NC0003875_Permit (Issuance)_20100910

NPDES DOCWdENT SCANNINC COVER SHEET
NPDES Permit:
NC0003875
Elementis Chromium WWTP
Document Type:
Permit Issuance )
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Staff Comments
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
September 10, 2010
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ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
•
Mr. Howard W. Morris
Site Manager
Elementis Chromium
5408 Holly Shelter Road
Castle Hayne, NC 28429
Dear Mr. Morris:
September 10, 2010
Subject: NPDES Permit Renewal
Permit NC0003875
Elementis Chromium
New Hanover County
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum
of Agreement between North Carolina and the U.S. Environmental Protection Agency dated October
15, 2007 (or as subsequently amended).
There is one change to this permit from the draft:
• Effluent Guideline limits for Total Suspended Solids, Hexavalent Chromium, Total
Chromium and Total Nickel have been set back to the limits on your previous permit. This is
due to the Northeast Cape Fear River classification as Primary Nursery Area, which is
automatically rated as High Quality Water. This causes very stringent requirements on Total
Suspended Solids increases.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within
thirty (30) days following receipt of this letter. This request must be in the form of a written
petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the
Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714).
Unless such demand is made, this decision shall be final and binding.
1617 Mail Service Centel. Raleigh, North Carolina 27699.161 -
Location: 512 N. Salisbury St. Raleigh. North Carolina 27 ;04
. Phone: [phone] ' FAX: [phone] \ Customer Service: -1177 ,':.: ;-e! 48 ,
Internet: www.ncwaterqu litv.org .
An Equal Opportunity \ AIPi!r-alive Action Employer
NorthCarol ina
Naturallij

Please note that this permit is not transferable except after notice to the Division. The Division may,.
require modification or revocation and reissuance of the permit. This permit does not affect the
legal requirements to obtain other permits which may be required by the Division of Water Quality
or permits required by the Division of Land Resources, the Coastal Area Management Act or any
other Federal or Local governmental permit that may be required. If you have any questions
concerning this permit, please contact Jim McKay at telephone number [phone].
Sin erely,
i�
een H. Sullins, Director
'Division of Water Quality
cc: NPDES files
Central files
Wilmington Regional Office - Surface Water Protection - via email
Aquatic Toxicology Unit - via emgii
EPA Region IV, with Fact Sheet and RPA
Sean Coury - via email (Sean.Coury®elementis.com)
1G 17 Mail Se vi, '.;rater. Raleigh. North Carolina 27699-1617
Location: 112 N. S>nisbuiy SI. Raleigh, North Carolina 27604
Phone: [phone]-i'.400 ; FAX: [phone] Customer Service: 1.877.123-67 48
Internet: www.iv'1/4:•ii-iiiNtliliility.Org
Ar. Equal Oppoi:: i , A i•mative Action Employer
One
NorthCarolina.
Naturally

Permit NC0003875
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision 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,
Elementis Chromium, LP
is hereby authorized to discharge wastewater from a facility located at the
Castle Hayne Plant
5408 Holly Shelter Road (NCSR 1002) -
Northeast of Castle Hayne
New Hanover County
to receiving waters designated as the Northeast Cape Fear River in the Cape Fear
River Basin
in accordance with effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective October 1, 2010.
This permit and authorization to discharge shall expire at midnight on January 31, 2013.
Signed this day September 9, 20-10. --
en H. Sullins, Director
&/' Division of Water Quality
By Authority of the Environmental Management Commission
4 ,

Permit NC0003875 •
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or
discharge are hereby revoked. As of this permit issuance, any previously issued
• permit bearing this number is po longer effective. Therefore, the exclusive a ithority
to operate and discharge from this facility arises under the permit conditions,
requirements, terms, and provisions included herein.
Elementis Chromium LP is hereby authorized to:
1. Continue to operate the existing process wastewater treatment facility
consisting of a storage tank, six (6) batch reactors, recirculation/equalization
tank, a series of three (3) hydrocyclones followed by a series of three (3)
polymer feed systems/thickeners and clarifiers, pressure sand filters and
optional sulfur dioxide feed with discharge through outfall 001, and,
2. Continue to operate the domestic wastewater treatment facility consisting of
dual train extended aeration package plants with effluent disinfection by
tablet chlorination with discharge through outfall 002, and,
3. After receiving an Authorization to Construct from the Division, to install
dechlorination equipment to the domestic wastewater treatment facility, and,
4. Discharge the flow from outfalls 001 and 002 from said treatment works at
the location specified on the attached map into the Northeast Cape Fear River,
classified B, Swamp, Primary Nursery Area, High Quality Water in the Cape
Fear River Basin.

Permit NC0003875
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Permit NC0003875
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is
authorized to discharge treated industrial wastewater from outfall 001. Such discharges shall be limited and
monitored by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
l
Monthly Average
Daily Maximum
Measurement
Frequency
Sample
Type
Sample Location
Flow
0.785 MGD
Continuous
Recording
Influent or Effluent
BOD, 5-day (20°C)
Weekly
Composite
Effluent
Total Suspended Solids (TSS)
117.11 lbs./day
234.22 lbs./day
Weekly
Composite
Effluent
Hexavalent Chromiumi
0.27 lbs./day
0.48 lbs./day
Weekly
Composite
Effluent
Total Chromium
2.34 lbs./day
4.68 lbs./day
Weekly
Composite
Effluent
Total Nickel
1.81 lbs./day
3.62 lbs./day
Weekly
Composite
Effluent
Temperature (°C)
Weekly
Grab
Effluent
Total Mercury 2
Quarterly
Grab
Effluent
Total Nitrogen (NO2 + NO3 + TKN)
_
Quarterly
Composite
Effluent
Total Phosphorus
Quarterly
Composite
Effluent
Chronic Toxicity 3
Quarterly
Composite
Effluent
Total Copper
Quarterly
Composite
Effluent
Total Zinc
Quarterly
Composite
Effluent
Total Selenium
Quarterly
Composite
Effluent
Total Silver
Quarterly
Composite
Effluent
Chloride
Weekly
Composite
Effluent
PH 4
_
Weekly
Grab
Effluent
Notes:
1. A composite sample may be used if the sample is analyzed within 24 hours of the first sample
portion collected.
2. Testing for mercury shall be by EPA low level method 1631E, using clean sampling technique.
3. Whole Effluent Toxicity (WET) shall be measured by chronic toxicity (Ceriodaphnia dubia)
Pass/Fail at 4.6% - tests shall be conducted in February, May, August and November. See Part
A. (3.) for details. Toxicity testing shall be done in conjunction with quarterly metals testing.
4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN
TRACE AMOUNTS.

