NC0004952_Permit (Issuance)_20131005

NPDES DOCIMENT f;CANNINO COVER SHEET
NPDES Permit:
NC0004952
Celanese Shelby Facility
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:
October 5, 2013
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ArA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
October 5, 2013
Ms. Pem Carter
CNA Holdings, LLC
2525 Blacksburg Rd
Grover, NC 28073
Subject: NPDES Final Permit
Permit NC0004952
Cleveland County
Class II Facility
Dear Ms. Carter:
Division personnel have reviewed and approved your application for renewal of the
subject permit. Accordingly, we are forwarding the attached NPDES 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 October 15, 2007 (or as subsequently amended).
The final permit contains the following changes from your previous permit:
• Owner name and facility name were corrected to CNA Holdings LLC and Celanese —
Shelby Plant.
• Permitted flow was reduced to 0.45 MGD based on a decrease in production and
expected production levels. As a result of flow reduction the classification of the
facility changes from Class III to Class II.
• Limits for BOD, TSS and OCPSF parameters were recalculated based on the expected
maximum production flows. Monitoring frequency for BOD and TSS was reduced to
weekly.
• pH monitoring frequency was reduced to weekly.
• The outfall location was corrected on the map.
• Instream turbidity monitoring was removed from the permit.
• Special Condition A. (5) was modified to include a requirement to submit a notification
to the Division in the event a treatment unit is taken off-line.
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
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet www.ncwaterrivality.org
NorthCarolina
Naturally
An Equal Opportunity 1 Affirmative Action Employer

CNA Holdings, LLC
October 5, 2013
Page2of2
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 fmal 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 permits that may be required.
If you have any questions concerning this permit, please contact Teresa Rodriguez at
telephone number [phone] or at email [e-mail].
t
Sincerely,
Thomas A. Reeder
cc: NPDES Files
Central Files
EPA Region 4 (e-copy)
Mooresville Regional Office / Surface Water Protection Section
NPDES, Steve Reid (e-copy)
Aquatic Toxicology Unit (e-copy)

Permit NC0004952
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
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, LLC
is hereby authorized to discharge wastewater and stormwater from a facility located at the
Celanese - Shelby Plant
2525 Blacksburg Road
Grover, North Carolina
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 November 1, 2013.
This permit and the authorization to discharge shall expire at midnight on August 31, 2018.
Signed this day October 4, 2013.
Thomas A. Reeder, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 7

Permit N00004952
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, LLC is hereby authorized to:
1. Continue to operate an existing activated sludge wastewater treatment facility,
operating and limited to 0.45 MGD, located at the Celanese - Shelby Plant,
2525 Blacksburg Rd., Grover, Cleveland County. The facility includes the
following components:
• Bar screen 86 grit chamber;
• Three equalization basins utilizing pH adjustment;
• Emergency equalization tank
• Two aeration basins with chlorine added on an as -needed basis;
• Two secondary clarifiers with polymer addition;
• Dual media tertiary filter;
• 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 above and boiler water make-
up and blowdown, clarifier blowdown, cooling tower make-up and blowdown,
fire lagoon water, and non -process spin -finish, compounding and LCP
wastewaters at the location specified on the attached map through outfall 001
into Buffalo Creek, a class C water in the Broad River Basin.
Page 2 of 7

Permit NC0004952
Part I
A. (1) Effluent Limitations and Monitoring Requirements [001]
Beginning on the effective date of this permit 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 '
0.45 MGD
Continuous
Recording
Effluent
BOD, 5-day, 20°C
68 pounds/day
181 pounds/day
Weekly
Composite
Effluent
Total Suspended Solids
124 pounds/day
395 pounds/day
Weekly
Composite
Effluent
Fecal Coliform
(Geometric Mean)
200 / 100 mL
400 / 100 mL
Weekly
Grab
Effluent
Oil and Grease
Quarterly
Grab
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
> 6.0 and < 9.0 Standard Units
Weekly
Grab
Effluent
40 CFR 414 Subpart I
Monitoring
See Section A (2.)
Notes:
1 Effluent is defined as final effluent from the polishing ponds.
2 Chronic Toxicity (Ceriodaphnia) P/F @ 2.13.%; March, June, September, December [see A. (3)].
3 The priority pollutant analysis shall be conducted during the month prior to submittal of the
permit renewal application [see A. (4)].
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.
Page 3 of 7

Permit NC0004952
A. (2) Effluent Limitations and Monitoring Requirements
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 Characteristic
Daily
Maximum
Monthly
Average
Frequency
Type
Sample
Location
Acenaphthene
0.190
0.071
Annually
Grab
Effluent
Acenaphthylene
0.190
0.071
Annually
Grab
Effluent
Acrylonitrile
72 mg/1
Annually
Grab
Effluent .
Anthracene
2 pg/1
Annually
Grab
Effluent
Benzene
0.439
0.119
Annually
Grab
Effluent
Benzo(a)anthracene
8.96 pg/1
Annually .
Grab
Effluent
3,4-Benzofluoranthene
8.96 Ng/1
Annually
Grab
Effluent
Benzo(k)fluoranthene
8.96 pg/1
Annually
Grab
Effluent
Benzo(a)pyrene
8.96 pg/1
Annually
Grab
Effluent
Bis(2-ethylhexyl) phthalate
0.900
0.332
Annually
Grab
Effluent
Carbon Tetrachloride
0.123
0.058
Annually
Grab
Effluent
Chlorobenzene
0.090
0.048
Annually
Grab
Effluent
Chloroethane
0.865
0.336
Annually
Grab
Effluent
Chloroform
0.148
0.068
Annually
Grab
Effluent
2-Chlorophenol
0.316
0.100
Annually
Grab
Effluent .
Chrysene
8.96 µg/1
Annually
Grab
Effluent
Di-n-butyl phthalate
0.184
0.087
Annually
Grab
Effluent
1,2-Dichlorobenzene
0.526
0.249
Annually
Grab
Effluent
1,3-Dichlorobenzene
0.142
0.100
Annually
Grab
Effluent
1,4-Dichlorobenzene
0.090
0.048
Annually
Grab
Effluent
1,1-Dichloroethane
0.190
0.071
Annually
Grab
Effluent
1,2-Dichloroethane
0.681
0.219
Annually
Grab
Effluent
1,1-Dichloroethylene
0.081
0.052
Annually
Grab
Effluent
1,2-trans-Dichloroethylene
0.174
0.068
Annually
Grab
Effluent
2,4-Dichlorophenol
0.361
0.126
Annually
Grab
Effluent
1,2-Dichloropropane
0.742
0.494
Annually
Grab
Effluent
1,3-Dichloropropylene
0.142
0.094
Annually
Grab
Effluent
Diethyl phthalate
0.655
0.261
Annually
Grab
Effluent
2,4-Dimethylphenol
0.116
0.058
Annually
Grab
Effluent
Dimethyl phthalate
0.152
0.061
Annually
Grab
Effluent
4,6-Dinitro-o-cresol
0.894
0.252
Annually
Grab
Effluent
2,4-Dinitrophenol
0.397
0.229
Annually
Grab
Effluent
2,4-Dinitrotoluene
0.920
0.365
Annually
Grab
Effluent
Page 4 of 7

