and zinc monitoring will be
removed from the permit.
NPDES Permit Fact Sheet — 11/21/06
Performance Fibers
Page 3 NC0001899
Table 2: 2004-2006 Zinc and Fluoride Values
Date
Parameter
Unit
Value
Allowable
1/13/2004
00951- Fluoride, Total (as F)
mg/1
0.12
192,175.5 mg/L
1/12/2005
00951- Fluoride, Total (as F)
mg/1
0.14
1/25/2006
00951- Fluoride, Total (as F)
mg/1
0.19
1/12/2005
01092 - Zinc, Total (as Zn)
ug/1
15
5338.2 ug/L
1/25/2006
01092 - Zinc, Total (as Zn)
ug/L
39
WET Test Results
The facility has a quarterly, chronic whole effluent toxicity testing requirement at 0.94% effluent concentration at
outfall 001. They have passed 19 of 19 tests administered since January 2002.
The facility also has an annual acute toxicity testing requirement at outfall 002. They have passed 5/5 test conducted
since April 2002.
Correspondence File Review/Compliance History
The facility appears to be well operated. No concerns were noted in compliance inspections performed during
the 2002-2006 review period. There have been no violations of the permitted limits.
IV. Proposed Schedule for Permit Issuance
Draft Permit to Public Notice: November 22, 2006
Permit Scheduled to Issue: February 1, 2006
V. State Contact Information
If you have any questions on any of the above information or on the attached permit, please contact Toya
Fields at (919) 733-5083, extension 551.
Copies of the following are attached to provide further information on the permit development:
• Draft permit
NPDES Recommendation by:
Signature
Date
Regional Office Comments:
Regional Recommendation by:
Signature
Regional Supervisor:
Date
Signature Date
MIDDLE CAPE FEAR STRATEGY
(Subbasins 30607, 30613306161 30618-30620)
Background
The Middle Cape Fear includes the Haw River (from Jordan Dam to Deep River) and the Upper Cape Fear
and Little Rivers. The Haw River is classified as NSW, and nutrient -related impacts are apparent downstream
of the Jordan Dam. The Division added a 6.7-mile stretch of the Cape Fear River (from the confluence of the
Haw and Deep Rivers to Sanford) to the 2006 303(d) list due to chlorophyll a exceedances; and 6.2 miles of
streams due to low D.O. The Modeling Unit expects to initiate stream studies in 2010 and modeling in 2012
to determine limits for nutrient and oxygen -demanding wastes in these waters.
Permit Requirements
Table 3 summarizes the requirements for dischargers in the Middle Cape Fear sub -watershed. Dischargers
here should monitor nutrients at the frequencies set in 2B .0508 and report the results as concentrations. It is
possible that we (DWQ) will expect these dischargers to conduct supplementary TN and TP monitoring to
support stream studies and modeling, beginning around January 2009. The permits will include a special
condition, similar to one used in the Jordan Lake permits, noting that the Division may require this
monitoring later in the permit cycle.
Table 3. Permitting Strategy - Middle Cape Fear - REVISED
Subbasins: 30607 30613 30615
30619
30614 30616 30618 30620
DISCHARGER TYPE
PERMITTED
FLOW (MGD)
TN, TP
LIMITS
NUTRIENT MONITORING
SPECIAL CONDITIONS
Frequency
(TN, TP) (1)
Units
(TN, TP)
Report N
Species
Mass
Calcs
Re -Opener
All Dischargers
> 1.0
See
"General
Req'ts"
1/Month
Conc.
Y
>0.05 to <1.0
1/Quarter
Conc.
Y
<0.05
N/A
N/A
Y
(1) Per 2B .0508, Footnote (*)(2)(B)
Supplement to NPDES Permitting Strategies — Cape Fear, 2006 - REVISED 11
MIDDLE CAPE FEAR STRATEGY
Permit Langua>:e
The following are nutrient -related conditions for the Middle Cape Fear sub -watershed permits. They include
effluent sheets and special conditions. Refer to Table 3 of the permitting strategy to determine which of these
requirements apply to a given permit. The effluent sheet below includes standard as well as nutrient -related
language in order to provide some context.
[Permit Writers:
On each effluent sheet:
Carry over existing permit limits for nutrients.