Permit NC0003875
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — FINAL
During the period beginning on the effective date of this permit and lasting until expiration. the Permittee is
authorized to discharge treated domestic wastewater from internal outfall 002. Such discharges shall be limited
and monitored by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly Average
Daily
Maximum
Measurement
Frequency
Sample Type
Sample Location1
Flow
0.020 MGD
Weekly
Instantaneous
Influent or Effluent
BOD, 5-day (20°C)
30.0 mg/L
45.0 mg/L
Weekly
Grab
Effluent
Total Suspended Solids (TSS)
30.0 mg/L
45.0 mg/L
Weekly
Grab
Effluent
Ammonia Nitrogen •
2/Month
Grab
Effluent
Dissolved Oxygen 2
Weekly
Grab
Effluent, Upstream,
Downstream
Fecal Coliform (geometric mean)
200/100 mL
400/ 100 mL
Weekly
Grab
Effluent
Total Residual Chlorine 3
28 ug/ L
2/Week
Grab
Effluent
Temperature (2C)
Daily
Grab
Effluent, Upstream,
Downstream
Conductivity
Weekly
Grab
Upstream,
Downstream
Salinity
Weekly
Grab
Upstream,
Downstream
pH 4
Weekly
Grab
Effluent
Notes:
1. Sample locations: Upstream: Upstream of the outfall (at least 100 yards) at the nearest
accessible point, Downstream: Downstream at HWY 117 bridge at Castle Hayne. Instream
monitoring is waived by Memorandum of Agreement between the permittee and the Lower
Cape Fear River Monitoring Program. Should the permittee's membership in this coalition
terminate at any time, the permittee shall notify the Division immediately in writing and
immediately resume instream monitoring as set in this permit.
2. The daily average dissolved oxygen concentration of the effluent shall not be less than 5.0
mg/L.
3. TRC limit and monitoring are only required if chlorine or chlorine derivatives are used for
disinfection. The TRC limit will become effective April 1, 2012. Monitoring and reporting is
required beginning with the permit effective date. The facility shall report all effluent TRC
values reported by a NC certified laboratory, including field certified. However, effluent values
below 50 ug/ L will be treated as zero for compliance purposes.
4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN
TRACE AMOUNTS.

Permit NC0003875
A. (3.) CHRONIC TOXICITY PASS/FAIL LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 4.6%.
The permit holder shall perform at a minimum, Quarter[tj monitoring using test procedures outlined in the
"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure." Revised February 1998, or subsequent
versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or
subsequent versions. The tests will be performed during the months of February, May, August and November.
Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all
treatment processes. '
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit
limit, then multiple -concentration testing shall be performed at a minimum. in each of the two following months
as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February
1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that
does have a detectable impairment of reproduction or survival. The definition of "detectable impairment,"
collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase
II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the .parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required.
the Permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No
Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at
the address cited above.
Should the Permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0003875
Facility Information
Applicant/Facility
Name:
Elementis Chromium Corporation - Castle Hayne Plant
Applicant Address:
5408 Holly Shelter Road; Castle Hayne, North Carolina 282,
Facility Address:
5408 Holly Shelter Road; Castle Hayne, North Carolina 282,
Permitted Flow
0.785 MGD (001)
Type of Waste:
Industrial (001) and domestic (002)
Facility/Permit Status:
Class II (physical chemical) and Class II (biological)/Active;
Renewal
Primary SIC Code: 2819
County:
New Hanover County
Miscellaneous
Receiving Stream:
Northeast Cape
Fear River
Regional Office:
Wilmington
(WiRO)
Stream Classification:
B,Swamp,PNA,
HQW
State Grid / USGS
Quad:
J27NE
Mooretown, NC
303(d) Listed?
Yes - Mercury
Permit Writer:
Jim McKay
Subbasin:
03-06-23
Date:
7/6/2010
HUC:
03030007
Assessment Unit:
18-74-(47.5)
Drainage Area (mi2):
1426
-
.��f"
001 & 002: Lat. 34° 22'
- ::- �_•.
34" N Long. 77°
Summer 7Q10 (cfs)
25
Winter 7Q10 (cfs):
90
30Q2 (cfs)
150
Average Flow (cfs):
1800
IWC (%) Outfall 001:
4.6
51'55"W
BACKGROUND
Elementis Chromium's Castle Hayne plant is the second largest producer
of chromium based chemicals in the world; the major product at the facility is
sodium dichromate.
Process wastewater is discharged through outfall 001 and consists of
groundwater remediation water, reject residue from the pH adjustment unit,
stormwater from coal pile runoff, and recycle residue. Treated domestic
wastewater is discharged through outfall 002 to the Northeast Cape Fear River
Waste sludge is disposed of as slurry and sent to a quarry permitted
under non -discharge permit WQ0001492. The domestic sludge is land applied
under WQ000783
Instream Monitoring and Verification of Existing Conditions and DMR
Data Review:
This facility discharges to the Northeast Cape Fear River (classified B,
Sw, PNA, HQW) in subbasin 03-06-23. As a member of the Lower Cape Fear
monitoring coalition, the instream monitoring requirements have been waived.
There is no appropriate upstream monitoring station on the Northeast Cape
Fear, but data from station NCF 117 was used to assess downstream impacts of
the discharge. Available data was pulled from the Coalition's water quality

reports and shows most of the monitored parameters (temperature, turbidity,
pH, DO, etc.) to be within acceptable ranges. There is one data point for fecal
coliform that exceeded 200 CFU/ 100 mL (5,500), but most data are below 100
CFU/ 100 mL. Nutrient levels are fairly low. DO and pH reflect the Swamp
secondary classification. There are several DO readings less than the instream
standard of 5.0 mg/ L, and a few pH readings less than the instream standard
of 6.0 SU.
The effluent values from outfalls 001 and 002 from the period of January
2008-April 2010 were analyzed. The data are summarized in the table below.
Metals and toxicants were also analyzed for outfall 001 (see Reasonable
potential Analysis).
Outfall 001
Flow (MGD)
Average Value
.538
Maximum Value
.822
Minimum Value
0.081
BOD (mg/L)
1.3
5.0
Not detected
TSS (mg/L)
19.3
110.03
4.92
Total Nitrogen (mg/L)
9.56
15.3
1.9
Total Phosphorus
(mg/L)
0.2
0.14
Not detected
Chloride (mg/L)
3,419
6,209
1,508
Hexavalent chromium
(lbs./day)
0.015
0.058
Not detected
Total Chromium
(lbs./day)
0.057
0.608
Not detected
Copper (µg/L)
13.8
44
5
Nickel (lbs./da )
0.034
0.144
Maximum Value
0.0110
Not detecicd
Minimum Value
0.0003
Outfall 002
Flow (MGD)
Average Value
0.0049
BOD (mg/L)
4.0
13.0
Not detected
TSS (mg/L)
8.8
24.1
2.5
Ammonia Nitrogen
(mg/L)
0.13
0.4
Not detected
Fecal Coliform (#/100
mL)
1.2
91.0
Not detected
Total Residual
Chlorine (µg/L)
7,980
18,900
1,300
Dissolved Oxygen
(mg/L)
8.5
12.5
5.1
Production data for sodium dichromate was also provided as follows:
Correspondence:
The -Wilmington Regional Office (WiRO) conducted a compliance
inspection. The report, dated January 28, 2010 describes the facility as well
maintained and in compliance. The inspector did note that the sludge in the
domestic WWTP appeared old, and recommended more frequent process
control monitoring, and that the company request Technical Assistance
Evaluation to help reduce the age of sludge.
One NOV was issued on January 13, 2010 for high TSS at Outfall 002,
the domestic WWTP.
1.1