Permit NC0004952
A. (2) Effluent Limitations and Monitoring Requirements - 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:
PARAMETER
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average'
Daily
Maximum'
Measurement
Frequency
Sample
Type
Sample
Location
2,6-Dinitrotoluene
205 µg/1
Annually
Grab
Effluent
Ethylbenzene
0.349
0.103
Annually
Grab
Effluent
Fluoranthene
5 pg/1
Annually
Grab
Effluent
Fluorene
0.190
0.071
Annually
Grab
Effluent
Hexachlorobenzene
0.08 µg/1
Annually
Grab
Effluent
Hexachlorobutadiene
0.158
0.065
Annually
Grab
Effluent
Hexachloroethane
0.174
0.068
Annually
Grab
Effluent
Methyl Chloride
0.613
0.278
Annually
Grab
Effluent
Methylene Chloride
0.287
0.129
Annually
Grab
Effluent
Naphthalene
0.190
0.071
Annually
Grab
Effluent
Nitrobenzene
0.219
0.087
Annually
Grab
Effluent
2-Nitrophenol
0.223
0.132
Annually
Grab
Effluent
4-Nitrophenol
0.400
0.232
Annually
Grab
Effluent
Phenanthrene
0.190
0.071
Annually
Grab
Effluent
Phenol
0.084
0.048
Annually
Grab
Effluent
Pyrene
0.216
0.081
Annually
Grab
Effluent
Tetrachloroethylene
0.181
0.071
Annually
Grab
Effluent
Toluene
0.258
0.084
Annually
Grab
Effluent
Total Chromium
3.583
2344 µg/1
Annually
Grab
Effluent
Total Copper
328 µg/1
Annually
Grab
Effluent
Total Cyanide
234 µg/1
Annually
Grab
Effluent
Total Lead
2.227
1.033
Annually
Grab
Effluent
Total Nickel
12.846
5.455
Annually
Grab
Effluent
Notes:
1 All units are pounds/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.
A. (3) 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 2.13 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in
the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or
subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised- December 2010) or subsequent versions. The tests will be performed during the months of
Page 5 of 7

Permit NC0004952
March, June, September, and December. These months signify the first month of each three
month toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be
obtained during representative effluent discharge and shall be performed at the NPDES permitted final
effluentdischarge 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 -December 2010) 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, Report Form AT-
3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
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. Assessment of toxicity compliance is based on
the toxicity testing quarter, which is the three month time interval that begins on the first day of the
month in which toxicity testing is required by this permit and continues until the final day of the third
month.
A. (4) 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.
Page 6 of 7

Permit NC0004952
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".
A. (5) 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 NC DENR 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.
A. (6) WWTP Operation
1. The WWTP shall be operated at the reduced flow of 0.45 MGD. In the event that the monthly
production flows increase or are projected to increase above the 0.45 MGD permitted capacity, the
Permittee shall submit a permit modification request to the Division of Water Resources, NPDES
Complex Permitting Unit at least 180 days prior to the projected increase in production.
2. The Permittee shall notify the Division in the event that any treatment unit is taken off line from
the treatment process. The notification shall be submitted to the Division of Water Resources,
Mooresville Regional Office and NPDES Complex Permitting Unit at the following addresses:
Mooresville Regional Office
Water Quality Programs
610 East Center Avenue, Suite 301
Mooresville, NC 28115
NPDES Complex Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699
Page 7 of 7

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CNA Holdings LLC— Celanese — Shelby Plant - NC0004952
USGS Quad Name: i3lacksburg North
Receiving Stream: Buffalo Creek
Stream Class: C
Subbasin: Yadkin — 030805
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Facility Location
Lat 35°11' 15"
Long 81°30' 37"
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PUBLIC NOTICE
North Carolina Environ-
mental Management Com-
mission / NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue a
NPDES Wastewater Per-
mit
AFFIDAVIT OF INSERTION OF ADVERTISMENT
The Star
The North Carolina Envi-
ronmental Management Shelby, N.C.
Commission proposes to
issue a NPDES waste- Cleveland County
water discharge permit to
the person(s) listed below.
Written comments regard-
ing the proposed permit
will be accepted until 30
days after the publish date
of this notice. The Director The Star does certify that the advertisement for:
of the NC Division of
Water Quality (DWQ) may
hold a public hearing WASTEWATER PERMIT: CNA Holdings, Inc. (Ticona Facility)
should there be a signifi-
cant degree of public inter-
est. Please. ma7.comment::
and/or information re-
quests to DWQ at the Measuring 5.90 inches appeared in The Star, a newspaper published in Cleveland
above address.
Interested persons may
visit the DWQ at 512 N.
Salisbury Street, Raleigh,
NC to review information
on file. Additional informa-
tion on NPDES permits
and this notice may be
found on our website:
http://portal.n s.ienr.org/we 08/16/2013.
tAQ/54 or
by cwllurg (919)
807-6390. CNA Holdings,
Inc. (Ticona Facility) has
applied for renewal of
NPDES permit
NC0004952 in Shelby, NC,
Cleveland County, dis-
charging treated domestic
and industrial wastewater
to Buffalo Creek.
August 16, 2013. 1tc.
Info: text GS537518 to
56654
County, Shelby, N.C., in issue(s):
Name of Account: NCDENR/DWQ/NPDES
Order Number: 54537518
Ad Number: 54613449
Sworn to, and subscribed before me this 16 th day of August, 2013.
Carla Norris Potter, Notary Public
My Commission Expires Sept.14, 2013

