HomeMy WebLinkAboutNC0004626_Fact Sheet_20220405Fact Sheet
NPDES Permit No. NC0004626
Permit Writer/Email Contact Julia Byrd, julia.byrd@ncdenr.gov:
Date: December 10, 2021
Division/Branch: NC Division of Water Resources/NPDES Complex Permitting
Permitting Action:
❑X Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
Electric Glass Fiber America, LLC
Applicant Address:
473 New Jersey Church Road, Lexington, NC 27292
Facility Address:
473 New Jersey Church Road, Lexington, NC 27292
Permitted Flow:
0.6 MGD
Facility Type/Waste:
Industrial; 6% domestic, 94% industrial
Facility Class:
Class 3
Treatment Units:
Bar Screen, Flow Equalization, Primary Clarification, Activated
Sludge, BNR, Secondary Clarification, Chlorination and
Dechlorination, Belt Dewatering Press
Pretreatment Program (Y/N)
No
County:
Davidson
Region
Winston-Salem
Briefly describe the proposed permitting action and facility background:
Permit History:
The facility name was changed from PPG Industries Fiber Glass Products, Inc. to Electric Glass Fiber
America, LLC on November 1, 2017. Electric Glass Fiber America, LLC has applied for NPDES permit
renewal, and submitted a renewal application dated October 26, 2021. This facility operates a fiberglass
fiber manufacturing facility in Lexington, NC. The Lexington plant currently concentrates the bulk of its
fiberglass yarn manufacturing on the textile industry as well as the printed circuit board industry.
This Lexington facility discharges through a single permitted outfall 001. This outfall is from the
wastewater treatment plant and receives the following types of wastewater:
➢ Sanitary (American Children's Home) ➢ Process Wastewater
➢ In -plant sanitary ➢ Non -contact cooling water
Page 1 of 9
➢ Boiler feed ➢ Sludge dewatering
No effluent guidelines are applicable to this facility according to extensive research conducted during the
1998 renewal. There are still no effluent guidelines applicable to this facility during this permit renewal.
Current limitations were installed in 1983 and are based on Waste Load Allocation.
Monitoring frequency is reduced to quarterly for BOD, TSS, Fecal Coliform, and 1/ 2 months for TRC,
based on 1996 EPA Interim Guidance for Performance — Based Reductions of NPDES Permit Monitoring
Frequencies.
Limits for fluoride were proposed in the previous permit renewal as fluoride showed reasonable potential
to exceed water quality standards. In addition, a 42-month compliance schedule is proposed to allow the
Permittee to be in complaint with the new fluoride limit. RP was also shown for copper; however due to
limited number of data, quarterly monitoring was added to the permit with no limit.
The previous permit renewal was slightly off the NPDES renewal schedule for Yadkin -Pee Dee River
Basin.
Current Permitting Actions:
The Division received the NPDES permit renewal application 10/29/2021, the current permit expires
5/31/2022. Seasonal nitrogen -ammonia and dissolved oxygen effluent limits were added. Based on results
of RPA, selenium showed no RP, monitoring requirements were removed from the permit. Based on results
of the WLA conducted for this review, seasonal ammonia -nitrogen limits were added. Weekly dissolved
oxygen monitoring and effluent limit of not less than 5 mg/L were added to the permit.
2. Receiving Waterbodv Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
001/North Potts Creek
Stream Segment:
03040103
Stream Classification:
C
Drainage Area (mi2):
11.5
Summer 7Q10 (cfs)
1
Winter 7Q10 (cfs):
2.2
30Q2 (cfs):
Average Flow (cfs):
11
IWC (% effluent):
48
303(d) listed/parameter:
No
Subject to TMDL/parameter:
Yes- Statewide Mercury TMDL implementation.
Basin/Sub-basin/HUC:
Yadkin -Pee Dee; 03-07-04/
USGS Topo Quad:
D17NE, E17NE
Page 2 of 9
3. Effluent Data Summary
Effluent data for Outfall 001 is summarized below for the period of December 2017 - November 2021.
Table. Effluent Data Summary Outfall 001
Parameter
Units
Average
Max
Min
Permit
Limit
Flow
MGD
0.7
0.1
MA 0.6
BOD summer
lbs/day
7.6
21.9
<2
MA 157
DM 314
BOD winter
lbs/day
9.8
16.9
2.7
MA 314
DM 630
TSS summer
lbs/day
9.1
19.2
3.1
MA 105
DM168
TSS winter
lbs/day
15.6
26.7
<1
MA 146
DM 292
Fecal coliform
#/100 ml
2.8
25
<1
(geometric)
WA 400
MA 200
NH3 as N
mg/L
0.4
14.9
<0.1
Monitor
weekly
pH
SU
--
8.99
6.12
6.0 > pH <
9.0
TRC
µg/1
25
<25
<25
DM 28.0
(< 50
compliance)
Total Fluoride
mg/L
2.2
19.9
0.36
MA 3.7
DM 45.7
O&G
mg/L
4.9
5.1
4.8
MA 30
DM 60
Temperature
° C
21.2
29.9
11.7
Monitor
weekly
TKN
mg/1
1.8
10.0
0.1
Monitor
weekly
NO2 + NO3
mg/L
5.2
23.4
0.04
Monitor
weekly
TP
mg/L
0.6
9.2
<0.1
Monitor
weekly
Total Copper
7.8
47.0
<0.1
Monitor
quarterly
Total Selenium
7.6
10.0
<0.1
Monitor
quarterly
Total Hardness (CaCO3)
mg/1
158.6
302
<0.662
Monitor
quarterly
Chronic Toxicity
P/F
Quarterly
MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA=Daily Average
Page 3 of 9
4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions when
model results for instream DO are within 1 mg/1 of instream standard at full permitted flow; 2) to verify
model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other instream
concerns. Instream monitoring may be conducted by the Permittee, and there are also Monitoring Coalitions
established in several basins that conduct instream sampling for the Permittee (in which case instream
monitoring is waived in the permit as long as coalition membership is maintained).
If applicable, summarize any instream data and what instream monitoring will be proposed for this permit
action: Current permit does not require instream monitoring as part of a settlement agreement reached in
1995. The facility was required to monitor at 10 instream stations once during the summer of 1995 and
once in 1996. Monitored parameters were DO, temperature, conductivity, pH, total phosphorus, nitrate,
nitrite, ammonia and TKN. The monitoring was completed as required; no changes are proposed.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (Y/N): NO
Name of Monitoring Coalition: NA
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): The facility has reported one
effluent limit violation in the last five years. The daily maximum limit for fecal coliform was exceeded on
9/7/2017. The Division issued a Notice of Deficiency in response, and no further issues or effluent limit
violations have been reported since.
Summarize the compliance record with aquatic toxicity test limits and any second species test results (past
5 years): The facility passed 20 of 20 quarterly chronic toxicity tests.
Summarize the results from the most recent compliance inspection: The last facility inspection conducted
was July 25, 2018, with a follow-up inspection July 31, 2018. The first inspection found the facility non-
compliant due to an issue with the effluent automatic sampler. The operators contacted the manufacturer
who provided troubleshooting assistance and calibration. The issue was resolved by July 31, 2021.