PERMITTING STRATEGY
Waste Load Allocation (WLA):
The Division prepared the last WLA in 1996. At that time, the facility had
requested a flow decrease from 1.04 MGD to 0.785 MGD. Instream monitoring
for temperature, dissolved oxygen (DO), conductivity and salinity were
recommended. Effluent limits for flow, TSS, hexavalent chromium, total
chromium, nickel and pH were recommended at outfall 001. The modeling
unit also recommended effluent monitoring of copper, chloride, total nitrogen
and total phosphorus. Outfall 002 had recommended limits on flow, BOD,
TSS, fecal coliform and pH with monitoring for total residual chlorine and
ammonia nitrogen. The previous and current effluent limits were based on
guidelines ((40 CFR 415.172 Subpart Q) and water quality standards. The
Division has judged previous parameters and limits to be appropriate for
renewal with some exceptions (see Reasonable Potential Analysis).
Federal Effluent Guidelines:
To determine a number of the effluent limits for the process wastestream,
the federal effluent guidelines for Subpart Q (Sodium Dichromate and Sodium
Sulfate Production Subcategory) were utilized. The guideline limits for total
suspended solids (TSS), hexavalent chromium, chromium, and nickel in terms
of pounds per thousand pounds of production. The Best Practicable
Technology (BPT) limitations for dischargers in this subpart (in terms of
pounds per thousand pounds) is as follows:
Pollutant or
pollutant property
TSS
Maximum for any 1
day
(daily maximum)
0.44
Average of 30
consecutive days
(monthly average)
0.22
Hexavalent
Chromium
0.00090
0.00050
Total Chromium
0.0088
0.0044
Total Nickel
0.0068
0.0034
pH
Within the range 6.0 to 9.0
The limits for the old permit were based on the year 1998, during which time
266.16 tons/day of sodium dichromate was produced. This translates to
532,320 lbs./day, which yields a multiplication factor of 532.32 1000 lbs. for
the limits given in the effluent guidelines. Permit limits result as follows:
Parameter_o f
Concern
Daily maximum
(lbs./day)
234.22
Monthly_average
(lbs./day)
117.11
TSS
Hexavalent
Chromium
0.48
0.27
Chromium
4.68
2.34
Nickel
3.62
1.81

Water Quality Based Limits:
Based upon North Carolina's water quality criteria - the following table
presents the water quality based limits determined using 7Q 10 flow and
permitted design flow at 001:
Parameter of
Concern
TSS
Total Chromium
Nickel
Monthly average
(lbs. /day)
2821.6
7.05
12.41
In this case, the technology -based limits (effluent guidelines) prove to be
more stringent for TSS, total chromium and nickel. Those limits will be used in
the permit.
Reasonable Potential Analysis (RPA):
The Division conducted EPA -recommended analysis on effluent data
from outfall 001 to determine the reasonable potential for toxicants to be
discharged by this facility, based on DMR data (January 2008 - April 2010).
Outfall 002 discharges strictly domestic wastewater and no toxicant monitoring
is performed on this effluent, so it was not included in this analysis.
Calculations for outfall 001 included parameters listed in the previous permit
to include: total chromium, nickel, chloride and copper.
Copper does show reasonable potential to exceed state water quality
standards, but copper is an action level parameter, and the facility has passed
all but one toxicity test (in 2006), so a limit is not required. Chromium and
nickel are estimated to be present in values below the state water quality
criteria. The limits for chromium and nickel will be based upon the federal
effluent guidelines.
Reasonable potential does exist for chloride, but this is an action level
pollutant. Given that the facility has only failed one toxicity test within the
past four and a half years, a limit for chloride is not required. Monitoring
frequency, however, should remain as weekly.
Reasonable potential also exists for mercury, however the old method
used to analyze for mercury is not accurate at the level mercury limits would
be set. There were only two hits in 28 months of quarterly monitoring. In
order to obtain better mercury data, EPA method 1631 with clean sampling
techniques will be required. Monitoring frequency will remain at quarterly with
no limit at this time. On renewal, with better data to review, we can determine
if mercury limits are required or not.
Reasonable Potential does not exist for Total Cadmium or for Total Lead.
For both, the predicted value is much less than 50% of the allowable, so in
keeping with the new limiting strategy, monitoring for these two metals will be
removed from the permit as requested by the permittee.
Primary Pollutant Analysis (PPA):
The PPA submitted by the facility with this renewal application indicates
detection of the following: cadmium, copper, nickel, chloride, aluminum,
fluoride, zinc, lead, mercury, selenium, and silver. Of these, copper, nickel and
chloride are already monitored in the current permit. Aluminum and fluoride

are considered ubiquitous and monitoring for these is unnecessary. The
remainder of the compounds shall be monitored quarterly for the term of the
permit (zinc, mercury, selenium, and silver).
SUMMARY OF PROPOSED CHANGES:
In keeping with Division policies, the following will be incorporated into the
permit:
• A review of Outfall 001 discharge data shows that Total Lead
and Total Cadmium do not have potential to exceed NC water
quality standards, so monitoring has been removed from the
permit as requested by the permittee.
• Mercury monitoring must be by Low Level Method 1631E with
clean sampling in order to develop more meaningful data for
future review.
• TACU has determined that the Industrial WWTP should be
rerated as a Grade II instead as the current Grade I
classification. A Grade II ORC and backup operator will be
required. TACU will send a letter to the plant, with a
compliance schedule.
• A TRC limit of 28 ug/ L is added to outfall 002 for the domestic
waste treatment system. A compliance schedule of 18 months
is granted to allow the facility to obtain funding and install
dechlorination equipment. The standard TRC footnote
regarding TRC results reported less than 50 ug/ L are in
compliance with the permit is used.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: July, 2010
Permit Scheduled to Issue: September, 2010
NPDES DIVISION CONTACT:
If you have questions regarding any of the above information or on the
attached permit, please contact Jim McKay at [phone].
NAME: /,iry `2 AIL; DATE: 6f - - z©l 0
REGIONAL' OFFICE COMMENTS:
NAME: DATE:
SUPERVISOR: DATE:

REASONABLE POTENTIAL ANALYSIS
Elementis Chromium Corporation
NC0003875
Time Period December 2008 - April 2010
Qw (MGD)
7010S (cfs)
7010W (cfs)
3002 (cfs)
Avg. Stream Flow, QA (cfs)
0.785 WWTP Class 1 Physical/ Chemi
25 IWC (%) @ 7Q10S 4.6411
90 ©7Q 10W 1.3339
150 @ 3002 0.8046
1800 @ QA 0.0676
Rec'ving Stream North East Cape Fear River
Outfall 1
Qw = 0.785 MGD
Calculation of 1010 based on 7Q10
11910= 0.843 (7Q10) o.s93
SUMMER 1Q10 = 20.6 (cfs)
SUMMER 1010 IWC % = 5.58
WINTER 1Q10 = 73.5 (cfs)
Stream Class B, Sw, PNA, HQIA WINTER 1Q10 IWC % = 1.63
PARAMETER
TYPE
II)
STANDARDS &
CRITERIA (2)
PAL
Units
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NCWQS/
Chronic
KFAV/
Acute
n xDet Max Pred Cw Allowable
Cadmium
NC
2
15
ug/L
8 1
Note: n<12
Limited data
2.2
set
Acute:
_______
Chronic:
269
_-__-_-_-_-_-_-_____-_
43
Noac_utelimitrequired
No chronic limit required
Remove monitoring from permit as requested.
Chromium
NC
50
1,022
ug/L
41 41
2739
Acute:
_ _ _ _._-____
Chronic:
18,315
1,077
No acute limit required
_ _ _ _-_ _-_-_-_-_-_______-_
No chronic limit required
Copper
NC
7
AL
7.3
ug/L
8 8
Note: n<12
Limited data
238.0
set
Acute:
_ _ _ _
Chronic:
131
- _ _ -
151
Action Level Parameter. Facility has passed all recent WE1
tests._ No_ acute limit required _ _ - _ - _ _ _ - _ _ J
Action Level Parameter. Facility has passed all recent WE1
tests. No chronic limit required
Chloride
NC
230
AL
ug/L
74 74
7,947.5
Acute:
_ _ _ _
Chronic:
NO WOS
_ _ _
4,956
No acute timit required ______
___ ______
_ _ _ _ _ _ _ . _ _ _ - _ _ _ _ _
Action Level Parameter. Facility has passed all recent W E1
tests. No chronic Limit required
Lead
NC
25
N
33.8
ug/L
8 1
Note: n<12
Limited data
6.2
set
Acute:
__ _ __
Chronic:
606
____
539
No acute limit required
_ _ _ _ ___________________
No chronic limit required
Remove monitoring from permit as requested.
Mercury
NC
12
2.0000
ng/L
i
9 2 1 846.0000
Note: n<12 !
Limited data set
Acute:
__ _.________
Chronic:
NO WQS
259
No acute limit required
_ _-_ _-_ _ _ _-_ _ _ _ _-_-!
Maintain quarterly monitoring, but require low level mercury
test method 1631E with clean sampling to get data.
Nickel
NC
88
261
ug/L
30 30
48.0
Acute:
__ _ ___
Chronic
4,677
__
1,896
No acute limit required .
_ _ _ _ __________________
No chronic limit required
Zinc
NC
50
AL
67
ug/L
8 4
Note: n<12
Limited data
426.6
set
Acute:
__ _ ___
Chronic:
1,201
_ __
1.077
No acute Limit required
_ _ _ _ _ ___________________
No chronic limit required
' Legend:
C = Carcinogenic
NC = Non -carcinogenic
A = Aesthetic
Freshwater Discharge
RPA. rpa
9/10/2010