DENR/DWR
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0004952
Facility Information
Applicant/Facility Name:
CNA Holdings/Ticona Facility
Applicant Address:
2525 Blacksburg Road, Grover, NC 28073
Facility Address:
Same
Permitted Flow
0.8 MGD Existing/0.45 MGD Proposed
Type of Waste:
Industrial
Facility Class:
III Existing/II Proposed
Permit Status:
Permit Renewal
County:
Cleveland
Miscellaneous
Receiving Stream:
Buffalo Creek
Regional Office:
Mooresville
Stream Classification:
C
State Grid / USGS Quad:
Gl2NEBIacksburg
North
303(d) Listed?
No
Permit Writer:
Teresa Rodriguez
HUC:
03050105
Date:
August 1, 2013
Drainage Area (mi2):
156
�"
)1101.
Lat. 35° 11' 15" N Long. 81° 30' 3T' W
Summer 7Q10 (cfs)
32
Winter 7Q10 (cfs)
48
Average Flow (cfs):
201
IWC (%):
2.13 (0.45 MGD)
SUMMARY
CNA Holdings manufactures thermoplastic and elastomer polyester resins at the Ticona
facility. Performance Fibers is also located at the site and manufactures sewing thread. Process
wastewaters from Performance Fibers a treated at the Ticona Facility WWTP. The facility is
classified under SIC codes 2824 (manmade organic fibers, except cellulosic) and 2821
(synthetic resins, plastic materials and non-vulcanizable elastometers). This facility is subject
to Effluent Guidelines in 40 CFR 414 — Organic Chemicals, Plastics and Synthetic Fibers,
Subparts C, D, and I.
A permit application was received by the Division on February 28, 2013. CNA Holdings
requested the following modifications to the permit:
• reduce permitted flow to 0.45 MGD due to decrease in production
• reclassification of WWTP from Class III to Class II
• reduction in BOD and TSS monitoring
• eliminate requirement for turbidity effluent monitoring.
Responses to these requests are addressed in subsequent sections of this fact sheet.
The wastewater treatment plant consists of a head works including screening and grit
chamber, an equalization basin with aeration and pH adjustment, an equalization/ mixing
basin, an equalization/pre-aeration basin, an emergency equalization tank, two activated
sludge treatment trains in parallel including aeration tanks/basins and secondary clarifiers,
three polishing ponds, tertiary filtration, aerated basin for sludge digestion, and sludge holding
pond. One activated sludge train and one clarifier were taken out of service due to reduction in
process flows.
Fact Sheet
NPDES NC0004952 Permit Renewal
Page I

RECEIVING STREAM
This facility discharges to Buffalo Creek in the Broad River Basin, classified C waters. Buffalo
Creek is no longer listed in the NC 303(d) list. The last basinwide assessment conducted from
2006 to 2010 indicates that turbidity is now meeting the evaluation criteria of <10%
exceedances. Due to the results of the basinwide assessment Buffalo Creek is no longer listed
in the 303(d) list.
The summer and winter 7Q l Os and average flow listed in the previous fact sheet were
incorrect. A recent model was run for Buffalo Creek and it was discovered that the flow
statistics for the CNA Holdings discharge location were different than the previous fact sheet
listed.
DMR DATA REVIEW AND VEFIFICATION OF EXISTING CONDITIONS
DMR were reviewed for the period of January 2010 to 2013. Data are summarized in Table 1.
Parameter
Units
Average
Max
Min
BOD
lb/day
12
211
0
TSS
lb/d
29
259
0
pH
SU
8.1
8.9
6.9
Fecal Coliform
Geometric mean 10 #/ 100m1
Total Copper
µg/ 1
9
28
<10
Oil and Grease
mg/1
2.7
6.2
< 5
Subpart I parameters are sampled annually. All samples results are below
laboratory detection limits.
LIMITS AND MONITORING REQUIREMENTS
A decrease in production in the last 5 years has resulted in sustained lower flows to the WWTP.
The highest average monthly flow was 0.45 MGD. This is expected to be the long term
maximum monthly flow. Due to the reduction in flow one train of the treatment system will be
taken out of service and will not be used in the future. Flows used for calculation OCPSF limits
are summarized in Table 2.
Table 2. Flows
40 CFR 414 Subpart C
0.212 MGD
40 CFR 414 Subpart D
Domestic
0.175 MGD
0.006
Modifications to monitoring requirements and permit limits are described in table Table 3.
d changes
Parameters
Change from Previous Permit
Basis for Condition/Change
Flow
Changed limit to 0.45 MGD
Permittee's flow projections based on
reduced production and most recent
three years flows.
BODS
Daily max 181 lb/d
Monthly aver 68 lb/d
Monitoring reduced to weekly
40 CFR 414 subparts C and D
(see attached calculations)
Monitoring was reduced to weekly as
per 15A NCAC 02B .0500 for a class II
facility.
TSS
Daily max 395 lb/d
Monthly aver 124 lb/d
40 CFR 414 subparts C and D (see
attached calculations)
Fact Sheet
NI'DI•:S NC:0004952 Pernik Renewal
I'age

