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Home My WebLink AboutNC0004952_Permit (Issuance)_20040420NPDES DOCUHENT SCANNING COVER SHEET NC0004952 Celanese Shelby Facility NPDES Permit: Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Correspondence Owner Name Change Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: April 20, 2004 This document iea printed on a -come paper - ignore any content on the z e -erne aide April 20, 2004 Ms. PEM Carter, Environmental Engineer CNA Holdings, Inc. Shelby Plant Highway 198 Shelby, North Carolina 28152 Dear Ms. Carter: 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 Subject: NPDES Permit Issuance Permit NC0004952 Ticona Facility Cleveland County Division personnel have reviewed and approved your application for renewal of the subject permit. Accordingly, we are forwarding the attached final 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). The attached final permit incorporates those changes communicated to you in the amended fact sheet. These changes are the result of comments received from the US EPA Region 4 as well as your attorney. Compliance with all terms and conditions of the attached permit is the responsibility of the Permittee. Please note that T15A 08G .0204 of the North Carolina Administrative Code has been interpreted to mean that the Operator in Responsible Charge is responsible for operation of water pollution control systems. 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 permit shall be final and binding. Please take notice that this permit is not transferable. 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, Coastal Area Management Act, or any other Federal or Local governmental permits which may be required. If you have any questions or need additional information, please do not hesitate to contact Mark McIntire of my staff at (919) 733-5083, extension 508. Sincerely, ORIGINAL SIGNED BY Mark McIntire • Alan W. Klimek, P.E. cc: Central Files NPDES Unit Files Mooresville Regional Office Aquatic Toxicology Unit EPA Region 4 1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-161 7 - TELEPHONE 919-733-5083/FAX 919-733-0719 VISIT US ON THE WEB AT http://h2o.enr.state.nc.us/NPDES Permit NC0004952 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 Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, CNA Holdings, Inc. is hereby authorized to discharge wastewater and stormwater from a facility located at CNA Holdings, Inc. - Ticona Facility On NC Highway 198 South of Shelby Cleveland County to receiving waters designated as Buffalo Creek in the Broad River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IV hereof. The permit shall become effective June 1, 2004. This permit and the authorization to discharge shall expire at midnight on August 31, 2008. Signed this day April 20, 2004. ORIGINAL SIGNED BY Mark McIntire Alan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission Permit NC0004952 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked, and as of this 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. CNA Holdings, Inc. Ticona Facility is hereby authorized to: 1. Continue to operate an existing 0.8 MGD activated sludge wastewater treatment facility located at on NC Highway 198, south of Shelby in Cleveland County, consisting of: • comminutor; • bar screen & grit chamber; • three (3) equalization basins utilizing pH adjustment; • two (2) aeration basins with chlorine added on an as -needed basis; • two (2) secondary clarifiers with polymer addition; • dual media tertiary treatment system; • ultraviolet disinfection; • a waste activated sludge digester; • two (2) sludge ponds; and • three (3) polishing ponds. 2. Discharge groundwater, process and domestic wastewaters, and first -flush stormwater from the treatment works described in item one above and boiler water make-up and blowdown, clarifier blowdown, cooling tower make-up and blowdown, fire lagoon water, and non -process spin -finish and Vectra wastewaters at the location specified on the attached map through outfall 001 into Buffalo Creek, a class C water in the Broad River Basin. r1it 1/4 CNA Holdings — Ticona Facility - NC0004952 USGS Quad Name: Blacksburg North Receiving Stream: Buffalo Creek Stream Class: C Subbasin: Yadkin - 030805 Lat.: 35°11'15" Long.: 81°30'37" l • Not to SCALE Permit NC0004952 Part I - Section A 1. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of this permit and lasting through April 30, 2006, the Permittee is authorized to discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: PARAMETER EFFLUENT LIMITATIONS MONITORING REQUIREMENTS Monthly Average . Daily Maximum Measurement Frequency Sample Type Sample Locations Flow (MGD) 0.8 Continuous Recording Effluent BOD, 5-day, 20°C 68.0 lbs/day 164.0 lbs/day Daily Composite Effluent Total Suspended Solids 114.0 lbs/day 328.0 lbs/day Daily Composite Effluent Fecal Coliform (Geometric Mean) 200 / 100 ml 400 / 100 ml Weekly Grab Effluent Oil and Grease Quarterly Grab Effluent Total Copper Monthly Composite Effluent Total Nitrogen (NO2+NO3+TKN) Semi -Annually Composite Effluent Total Phosphorus Semi -Annually Composite Effluent Chronic Toxicity2 Quarterly Composite Effluent Pollutant Analysis See Note 3 Composite Effluent pH4 Between 6.0 and 9.0 Standard Units Daily Grab Effluent 40 CFR 414 Subpart I Monitoring See Part I, Section A, Number 3 of this permit. Notes: 1 Effluent is defined as final effluent from the polishing ponds. 2 Chronic Toxicity (Ceriodaphnia) P/F @ 5.8%; March, June, September, December; see Part I, Section A, Number 4 of this permit. 3 The priority pollutant analysis shall be conducted during the month prior to submittal of the permit renewal application. See Part I, Section A, Number 5 of this permit. 4 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent by grab sample. The effluent pH of the wastewater is defined and limited at a point between the final clarifiers and final polishing pond, such a point being after the combination of all potential influents to the polishing pond. If the pH of the effluent from the polishing pond exceeds 9.0, there will be no effluent violation if the wastewater from the final clarifier has not exceeded 9.0 during the thirty (30) days preceding the measurements of the pH above 9.0 at the effluent from the polishing pond. The pH of the wastewater from the clarifiers and the pH of the effluent from the polishing ponds (final discharge) will be monitored by continuous recorder. Upstream and downstream monitoring shall be conducted weekly in any week the pH of the effluent from the polishing pond is outside the 6.0 - 9.0 range. THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS. Permit NC0004952 Part I - Section A 2. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on May 1, 2006 and lasting until permit expiration, the Permittee is authorized to discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: PARAMETER EFFLUENT LIMITATIONS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency Sample Type Sample Locations Flow (MGD) 0.8 Continuous Recording Effluent BOD, 5-day, 20°C 68.0 lbs/day 164.0 lbs/day Daily Composite Effluent Total Suspended Solids 114.0 lbs/day 328.0 lbs/day Daily Composite Effluent Fecal Coliform (Geometric Mean) 200 / 100 ml 400 / 100 ml Weekly Grab Effluent Oil and Grease Quarterly Grab Effluent Total Copper Monthly Composite Effluent Total Nitrogen (NO2+NO3+TKN) Semi -Annually Composite Effluent Total Phosphorus Semi -Annually Composite Effluent Chronic Toxicity2 Quarterly Composite Effluent Pollutant Analysis See Note 3 Composite Effluent pH Between 6.0 and 9.0 Standard Units Daily Grab Effluent 40 CFR 414 Subpart I Monitoring See Part I, Section A, Number 3 of this permit. Notes: 1 Effluent is defined as final effluent from the polishing ponds. 2 Chronic Toxicity (Ceriodaphnia) P/F @ 5.8%; March, June, September, December; see Part I, Section A, Number 4 of this permit. 