Table 1. Project Information
Facility Name
WWTP Grade
NPDES Permit
Outfall
Flow, Qw (MGD)
Receiving Stream
Stream Class
7Q10s (cfs)
7Q10w (cfs)
30Q2 (cfs)
QA (cfs)
Time Period
Data Source(s)
Elementis Chromium Corporation
Physical/ Chemical & II Biological
NC0003875
1
0.785
North East Cape Fear River
B, Sw, PNA, HQW
25.0
90.0
150.0
1800.0
December 2008 - April 2010
Table 2. Parameters of Concern
Par01
Par02
Par03
Par04
Par05
Par06
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Name
Type Chronic Modifier Acute PQL Units
Arsenic
C
10
ug/L
Beryllium
C
6.5
ug/L
Cadmium
NC
2
15
ug/L
Chromium
NC
50
1022
ug/L
ug/L
ug/L
Copper
NC
7
AL
7.3 ,
Cyanide
NC
5
N
22
i 10
Chloride
NC
230
AL
ug/L
Lead
NC
25
N
33.8
ug/L
Mercury
NC
12
2.0
ng/L
Molybdenum
A
3500
ug/L
Nickel
NC
88
261
ug/L
Phenols
A
1
N
ug/L
Selenium
NC
5
56
ug/L
Silver
NC
0.06
AL
1.23
ug/L
Zinc
NC
50
AL
67
ug/L
RPA, input
9/10/2010

REASONABLE POTENTIAL ANALYSIS
Cadmium
Chromium
Date Data BDL=1/2DL Results
1 < 1 0.5 Std Dev. 0.2588
2 1.0 1.0 Mean 0.6875
3 <' 1 0.5 C.V. 0.3764
4 < 1 0.5 n 8
5 < 1 0.5
6 < 1 0.5 Mult Factor= 2.2100
7 < 2.0 1.0 Max. Value 1.0 ug/L
8 < 2.0 1.0 Max. Pred Cw 2.2 ug/L
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Date Data BDL=1/2DL Results
1 57.18 57.2 Std Dev. 22.3313
2 50.80 50.8 Mean 26.7869
3 29.00 29.0 C.V. 0.8337
4 12.34 12.3 n 41
5 61.70 61.7
6 25.91 25.9 Mult Factor = 2.1900
7 27.35 27.4 Max. Value 125.0 ug/L
8 24.89 24.9 Max. Pred Cw 273.9 ug/L
9 24.89 24.9
10 29.62 29.6
11 22.01 22.0
12 20.57 20.6
13 46.48 46.5
14
12.34 12.3
15 ± 12.34 12.3
16 16.45 16.5
17 12.34 12.3
18 24.68 24.7
19 62.73 62.7
20 12.34 12.3
21 14.40 14.4
22 14.40 14.4
23 12.34 12.3
24 13.99 14.0
25 j' 14.81 14.8
26 12.96 13.0
27 16.45 16.5
28 27.56 27.6
29 10.28 10.3
30 9.67 9.7
31 10.69 10.7
32 8.84 8.8
33 20.57 20.6
34 3 35.99 36.0
35 :;j 10.28 10.3
36 15.63 15.6
37 #1¢ 62.52 62.5
38 39.08 39,1
39 ' 125.05 125.0
40 6.17 6.2
41 30.64 30.6
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57 --
58
59
60 f.:41
199
200
RPA, data
- 2 - 9/10/2010

REASONABLE POTENTIAL ANALYSIS
Copper
Chloride
Date Data BDL=1/2DL Results
1 44 44 0 Std Dev 12.5442
2 13 13.0 Mean 13.7500
3 8 8.0 C.V. 0.9123
4 13 13.0 n 8
5 7 70
6 5 5.0 Mult Factor = 5.4100
7 9 9.0 Max. Value 44.0 ug/L
8 11 11.0 Max. Pred Cw 238.0 ug/L
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Date Data BDL=1/2DL Results
1 4589 4589.0 Std Dev. 1145.8088
2 4484 4484.0 Mean 3470.6622
3 4970 4970.0 C.V. 0.3301
4 4204 4204.0 n 74
5 4898 4898.0
6 4630 4630.0 Mult Factor = 1.2800
7 5401 5401.0 Max. Value 6209.0 ug/L
8 4331 4331.0 Max. Pred Cw 7947.5 ug/L
9 4793 4793.0
10 5432 5432.0
11 4140 4140.0
12 4599 4599.0
13 4993 4993.0
14 3692 3692.0
15 4088 4088.0
16 4536 4536.0
17 3682 3682.0
18 4988 4988.0
19 6209 6209.0
20 4106 4106.0
21 4671 4671.0
22 5236 5236.0
23 4178 4178.0
24 4321 4321.0
25 4848 4848.0
26 3833 3833.0
27 3776 3776.0
28 4384 4384.0
29 2841 2841.0
30 3853 3853.0
31 4638 4638.0
32 3100 3100.0
33 3447 3447.0
34 3780 3780.0
35 3129 3129.0
36 3001 3001.0
37 4427 4427.0
38 1824 1824.0
39 1857 1857.0
40 2115 2115.0
41 1508 1508.0
42 2325 2325.0
43 2622 2622.0
44 2015 2015.0
45 2195 2195.0
46 2931 2931.0
47 1610 1610.0
48 2713 2713.0
49 3600 3600.0
50 1947 1947.0
51 2258 2258.0
52 2550 2550.0
53 1724 1724.0
54 3077 3077.0
55 5689 5689.0
56 1900 1900.0
57 3087 3087.0
58 3533 3533.0
59 2336 2336.0
60 2200 2200.0
199
200
-3
RPA, data
9/10/2010

REASONABLE POTENTIAL ANALYSIS
Lead
Mercury
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Date
Data
<
<
<
<
<
<
<
BDL=1/2DL
5 2 5
2.0 2.0
5 2.5
5 2.5
2 1.0
1 0.5
3 1.5
3 1.5
Results
Std Dev
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
0.7559
1.7500
0.4320
8
2.4600
2.5 ug/L
6.2 ug/L
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Date
Data
<
<
<
<
<
<
<
BDL=1/2DL
300.0 300.0
200.0 200.0
200.0 100.0
200.0 100.0
200.0 100.0
200.0 100.0
200.0 100.0
200.0 100.0
200.0 100.0
Results
Std Dev.
Mean
C V
n
Mutt Factor =
Max. Value
Max. Pred Cw
70.7107
133.3333
0.5303
9
2.82
300.0 ng/L
846.0 ng/L
-4-
RPA, data
9/10/2010