Monitoring reduced to weekly
Monitoring was reduced to weekly as
per 15A NCAC 02B .0500 for a class II
facility.
pH
Monitoring reduced to weekly
40 CFR 414 and State WQ standards,
T15A 2B .0200
Monitoring was reduced to weekly as
per 15A NCAC 02B .0500 for a class II
facility.
Oil and Grease
No change
Division policy
Total Copper
Remove monitoring
No reasonable potential (see attached
RPA spreadsheet)
Total Nitrogen
No change
Division policy
Total Phosphorus
No change
Division policy
Turbidity
Remove instream monitoring
Change in stream status
Fecal Coliform
No change
State WQ standards, T15A 2B .0200
Toxic Pollutants
New limits based on flow. See
attached Toxic Pollutant
spreadsheet.
40 CFR 414 Subpart I
INSTREAM MONITORING:
The permit requires turbidity instream monitoring. This requirement was included in the
permit because the stream was impaired for turbidity. Since the stream is no longer listed as
impared instream turbidity monitoring was removed form the permit.
PRIORITY POLLUTANT ANALYSIS:
A priority pollutant analysis was performed for the permit renewal application. Antimony and
copper were detected at levels well below the water quality criteria.
AQUATIC TOXICITY TESTING
Permit requires chronic toxicity, ceriodaphnia dubia, 5.8%, the months of March, June,
September, and December. The facility consistently passed the toxicity tests. Due to the
change in permitted flow the toxicity test will be modified to 2.13%.
SUMMARY OF PROPOSED CHANGES:
1. Permitted flow was reduced to 0.45 MGD based on a decrease in production and
expected production levels. As a result of flow reduction the classification of the facility
changes from Class III to Class II.
2. Limits for BOD, TSS and OCPSF parameters were recalculated based on the expected
maximum production flows. Monitoring frequency for BOD and TSS was reduced to
weekly.
3. pH monitoring frequency was reduced to weekly.
4. The outfall location was corrected in the map.
5. Flow statistics for Buffalo Creek were corrected in the fact sheet.
6. Instream turbidity monitoring was removed from the permit.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: August 14, 2013
Permit Scheduled to Issue: October 15, 2013
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit, please
contact Teresa Rodriguez at 919-807-6387.
NAB:
DATE: 03/20/ 3
Fact Sheet
NPDES NC0004952 Permit Renewal
Page 3

REGIONAL OFFICE COMMENTS
NAME: DATE:
SUPERVISOR: DATE:
Fact Sheet
NPDES NC0004952 Permit Renewal
Page 4

CNA Holdings
NC0004952
REASONABLE POTENTIAL ANALYSIS
Qw (MGD) = 0.45
1Q10S (cfs) = 26.33
7Q 1 OS (cfs) = 32.00
7Q 1 OW (cfs) = 48.00
30Q2 (cfs) = 2.00
Avg. Stream Flow, QA (cfs) = 201.00
Receiving Stream: Buffalo Creek
WWTP/WTP Class: Class 11
IWC @ 1QIOS = 2.58%
IWC @7Q10S= 2.13%
IWC @7QIOW= 1.43%
IWC @ 30Q2 = 25.86%
IWC ® QA = 0.35%
Stream Class: C
Outfall 001
Qw=0.45MGD
CHRONIC TEST CONCENTRATION = 2.1%
PARAMETER
TYPE
(1)
STANDARDS & CRITERIA (2)
J
.
N
z
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC WQS / Applied '/z FAV /
Chronic Standard Acute
n # Det. Max Pred Allowable Cw
Cw
Copper (AL)
NC
7 FW(7Q 10s) 7.3
ug/L
49 22
50
Acute: 282.9
_ _ _ _ _ _ _ _ _ _ _ — _
Chronic: 328.E
No value > Allowable Cw
NO RP, remove monitoring
_ — _ _ _ _ _ _ _ _ _ _ — _ - _
--- --_ --
0 0
N/A
Acute:
- ------------
Chronic:
— — —_ _ •-------_
— —.
— --- —
0 0
N/A
Acute:
------------
Chronic:
— --- ------
- - - —
— — —
-- - -
0 0
N/A
Acute:
- ------------
Chronic:--
-- — --
— — —-- — —
0 0
N/A
Acute:
- ------------
Chronic:
- _ - -----------------.
---- —
Page 1 of 1
0004952 RPA 2013.xlsm, rpa
8/6/2013