3 The priority pollutant analysis shall be conducted during the month prior to submittal of the permit renewal application. See Part I, Section A, Number 5 of this permit. THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS. Permit NC0004952 Part I - Section A 3. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - SUBPART I Beginning on the effective date of this permit and lasting through the expiration date, the Permittee shall comply with the limitations and monitoring frequencies established below at outfall 001: PARAMETER EFFLUENT LIMITATIONS MONITORING REQUIREMENTS Monthly Average' Daily Maximum' Measurement Frequency Sample Type Sample Location Acenaphthene 0.058 0.156 Annually Grab Effluent Acenaphthylene 0.058 0.156 Annually Grab Effluent Acrylonitrile 0.255 43.8 µg/L Annually Grab Effluent Anthracene 0.058 0.156 Annually Grab Effluent Benzene 0.098 0.361 Annually Grab Effluent Benzo(a)anthracene 3.2 µg/L Annually Grab Effluent 3,4-Benzofluoranthene 5.4 µg/L Annually Grab Effluent Benzo(k)fluoranthene 3.2 µg/L Annually Grab Effluent Benzo(a)pyrene 5.4 µg/L Annually Grab Effluent Bis(2-ethylhexyl) phthalate 0.273 0.740 Annually Grab Effluent Carbon Tetrachloride 0.048 0.101 Annually Grab Effluent Chlorobenzene 0.040 0.074 Annually Grab Effluent Chloroethane 0.276 0.711 Annually Grab Effluent Chloroform 0.056 0.122 Annually Grab Effluent 2-Chlorophenol 0.082 0.260 Annually Grab Effluent Chrysene 3.2 µg/L Annually Grab Effluent Di-n-butyl phthalate 0.072 0.151 Annually Grab Effluent 1,2-Dichlorobenzene 0.204 0.432 Annually Grab Effluent 1,3-Dichlorobenzene 0.082 0.117 Annually Grab Effluent 1,4-Dichlorobenzene 0.040 0.074 Annually Grab Effluent 1,1-Dichloroethane 0.058 0.156 Annually Grab Effluent 1,2-Dichloroethane 0.180 0.560 Annually Grab Effluent 1,1-Dichloroethylene 0.042 0.066 Annually Grab Effluent 1,2-trans-Dichloroethylene 0.056 0.143 Annually Grab Effluent 2,4-Dichlorophenol 0.103 0.297 Annually Grab Effluent 1,2-Dichloropropane 0.406 0.610 Annually Grab Effluent 1,3-Dichloropropylene 0.077 0.117 Annually Grab Effluent Diethyl phthalate 0.215 0.538 Annually Grab Effluent 2,4-Dimethylphenol 0.048 0.095 Annually Grab Effluent Dirnethyl phthalate 0.050 0.125 Annually Grab Effluent 4,6-Dinitro-o-cresol 0.207 0.735 Annually Grab Effluent 2,4-Dinitrophenol 0.188 0.326 Annually Grab Effluent 2,4-Dinitrotoluene 0.300 0.756 Annually Grab Effluent Permit NC0004952 Part I - Section A 3. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - SUBPART I CONTINUED Beginning on the effective date of this permit and lasting through the expiration date, the Permittee shall comply with the limitations and monitoring frequencies established below at outfall 001: EFFLUENT LIMITATIONS MONITORING REQUIREMENTS PARAMETER Monthly Daily Maximum' Measurement Frequency Sample Type Sample Location Average' 2,6-Dinitrotoluene 0.676 1.700 Annually Grab Effluent Ethylbenzene 0.085 0.286 Annually Grab Effluent Fluoranthene 0.066 0.180 Annually Grab Effluent Fluorene 0.058 0.156 Annually Grab Effluent Hexachlorobenzene 0.05 µg/L Annually Grab Effluent Hexachlorobutadiene 0.053 0.130 Annually Grab Effluent Hexachloroethane 0.056 0.143 Annually Grab Effluent Methyl Chloride 0.228 0.504 Annually Grab Effluent Methylene Chloride 0.106 _ 0.236 Annually Grab Effluent Naphthalene 0.058 0.156 Annually Grab Effluent Nitrobenzene . 0.072 0.180 Annually Grab Effluent _ 2-Nitrophenol 0.109 0.183 Annually Grab Effluent 4-Nitrophenol 0.191 0.329 Annually Grab Effluent Phenanthrene 0.058 0.156 Annually Grab Effluent Phenol 0.040 0.069 Annually Grab Effluent Pyrene 0.066 0.178 Annually Grab Effluent Tetrachloroethylene 0.058 0.149 Annually Grab Effluent Toluene 0.069 0.212 Annually Grab Effluent 1,2,4-Trichlorobenzene 0.180 0.371 Annually Grab Effluent 1,1,1-Trichloroethane 0.056 0.143 Annually Grab Effluent 1,1,2-Trichloroethane 0.056 0.143 Annually Grab Effluent Trichloroethylene 0.056 0.143 Annually Grab Effluent Vinyl Chloride 0.276 0.711 Annually Grab Effluent Notes: 1 All units are lbs/day unless otherwise noted. 2 Where the limit of detection of an approved analytical method utilized by the Permittee is greater than the stated effluent limitation, an analytical result below the limit of detection shall constitute compliance with the effluent limitation. Permit NC0004952 PART I - SECTION A 4. CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY) — OUTFALL 001 The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 5.8%. 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 March, June, September, and December. 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: Environmental Sciences Branch North Carolina Division of Water Quality 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch 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 Branch 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. Permit NC0004952 PART I - SECTION A 5. POLLUTANT ANALYSIS CONDITION The Permittee shall conduct a test for pollutants once every five years at the effluent from the treatment plant. The discharge shall be evaluated as follows: A. A pollutant analysis of the effluent must be completed using EPA approved methods for the following analytic fractions: • purgeables (i.e. volatile organic compounds); • acid extractables; • base/neutral extractables; • organochlorine pesticides and PCBs; • herbicides; and • metals and other inorganics. The Pollutant Analysis Monitoring (PAM) Requirement Reporting Form A and accompanying memo, to be provided to all discharges impacted by this monitoring requirement, describes the sampling and analysis requirements and lists chemicals to be included in the pollutant analysis. B. Other significant levels of synthetic organic chemicals must be identified and approximately quantified. For the purposes of implementing this requirement, the largest 10 GC/MS peaks in the purgeable, base/neutral extractable, and acid extractable fractions (or fewer than 10 if less than 10 unidentified peaks occur) for chemicals other than those specified on the PAM reporting form should be identified and approximately quantified as stated in the aforementioned reporting form. This part (item B) of the PAM requirement is to be referred to as the "10 significant peaks rule". 6. GROUNDWATER TREATMENT AND REPORTING CONDITION The Permittee shall submit to the Division a copy of its Semi -Annual Reports on Operable Unit 1 at the same time that it submits such reports to U.S. EPA Region IV and the North Carolina Division of Waste Management. The Permittee shall not be required to submit a Semi -Annual Report to the Division for any period in which there was no flow of groundwater from Operable Unit 1 to the wastewater treatment plant. The Permittee shall maintain the sequencing batch reactor treatment system previously used to treat extracted groundwater in an idled, but standby, mode such that it can be employed in the event the groundwater has an adverse impact on the activated sludge treatment system. THE STAR NCDENR / DWQ / NPDES 1617 MAIL SERVICE CENTER RALEIGH NC 27699-1617 ATTN: VALERY STEPHENS PUBLIC NOTICE NOTIFICATION OF INTENT TO ISSUE A NPDES WAS CLEVELAND COUNTY I, Tina Mc Combs, Classified Advertising Manager at THE STAR, a newspaper published in Shelby, N. C., do solemnly swear that the advertisement hereto annexed appeared in the SHELBY STAR , for one successive week/days beginning FEB. 08, 74 AAR Classified Advertising Manager Sworn to and subscribed before me on this the 11TH day of FEBRUARY, 2004 ineLxtwaitcb otary Public MY COMMISSION E Y.P7._ .,t:,n ',n,n; �,.VrLriNO^CP�,.s February 11, 2004 PUBLIC NOTICE STATE OF NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION/ NPDES UNIT 1617 MAIL SERVICE CENTER, RALEIGH, NC 27699-1617 NOTIFICATION OF INTENT TO ISSUE A NPDES WASTEWATER PERMIT On the basis of a thorough staff review and application of NC General Statute 143.21, Public law 92-500 and other lawful standards and regulations, the North Carolina Environmental Management Commission proposes to issue a Nation- al Pollutant Discharge Elimination System (NPDES) wastewater dis- charge permit to the per- sons) listed below effec- tive 45 days from the pub- lish date of this notice. Written comments regard- ing the proposed permit will be accepted until 30 days after the publish date of this notice. All comments re- ceived prior to that date are considered in the final de- terminations regarding, the proposed permit. The Di- rector of the NC Division of Water Quality may decide to hold a public meeting for the proposed permit should the Division receive a.sig- nificant degree of public in- terest. F E B 1 3 2004 Copies of the draft permit and other supporting infor- mation on file used to de- termine conditions present in the draft permit are available upon request and payment of the costs of re- production. Mail comments and/or requests for infor- mation to the NC Division of Water Quality at the above address or call Ms. Valery Stephens at (919) 733-5083, extension 520. Please indicate the NPDES permit number (attached) in any communication. Inter- ested persons may also visit the Division of Water Quality at 512 N. Salisbury Street„ Raleigh, NC 27604-1148 between the hours of 8:00 a.m. and 5:00 p.m. to review information on file. CNA Holdings, Inc. has ap- pliod for renewal of its NPDES permit for the Ticona Facility (NC0004952) in Shelby, NC, Cleveland County, discharging a maximum of 0.8 MGD of treated domes- tic and industrial wastewater to Buffalo Creek, a class C water in the Broad River Basin. No parameters are water quali- ty limited, however this dis- charge may impact future allocation of this aquatic re- source. The city of Kings Mountain has applied for renewal the NPDES permit for its Pilot Creek WWTP (NC0020737). The facility is permitted to discharge up to 6.0 MGD of treated do- mestic wastewater into Buf- falo Creek, a class C stream in the Broad River Basin. Currently ammo- nia -nitrogen and cadmium are water quality limited. This discharge may impact future allocation of the re- source. The City of Shelby has ap- plied for renewal of NPDES permit for its wastewater treatment facility (NC0024538). This facility is permitted to discharge a maximum of 6.0 MGD of treated domestic wastewater to the First Broad River, a class C wat- er in the Broad River Basin. Currently ammo- nia -nitrogen, cyanide, and nickel are water quality lim- ited. This discharge may impact future allocation of this resource. February 8, 2004 ttc PUBLIC NOTICE STATE of NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION/NPDES UNIT 1617 MAIL SERVICE CENTER RALEIGH, NC 27699-1617 NOTIFICATION OF INTENT TO ISSUE A NPDES WASTEWATER PERMIT On the basis of thorough staff review and application of NC General Statute 145.21, Public law 92-500 and other lawful standards and regulations, the North Carolina Environmental Management Commission proposes to issue a National Pollutant Discharge Elimination System (NPDES) wastewater discharge permit to the person(s) listed below effective 45 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 for,., the proposed permit sfioutd 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 draft permit are available upon request and payment of the costs of reproduction. Mail comments and/or requests for information to the NC Division of Water Quality at the above address or call Ms. Valery Stephens at (919) 733-5083, extension 520. Please include the NPDES permit number (attached) in any communication. Interested persons may also visit the Division of Water Quality at 512 N Salisbury Street Raleigh, NC 27604-1148 between the hours of 8:00 a.m. and 5:00 p.m to review information on file. CNA Holdings, Inc. has applied for renewal of its NPDES permit for the Ticona Facility (NC0004952) in Shelby, NC, Cleveland County, discharging a maximum of 0.8 MGD of treated domestic and industrial wastewater to Buffalo Creek, a class C water in the Broad River Basin. No parameters are water quality limited, however this discharge may impact future allocation of this aquatic resource. The City of Kings Mountain has applied for renewal the NPDES permit for its Pilot Creek WWTP (NC0020737). The facility is permitted to discharge up to 6.0 MGD of treated dornestic wastewater into Buffalo Creek, a class C stream in the Broad River Basin. Currently ammonia - nitrogen and cadmium are water quality limited. This discharge may impact future allocation of the resource. The City of Shelby has applied for renewal of NPDES permit for its wastewater treatment facil- ity (NC0024538). This facility is permitted to dis- charge a maximum of 6.0 MGD of treated domestic wastewater to the First Broad River, a class C water in the Broad River Basin. Currently ammonia -nitrogen, cyanide, and nickel are water quality limited. This discharge may impact future allocation of this resource. AFFIDAVIT OF PUBLICATION STATE OF NORTH CAROLINA RUTHERFORD COUNTY Before the undersigned, a Notary Public of said County and State, duly commissioned, qualified, and authorized by law to administer oaths, personally appeared Susie Sisk who being first duly sworn, deposes and says: that they are Classified Advertising Representitive (Owner, partner, publisher, or other officer or employee authorized to make this affidavit) of THE DAILY COURIER, a newspaper published, issued and entered as second class mail In the town of FOREST CITY, In said County and State; that they are authorized to make this affidavit and sworn statement; that the notice or other legal advertisement, a true copy of which is attached hereto, was published in THE DAILY COURIER on the following dates: February 7, 2004 and that 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 qualified newspaper within the meaning of Section 1-597 of the General Statutes of North Carolina. This the 12th day of February, 2004. v�xl.nt Susie Sisk, Classified Advertising Representitive Sworn to and subscribed before me this the 12th day of February, 2004. j az -un (Heather D. Rhodes, Notary Public) My commission expires: August 21, 2008 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 MAR 0 5 Innd Mr. Mark McIntire 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 CNA Holdings Inc. - Ticona Plant Permit No. NC0004952 Dear Mr. McIntire: 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 it 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 OH Based Inks on Recycled Paper (Minimum 30% Postconsumer) CERTIFIED MAIL 7002 0860 0006 3968 1022 Return Receipt to PEM Carter PEMC0411 t,':A.R 1 5 c'r.', March 11, 2004 Mr. Mark D. McIntire North Carolina Department of Environment And Natural Resources Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 RE: Ticona Shelby Facility Draft NPDES Permit Permit No. NC0004952 Cleveland County Dear Mr. McIntire: iicona Ticona Shelby Plant Highway 198 Shelby, NC 28152 Telephone (704) 480-4700 I am writing on behalf of CNA Holdings, Inc. ("Ticona"), to comment on the draft NPDES permit for the above -referenced facility, which we received from the Division of Water Quality ("DWQ") on February 11, 2004. 