REASONABLE POTENTIAL ANALYSIS
Nickel
Zinc
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Date Data BDL=1/2DL Results
29.00 29.0 Std Dev. 6.2666
25.91 25.9 Mean 15.7130
27.35 27.4 C.V. 0.3988
24.89 24.9 n 30
24.89 24.9
29.62 29.6 Mult Factor = 1.6200
22.01 22.0 Max. Value 29.6 ug/L
12.34 12.3 Max. Pred Cw 48.0 ug/L
14.40 14.4
12.34 12.3
12.34 12.3
16.45 16.5
12.34 12.3
14.40 14.4
12.34 12.3
14.40 14.4
14.40 14.4
12.34 12.3
13.99 14.0
14.81 14.8
12.96 13.0
12.34 12.3
14.40 14.4
10.28 10.3
9.67 9.7
10.69 10.7
8.84 8.8
10.28 10.3
11.93 11.9
9.46 9.5
Date Data BDL=1/2DL Results
45 45.0 Std Dev. 14.3177
5.00 5.0 Mean 10.3125
t 5 2.5 C.V. 1.3884
5 2.5 n 8
20 10.0
6 6.0 Mult Factor = 9.4800
5 2.5 Max. Value 45 0 ug/L
9.0 9.0 Max. Pred Cw 426.6 ug/L
-5-
RPA, data
9/10/2010

' . Mckay, James
From: Mckay, James
Sent: Friday, September 10, 2010 12:50 PM
To: Glazier, Kipp
Cc: Shiver, Rick; Belnick, Tom
Subject: Response to August 23, 2010 memo re. Elementis Chromium Renewal
Kipp,
In response to your memo of 23 August, 2010, we have reset the permit limits to the old permit limits in order to get the
permit issued. It is an EPA Priority permit.
We did review production for the years 2005 through 2009. Per EPA guidance, the production for 2009 was more than
20% less than the average production over the time period, so it was not used. The average production for 2005 — 2008
is 270 tons per day, slightly higher than the 266 tons per day in 1998, but we stayed with the old limits.
Re your recommendation that we use mass limits and concentration limits. We do not do that.
Thank you for your review and comments.
Jim McKay, Environmental Engineer
NC DENR / Division of Water Quality / Surface Water Protection Section
Point Source Branch
1617 Mail Service Center, Raleigh, NC 27699-1617
919/807-6404 (work); 919/807-6495 (fax)
**Please note, my email address has changed to [e-mail]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records law and may be
disclosed to third parties.
1

0
DIVISION OF WATER QUALITY
WILMINGTON REGIONAL OFFICE
August 23, 2010
MEMORANDUM
To:
Through:
From:
Jim McKay
Complex NPDES Permitting Unit
Rick Shiver ,_ --
Wilmington Regional Supervisor
Kipp Glazier14
�;�.-�
Environme pecialist
Wilmington Regional Office
Subject: Draft NPDES Permit NC0003875
Elementis Chromium
New Hanover County
• The Northeast Cape Fear River at the discharge location is classified B-Swamp, HWQ, PNA.
Based on the water quality standards for HQW, the receiving stream.merits greater protection
than provide for by the categorical production based limits. The DWQ should not allow an
increase in pollutant loading to this water body. TSS, Hex. Chromium, Total Chromium, and
Nickel limits for outfall 001 should be retained at the current level .
• Historical self -monitoring discharge data indicates that the Permittee can meet current limits
even with the increased production over the past 2 years.
• Production based Categorical limits are usually calculated based on long-term production
averages. EPA guidance recommends 5 years of monthly average production data. The subject
limits (outfall 001) were calculated based on 2 years of production data. A five year production
average further demonstrates that limit increases are not indicated.
• The source of pollutants at the facility is not entirely from production. A portion of the
wastewater is from recovery wells. The Permittee has requested additional pollutant loading
based on an increase in production. Categorical Production limits do not apply to the portion of
the waste stream that is not from production. The additional pollutant load allowed by the
proposed permit limits could be used to transfer pollutants form the groundwater to the
receiving stream.
• DWQ should issue concentration limits in addition to the mass limits. The addition of
concentration limits will help ensure that the Permittee operates the facility at optimal
efficiency when production is below average, providing a greater degree of protection to the
HQW receiving stream.

DIVISION OF WATER QUALITY
WILMINGTON REGIONAL OFFICE
August 23, 2010
MEMORANDUM
•
To: Jim McKay
Complex NPDES Permitting Unit
Through: Rick Shiver
Wilmington Regional Supervisor
From: Kipp Glazier
Environme pecialist
Wilmington Regional Office
Subject: Draft NPDES Permit NC0003875
Elementis Chromium
New Hanover County
• The Northeast Cape Fear River at the discharge location is classified B-Swamp, HWQ, PNA.
Based on the water quality standards for HQW, the receiving stream.merits greater protection
than provide for by the categorical production based limits. The DWQ should not allow an
increase in pollutant loading to this water body. TSS, Hex. Chromium, Total Chromium, and
Nickel limits for outfall 001 should be retained at the current level .
• Historical self -monitoring discharge data indicates that the Permittee can meet current limits
even with the increased production over the past 2 years.
• Production based Categorical limits are usually calculated based on long-term production'
averages. EPA guidance recommends 5 years of monthly average production data. The subject
limits (outfall 001) were calculated based on 2 years of production data. A five year production
average further demonstrates that limit increases are not indicated.
• The source of pollutants at the facility is not entirely from production. A portion of the
wastewater is from recovery wells. The Permittee has requested additional pollutant loading
based on an increase in production. Categorical Production limits do not apply to the portion of
the waste stream that is not from production. The additional pollutant load allowed by the
proposed permit limits could be used to transfer pollutants form the groundwater to the
receiving stream.
• DWQ should issue concentration limits In addition to the mass limits. The addition of
concentration limits will help ensure that the Permittee operates the facility at optimal
efficiency when production is below average, providing a greater degree of protection to the
HQW receiving stream. •

Mckay, James
From: [e-mail]
Sent: Monday, July 26, 2010 4:11 PM
To: Mckay, James
Subject: re NC0003875, Elementis Chromium LP
EPA has no comments on this draft permit.
1

AFFIDAVIT OF PUBLICATION
STATE OF NORTH CAROLINA
COUNTY OF NEW HANOVER
PUBLIC NOTCE
North Carolina Environmental Man-
agement Commission/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue a NPDES
Wastewater Permit
The North Carolina Environmental
Management Commission proposes
to issue a NPDES wastewater dis-
charge permit to the' person(s)
listed below.
Written comments regarding the
proposed permit will be accepted
until 30 days after the publish date
of this notice. The Director of the
NC Division of Water Quality (DWQ)
may hold a public hearing should
there be a significant degree of
public interest. Please mail com-
ments and/or information requests
to DWQ at the above address. In-
terested persons may visit the DWQ
at 512 N. Salisbury Street, Raleigh,
NC to review information on file.
Additional information on NPDES
permits and this notice may be
found on our website:
www.ncwaterquality.org, or by call-
ing [phone].
Elementls Chromium has applied
for renewal of NDPES permit
NC0003875. This facility dis-
charges treated industrial wastewa-
ter and treated domestic wastewa- 7/24 lx
ter to the NE Cape Fear River in the
Cape Fear River Basin. BOD, TSS,
fecal coliform and TRC are water
quality limited. This discharge may
affect future allocations. ] And at the time of such publication Star -News was a newspaper meeting all the requirements and
qualifications prescribed by Sec. No. 1-597 G.S. of N.C.
Before the undersigned, a Notary Public of Said County and State,
Keith Raffone
Who, being duly sworn or affirmed, according to the law, says that he/she is
Controller
of THE STAR -NEWS, a corporation organized and doing business under the Laws of the State of
North Carolina, and publishing a newspaper known as STAR -NEWS in the City of Wilmington
PUBLIC NOTCE North Carolina Environmental Management Commission/NPDES Unit 1617
Mail Service Center Raleigh, NC 27699-1617 Notice of Intent to Issue a NPDES Wastewater
Permit The North Carolina Environmental Management Commission proposes to issue a
NPDE
was inserted in the aforesaid newspaper in space, and on dates as follows:
ith
Sworn or affirmed to, an bscribed before me this
, A.D., 2e) ID
Title: Controller �ostniainst r��
In Testin my Whereof, I have hereunto set my hand and affixed mV.PficiatkOaThiliipay if..
year aforesaid. = e
z g
I.. _ 0 L 'cn P B LIO ice.'
'.; Notaw�,�oolic
My commission expires . Z day of , 20 /Z
Upon reading the aforegoing affidavit with the advertisement thereto annexed it is adjudged by the Court that the said
publication was duly and properly made and that the summons has been duly and legally served on the defendant(s).
This day of
MAIL TO:
Clerk of Superior Court