OCPSF Subpart I Calculations
FACILITY =>
NPDES Permit # =>
Outfall # _>
OCPSF Flow =>
op =>
WS Class ?
7Q10s =>
Average Stream Flow = >
CNA HOLDINGS
NC0004952
1
0.39 MGD
0.45 MGD
NO
32 cfs
201 cfs
IWC (%)
2.1%
0.3%
Parameter
1
OCPSF
Daily
Maximum
pg/L
2
OCPSF
Monthly
Average
pg/L
3
OCPSF
Daily
Maximum
Ibslday
4 5 6 7 8 9
OCPSF
Monthly
Average
Ibslday
Federal
Criteria or
State
Standard
Standard
Aquatic
Life
pg/L
Human
Health
Standard
pg/L
Acenaphthene
Acenaphthylene
Acrylonitrile
Anthracene
Benzene
Benzo(a)anthracene
3, 4- B e n zof l u o ra n t h e n e
B e n z o (k)f I u o ra n t h e n e
Benzo(a)pyrene
Bis(2-ethylhexyl) phthalate
Carbon Tetrachloride
Chlorobenzene
Chloroethane
Chloroform
2-Chiorophenol
Chrysene
Di-n-butyl phthalate
1,2-Dichtorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1,1-Dichloroethane
1, 2-Dichloroethane
1,1-Dichloroethylene
1, 2-trans-Dichloroethylene
2,4-Dichlorophenol
1,2-Dichloropropane
1,3-Dichloropropylene
Diethyl phthalate
2,4-Dimethylphenol
Dimethyl phthalate
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Ethylbenzene
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Methyl Chloride
Methylene Chloride
Naphthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
59
59
242
59
136
59
61
59
61
279
38
28
268
46
98
59
57
163
44
28
59
211
25
54
112
230
44
203
36
47
277
123
285
641
108
68
59
28
49
54
190
89
59
68
69
124
22
22
96
22
37
22
23
22
23
103
18
15
104
21
31
22
27
77
31
15
22
68
16
21
39
153
29
81
18
19
78
71
113
255
32
25
22
15
20
21
86
40
22
27
41
72
0.190
0.190
0.781
0.190
0.439
0.190
0.197
0.190
0.197
0.900
0.123
0.090
0.865
0.148
0.316
0.190
0.184
0.526
0.142
0.090
0.190
0.681
0.081
0.174
0.361
0.742
0.142
0.655
0.116
0.152
0.894
0.397
0.920
2.069
0.349
0.219
0.190
0.090
0.158
0.174
0.613
0.287
0.190
0.219
0.223
0.400
0.071 FC 60
0.071 FC none
0.310 FC none
0.071 FC 0.05
0.119 SS none
0.071 FC none
0.074 FC none
0.071 FC none
0.074 FC none
0.332 FC none
0.058 SS none
0.048 FC 140
0.336 FC none
0.068 SS none
0.100 FC none
0.071 FC none
0.087 FC 9.5
0.249 FC 470
0.100 FC 390
0.048 FC 100
0.071 FC 20000
0.219 FC none
0.052 FC 5400
0.068 FC none
0.126 FC none
0.494 FC none
0.094 FC none
0.261 FC 1200
0.058 FC 320
0.061 FC 3400
0.252 FC 12
0.229 FC 26
0.365 FC none
0.823 FC none
0.103 FC 97
0.081 FC 0.11
0.071 FC 46
0.048 FC none
0.065 SS none
0.068 FC none
0.278 FC none
0.129 FC none
0.071 FC 330
0.087 FC none
0.132 FC 8000
0.232 FC 750
Water
Consumption
Standard
pg/L
Carcinogen?
10
min
criteria
pgIL
11
Water Qual
Allowable
Load
Ibslday
12
OCPSF
Daily
Maximum
Ibslday
13
find min.
14
Limit
Based On:
15
Daily
Maximum
Limit
16
17
Monthly
Average
Limit
lbs/day
none 20 no 60.00 10.56 0.190 0.190 OCPSF 0.190 lbs/day 0.071
none none no none none 0.190 0.190 OCPSF 0.190 lbs/day
0.25 0.051 yes 0.250 0.27 0.781 0.271 CHRONIC 72.293 uglL
40000 none no 0.05 0.01 0.190 0.009 CHRONIC 2.344 ug1L
51 1.19 yes 51.000 55.35 0.439 0.439 OCPSF 0.439 lbs/day 0.119
0.031 0.0028 yes 0.031 0.03 0.190 0.034 CHRONIC 8.964 ug/L
0.031 0.0028 yes 0.031 0.03 0.197 0.034 CHRONIC 8.964 ug/L
0.031 0.0028 yes 0.031 0.03 0.190 0.034 CHRONIC 8.964 ug/L
0.031 0.0028 yes 0.031 0.03 0.197 0.034 CHRONIC 8.964 ug/L
2.2 1.2 yes 2.200 2.39 0.900 0.900 OCPSF 0.900 lbs/day 0.332
1.6 0.254 yes 1.600 1.74 0.123 0.123 OCPSF 0.123 lbs/day 0.058
none 130 no 140.00 24.63 0.090 0.090 OCPSF 0.090 Ibslday 0.048
550 12 no 550.00 96.76 0.865 0.865 OCPSF 0.865 lbs/day 0.336
170 5.6 yes 170.00 184.49 0.148 0.148 OCPSF 0.148 lbs/day 0.068
none none no none none 0.316 0.316 OCPSF 0.316 lbs/day 0.100
0.031 0.0028 yes 0.031 0.03 0.190 0.034 CHRONIC 8.964 ug/L
none none no 10 1.67 0.184 0.184 OCPSF 0.184 lbs/day 0.087
none 420 no 470 82.69 0.526 0.526 OCPSF 0.526 lbs/day 0.249
none 320 no 390.00 68.61 0.142 0.142 OCPSF 0.142 Ibslday 0.100
190 63 no 100.00 17.59 0.090 0.090 OCPSF 0.090 lbs/day 0.048
170000 6700 no 20,000.00 3518.67 0.190 0.190 OCPSF 0.190 lbs/day 0.071
37 0.38 yes 37.00 40.15 0.681 0.681 OCPSF 0.681 lbs/day 0.219
7.1 330 yes 7.10 7.71 0.081 0.081 OCPSF 0.081 Ibslday 0.052
10000 140 no 10,000.00 1759.34 0.174 0.174 OCPSF 0.174 lbs/day 0.068
none none no none none 0.361 0.361 OCPSF 0.361 Ibs/day 0.126
15 0.5 yes 15.00 16.28 0.742 0.742 OCPSF 0.742 lbs/day 0.494
none none no none none 0.142 0.142 OCPSF 0.142 Ibs/day 0.094
15000 none no 1,200 211.12 0.655 0.655 OCPSF 0.655 lbs/day 0.261
none none no 320 56.30 0.116 0.116 OCPSF 0.116 lbs/day 0.058
none none no 3,400 598.17 0.152 0.152 OCPSF 0.152 lbs/day 0.061
280 none no 12.00 2.11 0.894 0.894 OCPSF 0.894 lbs/day 0.252
none none no 26.00 4.57 0.397 0.397 OCPSF 0.397 lbs/day 0.229
3.4 0.11 yes 3.40 3.69 0.920 0.920 OCPSF 0.920 lbs/day 0.365
0.71 0.048 yes 0.71 0.77 2.069 0.771 CHRONIC 205.312 ug/L
none none no 97.00 17.07 0.349 0.349 OCPSF 0.349 lbs/day 0.103
none none no 0.11 0.02 0.219 0.019 CHRONIC 5.157 ug/L
none none no 46.00 8.09 0.190 0.190 OCPSF 0.190 Ibs/day 0.071
0.00029 0.00028 yes 0.000 0.000 0.090 0.000 CHRONIC 0.084 ug/L
18 0.44 yes 18.00 19.53 0.158 0.158 OCPSF 0.158 Ibslday 0.065
3.3 1.4 yes 3.30 3.58 0.174 0.174 OCPSF 0.174 Ibs/day 0.068
96 2.6 no 96.00 16.89 0.613 0.613 OCPSF 0.613 Ibs/day 0.278
590 4.7 yes 590.00 640.30 0.287 0.287 OCPSF 0.287 Ibs/day 0.129
none none no 330.00 58.06 0.190 0.190 OCPSF 0.190 lbs/day 0.071
30 17 no 30.00 5.28 0.219 0.219 OCPSF 0.219 Ibslday 0.087
none none no 8,000.00 1407.47 0.223 0.223 OCPSF 0.223 Ibs/day 0.132
none 270 no 750.00 131.95 0.400 0.400 OCPSF 0.400 lbs/day 0.232
8/6/2013
0.071