1. Effluent Sampling Location. The draft permit proposes to relocate the facility's effluent sampling location from its ✓current location, the discharge point from the final clarifier, to the outfall from the final polishing pond to Buffalo Creek. While we understand why DWQ perceives the need to relocate the sampling point, as our attorney, Steve Levitas of Kilpatrick Stockton LLP, has discussed with you, accomplishing that goal and achieving compliance at the new location with the permit limit for pH will require a significant engineering and construction effort. Although the facility's effluent consistently meets the pH limit upon discharge from the final clarifier, natural processes occurring in the polishing ponds tend to raise pH to the point that it may not consistently meet the permit limit upon discharge to Buffalo Creek. This problem can be corrected in a number of ways, including through the addition of acid solution to some point in the wastewater treatment system to lower pH. Ticona is prepared to make modifications to its treatment system for this purpose, but requires time to determine the approach that will effectively control pH with the least amount of acid used in the process and to design and construct the necessary new and modified facilities. This process will take a minimum of 24 months to complete. You indicated to Mr. Levitas that you are prepared to include a compliance schedule in the permit to address this issue. Accordingly, we propose that the permit be modified to include two versions of Section I.A.1. The first version, which would be in effect until 24 months from the date of permit issuance, would include a footnote 4 identical to footnote 4 in the existing NPDES permit for the facility. That footnote reads as follows: "The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent by grab sample. The effluent pH of the wastewater is defined and limited at a point between the final clarifiers and final polishing Celanese pond, such a point being after the combination of all potential influents to the polishing pond. If the pH of the effluent from the polishing pond exceeds 9.0, there will be no effluent violation if the wastewater from the final clarifier has not exceeded 9.0 during the thirty (30) days preceding the measurements of the pH above 9.0 at the effluent from the polishing pond. The pH of the wastewater from the clarifiers and the pH of the effluent from the polishing ponds (final discharge) will be monitored by continuous recorder. Upstream and downstream monitoring shall be conducted weekly in any week the pH of the effluent from the polishing pond is outside the 6.0-9.0 range." The second version of Section I.A.1. would be the version that appears in the current draft permit (i.e., with footnote 4 deleted) and would become effective 24 months from the date of permit issuance. 2. Effluent Limitations and Monitoring Requirements. The draft permit significantly reduces a number of effluent limitations for the facility. A though Ticona's two contract laboratories use approved analytical methods (test method frt CPSF Semivolatiles 625 and Volatiles 624), as Mr. Levitas has discussed with you, the limits of detection of those methods for a number of parameters are above the proposed effluent limitations. Accordingly, we request that a new footnote be added to the "Effluent Limitations" column in Section I.A.2. which reads as follows: "Where the limit of detection of an approved analytical method utilized by the Permittee is greater than the stated effluent limitation, an analytical result below the limit of detection shall constitute compliance with the effluent limitation." In addition, based on our review of your calculation worksheet, it appears that the effluent limitation for acrylonitrile should be 43.8 ug/L (rather Ibs/day), with no monthly average limitation. 3. Groundwater Extraction Monitoring and Reporting. As you know, Ticona proposes to eliminate its current dedicated sequencing batch reactor wastewater treatment system used to treat extracted groundwater pursuant to the facility's CERCLA Record of Decision ("the ROD") and to redirect that stream to the facility's primary wastewater treatment plant. There is no reason to believe that the wastewater treatment system will have any problem treating this additional stream or continuing to meet its permit limits. The constituents found in the extracted groundwater are generally very similar to those being treated in the facility's process wastewater. You have indicated to Mr. Levitas and to our environmental consultant, Jerry Kubal of Kubal-Furr & Associates, that DWQ would like to receive that data we currently generate on the quality of the extracted groundwater to be treated. We are happy to provide that data to DWQ. However, special condition I.A.5. included in the draft permit to address this issue, which is entitled "Groundwater Treatment and Reporting Condition" is both ambiguous as to exactly what data is required to be collected and reported and presents a problem as to the proposed reporting format and frequency. As Mr. Levitas explained, we currently sample the influent from the nine, so-called "inner tier" groundwater extraction wells and analye for TOC, VOC's and ethylene glycol on a quarterly basis. These extraction wells are part of what is referred to under the ROD as "Operable Unit 1" or "OU-1." We report our results, along with other groundwater monitoring data associated with OU-1, to U.S. EPA Region IV ("EPA") and the North Carolina Division of Waste Management Superfund Section ("DWM") on a semi-annual basis. (The lag time between sampling and reporting allows us to perform important quality assurance/quality control review of the data.) We have obtained approval from EPA and DWM to suspend operation of the OU-1 groundwater pump -and -treat system for several years in order to evaluate the efficacy of We have obtained approval from EPA and DWM to suspend operation of the OU-1 groundwater pump -and -treat system for several years in order to evaluate the efficacy of monitored natural attenuation. During the evaluation period we will not be extracting and treating groundwater. We therefore propose to provide DWQ with copies of our semi-annual reports only for those periods when the pump -and -treat system is in operation. Accordingly, we would propose to modify Condition I.A.S. to read as follows: rmittee shall submit to the Division a copy of its Semi -Annual Reports on Operable Unit 1 same time that it submits such reports to U.S. EPA Region IV and the North Carolina vision of Waste Management. The Permittee shall not be required to submit a Semi -Annual Report to the Division for any period in which there was no flow of groundwater from Operable Unit 1 to the wastewater treatment plant. The Permittee shall maintain the sequencing batch reactor treatment system previously used to treat extracted groundwater in an idled, but standby, mode such that it can be employed in the event the groundwater has an adverse impact on the activated sludge treatment system." If you have any questions concerning these requested modifications to the draft permit, please give me a call (704-480-4900) or Mr. Levitas (919-420-1707). We appreciate your willingness to entertain these comments and would also appreciate the opportunity to review a revised draft of the permit before it is finalized. Thanks very much for your assistance. We look forward to hearing from you. incerely yours, PEM Carter cc: Steve Levitas — Kilpatrick & Stockton Jerry Kubal — Kubal-Furr & Associates comments on NC0004952, CNA Holdings - Ticona Subject: comme s on NC0004952, CNA Holdings - Ticona From: Hyatt.Mars amail.epa.gov Date: Mon, 23 Feb 2004 08:19:03 -0500 To: mark.mcintire(a ncmail.net hope these are useful. will you be able to respond by March 3? thanks Marshall V In Item I.A., shouldn't "total suspended residue" be "total suspended solids"? 2. he fact sheet indicates that the Item I.A.2 limits have been usted due to production, but no sample calculation was provided. It's not clear how the limits were derived and differ from those in the previous permit and how production was evaluated to reach this conclusion. Is it possible to provide info re how production was evaluated and a sample calculation for a single parameter so I can see what You did? In Item I.A.2, the parameters benzo(a)anthracene, 3,4-benzofluoranthene, benzo(k)fluoranthene, benzo(a)pyrene, chrysene, and hexachlorobenzene do not have monthly avg permit limits. Why not? Subpart I for these parameters does require monthly average limits and the previous permit did have monthly average limits. 