6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1Q10 streamflow (acute Aquatic Life); 7Q10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA
If applicable, describe any mixing zones established in accordance with 1SA NCAC 2B. 0204(b): NA
Page 4 of 9
Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD= 30 mg/1 for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
If permit limits are more stringent than TBELs, describe how limits were developed: Current effluent
limitations for BOD5 and TSS are based on water quality protection and not on federal guidelines. Extensive
research was conducted during the 1998 renewal to determine if any federal guidelines exist for such a
manufacturing operation. Neither textile nor glass guidelines applies to the Permittee's process. A review
of the WLA file indicates that the limits installed in 1983 were based on Waste Load Allocation.
There is not currently a permit limit for dissolved oxygen. A daily average effluent limit of not less than
5.0 mg/L will be added per 15A NCAC 02B .0211(6).
Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/1 (summer) and 1.8 mg/1 (winter). Acute ammonia limits are derived from chronic criteria, utilizing
a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/1) and capped at 28 ug/1 (acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/1 are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: Based on results of
the waste load allocation review, the calculated allowable ammonia concentration for summer is 1.8 mg/L;
and 5.5 mg/L for winter. Seasonal monthly average and daily maximum limits will be added to the permit
for protection of acute and chronic aquatic life as follows:
Season
MA
DM
Summer
1.8 mg/L
9 mg/L
Winter
5.5 mg/L
27.5 mg/L
No changes are proposed to the current limit for TRC of 28 ug/L.
Reasonable Potential Analysis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of Y2 detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between December 2017
and November 2021. Pollutants of concern included toxicants with positive detections and associated water
quality standards/criteria. Based on this analysis, the following permitting actions are proposed for this
permit:
• Effluent Limit with Monitoring. The following parameters will receive a water quality -based
effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable water
quality standards/criteria: Fluoride
Page 5 of 9
• Monitoring Only. The following parameters will receive a monitor -only requirement since they
did not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but
the maximum predicted concentration was >50% of the allowable concentration: Copper
• No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since
they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria
and the maximum predicted concentration was <50% of the allowable concentration: Selenium
Toxicity Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several exceptions.
The State has received prior EPA approval to use an Alternative WET Test Procedure in NPDES permits,
using single concentration screening tests, with multiple dilution follow-up upon a test failure.
Describe proposed toxicity test requirement: Quarterly chronic WET limit at 48% effluent concentration
will be maintained in reissued permit.
Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply with
EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will receive
an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a pollutant
of concern. Effluent limits may also be added if annual average effluent concentrations exceed the WQBEL
value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL value of 47 ng/1
Describe proposed permit actions based on mercury evaluation: Quarterly monitoring requirement was
removed from the permit in the previous renewal based on no exceedances of WQBELs and TBELs. No
changes are proposed.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation within
this permit: NA
Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: NA
If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with 15A
NCAC 2H 0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: 3-year compliance schedule for
fluoride was implemented in the previous permit. Limits were enforced starting June 15, 2021.
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3€ and 15A NCAC 2B. 0226 for this permit renewal: NA
Page 6 of 9
7. Technology -Based Effluent Limitations (TBELs)
Describe what this facility produces: fiber glass
List the federal effluent limitations guideline (ELG) for this facility: No ELGs are applicable, limits were
developed based on the BPJ in 1983.
For ELG limits, document the calculations used to develop TBEL limits: NA
If any limits are based on best professional judgement (BPJ), describe development: Limits for BOD and
TSS are based on BPJ in 1983
Document any TBELs that are more stringent than WQBELs: NA
Document any TBELs that are less stringent than previous permit: NA
8. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 2B.0201. Each applicant for a new/expanding NPDES permit must
document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105( c)(2). In all cases,
existing instream water uses and the level of water quality necessary to protect the existing use is maintained
and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results: NA
9. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent th7reviousious permit (YES/NO): NO
If YES, confirm that antibacksliding provisions are not violated: NA
10. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following regulations
and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2) NPDES
Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance, Reduced
Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best Professional
Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not considered
effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -backsliding
prohibitions would not be triggered by reductions in monitoring frequencies.
11. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective December
21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports (DMRs)
electronically. While NPDES regulated facilities would initially be required to submit additional NPDES
reports electronically effective December 21, 2020, EPA extended this deadline from December 21, 2020,
to December 21, 2025. The current compliance date, effective January 4, 2021, was extended as a final
regulation change published in the November 2, 2020, Federal Register This permit contains the
requirements for electronic reporting, consistent with Federal requirements.
Page 7 of 9
12.Summary of Proposed Permitting Actions:
A. Table. Current Permit Conditions and Proposed Changes
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
MA 0.6 MGD
No change
15A NCAC 2B .0505
BODS
Summer
No change
BPJ 1983
EPA Guidance for Monitor
Frequency Reduction
MA 157 lbs/day
DM 314 lbs/day
Winter:
MA 314 lbs/day
DM 630 lbs/day
NH3-N
Weekly monitoring
Summer:
MA 1.8 mg/L
DM 9 mg/L
Winter:
MA 5.5 mg/Lg
DM 27.5 mg/L
WQBEL. Based on protection of
State WQ criteria. 15A NCAC
2B.0200 and 02B .0500
TSS
Summer-
No change
BPJ 1983
EPA Guidance for Monitor
Frequency Reduction
MA 105 lbs/day
DM 314 lbs/day
Winter:
MA 146 lbs/day
DM 292 lbs/day
Fecal coliform
MA 200 /100m1
WA 400 /100m1
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
DO
None
Not less than 5 mg/L
WQBEL. State WQ standard, 15A
NCAC 2B .0200
pH
6 — 9 SU
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
TRC
DM 28 ug/L
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
TKN
Monitor Weekly
No change
15A NCAC 2B .0500
NO2+NO3
Monitor Weekly
No change
15A NCAC 2B .0500
Total Phosphorus
Monitor Weekly
No change
15A NCAC 2B .0500
Total Fluoride
MA 3.7 mg/L
DM 45.7 mg/L
No change
WQBEL. Reasonable potential to
exceed water quality standard
Total Selenium
Monitor quarterly
Removed
WQBEL. No RP, max predicted <
50% AWC. No monitoring.
Total Copper
Monitor quarterly
No change
WQBEL. No RP, max predicted >
50% AWC. Quarterly monitoring.
Total Hardness
Quarterly U & E
monitoring
No Change
Hardness -dependent dissolved metal
WQ standard, 2016
Toxicity Test
Chronic limit, 48%
effluent
No change
WQBEL. No toxics in toxic
amounts. 15A NCAC 2B.0200
Electronic
Reporting
Electronic Reporting
Special Condition
Updated language
In accordance with EPA Electronic
Reporting Rule 2015.
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
Page 8 of 9
13. Public Notice Schedule:
Permit to Public Notice: 2/25/2022
Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the
Director within the 30 days comment period indicating the interest of the party filing such request and the
reasons why a hearing is warranted.
14. NPDES Division Contact
If you have any questions regarding any of the above information or on the attached permit, please
contact Julia Byrd at (919) 707-3707 or via email at julia.byrd@ncdenr.gov.
15. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): Yes
If Yes, list changes and their basis below: NA
• Correction made to treatment unit list, dual activated carbon with pH adjustment no longer in service.