Include nutrient parameters and set monitoring
requirements per Table 3 f
FEEL U ENT
Flow (MGD)
EFFLUENT
Flow (MGD)
(text text]
Legend
Standard permit text
New text for permits in this basin
Input from Permit Writer (facility or sub -
watershed -specific)
Comments to Permit Writers (delete prior
to Public Notice)
A.(.1.) EFFLUENT LIMITATIONS AND M.ONI1ORI.NG .REQUIREMENTS
During the period beginning on the effective date of this permit and lasting until expiration, the
Per niittee shall be authorized to discharge treated effluent from Outfail 001 subject to the following
effluent limitations and monitoring requirements:
EFFLUENT NT
CHARACTERISTICS
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly Weekly
Average Average
Daily
L Maximum
Measurement
Frequency
Sample
Type
Sample
Location '�
Flow (MGD)
—
Cur ;,3 luuus
Recording
i ur E
Total Nitrogen (mg/L) (2)
[existing]
[See Table 3]
Comp Grab
E
Total Phosphorus (mg/L) ()
[ex/sbngl
[See Table 31
Comp Grab
E
(I) Sample i.:i;cat:Ion: l - Influent E - Effluent.
(2) TN = TKN + NO3-N + NO2-N, where TN is Total Nitrogen, TKN is Total Kjeldahl Nitrogen, and NO3-N and
NO2-N are Nitrate and Nitrite Nitrogen, respectively. rinehmilt this footnote only e TN.
(3) The quarterly average for total phosphorus shall be the average of compasite.gralb samples collected weekly
during each calendar quarter (January -March, April -June, July -September, October -December). itnru this
*tie orrlyfirfacilities with a quarterly avenge TPWit,]
There shall be no disL harg
e
er than lrace a).rt:a u.its
A.(2.) PERMIT RE -OPENER: SUPPLEMENTARY NUTRIENT MONITORING
Pursuant to N.C. General Statutes Section 143-215.1 and the implementing rules found in Title 15A of the
North Carolina Administrative Code, Subchapter 02H, specifically, 15A NCAC 02H.0112(b)(1) and
02H.0114(a), and Part II, Sections B.12. and B.13. of this Permit, the Director of DWQ may reopen this
permit to require supplemental nutrient monitoring of the discharge. The additional monitoring will be to
support water quality modeling efforts within the Cape Fear River Basin, and shall be consistent with a
monitoring plan developed jointly by the Division and affected stakeholders.
Supplement to NPDES Permitting Strategies — Cape Fear, 2006 - REVISED
12
Performance Fibers NPDES Wastewater Permit Renewal
Subject: Performance Fibers NPDES Wastewater Permit Renewal
From: "Powell, Chuck" <Chuck.Powell@performancefibers.com>
Date: Tue, 14 Nov 2006 16:10:54 -0500
To: "Toya Fields" <toya.fields@ncmail.net>
Ms. Fields:
Per our meeting at your office in Raleigh a few weeks ago, Performance Fibers understands that there is a
possibility that the Fecal Coliform Monthly monitoring requirement may be taken out of our new NPDES
permit that is currently undergoing renewal with DWQ. If the Fecal Coliform monitoring requirement is
taken out of the renewed permit, then Performance Fibers will cease chlorination treatment activity at our
wastewater treatment plant. Ceasing chlorination activity will enhance safety and reduce treatment costs.
We currently chlorinate at the tail end of our treatment process at our chlorine contact chamber. We
would disconnect chlorine cylinder operations and simply send effluent and polishing pond, blend through
the contact chamber without chlorination.
We also understand that there is a possibility that DWQ could also take out monitoring requirements for
Zinc and Fluoride.
We appreciate your meeting with us in person at your office to discuss specifics related to the renewal of
our NPDES permit. Please contact me if you have any further questions.
Sincerely,
Chuck
Performance
Charles E. Powell, Jr., REM
Environmental/Industrial Hygiene Leader
Performance Fibers, Inc.