OCPSF
Daily
Maximum
ig/L
OCPSF
Monthly
Average
pg/L
OCPSF
Daily
Maximum
lbs/day
OCPSF
Monthly
Average
Ibslday
Federal
Criteria or
State
Standard
Standard
Aquatic
Life
pg/L
OCPSF Snhnart I Cal illations
Human
Health
Standard
pg/L
Water
Consumption
Standard
pg/L
8/6/2013
Carcinogen?
min
criteria
µg/L
find min.
Daily
Maximum
Limit
Monthly
Average
Limit
lbs/day
Water Quat OCPSF
Allowable Daily
Load Maximum Limit
Parameter Ibs/daa lbs/day Based On:
Phenanthrene 59 22 0.190 0.071 FC none none none no none none 0.190 0.190 OCPSF 0.190 lbs/day 0.071
Phenol 26 15 0.084 0.048 FC none 300 300 no 300 52.78 0.084 0.084 OCPSF 0.084 lbs/day 0.048
Pyrene 67 25 0.216 0.081 FC none 4000 830 no 4,000 703.73 0.216 0.216 OCPSF 0.216 lbs/day 0.081
Tetrachloroethylene 56 22 0.181 0.071 SS none 3.3 0.7 yes 3.30 3.58 0.181 0.181 OCPSF 0.181 lbs/day 0.071
Toluene 80 26 0.258 0.084 SS 11 none none no 11.00 1.94 0.258 0.258 OCPSF 0.258 Ibs/day 0.084
Total Chromium 2770 1110 8.940 3.583 SS 50 none none no 50.00 8.80 8.940 8.797 CHRONIC 2343.907 ug/L 3.583
Total Copper 3380 1450 10.909 4.680 SS -AL 7 none none no 7.00 1.23 10.909 1.232 CHRONIC 328.147 ug/L
Total Cyanide 1200 420 3.873 1.356 SS 5 none none no 5.00 0.88 3.873 0.880 CHRONIC 234.391 ug/L
Total Lead 690 320 2.227 1.033 SS 25 none none no 25.00 4.40 2.227 2.227 OCPSF 2.227 lbs/day 1.033
Total Nickel 3980 1690 12.846 5.455 SS 88 none 25 no 88.00 15.48 12.846 12.846 OCPSF 12.846 lbs/day 5.455
Total Zinc 2610 1050 8.424 3.389 SS -AL 50 none none no 50.00 8.80 8.424 8.424 OCPSF 8.424 lbs/day 3.389
1,2,4-Trichlorobenzene 140 68 0.452 0.219 FC 61 none 35 no 61.00 10.73 0.452 0.452 OCPSF 0.452 Ibs/day 0.219
1,1,1-Trichloroethane 54 21 0.174 0.068 FC none 4.4 0.54 yes 4.40 4.78 0.174 0.174 OCPSF 0.174 lbs/day 0.068
1,1,2-Trichloroethane 54 21 0.174 0.068 FC none 16 0.59 yes 16.00 17.36 0.174 0.174 OCPSF 0.174 lbs/day 0.068
Trichloroethylene 54 21 0.174 0.068 FC none 30 2.5 yes 30.00 32.56 0.174 0.174 OCPSF 0.174 Ibs/day 0.068
Vinyl Chloride 268 104 0.865 0.336 SS none 2.4 0.025 yes 2.40 2.60 0.865 0.865 OCPSF 0.865 lbs/day 0.336

To: NPDES Unit
Water Quality Section
Attention: Charles Weaver
Date: March 22, 2013
NPDES STAFF REPORT AND RECOMMENDATION
County: Cleveland
Permit No. NC0004952
PART I - GENERAL INFORMATION
1. Facility and address: CNA Holdings, Inc.-Ticona facility
2525 Blacksburg Road
Grover, NC 28073
2. Date of investigation: March 12, 2013
3. Report prepared by: Samar Bou-Ghazale, Environmental Eng. II
4. Persons contacted and telephone number: Ms. Pem Carter, Environmental Engineer with
CNA Holding; Tel # [phone].
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"
U.S.G.S. Quad No.: G 12 NE U.S.G.S. Name: Blacksburg North, N.C.
7. 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 is
approximately 85 to 90 feet wide with sandy bottom at the location of the discharge
point. No detrimental effects were observed as a result of this discharge.
Downstream uses are typical for 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. Actual treatment capacity of the current facility (current design capacity)? 0

2. a. Type of treatment: The existing WWT 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, which consist of dual aeration basins with
pH adjustment, polymer addition system and dual clarifiers, dual media tertiary
treatment system, three (3) aerated polishing ponds with chemical addition for
foam/algae control, an aerated sludge digesting basin, and two sludge storage ponds.
There are two groundwater remediation systems that are producing approx. 0.003
MGD that is routed to the plant headworks.
3. b. Prevalent toxic impacts to surface waters: Process waters, contact cooling water.
Also, polymer and other chemical additions could have toxic impacts.
PART III - OTHER PERTINENT INFORMATION
1. Special monitoring/effluent limit requests: See Part IV
2. Compliance information: No problems were note in the latest CEI.
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. Since last permit renewal in 2008, the facility has used the
UV disinfection since they have no fecal issue according to Ms. Pem Carter. No algacides are being
used at the facility at this time. Also, the facility has consistently passing their toxicity testing since
2008. Due to a decrease in manufacturing operations and production rates at the site, Ticona facility
is requesting to remove one aeration basin and one clarifier from operation and use them as a standby
since the discharge at the facility has been reduced by almost half. Also, Ticona is requesting to
reduce the frequency of monitoring for Biochemical Oxygen Demand (BOD) and Total Suspended
Solids (TSS) to twice/week from daily based on historical monitoring data. Ticona also requests the
removal of turbidity monitoring based on historical monitoring data. The facility appeared to be in
good operational condition at the time of the site investigation.
Pending review and approval of the requested Permit modifications by the NPDES Unit, it is
recommended the subject permit be renewed as requested.
ignature of Report Preparer
Date
/1- 2 3
Water Quality Regional Supervisor D to