1 of 1 3/5/2004 2:18 PM Cleveland County The City of Kings Mountain has applied for renewal the NPDES permit for its Pilot Creek WWTP (NC0020737). The facility is permitted to discharge up to 6.0 MGD of treated domestic wastewater into Buffalo Creek, a class C stream in the Broad River Basin. Currently ammonia -nitrogen and cadmium are water quality limited. This discharge may impact future allocation of the resource. The City of Shelby has applied for renewal of NPDES permit for its wastewater treatment facility (NC0024538). This facility is permitted to discharge a maximum of 6.0 MGD of treated domestic wasteater to the First Broad River, a class C water in the Broad River Basin. Currently ammonia -nitrogen, cyanide, and nickel are water quality limited. This discharge may impact future allocation of this resource. CNA Holdings, Inc. has applied for renewal of its NPDES permit for the Ticona Facility (NC0004952) in Shelby, NC, Cleveland County, discharging a maximum of.0.8 MGD of treated domestic and industrial wastewater to Buffalo Creek, a class C water in the Broad River Basin. No parameters are water quality limited, however this discharge may impact future allocation of this aquatic resource. Wednesday, February 04, 2004 1617 Mail Service Center, Raliegh, North Carolina 27699-1617 - Telephone 919-755-5083 FAX 919-753-0719 An Equal Opportunity Affirmative Action Employer - 50% Recycled / 10% post -consumer paper 4/15/2004 NCDENR/DWQ FACT SHEET ADDENDUM FOR NPDES PERMIT DEVELOPMENT CNA Holdings, Inc. Ticona Facility NPDES Permit Number NC0004952 PROPOSED CHANGES FROM ORIGINAL DRAFT Based on comments received from US EPA Region IV and the permit holder, the draft permit has been modified with the content of those modifications described herein. US EPA Comments (DWQ response in bold): • In Item I.A. 1, total suspended residue should read total suspend solids. Wording changed accordingly. • Guideline calculations were not attached to the original fact sheet. US EPA cannot approve the draft permit without such calculations. Calculations were provided to US EPA. They had no further comment upon review. • A number of parameters listed in Item I.A.2 do not have monthly average limits. Why not? Changes to either federal water quality criteria, state standards, or effluent guideline values yielded water quality based limits for those parameters (benzo(a)anthracene, 3,4-benzofluoranthene, benzo(k)fluoranthene, benzo(a)pyrene, chrysene, and hexachlorobenzene). The daily maximum water quality based effluent limitations are more stringent than the monthly average limitation. As such, no monthly average limit is necessary. Facility Comments (DWQ response in bold): • The facility requests a compliance schedule for the new effluent monitoring and compliance location for pH. A 24 month compliance schedule has been included in the revised draft. Effective May 1, 2006, effluent pH shall be defined as pH from the final effluent. • The facility requested clarification of compliance with parameters where the method detection level is greater than the effluent limitation. A footnote was included to indicate that, in such cases, values reported as less than the detection level shall constitute compliance with the effluent limitation. • The facility indicated that it appeared acrylonitrile should be limited as a daily maximum concentration only. As opposed to the other parameters where a daily maximum water quality based limit is more stringent than the corresponding monthly average effluent guideline limit, the water quality based daily maximum concentration for acrylonitrile is less stringent than the monthly average effluent guideline limit. As such, the federal guidelines mandate inclusion of the water quality based daily maximum and the effluent guideline based monthly average. • The facility requested clarification of the groundwater reporting condition. The groundwater reporting condition has been clarified in accordance with the facility's request. Item numbers in the permit have been updated to include the addition of a new item to accommodate the pH location compliance schedule. 1/30/2004 NCDENR/DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT CNA Holdings, Inc. Ticona Facility NPDES Permit Number NC0004952 .:.. ... - ., --:i ,_v.. :i »� ..M._ •_-�,'y...*. y*.. IN1 ' f 0o 'Ft t .- 7_M .-. ,tea- .yam.`x s •y' (1.) Facility Name: CNA Holdings, Inc. — Ticona Facility 2. Permitted Flow MGD : (3.) Facility Class: 0.8 j j6.1.Couny.: Cleveland III I (7.) Regional Office: Mooresville (4.) Pretreatment Program: NA (8.) USGS Topo Quad: G12NE (5.) Permit Status: Renewal (9.) USGS Quad Name: I Blacksburg North 0... —It. :�� -: uq`li :' e 'Fa7;a�� •w';1,r3.."2 . w .. Buffalo Creek .: ..e.,afHoi•.•1 ' ,.,x1Y srs:.a�itaL (7.) Drainage Area (mi2): ; 154 (2.) Sub -basin: 03-08-05 (8.) Summer 7Q10 (cfs): ! 20 (3.) Stream Index Number: (9.) Winter 7Q10 (cfs): i 46 (4.) Stream Classification: C (10.) 30Q2 (cfs): } NA I5.) 303(d) Status: Not Listed (11.9 Average Flow (cfs): 216 (6.) 305(b) Status: Supporting (12.) IWC %: 5.8% 1.0 PROPOSED CHANGES • Effluent limitations for BOD, TSS, and Subpart I parameters have been modified to reflect actual production for the previous three years. • Effluent limitations and monitoring requirements for TSS and pH will be implemented at the final effluent from the polishing ponds with this renewal. This is consistent with federal guidelines and recently issued permits that have addressed alternate compliance points for said parameters. • A special condition has been added to the permit requiring the facility to submit groundwater data collected in accordance with CERCLA requirements as the groundwater remediation system will be idled. All pumped groundwater will be treated in the activated sludge facility. 2.0 BACKGROUND This is a permit renewal for a major industrial wastewater treatment facility with a current facility design and permitted flow of 0.8 MGD with a discharge to Buffalo Creek in the Broad River Basin. Buffalo Creek was a 303(d) listed stream on North Carolina's 1998 impaired streams list. This listing was the result of a Fair bioclassification resulting from macroinvertebrate data collected in 1990. Resampled in 2000, Buffalo Creek received a Good bioclassification and was therefore delisted in 2002. That being said, Buffalo Creek still exhibits water quality and habitat impacts associated with agriculture and clear lands. NPDES Permit Fact Sheet - January 29, 2004 CNA Holdings, Inc - Ticona Facility Page 2 NC0004952 3.0 FACILITY INFORMATION The subject facility manufactures thermoplastic resins and then extrudes a portion of those resins into synthetic fibers. As such, 40 CFR 414.30 and 414.40 are applicable. Information regarding guideline load allocations is presented in the Permit Development portion of this document. In addition to manufacturing operations, this facility has operated a pump -and -treat groundwater remediation facility regulated by North Carolina's Superfund program for some time. On Thursday, January 22, 2004, the writer met with Dave Mattison with North Carolina's Hazardous Waste program, Ken Lucas with USA EPA Region 4, and Jerry Kubal, the hazardous waste consultant for the Ticona Facility to discuss CNA Holding's proposal to idle the pump - and -treat system, thus directing pumped groundwater to the headworks of the activated sludge treatment system. It was agreed that with this renewal, the NPDES permit would reflect such operation and require the facility to submit CERCLA related groundwater data to the Division of Water Quality with it's monthly discharge monitoring reports (DMRs). This facility's compliance history was reviewed for the previous permit period. The facility appears to be operated well and has little difficulty meeting effluent limitations. The facility had two chronic toxicity test failures during that timeframe. The failures occurred in December of 1999 and 2000 and were each followed up immediately with a pass. 4.0 PERMIT DEVELOPMENT • Effluent Limitations: limitations for BOD, TSS, and Subpart I parameters have been updated using appropriate process wastewater flow information and the appropriate federal effluent guidelines (see attached spreadsheet). • TSS and pH compliance point: the previous permit incorrectly established a compliance point for TSS and pH between the secondary clarifiers and the polishing ponds. These polishing ponds are part of the treatment system. As such, compliance with limitations for solids and pH should be judged at a point downstream of them. The permit has been updated accordingly. • Groundwater Special Condition: a special condition has been added requiring the facility to submit CERCLA data for groundwater. Furthermore, the condition requires the facility to reinstate use of the idled pump -and -treat system in the event the groundwater causes problems in the activated sludge system. 