• Correction to footnotes 4 and 5 in A. (1)
• Total Cadmium quarterly monitoring removed
• Special Condition A. (2), revised to correct the DWR mailing address, and added option for test
results to be sent via email to ATForms.ATB@ncdenr.gov
16. Fact Sheet Attachments (if applicable):
• Compliance inspection report
• Monitoring violations summary
• RPA Spreadsheet Summary
• NPDES Implementation of Instream Dissolved Metals Standards — Freshwater
Standards
• NH3/TRC WLA Calculations
• Affidavit of draft permit public notice
• Comments on draft permit from EFGA Environmental Manager
Page 9 of 9
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
NORTH CAROLINA
Environmental Quality
Certified Mail # 7013 1710 0002 1922 2118
Return Receipt Requested
August 10, 2018
Alan Toney
Electric Glass Fiber America LLC
473 New Jersey Church Road
Lexington, NC 27293
SUBJECT: Compliance Evaluation Inspection and Notice of Violation
NOV Tracking Number NOV-2018-PC-0322
Electric Glass Fiber America LLC WWTP
NPDES Permit No. NC0004626
Davidson County
Dear Mr. Toney:
On July 25, 2018, Paul DiMatteo and Kelli Park of this office met with Darrell Horner, operator in
responsible charge (ORC), Brigette Tinsley, backup ORC, and Terry Taylor to perform a Compliance
Evaluation Inspection on the subject wastewater treatment facility. Chris McHugh of the US
Environmental Protection Agency was also present to perform an oversight inspection of this office. A
follow-up inspection was performed by Paul DiMatteo on July 31, 2018. This type of inspection consists
of two basic parts: an in -office file review and an on -site inspection of the treatment facility. The attached
inspection form notes the areas that were evaluated for this inspection. The findings and observations
are outlined as follows.
I. Permit
The permit became effective on January 1, 2018 and will expire on May 31, 2022. A copy of the
current permit was available during the inspection. The facility was as described in the permit.
II. Self -Monitoring Program
A review of discharge monitoring reports (DMRs) from July 2016 through May 2018 showed the
following actioned violation, which was addressed through previous correspondence from this office:
D_E Q?)
NORTH OAROUNA
oeomumnta[mhamnwl Wy
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27103
336.776.9800
Electric Glass Fiber America WWTP, 7/25/2018
NOV-2018-PC-0322
PARAMETER
VIOLATIONDATE
VIOLATION TYPE
VIOLATION ACTION
Fecal Coliform
09/14/2017
Daily Maximum Exceeded
Proceed to NOD
Sampling is being conducted at the location and frequency specified by the permit.
The facility analyzes field parameters under its in-house laboratory, certification # 5460. Effluent
toxicity analysis is performed by R&A Labs (# 34) and other analysis is performed by Pace Analytical
(# 40). Copies of all laboratory documentation were readily available. Procedures for analyzing field
parameters including required calibration appeared acceptable.
A portion of finished effluent is continuously diverted to a sink in a nearby room. Effluent grab
samples are taken from this line. In -situ measurements are taken in the sink. An ISCO 5800 composite
sampler is set to take composite samples.
During the sampling review the 10-liter sample jug was full and overflowing. The operators said
that the sample had been started only 3 hours prior to that time. Further investigation revealed that the
composite sampler was programmed to take a 50-milliliter (ml) sample every 600 gallons of flow, or 45
liters of sample per day.
Please note that Part II Section D.1 of the Permit requires that samples collected be
representative of the permitted discharge. A composite sample taken such that the sample is
overflowing after only 3 hours is not representative of the permitted discharge. Furthermore, Part II
Section A of the Permit requires that samples taken for variable time/constant volume flow proportional
compositing be at least 100 ml in volume and that the volume interval between samples be no greater
than 1/24 of the expected total daily flow. Failure to take representative samples for an
undetermined amount of time has resulted in this Notice of Violation. Mr. Horner said he would
work to set up the sampler correctly and would call for reinspection. He also said that he would not
send this sample for analysis and would start again the next day.
III. Records/Reports
Copies of DMRs, operator visitation logs, daily operation sheets, maintenance reports, lab
reports and chain -of -custody forms were available for review during the inspection. DMRs and lab data
are maintained according to the permit. DMRs include all permit parameters. A comparison of submitted
data with bench sheets revealed no errors or concerns.
IV. Flow Measurement
Effluent flow is measured using a Siemens Sitrans F M Magflo® Mag5000 electromagnetic flow
meter. The meter was calibrated by Fortech on July 7, 2018. The facility is permitted to discharge a
monthly average of 0.6 million gallons per day (mgd); typical daily discharge is about 0.54 mgd.
V. Operations and Maintenance
The plant is operated as required. All operators are properly designated and hold adequate
certifications. The facility appeared to be well operated and managed.
Page 2 of 4
Electric Glass Fiber America WWTP, 7/25/2018
NOV-2018-PC-0322
VI. Facility Site Review
All components appeared to be operating properly. Corrosion was visible on the chlorine contact
chamber's baffles. The operators said that they recognized it will eventually need to be repaired, but
that they thought they would try to remove their disinfection step first as they thought they would be
able to meet fecal coliform standards without it. The operators said that a standby power source capable
of powering the entire plant is available and tested under load regularly.
VII. Effluent/Receiving Waters
Treated effluent is discharged to North Potts Creek, class C waters in the Yadkin -Pee Dee River
Basin. Effluent in the sampling equipment appeared clear. The outfall was not observed during the
inspection due to wet conditions and time constraints. Please be sure to keep the ouffall line's easement
cleared such that the ouffall is accessible for inspection and in case of need for emergency
maintenance.
VIII. Sludge Handling/Disposal
All sludge is dewatered and hauled to a landfill as needed. Removed water is returned to the
head of the facility.
IX. Compliance Schedule
The 2018 permit renewal included a new effluent limit and compliance schedule for total fluoride.
DMRs showed a significant decrease in fluoride concentration since March 2018. The operators
explained that fluoride was used as an additive in the boiler system, but that the system was rebuilt in
March and fluoride is no longer used. They said they hoped this alone would bring them in compliance
with the limit.
Please note that a written status report is due by March 15, 2019, as specified in Part I A(3) of
the Permit.
X. Follow-up Inspection
Mr. Horner called to say that he evaluated the composite sampling equipment and had ensured
it was set up correctly. A follow up inspection was performed on July 31, 2018 to verify the setup. The
sampler was set to take 115 ml of sample every 11,300 gallons, to average 48 aliquots per composite.
Sample volume was verified using a graduated cylinder.
Mr. Horner said that he encountered additional issues with the sampling equipment: firstly, that
the sampler would not correctly calibrate the volume taken, so that he was consistently getting twice
the volume the sampler was programmed to take; and secondly, that in investigating the first issue he
discovered that the sampler tubing was installed in reverse. He said he corrected the tubing installation
and that solved the volume issue. Mr. Horner said that he had not modified the sampler since becoming
ORC.
XII. Conclusions
Afterfollow-up, the compliance evaluation inspection is satisfactory. Please continue to ensure
that all effluent composite samples are taken in the manner specified by the permit and that the
Page 3of4
Electric Glass Fiber America WWTP, 7/25/2018
NOV-2018-PC-0322
sample produced is representative of the discharge. Please be aware that violations of your NPDES
permit, or the NC statutes and regulations under which it is promulgated, are subject to fines of up to
$25,000 per day, per violation, as set forth in NC General Statute 143-215.6A, Enforcement
Procedures, Civil Penalties.
