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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 � o s a. 1 _ F ry d USS 2: ad'Name, Moneure V ' Recei tg Streams 001 Taw River, 002 Sbaddox Cree Stream Class WS-IV Subbasm Case Feat '.03 06 07 • ,.? �r- t(r - 1 I *t r]I S Lk �,lt i t i y �\ 1 + i !iii)l 97—`YI1 fdf �t ✓QQ] 4t.35°3.'01^ • Long: 77°0,3.`25" f' Long. '79°02'36" N S rlubma 0343 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: ...`!jL E V/ 1E i Li AF 1 ZuU0 J 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 4/ 'k. . A„ r .f E y, Discharge NO. 002 (113 GPD) 113 Overflow vv 33 Steam Boilers ..14 5 I-1VAC, Air Compressor and Steam Condensate 4r 78.5 Storm Water r „0.5 Air Dryer ,10 15 Process 7.5 1.5 v 1.0 HAW RIVER 261 I Fire Pond 224 Potable Water Treatment 8 H 215 1 Oil Mist Air Pollution Control System ,1.5 Q 5 Alum Settling Pond RR Cooling Towers TW-1,4,5,6 3 on 1).°15 Pre Treatment- 0.25 Concentrated Oil Emulsion „Shipped Off -site — ♦ WATER �► --D' EVAPORATION —t> - --► STEAM - OIL -� 62.7 4.9 10 Sanitary Beam Cleaning 10 1.0 SC:NEMA I IL: UI- WA I ER FLOW 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 • Cv1 T/Ffacf Wk.) k / ,(A)o-P etcA,7-#. 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