5.0 PROPOSED SCHEDULE FOR PERMIT ISSUANCE Draft Permit to Public Notice: February 11, 2004 Permit Scheduled to Issue: March 29, 2004 6.0 STATE CONTACT If you have any questions on any of the above information or on the attached permit, please contact Mark McIntire at (919) 733-5083, extension 508. NPDES Permit Fact Sheet — January 29, 2004 CNA Holdings, Inc — Ticona Facility Page 3 NC0004952 Copies of the following are attached to provide further information on the permit development: • Limit calculations • Permit application • Draft Permit NPDES RECOMMENDATION BY: REGIONAL OFFICE COMMENTS: REGIONAL RECOMMENDATION BY: 1 wil‘ , Signature 1/7-1/7 Date Signature Date CNA Holdings, Inc. NC0004952 Average Flow for 2001- 2003: 0.445 MGD Information provided by CNA with this permit renewal indicates that of the flow discharged through outfall outfall 001, approximately 71.4% is process wastewater. Of the process wastewater, approximately 0.215 MGD is attributable to 414 Subpart C manufacturing with the remaining 0.103 attributable to Subpart D. Subpart C flow: Subpart D flow: Domestic flow: 0.215 MGD 0.103 MGD 0.0605 MGD 40 CFR 414.31 (Subpart C - All units are mg/L) Daily Max I Mon. Avg. BOD5 TSS 48 115 18 36 40 CFR 414.41 (Subpart D - All units are mg/L) Daily Max I Mon. Avg. BOD5 TSS 64 130 24 40 Subpart C Allocation - lbs/day Daily Max BODS TSS 86.1 206.2 Mon. Avg. 32.3 64.6 Subpart D Allocation - lbs/day Daily Max Mon. Avg. BODS TSS 55.0 98.8 20.6 34.4 The Difference between the average flow and the sum of the flows to left are attributed to water treatment blowdown and NCCW. Domestic Allocation (Q = 60,500 gpd) - Assuming secondary limits - lbs/day Daily Max BOD5 TSS 22.7 22.7 Mon. Avg. 15.1 15.1 Total Allocation (Sum of C, D, and Domestic) - lbs/day Daily Max Mon. Avg. BOD5 TSS 164 328 68 114 Mark McIntire 1/29/2004 FACILITY CNA Holdings. Inc. - Troona Facility OCPSF Flow 0.318 MGD Outfati 001: flow is based on processes only 7010s 20 da Oavg 216 ds Permitted Floes 0.8 MGD Human Filth Human lath Allowable Allowable Limit Limit Federal or Standard Standard Ailowabte Allowable Aquatic Life Human Htth Limit Daily Monthly Daffy Monthly Daily Monthly State Aquatic Organisms conc. Aquatic cone Organisms Basod Max Avg. max nog MAX ovg Life Life Organisms on: Parameter ug/1 ugA #/d #/d atdrd pgll Pg/I PO pgA #/day #/day #/day Acenaphthene 59 22 0.156 0.058 Federal no stdrd 990.00 no stdrd 16957.74 no stdrd 113.052 OCPSF 0.156 #/day 0.058 Aconaphthyleno 59 22 0.156 0.058 Federal no stdrd no stdrd no stdrd no stdrd no stdnt no stdrd OCPSF 0.156 #/day 0.058 Aciylonll►ile (c) 242 98 0.642 0.255 Fodoral no stdrd 0.25 no stdrd 43.80 no stdrd 0.292 CHRONIC 43.798 pg/I 0.255 Anthmcene 59 22 0.156 0.058 Federal no stdrd 40300.00 no stdrd 685161.29 no stdrd 4567.742 OCPSF 0.156 #/day 0.058 Bonzone (c) 136 37 0.361 0.098 State no stdrd 71.40 no stdrd 12508.82 no stdrd 83.392 OCPSF 0.361 #/day 0.098 Benzo(a)anthraeene (c. Pr 59 22 0.156 0.058 Federal no stdrd 0.018 no atdrd 3.15 no stdrd 0.021 CHRONIC 3.153 {rg/I 3,4 Benzafluorarrthono (c. 61 23 0.162 0.061 Federal no stdrd 0.0311 no stdrd 5.45 no stdrd 0.036 CHRONIC 5.449 )rg/I Benzo(k)lluorentheno (c.P 59 22 0.156 0.058 Federal no stdrd 0.0180 no stdrd 3.15 no stdrd 0.021 CHRONIC 3.153 Ihg/I Benzo(a)pyrene (c, PAH) 61 23 0.162 0.061 Fedora! no stdrd 0.0311 no stdrd 5.45 no stdrd 0.036 CHRONIC 5.449 pg/I Bis(2-ethylhexyl) phthalate 279 103 0.740 0.273 Federal no stdrd 2.20 no stdrd 385.43 no stdrd 2.570 OCPSF 0.740 #/day 0.273 Carbon Tetraehbdde (c) 38 18 0.101 0.048 State no stdrd 4.42 no stdrd 774.36 no atdrd 5.162 OCPSF 0.101 #/day 0.048 Chlorobenzene 28 15 0.074 0.040 Federal no stdrd 21000.00 no stdrd 359709.68 no stdrd 2398.065 OCPSF 0.074 #/day 0.040 Chbroethane 268 104 0.711 0276 Federal no stdrd no atdrd no atdrd no stdrd no stdrd no atdrd OCPSF 0.711 #/day 0.276 Chloroform (c) 46 21 0.122 0.056 Federal no stdrd 470.00 no stdrd 82340.97 no stdrd 548.940 OCPSF 0.122 #/doy 0.056 2-Chlorophonol 98 31 0.260 0.082 Federal no stdrd 150.00 no stdrd #REFI no stdrd #REFI #REFI #REFI #REFI #REFI Chrysene (c, PAH) 59 22 0.156 0.058 Federal no stdrd 0.0180 no stdrd 3.15 no stdrd 0.021 CHRONIC 3.153 pg/1 OM -butyl phthalate 57 27 0.151 0.072 Federal no stdrd no atdrd no stdrd no stdrd no stdrd no stdrd OCPSF 0.151 #/day 0.072 1.2-Dlchbrobenzono 163 77 0.432 0.204 Federal no stdrd 17000.00 no stdrd 291193.55 no stdrd 1941.290 OCPSF 0.432 #/day 0.204 1.3-Dichlorobenzeno 44 31 0.117 0.082 Fedora! no stdrd 960.00 no stdrd 16443.87 no stdrd 109.626 OCPSF 0.117 #/doy 0.082 1.4-Dichlorobenzeno 28 15 0.074 0.040 Federal no stdrd 2600.00 no stdrd 44535.48 no stdrd 296.903 OCPSF 0.074 #/day 0.040 1,1-Dichloroelhane (c) 59 22 0.156 0.058 Federal no atdrd : no stdrd no stdrd no stdrd no stdrd no stdrd OCPSF 0.156 #/day 0.058 12.Didsbroethane (c) 211 68 0.560 0.180 Federal no stdrd 3.70 no stdrd 648.22 no stdrd 4.321 OCPSF 0.560 #/day 0.180 1,1-Dichloroethylene (c) 25 16 0.066 0.042 Federal no stdrd 3.20 no stdrd 560.62 no stdrd 3.737 OCPSF 0.066 #/day 0.042 1.2-trans-Dichbroethylene 54 21 0.143 0.056 Federal no stdrd 140000.00 no stdrd 2398064.52 no stdrd 15987.097 OCPSF 0.143 II/day 0.056 2,4.Dichlorophenol 112 39 0.297 0.103 Federal no stdrd 290.00 no stdrd #REFI no stdrd #REFI *REF! #REFI #REFI #REFI 1,2•Dichbropropane 230 153 0.610 0.406 Federal no stdrd 15.00 no stdrd 256.94 no stdrd 1.713 OCPSF 0.610 #/day 0.406 1,3-Dichbropropylene (c) 44 29 0.117 0.077 Federal no stdrd 1700.00 no stdrd 297829.03 no stdrd 1985.527 OCPSF 0.117 #/day 0.077 Diothyl phthalate 203 81 0.538 0.215 Federal no stdrd 44000.00 no stdrd 753677.42 no stdrd 5024.516 OCPSF 0.538 #/day 0.215 2.4-Dimoth ylph cool 36 18 0.095 0.048 Federal no stdrd 850.00 no stdrd 14559.68 no stdrd 97.065 OCPSF 0.095 #/day 0.048 Dimothyl phthatato 47 19 0.125 0.050 Federal no stdrd 1100000.00 no stdrd 18841935.48 no atdrd 125612.903 OCPSF 0.125 #/day 0.050 4,6-Dlnitro-o-cresol (2-Met 277 78 0.735 0.207 Federal no stdrd 280.00 no stdrd 4798.13 no stdrd 31.974 OCPSF 0.735 #/day 0.207 2,4•Dinitrophenol 123 71 0.326 0.188 Federal no stdrd 5300.00 no sldrd 80783.87 no atdrd 605.226 OCPSF 0.326 #/day 0.188 2.4-Dinitrotoluene (c) 285 113 0.756 0.300 Federal no stdrd 3.40 no stdrd #REFI no stdrd #REF! #REFI #REFI #REFI #REFI 2.6-Disitrototuone (c) 641 255 1.700 0.676 Federal no stdrd no stdrd no stdrd no stdrd no stdrd no stdrd OCPSF 1.700 #/day 0.676 Ethylbenzene 108 32 0.286 0.085 AQINOEC 325.000 29000.00 5566.94 496741.94 37.113 3311.613 OCPSF 0.286 8/day 0.085 Flourenthene 68 25 0.180 0.066 Federal no stdrd 140.00 no stdrd 2398.06 no stdrd 15.987 OCPSF 0.180 #/day 0.066 Moreno 59 22 0.156 0.058 Fedora) no stdrd 5300.00 no stdrd 90783.87 no stdrd 605.226 OCPSF 0.156 #/day 0.058 Hexachbrobenzene (c) 28 15 0.074 0.040 Federal no stdrd 2.90E-04 no stdrd 0.05 no stdrd 3.39E-04 CHRONIC 0.051 pg/1 Hoxachbrobutadtono (c) 49 20 0.130 0.053 Federal no stdrd 18.00 no atdrd 3153.48 no stdrd 21.023 OCPSF 0.130 #/day 0.053 Hexachbroethane (c) 54 21 0.143 0.056 Federal no stdrd 3.30 no atdrd 578.14 no stdrd 3.854 OCPSF 0.143 #/day 0.056 Mothyl Chloride 190 86 0.504 0.228 Fedora) no stdrd no stdrd no atdrd no stdrd no stdrd no stdrd OCPSF 0.504 #/day 0.228 Methylene Chloride (c) 89 40 0.236 0.106 Federal no stdrd 590.00 no stdrd 103364.19 no stdrd 689.095 OCPSF 0.236 #/day 0.106 Naphthalene 59 22 0.156 0.058 Federal no stdrd no atdrd no stdrd no stdrd no stdrd