If you have any questions regarding the inspection or this report, please contact Paul DiMatteo
at (336) 776-9691 or me at (336) 776-9800.
Sincerely,
9P41.14.)f
Sherri V. ight, P.E.
Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
Attachments: BIMS EPA Water Compliance Inspection Report
cc: WSRO
NPDES Unit
Central Files
Chris McHugh, by email at mchugh.christopher(c�epa.gov
Page 4 of 4
United States Environmental Protection Agency
E PA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection
1 Ni 2 u 3 I NC0004626 111 121 18/07/25 117
Type
18 L I
I I I I I
Inspector Fac Type
19 I r] 20
211111 1 I I I I I II I I I I I I I I !III 1 1 I I I
I II I I I I I r6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA
67I I 70I I 71 I 172 LJ �,
Reserved
—
731 I 174751 11 1 1 1 1 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
PPG Industries Fiber Glass Products
473 New Jersey Church Rd
Lexington NC 27293
Entry Time/Date
10:00AM 18/07/25
Permit Effective Date
18/01/01
Exit Time/Date
02:OOPM 18/07/25
Permit Expiration Date
22/05/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Darrell Horner/ORC/910-428-9052/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Alan Toney,473 New Jersey Church Rd Lexington NC 27293//336-357-8151/
Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit • Flow Measurement • Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review • Compliance Schedules
Effluent/Receiving Waters Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Kelli A Park WSRO WQ//336-776-9689/
Paul DiMatteo _ WSRO WQ//336-776-9691/
I 11/4-- , 1: t) 1 7
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers
Date
J
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1
NPDES
31 NC0004626 I 1 121
yr/mo/day
18/07/25
I17
Inspection Type
181r1
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page# 2
Permit: NC0004626
Inspection Date: 07/25/2018
Owner - Facility: PPG Industries Fiber Glass Products
Inspection Type: Compliance Evaluation
Compliance Schedules
Is there a compliance schedule for this facility?
Is the facility compliant with the permit and conditions for the review period?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: 2018 permit renewal added a limit and compliance schedule for fluoride. Since March, their
concentration has dropped significantly. The operators explained that fluoride was used in
the boiler system, but that the system was rebuilt in March and no longer uses fluoride. They
hoped this would bring them in compliance with the limit.
Please note that a written status report is due by March 15, 2019, as specified in Part I A(3)
of the Permit.
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
Permit
(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Comment:
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current'?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Yes No NA NE
II ❑ ❑ ❑
▪ ❑ ❑ ❑
Yes No NA NE
❑ ❑ III❑
III ❑ ❑ ❑
❑ • ❑ ❑
• ❑ ❑ ❑
II ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
III ❑ ❑ ❑
•
•
•
•
•
Page# 3
Permit: NC0004626
Inspection Date: 07/25/2018
Owner -Facility: PPG Industries Fiber Glass Products
Inspection Type: Compliance Evaluation
Record Keeping
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility classification?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
Comment: Checked 5/2018 and 7/2017 DMRs. No issues were noted.
Effluent Pipe
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Yes No NA NE
•
• ❑ ❑ ❑
❑ ❑ � ❑
❑ ❑ III ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
▪ ❑ ❑ ❑
❑ ❑ II ❑
Yes No NA NE
❑ ❑ ❑ •
❑ ❑ ❑ •
❑ ❑ ❑ •
Comment: Outfall was not observed during the inspection due to heavy rain and access concerns.
Flow Measurement - Effluent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Yes No NA NE
MODE
• ❑ ❑ ❑
▪ ❑ ❑ ❑
111 ❑ ❑ ❑
Comment: Facility uses a Siemens Sitrans F M Magflo type MAG 5000 flow meter at the effluent. The
meter appears to capture all effluent flow before discharge. The meter was calibrated by
Fortech on 7/7/2018.
Solids Handling Equipment
Is the equipment operational?
Is the chemical feed equipment operational?
Is storage adequate?
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
Is the site free of sludge buildup on belts and/or rollers of filter press?
Is the site free of excessive moisture in belt filter press sludge cake?
Yes No NA NE
• ❑ ❑ ❑
▪ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Page# 4
Permit: NC0004626
Inspection Date: 07/25/2018
Owner - Facility: PPG Industries Fiber Glass Products
Inspection Type: Compliance Evaluation
Solids Handling Equipment Yes No NA NE
The facility has an approved sludge management plan? ❑ ❑ ❑ •
Comment:
Chemical Feed
Is containment adequate?
Is storage adequate?
Are backup pumps available?
Is the site free of excessive leaking?
Comment:
Bar Screens
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Yes No NA NE
III ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ •
• ❑ ❑ ❑
Yes No NA NE
MOOD•
•
III ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: Facility uses 2 screening devices. One fine Hydrosieve Screen is used to filter glass fibers,
and one traditional bar screen captures larger debris. Hydrosieve Screen is run manually on
a schedule.
Grit Removal
Type of grit removal
a.Manual
b.Mechanical
Is the grit free of excessive organic matter?
Is the grit free of excessive odor?
# Is disposal of grit in compliance?
Comment:
Equalization Basins
Is the basin aerated?
Is the basin free of bypass lines or structures to the natural environment?
Yes No NA NE
•
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
❑ ❑ • ❑
• ❑ ❑ ❑
Page# 5
Permit: NC0004626
Inspection Date: 07/25/2018
Owner - Facility: PPG Industries Fiber Glass Products
Inspection Type: Compliance Evaluation
Equalization Basins
Is the basin free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Are audible and visual alarms operable?
# Is basin size/volume adequate?
Comment:
Primary Clarifier
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the sludge blanket level acceptable?
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
Comment:
Secondary Clarifier
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
II ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
1111 ❑ ❑ ❑
IN ❑ ❑ ❑
Yes No NA NE
III El El El
• ❑ ❑ ❑
III El El 0
• ❑ ❑ ❑
III ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
III ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Page# 6
Permit: NC0004626
Inspection Date: 07/25/2018
Owner - Facility: PPG Industries Fiber Glass Products
Inspection Type: Compliance Evaluation
Secondary Clarifier Yes No NA NE
Comment: Sludge blanket measured at approximately 0.75 feet today. Operators said they try to keep
to about 3 feet.
Aeration Basins
Mode of operation
Type of aeration system
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin's surface?
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/I)
Comment:
Yes No NA NE
Ext. Air
Diffused
II ❑ ❑ ❑
• ❑ ❑ ❑
• ❑❑❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ❑ •
❑ ❑ ❑
Filtration (High Rate Tertiary) Yes No NA NE
Type of operation: Down flow
Is the filter media present? •❑ 0 0
Is the filter surface free of clogging? ❑ ❑ ❑ •
Is the filter free of growth? ❑ 0 0 •
Is the air scour operational? 0 0 • 0
Is the scouring acceptable? 0 0 • 0
Is the clear well free of excessive solids and filter media? 0 0 • 0
Comment: 2 activated carbon filtration chambers. Operators said they replaced media in one chamber
recently, and plan to do the next one sometime in August.
Disinfection -Liquid
Is there adequate reserve supply of disinfectant?
(Sodium Hypochlorite) Is pump feed system operational?
