NC0004308_More Information (Received)_20220527

Badin Business Park LLC
201 Isabella Street
Suite 500
Pittsburgh, PA 15212-5858 USA
Tel: [phone]
May 27, 2022
North Carolina Department of Environmental Quality
Sushma Masemore
Director, Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Badin Business Park LLC March 9, 2022, Technical Meeting
Dear Ms. Masemore,
Badin Business Park LLC ("BBP") appreciates the time that the Deparliiient spent with our team
on March 09,2022 reviewing potential solutions for the fluoride discharge issues that we are
experiencing at Outfall 005.
Below is a summary of the information presented by BBP and discussed by the parties:
1. BBP provided a summary of the current Outfall 005 drainage area as well as an updated
understanding of the sources of fluoride in the discharge. Studies performed by BBP
demonstrate the majority of the fluoride entering the system is a result of groundwater
infiltrating the very old storm sewer systems. As explained by BBP, although progress
has been made to reduce the amount of fluoride in the discharge, BBP has not been able
to entirely eliminate the low concentrations of fluoride in the stormwater discharge.
2. BBP provided a brief background of Little Mountain Creek and spoke to water quality
information collected by BBP between 2019 and 2021 which illustrates that fluoride and
total cyanide concentrations in Little Mountain Creek downstream of BBP were below
chronic criteria. In addition, BBP discussed the collection of flow data in Little
Mountain Creek since 2019. Table 1 summarizes BBP's Little Mountain Creek data.
3. A summary of recent activities at the site were shared, specifically the source
identification and control activities BBP undertook. While these actions have made
fluoride reductions across the site, they have been unsuccessful at bringing Outfall 005
into consistent compliance with the fluoride limit. BBP reviewed, in detail, information
related to a soil excavation in the former Bath Mill area that was completed in October
2021; as part of this effort, approximately 2,000 tons of soil materials were excavated
and disposed of offsite. Although only a small portion of these soils were shown to
contain fluoride and at very low concentrations, the excavation conservatively
encompassed roughly 4,000 square feet. To date, as discussed, we have not seen
quantifiable benefits from this source removal activity.
4. BBP discussed a proposal for a direct discharge to Little Mountain Creek which was
developed based on 7Q10 information for Little Mountain Creek shared by the

North Carolina Department of Environmental Quality
May 27, 2022
Page 2
Department as a follow up to our February 2021 meeting. BBP spent considerable time
and effort to investigate the potential for a direct discharge to Little Mountain Creek
with the understanding that the Department would consider a mixing zone similar to that
afforded an adjacent discharger only to find out that we would be required to
reengage USGS to provide a new 7Q10 determination.
a. As discussed during our meeting, USGS performed a desktop analysis for
ungauged streams that compared similar stream types to Little Mountain Creek
which resulted in an estimated 7Q10 value of approximately 0.04 cfs. This result
was considerably lower than a prior finding by USGS. After USGS was
informed of its prior determination, USGS recommended a study be undertaken
to confirm the previous assessment as they could not locate the basis for the
prior determination in their files due to age.
b. Importantly, BBP requested during the meeting and is again asking DWR to
consider permitting a new direct discharge to Little Mountain Creek utilizing the
previously determined 7Q10 with a condition that BBP monitor Little Mountain
Creek and obtain new flow information to support a new 7Q10 determination as
recommended by USGS.
c. While the Department indicated that a permit requiring instream monitoring
would require approval by US EPA, BBP explored this avenue and Attachment
1 includes a memo summarizing recommended permitting approaches which
could be utilized to ensure a new discharge to Little Mountain Creek would be
protective of human health and the environment as well as provides examples
where similar concepts have been approved and permitted in EPA Region 4.
d. In addition, BBP is already working with the USGS to establish a flow
monitoring station in Little Mountain Creek in order to update the historic 7Q10
determination.
5. Finally, we discussed the Department's request for BBP to explore treatment
alternatives for Outfall 005. As we mentioned during the meeting, BBP continues to
explore options for compliance, but our initial assessment showed traditional treatment
options (i.e., reverse osmosis, adsorption, coagulation/filtration, lime/soda ash
softening) are not viable, as the flows at this Outfall are highly variable and dependent
on both rainfall and groundwater elevation. Treatment of a stormwater discharge in its
entirety is not realistic using traditional treatment technologies for fluoride.
a. Attachment 2 is a technology review for the removal of fluoride from industrial
wastewaters prepared for EPA in 2020 which provides further details regarding
the limitations.
b. Prior to the conclusion of the meeting, we discussed the completion of a
document similar to an Engineering Alternatives Analysis used for new or
expansion permit for wastewater treatment plants to aid in assessing potential
solutions for Outfall 005.
c. BBP also introduced current efforts to update the hydrogeologic model for the
site. One of the associated tasks will look to validate a conceptualization to
divert groundwater around the site thereby reducing the potential for fluoride

North Carolina Department of Environmental Quality
May 27, 2022
Page 3
containing groundwater to infiltrate into the storm sewer. The work plan for this
effort is being developed and will be shared with the Department upon
completion.
Again, we appreciate the Department's time and cooperation on this matter. Should you have
questions, please contact me at 412.389.1768 or [e-mail].
Sincerely,
Robyn L. Gross
Director, Asset Management Americas
Badin Business Park LLC
cc via email:
Richard Rogers, NCDEQ
Michael Scott, NCDEQ
Joy Hicks, NCDEQ
Jason Mibroda, Alcoa Corp.
Cameron Henley, Moore & VanAllen

North Carolina Department of Environmental Quality
May 27, 2022
Page 4
Table 1: Monthly Average Flowrate
for Little Mountain Creek (USG/min)
Nov-2019
2,256
Dec-2019
3,990
Jan-2020
4,003
Feb-2020
6,013
Mar-2020
2,536
Apr-2020
2,957
May-2020
69,114
Jun-2020
5,679
Jul-2020
2,594
Aug-2020
747
Sep-2020
1,078
Oct-2020
3,196
Nov-2020
6,790
Dec-2020
10,024
Jan-2021
15,915
Feb-2021
24,130
Mar-2021
10,375
Apr-2021
3,483
May-2021
930
Jun-2021
488
Jul-2021
658
Aug-2021
1,322
Sep-2021
1,989
Oct-2021
4,120
Nov-2021
140
Dec-2021
2,205

Attachment 1
iijtn
associates Ltd.
water resources I environmental consultants 3 Innwood Circle, Suite 220 • Little Rock, AR 72211 • [phone] • Fax [phone]
TECHNICAL MEMORANDUM
DATE: May 18, 2022
TO: Robyn Gross and Jason Mibroda
Alcoa Corporation
FROM: Philip Massid Nathan Siria
FTN Associates, Ltd.
SUBJECT: Hydrograph-Controlled Release Permitting Approaches for
Proposed New Outfall to Little Mountain Creek at Badin Business Park
FTN No. R06010-1805-005
1.0 INTRODUCTION
This technical memorandum provides an overview of hydrograph-controlled release (HCR)
permitting approaches and describes two specific ways than an HCR approach could be
implemented for the proposed new outfall to Little Mountain Creek at Badin Business Park (BBP).
The proposed new outfall would receive water that would be diverted from the eastern drainage
line within the Outfall 005 drainage area into a proposed pipeline that would carry the water
directly to Little Mountain Creek just upstream of the Highway 740 bridge. HCR permit limits for
this outfall would allow the discharge to utilize the assimilative capacity of the creek while
maintaining water quality standards in the creek.
2.0 OVERVIEW OF HCRs
The fundamental concept of an HCR is that the effluent flow rate is allowed to vary over time but
is controlled to ensure that water quality standards are maintained in the receiving stream. The
effluent flow rate can increase during periods when the assimilative capacity of the receiving
stream is greater, but it must be decreased during periods when the assimilative capacity of the
receiving stream is less. For most wastewater facilities, this requires a storage basin to hold treated
wastewater so that it can discharged according to the assimilative capacity of the stream.
The HCR concept has been utilized since the 1980's when it was first promoted for effluent
"releases" from wastewater lagoons (EPA 1984; Zirschsky and Thomas 1987). Since then, it has
been used in permits for various types of discharges, including effluent from industrial sites.
Regional Offices: Fayetteville, AR; Baton Rouge, LA; Chesterfield, MO • Web Site: www.ftn-assoc.com • E-mail: [e-mail]

Robyn Gross and Jason Mibroda
May 18, 2022
Page 2
HCRs can be expressed in National Pollutant Discharge Elimination System (NPDES) permits in
various ways, including the following:
A. Specify a permit limit for "discharge flow as percent of stream flow" (parameter code
01352 in EPA's Permit Compliance System (PCS) and Integrated Compliance Information
System (ICIS) databases). This is probably the most common method of expressing HCR
limits in a permit. The permit limit for discharge flow as percent of stream flow is
calculated using the common equation for complete mixing of effluent and upstream flow:
Allowable percentage = 100% x (Effluent conc. — WQ standard)
(WQ standard — Upstream conc.)
The permit would still include average and maximum limits for concentrations, but the
limits for effluent concentration and effluent flow (as a percentage of the upstream flow)
are dependent on each other. A more stringent limit for effluent concentration allows a
higher limit for effluent flow as a percentage of upstream flow. Conversely, a less stringent
limit for effluent concentration results in a lower limit for effluent flow as a percentage of
upstream flow.
B. Specify a permit limit in pounds per day per cfs of stream flow. This method is less
commonly used, but the load component (pounds per day) eliminates the large number of
possible combinations of limits for effluent concentration and effluent flow rate. Because
the load component incorporates both flow and concentration, there is usually no need to
include an additional limit for effluent concentration.
C. Specify limits for effluent flow, concentration, or load that apply for certain ranges of
upstream flow. This method was used for several discharges in the lower portions of the
Pee Dee and Waccamaw River basins in South Carolina. A modeling study led by the US
Geological Survey (USGS) resulted in a three-tier set of allowable loadings for each
discharge. Each tier was defined based on the flow rate in the Pee Dee River or
Waccamaw River (Conrads et al. 2003).
Most HCR discharges are not based on a single critical flow (e.g., 7Q 10) because they are designed
to be protective of water quality standards for all hydrologic conditions, not just at critical flow.
3.0 EXAMPLES OF HCRs IN EPA REGION 4
A query on EPA's Environmental Compliance and History Online (ECHO) web site showed
36 NPDES permits that currently require (or recently required) reporting of "discharge flow as
percent of stream flow". These permits were issued for facilities in eight different states, including
four states in EPA Region 4 (Florida, Georgia, Kentucky, and South Carolina). Additionally, a
permit with an HCR discharge was issued in Alabama in 2013 but the HCR discharge was
discontinued in 2018.
in

Robyn Gross and Jason Mibroda
May 18, 2022
Page 3
Attached to this memo are three examples of currently effective HCR permits that were issued by
states within EPA Region 4. The HCR components of these permits are summarized below.
A. FL0000281 - Packaging Corporation of America: This permit regulates discharges from
an industrial wastewater treatment system for an unbleached kraft linerboard production
facility. The receiving water is the Withlacoochee River. Outfall D-001 has a daily
maximum limit of 20% for discharge flow as a percent of stream flow, although this
parameter is labeled as RWC (Receiving Water Concentration) in the table of limits. In this
permit, RWC does not represent the concentration of a particular constituent, but instead
represents the "concentration" (percentage) of effluent in the river; this is the same as
instream waste concentration (IWC) that is used in some fact sheets for NPDES permits.
RWC is calculated as the average daily effluent flow rate divided by the instantaneous
downstream (not upstream) flow rate using provisional data from a specific USGS gauge
at 7:00 am each day. (Note: The USGS periodically reviews provisional flow data and
sometimes makes slight adjustments before deeming the data as "approved"; the review
might occur a month or more after the provisional data were recorded.) Using an
instantaneous stream flow value instead of a daily average is necessary in order for the
permittee to know how to set the effluent pumping rate for that day (the exact value for the
daily average stream flow will not be known until the end of the day).
This permit also restricts the discharge of 5-day biochemical oxygen demand (BOD5) to
either 14, 12, 10, 8, 6, 4, or 2 pounds per day per cfs of river flow depending on the
dissolved oxygen (DO) levels in the effluent and upstream in the river.
B. GA0003280 - King America Finishing, Inc.: This facility is a textile mill that discharges
a combination of process water, cooling water, and stormwater into the Ogeechee River.
The permit does not allow the 24-hour average effluent flow to exceed either 8% of the
upstream flow or 3.1 million gallons per day (MGD), whichever is smaller. The upstream
flow rate is specified in the permit to be an instantaneous daily reading at 8:00 am at a
USGS gauge.
C. GA0024911 - City of Adel: This is a municipal wastewater treatment facility that
discharges to a small creek with an upstream drainage area of approximately 23 square
miles. The permit specifies a daily maximum limit of either 14% or 25% (depending on
the month of the year) for discharge as percent of stream flow. The permit also specifies
that the percentage is to be calculated using downstream flow. There are no active USGS
flow gauges on this stream; therefore, it appears that the permittee operates a flow
monitoring system themselves.
n

Robyn Gross and Jason Mibroda
May 18, 2022
Page 4
The permit also prohibits the daily maximum effluent flow from exceeding 4.3 MGD,
which is the facility's design flow for treatment. This maximum limit for effluent flow is
unusual and is counter to the basic premise of an HCR that allows facilities to treat
wastewater at a constant rate and store the treated effluent as necessary until the stream has
sufficient assimilative capacity, at which time the maximum allowable effluent flow rate
should be dependent on the assimilative capacity of the stream rather than the treatment
rate.
4.0 IMPLEMENTATION OF AN HCR APPROACH AT BBP
For the proposed new outfall in Little Mountain Creek, the preferred approach for implementing
an HCR is to specify a permit limit for discharge as percent of stream flow. Recommendations for
the flow monitoring and reporting details are as follows:
• Measure stream flow at Highway 740 (just downstream of the proposed outfall) on a
continuous basis (intervals no greater than hourly). If this gauging system is set up and
operated by the USGS, stream flow data will likely be recorded at 15-minute intervals.
• Measure effluent flow with a totalizer or on a continuous basis (intervals no greater than
hourly).
• For each day, calculate 24-hour averages of stream flow at Highway 740 and effluent
flow.
• 24-hour average upstream flow = 24-hour average stream flow at Highway 740 minus
24-hour average effluent flow.
• Discharge flow as percent of stream flow = 100% times 24-hour average effluent flow
divided by 24-hour average upstream flow.
If the stream flow gauging station is set up and operated by the USGS, it is assumed here that they
would prefer to set up the gauging station at the Highway 740 bridge rather than a short distance
upstream of the proposed outfall. Most of the USGS flow gauges are located at bridges, probably
because of three advantages: 1) access, 2) lack of shading on solar panels that are installed to
provide power for the measurement and telemetry devices, and 3) ease of high flow measurements
with an acoustic doppler current profiler (ADCP). However, it is possible that the USGS might be
willing to set up the flow gauge upstream of where the proposed pipeline will enter Little Mountain
Creek, as long as BBP would provide USGS with all-weather access to the gauging site.
It is interesting to note that two of the three example HCR permits described in Section 3 specify
limits based on downstream flow rather than upstream flow. Calculating permit limits based on
downstream flow vs. upstream flow is a simple math exercise, but from an operational standpoint,
using downstream flow creates the equivalent of a circular reference in a spreadsheet when it
comes to controlling the effluent flow (this effect is more pronounced when the effluent flow is a
relatively large percentage of the upstream flow). This is why it is recommended by FTN to use
upstream flow, even if the flow gauge is located downstream of the discharge.
in