no stdrd OCPSF 0.156 #/day 0.058 Nitrobenzene 68 27 0.180 0.072 Federal no stdrd 690.00 no stdrd 11819.03 no stdrd 78.794 OCPSF 0.180 #/day 0.072 2-Nitrophonot 69 41 0.183 0.109 Federal no stdrd no atdrd no stdrd no stdrd no stdrd no stdrd OCPSF 0.183 #/day 0.109 4-Nitrophenol 124 72 0.329 0.191 Federal no stdrd no atdrd no stdrd no stdrd no stdrd no stdrd OCPSF 0.329 #/day 0.191 Phonanthrone 59 22 0.156 0.058 Federal no stdrd no stdrd no stdrd no stdrd no stdrd no stdrd OCPSF 0.156 #/day 0.058 Phenol 26 15 0.069 0.040 Federal no stdrd 1700000.00 no stdrd 29119354.84 no stdrd 194129.032 OCPSF 0.069 #/day 0.040 Pyrone 67 25 0.178 0.066 Federal no atdrd 4000.00 no atdrd 68516.13 no stdrd 456.774 OCPSF 0.178 0/day 0.066 Totrachloroethyleno (c) 56 22 0.149 0.058 Federal no stdrd 3.30 no atdrd 578.14 no stdrd 3.854 OCPSF 0.149 #/day 0.058 Toluene 80 26 0.212 0.069 State/AO 11.000 200000.00 188.42 3425806.45 1256 22838.710 OCPSF 0.212 8/day 0.069 1.2,4•Tdchbrobenzene 140 68 0.371 0.180 Federal no stdrd 940.00 no stdrd 16101.29 no stdrd 107.342 OCPSF 0.371 #/day 0.180 1.1,1•Trichbroethane 54 21 0.143 0.056 Federal no stdrd no stdrd no stdrd no stdrd no stdrd no stdrd OCPSF 0.143 #/doy 0.056 1,12•tridrbroethane (c) 54 21 0.143 0.056 Federal no stdrd 16.00 mo atdrd 2803.10 no stdrd 18.687 OCPSF 0.143 #/day 0.056 Trichlormethylene (c) 54 21 0.143 0.056 State no stdrd 30.00 no stdrd 5255.81 no stdrd 35.039 OCPSF 0.143 0/Cloy 0.056 Yslyl Chloride (c) 268 104 • 0.711 0276 State no stdrd 530.00 no stdrd 92852.58 no stdrd 619.017 OCPSF 0.711 11/day 0.276 Total Chromium 2770 1110 0.000 0.000 State 50.000 no stdrd 856.45 no stdrd 5.710 no stdrd OCPSF 0.000 #/day 0.000 " Total Copper 3380 1450 0.000 0.000 Action level 7.000 no stdrd 119.90 no stdrd 0.799 no stdrd OCPSF 0.000 #/day 0.000 " Total Cyanide 1200 420 0.000 0.000 State 5.000 no stdrd 85.65 no stdrd 0.571 no stdrd OCPSF 0.000 #/day 0.000 "Total Lead 690 320 0.000 0.000 Stale 25.000 no stdrd 428.23 no stdrd 2.855 no stdrd OCPSF 0.000 #/day 0.000 " Total Nickol 3980 1690 0.000 0.000 State 88.000 no stdrd 1507.35 no stdrd 10.049 no stdrd OCPSF 0.000 #/day 0.000 "Total Tic' 2610 1050 0.000 0.000 Action level 50.000 50.00 856.45 856.45 5.710 5.710 OCPSF 0.000 #/day 0.000 'Total Zinc for Rayon Fiber Manufacuro •' Metals should only be limited 11 Total metal bearing wastetlov 0.00 that uses the viscose process and Acrylic process contains metal bearing wastellow. Fbor Manufacture that uses zinc Cyanide should only be United 8 Total cyanide bearing waslef 0.00 chloride/advent process Is 6,796 ugrL and process contains cyanide bearing wasteflow. 3.325 ug/L tor maximum for any one day and maximum for monthly average, rospoctivoy. 1/29/2004 1 SOC PRIORITY PROJECT: Yes No If Yes, SOC No. To: Permits and Engineering Unit Water Quality Section Attention: Valery Stephens Date: October 9, 2003 NPDES STAFF REPORT AND RECOMMENDATION County: Cleveland Permit No. NC0004952 MRO No.: 03-14 PART I - GENERAL INFORMATION 1. Facility and address: CNA Holdings, Inc. P.O. Box 87 Shelby, N.C. 28151 L. OCT 1 3 2003 L' - WATER QUALITY r)i ,r Sc,; : E BRANCH 2. Date of investigation: September 24, 2003 3. Report prepared by: Samar Bou-Ghazale, Environmental Eng. I 4. Persons contacted and telephone number: Ms. Pem Carter, Environmental Engineer with CNA Holding; Tel # 704/434-2261 Ext.411. 5. Directions to site: From the intersection of I-85 and I-77 travel south on I-85. Approximately 5 miles after crossing into South Carolina, exit at Highway 198. Travel north on Highway 198 approximately 5 miles. The facility is located on the right. 6. Discharge Point(s). List for all discharge points: Latitude: 35 ° 11'14" Longitude: 81 ° 30' 35" Attach a U.S.G.S. map extract and indicate treatment facility site and discharge point on map. U.S.G.S. Quad No.: G 12 NE U.S.G.S. Name: Blacksburg North, N.C. 7. Site size and expansion area are consistent with application? Yes x No_ If No, explain: 1 8. Topography (relationship to flood plain included): Slopes range from 2 to 3 %. The WWTP is not located in a flood plain. 9. Location of nearest dwelling: None within 500 feet. 10. Receiving stream or affected surface waters: Buffalo Creek. a. Classification: C b. River Basin and Subbasin No.: BRD05 c. Describe receiving stream features and pertinent downstream uses: Buffalo Creek appears to have uses consistent with Class C waters. PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS 1. a. Volume of wastewater to be permitted: 0.8 MGD (Ultimate Design Capacity) b. What is the current permitted capacity of the wastewater treatment facility? 0.8 MGD c. Actual treatment capacity of the current facility (current design capacity)? 0.8 MGD d. Date(s) and construction activities allowed by previous Authorizations to Construct issued in the previous two years: N/A e. Please provide a description of existing or substantially constructed wastewater treatment facilities: The existing WW1' facilities consist of screening with a grit chamber, a comminutor (for the domestic waste stream), three (3) equalization lagoons, and a 500,000 gallon storage tank. At this point the domestic and industrial flows combine for additional treatment (consisting of dual aeration basins with disinfection, polymer addition system and dual clarifiers, dual media tertiary treatment system followed by UV disinfection, three (3) aerated polishing ponds with chemical addition for foam/algae control, an aerated sludge digesting basin, and two sludge storage ponds). Also, there are two groundwater remediation systems that discharge to polishing pond "A": 1) the WWTP for treating contaminated discharge from the "inner tier wells" consists of an eq>>ali7ation tank, an inclined plate clarifier, and a sequencing batch reactor, air stripping and carbon filtration. 2) The other system for the "outer tier wells"consists of air stripping and carbon filtration. f. Please provide a description of proposed wastewater treatment facilities: N/A g• Possible toxic impacts to surface waters: Process waters, contact cooling water, and ethylene glycol from the gorundwater remediation systems could have toxic impacts. Also, the algicides and other chemical additions could have toxic impacts. 2 h. Pretreatment Program (POTWs only): N/A 2. Residuals handling and utilization/disposal scheme: a. If residuals are being land applied, please specify DWQ permit no.: WQ0011038 Residuals Contractors: 1) Sludge generated by WWTP is contracted to Synogro for disposal. 2) Sludge generated by the ground water remediation facilities is disposed by Onyx Environmental (EPA ID# NCD986166338). b. Residuals stabilization: PSRP 3. Treatment plant classification (attach completed rating sheet): Class IV 4. SIC Code(s): 3079 Primary: 36 Secondary: 02 Main Treatment Unit Code: 05203 PART III - OTHER PERTINENT INFORMATION 1. Is this facility being constructed with Construction Grant Funds or are any public monies involved (municipals only)? N/A 2. Special monitoring or limitations (including toxicity) requests: None at this time. 3. Important SOC, JOC or Compliance Schedule dates: (please indicate) N/A 4. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge options available. Please provide regional perspective for each option evaluated. N/A 5. Air Quality and/or Groundwater concerns or hazardous materials utilized at this facility that may impact water quality, air quality, or groundwater: No AQ or hazardous material concerns. Two ground water remediation systems exist at the facility. 