2005
Month Production (tons)
Avg Daily Production (tonslday)
JAN
8073
260
FEB
8049
287
MAR
7180
232
APR
8369
289
MAY
7837
245
JUN
9514
317
JUL
6081
203
AUG
9056
283
SEP
7725
257
OCT
8618
278
NOV
9135
304
DEC
9572
309
TOTAL YEAR
99207
272
2006
Month Production (tons)
Avg Daily Production (tonslday)
JAN
9140
295
FEB
8492
303
MAR
8981
290
APR
8646
288
MAY
7507
242
JUN
6612
220
JUL
7206
232
AUG
6934
224
SEP
6451
215
OCT
7705
249
NOV
7803
260
DEC
8557
276
TOTAL YEAR
94035
258
2007
Month Production (tons)
Avg Daily Production (tonslday)
JAN
8538
275
FEB
6775
242
MAR
7709
249
APR
8263
275
MAY
9326
301
JUN
8581
286
JUL
9262
299
AUG
9013
291
SEP
8316
277
OCT
8404
271
NOV
4912
164
DEC
7342
237
TOTAL YEAR
96440
264
2008
Month Production (tons)
Avg Daily Production (tons/day)
JAN
8957
289
FEB
8292
286

MAR
8883
287
APR
9100
303
MAY
9057
292
JUN
9260
309
JUL
9513
307
AUG
8686
280
SEP
9411
314
OCT
8145
263
NOV
7761
259
DEC
7597
245
TOTAL YEAR
104663
286
2009
Month Production (tons)
Avg Daily Production (tons/day)
JAN
2715
88
FEB
2643
94
MAR
3320
107
APR
1774
59
MAY
4097
132
JUN
6186
206
JUL
6032
195
AUG
6306
203
SEP
6365
212
OCT
6140
198
NOV
6569
219
DEC
5201
168
TOTAL YEAR
57348
157

IWC Calculations
Facility: Elementis Chromium
NC0003875
Prepared By: Jim McKay i/jB %4p i p
Enter Design Flow (MGD):
Enter s7Q10 (cfs):
Enter w7Q10 (cfs):
0.02
25
90
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/l)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
Upstream Bkgd (ug/I)
IWC (%)
Allowable Conc. (ug/I)
2 SV4r // /nix
Fecal Coliform
Monthly Average Limit:
(If DF >331; Monitor)
(If DF<331; Limit)
Dilution Factor (DF)
tie e,t. (/ ..
25
0.02
0.031
17.0
0
0.12
13727
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/I)
s7Q10 (CFS) 25
DESIGN FLOW (MGD) 0.02
DESIGN FLOW (CFS) 0.031
STREAM STD (MG/L) 1.0
Upstream Bkgd (mg/I) 0.22
IWC (%) 0.12
Allowable Conc. (mg/I) 630.0
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/I)
w7Q10 (CFS)
Not Required DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/I)
/l'' p n -t o^ 4 n / /;/-�
11 ot
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); capped at 35 mg/I
3. Monthly Avg limit x 5 = Daily_Max limit (Non-Munis);1apped_2t 35 mgll---
4. BAT for Minor Domestics: 2 mg/I (summer) and 4 mg/I (winter)
5. BAT for Major Municipals: 1 mg/I (year-round)
90
0.02
0.031
1.8
0.22
0.03
4588.9
itr,'-tom
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)
NPDES Server/Current Versions/WLA; TB 1/16/2009

a
Element's Chromium Production Data
Year Average Daily Production % of Average
Tons per Day
2005 272 110% A < 20%
2006 258 104% A < 20%
2007 264 107% A < 20%
2008 286 116% A < 20%
2009 157 63% A > 20%
Average: 247
Avg 2005 - 2008 270

Table 26 CAPE FEAR Subbasin 03-06-23
AU Number Classification Length/Area
Description
18-74-55a C Sw
From source to Cypress Creek
7.7 FW Miles
Aquatic Life Assessment
Year/
AL Rating Station Result Parameter % Exc
BB139 S 2003
Recreation Assessment
REC Rating Station Result
ND
Stressors
Sources
Habitat Degradation
Unknown
I8-74-55b C Sw 21.5 FW Miles ND
From Cypress Creek to Northeast Cape Fear River
Merricks Creek
18-74-49-2
ND
C Sw 5.3 FW Miles
From source to Harrisons Creek
ND
BB107 N '2003
BB107 N '1999
Northeast Cape Fear River
—4 18-74-(47.5) B Sw 15.6 FW Miles NR BA694 NCE Low DO 23.3 S BA694 NCE
From NC Hwy 210 to Princes George Creek
18-74-(52.5) C Sw 12.4 FW Miles NR BA699 NCE Low DO 10.4 S BA699 NCE
From Prince George Creek to mouth of Ness Creek
Low Dissolved Oxygen Unknown
Total Suspended Solids WWTP NPDES
Low Dissolved Oxygen WWTP NPDES
18-74-(61) SC Sw 1.0 S acres NR
From mouth of Ness Creek to Cape Fear River
BA703 NCE Low DO 39.3
S BA703 NCE
Low Dissolved Oxygen Unknown
18-74-33-2-2 C Sw
From source to Sandy Run Swamp
13.3 FW Miles
BB134 N '1999
ND
Smith Creek
18-74-63
C Sw
11.1 FW Miles
From source to Northeast Cape Fear River
BB79 S 2003
ND
Low Dissolved Oxygen WWTP NPDES
CAPE FEAR Subbasin 03-06-23