Robyn Gross and Jason Mibroda
May 18, 2022
Page 5
In addition to the limit for discharge as percent of stream flow, the permit would need to include
monthly average and daily maximum limits for concentrations of fluoride and cyanide. Using the
equation presented in Section 2 with upstream concentrations of 0.09 mg/L fluoride and zero
cyanide, and water quality standards to protect from chronic toxicity (1.8 mg/L fluoride and
5.0 µg/L cyanide), the recommended limits are:
• Monthly average concentration limits = 3.94 mg/L fluoride and 11.25 µg/L cyanide.
• Daily maximum limit for discharge flow as percent of stream flow = 80%.
The daily maximum concentration limits would be equal to the criteria to protect from acute
toxicity (24 mg/L fluoride and 46.6 µg/L cyanide).
If BBP prefers higher limits for concentrations, then the limit for discharge flow as percent of
stream flow would decrease. Conversely, if BBP prefers a higher limit for discharge flow as
percent of stream flow, the concentration limits would become more stringent.
An alternative HCR permitting approach would consist of permit limits for pounds per day per cfs
of upstream flow instead of discharge flow as percent of stream flow. Like the approach
recommended above, this approach would be protective of instream water quality standards at all
hydrologic conditions. However, the details of implementing this approach can be somewhat
complicated for certain situations.
5.0 ADVANTAGES OF AN HCR APPROACH AT BBP
Any permitting approach for the proposed new outfall in Little Mountain Creek must comply with
the North Carolina Water Quality Standards, including the following requirement: "Toxic
substance standards to protect aquatic life from chronic toxicity shall be protected using the 7Q10
flow" (15A NCAC 02B .0206 (a)(2)). A permit limit for discharge flow as percent of stream flow
complies with that requirement because it will be protective of instream water quality standards at
7Q10 conditions, regardless of whether the 7Q10 is zero or non -zero. Additionally, the limit will
be protective of instream water quality standards at all other hydrologic conditions. If the upstream
flow is zero, the allowable effluent flow will be zero (i.e., the entrance to the pipeline will have to
be completely closed to make sure there is no discharge at the outfall). If the upstream flow is any
non -zero number, the allowable effluent flow will be 80% of that number, which will be protective
of water quality standards. Zero upstream flow is expected to be rare in Little Mountain Creek
based on USGS daily flow data for Dutchmans Creek (gage number 02123567; about 5-6 miles
southeast of BBP), where zero flow occurred during only 1 year out of 19 years of record. The
drainage area at the Dutchmans Creek flow gauge is 3.44 square miles, which is smaller than the
drainage area of Little Mountain Creek at Highway 740 (approximately 5.6 square miles).
n

Robyn Gross and Jason Mibroda
May 18, 2022
Page 6
The recommended limits shown in Section 4 will be protective of water quality standards in the
stream and are expected to be achievable by BBP based on available information. This information
includes a long-term daily hydrologic analysis as well as limited water quality data collected by
BBP in the eastern drainage line within the Outfall 005 drainage area (the drainage line that will
be diverted to the proposed new outfall).
The long-term daily hydrologic analysis consisted of data and calculations to estimate upstream
flows in Little Mountain Creek and effluent flows from the proposed new outfall for each day
during a 19-year period. The 19-year period was selected because it represented the continuous
period of record for USGS daily flow data for Dutchmans Creek. Daily upstream flows in Little
Mountain Creek were estimated as Dutchmans Creek flows multiplied times the ratio of drainage
areas for the two streams. Daily effluent flows for the proposed new outfall were estimated as the
sum of surface runoff and subsurface inflow entering the eastern drainage line within the
Outfall 005 drainage area. Surface runoff was estimated using the SCS curve number method.
Subsurface inflow was estimated by representing shallow groundwater within the drainage area as
a linear reservoir and then adding groundwater inputs from outside the drainage area. The curve
numbers, groundwater recession coefficient, and external groundwater inputs were calibrated by
adjusting their values so that the predicted effluent flows would provide a reasonable match to
continuous flow data collected by BBP in the eastern drainage line during November
2019 - October 2020.
The results of the long-term daily hydrologic analysis showed that effluent flows for the proposed
new outfall are expected to be less than 80% of the upstream flow approximately 99.4% of the
time without controlling the flow entering the pipeline. For the small percentage of time that flow
entering the pipeline will need to be restricted or shut off, the flow in the eastern drainage line will
bypass the pipeline and drain to Outfall 005. This is not expected to have a measurable effect on
long-term compliance at Outfall 005 because it will happen infrequently.
6.0 REFERENCES
Conrads, Paul A, William P. Martello, and Nancy R. Sullins. 2003. "Living with a Large Reduction
in Permited Loading by Using a Hydrograph-Controlled Release Scheme". Environmental
Monitoring and Assessment, January 2003.
https://www.researchgate.net/publication/ 10871043_Living_with_a_Large_Reduction_in
_Permited Loading_by_Using_a_Hydrograph-Controlled Release_Scheme.
EPA. 1984. "A Practical Technology: Hydrograph Controlled Release Lagoons, A Promising
Modification". https://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=200045JF.TXT.
Zirschsky, John, and Richard Thomas. 1987. "State of the Art Hydrograph Controlled Release
(HCR) Lagoons". Journal of Water Pollution Control Federation, Vol. 59, No. 7 (July
1987), pp. 695-698. https://wwwjstor.org/stable/25043324.
n

Robyn Gross and Jason Mibroda
May 18, 2022
Page 7
We appreciate the opportunity to work with you on this project. If you have any questions or
comments regarding this memorandum, please do not hesitate to call me or Nathan Siria, at
[phone].
PHM/dlc
R:\WP_FILES\06010-1805-005\2022-05-18 FTN TM TO BADIN - HCR PERMITTING APPROACHES\2022-05-18 FTN TM TO BADIN - HCR PERMITTIN��
APPROACHES.DOCX
n

Florida Department of
Environmental Protection
Northeast District
8800 Baymeadows Way West, Suite 100
Jacksonville, Florida 32256
April 27, 2018
In the Matter of an
Application for Permit by:
W. Kirk Thomas, Mill Manager
Valdosta Operations
Packaging Corporation of America
Post Office Box 1048
Valdosta, Georgia 31603-1048
Val [e-mail]
Rick Scott
Governor
Carlos Lopez-Cantera
Lt. Governor
Noah Valenstein
Secretary
File Number: FL0000281-007-IW1S
Hamilton County
Packaging Corporation of America - Valdosta Operations
PERMIT ISSUANCE
Enclosed is Permit Number FL0000281 to operate the Packaging Corporation of America -
Valdosta Operations, issued under Chapter 403, Florida Statutes. This permit is for the operation
renewal for the 14 million gallons per day (MGD) average design flow industrial wastewater
treatment system for an unbleached kraft linerboard production facility. The facility is located at
latitude 30° 41' 38.16" N, longitude 83° 18' 18.21" W, on 5495 Clyattville-Lake Park Road,
Valdosta, Georgia 31601 in Lowndes County, with discharge location in Hamilton County,
Florida.
Monitoring requirements under this permit are effective on the first day of the second month
following the effective date of the permit. Until such time, the permittee shall continue to
monitor and report in accordance with previously effective permit requirements, if any.
Any party to this order (permit) has the right to seek judicial review of the permit action under
Section 120.68, Florida Statutes, by the filing of a notice of appeal under Rules 9.110 and 9.190,
Florida Rules of Appellate Procedure, with the Clerk of the Department of Environmental
Protection, Office of General Counsel, 3900 Commonwealth Boulevard, Mail Station 35,
Tallahassee, Florida 32399-3000, and by filing a copy of the notice of appeal accompanied by
the applicable filing fees with the appropriate district court of appeal. The notice of appeal must
be filed within 30 days from the date when this document is filed with the Clerk of the
Department.

PCA — Valdosta Operations
FL0000281-007
Page 2 of 2
Executed in Jacksonville, Florida.
STATE OF FLORIDA DEPARTMENT
OF ENVIRONMENTAL PROTECTION
Thomas G. Kallemeyn
Permitting Program Administrator
CERTIFICATE OF SERVICE
The undersigned duly designated deputy clerk hereby certifies that this permit and all copies
were sent on the filing date below to the following listed persons:
USEPA-Region IV, [e-mail]
Hamilton County Commissioners, [e-mail]
Hamilton County Health Department, [e-mail]
United States Fish & Wildlife Service, heath [e-mail]
Florida Fish & Wildlife Conservation Commission,
[e-mail]
US Army Corps, [e-mail]
Warren Zwanka, SRWMD, [e-mail]
Elsa Potts, PE, FDEP
Jeff Martin, PE, FDEP
Tom Kallemeyn, FDEP
FILING AND ACKNOWLEDGMENT
FILED, on this date, pursuant to Section 120.52, F. S., with the designated Department Clerk,
receipt of which is hereby acknowledged.
Clerk
April 27, 2018
Date

Florida Department of
Environmental Protection
Northeast District
8800 Baymeadows Way West, Suite 100
Jacksonville, Florida 32256
STATE OF FLORIDA
INDUSTRIAL WASTEWATER FACILITY PERMIT
PERMITTEE:
Packaging Corporation of America
RESPONSIBLE OFFICIAL:
W. Kirk Thomas, Mill Manager -Valdosta Operations
Packaging Corporation of America
Post Office Box 1048
Valdosta, Georgia 31603-1048
Phone: [phone]
Email: Val_Environmental(&,,packagingcorp.com
FACILITY:
Packaging Corporation of America - Valdosta Operations
5495 Clyattville — Lake Park Road
Valdosta, Georgia 31601
Latitude: 30° 41' 38.16" N
PERMIT NUMBER:
FILE NUMBER:
ISSUANCE DATE:
EFFECTIVE DATE:
EXPIRATION DATE:
Longitude: 83° 18' 18.21" W
Discharge located in Hamilton County, Florida
Rick Scott
Governor
Carlos Lopez-Cantera
Lt. Governor
Noah Valenstein
Secretary
FL0000281 (Major)
FL0000281-007
April 27, 2018
April 27, 2018
April 26, 2023
This permit is issued under the provisions of Chapter 403, Florida Statutes (F.S.), and applicable rules of the
Florida Administrative Code (F.A.C.) and constitutes authorization to discharge to waters of the state under the
National Pollutant Discharge Elimination System. This permit does not constitute authorization to discharge
wastewater other than as expressly stated in this permit. The above named permittee is hereby authorized to
operate the facilities in accordance with the documents attached hereto and specifically described as follows:
FACILITY DESCRIPTION:
This permit is for the operation renewal for the 14 million gallons per day (MGD) average design flow industrial
wastewater treatment system for an unbleached haft linerboard production facility.
WASTEWATER TREATMENT:
Treatment consists of a mechanical bar screen at the influent to the wastewater lift station prior to the primary
clarifier, a manual bar screen for the auxiliary wastewater lift station bypass line, and a back-up manual bar screen
in the channel downstream from the mechanical bar screen. The wastewater lift station pumps wastewater
consisting of process and non -process wastewater from the mill manufacturing operations, and storm water, to a
primary clarifier and associated sludge ponds for treatment for settleable solids removal.
www. dep.state. tl. us

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
Secondary treatment is accomplished in a series of seven ponds covering approximately 850 acres with nutrient
addition to the individual ponds as needed, and coagulant/precipitant at the discharge from Pond 6 for incremental
emergency color reduction. Pond 1 has been taken out of service and is not currently being used for secondary
treatment, but may be returned to service after solids removal at a later date. There are three facultative ponds,
followed by an aerated stabilization basin, a 350-acre facultative impoundment, and a final polishing pond (Pond
7), prior to a final effluent pumping station and associated conveyance system which discharges final treated
effluent from outfall D-001 to the Withlacoochee River, a Class III fresh surface water of the state.
The facility is located at latitude 30° 41' 38.16" N, longitude 83° 18' 18.21" W, on 5495 Clyattville-Lake Park
Road, Valdosta, Georgia 31601 in Lowndes County, with discharge location in Hamilton County, Florida.
The pump station is designed to convey 55 MGD maximum of effluent to outfall D-001. The pump station
includes bar screens, a post aeration chamber, Parshall flume for effluent flow monitoring, and effluent pumps
which convey the effluent to a final concrete control splitter structure identified as station 001B and then to outfall
D-001. Approximately 13,000 L.F. of 48-inch HDPE transmission pipe conveys the effluent from EFF-1 to
station 001B. The effluent gravity flows into the Withlacoochee River through outfall D-001. Under high -river
stage the control structure splits the flow to a 5th port in order to prevent overflow of effluent from the control
structure and damage from backpressure to the diffuser system and associated effluent conveyance system. A
culvert with a minimum 8 square foot opening in the control dam of Jumping Gully Creek is provided to allow
normal flow from Jumping Gully Creek to pass unrestricted to the Withlacoochee River. Outfall D-001
discharges into a segment of the Withlacoochee wherein a site -specific alternative water quality criterion (SSAC)
for dissolved oxygen (DO) has been established and continued beginning since 1990.
REUSE OR DISPOSAL:
Surface Water Discharge D-001: An existing 55.0 MGD Daily Maximum Flow permitted discharge to
Withlacoochee River, Class III Fresh Waters, (WBID# 3315) which is approximately 150 feet in length under
water diffuser. The point of discharge is located approximately at latitude 30° 37' 22" N, longitude 83° 16' 10"
W.
IN ACCORDANCE WITH: The limitations, monitoring requirements and other conditions set forth in this
Cover Sheet and Part I through Part IX on pages 1 through 23 of this permit.
2

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL000028 1 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
I. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
A. Surface Water Discharges
1. During the period beginning on the issuance date and lasting through the expiration date of this permit, the permittee is authorized to discharge
process wastewater from Outfall D-001 to Withlacoochee River. Such discharge shall be limited and monitored by the permittee as specified
below and reported in accordance with Permit Condition I.B.3:
Effluent Limitations
Monitoring Requirements
Parameter
Units
Max/
Min
Limit
Statistical Basis
Frequency of
Analysis
Sample Type
Monitoring
Site
Notes
Flow (Effluent)
MGD
Max
Report
Monthly Average
Continuous
Recording
Flow Meter
with Totalizer
EFF-1
Report
Daily Maximum
Flow (Upstream River)
CFS
Max
Report
Daily Maximum
Daily
Calculated
CAL-1
See I.A.6
Flow
(Downstream River)
CFS
Max
Report
Daily Maximum
Daily
Calculated
CAL-1
See I.A.5
Flow (RWC)
Percentage
20 % RWC
Daily Maximum
Daily
Calculated
CAL-1
See I.A.4
pH
s.u.
Min
6.0
Daily Minimum
Daily
In -situ
EFF-1
See I.A.10
Max
9.0
Daily Maximum
Oxygen, Dissolved
(DO)
mg/L
Min
1.5
Daily Minimum
Daily
In -situ
EFF-1
See I.A.10
Biochemical Oxygen
Demand-5
lb/day
Max
5,550
Annual Average
Daily
24-hr TPC
EFF-1
See I.A.8
Max
7,792
Monthly Average
Max
15,585
Daily Maximum
3