CERTIFIED MAIL: 7007 2680 0003 1602 1153
Return Receipt to PEM Carter
PEMC13:10
February 26, 2013
NCDENR
DWQ / Point Source Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
ATTN: Lisa Palmer
!Kona
Ticona
2525 Blacksburg Road
Grover, NC 28073-9641
Carolina Star Worksite
150 9001, ISO/TS 16949,
ISO 17025, and ISO 14001
Reference: NPDES Permif ewiai,ioiCNA Holdings, Inc. — TICONA Facility
Permit No. NC 0004952
This letter is written to request the 10—he val of the above referenced NPDES permit, per the requirements of
our existing permit. Also enclosed, one signed original and two copies, are the necessary documents for this
permit renewal:
• Completed application General Information Form 1 and Form 2C.
• Supporting documentation: analytical results from CNA Holding's Inc. —certified laboratories.
• A narrative description of the sludge management plan.
CNA Holdings, LLC. — Ticona Facility request the renewal to reflect treatment of process and domestic
wastewaters of Vectra, Compounding, & Performance Fibers; and to include goundwater, first -flush
stormwater, utilities waters & blowdowns, fire lagoon water & non -process spin -finish.
CNA Holding LLC — TICONA Facility is committed to ensuring compliance with all County, State, and Federal
regulations. Should there be a need for further discussion pertaining to the information on the forms, feel free
to call me at 704/480-5726, or via email at [e-mail].
Inc
al-i--
PEM Carter
Sr. Environmental Engineer
Attachment
i Celanese
A\P
Ticona
A business of Celanese

Application for Renewal of NPDES No. NC0004952
CNA Holdings LLC - Ticona Facility Site
Grover, NC
AECOM Project No. 60283293
1.0 INTRODUCTION
CNA Holdings LLC (CNA) has a manufacturing operation at its Ticona Facility Site (Site) located
at 2525 Blacksburg Road, Grover in Cleveland County, North Carolina. Performance Fibers is
co -located on the Site, manufactures sewing thread, and is a source of wastewater discharged
to the Site Wastewater Treatment Plant (WWTP). The Site location is shown on the Site
Location Map, Figure 1. The Site manufacturing operations include those under Standard
Industrial Classification Codes 2824 - Establishments primarily engaged in manufacturing
manmade organic fibers, except cellulosic; and 2821 - Establishments primarily engaged in
,,,i, manufacturing synthetic resins, plastics materials, and non-vulcanizable elastomers.
Min
r�r
roN
Process wastewater is subject to Effluent Guidelines and Standards for the following Point
Source Categories:
• 40 CFR 414 - Organic Chemicals, Plastics, and Synthetic Fibers - Subpart C — Other Fibers
(SIC Code 2824);
• 40 CFR 414 - Organic Chemicals, Plastics, and Synthetic Fibers - Subpart D —
Thermoplastic Resins (SIC Code 2821); and
• 40 CFR 414—Organic Chemicals, Plastics, and Synthetic Fibers - Subpart I —Direct
Discharge Point Sources That Use End -of -Pipe Biological Treatment.
The Site generated a combined wastewater flow consisting of process wastewater, utility
wastewater (i.e. boiler blowdown, cooling tower blowdown), sanitary wastewater, storm water
runoff primarily from direct rainfall onto WWTP units, and groundwater from three groundwater
extraction wells. All wastewater from the Site is collected, combined, and subjected to
treatment in an on -site WWTP prior to a discharge through one outfall, Outfall 001, to a
receiving stream (Buffalo Creek) in accordance with effluent limitations and other monitoring
requirements of National Pollutant Discharge Elimination System (NPDES) Permit No.
NC0004952. Buffalo Creek is a Class C state water body located in the Broad River Basin.
The approximate location of the monitoring station for Outfall 001 and the discharge to Buffalo
Creek is shown on the Site Location Map, Figure 1. A Water Balance Flow Diagram showing
wastewater flows from the various sources is provided in Figure 2.
The existing wastewater treatment facility includes a head works (screening and grit chamber);
an equalization basin with aeration where pH adjustment occurs; an equalization/mixing basin;
an equalization/pre-aeration basin; an emergency equalization tank; two activated sludge
treatment trains operating in parallel including aeration tanks/basins and secondary clarifiers;
three polishing ponds; tertiary filtration; an aerated basin for sludge digestion; sludge holding
ponds; and a discharge to a receiving stream. Sludge is periodically removed from the sludge
1 February 2013

fmcr
ftel
fun
Awl
Application for Renewal of NPDES No. NC0004952
CNA Holdings LLC - Ticona Facility Site
Grover, NC
AECOM Project No. 60283293
holding ponds for land application at off -site locations and supematant from the sludge digester
is returned to the activated sludge aeration basins. Both ammonia and phosphorus can be
added as a nutrient source for the activated sludge biological treatment process. The tertiary
filters are presently used on an intermittent basis to further control suspended solids during
warmer months of the year when there may be some algae growth in the polishing ponds.
Land application of sludge is currently. permitted through April 28, 2014 under a Land
Application of Residual Solids (503 B Exempt) Permit.
CNA is submitting this application for the Site to renew NPDES Permit No. NC0004952 at least
180 days prior to the expiration date of the permit of August 31, 2013. Presented in Table 1 is a
summary of NPDES discharge monitoring report data, previously submitted to NCDENR, from
December 2011 through November 2012 for Outfall 001. We have included this discharge
monitoring data, for which monitoring is required under the existing NPDES Permit, on Form 2C
of this application with the exception of flow. Due to a decrease in manufacturing operations
and production rates at the site, discharge flow rates for Outfall 001 have been well below the
monthly average flow rate of 0.8 MGD currently specified in existing NPDES Permit No.
NC0004952. In this permit renewal application, we have included a projected maximum daily
flow value, a maximum 30 day flow value, and a long term average value (lower than the
existing monthly average permit limit of 0.800) based on the potential for those flows to occur
during the effective period of a renewed NPDES Permit.
In' Samples of Outfall 001 were collected in December 2012 for other constituents for which
monitoring is not routinely required by the existing NPDES Permit. The results from this
rwr sampling event are also reported on Form 2C. The. laboratory reports of the results of sampling
for Outfall 001 in December 2012 are provided in the appendix of this application.
As stated earlier, process wastewater is subject to Effluent Guidelines and Standards for the
following Point Source Categories:
• 40 CFR 414 - Organic Chemicals, Plastics, and Synthetic Fibers - Subpart C — Other Fibers
(SIC Code 2824);
• 40 CFR 414 - Organic Chemicals, Plastics, and Synthetic Fibers - Subpart D —
Thermoplastic Resins (SIC Code 2821); and
• 40 CFR 414—Organic Chemicals, Plastics, and Synthetic Fibers - Subpart I —Direct
rof Discharge Point Sources That Use End -of -Pipe Biological Treatment.
These effluent limitations established under 40 CFR 414 are based on flows from each
regulated process operation. The mass effluent limitation is based on flow rate from the
regulated process operation and the concentration specified in 40 CFR 414 for a regulated
pollutant. Average process wastewater flow rates at the Site are projected to be as follows:
2 February 2013