Is bulk storage tank containment area adequate? (free of leaks/open drains)
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de -chlorination?
Comment:
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
▪ ❑ ❑ ❑
❑ ❑ ❑ •
• ❑ ❑ ❑
❑ ❑ ❑•
Page# 7
Permit: NC0004626
Owner - Facility: PPG Industries Fiber Glass Products
Inspection Date: 07/25/2018 Inspection Type: Compliance Evaluation
De -chlorination
Type of system ?
Is the feed ratio proportional to chlorine amount (1 to 1)?
Is storage appropriate for cylinders?
# Is de -chlorination substance stored away from chlorine containers?
Comment:
Are the tablets the proper size and type?
Are tablet de -chlorinators operational?
Number of tubes in use?
Comment:
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Yes No NA NE
Liquid
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ • ❑
• ❑ U ❑
Yes No NA NE
❑• ❑ ❑
▪ ❑ ❑ ❑
❑ • ❑ ❑
• ❑ ❑ ❑
III ❑ ❑ ❑
❑ III ❑ ❑
Comment: During the inspection we discovered that the effluent composite sampler was not setup
correctly and the sample lug was overflowing. The operators said that the sample was
started at around 8:00 am that morning, and the sample lug held approximately 10 litres.
Composite sampler was set to take a 50 ml sample every 6 pulses, but the operators did
not know how many gallons constituted one pulse. Operators said they would contact
Siemens to help determine the pulse volume, and that they would set the sampler correctly.
They also said that they would not analyze the sample from that day; that they would start
the composite sampler again the next day.
Upstream / Downstream Sampling
Is the facility sampling performed as required by the permit (frequency, sampling type, and
sampling location)?
Comment: Operators reported that the upstream sampling point was at Sam Sharpe Road.
Laboratory
Are field parameters performed by certified personnel or laboratory?
Are all other parameters(excluding field parameters) performed by a certified lab?
Yes No NA NE
• ❑ ❑ ❑
Yes No NA NE
▪ ❑ ❑ ❑
• ❑ ❑ ❑
Page# 8
Permit: NC0004626
Inspection Date: 07/25/2018
Owner - Facility: PPG Industries Fiber Glass Products
Inspection Type: Compliance Evaluation
Laboratory Yes No NA NE
# Is the facility using a contract lab? 0 • 0 0
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 0 0 •
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ ❑ •
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ ❑
Comment:
Standby Power
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Was generator tested & operational during the inspection?
Do the generator(s) have adequate capacity to operate the entire wastewater site?
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
Is the generator fuel level monitored?
Comment:
Yes No NA NE
▪ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ❑ 11
• ❑ ❑ ❑
❑ ❑ ❑ •
❑ ❑ ❑ •
Page# 9
II
S,p
N io FRTjpi'Ser��•
rZ> por �rtesric'f 0 M e rM
Z as9fro,. ai/O,,?k 411
oZ "'Volk
�N°i')ati C0k,_
T
N Sit ce C,
�Or W °V
tL ebsit `�~a9e
postage IA,
Pl e et A
O�� (Fnd Oeorn eniredFee S+t4ettt '4sps c°s-iae4J
me eee/ *Con,
� et pe
� (nabrnetee O/i ee9u r d� tiG
ryF V
N s Iota/postage Re9uirery� �3.Z z0(a'_
y e4rTo plan 76
poStm NC-
�� os�Pei.--- Fleet riey tJ :el'
jbe"Of4;: iiC
cr,. ox,yo ... 4j3 iv Glass F
•PS Form are aiax. L
e
k/ngton Jersey Cer'1 h7eri
38p0 Au9ust2 po NC2y�-,reh RD�a<<C
s
See Reverse to"ths
truCtiens
SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY
• Complete items 1,2,and 3. A. Signature
• Print your name and address on the reverse X •
h ❑Agent
so that we can return the card to you. �,l Q ,(�, �� ❑Addressee
4t
• Attach this card to the back of the mailpiece, B. Received by(Printed Name) C. ate of Delivery
or on the front if space permits. V\� f o f
1. Article Addressed to: gwelC(� e `1 1
D. Is el a l;�."'-n ? ❑Yes
All'.n Toney If YES,enter gici �r ess below: 0 No
Electric Glass Fiber America LLC R''
473 New Jersey Church Road rtv3 I 202
Lexington, NC 27293 Winston-Salem
Regional nffirp
11111111111111111
II1111111111111I I1II II III I I 1111 I'll II I II II III 3.0 Adult Signature ❑RegisteredExpress®
MaiIT^+
❑Adult Signature Restricted Delivery ❑Registered Mail Restricted
9590 9402 2546 6306 9697 12 ^.y-�yCertified Mail® Delivery
/L7 Certified Mail Restricted Delivery 0 Return Receipt for
❑Collect on Delivery Merchandise
0 Collect on Delivery Restricted Delivery 0 Signature ConfirmationrM
7 013 1710 0002 19 2 2 211 La ❑Insured Mail ❑Signature Confirmation
0 Insured Mail Restricted Delivery Restricted Delivery
(over$500)
PS Form 3811,July 2015 PSN 7530-02-000-9053 Domestic Return Receipt
MONITORING REPORT(MR) VIOLATIONS for:
Report Date: 12/08/21 Page 1 of 1
Permit: NC0004626 MRs Betweei 1 - 2017 and12 - 2021 Region: % Violation Category:% Program Category:
Facility Name: % Param Nam( % County: % Subbasin: % Violation Action:
Major Minor: %
PERMIT: NC0004626
FACILITY: Electric Glass Fiber America LLC - PPG Industries Fiber
Glass Products, Inc.