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL000028 1 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
Effluent Limitations
Monitoring Requirements
T
Parameter
Units
Max/
Min
Limit
Statistical Basis
Frequency of
Analysis
Sample Type
Monitoring
Site
Notes
Solids, Total Suspended
lb/day
Max
10,760
Monthly Average
Weekly
24-hr TPC
EFF-1
Max
16,140
Daily Maximum
Color, True
PCU
Max
See I.A.9
Daily Maximum
Daily
Calculated
CAL-1
See I.A.9,
See I.A.10
Turbidity
NTU
Max
103
Daily Maximum
Weekly
Grab
EFF-1
See I.A.10
Specific Conductance
umhos /cm
Max
3,900
Daily Maximum
Weekly
Grab
EFF-1
See I.A.10
Temperature (°C), Water
Deg °C
Max
Report
Daily Maximum
Weekly
In -situ
EFF-1
Nitrogen, Total
mg/L
Max
Report
Daily Maximum
Quarterly
Grab
EFF-1
Nitrogen, Total
lb/day
Max
Report
Daily Maximum
Quarterly
Calculated
CAL-1
Nitrogen, Kjeldahl,
Total (as N)
mg/L
Max
Report
Daily Maximum
Quarterly
Grab
EFF-1
Nitrogen, Ammonia,
Total (as N)
mg/L
Max
1.40
Daily Maximum
Monthly
Grab
EFF-1
See I.A.10
Phosphorus, Total
(as P)
mg/L
Max
Report
Daily Maximum
Quarterly
Grab
EFF-1
Phosphorus, Total
(as P)
lb/day
Max
Report
Daily Maximum
Quarterly
Calculated
CAL-1
Oil and Grease
mg/L
Max
5.9
Daily Maximum
Quarterly
Grab
EFF-1
See I.A.10
Lead, Total Recoverable
ug/L
Max
9.6
Daily Maximum
Quarterly
Grab
EFF-1
See I.A.10
4

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL000028 1 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
Effluent Limitations
Monitoring Requirements
Parameter
Units
Max/
Min
Limit
Statistical Basis
Frequency of
Analysis
Sample Type
Monitoring
Site
Notes
Hardness, Total
(as CaCO3)
mg/L
Max
Report
Daily Maximum
Quarterly
Grab
EFF-1
Chronic Whole Effluent
Toxicity, 7-Day IC25
(Ceriodaphnia dubia)
percent
Min
35
Single Sample collected
on Days 1, 3, and 5
Annually
Grab
EFF-1
See I.A.13
Chronic Whole Effluent
Toxicity, 7-Day IC25
(Pimephales promelas)
percent
Min
35
Single Sample collected
on Days 1, 3, and 5
Annually
Grab
EFF-1
See I.A.13
Mercury, Total
Recoverable
ug/L
Max
Report
Daily Maximum
Annually
Grab
EFF-1
See I.A.14
Oxygen, Dissolved
(DO)
mg/L
Max
Min
Report
Daily Maximum
Daily
In -situ
SWU-1
Daily Minimum
Monthly Average
pH
s.u.
Max
Report
Daily Maximum
Weekly
In -situ
SWU-1
Min
Report
Daily Minimum
Temperature (°C), Water
Deg °C
Max
Report
Daily Maximum
Weekly
In -situ
SWU-1
Specific Conductance
umhos/ cm
Max
Report
Daily Maximum
Weekly
Grab
SWU-1
Color, True
PCU
Max
Report
Daily Maximum
Daily
Grab
SWU-1
Turbidity
NTU
Max
Report
Daily Maximum
Weekly
Grab
SWU-1
Nitrogen, Total
mg/L
Max
Report
Daily Maximum
Quarterly
Grab
SWU-1
5

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL000028 1 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
Effluent Limitations
Monitoring Requirements
T
Parameter
Units
Max/
Min
Limit
Statistical Basis
Frequency of
Analysis
Sample Type
Monitoring
Site
Notes
r
Report
Annual Geometric Mean
See LA.11
& 12
Nitrogen, Ammonia,
Total (as N)
mg/L
Max
Report
Daily Maximum
Quarterly
Grab
SWU-1
Phosphorus, Total
(as P)
mg/L
Max
Report
Daily Maximum
Quarterly
Grab
SWU-1
See I.A.11
& 12
Report
Annual Geometric Mean
Oil and Grease
mg/L
Max
Report
Daily Maximum
Quarterly
Grab
SWU-1
Lead, Total Recoverable
ug/L
Max
Report
Daily Maximum
Quarterly
Grab
SWU-1
Hardness, Total
(as CaCO3)
mg/L
Max
Report
Daily Maximum
Quarterly
Grab
SWU-1
Oxygen, Dissolved
(DO)
mg/L
Max
Min
Report
Daily Maximum
Daily
In -situ
SWD-1
Daily Minimum
Monthly Average
pH
s.u.
Max
Report
Daily Maximum
Weekly
In -situ
SWD-1
Min
Report
Daily Minimum
Temperature (°C), Water
Deg °C
Max
Report
Daily Maximum
Weekly
In -situ
SWD-1
Specific Conductance
umhos /cm
Max
Report
Daily Maximum
Weekly
Grab
SWD-1
Color, True
PCU
Max
Report
Daily Maximum
Weekly
Grab
SWD-1
6

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL000028 1 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
Effluent Limitations
Monitoring Requirements
Parameter
Units
Max/
Min
Limit
Statistical Basis
Frequency of
Analysis
Sample Type
Monitoring
Site
Notes
Turbidity
NTU
Max
Report
Daily Maximum
Weekly
Grab
SWD-1
Nitrogen, Total
mg/L
Max
Report
Daily Maximum
Quarterly
Grab
SWD-1
See I.A.11
& 12
Max
Report
Annual Geometric Mean
Nitrogen, Ammonia,
Total (as N)
mg/L
Max
Report
Daily Maximum
Quarterly
Grab
SWD-1
Phosphorus, Total
(as P)
mg/L
Max
Report
Daily Maximum
Quarterly
Grab
SWD-1
See I.A.11
& 12
Max
Report
Annual Geometric Mean
Oil and Grease
mg/L
Max
Report
Daily Maximum
Quarterly
Grab
SWD-1
Lead, Total Recoverable
mg/L
Max
Report
Daily Maximum
Quarterly
Grab
SWD-1
Hardness, Total
(as CaCO3)
mg/L
Max
Report
Daily Maximum
Quarterly
Grab
SWD-1
7

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
2. Effluent samples shall be taken at the monitoring site locations listed in Permit Condition I.A.1. and as
described below:
Monitoring Site
Description of Monitoring Site
EFF-1
Effluent control structure following the Parshall flume flow meter. No chemical
addition, including defoamers, shall occur after the sampling location.
CAL-1
Calculated Value.
SWD-2
In the Withlacoochee River at the USGS Gauging Station at Pinetta, Florida. See
I.A.5
SWU-1
In the Withlacoochee River, located approximately 100 feet up stream (north) of
outfall D-001 (located near the confluence of Jumping Gully Creek and the
Withlacoochee River). Streamside samples will be taken from the east riverbank,
approximately four to five feet out from the water's edge.
SWD-1
In the Withlacoochee River, near Florida Highway 150 Bridge. Streamside samples
will be taken approximately four to five feet out from the water's edge or mid -river
from the bridge, as appropriate.
3. The discharge shall not contain components that settle to form putrescent deposits or float as debris, scum, oil,
or other matter. [62-302.500(1)(a)]
4. The Receiving Water Concentration (RWC) shall be calculated daily and reported monthly on the DMR. The
RWC shall be calculated as the average daily effluent flow rate at EFF-1 divided by the daily downstream
river flow rate as measured in the Withlacoochee River at the USGS Gauging Station at Pinetta, Florida per
Note I.A.5. The daily RWC shall not exceed 20 percent after mixing.
5. The daily downstream river flow at SWD-2 shall be reported as the USGS gauging station value at 07:00 am,
as published at the USGS website when the data is available online. If the website data is not available, the
Permittee may obtain a USGS reading via telephone if available, or the Permittee shall take a manual stage
reading at the USGS gauging station before 12:00 noon, and shall use the corresponding USGS flow rating to
report the daily river flow that day.
6. The daily upstream river flow shall be calculated using the downstream flow reading and subtracting the 24-
hour effluent discharge flow. The upstream river flow value is used to calculate the pounds per day of BOD5
for each cubic foot/second (cfs) of river flow, in accordance with I.A.8.
7. Effluent, upstream, and downstream samples for pH and temperature shall be monitored at the same time and
location as the total ammonia grab sample which is used to calculate the TAN standard.
8. If the upstream dissolved oxygen level is greater than or equal to 6.0 mg/L and the effluent dissolved oxygen
is greater than or equal to 3.5 mg/L then the BOD5 limit shall be 14 lbs/day/cfs.
If both of the above conditions are not met then the BOD5 shall be limited as follows:
Upstream Dissolved Oxygen BOD5 Limit (lb/day/river cfs)
Upstream DO > 4.5 mg/L 12 lb/day/cfs
4.4 mg/L< Upstream DO < 4.5 mg/L 10 lb/day/cfs
4.3 mg/L< Upstream DO < 4.4 mg/L 8 lb/day/cfs
8

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
4.2 mg/L< Upstream DO < 4.3 mg/L 6 lb/day/cfs
4.1 mg/L< Upstream DO < 4.3 mg/L 4 lb/day/cfs
Upstream DO <4.1 mg/L 2 lb/day/cfs
9. Color limits were established to meet the transparency standard of FAC Rule 62-302.530(68), in the receiving
water based upon full mixing. Full mixing was determined to be a length of 1,171 feet from outfall structure
D-001 in conjunction with the mixing zones established in Part I.A.10. Therefore, full mixing length is
recognized for demonstrating compliance with the transparency standard in the receiving water.
From the effective date of this permit the permittee shall sample EFF-1 daily and discharge shall comply with
the following effluent limitation:
The seasonal color limit shall be calculated as follows:
May 1- November 30:
Ce = (50/RWC) + Cu
December 1 — April 30:
Ce = (50/RWC) + 125, whenever measured Cu < 125 PCU
Ce = (50/RWC) + Cu, whenever measured Cu > 125 PCU
where:
Ce = effluent color limitation, PCU
Cu = upstream color, PCU, monitored per Part I.A.1.
RWC = receiving water concentration, calculated per Part I.A.4.
The permittee shall calculate the maximum allowable effluent color, measured as true color per NCASI
Technical Bulletin 253, also available as HACH Program 125, for each day based on the RWC and upstream
color, and shall prepare a table of the daily calculated RWC, maximum effluent color limit, and the measured
effluent color value. This table shall be submitted as an attachment to the DMR.
10. Mixing zones are hereby established for the following effluent parameters based on the Maximum instream
waste concentration of the permittee's discharge into the Withlacoochee River. The Permittee's discharge
shall not cause an exceedance of Rule 62-302.530, F.A.C., Class III fresh water quality criteria outside the
described mixing zones for each parameter identified below with the exception of dissolved oxygen in
accordance with the Department approved site -specific alternative criteria (SSAC). The SSAC approved on
February 14, 1990 (DEP File No. VE-24-334), allows the dissolved oxygen outside of the mixing zone to not
be lowered to any less than 4.0 mg/L during the months of June through October. The receiving water shall at
no time have in excess of 20 percent mill effluent as calculated pursuant to Part I.A.4:
Length Downstream from Outfall D-001
a. Dissolved oxygen 1,171 ft.
b. Specific Conductance 853 ft.
c. Chronic Whole Effluent Toxicity 1,171 ft.
d. pH 1,171 ft.
e. Turbidity 828 ft.
9

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
f. Total Ammonia Nitrogen as N
g. Total Recoverable Lead
h. Transparency
i. Oil & Grease
663 ft.
972 ft.
1,171 ft.
396 ft.
11. To evaluate narrative nutrient criteria as well as demonstrate that the discharge shall not cause an imbalance
in natural populations of flora or fauna, the Permittee shall conduct the Department approved bioassessment
Plan of Study (POS) on the second (year 2019) and fourth years (year 2021) of the permit term. Based upon
the results of the required bioassessment sampling, or Department bioassessments of the Withlacoochee
River, the permit may be reopened as necessary (in accordance with Part VII.F of the permit) to include
biointegrity monitoring, reporting or limitations in accordance with FAC Rule 62-302.530(47)(a) and (b).
[62-302.531(2)(c)]
12. The Permittee shall monitor for total nitrogen (TN) and total phosphorus (TP) upstream and downstream of
the point of discharge and calculate the annual geometric mean concentrations of TN and TP. The annual
geometric mean concentrations of TN or TP shall be calculated once per calendar year using all data collected
during the period. [62-302.531(6)1
13. The permittee shall comply with the following requirements to evaluate chronic whole effluent toxicity of the
discharge from outfall D-001.
a. Effluent Limitation
(1) In any routine or additional follow-up test for chronic whole effluent toxicity, the 25 percent
inhibition concentration (IC25) shall not be less than 35% effluent. [Rules 62-302.530(61) and 62-
4.241(2)(b), F.A.C.]
(2) For acute whole effluent toxicity, the 96-hour LC50 shall not be less than 100% effluent in any test.
[Rule 62-302.500(1)(a)4 and 62-4.241(2)(a), F.A.C.]
b. Monitoring Frequency
(1) Routine toxicity tests shall be conducted annually, the first starting within 1 year from the last chronic
test and lasting for the duration of this permit.
c. Sampling Requirements
(1) For each routine test or additional follow-up test conducted, single grab samples of final effluent shall
be collected on days 1, 3 and 5 and used in accordance with the sampling protocol discussed in EPA-
821-R-02-013, Section 8.
(2) The first sample shall be used to initiate the test. The remaining two samples shall be collected according
to the protocol and used as renewal solutions on Day 3 (48 hours) and Day 5 (96 hours) of the test.
(3) Samples for routine and additional follow-up tests shall not be collected on the same day.
d. Test Requirements
(1) Routine Tests: All routine tests shall be conducted using a control (0% effluent) and a minimum of
five test dilutions: 100%, 70%, 35%, 20%, and 10% final effluent.
(2) The permittee shall conduct a daphnid, Ceriodaphnia dubia, Survival and Reproduction Test and a
fathead minnow, Pimephales promelas, Larval Survival and Growth Test, concurrently.
(3) All test species, procedures and quality assurance criteria used shall be in accordance with Short-term
Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to Freshwater
Organisms, 4th Edition, EPA-821-R-02-013. Any deviation of the bioassay procedures outlined
herein shall be submitted in writing to the Depai tinent for review and approval prior to use. In the
event the above method is revised, the permittee shall conduct chronic toxicity testing in accordance
with the revised method.
(4) The control water and dilution water shall be moderately hard water as described in EPA-821-R-02-
013, Section 7.2.3.
10