6. Other Special Items: The ground water remediation system for the "outer tier wells" is inactive at this time; However, the permittee would like to keep the system permitted for possible future use. PART IV - EVALUATION AND RECOMMENDATIONS The Permittee, CNA Holdings, Inc., has applied for permit renewal for the discharge of treated wastewater at its Shelby Plant. The permittee proposes to direct the stormwater "first flush" through the wastewater treatment facility and requests that this activity be included in the permit. This office recommends that the stormwater process be approved as proposed provided that the 3 permitted flow/limits will not be exceeded. The permittee is also requesting that the permit allow pH measurements for outfall 001 to be made between the final clarifiers and final finishing pond claiming that a high pH is a natural occurrence in all types of ponds and lagoons throughout the region. It is our understanding that the pH limits established by the federal guidelines must be applied at the effluent (see cover letter for permit No. NC0004944, dated January 17, 2000, issued to Kosa- Salisbury Plant, as an example of a similar request that was denied). Based on the above the request made by the company for pH measurements between the final clarifiers and the final finishing pond should be denied. The company will also continue to use biocides in the cooling towers at the facility. A biocidal sheet needs to be submitted by the company for approval by the Toxicology Unit prior to issuing this permit. Pending review and approval by P&E, It is recommended the subject permit be renewed with the above mentioned changes. Signature of Repo • "parer �! /2 Water Quality R ional Supervisor DateVP_.? 4 CERTIFIED MAIL 7001 1140 0002 8843 4445 Return Receipt to PEM Carter February 26, 2003 Mrs. Valery Stephens NC DENR/Water Quality/Point Source Branch 1617 Mail Service Center Raleigh, NC 27699 — 1617 Reference: NPDES Permit Renewal Number NC0004952 CNA Holdings, Inc. — Ticona Facility Cleveland County Dear Mrs. Stephens: Ticona Ticona Shelby Plant Highway 198 Shelby, NC 28152 Telephone (704) 480-4700 This letter is written to request the renewal of the above referenced NPDES permit, per the requirements of your letter dated January 3, 2003. Also enclosed are the necessary materials for this permit renewal: (a) Completed application form , signed and submitted in triplicate (b) Supporting analysis per the requirements of the renewal process from both outside contract laboratory and in-house certified laboratory, submitted in triplicate. (c) A narrative description of the sludge management plan, submitted in triplicate. As you and your staff prepare the renewed permit for the facility, there are several items that CNA Holdings, Inc. — Ticona Facility respectfully requests considering: CNA Holdings, Inc — Ticona Facility has revised the submitted water balance diagram to reflect "first flush" stormwaters and those rainwaters having come in contact with industrial activities which no longer meeting the definition of stormwater, to be permitted for treatment through the existing waste water facility. The treatment of these waters would be the most environmentally sound approach benefiting all parties involved and we request this to be added to our permit. It has been historically documented that the polishing ponds being used at the facility exhibit a large algae bloom, especially during the warm summer months. This is not a source specific occurrence; it is a natural occurrence in all types of ponds and lagoons throughout the region. While this is a naturally occurring phenomenon, it also has a direct impact on the water discharging from the pond. Specifically, the pH of the discharge stream is elevated. Instead of artificially controlling the discharge pH through the introduction of additional chemicals, the current permit contains a clause allowing pH measurements for Outfall 001 to be made between the final clarifiers and the final finishing pond (Section A. (1) Effluent Limitations and Monitoring Requirements: Note 4). This is a clause that allows Ticona to continue to operate in a manner consistent with the most environmentally sound management systems, while minimizing the interference Celanese with the natural life cycles of the surrounding areas. This is a condition that benefits all parties involved, and should be retained in the permit renewal. An additional effect of this alga growth is the additional Total Suspended Solids (TSS) loading. Although Ticona believes that the natural biological processes occurring in the polishing ponds should not be inhibited, we do realize during the summer months it maybe necessary to use a biocide in conjunction with the tertiary filtration system in order to meet the established TSS levels of the existing permit. In addition, Ticona will continue to operate all cooling tower water with biocides. All cooling tower water is combined with, and treated in the same manner as all other waters collected for discharge through Outfall 001. Ticona has quantified which wastewater streams are subject to the categorical standards for Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) Subparts. Based upon the water balance diagram submitted with this permit renewal package, the streams subject to the OCPSF regulations with respect to manufacturing processes are delineated as follows: Process Water Stream SIC Code 2824 Percent of Flow Subpart C Volume of Flow (GPD) SIC Code 2821 Percent of Flow Subpart D Volume of Flow (GPD) Misc. Process Waters `� Process Cooling Water " 80% 0% 25% 100% 100% 102,800 0 10,000 27,000 75,000 20% 100% 75% 0% 0% 25,700 47,000 30,000 0 0 CT Make Spin Finish- -_ Groundwater ', CNA Holdings, Inc. — Ticona Facility request the permit to reflect our name, which changed as of July 31, 1999. We appreciate your time and cooperation in working with us so that we may develop a permit that accomplishes the needs and goals of both the Division of Water Quality and our facility. Should you have any questions pertaining to the any material contained in this permit renewal application, please do not hesitate to contact me at 704/480-4900 or by e-mail, nem.carter(a�ticona.com. Sincerely, PEM Carter Environmental Engineer Ticona Facility RAW WATER INTAKE FROM BUFFALO CREEK 900,000 GPD WATER TREATMENT SYSTEM CNA HOLDINGS, INC • TICONA SHELBY PLANT WATER BALANCE DIAGRAM AVERAGE FLOWS 0 a ca Q O O in CLARIFIER BLOW -DOWN 0 a c> 0 0 N 0 BOILER WATER MAKE- UP / BLOW - DOWN 0 a c, 0 0 0 OD 0 v 147,000 GPD 0 a oL.OSS o , an 00 MISC PROCESS WATERS L & K OPEN SUMPS CHILL WATER SYSTEM K TT CHILL WATER SUMP WASTE TREATMENT WASH DOWN PROCESS WATER 153,000 GPD 0 a CD 0 0 0 00 0 mr. CONTACT PROCESS COOLING WATER 128,500 GPD lir 47,000 GPO —0.1 COOLING oa TOWER c> MAKE-UP/ o BLOWDOWN o & FIRE LAGOON 0 0- CD 0 0 O lS ) M KOSA SPIN FINISH 0 a c9 0 I. OS 0 Aco 0 V a c7 0 0 0 CLEVELAND COUNTY SANITARY DISTRICT 0 a cD 0 0 Ill e0 POTABLE WATER CONSUMED IN PRODUCT 40,000 GPD 0 a 0 O 0 N 0- CD 0 0 In O (0 GROUND- WATER TREATMENT SYSTEM 100,000 GPD RECYCLE TO PLANT r 450,000 GPO - 450,000 GPO. DISCHARGE 001 DRY WEATHER WASTEWATER TREATMENT PLANT mil FLOW 150,000 GPD"" WET WEATHER STORMWATER RUN-OFF FROM APPROX.250 ACRES STORM WATER STORMWATER RUN-OFF FROM COLLECTION APPROX. 250 ACRES SYSTEM 's STORM WATER 1ST FLUSH & STORM WATER (FOR WET WEATHER FLOW 600,000 TO 750,000 GPO) ASSOCIATED WITH INDUSTRIAL ACTIVITY h:U08SODD%G1901.001SStow.dgn 02/19/0311:15:47 AM ANY INFRINGENEN E OR IN PART 0 N W 0 0 Z OF 0 4 0 0 O 0 O KW 0 0 i 0W W S 1-� 2 0 VI W Z 0 N X SCALE 1:24 000 0 0 1000 2000 3000 )-i CONTOUR INTERVAL 20 FEET NATIONAL GEODETIC VERTICAL DATUM OF 1929 p 1.6011 REMISE REMISE 10766.00 ZflrY w - 5 EVENS POWELL JUN.1997 GAR LOCATION MAP HOECHST CELANESE SHELBY, NC DAyl FLMT SENGINEERS ARCHITECTS Dc.x...c. . a, .. mWItl PLANNERS SCIENTISTS hill l N.P.D.E.S. PERMIT RENEWAL i TICONA CNA HOLDINGS, INC - TICONA SHELBY PLANT SHELBY, NORTH CAROLINA SECTION 6.0 SLUDGE MANAGEMENT PLAN As required by law, this section contain information pertaining to the sludge management plan for the facility: • All biological sludge generated by the facility's wastewater treatment plant is land applied in accordance with the terms and conditions of the attached Land Application of Sludge residuals Permit # WQ0011038. • All sludge generated by the groundwater treatment system is disposed of off site by Onyx Environmental (EPA ID # NCD986166338) for proper disposal.