338 Pea Ridge Road
New Hill, NC 27562
(919) 545-3154-Office
(919) 542-6324-Fax
chuck.powell@performancefibers.com
Disclaimer:
This e-mail communication and any attachments may contain confidential
and privileged information and is for use by the designated
addressee(s) named above only. If you are not the intended addressee,
you are hereby notified that you have received this communication in
error and that any use or reproduction of this email or its contents is
strictly prohibited and may be unlawful. If you have received this
communication in error, please notify us immediately by replying to
this message and deleting it from your computer.
Thank you.
1 of 1 11/14/2006 4:17 PM
Performance r' Fibers
April 4, 2006
Ms. Toya Fields
Division of Water Quality
NPDES Permit Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject:
Dear Ms. Fields:
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DENR - WATER DUALITY
POINT SOURCE BRANCH
Performance Fibers Inc., New Hill, Chatham County, North Carolina
NPDES Permit No. NC001899
NPDES Permit Renewal Application Follow Up Submittal of Priority Pollutant Analysis
Data
Pursuant to our telephone conversations regarding the above subject, please find enclosed a finalized
renewal Application for Permit to Discharge Wastewater for Existing Manufacturing, Commercial, Mining,
and Silvicultural Operations (Forms 1 and 2c) for Performance Fibers, Inc., New Hill, North Carolina
Facility. Enclosed are one original and two (2) copies as required.
This is a follow up to Performance Fibers, Inc., original submission of the above state permit renewal
application which was noted as being received by the NPDES Permit Unit on January 30, 2006. As
discussed, the Priority Pollutant Analysis data which was under analysis by our contract laboratory on
January 30, 2006 has been included with this finalized renewal application. for your review.
If you have any questions regarding the revised permit renewal application or the enclosed copies of the
analytical data from our contract laboratory(PACE Analytical Labs), please contact me at (919) 545-3154.
Sincerely,
harles E. Powell, Jr., REM
Environmental Engineer
cc: D. Peterson -Cover Letter Only
G. Gardner-hardcopy Renewal Application Only
B. Ferree-hardcopy Renewal Application Only
D. Stidham-hardcopy Renewal Application Only
Enclosures
338 PEA RIDGE ROAD I NEW HILL, NC 27562 I TEL 919 542 2200
www.performancefibere.com
Performance Y ° Fibers
January 27, 2006
Mr. Charles H. Weaver, Jr.
NC Department of Environment & Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject:
Dear Mr. Weaver:
NPDES Permit Renewal Application
Performance Fibers, Inc.
New Hill, Chatham County, North Carolina
Permit # NC0001899
Performance Fibers is requesting renewal of its NPDES Permit (NPDES Permit No. 0001899) per Federal
Regulations 40 CFR 122.41, and North Carolina Regulations (15A NCAC 2H.0105(e)). The permit would
continue to allow Performance Fibers to discharge water from two outfalls into receiving waters designated
as the Haw River and Shaddox Creek in the Cape Fear River Basin. Enclosed are three (3) signed copies of
the EPA Application for Permit to Discharge Wastewater for Existing Manufacturing, Commercial,
Mining, and Silviculural Operations (FORM 2C) and EPA FORM 1 (General Information).
Performance Fibers New Hill, North Carolina facility has not made any operational or process changes that
impact the wastewater treatment plant since the last NPDES permit application. Since there has not been a
significant change in hydraulic or organic loading on the wastewater treatment plant, Performance Fibers
requests that the NPDES effluent limitations and monitoring requirements remain the same as those in the
existing permit.
At this time there are only two changes anticipated at the wastewater treatment facility in the next five (5)
years. One is to add a second sludge drying bed and the second is to add a pumping station at the polishing
pond so water can be pumped back to the aeration basin. The return of polishing pond water would
improve treatment plant performance during low influent flow situations. Performance Fibers understands
that any planned change could result in the need to submit for a minor or major permit modification and
Performance Fibers would consult with the NPDES Unit prior to such a change.