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
e. Quality Assurance Requirements
(1) A standard reference toxicant (SRT) quality assurance (QA) chronic toxicity test shall be conducted
with each species used in the required toxicity tests either concurrently or initiated no more than 30
days before the date of each routine or additional follow-up test conducted. Additionally, the SRT test
must be conducted concurrently if the test organisms are obtained from outside the test laboratory
unless the test organism supplier provides control chart data from at least the last five monthly
chronic toxicity tests using the same reference toxicant and test conditions. If the organism supplier
provides the required SRT data, the organism supplier's SRT data and the test laboratory's monthly
SRT-QA data shall be included in the reports for each companion routine or additional follow-up test
required.
(2) If the mortality in the control (0% effluent) exceeds 20% for either species in any test, or any other
test acceptability criteria are not met, the test for that species (including the control) shall be
invalidated and the test repeated. Test acceptability criteria for each species are defined in EPA-821-
R-02-013, Section 13.12 (Ceriodaphnia dubia) and Section 11.11 (Pimephales promelas). The
repeat test shall begin within 21 days after the last day of the invalid test.
(3) If 100% mortality occurs in all effluent concentrations for either species prior to the end of any test
and the control mortality is less than 20% at that time, the test (including the control) for that species
shall be terminated with the conclusion that the test fails and constitutes non-compliance.
(4) Routine and additional follow-up tests shall be evaluated for acceptability based on the observed
dose -response relationship as required by EPA-821-R-02-013, Section 10.2.6., and the evaluation
shall be included with the bioassay laboratory reports.
f. Reporting Requirements
(1) Results from all required tests shall be reported on the Discharge Monitoring Report (DMR) as the
calculated IC25 for each test species.
(2) A bioassay laboratory report for each routine test shall be prepared according to EPA-821-R-02-013,
Section 10, Report Preparation and Test Review, and mailed or emailed to the Department at the
address below within 30 days after the last day of the test.
(3) For additional follow-up tests, a single bioassay laboratory report shall be prepared according to EPA-
821-R-02-013, Section 10, and mailed or emailed within 30 days after the last day of the second valid
additional follow-up test.
(4) Data for invalid tests shall be included in the bioassay laboratory report for the repeat test.
(5) The same bioassay data shall not be reported as the results of more than one test.
(6) All bioassay laboratory reports shall be mailed or emailed within 30 days to Jacksonville only:
Florida Department of Environmental Protection
Northeast District — Wastewater Section
8800 Baymeadows Way West, Suite 100
Jacksonville, Florida 32256
g•
Test Failures
A test fails when the test results do not meet the limits in 13.a.(1).
(1) Additional Follow-up Tests:
(a) If a routine test does not meet the chronic toxicity limitation in 13.a.(1) above, the permittee shall
notify the Depai tinent at the address above within 21 days after the last day of the failed routine
test and conduct two additional follow-up tests on each species that failed the test in accordance
with 13.d.
(b) The first test shall be initiated within 28 days after the last day of the failed routine test. The
remaining additional follow-up tests shall be conducted weekly thereafter until a total of two
valid additional follow-up tests are completed.
(c) The additional follow-up tests shall be conducted using a control (0% effluent) and a minimum of
five dilutions: 100%, 70%, 35%, 20%, and 10% effluent. The permittee may modify the dilution
series in the additional follow-up tests to more accurately bracket the toxicity such that at least
11

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
two dilutions above and two dilutions below the target concentration and a control (0% effluent)
are run. All test results shall be analyzed according to the procedures in EPA-821-R-02-013.
(2) In the event of three valid test failures (whether routine or additional follow-up tests) within a 12-
month period, the permittee shall notify the Department within 21 days after the last day of the third
test failure.
(a) The permittee shall submit a plan for correction of the effluent toxicity within 60 days after the
last day of the third test failure.
(b) The Department shall review and approve the plan before initiation.
(c) The plan shall be initiated within 30 days following the Department's written approval of the plan.
(d) Progress reports shall be submitted quarterly to the Department at the address above.
(e) During the implementation of the plan, the permittee shall conduct quarterly routine whole
effluent toxicity tests in accordance with 13.d. Additional follow-up tests are not required while
the plan is in progress. Following completion or termination of the plan, the frequency of
monitoring for routine and additional follow-up tests shall return to the schedule established in
13.b.(1). If a routine test is invalid according to the acceptance criteria in EPA-821-R-02-013, a
repeat test shall be initiated within 21 days after the last day of the invalid routine test.
(f) Upon completion of four consecutive quarterly valid routine tests that demonstrate compliance
with the effluent limitation in 13.a.(1) above, the permittee may submit a written request to the
Department to terminate the plan. The plan shall be terminated upon written verification by the
Department that the facility has passed at least four consecutive quarterly valid routine whole
effluent toxicity tests.
(g) If a test within the sequence of the four is deemed invalid, but is replaced by a repeat valid test
initiated within 21 days after the last day of the invalid test, the invalid test will not be counted
against the requirement for four consecutive quarterly valid routine tests for the purpose of
terminating the plan.
(3) If chronic toxicity test results indicate greater than 50% mortality within 96 hours in an effluent
concentration equal to or less than the effluent concentration specified as the acute toxicity limit in
13.(a)(2), the Department may revise this permit to require acute definitive whole effluent toxicity
testing.
(4) The additional follow-up testing and the plan do not preclude the Department taking enforcement
action for acute or chronic whole effluent toxicity failures.
[62-4.241, 62-620.620(3)]
14. EPA Method 1631E shall be used to analyze for total recoverable mercury or other clean techniques
approved for analysis such as Method 245.1 or Method 245.7 where the method detection limit is equal
to or less than 25 ng/L. If the values detected are below the water quality standard the mercury is in
compliance and does not trigger the need for a minimization plan. However, if testing results are above
the water quality standard of 0.012 ug/L, the permittee shall contact and discuss with the DEP NED
wastewater section within 30 days of receipt of the results prior to submitting, preparing and
implementing a mercury minimization plan addressing sources of mercury. [62-304.900, 62-302 FAC,
62-4 FAC]
15. If conventional effluent discharge restrictions and other factors (e.g., weather) result in the
Permittee's holding pond #6 level to exceed 85 inches of impounded effluent, the Permittee will be
allowed to utilize a temporary alternative discharge strategy until the holding pond level is below 85
inches of level (the emergency spillway from Pond 6 to Pond 7 is at level 132 inches elevation). The
Permittee will be allowed to utilize this temporary alternative discharge strategy by observing the
following requirements:
a. The Permittee must notify the Department (i.e., e-mail or written correspondence) one (1)
business day in advance of its intent to utilize the temporary alternative discharge allowance.
Report holding pond #6 elevation.
12

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
b. The Permittee must notify the Department (i.e., e-mail or written correspondence) one (1)
business day after ceasing to utilize the temporary alternative discharge allowance. Report
holding pond #6 elevation.
c. While utilizing this temporary alternative discharge allowance, the Permittee must provide the
Department with daily updates with respect to the actual volume of effluent discharged to the
receiving stream and the calculations used to determine the allowable discharge volume.
d. The Permittee must use the following algorithm to determine the allowable volume of treated
effluent that can be discharged to the receiving stream:
i. Available Receiving Stream D.O., lb_oxygen = Upstream river flow, MGD * (Upstream
D.O. mg/L — 4.0 mg/L limit) * 8.34
ii. Allowable Mill Effluent Discharge, MGD = Available Receiving Stream D.O.,
lb_oxygen / (8.34 x 9 mg/L BOD**)
**Conservative assumption based on 5-year daily actual maximum discharge
The Permittee must adhere to all other effluent limitations and monitoring requirements.
[62-620.620]
B. Other Limitations and Monitoring and Reporting Requirements
1. The sample collection, analytical test methods, and method detection limits (MDLs) applicable to this
permit shall be conducted using a sufficiently sensitive method to ensure compliance with applicable
water quality standards and effluent limitations and shall be in accordance with Rule 62-4.246,
Chapters 62-160 and 62-601, F.A.C., and 40 CFR 136, as appropriate. The list of Department
established analytical methods, and corresponding MDLs (method detection limits) and PQLs
(practical quantitation limits), which is titled "FAC 62-4 MDL/PQL Table (April 26, 2006)" is
available at http://www.dep.state.fl.us/labs/library/index.htm. The MDLs and PQLs as described in
this list shall constitute the minimum acceptable MDL/PQL values and the Department shall not
accept results for which the laboratory's MDLs or PQLs are greater than those described above unless
alternate MDLs and/or PQLs have been specifically approved by the Department for this permit. Any
method included in the list may be used for reporting as long as it meets the following requirements:
a. The laboratory's reported MDL and PQL values for the particular method must be equal or less
than the corresponding method values specified in the Depaitiiient's approved MDL and PQL list;
b. The laboratory reported MDL for the specific parameter is less than or equal to the permit limit or
the applicable water quality criteria, if any, stated in Chapter 62-302, F.A.C. Parameters that are
listed as "report only" in the permit shall use methods that provide an MDL, which is equal to or
less than the applicable water quality criteria stated in 62-302, F.A.C.; and
c. If the MDLs for all methods available in the approved list are above the stated permit limit or
applicable water quality criteria for that parameter, then the method with the lowest stated MDL
shall be used.
When the analytical results are below method detection or practical quantitation limits, the permittee
shall report the actual laboratory MDL and/or PQL values for the analyses that were performed
following the instructions on the applicable discharge monitoring report.
Where necessary, the permittee may request approval of alternate methods or for alternative MDLs or
PQLs for any approved analytical method. Approval of alternate laboratory MDLs or PQLs are not
necessary if the laboratory reported MDLs and PQLs are less than or equal to the permit limit or the
applicable water quality criteria, if any, stated in Chapter 62-302, F.A.C. Approval of an analytical
method not included in the above -referenced list is not necessary if the analytical method is approved
in accordance with 40 CFR 136 or deemed acceptable by the Department. [62-4.246, 62-160]
With respect to this Permit, the Department approves all effluent and receiving water color monitoring
to be measured using the NCASI method authorized in the previous Permits to this facility [NCASI
13

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
Technical Bulletin No.253 for color, reported in Platinum -Cobalt Units (PCU), specifying the color as
True Color; also available as HACH Program 125]
The Department approves the use of HACH Method 8195 as an alternative to EPA Method 180.1, Rev
2.0, and the use of the Modified HACH Method 8195, i.e., HACH Method 8195 using Ratio
Instrument Design, for use with samples with turbidity greater than 40 NTU.
2. The permittee shall provide safe access points for obtaining representative influent and effluent
samples which are required by this permit. [62-620.320(6)]
3. Monitoring requirements under this permit are effective on the first day of the second month
following permit issuance. Until such time, the permittee shall continue to monitor and report in
accordance with previously effective permit requirements, if any. During the period of operation
authorized by this permit, the permittee shall complete and submit to the Department Discharge
Monitoring Reports (DMRs) in accordance with the frequencies specified by the REPORT type (i.e.
monthly, toxicity, quarterly, semiannual, annual, etc.) indicated on the DMR forms attached to this
permit. Unless specified otherwise in this permit, monitoring results for each monitoring period shall
be submitted in accordance with the associated DMR due dates below. DMRs shall be submitted for
each required monitoring period including periods of no discharge.
REPORT Type on DMR
Monitoring Period
Mail or Electronically Submit by
Monthly
first day of month - last day of month
28th day of following month
Toxicity
first day of month - last day of month
28th day of following month
Quarterly
January 1 - March 31
April 1 - June 30
July 1 - September 30
October 1 - December 31
April 28
July 28
October 28
January 28
Semi-annual
January 1 - June 30
July 1 - December 30
July 28
January 28
Annual
January 1 - December 31
January 28
The permittee shall use the electronic DMR system approved by the Department (EzDMR) and shall
electronically submit the completed DMR forms using the DEP Business Portal at
http://www.fldepportal.com/go/, unless the permittee has a waiver from the Department in accordance
with 40 CFR 127.15. Reports shall be submitted to the Department by the twenty-eighth (28th) of the
month following the month of operation.
[62-620.610(1811[62-600.680(1)]
4. Unless specified otherwise in this permit, all reports and other information required by this permit,
including 24-hour notifications, shall be submitted to or reported to, as appropriate, the Department's
Northeast District Office at the address specified below:
Florida Department of Environmental Protection
Northeast District
8800 Baymeadows Way West, Suite 100
Jacksonville, Florida 32256
Phone [phone]; FAX [phone]
(All FAX copies and e-mails shall be followed by original copies.) [62-620.305]
14

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
5. All reports and other information shall be signed in accordance with the requirements of Rule 62-620.305,
F.A.C. [62-620.305]
6. If there is no discharge from the facility on a day when the facility would normally sample, the sample
shall be collected on the day of the next discharge. [62-620.320(6)]
II. SLUDGE MANAGEMENT REQUIREMENTS
1. Section II is not applicable to this facility.
III. GROUND WATER REQUIREMENTS
1. Section III is not applicable to this facility.
IV. ADDITIONAL LAND APPLICATION REQUIREMENTS
1. Section IV is not applicable to this facility.
V. OPERATION AND MAINTENANCE REQUIREMENTS
1. During the period of operation authorized by this permit, the wastewater facilities shall be operated
under the supervision of a person who is qualified by formal training and/or practical experience in
the field of water pollution control. [62-620.320(6)]
2. The permittee shall maintain the following records and make them available for inspection on the site
of the permitted facility.
a. Records of all compliance monitoring information, including all calibration and maintenance
records and all original strip chart recordings or electronically recorded data in the Process
Information system for continuous monitoring instrumentation, including, if applicable, a copy of
the laboratory certification showing the certification number of the laboratory, for at least three
years from the date the sample or measurement was taken;
b. Copies of all reports required by the permit for at least three years from the date the report was
prepared;
c. Records of all data, including reports and documents, used to complete the application for the
permit for at least three years from the date the application was filed;
d. A copy of the current permit;
e. A copy of any required record drawings; and
f. Copies of the logs and schedules showing plant operations and equipment maintenance for three
years from the date of the logs or schedules.
[62-620.350]
VI. SCHEDULES
1. The following improvement actions shall be completed according to the following schedule. The
Best Management Practices (BMP) Plan shall be prepared and implemented in accordance with Part
VII of this permit.
Improvement Action
Completion Date
a. Continue implementing the existing BMP Plan
Issuance date of permit
[62-620.320(6)]
15