Cape Fear River Basin Northeast Cape Fear River 8-Digit Subbasin 03030007
Assessment Unit Number Name
Description
Classification Old DWQ Subbasin Miles/Acres
Use
Support
Category
Use
Support
Rating
Reason for
Rating
Parameter of Collection Listing IR
Interest Year Year Category
18-74-19a Goshen Swamp
From source to Bear Swamp
C;Sw
03-06-22 16.6 FW Miles
Aquatic Life Impaired Severe Bioclassification Ecological/biological Integrity 2003 2006 5
Bcnthos
18-74-55a Long Creek
From source to Cypress Creek
C;Sw 03-06-23
7.7 FW Miles
Aquatic Life Impaired Severe Bioclassification Ecological/biological Integrity 2003 2006 5
Benthos
18-74-55b Long Creek
From Cypress Creek to Northeast Cape Fear River
C;Sw
03-06-23 21.5 FW Miles
Fish Impaired Standard Violation Mercury
Consumption
2000 2006 5
18-74-25 Muddy Creek
From source to Mortheast Cape Fear River
C;Sw 03-06-22
14.0 FW Miles
18-74-(1)a Northeast Cape Fear River
From source to SR 1558
C;Sw 03-06-21 3.4 FW Miles
Aquatic Life Impaired Fair Bioclassification Ecological/biological Integrity 2003 2000 5
Benthos
Aquatic Life Impaired Standard Violation Chloride
1998 1998 4b
18-74-(25.5) Northeast Cape Fear River
From Muddy Creek to Rock Fish Creek
C;Sw,HQW
03-06-22 19.5 FW Miles
Aquatic Life Impaired Poor Bioclassification Ecological/biological Integrity 1998 2006 5
Benthos
18-74-(47.5) Northeast Cape Fear River Fish Impaired Standard Violation Mercury 2000 2006 5
Consumption
From NC Hwy 210 to Princes George Creek
B;Sw 03-06-23
15.6 FW Miles
18-74-63 Smith Creek
From source to Northeast Cape Fear River
C;Sw 03-06-23
11.1 FW Miles
Cape Fear River Basin
Aquatic Life .insp.. Severe Bioclassification Ecological/biological Integrity 2003 2006 5
Benthos
Long Bay -Atlantic Ocean 8-Digit Subbasin 03040208
99-(2) Atlantic Ocean
49 Street SE in Long Beach to the mouth of the Cape Fear River
SB 03-06-17 5.6 Coast Miles
Fish Impaired Standard Violation Mercury 2000 2000 5
Consumption
Catawba River Basin
Catawba River Headwaters 8-Digit Subbasin 03050101
All NC Waters are in Category 5 due 10 statewide Fish Consumption Advice for Mercury Category 5 Assessments require "/'RIDL development per Clean Water ater Act Section 303(d)
2008 North Carolina Integrated Report Category 4 and 5 Impaired Waters List- 2010311 Page 18 of 139

23.3.3 Northeast Cape Fear River [AU#18-74-(47.5)]
Current Status and 2005 Recommendations
The Northeast Cape Fear River from Hwy 210 to Prince George Creek (15.6 miles) is Impaired
on a monitored basis in the fish consumption category and will be added to the 303(d) list of
Impaired waters.
23.3.4 Long Creek [AU#18-74-55a and b]
Current Status
Long Creek was Fully Supporting in the 2000 basin plan; however, Long Creek [18-74-55a]
from source to Cypress Creek (7.7 miles) is currently Impaired for aquatic life because of a
Severe benthic community rating at site BB139. Long Creek is channelized and has poor habitat
conditions. The stream is affected by beaver dams. Conductivity was high at the sample site and
the benthic community was dominated by tolerant species.
Long Creek [18-74-55b] from Cypress Creek to (21.5 miles) is Impaired on a monitored basis in
the fish consumption category. No other data were collected in this segment.
2005 Recommendations
DWQ will continue to monitor the Long Creek watershed and evaluate impacts of NPDES
discharges into Long Creek. DWQ will contact DSWC to evaluate if agricultural BMPs can be
implemented to improve water quality.
Both segments will be added to the 303(d) list of Impaired waters. TMDLs (Chapter 35) will be
developed for identified stressors within 8-13 years of listing.
23.3.5 Smith Creek [AU#18-74-63]
Current Status
Smith Creek was Not Rated in the 2000 basin plan; however, Smith Creek from source to
Northeast Cape River (11.1 miles) is currently Impaired for aquatic life because of a Severe
benthic community rating at site BB79. The Smith Creek WWTP (NC0000817) had significant
violations of dissolved oxygen permit limits during the assessment period that could have
negatively impacted aquatic life. This facility is no longer discharging.
2005 Recommendations
DWQ will continue to monitor the Smith Creek watershed. The NPDES compliance process
will be used to address the significant permit violations noted above.
Smith Creek will be added to the 303(d) list of Impaired waters. TMDLs (Chapter 35) will be
developed for identified stressors within 8-13 years of listing.
Water Quality Initiatives
The NCEEP completed the New Hanover County Local Watershed Plan in 2003 that includes
Smith Creek. The plan is discussed under Burnt Mill Creek in this chapter. The plan is available
for download at: http://www.nceep.net/services/lwps/new%20hanover/newhanover.htm
Chapter 23 — Cape Fear River Subbasin 03-06-23 217

Elementis'chromium, NC0003875
•
Subject: Elementis Chromium, NC0003875
From: Bethany Georgoulias <[e-mail]>
Date: Fri, 30 May 2008 15:01:48 -0400
To: [e-mail]
Hi Jim,
I spoke briefly with Michelle Mayfield of URS Corporation (919.461.1355) and let her
know you are the reviewer assigned to the wastewater permit renewal/mod. for,this
facility. She will likely touch base with you in the near future to talk more about
the company's plans with using and storing coal on -site, and what that will mean for
the wastewater permit. There are effluent limitations (TSS and pH, I believe) that
apply to coal pile runoff at any industry covered by the NPDES regs.
I also talked to Bradley, and he confirmed that we don't usually handle coal pile
runoff in our stormwater permits -- it's part of the wastewater permit. I advised
Michelle that as far as the stormwater permit goes, they just need to revise their
stormwater pollution prevention plan accordingly to be in compliance (their
individual permit NCS000003 is also on our long backlog to renew). Unfortunately I
think that means the NPDES wastewater permit will be the limiting factor for them as
far as timing of when they can bring the coal on site and begin using it, which they
are interested in doing rather soon. Michelle may be able to give a more current
update. I let her know that you had some other projects ahead of this one, so she
should understand it won't be immediately handled.
If we can help at all in the process, please let me know.
Thanks,
Bethany
Bethany Georgoulias
Environmental Engineer
NC DENR Division of Water Quality
Stormwater Permitting Unit
tel. [phone], ext. 529
fax [phone]
1 of 1 5/30/2008 3:05 PM

ELEMENTIS
CHROMIUM
HAND DELIVERED
August 3, 2006
NC DENR — DIVISION OF WATER QUALITY
Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Attn: Mrs. Carolyn Bryant
RE: NPDES PERMIT RENEWAL
NC0003875 — ELEMENTIS CHROMIUM, LP CASTLE HAYNE PLANT
Dear Mrs. Bryant:
Enclosed please find the original and two copies of the completed NPDES Permit Application for
renewal of this facility's NPDES permit, Permit Number NC0003875. Our current permit expires
at midnight on January 31, 2007. Elementis Chromium, LP (Elementis) hereby respectively
requests renewal of NPDES Permit Number NC0003875 for the above referenced facility.
Elementis manufactures sodium dichromate, chromic acid, sodium sulfate anhydrous, and salt
cake at its Castle Hayne facility and is subject to 40 CFR 415.
Please note that there have been no changes at the facility since issuance of the last permit.
However, with this permit renewal, Elementis requests a number of modifications. The first
relates to Elementis' status as a major facility. In accordance with direction from staff of the
NPDES permitting program, an NPDES Permit Rating Worksheet was completed by Mark
McIntire of Stearns & Wheler, PLLC. Elementis scored 23 points with 80 being the threshold for
designated as a major. Elementis requests a change in its facility status from major to minor.
Elementis also requests modification to Outfall 001 to include wastewaters associated with the
storage and burning of coal. For approximately 10 years from the mid-80s to the mid-90s, this
facility heated its three large rotary kilns by burning coal in the manufacturing of sodium
dichromate. Such an operation would involve the generation of wastewaters from coal pile runoff
and dust control. These wastewaters would be collected in a coal pad sump and delivered to the
industrial wastewater treatment system for disposal through Outfall 001. Elementis does not
anticipate needing additional permitted flow at Outfall 001 to accommodate these waste streams.
Additionally, Elementis intends to connect the sanitary wastewater treatment plant effluent to the
headworks of the industrial wastewater treatment plant. In recognition of this change in operation,
Elementis requests deletion of any reference to Outfall 002, including all limits and monitoring
requirements. The average flow from the sanitary treatment plant constitutes less than 1% of the
total flow discharged from this facility. Connection of 002 effluent to the industrial wastewater
treatment plant can be accommodated without an increase in the permitted flow for Outfall 001.
Elementis Chromium LP
5408 Holly Shelter Rd.
Castle Hayne, NC 28429
Telephone: [phone]
Facsimile: [phone]