In order to expand on the enclosed narrative description of our outfalls (Item II-B.) and our wastewater
treatment process, Performance Fibers manages sludge generated from our "wasting sludge" process as
follows: Sludge that is wasted from the biological system is pumped to a sand drying bed where the water
drains through the sand into a collection system that leads to a sump. The sump is equipped with an
automatic level control switch and the water is returned directly to the aeration basin. Once the sludge is
dried, it is shoveled off the bed into a metal dumpster and transported to the following landfill:
Brunswick Waste Management Facility, LLC
107 Mallard Crossing Road
Lawrenceville, Virginia 23868
(434) 848-9277
338 PEA RIDGE ROAD I NEW HILL, NC 27562 I TEL 919 542 2200
u'wu'.perfornxancefibers.co,n
Performance F • Fibers
Pursuant to telephone conversations with Ms. Toya Fields, NPDES Permit Unit, the information contained
in Form 2C, Item V is not complete, as Performance Fibers is awaiting receipt of analytical results for a
certain number of these pollutants. Pollutants for which analyses are pending are noted on the Form for
each Outfall. Performance Fibers expects to received analytical results within the next 30 days and as
discussed, when results are received from the certified laboratory, these results will be submitted to the
NPDES Permit Unit. In addition as discussed in our telephone conversations, Form 3 is not included in this
submission package, as it is not required as part of this application. Similarly, we also understand that
Form 5 is not required, as this is a renewal application, and Form 5 is a requisite item for proposed
facilities.
Performance Fibers continues its membership in the Upper Cape Fear River Basin Association and
renewed signature of membership in March of 2005. Performance Fibers understands that pursuant to the
memorandum of agreement between NC DENR and the Upper Cape Fear River Basin Association, that any
instream monitoring requirements specified in the new permit will be waived as long as Performance Fibers
remains a member of UCFRBA. This agreement should be described in the effluent limitations and
monitoring requirements section of the new permit.
Performance Fibers is most appreciative of the telephone assistance of the NPDES Permit Unit in
preparation of this submission package. If we can provide any further information or should you have any
questions regarding this submission, please contact me at (919) 545-3154.
Sincerely,
Charles E. Powell, Jr., REM
Environmental Engineer
Enclosures: -EPA FORM 1- General Information
-EPA FORM 1-Item XI- Topographic Map
-EPA FORM 2C-Application for Permit to Discharge Wastewater, Existing
Manufacturing, Commercial, Mining and Silvicultural Operations
-Water Flow Line Drawing
-Wastewater Treatment Process Description-Outfall 001 and Outfall 002
-List of Item V-C pollutants
With Enclosures
cc: B. Ferree
G. Gardner
D. Peterson -W/O Enclosures
D. Stidham- W/O Enclosures
338 PEA RIDGE ROAD I NEW HILL, NC 27562 I TEL 919 542 2200
oowic.performancefibers.com
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Discharge
NO. 002
(113 GPD)
113
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PERFORMANCE FIBERS, INC.
NEW HILL, CHATHAM
COUNTY
NORTH CAROLINA
NPDES Permit No. NC0001899
J83.05 GPD)
0.2
A
Polishing
Pond
4.7
5.75
Wastewater
Treatment
Plant
C12
—� Disinfection
77.3
V
Discharge
NO. 001
(82 GPD)
NOTE: Flows are listed in units
of thousands of gallons.
Item II. B. Outfall Descriptions
Outfall 001
Performance Fiber's Moncure, North Carolina facility operates a 0.244-MGD wastewater
treatment facility with the following components and with final discharge through Outfall 001 to
the Haw River:
• Sanitary Flow Bar Screen and Grinder
• Process Wastewater Bar Screen
• Neutralization Chamber
• Aeration Basin
• Clarifier
• Sludge Drying Bed
• Optional Polishing Pond
• Chlorine Gas Disinfection
• Chlorine Contact Chamber.
Two separate pipelines transport process and sanitary waste to the wastewater treatment plant.
Process wastewater comes primarily from non -process cooling tower blowdown with smaller
contributions from the following: steam condensate, regenerated water from water softeners,
demineralizer blowdown, water rinse from polyester parts cleaning operations, stormwater from
raw material handling areas, finish oil pretreatment (ultrafiltration permeate), beam cleaning and
manufacturing building floor drains.
Sanitary wastewater comes primarily from plant restrooms, cafeteria, and custodial sinks. The
plant has a separate sanitary collection system that flows to a lift station. Sanitary waste is
blended in a comminutor, or the comminutor may be bypassed in the event of a mechanical
failure and the flow would be directed through a bar screen. From the lift station, the sanitary
influent is pumped directly into the aeration basin.