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
2. The permittee is not authorized to discharge to waters of the state after the expiration date of this
permit, unless:
a. The permittee has applied for renewal of this permit at least 180 days before the expiration date
of this permit using the appropriate forms listed in Rule 62-620.910, F.A.C., and in the manner
established in the Department of Environmental Protection Guide to Permitting Wastewater
Facilities or Activities Under Chapter 62-620, F.A.C., including submittal of the appropriate
processing fee set forth in Rule 62-4.050, F.A.C.; or
b. The permittee has made complete the application for renewal of this permit before the permit
expiration date.
[62-620.335(1)-(4)J
VII. BEST MANAGEMENT PRACTICES/STORMWATER POLLUTION PREVENTION PLANS
A. Specific Conditions Applicable to All Permits
1. Drawings, plans, documents or specifications submitted by the permittee, not attached hereto, but
retained on file at the Northeast District Office, are made a part hereof.
2. Where required by Chapter 471 (P.E.) or Chapter 492 (P.G.) FS, applicable portions of reports to be
submitted under this permit, shall be signed and sealed by the professional(s) who prepared them.
3. This permit satisfies Industrial Wastewater program permitting requirements only and does not
authorize operation of this facility prior to obtaining any other permits required by local, state or
federal agencies.
4. The permittee shall provide verbal notice to the Department as soon as practical after discovery of a
sinkhole within an area for the management or application of wastewater or sludge. The permittee
shall immediately implement measures appropriate to control the entry of contaminants, and shall
detail these measures to the Department in a written report within 7 days of the sinkhole discovery.
B. Specific Conditions Related to Construction
1. This section is not applicable to this facility.
C. Duty to Reapply
1 The permittee shall apply for renewal of this permit at least 180 days before the expiration date of the
permit using the appropriate forms listed in Rule 62-620.910, FAC, including submittal of the
appropriate processing fee set forth in Rule 62-4.050, FAC. The existing permit shall not expire until
the Department has taken final action on the application renewal in accordance with the provisions of
Rules 62-620.335(3) and (4), FAC.
D. Specific Conditions Related to Best Management Practices
1. BMP Plan:
For purposes of this part, the terms "pollutant" or "pollutants" refer to any substance listed as toxic
under Section 307(a)(1) of the Clean Water Act (the "Act"), oil, as defined in Section 311(a)(1) of the
Act, and any substance listed as hazardous under Section 311 of the Act. The permittee shall develop
and implement a Best Management Practices (BMP) plan which prevents, or minimizes, the potential
for the release of pollutants from ancillary activities, including material storage areas; plant site runoff;
16

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
in -plant transfer, process and material handling areas; loading and unloading operations; and sludge
and waste disposal areas, to the waters of the State through plant site runoff; spillage or leaks; sludge
or waste disposal; or drainage from raw material storage.
2. Implementation:
The BMP plan shall be implemented in accordance with the schedule contained in Part VI of this
permit.
3. General Requirements:
The BMP plan shall:
a. Be documented in narrative form, and shall include any necessary plot plans, drawings or maps.
b. Establish specific objectives for the control of pollutants.
(1) Each facility component or system shall be examined for its potential for causing a release of
significant amounts of pollutants to waters of the State due to equipment failure, improper
operation, natural phenomena such as rain or snowfall, etc.
(2) Where experience indicates a reasonable potential for equipment failure (e.g., a tank overflow or
leakage), natural conditions (e.g., precipitation), or other circumstances to result in significant
amounts of pollutants reaching surface waters, the plan should include a prediction of the
direction, rate of flow, and total quantity of pollutants which could be discharged from the facility
as a result of each condition or circumstance.
c. Establish specific best management practices to meet the objectives identified under paragraph b. of
this subsection, addressing each component or system capable of causing a release of significant
amounts of pollutants to the waters of the State, and identifying specific preventative or remedial
measures to be implemented.
d. Be reviewed by plant engineering staff and plant manager.
4. Documentation:
The permittee shall maintain the BMP plan at the facility and shall make the plan available to the
Department upon request.
5. BMP Plan Modification:
The permittee shall amend the BMP plan whenever there is a change in the facility or change in the
operation of the facility which materially increases the potential for the ancillary activities to result in a
discharge of significant amounts of pollutants.
6. Modification for Ineffectiveness:
If the BMP plan proves to be ineffective in achieving the general objective of preventing the release of
significant amounts of pollutants to surface waters and the specific objectives and requirements under
paragraphs b. and c. of item 3, the permit shall be subject to modification pursuant to rule 62-620.325,
FAC, to incorporate revised BMP requirements.
17

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
E. Specific Conditions Related to Existing Manufacturing, Commercial, Mining, and Silviculture
Wastewater Facilities or Activities
1. Existing manufacturing, commercial, mining, and silvicultural wastewater facilities or activities that
discharge into surface waters shall notify the Department as soon as they know or have reason to
believe:
a. That any activity has occurred or will occur which would result in the discharge, on a routine or
frequent basis, of any toxic pollutant which is not limited in the permit, if that discharge will exceed
the highest of the following levels
(1) One hundred micrograms per liter,
(2) Two hundred micrograms per liter for acrolein and acrylonitrile; five hundred micrograms per liter
for 2,4-dinitrophenol and for 2-methyl-4,6-dinitrophenol; and one milligram per liter for antimony, or
(3) Five times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine or
infrequent basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the
highest of the following levels
(1) Five hundred micrograms per liter,
(2) One milligram per liter for antimony, or
(3) Ten times the maximum concentration value reported for that pollutant in the permit application.
F. Reopener Clause
1. The permit or Bioassessment Plan of Study (see Part I.A.11) may be revised, or alternatively, revoked
and reissued in accordance with the provisions contained in Rules 62-620.325 and 62-620.345, FAC, if
applicable, or to comply with any applicable effluent standard or limitation issued or approved under
Sections 301(b)(2)(C) and (D), 304(b)(2) and 307(a)(2) of the Clean Water Act (the Act), as amended,
if the effluent standards, limitations, or water quality standards so issued or approved:
a. Contain different conditions or is otherwise more stringent than any condition in the permit/or;
b. Control any pollutant not addressed in the permit.
c. The standard or limitation has been duly adopted by the Department.
The permit as revised or reissued under this paragraph shall also contain any other requirements of the
Act then applicable.
2. The permit may be reopened to adjust effluent limitations or monitoring requirements should future
Water Quality Based Effluent Limitation determinations, water quality studies, DEP approved changes
in water quality standards, or other information show a need for a different limitation or monitoring
requirement.
3. The Department may develop a revised or additional Total Maximum Daily Loads (TMDL) during the
life of the permit. Once a new or revised TMDL has been established and adopted by rule, the
Department may revise this permit to incorporate the final findings of the TMDL.
VIII. GENERAL CONDITIONS
1. The terms, conditions, requirements, limitations and restrictions set forth in this permit are binding
and enforceable pursuant to Chapter 403, Florida Statutes. Any permit noncompliance constitutes a
violation of Chapter 403, Florida Statutes, and is grounds for enforcement action, permit termination,
permit revocation and reissuance, or permit revision. [62-620.610(1)]
18

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
2. This permit is valid only for the specific processes and operations applied for and indicated in the
approved drawings or exhibits. Any unauthorized deviations from the approved drawings, exhibits,
specifications or conditions of this permit constitute grounds for revocation and enforcement action
by the Department. [62-620.610(2)]
3. As provided in subsection 403.087(7), F.S., the issuance of this permit does not convey any vested
rights or any exclusive privileges. Neither does it authorize any injury to public or private property or
any invasion of personal rights, nor authorize any infringement of federal, state, or local laws or
regulations. This permit is not a waiver of or approval of any other Department permit or
authorization that may be required for other aspects of the total project which are not addressed in this
permit. [62-620.610(3)]
4. This permit conveys no title to land or water, does not constitute state recognition or acknowledgment
of title, and does not constitute authority for the use of submerged lands unless herein provided and the
necessary title or leasehold interests have been obtained from the State. Only the Trustees of the
Internal Improvement Trust Fund may express State opinion as to title. [62-620.610(4)]
5. This permit does not relieve the permittee from liability and penalties for harm or injury to human
health or welfare, animal or plant life, or property caused by the construction or operation of this
permitted source; nor does it allow the permittee to cause pollution in contravention of Florida
Statutes and Department rules, unless specifically authorized by an order from the Department. The
permittee shall take all reasonable steps to minimize or prevent any discharge, reuse of reclaimed
water, or residuals use or disposal in violation of this permit which has a reasonable likelihood of
adversely affecting human health or the environment. It shall not be a defense for a permittee in an
enforcement action that it would have been necessary to halt or reduce the permitted activity in order
to maintain compliance with the conditions of this permit. [62-620.610(5)]
6. If the permittee wishes to continue an activity regulated by this permit after its expiration date, the
permittee shall apply for and obtain a new permit. [62-620.610(6)]
7. The permittee shall at all times properly operate and maintain the facility and systems of treatment
and control, and related appurtenances, that are installed and used by the permittee to achieve
compliance with the conditions of this permit. This provision includes the operation of backup or
auxiliary facilities or similar systems when necessary to maintain or achieve compliance with the
conditions of the permit. [62-620.610(7)]
8. This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request
by the permittee for a permit revision, revocation and reissuance, or termination, or a notification of
planned changes or anticipated noncompliance does not stay any permit condition. [62-620.610(8)]
9. The permittee, by accepting this permit, specifically agrees to allow authorized Department
personnel, including an authorized representative of the Department and authorized EPA personnel,
when applicable, upon presentation of credentials or other documents as may be required by law, and
at reasonable times, depending upon the nature of the concern being investigated, to:
a. Enter upon the permittee's premises where a regulated facility, system, or activity is located or
conducted, or where records shall be kept under the conditions of this permit;
b. Have access to and copy any records that shall be kept under the conditions of this permit;
c. Inspect the facilities, equipment, practices, or operations regulated or required under this permit;
and
19

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
d. Sample or monitor any substances or parameters at any location necessary to assure compliance
with this permit or Department rules.
[62-620.610(9)]
10. In accepting this permit, the permittee understands and agrees that all records, notes, monitoring data,
and other information relating to the construction or operation of this permitted source which are
submitted to the Department may be used by the Department as evidence in any enforcement case
involving the permitted source arising under the Florida Statutes or Department rules, except as such
use is proscribed by Section 403.111, F.S., or Rule 62-620.302, F.A.C. Such evidence shall only be
used to the extent that it is consistent with the Florida Rules of Civil Procedure and applicable
evidentiary rules. [62-620.610(10)]
11. When requested by the Department, the permittee shall within a reasonable time provide any
information required by law which is needed to determine whether there is cause for revising,
revoking and reissuing, or terminating this permit, or to determine compliance with the permit. The
permittee shall also provide to the Department upon request copies of records required by this permit
to be kept. If the permittee becomes aware of relevant facts that were not submitted or were incorrect
in the permit application or in any report to the Department, such facts or information shall be
promptly submitted or corrections promptly reported to the Department. [62-620.610(11)]
12. Unless specifically stated otherwise in Department rules, the permittee, in accepting this permit,
agrees to comply with changes in Department rules and Florida Statutes after a reasonable time for
compliance; provided, however, the permittee does not waive any other rights granted by Florida
Statutes or Department rules. A reasonable time for compliance with a new or amended surface water
quality standard, other than those standards addressed in Rule 62-302.500, F.A.C., shall include a
reasonable time to obtain or be denied a mixing zone for the new or amended standard. [62-
620.610(12)]
13. The permittee, in accepting this permit, agrees to pay the applicable regulatory program and
surveillance fee in accordance with Rule 62-4.052, F.A.C. [62-620.610(13)]
14. This permit is transferable only upon Department approval in accordance with Rule 62-620.340,
F.A.C. The permittee shall be liable for any noncompliance of the permitted activity until the transfer
is approved by the Department. [62-620.610(14)]
15. The permittee shall give the Department written notice at least 60 days before inactivation or
abandonment of a wastewater facility or activity and shall specify what steps will be taken to
safeguard public health and safety during and following inactivation or abandonment. [62-
620.610(15)]
16. The permittee shall apply for a revision to the Department permit in accordance with Rules 62-
620.300, F.A.C., and the Department of Environmental Protection Guide to Permitting Wastewater
Facilities or Activities Under Chapter 62-620, F.A.C., at least 90 days before construction of any
planned substantial modifications to the permitted facility is to commence or with Rule 62-
620.325(2), F.A.C., for minor modifications to the permitted facility. A revised permit shall be
obtained before construction begins except as provided in Rule 62-620.300, F.A.C. [62-620.610(16)]
17. The permittee shall give advance notice to the Department of any planned changes in the permitted
facility or activity which may result in noncompliance with permit requirements. The permittee shall
be responsible for any and all damages which may result from the changes and may be subject to
20

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
enforcement action by the Department for penalties or revocation of this permit. The notice shall
include the following information:
a. A description of the anticipated noncompliance;
b. The period of the anticipated noncompliance, including dates and times; and
c. Steps being taken to prevent future occurrence of the noncompliance.
[62-620. 610(17)]
18. Sampling and monitoring data shall be collected and analyzed in accordance with Rule 62-4.246 and
Chapters 62-160, 62-601, and 62-610, F.A.C., and 40 CFR 136, as appropriate.
a. Monitoring results shall be reported at the intervals specified elsewhere in this permit and shall be
reported on a Discharge Monitoring Report (DMR), DEP Form 62-620.910(10), or as specified
elsewhere in the permit.
b. If the permittee monitors any contaminant more frequently than required by the permit, using
Department approved test procedures, the results of this monitoring shall be included in the
calculation and reporting of the data submitted in the DMR.
c. Calculations for all limitations which require averaging of measurements shall use an arithmetic
mean unless otherwise specified in this permit.
d. Except as specifically provided in Rule 62-160.300, F.A.C., any laboratory test required by this
permit shall be performed by a laboratory that has been certified by the Department of Health
Environmental Laboratory Certification Program (DOH ELCP). Such certification shall be for
the matrix, test method and analyte(s) being measured to comply with this permit. For domestic
wastewater facilities, testing for parameters listed in Rule 62-160.300(4), F.A.C., shall be
conducted under the direction of a certified operator.
e. Field activities including on -site tests and sample collection shall follow the applicable standard
operating procedures described in DEP-SOP-001/01 adopted by reference in Chapter 62-160, F.A.C.
f. Alternate field procedures and laboratory methods may be used where they have been approved
in accordance with Rules 62-160.220, and 62-160.330, F.A.C.
[62-620.610(18)]
19. Reports of compliance or noncompliance with, or any progress reports on, interim and final
requirements contained in any compliance schedule detailed elsewhere in this permit shall be
submitted no later than 14 days following each schedule date. [62-620.610(19)]
20. The permittee shall report to the Department's Northeast District any noncompliance which may
endanger health or the environment. Any information shall be provided orally within 24 hours from
the time the permittee becomes aware of the circumstances. A written submission shall also be
provided within five days of the time the permittee becomes aware of the circumstances. The written
submission shall contain: a description of the noncompliance and its cause; the period of
noncompliance including exact dates and time, and if the noncompliance has not been corrected, the
anticipated time it is expected to continue; and steps taken or planned to reduce, eliminate, and
prevent recurrence of the noncompliance.
a. The following shall be included as information which must be reported within 24 hours under this
condition:
(1) Any unanticipated bypass which causes any reclaimed water or effluent to exceed any permit
limitation or results in an unpermitted discharge,
21