COUNTY: Davidson REGION: Winston-Salem
Limit Violation
MONITORING UNIT OF
OUTFALL LOCATION PARAMETER VIOLATION FREQUENCY
REPORT DATE MEASURE
LIMIT
CALCULATED %
VALUE Over
VIOLATION TYPE VIOLATION ACTION
09-2017 001 Effluent Coliform, Fecal MF, MFC 09/14/17 2 X month #/100m1 400 8,700 2,075 Daily Maximum Proceed to NOD
Broth, 44.5 C Exceeded
Monitoring Violation
MONITORING VIOLATION UNIT OF CALCULATED
REPORT OUTFALL LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION
01 -2018 001 Effluent Chlorine, Total Residual 01/31/18 2 X month ug/I Frequency Violation No Action, BPJ
02-2018 001 Effluent Chlorine, Total Residual 02/28/18 2 X month ug/I Frequency Violation No Action, BPJ
01-2018 001 Effluent Fluoride, Total (as F) 01/31/18 Monthly mg/I Frequency Violation No Action, Facility
Reporting Error
Electric Glass Fiber America
NC0004626
Freshwater RPA -
Qw (MGD) = 0.6000
1Q10S(cfs)= 0.84
7Q1OS (cfs) = 1.00
7Q1OW (cfs) = 2.20
30Q2 (cfs) = NO 30Q2 DATA
Avg. Stream Flow, QA (cfs) = 11.00
Receiving Stream: North Potts Creek
95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
WWTP/WTP Class:
IWC% @ 1Q10S = 52.54237288
IWC% @ 7Q10S = 48.1865285
IWC% @ 7Q1 OW = 29.71246006
IWC%@, 30Q2 = N/A
IW%C @ QA = 7.795473596
Stream Class: C
Outfall 001
Qw = 0.6 MGD
COMBINED HARDNESS (mg/L)
Acute = 109.79 mg/L
Chronic = 105.31 mg/L
PARAMETER
TYPE
NC STANDARDS OR EPA CRITERIA
_1r
°
m
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
Chronic Stanpdard Acute
n # Det. Max Pred Cw Allowable Cw
Arsenic
Arsenic
C
C
150 FW(7Q10s) 340
10 HH/WS(Qavg)
ug/L
ug/L
0 0
N/A
Acute (FW): 647.1
Chronic (FW): 311.3
Chronic (Hi): 128.3
Beryllium
NC
6.5 FW(7Q10s) 65
ug/L
0 0
N/A
Acute: 123.71
-- _ _ _ ----- _ _ ------------------------------
Chronic: 13.49
Cadmium
NC
1.7473 FW(7Q10s) 11.7724
ug/L
3 0
Note: n < 9
Limited data set
1.500
C.V. (default)
NO DETECTS
Acute: 22.405
_ _ _ _ _ _ _
Chronic: 3.626
Max MDL = 1
_ _ _ _ _ _ _ _ _ _ _ _ _ _
Chlorides
NC
230 FW(7Q10s)
mg/L
0 0
N/A
Acute: NO WQS
_ _ _
-- Chronic:-----477.3------------------------------
Chlorinated Phenolic Compounds
NC
1 A(30Q2)
ug/L
0 0
N/A
Acute: NO WQS
-- Chronic:-----IWC?------------------------------
Total Phenolic Compounds
NC
300 A(30Q2)
ug/L
0 0
N/A
Acute: NO WQS
-- Chronic:-----IWC?------------------------------
Chromium III
NC
382.2848 FW(7Q10s) 3040.8791
µg/L
0 0
N/A
Acute: 5,787.5
— _ Chronic:------3 ------------------------------
_ _ 79
Chromium VI
NC
11 FW(7Q10s) 16
µg/L
0 0
N/A
Acute: 30.5
-- _ _ _ ----- _ _ ------------------------------
Chronic: 22.8
Chromium, Total
NC
µg/L
0 0
N/A
Copper
NC
26.9292 FW(7Q10s) 42.2194
ug/L
17 11
29.73
Acute: 80.35
___ _ _______ ____
Chronic: 55.89
_ _ _ ___ _ _ _ _ _
No RP Predicted Max >_ 50 % of Allowable Cw
Page 1 of 3
NC0004626_RPA, rpa
3/22/2022
Electric Glass Fiber America
NC0004626
Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
Outfall 001
Qw = 0.6 MGD
No value > Allowable Cw
apply Quarterly Monitoring
Cyanide
NC
5
FW(7Q10s)
22
10
ug/L
0
0
N/A
Acute: 41.9
------------------------------
Fluoride
NC
1800
FW(7Q10s)
ug/L
49
49
22,089.0
Acute: NO WQS
___ _ _____ _ _ ___
Chronic: 3,735.5
3 value(s) > Allowable Cw
_ _ _ _ _ ___ _ _ _ _ ___
RP shown - apply Monthly Monitoring with Limit
Lead
NC
14.4771
FW(7Q10s)
388.7105
ug/L
0
0
N/A
Acute: 739.804
-- _ _ _ ----_
Chronic:-30.044 -----------------------------
Mercury
NC
12
FW(7Q10s)
0.5
ng/L
0
0
N/A
Acute: NO WQS
------------------------------
Molybdenum
NC
2000
HH(7Q10s)
ug/L
0
0
N/A
Acute: NO WQS
_ _ _ _ _
-- Chronic:---- 4,150.5 -----------------------------
Nickel
Nickel
NC
NC
125.6786
25.0000
FW(7Q10s)
WS(7Q10s)
1172.1347
µg/L
µg/L
0
0
N/A
Acute (FW): 2,230.8
_ _ _ _
Chronic (FW): 260.8
Chronic (WS): 51.9
— — —
Selenium
NC
5
FW(7Q10s)
56
ug/L
43
0
5.4
NO DETECTS
Acute: 106.6
Chronic: 10.4
Max MDL = 10
No RP , Predicted Max >_ 50% of Allowable Cw -
apply Quarterly Monitoring
Silver
NC
0.06
FW(7Q10s)
3.7774
ug/L
0
0
N/A
Acute: 7.189
-- Chronic:-----0.125------------------------------
Zinc
NC
428.6039
FW(7Q10s)
440.4037
ug/L
0
0
N/A
Acute: 838.2
— — — — — — — — —
Chronic: 889.5
— — — — — — — — — — — — —
0
0
N/A
Acute:
-- _ _ _ --------------------------------------
Chronic:
0
0
N/A
Acute:
_ _ _
Chronic:
0
0
N/A
Acute:
_ _ _
Chronic:
0
0
N/A
Acute:
Page 2 of 3
NC0004626_R PA, rpa
3/22/2022
Permit No. NC0004626
NPDES Implementation of Instream Dissolved Metals Standards - Freshwater Standards
The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by the NC
Environmental Management Commission (EMC) on November 13, 2014. The US EPA subsequently
approved the WQS revisions on April 6, 2016, with some exceptions. Therefore, metal limits in draft
permits out to public notice after April 6, 2016 must be calculated to protect the new standards as approved.
Table 1. NC Dissolved Metals Water Quality Standards/Aquatic Life Protection
Parameter
Acute FW, 14/1
(Dissolved)
Chronic FW, 14/1
(Dissolved)
Acute SW, 14/1
(Dissolved)
Chronic SW, 14/1
(Dissolved)
Arsenic
340
150
69
36
Beryllium
65
6.5
---
---
Cadmium
Calculation
Calculation
40
8.8
Chromium III
Calculation
Calculation
---
---
Chromium VI
16
11
1100
50
Copper
Calculation
Calculation
4.8
3.1
Lead
Calculation
Calculation
210
8.1
Nickel
Calculation
Calculation
74
8.2
Silver
Calculation
0.06
1.9
0.1
Zinc
Calculation
Calculation
90
81
Table 1 Notes:
1. FW= Freshwater, SW= Saltwater
2. Calculation = Hardness dependent standard
3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life standards
for Mercury and selenium are still expressed as Total Recoverable Metals due to bioaccumulative
concerns (as are all human health standards for all metals). It is still necessary to evaluate total
recoverable aquatic life and human health standards listed in 15A NCAC 2B.0200 (e.g., arsenic at
10 µg/1 for human health protection; cyanide at 5 µg/L and fluoride at 1.8 mg/L for aquatic life
protection).
Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A
NCAC 02B .021 Sub naraeranh (111(dl
Metal
NC Dissolved Standard, µg/I
Cadmium, Acute
WER*{1.1366724ln hardness](0.041838)} - e^{0.9151 [ln hardness]-3.1485}
Cadmium, Acute Trout waters
WER*{1.136672-[ln hardness](0.041838)} - e^{0.9151[ln hardness]-3.6236}
Cadmium, Chronic
WER*{1.101672-[ln hardness](0.041838)} - e^{0.7998[In hardness]-4.4451}
Chromium III, Acute
WER*0.316 - e^{0.8190[ln hardness]+3.7256}
Chromium III, Chronic
WER*0.860 • e^{0.8190[ln hardness]+0.6848}
Copper, Acute
WER*0.960 • e^{0.9422[ln hardness]-1.700}
Copper, Chronic
WER*0.960 • e^{0.8545[ln hardness]-1.702}
Lead, Acute
WER* {1.46203-[ln hardness](0.145712)} • e^{1.273[ln hardness]-1.460}
Lead, Chronic
WER*{1.46203-[ln hardness](0.145712)} • e^{1.273[ln hardness]-4.705}
Nickel, Acute
WER*0.998 • e^{0.8460[ln hardness]+2.255}
Nickel, Chronic
WER*0.997 • e^{0.8460[ln hardness]+0.0584}
Silver, Acute
WER*0.85 • e^{1.72[ln hardness]-6.59}
Silver, Chronic
Not applicable
Zinc, Acute
WER*0.978 • e^{0.8473[ln hardness]+0.884}
Zinc, Chronic
WER*0.986 • e^{0.8473[ln hardness]+0.884}
Page 1 of 4
Permit No. NC0004626
General Information on the Reasonable Potential Analysis (RPA)
The RPA process itself did not change as the result of the new metals standards. However, application of
the dissolved and hardness -dependent standards requires additional consideration in order to establish the
numeric standard for each metal of concern of each individual discharge.
The hardness -based standards require some knowledge of the effluent and instream (upstream) hardness
and so must be calculated case -by -case for each discharge.
Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR 122.45(c). The
discharge -specific standards must be converted to the equivalent total values for use in the RPA
calculations. We will generally rely on default translator values developed for each metal (more on that
below), but it is also possible to consider case -specific translators developed in accordance with established
methodology.
RPA Permitting Guidance/WOBELs for Hardness -Dependent Metals - Freshwater
The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern,
based on recent effluent data, and calculate the allowable effluent concentrations, based on applicable
standards and the critical low -flow values for the receiving stream.
If the maximum predicted value is greater than the maximum allowed value (chronic or acute), the discharge
has reasonable potential to exceed the standard, which warrants a permit limit in most cases. If monitoring
for a particular pollutant indicates that the pollutant is not present (i.e. consistently below detection level),
then the Division may remove the monitoring requirement in the reissued permit.
1. To perform a RPA on the Freshwater hardness -dependent metals the Permit Writer compiles the
following information:
• Critical low flow of the receiving stream, 7Q10 (the spreadsheet automatically calculates
the 1Q10 using the formula 1Q10 = 0.843 (s7Q10, cfs) 0.993
• Effluent hardness and upstream hardness, site -specific data is preferred
• Permitted flow
• Receiving stream classification
2. In order to establish the numeric standard for each hardness -dependent metal of concern and for
each individual discharge, the Permit Writer must first determine what effluent and instream
(upstream) hardness values to use in the equations.
The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test results for any
hardness data and contacts the Permittee to see if any additional data is available for instream
hardness values, upstream of the discharge.
If no hardness data is available, the permit writer may choose to do an initial evaluation using a
default hardness of 25 mg/L (CaCO3 or (Ca + Mg)). Minimum and maximum limits on the hardness
value used for water quality calculations are 25 mg/L and 400 mg/L, respectively.
If the use of a default hardness value results in a hardness -dependent metal showing reasonable
potential, the permit writer contacts the Permittee and requests 5 site -specific effluent and upstream
hardness samples over a period of one week. The RPA is rerun using the new data.
The overall hardness value used in the water quality calculations is calculated as follows:
Combined Hardness (chronic)
= (Permitted Flow, cfs *Avg. Effluent Hardness, mg/L) + (s7Q10, cfs *Avg. Upstream Hardness, mg/L)
(Permitted Flow, cfs + s7Q10, cfs)
The Combined Hardness for acute is the same but the calculation uses the 1Q10 flow.
Page 2 of 4
Permit No. NC0004626
3. The permit writer converts the numeric standard for each metal of concern to a total recoverable
metal, using the EPA Default Partition Coefficients (DPCs) or site -specific translators, if any have
been developed using federally approved methodology.
EPA default partition coefficients or the "Fraction Dissolved" converts the value for
dissolved metal at laboratory conditions to total recoverable metal at in -stream
ambient conditions. This factor is calculated using the linear partition coefficients
found in The Metals Translator: Guidance for Calculating a Total Recoverable
Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996) and the
equation:
Cdiss = 1
Ctotal 1 + /KPA] [SSct+a)] /10 61
Where:
ss = in -stream suspended solids concentration [mg/1], minimum of 10 mg/L used,
and
Kpo and a = constants that express the equilibrium relationship between dissolved
and adsorbed forms of metals. A list of constants used for each hardness -dependent
metal can also be found in the RPA program under a sheet labeled DPCs.
4. The numeric standard for each metal of concern is divided by the default partition coefficient (or
site -specific translator) to obtain a Total Recoverable Metal at ambient conditions.
In some cases, where an EPA default partition coefficient translator does not exist (ie. silver), the
dissolved numeric standard for each metal of concern is divided by the EPA conversion factor to
obtain a Total Recoverable Metal at ambient conditions. This method presumes that the metal is
dissolved to the same extent as it was during EPA's criteria development for metals. For more
information on conversion factors see the June, 1996 EPA Translator Guidance Document.
5. The RPA spreadsheet uses a mass balance equation to determine the total allowable concentration
(permit limits) for each pollutant using the following equation:
Ca = (s7Q10 + Qw) (Cwqs) — (s7Q10) (Cb)
Qw
Where: Ca = allowable effluent concentration (µg/L or mg/L)
Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L)
Cb = background concentration: assume zero for all toxicants except NH3* (µg/L or mg/L)
Qw = permitted effluent flow (cfs, match s7Q10)
s7Q10 = summer low flow used to protect aquatic life from chronic toxicity and human
health through the consumption of water, fish, and shellfish from noncarcinogens (cfs)
* Discussions are on -going with EPA on how best to address background concentrations
Flows other than s7Q10 may be incorporated as applicable:
1Q10 = used in the equation to protect aquatic life from acute toxicity
QA = used in the equation to protect human health through the consumption of water,
fish, and shellfish from carcinogens
30Q2 = used in the equation to protect aesthetic quality
6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant of concern.
Data entered must have been taken within four and one-half years prior to the date of the permit
application (40 CFR 122.21). The RPA spreadsheet estimates the 95th percentile upper
Page 3 of 4
Permit No. NC0004626
concentration of each pollutant. The Predicted Max concentrations are compared to the Total
allowable concentrations to determine if a permit limit is necessary. If the predicted max exceeds
the acute or chronic Total allowable concentrations, the discharge is considered to show reasonable
potential to violate the water quality standard, and a permit limit (Total allowable concentration) is
included in the permit in accordance with the U.S. EPA Technical Support Document for Water
Quality -Based Toxics Control published in 1991.
7. When appropriate, permit writers develop facility specific compliance schedules in accordance
with the EPA Headquarters Memo dated May 10, 2007 from James Hanlon to Alexis Strauss on 40
CFR 122.47 Compliance Schedule Requirements.