The process wastewater flows into a lift station adjacent to the sanitary lift station. It is then
pumped into a 1,200 gallon neutralization/mixing basin at the north end of the aeration basin. A
mixer provides thorough mixing to keep settleable solids in suspension and to aid in the
dispersion of pH control chemicals. A pH probe is used to measure influent pH and transmits a
signal to the pH analyzer/controller. The pH controller regulates the speed of a sulfuric acid
pump, which is used to control pH. The mixing basin then discharges through a 6" pipe into the
aeration basin.
The aeration basin has a capacity of 650,000 gallons and contains four surface aerators to
introduce oxygen into the water and provide mixing horsepower.
Water from the aeration basin overflows a weir into a 20' diameter clarifier. The clarifier is
designed with a surface overflow rate of 440 gallons/ft2/day. A liquid coagulant is added to the
water as it flows from the aeration basin to the clarifier to aid in solids settling. The clarifier is
equipped with surface and bottom sweep arms. The surface sweep arm directs floating solids to a
scum pit. The bottom sweep rakes sludge to be recycled or wasted. Sludge pumps remove settled
solids from the bottom of the clarifier and either pump the recycled sludge back to the aeration
basin or waste it to the sludge drying beds.
Clarifier overflow can be valved to a one -million gallon capacity polishing pond for additional
solids removal or directly into the chlorine contact chamber. Thus, overflow form the clarifier,
water from the polishing pond, or a blended flow from both structures enters a 9' X 37' X 3'
chlorine contact chamber that is designed for a minimum of 30 minutes contact time at a flow rate
of 90 gpm. The chlorinators located in the wastewater treatment plant lab building are manually
controlled and the chlorination room is equipped with a chlor-alert alarm system. Chlorine is
supplied to the chlorinators through scale -mounted 150 lb. cylinders. Chlorine recirculation
pumps transfer water from the effluent end of the chlorine contact chamber and supplies the
diluted water through the chlorine injector. The chlorinated water is returned through a
submerged diffuser to the influent end of the contact chamber.
Effluent flow from the chlorine contact chamber is measured before it enters an underground
pipeline that discharges directly into the Haw River.
Outfall 002
Stormwater, steam condensate, air dryer condensate, and fire pond overflow discharge through
Outfall 002 to Shaddox Creek. The drainage system which reports to Outfall 002 includes a
system of baffles and weirs designed to contain accidental spills of oil. In an emergency, flow
can be contained in a holding pond and pumped to a storage or pumped to the process sewer.
Item III. A & B. Production
On November 5, 1987 EPA issued regulations establishing effluent limitations for the Organic
Chemicals, Plastics, and Synthetic Fibers (OCPSF) industrial category. Provisions of Subpart C
(414.31) and Subpart I (414.90) Direct Discharge Point Sources That Use End -of -Pipe Biological
Treatment are applicable to process wastewater discharges from the manufacture of polyester
fiber and resin. OCPSF effluent guidelines are not expressed in terms of production. No metal -
bearing waste streams or cyanide -bearing waste streams listed in Appendix A to Part 414 exist in
the manufacture of polyester fiber and resin.
Item V. A-C.
Characteristics listed in Item V reflect data from January 1, 2005 - January 25, 2006. For some
parameters, testing was conducted throughout the year, while other parameters were tested
annually. One time testing was conducted for most of the parameters.
a
Item VI.
The following is a list of Item V-C pollutants that are present on the plant site. None of these
materials are used as a raw material or intermediate and none of these materials are manufactured
as a product or a by-product of the manufacturing process. The list may not be exhaustive, as
some commercial products are considered proprietary by the manufacturer and their specific
composition is not known to us. In addition, some new materials may be obtained in the future
that contain one or more of the listed chemicals and whose composition may not be known to us.