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
(2) Any upset which causes any reclaimed water or the effluent to exceed any limitation in the
permit,
(3) Violation of a maximum daily discharge limitation for any of the pollutants specifically listed
in the permit for such notice, and
(4) Any unauthorized discharge to surface or ground waters.
b. Oral reports as required by this subsection shall be provided as follows:
(1) For unauthorized releases or spills of treated or untreated wastewater reported pursuant to
subparagraph (a)4. that are in excess of 1,000 gallons per incident, or where information
indicates that public health or the environment will be endangered, oral reports shall be
provided to the STATE WARNING POINT TOLL FREE NUMBER [phone], as
soon as practical, but no later than 24 hours from the time the permittee becomes aware of the
discharge. The permittee, to the extent known, shall provide the following information to the
State Warning Point:
(a) Name, address, and telephone number of person reporting;
(b) Name, address, and telephone number of permittee or responsible person for the
discharge;
(c) Date and time of the discharge and status of discharge (ongoing or ceased);
(d) Characteristics of the wastewater spilled or released (untreated or treated, industrial or
domestic wastewater);
(e) Estimated amount of the discharge;
(f) Location or address of the discharge;
(g) Source and cause of the discharge;
(h) Whether the discharge was contained on -site, and cleanup actions taken to date;
(i) Description of area affected by the discharge, including name of water body affected, if
any; and
(j) Other persons or agencies contacted.
(2) Oral reports, not otherwise required to be provided pursuant to subparagraph b.1 above, shall
be provided to the Department's Northeast District within 24 hours from the time the
permittee becomes aware of the circumstances.
c. If the oral report has been received within 24 hours, the noncompliance has been corrected, and
the noncompliance did not endanger health or the environment, the Department's Northeast
District shall waive the written report.
[62-620.610(20)]
21. The permittee shall report all instances of noncompliance not reported under Permit Conditions VIII.
17, 18 or 19 of this permit at the time monitoring reports are submitted. This report shall contain the
same information required by Permit Condition VIII.20 of this permit. [62-620.610(21)]
22. Bypass Provisions.
a. "Bypass" means the intentional diversion of waste streams from any portion of a treatment works.
b. Bypass is prohibited, and the Department may take enforcement action against a permittee for
bypass, unless the permittee affirmatively demonstrates that:
(1) Bypass was unavoidable to prevent loss of life, personal injury, or severe property damage;
and
(2) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment
facilities, retention of untreated wastes, or maintenance during normal periods of equipment
downtime. This condition is not satisfied if adequate back-up equipment should have been
22

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
installed in the exercise of reasonable engineering judgment to prevent a bypass which
occurred during normal periods of equipment downtime or preventive maintenance; and
(3) The permittee submitted notices as required under Permit Condition VIII. 22. c. of this
permit.
c. If the permittee knows in advance of the need for a bypass, it shall submit prior notice to the
Department, if possible at least 10 days before the date of the bypass. The permittee shall submit
notice of an unanticipated bypass within 24 hours of learning about the bypass as required in
Permit Condition VIII. 20. of this permit. A notice shall include a description of the bypass and
its cause; the period of the bypass, including exact dates and times; if the bypass has not been
corrected, the anticipated time it is expected to continue; and the steps taken or planned to reduce,
eliminate, and prevent recurrence of the bypass.
d. The Department shall approve an anticipated bypass, after considering its adverse effect, if the
permittee demonstrates that it will meet the three conditions listed in Permit Condition VIII. 22.
b.(1) through (3) of this permit.
e. A permittee may allow any bypass to occur which does not cause reclaimed water or effluent
limitations to be exceeded if it is for essential maintenance to assure efficient operation. These
bypasses are not subject to the provisions of Permit Condition VIII. 22. b. through d. of this
permit.
[62-620.610(22)]
23. Upset Provisions.
a. "Upset" means an exceptional incident in which there is unintentional and temporary
noncompliance with technology -based effluent limitations because of factors beyond the
reasonable control of the permittee.
(1) An upset does not include noncompliance caused by operational error, improperly designed
treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or
careless or improper operation.
(2) An upset constitutes an affirmative defense to an action brought for noncompliance with
technology based permit effluent limitations if the requirements of upset provisions of Rule
62-620.610, F.A.C., are met.
b. A permittee who wishes to establish the affirmative defense of upset shall demonstrate, through
properly signed contemporaneous operating logs, or other relevant evidence that:
(1) An upset occurred and that the permittee can identify the cause(s) of the upset;
(2) The permitted facility was at the time being properly operated;
(3) The permittee submitted notice of the upset as required in Permit Condition VIII.5. of this
permit; and
(4) The permittee complied with any remedial measures required under Permit Condition VIII. 5.
of this permit.
c. In any enforcement proceeding, the burden of proof for establishing the occurrence of an upset
rests with the permittee.
d. Before an enforcement proceeding is instituted, no representation made during the Department
review of a claim that noncompliance was caused by an upset is final agency action subject to
judicial review.
[62-620.610(23)]
23

PERMITTEE: Packaging Corporation of America PERMIT NUMBER: FL0000281 — 007 (Major)
FACILITY: Packaging Corporation of America — Valdosta Operations EXPIRATION DATE: April 26, 2023
Executed in Jacksonville, Florida.
STATE OF FLORIDA DEPARTMENTOF
ENVIRONMENTAL PROTECTION
Thomas G. Kallemeyn
Permitting Program Administrator
DATE: APRIL 27, 2018
Attachment(s):
Discharge Monitoring Report
24

FACT SHEET
FOR
STATE OF FLORIDA
INDUSTRIAL WASTEWATER FACILITY PERMIT
PERMIT NUMBER:
FACILITY NAME:
FACILITY LOCATION:
NAME OF PERMITTEE:
PERMIT WRITER:
1. SUMMARY OF APPLICATION
a. Chronology of Application
Application Number:
Application Submittal Date:
RAI:
RAI responses:
FL0000281 — 007 (Major)
PCA — Valdosta Operations
5495 Clyattville-Lake Park Road
Valdosta, Georgia 31601
Discharge located in Hamilton County, Florida
Packaging Corporation of America
Jeff Martin, PE, D. A. Vo, PE
FL0000281 — 007 — IW 1 S
August 15, 2017
September 14, 2017
December 15, 2017, January 4, and 25, 2018
Effective Date (notify applicant): January 25, 2018
Preliminary permit to applicant: January 25, 2018
Draft permit to applicant and EPA: February 9, 2018
Publish notice of draft: March 1, 2018
No public comments received and no comments received from
any agency.
Notice of Intent
Publication of Intent
Final Permit Issuance:
b. Type of Facility
April 2, 2018
April 12, 2018
April 27, 2018
This permit is for the operation renewal for the 14 MGD average (design) flow industrial
wastewater treatment system for an unbleached kraft liner board production facility.
SIC Code: 2631 - Paperboard Mills

PCA — Valdosta Operations
FL0000281-007
Page 2 of 17
c. Facility Capacity
Treatment Capacity
(MGD Average Daily flow)
Disposal Capacity
(MGD Average Daily flow)
Existing
14.00
14.00
Proposed Increase
0.00
0.00
Proposed Total
14.00
14.00
d. Description of Wastewater Treatment
Treatment consists of a mechanical bar screen at the influent to the wastewater lift station prior to
the primary clarifier, a manual bar screen for the auxiliary wastewater lift station bypass line, and
a back-up manual bar screen in the channel downstream from the mechanical bar screen. The
wastewater lift station pumps wastewater consisting of process and non -process wastewater from
the mill manufacturing operations, and storm water, to a primary clarifier and associated sludge
ponds for treatment for settleable solids removal.
Secondary treatment is accomplished in a series of seven ponds covering approximately 850 acres
with nutrient addition to the individual ponds as needed, and coagulant/precipitant at the discharge
from Pond 6 for incremental emergency color reduction. Pond 1 has been taken out of service and
is not currently being used for secondary treatment, but may be returned to service after solids
removal at a later date. There are three facultative ponds, followed by an aerated stabilization basin,
a 350-acre facultative impoundment, and a fmal polishing pond (Pond 7), prior to a final effluent
pumping station and associated conveyance system which discharges final treated effluent from
outfall D-001 to the Withlacoochee River, a Class III fresh surface water of the state. The facility is
located at latitude 30° 41' 38.16" N, longitude 83° 18' 18.21" W, on 5495 Clyattville -Lake Park
Road, Valdosta, Georgia 31601 in Lowndes County, with discharge location in Hamilton County,
Florida.
The pump station is designed to convey 55 MGD maximum of effluent to outfall D-001. The
pump station includes bar screens, a post aeration chamber, Parshall flume for effluent flow
monitoring, and effluent pumps which convey the effluent to a final concrete control splitter
structure identified as station 001B and then to outfall D-001. Approximately 13,000 L.F. of 48-
inch HDPE transmission pipe conveys the effluent from EFF-1 to station 001B. The effluent
gravity flows into the Withlacoochee River through outfall D-001. Under high -river stage the
control structure splits the flow to a 5th port in order to prevent overflow of effluent from the
control structure and damage from backpressure to the diffuser system and associated effluent
conveyance system. A culvert with a minimum 8 square foot opening in the control dam of
Jumping Gully Creek is provided to allow normal flow from Jumping Gully Creek to pass
unrestricted to the Withlacoochee River. Outfall D-001 discharges into a segment of the
Withlacoochee wherein a site -specific alternative water quality criterion (SSAC) for dissolved
oxygen (DO) has been established and continued beginning since 1990.

PCA — Valdosta Operations
FL0000281-007
Page 3 of 17
e. Description of Effluent Disposal and Land Application Sites (as reported by applicant)
Monitoring Group D-001:
Class III Fresh Waters, Withlacoochee River, WBID 3315.
Pollutants which are present in significant quantities or which are subject to permit limitations are
as follows:
Parameter
Units
Reported
Daily
Min/Max
Reported
30-day
Max
Reported
Annual
Average
pH
SU
7.1-8.9
7.6-8.3
-
Biochemical Oxygen Demand - 5
MG/L
34
20
6
Solids, Total Suspended
MG/L
82
40
9
For Outfall D-001, the following table includes the list of Impaired Waters and the parameter(s)
of concern from the applicable EPA and FDEP 303(d) Lists:
Receiving
Waterbody
Outfall (D-001)
Downstream of Outfall
WBID
WBID 3315
WBID 3315A
303(d)
EPA 303 (d) List
(Version:
11/2010)
DEP 303 (d) List
(11/17/2017)
EPA 303 (d) List
(Version:
12/2012)
DEP 303 (d) List
(11/17/2017)
Listed
Impaired
Parameters
Mercury,
nutrients
Mercury in fish
tissue.
n/a
Mercury in fish tissue.
Table 1— DEP Verified WID List
These water bodies are not impaired and there is mercury TMDL for the State. Based on three facility
effluent samples, mercury was not detected (below the MDL using EPA method 1631B).
Water Quality modeling was conducted by Rick Roberts, P.E., the consultant for PCA. He reviewed
and considered effluent and stream parameters such as total ammonia nitrogen, conductivity,
turbidity, DO, color, transparency, the BOD-DO sag and stream flow conditions. His model runs
considered seasonal stream flow conditions (low and high). The report reviewed the mixing zones for
DO, specific conductivity, chronic whole effluent toxicity, pH, turbidity, total ammonia nitrogen as
N, total recoverable lead, transparency, and oil and grease taking into consideration the limitations
and the aerial extent for the size of each mixing zone.
Monitoring results indicate PCA meets the applicable effluent limitations established under this
permit.

PCA — Valdosta Operations
FL0000281-007
Page 4 of 17
2. SUMMARY OF SURFACE WATER DISCHARGE
Some changes were made to existing mixing zones. An anti -degradation analysis is provided in
section 4 below.
The Department does not anticipate adverse impacts on threatened or endangered species as a result
of permit issuance.
The long hydraulic retention time of the treatment system combined with gravity flow design, good
pond level management, and effective treatment helps mitigate the impact of any temporary power
outages, upsets or unavoidable bypasses. The design of the final aeration chamber and the gravity
flow system also minimize the potential for any upset to occur as a result of a power outage at the
final discharge structure.
Because of the very large surface area of the effluent system and its gravity flow design, sudden
heavy rainfall at the facility or the treatment system can have a major effect on the effluent
discharge volume during the period of heavy rain and on the ability of the treatment system to
mitigate the impact of that increase in volume. The Pond 6 control valve is automated to help
restrict flow from Pond 6 during such events, to minimize the chance of exceeding a permit limit
due to sudden excess rainfall during periods of significantly restricted discharge flow.
During extended periods of low river flow, color and BOD lb/cfs become significant limiting factors
on the discharge volume and can potentially create an emergency situation. When color is a
significant restricting parameter for the discharge, PCA has the ability to add a small amount of
precipitant/ coagulant to the effluent leaving Pond 6 to achieve some reduction in color so the
effluent will meet color limitations at a slightly higher discharge volume. This ability is a key
component of the operating procedures that are typically used for such conditions. There are times
however when, as a result of the very low river flow and the corresponding low color, the effluent
cannot be sufficiently treated with precipitant/coagulant to lower the effluent color sufficiently to the
permit's color limitations and still maintain normal discharge flow. Effluent is retained in the ponds
in such situations, in order to ensure compliance with permit limitations. Similarly, BOD lb/day/cfs
can be a significant restriction on the discharge at very low flow or low river DO conditions, with the
same requirement to retain effluent volume.
When either of these circumstances continue over an extended period, it results in unavoidable, and at
times, critically high pond levels and a concomitant threat that those ponds could overtop or be
breached if levels become too high. When pond levels are too high, the ability of the system to react
to upsets and accommodate heavy rainfall events is compromised. This threat is made worse by the
potential for heavy localized rainfall on the treatment system. Heavy rainfall events can result in
significant sudden increases in effluent pond levels. The risk is illustrated by an extreme event with
just over 9 inches of rain in less than 3 days in late June 2012, most of it within a 24 hour period on
June 26, 2012 with a loss of 18 inches freeboard at Pond 6 by June 27, 2012.
The 2013 Permit implemented changes in discharge limits relative to color and BOD to better
accommodate the wider range of weather cycles that were experienced over the last two permit terms
and that can be expected to recur. The changes helped provide additional discharge flexibility to help
keep the pond levels sufficiently low and minimize or eliminate the possibility of uncontrolled
discharge of untreated or partially treated wastewater from the ponds, while maintaining the natural
seasonal variability of the River. However, as discussed further below, additional discharge flexibility

PCA — Valdosta Operations
FL0000281-007
Page 5 of 17
is needed to address these weather -related conditions. PCA is seeking a slight increase in the
technology -based effluent limitation for BOD in order to better address weather extremes that are
beyond PCA's control and reflect increased production rates at the mill. This slight increase will
minimize impoundment during periods of high river flow when the river's assimilative capacity is
greatest and help avoid unnecessarily raising pond levels following high rainfall events, with the same
risks due to high pond levels as discussed above. This change will not have an adverse effect on the
River, as is also discussed below.
Part of the emergency operation procedures include river flow averaging for determination of the
allowable effluent discharge limit (see "River Flow" Form 2 CS Technical Memorandum
Attachment) or use of the land application system (see "Normal Operation in Extended Drought
Periods" Form 2CS Technical Memorandum Attachment).
Over the course of prior permits, PCA began adding precipitant/coagulant (as described in
"Emergency Operations" Form 2CS Technical Memorandum Attachment) under more "routine"
operations during drought conditions to more proactively manage pond inventory, since the duration
or severity of drought cannot be predicted. The Department concurred that this procedure was
appropriate and it will continue to be used as needed on this more routine basis.
As mentioned above, some increased discharge flexibility was included in the last permit cycle, to
recognize naturally occurring conditions in the river. Modelling data provided with that application
demonstrated that a limit of 141b BOD/day/cfs during higher DO river conditions is protective of
the river. Similarly, the Withlacoochee River is typically naturally high in color during the winter
and early spring (i.e., it is a seasonal black water river), and the biota is accustomed to higher color
and lower transparency during this period. Using a seasonally adjusted background value in the
color limit calculation maintains the normal seasonal variability of the river while reducing the
severe restriction on the discharge due to drought -induced conditions, with the same benefit of
reducing the risk for an uncontrolled discharge. However, as discussed below, PCA is seeking a
slight increase in the TBEL for BOD to provide additional discharge flexibility during high river
flow conditions to better address these weather extremes that are outside of its control and
accommodate increased production. These changes will not cause any adverse impacts to the river
and will maintain normal seasonal variability in
the river.
3. BASIS FOR PERMIT LIMITATIONS AND MONITORING REQUIREMENTS
This facility is authorized to discharge process wastewater from Outfall D-001 to Withlacoochee
River based on the following:
Parameter
Units
Max/
Min
Limit
Statistical
Basis
Rationale
Effluent
Chronic Whole
Effluent Toxicity, 7-
Day IC25
(Ceriodaphnia dubia)
percent
Min
35
Single Sample
62-302.530(20) & (61) FAC
and 62-4.241(2)(b), F.A.C.