Application for Renewal of NPDES No. NC0004952
CNA Holdings LLC - ricotta Facility Site
Grover, NC
AECOM Project No. 60283293
Regulated Process
SIC Code
Applicable 40 CFR
Subcategory
Average Process
Wastewater Flow
Compounding
2821
Subpart D —
Thermoplastic Resins
0.158 MGD
Vectra
2821
Subpart D —
Thermoplastic Resins
0.017 MGD
Performance Fibers
2824
Subpart C — Other
Fibers; Subpart D —
Thermoplastic Resins
0.212 MGD
Total
0.387 MGD
Analytical results of sampling performed for Outfall 001 in December 2012 also included the
following:
• 1,4 Dioxane — 152 pig/
• Volatile Organic Tentatively Identified Compounds (TICs) — None detected.
• Semi -Volatile Organic TICs included the following:
• 1,4 Dioxane — 11.2 µg/L
■ 3-Hexen-1-OL — 2.11 µg/L
• Eicosane — 2.31 µg/L
• Eicosane — 3.63 µg/L
■ Hexatriacontane — 3.26 µg/L
Octadecane — 2.96 µg/L
Tetracosane — 2.07 µg/L
The laboratory responsible for performing the above analyses stated that the TICs are only
"tentatively identified" compounds based on standards the laboratory has available to them, and
all reported values are estimated values. The laboratory stated that there could be two peaks
associated with the same compound resulting in two separate results for the same compound
(i.e. Eicosane).
CNA asks NCDENR to consider the following during the review and processing of this
application and in the renewal of NPDES Permit No. NC0004952.
• As stated above, due to a decrease in manufacturing operations and production rates at
the site, discharge flow rates for Outfall 001 have been well below the monthly average
3 February 2013

Application for Renewal of NPDES No. NC0004952
CNA Holdings LLC - Ticona Facility Site
Grover, NC
AECOM Project No. 60283293
flow rate of 0.8 MGD currently specified in existing NPDES Permit No. NC0004952. We
anticipate that long term average wastewater flows during the effective period of the
renewed NPDES Permit will not exceed 0.450 MGD. According to the descriptions
provided below from the North Carolina Administrative Code (NCAC) Title 15a -
Environment and Natural Resources, the WWTP at this permitted flow rate should be
classified as a Grade II Biological Water Pollution Control System. Therefore, it is
requested with this application that the WWTP be classified as a Grade II WWTP instead
of the Grade III WWTP as currently specified.
■ (b) Systems that utilize an activated sludge or fixed growth process with a
permitted flow less than or equal to 0.5 million gallons per day (MGD) are
assigned the classification of Grade 11 Biological Water Pollution Control System.
• (c) Systems utilizing an activated sludge or fixed growth process with permitted
flows of greater than 0.5 through 2.5 million gallons per day (MGD) are assigned
the classification of Grade 111 Biological Water Pollution Control System.
• Again, due to a decrease in manufacturing operations and production rates at the Site,
discharge flow rates for Outfall 001 have been well below the monthly average flow rate
of 0.8 MGD currently specified in existing NPDES Permit No. NC0004952. Therefore,
the full operating capacity of the existing WWTP is not needed at the lower long term
average flows of 0.450 MGD. Therefore, with this application, CNA is informing
NCDENR that one of the two activated sludge treatment trains (one activated sludge
aeration basin and one secondary clarifier) as shown by the dotted lines in the Water
Balance Flow Diagram, Figure 2, will be inactivated or taken out of service until
wastewater flows increase and additional WWTP capacity is needed. Inactivation
indicates that the facilities will not be permanently closed, but those units will be placed
in an idled mode, and equipment in those units will either be re -purposed for other uses
at the Site or measures will be taken to protect the equipment as appropriate during the
extended shut -down period.
• CNA asks that NCDENR reduce the frequency of monitoring for Biochemical Oxygen
Demand (BOD) and Total Suspended Solids (TSS) from daily to twice/week based on
historical monitoring data.
• CNA asks that NCDENR eliminate the requirement for turbidity monitoring based on
historical monitoring data.
4 February 2013

6'> It
Substation ' [' `- ie -Ponds
1� \�
,ri. - y Oulfall001 --
u 8�J ` Monitoring Station '—
•
,_ .
> L` �"l�
ACOM
AECOM Technical Services, Inc.
10 Patewood Drive, Bldg. VI, Suite 500
Greenville, South Carolina 29615
6,000 %fl
NPDES Permit No. NC0004952
Renewal Application
CNA Holdings, LLC - Ticona Facility Site
Grover, North Carolina
FIGURE 1 - SITE LOCATION MAP
[phone] www.aecom.com
AECOM Project No. 60283293 January 2013

Groundwater
0.003 MGD
Evaporative
and Other
Losses
0.120 MGD
Public
Water
0.480 MGD
♦
-
Storm
Water
Process
Water
T
Utility
Wastewater
0.029 MGD
Performance
Fibers -
Vectra
Process
Compounding
0.212 MGD 0.017 MGD (' , 0.158 MGD
•
�► Headworks ► Equalization
Box Basin A
41
Equalization
Basin B
•
Equalization
Basin C
Potable
Water
Sanitary
Wastewater
0.006 MGD
•
—► Mixing Box
♦
Tertiary Filter Polishing
Pond C
1-
0.450 MGD
•
Outfall 001 to
Buffalo Creek
LEGEND
—♦ In Service
- - -®F - - -, Standby Mode
Polishing
Pond B
Polishing
Pond A
1
4-
-
-
Ai
South Aeration
Basin •
RAS
►
North Aeration
Basin 4-r
YRAS
A
North Sludge
Basin
4
South Sludge
Basin
Waste Activated Sludge (WAS)
Sludge
Digestion
Waste Sludge
► Land Application (Off -Site)
0.025 MGD
Figure 2
Water Balance Flow Diagram
CNA Holdings LLC
Ticona Facility Site
Grover, NC