Pollutant
Use on Site
Antimony
Lab Reagent
Chromium
Lab Reagent
Copper
Lab Reagent
Lead
Lab Reagent
Mercury
Lab Reagent, Instrumentation
Nickel
Lab Reagent
Silver
Lab Reagent, Electrical Equipment
Zinc
Lab Reagent
Phenols
Lab Reagent
Carbon Tetrachloride
Lab Reagent
Chloroform
Lab Reagent
Dichlorodifluoromethane
Lab Reagent, Refrigerant, Leak Checks
1,1,2,2-Tetrachloroethane
Lab Reagent
Tetrachloroethylene
Solvent
Toluene
Lab Reagent
1,1, 1 -Trichloroethane
Solvent
Trichloroethylene
Solvent
Phenol
Lab Reagent
Dichlorobenzene
Lab Reagent
1,2,4-Trichlorobenzene
Electrical Equipment
PCB
Electrical Equipment
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 6
1445 ROSS AVENUE. SUITE 1200
DALLAS. TEXAS 7S202-2733
OCT 2 0 2006
Chuck Carr Brown, Ph.D.
Assistant Secretary
Louisiana Department of Environmental Quality
P.O. Box4313
Baton Rouge, Louisiana 70821-4313
Dear Mr. Brown:
Thank you for your letter of September 26, 2006, requesting clarification on questions
concerning the National Pollutant Discharge Elimination System (NPDES) permitting of
centralized waste treatment (CWT) facilities that accept oiI and gas extraction produced waters. i
appreciate your efforts to ensure effective regulation of these types of facilities_
EPA Headquarters has determined that oil and gas extraction produced waters, which are
prohibited from being discharged at the wellhead, may be collected .and transferred to a CWT
facility for treatment and subsequent discharge when required technology and water -quality
based effluent limits are included in the CWT's NPDES permit. According to this
determination, discharges from a CWT treating oil and gas extraction produced waters are
subject to the effluent limitations and pretreatment standards established for the CWT Oils
Treatment and Recovery Subcategory of the Centralized Waste Treatment Point Source
Category. See 40 CFR 437, Subpart B_ However, additional limits and conditions are needed to
address pollutants which were not considered in developing the CWTEffluent Guidelines and
Standards.
Based on our review, my staff identified several pollutants commonly found in produced
waters (e.g., radionuclides, chlorides) that were not regulated or considered for in the
development of the CWT Effluent Guidelines.' EPA's NPDES regulations require an NPDES
pen -nit writer to include certain conditions in an NPDES permit. The permit writer must include
permit requirements, based on 1) promulgated effluent limitations guidelines and standards; 2)
new source performance standards; 3) case -by -case technology limitations for pollutants to the
extent promulgated guidelines do not apply; or 4) a combination of three, 40 C.F.R. §
122.44(a)(1). EPA's regulation at 40 C.F.R. 125.3 describes how a permit writer must develop
these technology based limitations. Next, the permit writer must also develop permit
requirements in addition to or more stringent than promulgated guidelines that are necessary to
achieve water quality standards. 40 C.F.R. 122.44(d).
'See the following two documents for additional examples of pollutant present in oil and
gas extraction produced waters: Coastal Technical Development Document (1996) and Offshore
Technical Development Document (1993).
Consequently, fora CWT facility that accepts produced waters or other waste from oil
and gas extraction facilities, you will need to develop best professional judgement technology
based effluent limits to address those pollutants not considered or regulated by the CWT Effluent
Guidelines and incorporate these limits in the facility'sNPDES permit. Additionally, you will
need to develop water quality based effluent limits for this facility's NPDES permit to protect
water quality.
Finally, EPA is also aware that issues, such as interference or pass through of pollutants,
can arise when these sorts of wastes are discharged to publicly owned treatment works (POTW).
All indirect dischargers are subject to general pretreatment standards (40 C.F.R 403), includinga
prohibition on discharges causing "pass through" or "interference." See 40 C.F.R 403.5. You will
need to ensure that the POTW develops additional limitations for pollutants not regulated under
the CWT guidelines under a pretreatment program for a CWT facility that accepts oil and gas
extraction wastes, if necessary to protect the sewage treatment plant infrastructure and prevent
interference or pass through of pollutants.
EPA is committed to provide any assistance necessary for this permitting effort. Feel free
to contact me if you should need any additional information or have your staff contact Scott
Wilson of my staff. Scott can be reached by telephone at (214) 665-7511 or via e-mail at
wilson js®epa.gov.
Sincerely,
Migru4l L Flores
Dire or
Water Quality Protection Division