PCA — Valdosta Operations
FL0000281-007
Page 6 of 17
Parameter
Units
Max/
Min
Limit
Statistical
Basis
Rationale
Chronic Whole
Effluent Toxicity, 7-
Day IC25
(Pimephales
promelas)
percent
Min
35
Single Sample
62-302.530(20) & (61) FAC
and 62-4.241(2)(b), F.A.C.
Flow (effluent)
MGD
Max
Report
Daily
Maximum
62-620, FAC
Flow (upstream river)
CFS
Max
Report
Daily
Maximum
62-620, FAC
Flow (downstream
rived
CFS
Max
Report
Daily
Maximum
62-620, FAC
Flow (Receiving
Water Concentration)
percentage
Max
20 %
Daily
Maximum
62-620, FAC
pH
s.u.
Min
6.0
Daily
Minimum
62-302.530, FAC, 40 CFR Part
430.33 Subpart C
Max
9.0
Daily
Maximum
62-302.530, FAC (Mixing Zone)
Oxygen, Dissolved
(DO)
mg/L
Min
1.5
Daily
Minimum
62-302.530, FAC, 62-4.244 FAC
(Mixing Zone). An SSAC has
been developed for DO in the
Withlacoochee.
Biochemical Oxygen
Demand-5
lb/day
Max
5,550
Annual
Average
62-302.530, FAC, 40 CFR Part
430.33 Subpart C
Max
7,792
Monthly
Average
Max
15,585
Daily
Maximum
Solids, Total
Suspended
lb/day
Max
10,760
Monthly
Average
40 CFR Part 430.33 Subpart C
Max
16,140
Daily
Maximum
True Color
PCU
-
-
-
62-302.530, 62-4.244 FAC
(Mixing Zone)
Turbidity
NTU
Max
103
Daily
Maximum
62-302.530, 62-4.244 FAC
(Mixing Zone)
Specific Conductance
umhos/cm
Max
3,900
Daily
Maximum
62-302.530, 62-4.244 FAC
(Mixing Zone)
Temperature (°C),
Water
Deg °C
Max
Report
Daily
Maximum
62-302.530, FAC
Nitrogen, Total
mg/L
Max
Report
Daily
Maximum
62-302.530, FAC
Nitrogen, Total
lb/day
Max
Report
Daily
Maximum
62-302.530, FAC
Nitrogen, Kjeldahl,
Total (as N)
mg/L
Max
Report
Daily
Maximum
62-302.530, FAC
Nitrogen, Ammonia,
Total (as N)
mg/L
Max
1.40
Daily
Maximum
62-302.530, 62-4.244 FAC
(Mixing Zone)

PCA — Valdosta Operations
FL0000281-007
Page 7 of 17
Parameter
Units
Max/
Min
Limit
Statistical
Basis
Rationale
Phosphorus, Total
(as P)
mg/L
Max
Report
Daily
Maximum
62-302.530, FAC
Phosphorus, Total
(as P)
lb/day
Max
Report
Daily
Maximum
62-302.530, FAC
Oil and Grease
mg/L
Max
5.9
Daily
Maximum
62-302.530, 62-4.244 FAC
(Mixing Zone)
Lead, Total
Recoverable
ug/L
Max
9.6
Daily
Maximum
62-302.530, 62-4.244 FAC
(Mixing Zone)
Hardness, Total
(as CaCO3)
mg/L
Max
Report
Daily
Maximum
62-302.530, FAC
Mercury, Total
Recoverable
ug/L
Max
Report
Daily
Maximum
62-302.530, FAC
Upstream
Oxygen, Dissolved
(DO)
mg/L
Min
Report
Daily
Minimum,
62-302.530, 62-4.244 FAC
(Mixing Zone)
Daily
Maximum,
Monthly Avg.
pH
s.u.
Max
Report
Daily
Maximum
62-302.530, FAC
Min
Report
Daily
Minimum
62-302.530, FAC
Temperature (°C),
Water
Deg °C
Max
Report
Daily
Maximum
62-302.530, FAC
Specific Conductance
umhos/cm
Max
Report
Daily
Maximum
62-302.530, 62-4.244 FAC
(Mixing Zone)
True Color
PCU
Max
Report
Daily
Maximum
62-302.530, 62-4.244 FAC
(Mixing Zone)
Turbidity
NTU
Max
Report
Daily
Maximum
62-302.530, 62-4.244 FAC
(Mixing Zone)
Nitrogen, Total
mg/L
Max
Report
Daily
Maximum
Annual
Geometric
Mean
62-302.530, FAC
Nitrogen, Ammonia,
Total (as N)
mg/L
Max
Report
Daily
Maximum
62-302.530, FAC
Phosphorus, Total
(as P)
mg/L
Max
Report
Daily
Maximum
62-302.530, FAC
Annual
Geometric
Mean
Oil and Grease
mg/L
Max
Report
Daily
Maximum
62-302.530, 62-4.244 FAC
(Mixing Zone)
Lead, Total
Recoverable
ug/L
Max
Report
Daily
Maximum
62-302.530, 62-4.244 FAC
(Mixing Zone)

PCA — Valdosta Operations
FL0000281-007
Page 8 of 17
Parameter
Units
Max/
Min
Limit
Statistical
Basis
Rationale
Hardness, Total
(as CaCO3)
mg/L
Max
Report
Daily
Maximum
62-302.530, FAC
Downstream
Oxygen, Dissolved
(DO)
mg/L
Max
Report
Daily
Minimum,
62-302.530, 62-4.244 FAC
(Mixing Zone)
Daily
Maximum,
Monthly Avg.
pH
s.u.
Max
Report
Daily
Maximum
62-302.530, FAC
Min
Report
Daily
Minimum
62-302.530, FAC
Temperature (°C),
Water
Deg °C
Max
Report
Daily
Maximum
62-302.530, FAC
Specific Conductance
umhos/cm
Max
Report
Daily
Maximum
62-302.530, 62-4.244 FAC
(Mixing Zone)
True Color
PCU
Max
Report
Daily
Maximum
62-302.530, 62-4.244 FAC
(Mixing Zone)
Turbidity
NTU
Max
Report
Daily
Maximum
62-302.530, 62-4.244 FAC
(Mixing Zone)
Nitrogen, Total
mg/L
Max
Report
Daily
Maximum
Annual
Geometric
Mean
62-302.530, FAC
Nitrogen, Ammonia,
Total (as N)
mg/L
Max
Report
Daily
Maximum
62-302.530, FAC
Phosphorus, Total
(as P)
mg/L
Max
Report
Daily
Maximum
Annual
Geometric
Mean
62-302.530, FAC
Oil and Grease
mg/L
Max
Report
Daily
Maximum
62-302.530, 62-4.244 FAC
(Mixing Zone)
Lead, Total
Recoverable
mg/L
Max
Report
Daily
Maximum
62-302.530, 62-4.244 FAC
(Mixing Zone)
Hardness, Total
(as CaCO3)
mg/L
Max
Report
Daily
Maximum
62-302.530, FAC

PCA — Valdosta Operations
FL0000281-007
Page 9 of 17
Mixing zones have been established as follows:
a.
b.
c.
d.
e.
f.
g•
h.
i.
Length Downstream from Outfall
Dissolved oxygen
Specific Conductance
Chronic Whole Effluent Toxicity
pH
Turbidity
Total Ammonia as N
Total Recoverable Lead
Transparency
Oil & Grease
D-001
1,171 ft.
853 ft.
1,171 ft.
1,171 ft.
828 ft.
663 ft.
972 ft.
1,171 ft.
396 ft.
This facility has provided reasonable assurance that the discharge will not adversely affect the designated
use of the receiving water. Fifth year inspection data, as well as all other available data, have been
evaluated in accordance with the Department's reasonable assurance procedures to ensure that no limits
other than those included in this permit are needed to maintain Florida water quality standards.
This facility is required to conduct chronic toxicity tests for this discharge based on Rule 62-620.620(3)(a)1,
FAC.
Based on this analysis anti -degradation requirements have been fully met by the permittee. The revised
effluent limits (for BODS) does not result in a violation of effluent guidelines or water quality standards
outside of the mixing zone.
In relation to BODS, the increase in BODS loading rates under the specific conditions detailed in Part
I.A.8 of the permit is allowable due to events beyond the permittee's control. In situations of extended low
river flow, the effluent is limited by color and BOD. Also during periods of low river DO, BOD becomes
the limiting discharge factor. During such times the effluent must be retained in the pond system to ensure
compliance with permit limitations. When either of these circumstances occur, critically high pond levels
can result and may lead to overtopping of ponds or a pond breach. Allowing the facility to discharge more
effluent during favorable conditions (i.e. when DO levels are high in the river) will allow the facility more
control over maintaining proper pond levels. It should be noted that only the daily BODS and monthly
average limits have been changed. The annual average BOD5 loading rate remains the same.
4. EXPANDED OR REVISED DISCHARGES TO SURFACE WATERS: ANTI -
DEGRADATION REQUIREMENTS
Review of DO, BOD and TSS Sampling
All applicants for new or expanded discharges to surface waters are required to comply with the Anti -
degradation requirements of Rule 62-302.300, and Rule 62-4.242, F.A.C.
The anti -degradation and back -sliding evaluation considered the increase of the final effluent limits. The
anti -degradation analysis provides for holding the flow and annual average mass loading at the current
levels.

PCA — Valdosta Operations
FL0000281-007
Page 10 of 17
Back -sliding does not apply since the Permittee has installed and properly operated and maintained
required treatment facilities but still has been unable to meet permit limitations. The revised effluent
limits (for BOD5) do not result in a violation of effluent guidelines or water quality standards outside of
the mixing zone. The receiving water body is not impaired based on DEP lists. It has been determined that
"existing uses" of the receiving water body, Class III fresh water, will be maintained with the proposed
discharge.
It is evident that the discharge will not "cause or contribute to violations of water quality standards."
Receiving waters meet the water quality standards with the discharge as demonstrated above. This
analysis indicates that the receiving waters meet standards in the absence of the discharge except that due
to the natural stream, a DO SSAC is set at 4.0 mg/L minimum, which is the same criteria since 1990, as in
previous NPDES permits.
A review of the submitted model for DO and BOD, uses appropriate ambient temperature data and K
constant values. Ambient review temperature data indicates that the 95thpercentile temperature is 27 ° C
and the predicted DO stream minimum value is greater than the SSAC minimum value of 4.0 mg/L.
Numeric Nutrient Criteria (NNC) Evaluation
The nutrient criteria for the Withlacoochee River has a nitrate -nitrogen level established at 0.35 mg/L. the
upstream of the discharge average 0.38 mg/L and the downstream avenges 0.37 mg/L. the TN criteria is
0.30 mg/L for TP and 1.87 mg/L for TN. The annual geometric mean for TP of the river sampling was
below 0.15 mg/L over the 2013 -2016 period, and the TN of the river sampling was below 1.50 mg/L
over the 2013 -2016 period. For the period of 2014 through 2016 the chlorophyll -a have ranged from 0.96
to 2.35 ug/L which is below the "problem" threshold level of 3.2 ug/L. In consideration of the biological
and water quality scores for the receiving waters, the stream in this basin meeting the NNC TN And TP
and nitrate criteria.
The permit applicant was informed that the Department may be developing a TMDL for their receiving
waters in the near future, and that reductions in their discharge of any pollutants of concern may be
required. Current Florida rules also incorporate nutrient numeric criteria (NNC) and a permit reopener
clause is included in this permit as a specific condition for all of these considerations.
Biological Assessments: SCI, RPS and LVI Results: A review of the Integrated Water Quality
Assessment for Florida: 305(b) Report and 303(d) List Update, dated November 17, 2017, indicates that
there are no listed parameters for this water body for the mixing zone parameters (ID # 3315,
Withlacoochee River Basin). EPA decision document dated December 2010, listed mercury and nutrients.
The facility meets the mercury WQ standard at the end of pipe and the DEP has submitted to EPA to
delist this WBID for nutrients. Historic SCI scores above and below this discharge indicate meeting the
current healthy DEP criteria. Permit specific condition number I.A.11 requires continuation of
bioassessments (SCI sampling or other appropriate sampling) every two years.

PCA — Valdosta Operations
FL0000281-007
Page 11 of 17
Year
Reference Site Score (upstream)
Test Site Score (downstream)
2015
80 Exceptional
74 Exceptional
2013
52 Healthy
43 Healthy
2011
43 Healthy
35 Healthy
2009
48 Healthy
51 Healthy
Table 2 - SCI scores at this basin
After a review of the SCI scores and results, two conclusions may be drawn from this data:
1) the discharge does not adversely impact the SCI scores/ Water Quality (comparing upstream
to downstream) and
2) the SCI scores indicate good water quality overall at 35 or higher.
Biological assessment of flora in the Withlacoochee River near the PCA discharge was also conducted
during the current permit term. Two temporally -independent Rapid Periphyton Surveys (RPS) and Linear
Vegetative Surreys (LVS) assessments were conducted, one in 2015 and one in 2016. Both sets of
assessments indicate no imbalance of flora either upstream or downstream of the PCA discharge.
The facility will conduct SCIs in the next renewal period for 2019 and 2021.
Total recoverable mercury: The facility conducted sampling, collecting 8 samples from 2012 through
2016 and all sample results using Method 1631E were below the water quality level of 0.012 ug/L.
Annual sampling will be conducted by the facility in the permit renewal and if future sampling results are
above 0.012 ug/L, the PCA will contact the DEP and prepare and implement a mercury minimization
plan.
Bacteriological Sampling: The facility sends all domestic wastewater to the local POTW and the IW
waste stream is not a likely source of e. coli and other fecal coliform bacteria and not reasonably likely to
be present in the effluent and is not monitored.
Whole Effluent Toxicity Test Results
Current permit requires annual freshwater chronic definitive tests with dilutions of 100%, 70%, 35%,
20%, and 10% final effluent with grab samples. If IC25 is less than 35% effluent, then 2 additional
definitive tests are required. Satisfactory test results have occurred.