Finally, Elementis requests that the quarterly monitoring requirement for cadmium, lead, and
mercury be deleted from Outfall 001. These metals have not been detected in at least 14 quarterly
consecutive samples going back to February 2003.
As it pertains to the industrial wastewater treatment facility, Elementis is proposing the
installation of a larger premix tank to increase treatment efficiency of the reduction of hexavalent
chrome using sulfur dioxide and pickle liquor. Plans and specifications for this new tank will be
prepared and submitted to the Division's Construction Grants & Loans program for issuance of
Authorization to Construct.
Thank you for your efforts with this renewal. If you have any questions or concerns, please do not
hesitate to contact me or Bob Hollinger at [phone].
Sincerely,
Howard W. Morris
Site Manager
----A--$3;54,

6448-10(0 26 )C N— T V0 01
()rowing No.
(ELEMENTIS CHROMIUM, L.P.
CASTLE HAYNE, NORTH CAROLINA
REF; USGS 7.5' TDPDGRAPFDC NAPS,
CASTLE HAYNE, SCOTTS HILL,
ROCKY P01 NT, AND NDORETOWN,
NORTH CAROLINA, DATED 1970.
0
feet
2000
SCALE
FACILITY LOCATION
MAP

Outfails 001 & 002
Latitude:
34°22'34"
Longitude:
77°51'55"
L3
Stearns & Wheler, LLC
{ Environmental Engineers and Scientists
6 ooltda
•
Elementis Chromium, LP
NC0003875
New Hanover County

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26448-10(033}GN-1V013.dgn 7/18/2006 9:51:07 AM

e
NARRATIVE DESCRIPTION OF INDUSTRIAL WASTEWATER TREATMENT
Wastewater slurry from the production neutralization area enters the wastewater treatment
process via the 500 gallon premix tank. Pickle liquor (ferrous chloride reducing agent) and sulfur
dioxide are added to begin the reduction of hexavalent chromium to trivalent chromium. From
the premix tank the pre-treated slurry goes to the 80,000 gallon waste collection tank.
Wastewater slurry from the production recycle area enters the wastewater treatment process via
the 80,000 gallon wastewater collection tank.
Wastewater slurry is pumped from the waste collection tank to one of three 24,000 gallon
reactors. Pickle liquor is added to the reactor to complete the reduction of hexavalent chromium
to trivalent chromium. When the reduction is complete, lime slurry is added to the reactor to
raise the pH so that chromium, iron, and other metals will precipitate from the treated wastewater
solution.
Contaminated water wastes from groundwater recovery wells, containment areas, production
area sumps, etc. enter the wastewater treatment process via the 10,000 gallon sump surge tank.
The sump surge tank is pumped to the 12,000 gallon water batch reactor. Pickle liquor is added
to the reactor to reduce the hexavalent chromium to trivalent chromium. When the reduction is
complete, lime slurry is added to raise the pH, to precipitate metals.
All four reactors are pumped to the 103,000 gallon treatment surge tank. This tank allows a
continuous feed of the treated wastewater batches into the chloride removal
(countercurrent washing) circuit.
The treatment surge tank is pumped to the 4,700 gallon feed reslurry tank. This feed reslurry tank
is the starting point for two parallel washing circuits. One circuit washes soluble solids from light
solids. The other circuit washes soluble solids from heavy solids.
The light circuit has three 95,000 gallon clarifiers, and two 3,200 gallon light reslurry tanks.
The heavies circuit has three hydroclones, and two 1,100 gallon light reslurry tanks.
Both washing circuits wash soluble solids away from the insoluble solids. The liquid proceeds
from three to two to one and eventually becomes the effluent to the river, while the washed
residual solids go from one to two to three and eventually to a surface impoundment.
The underflows (residual solids) from the third stage washing circuits enters the 3,950 gallon
sludge hold tank. Crushed limestone is added to the treated waste slurry in the sludge hold tank
to decrease the solubility and mobility of metals in the residual solids. The treated slurry is then
pumped to the 10,000 gallon sludge retention tank where either river water, or quarry return
water is added for transport to the surface impoundment. The residual solids are pumped via
conveyance piping to the surface impoundment. Please see the attached, signed Sludge
Management Plan for details.

4-
The liquid overflow from the first stage clarifier goes to the 10,000 gallon overflow tank. The
overflow tank feeds one of the three, eleven foot diameter, 800 GPM capacity sand filters. The
polished water from the sand filters is the 001 effluent to the river. The maximum permitted
monthly average flow of this stream is 0.785 MGD.

NARRATIVE DESCRIPTION OF DOMESTIC WASTEWATER TREATMENT
Domestic wastewater from showers, sinks, and restrooms enters the wastewater treatment
process via the 5,000 gallon equalization tank. The equalization tank is continuously aerated.
The flow from the equalization tank is split and pumped to two parallel extended aeration
package plants; each plant has a 10,000 gpd treatment capacity.
Plant one has two 5,000 gallon aeration compartments, while plant two has one 10,000 gallon
aeration compartment, but the operation is essentially the same. The treatment units share five
blowers. One is used for the equalization tank. Two are used for the aeration compartments and
air lifts, and two are spares.
The flow precedes from the aeration compartments to the clarifiers. The overflow from the
clarifiers feed tablet chlorinators. Each plant has a chlorine contact tank sized to provide a
minimum of thirty minutes contact time at 10,000 gallons per day. The water from each of the
plants' chlorine contact chambers is the 002 effluent to the river. The maximum permitted
monthly average flow of this stream is 0.020 MGD.
Wasted sludge is sent to a digester for further aeration. Plant one has a 1,500 gallon digester and
Plant two has a 3,000 gallon digester.
Lime is added to digested sludge for vector control and is land -farmed by S&B Maintenance.
Please see the attached, signed Sludge Management Plan for details.
A 3.0 liter diesel backup generator auto starts during power interruptions, supplying electricity to
operate the treatment plants, pumps, lights, etc.

ELEMENTIS CHROMIUM SLUDGE MANAGEMENT PLAN
Date: August 3, 2006
rRi..,71v . A ,/
a
Prepared by: Robert W. Hollinger — Elementihromium ORC
The sludge generated in Elementis Chromium's industrial wastewater treatment process is sent
as slurry to the "quarry" under Occidental Chemical Corporation's Surface Disposal of Residual
Solids Permit No. WQ0001492. Elementis Chromium holds a license agreement with
Occidental Chemical Corporation to dispose of the solids discharged to the "Quarry". Specific
regulatory requirements are stipulated in the permit. They include maintaining two feet of
freeboard, monitoring the waste using the TCLP test, and maintaining inspection logs, etc. This
activity is 503 exempt.
The sludge generated from the domestic wastewater treatment process is removed for land
application at a permitted site (WQ0000783) by S & B Maintenance. Vector control is
accomplished by having S & B Maintenance add lime to the truck load of sludge and follow the
DENR procedure to maintain a high pH prior to Land Application. Annual samples of the sludge
are collected and analyzed as required by S & B Maintenance's Permit. Typically 4,000 to 8,000
gallons of sludge are removed annually.
C.
Approved by: Howard Morris — Ele entis Chromium Site Manager