8. The Total Chromium NC WQS was removed and replaced with trivalent chromium and hexavalent
chromium Water Quality Standards. As a cost savings measure, total chromium data results may
be used as a conservative surrogate in cases where there are no analytical results based on chromium
III or VI. In these cases, the projected maximum concentration (95th %) for total chromium will be
compared against water quality standards for chromium III and chromium VI.
9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge, are inserted
into all permits with facilities monitoring for hardness -dependent metals to ensure the accuracy of
the permit limits and to build a more robust hardness dataset.
10. Hardness and flow values used in the Reasonable Potential Analysis for this permit included:
Parameter
Value
Comments (Data Source)
Average Effluent Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
158.61 mg/L
Calculated in RPA with DMR data
Average Upstream Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
55.74 mg/L
Calculated in RPA with DMR data
7Q10 summer (cfs)
1
NPDES Files
1Q10 (cfs)
0.84
Calculated in RPA
Permitted Flow (MGD)
0.6
NPDES Files
Date: 2/03/2022
Permit Writer: Julia Byrd
Page 4 of 4
NH3/TRC WLA Calculations
Facility: Electric Glass Fiber America, LLC
PermitNo. NC0004626
Prepared By: Julia Byrd
Enter Design Flow (MGD):
Enter s7Q10 (cfs):
Enter w7Q10 (cfs):
0.6
1
2.2
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/I)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
Upstream Bkgd (ug/I)
IWC (%)
Allowable Conc. (ug/I)
Fecal Coliform
Monthly Average Limit:
(If DF >331; Monitor)
(If DF<331; Limit)
Dilution Factor (DF)
1
0.6
0.93
17.0
0
48.19
35
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/I)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/I)
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/I)
w7Q10 (CFS)
200/100m1 DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
2.08 Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/I)
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/I, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals)
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis)
If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed
1
0.6
0.93
1.0
0.22
48.19
1.8
2.2
0.6
0.93
1.8
0.22
29.71
5.5
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)
LOCALiQ
PO Box 631245 Cincinnati, OH 45263-1245
StarNews I The Dispatch
Times-News
Public Notice
PROOF OF PUBLICATION North Carolina Environ-
mental Management
Commission/NPDES Unit
Ncdenr/Dwq/Npdes 1617 Mail Service Center
RC
Wren Thedford Notice eofhInt nt76o9-1617 Issue a
Ncdenr/Dwq/Npdes NPDES at NC0004626 Wastewater
Industries
1617 Mail Service Center Fiber Glass Products, Inc.
Ralei h NC 27699 The North Carolina Environ-
Raleigh Management
Commission proposes to
issue a NPDES wastewater
discharge permit to the
STATE OF NORTH CAROLINA, COUNTY OF DAVIDSON Person(s) listed below. Writ-
ten comments regarding the
proposed permit will be
The Lexington Dispatch,a newspaper printed and published in the accepted until 30 days after
the city of Lexington,and of general circulation in the County of notice.uThe Directorblish of the
Davidson,State of North Carolina,and personal knowledge of the NC Division of Water
facts herein state and that the notice hereto annexed was Resources (DWR) may hold
a public hearing should there
Published in said newspapers in the issue dated: be a significant degree of
public interest. Please mail
comments and/or informa-
02/25/2022 Lion requests to DWR at the
above address. Interested
persons may visit the DWR
and that the fees charged are legal. at 512 N. Salisbury Street,
Sworn to and subscribed before on 02/25/2022 Raleigh, NC 27604 to review
information on file. Addi-
tional information on NPDES
permits and this notice may
be found on our website:
http://deq.nc.gov/about/divisi
ons/water-resources/wate r-
resources-perm its/waste-
water-branch/npdes-waste-
water/public-notices,or by
calling (919) 707-3601. Elec-
tric Gloss Fiber America,
LLC, Lexington, NC Plant [
/ + 473 New Jersey Church Rd,
Lexington NC 27292] has
requested renewal of NPDES
permit NC0004626 for its
Legal Clerk l Lexington Wastewater Treat-
ment Plant, located in
Davidson County. This
permitted facility discharges
Notary,State of WI, of Bro treated domestic and Indus-
14 •
trial wastewater to North
Potts Creek, a class C water
in the Yadkin-Pee Dee River
My commision expires Basin. Some of the parame-
ters in the permit are water
Publication Cost: $114.03 quality limited. This
discharge may affect future
Order No: 6961450 #of Copies: allheocations YadkinPee Dee Riin this ver.ent of
Customer No: 510641 1 2n5 2022
PO#:
TFIIS IS NOT AN INVOICE!
Please do not use this form for payment remittance.
VICKY FELTY
Notary Public
State of Wisconsin
•
1-'1 Page 1 of 1
Terry Steinert,Environmental Manager
E Nippon Electric Glass T:704-434-2261 ext.22007
Electric Glass Fiber America,LLC Email: terry.steinert(@neo-us.com
473 New Jersey Church Rd,Lexington, NC 27292
via Federal Express March 16, 2022
Julia Byrd
NC DEQ DWR NPDES Industrial Permitting Unit
512 North Salisbury St.
1617 Mail Service Center RECEIVED
Raleigh, NC 27699-1617
!' =‘.R 21 2022
Re: Electric Glass Fiber America, LLC
Draft NPDES Permit No. NC0004626 NCDEQIDWRINPDES
Dear Ms. Byrd,
Electric Glass Fiber America, LLC (EGFA) has received a draft NPDES permit for the EGFA facility located
at 473 New Jersey Church Road in Lexington, NC (Davidson County). Thank you for the prompt issuance
of this draft and the opportunity to review. EGFA has these comments on the draft permit:
1. The cover letter and permit are addressed to Ms. Brigette Tinsley. Ms.Tinsley no longer works
at EGFA. Per the permit application, please address future correspondence to me.
2. On the list of equipment comprising the wastewater treatment facility,the dual activated
carbon adsorption units with pH adjustment were taken out of service with DEQ approval prior
to 2021 and so noted on the permit renewal application form.
3. Cadmium is not currently a parameter that is monitored at the EGFA Lexington facility. On the
permit renewal application, EGFA indicated cadmium was "believed absent." The second bullet
of your cover letter indicates there has been previous analysis at a quantitation level of 1.0
mg/L. EGFA does not analyze cadmium in the effluent and does not know what the quantitation
statement is based on. EGFA respectfully requests that cadmium monitoring be eliminated from
the permit as the parameter is not believed to be present.
4. Dissolved Oxygen (DO) monitoring is listed as composite sampling. According to approved
procedures for DO monitoring at
Approved Procedure for the Analysis of Dissolved Oxygen FINAL 04 07 2020.pdf(nc.gov),
the hold time for DO samples is 15 minutes,thereby precluding composite sampling.
5. The footnotes in the table in Part I.A on page 3 indicate that cadmium and copper sampling
should be completed concurrently with hardness sampling. However,the same footnote (4) is
used in reference to chronic toxicity sampling. It appears the footnote for chronic toxicity
sampling should be (5).
6. The cover letter refers to changes in the Chronic Toxicity wording, but no wording changes were
identified in the draft permit. Are changes proposed or will the wording in the draft permit be
used when the permit is issued?
Again,thank you fort is opportunity to comment. If you have any questions abot t these comments or
need additional information, please contact me at 704.434.2261 x22007 or terry.steinert@neg-us.com.
Kindest R gar,
c.
%T Steinert, Environmental Manager