PCA — Valdosta Operations
FL0000281-007
Page 12 of 17
Date Tests
Performed
Date Report
Received, Lab
Test Results
PCA -- FL0000281
Comments
8.06.13
annual
9.09.13
Marinco
CD pass IC25 > 100% and LC50 > 100%.
FM pass IC25 > 100% and LC50 > 100%.
CD 6-day test. Cond — 2300.
QA 3/13/14 jo
7.29.14
annual
8.27.14
Marinco
CD pass IC25 > 100% and LC50 > 100%.
FM pass IC25 > 100% and LC50 > 100%.
All CD repro > controls. 6-day test.
Cond — 2600.
7.28.15
annual
8.19.15
Marinco
CD pass IC25 > 100% and LC50 > 100%.
FM pass IC25 > 100% and LC50 > 100%.
CD 6-day test.
Cond — 2500.
8.23.16
annual
9.21.16
Marinco
CD pass IC25 > 100% and LC50 > 100%.
FM pass IC25 > 100% and LC50 > 100%.
CD 6-day test. FM all growth > controls.
Cond — 2900.
4.11.17
annual
4.27.17
Marinco
CD pass IC25 > 86.3% and LC50 > 100%.
FM pass IC25 > 100% and LC50 > 100%.
CD 6-day test. FM all growth > controls.
Cond — 2900.
Table 3 WET Test Results
Moderating Provisions. Moderating provisions (provided in Subsection 62-302.300[10] and Rules 62-4
and 62-6, F.A.C., and described in Sections 62-302.300, 62-4.244, 62-302.800, 62-4.243, F.A.C., and
Sections 403.201 and 373.414, F.S.) include mixing zones, zones of discharge, site -specific alternative
criteria, exemptions, and variances. These provisions are intended to moderate the applicability of water
quality standards where it has been determined that, under certain special circumstances, the social,
economic, and environmental costs of such applicability outweigh the benefits.
It has been determined that the expected degradation is "necessary or desirable under federal standards
and under circumstances which are clearly in the public interest." This determination requires
consideration of a balancing test and an options review.
Balancing test: It has been determined that the degradation is important to and beneficial to public health,
safety, and welfare, and this benefit outweighs adverse impacts on fish and wildlife or recreation. There
was a small decrease in the length of the lead mixing zone based on more recent river hardness data,
however the permit end of pipe limitation did not change. The turbidity mixing zone length was
increased to better reflect naturally occurring conditions in the receiving water. It should be noted that the
mixing zone size for toxicity has remained the same and ammonia has remained the same.
1) As a major employer for the region, the discharge is clearly in the public interest. The discharge is
permittable.
2) The degradation is in the public interest, so the analysis proceeds to the options review.
Options review: It has been determined that reuse or other options are not available that could minimize
or eliminate the need to lower water quality.
1) Since reuse or other options are not available, the applicant demonstrated that they are not
economically and technologically reasonable.
2) No other options are reasonable, and therefore anti -degradation requirements have been met.
3) Reuse is determined not to be reasonable, the request to increase the concentration of the effluent
discharged within the existing mixing zone to the surface water would be permittable.

PCA — Valdosta Operations
FL0000281-007
Page 13 of 17
Discharge Criteria Due to Extreme Weather Conditions
As reported to DEP by PCA, On June 14, 2017, there was unexpected, heavy local rain at the PCA site.
There was a 7" to 9" rainfall in a 24-hour period, the heaviest being the early hours of 6/7/17. With
continued rainfall, PCA was concerned for pond dam integrity.
PCA was able to contain upper ponds as much as currently feasible to reduce downstream pond levels and
allow some flexibility in volume retention. However, PCA reached only 26" from overflow at Pond 6.
For every 1" of rain at Pond 6, that can be an instantaneous impact of 2-3" of level, and that would not
include the later impact of upstream ponds flow into Pond 6. This is a significant land mass for inflow to
the WWTS during precipitation events, even with PCA operating the backup Land Application System to
relieve some of the pond volume.
PCA also was able to reduce or reuse water in the mill to the best of their capabilities. This includes some
temporary reduction and reuse measures that are not long term sustainable.
PCA proposed a temporary discharge scenario to lower our Pond 6 level to 85", ultimately as a
preemptive means to manage potential rainfall in the forecast. One inch of Pond 6 level is approximately
10 million gallons of volume.
Level and flow are monitored with a staff gage, electronic level transmitter, and electronic flow meter.
Staff gage is checked manually once daily and electronic meter data are fed continuously to data
archiving system. The emergency spillway from Pond 6 to Pond 7 is at level 132 inches elevation, leaving
47" of freeboard until bypass into Pond 7. This may seem like a generous amount of freeboard; however,
85" represents a level well above typical operating levels but still allows an adequate safety factor for
dam integrity. Further, Pond 7 has a significantly smaller volume relative to Pond 6 and all major
retention is done in Pond 6. As discussed in June 2017 when this criteria was utilized, 1" of rain has an
instantaneous impact of 2-3" of level in the pond directly, in addition to substantial land runoff from the
surrounding drainage basin and upper ponds flowing downstream through the treatment system. The
proposed 85" level would provide retention of significant rainfall without compromising dam safety.
Calculation Estimates: Note: bold values vary daily
Conservatively Assume:
River flow = 230 cfs = 149 MGD
Downstream D.O. = 4.7 mg/L
River water quality std = downstream limit 4.0 mg/L (Part I.A.10 in our NPDES permit)
Mill effluent BOD = estimate at approx. 13 mg/L
1 lb BOD consumes 1 lb D.O.
Mill effluent D.O. = 8 mg/L
Mill water use = 11 MGD
Conceptual Temporary Technical Approach:
`Surplus' downstream river D.O. = 4.7 — 4.0 = 0.7 mg/L x 8.34 x 149 MGD = 8701b Oxygen surplus
Mill BOD discharge at 11 MGD = 13 mg/L BOD x 8.34 x 11 MGD = 1,200 lb/d BOD
Allowable mill discharge that consumes `surplus' D.O. = 870/1200 x 11 MGD = 8 MGD discharge (does
not account for effluent D.O., therefore conservative assumption)

PCA — Valdosta Operations
FL0000281-007
Page 14 of 17
PCA Proposal
Allow mill, on a daily basis, to use the above calculation (with real-time values available) to determine
allowable additional discharge not to exceed a downstream river D.O less than 4.0 mg/L, until we have
better inventory conditions.
DEP Review
DEP reviewed this proposal by using the Streeter -Phelps model and the model results indicate that the
DO sag downstream under these conservative assumptions would meet the permit limit of 4.0 mg/L (see
attachment A).
Permit Specific Condition
If conventional effluent discharge restrictions and other factors (e.g., weather) result in the Permittee's
holding pond #6 level to exceed 85 inches of impounded effluent, the Permittee will be allowed to utilize
a temporary alternative discharge strategy until the holding pond level is below 85 inches of level (the
emergency spillway from Pond 6 to Pond 7 is at level 132 inches elevation). This temporary allowance
provides for a discharge rate of treated effluent that does not compromise downstream dissolved oxygen
minimum standards and also protects the integrity of the Permittee's wastewater treatment pond dam.
Further, the algorithm used to calculate the temporary alternative discharge allowance incorporates
conservative assumptions regarding receiving stream flow, in -stream dissolved oxygen, and the treated
effluent BOD concentration. The Permittee will be allowed to utilize this temporary alternative discharge
strategy by observing the following requirements:
1. The Permittee must notify the Department (i.e., e-mail or written correspondence) one (1)
business day in advance of its intent to utilize the temporary alternative discharge allowance.
2. The Permittee must notify the Department (i.e., e-mail or written correspondence) one (1)
business day after ceasing to utilize the temporary alternative discharge allowance.
3. While utilizing this temporary alternative discharge allowance, the Permittee must provide the
Department with daily updates with respect to the actual volume of effluent discharged to the
receiving stream and the calculations used to determine the allowable discharge volume.
4. The Permittee must use the following algorithm to determine the allowable volume of treated
effluent that can be discharged to the receiving stream:
a. Available Receiving Stream D.O., lb_oxygen = Upstream river flow, MGD *
(Upstream D.O. mg/L — 4.0 mg/L limit) * 8.34
b. Allowable Mill Effluent Discharge, MGD = Available Receiving Stream D.O.,
lb_oxygen / (8.34 x 9 mg/L BOD**)
5. The Permittee must adhere to all other effluent limitations and monitoring requirements.
**Conservative assumption based on 5-year daily actual maximum discharge
5. DISCUSSION OF CHANGES TO PERMIT LIMITATIONS
a. The daily maximum technology based limitation for BOD is increasing from 14,168 lbs/day to
15,585 lbs/day and the monthly average BOD limit is increasing from 7,084 lbs/day to 7,792
lbs/day. The annual average loading for BOD will not change. This increase in the daily
maximum and monthly average will minimize or eliminate the possibility of future bypasses,
emergency operations, or critically high ponds levels.
b. The effluent limit for total recoverable lead will be maintained at 9.6 ug/L, however due to
hardness data collected during the last permit cycle and the proposed mixing zone length required
is changed from 989 feet to 972 feet.

PCA — Valdosta Operations
FL0000281-007
Page 15 of 17
c. Due to water conservation efforts in the mill process and low rainfall during the last few years,
several times the facility's discharge has been unable to meet the specific conductance permit
limitation. The specific conductance limitation remains at 3900 umhos/cm with the mixing zone
length reduced from 959 feet to 853 feet.
d. Three excursions over the current turbidity limitation were noted last year during a drought period.
The turbidity limitation remains at 103 NTU with a corresponding mixing zone length of 828 feet.
e. The chronic toxicity discharge limit will be maintain the NOEC with IC25 endpoint in the chronic
toxicity bioassays with 35% effluent is based on 62-4.244(1)(f), FAC, which directs the mixing
zone to be no larger than necessary. The chronic toxicity limit for the mixing zone size has been
revised based on toxicity results over the last permit cycle.
f. The total ammonia nitrogen limitation will be 1.40 mg/L, with a mixing zone length of 663 feet
after a review of the change in WQ standard from unionized ammonia to TAN.
The facility conducted sampling for total recoverable mercury and annual sampling will be
required.
g.
6. TECHNOLOGY BASED EFFLUENT LIMITATIONS
This facility is subject to technology based effluent limitations in accordance with 40 CFR Part 430
Subpart C for BOD5 and TSS. The limitations are calculated based on the air-dry pounds of product
produced daily.
As the result of solids accumulation that has occurred gradually over the many years of operation, the
first facultative stabilization pond (Pond 1) was taken out of service in 2013 to allow more effective
management of these accumulated solids, and remains in this operational mode currently. The pond
is used for managing events, such as high BOD or conductivity loading to the treatment system;
during which wastewater may be recirculated from Pond 3 discharge back through Pond 1 using
temporary equipment. The intention is that Pond 1 will remain out of service for an extended time
for solids management, and the pond may or may not be returned to service. The final Pond 1 use
decision will be made when further evaluation of the residual solids' volume, dewatering capability,
and disposal requirements is completed, and the Department will be advised.
Based on the submitted data, it was reported that the maximum annual average production rate
expressed as off -machine production (i.e., 12 consecutive months), expressed as off -machine
production at 10% moisture (air-dry paper tons), was achieved during the period from January 2015
through December 2015 with an average of 1690 air-dry paper tons (ADPT) per day.

PCA — Valdosta Operations
FL0000281-007
Page 16 of 17
The calculated technology -based effluent guideline limits are shown below for BOD5 (5-day) and TSS:
BPT Calculation of BOD (5-day) and TSS Effluent Guideline Limit
(40 CFR Part 430 Subpart C — BPT unbleached kraft)
Parameter
Average
Production
(10001b/day)
Guideline Factor
Limits
Average
(lb/day)
Maximum
Average
Maximum
BOD5 (5-day)
3380 (average
for the year
2016)
2.8
5.6
9464
18928
TSS
3380 (average
for the year
2016)
6.0
12.0
20280
40560
The limitations in the permit are more stringent than the technology -based effluent guidelines above.
The permit limitations will be maintained with the adjustments as outlined in the discussion section
above.
Under 40 CFR Subpart C (Unbleached Kraft Subcategory), the Permittee is not using chlorophenolic-
containing biocides and they certify to the DEP that they are not using these biocides. Therefore, PCA
is not subject to limits for Pentachlorophenol and for Trichlorophenol.
7. GROUND WATER MONITORING REQUIREMENTS
This section is not applicable to this facility.
8. PERMIT SCHEDULES
A schedule is not included in the wastewater permit.
9. BEST MANAGEMENT PRACTICES/STORMWATER POLLUTION PREVENTION PLANS
As stated in Section VII of the permit, a Best Management Practices (BMP) Plan is required for the
facility, pursuant to Rule 62-620.100(m), F.A.C., and 40 CFR Part 122.44(k). The plan provides a
facility -specific approach for the minimizing of pollutant discharge from ancillary activities.
10. ADMINISTRATIVE ORDERS (AOLAND CONSENT ORDERS (CO)
This permit is not accompanied by an AO and has not entered into a CO with the Department.
11. REQUESTED VARIANCES OR ALTERNATIVES TO REQUIRED STANDARDS
No variances were requested for this facility.

PCA — Valdosta Operations
FL0000281-007
Page 17 of 17
12. THE ADMINISTRATIVE RECORD
The administrative record including application, draft permit, fact sheet, public notice (after release),
comments received and additional information is available for public inspection during normal
business hours at the location specified in item 14. Copies will be provided at a minimal charge per
page.
13. PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit and Public Notice to Applicant and EPA February 9, 2018
Public Comment Period Beginning: March 1, 2018
Ending: March 30, 2018
Notice of Intent to Issue April 2, 2018
Notice of Permit Issuance April 27, 2018
14. DEP CONTACT
Additional information concerning the permit and proposed schedule for permit issuance may be
obtained during normal business hours from:
Jeff Martin, P.E.
FDEP Northeast District office
8800 Baymeadows Way West, Suite 100
Jacksonville, Florida 32256
Telephone: [phone]

DEPARTMENT OF ENVIRONMENTAL PROTECTION DISCHARGE MONITORING REPORT - PART A
When Completed mail this report to: Department of Environmental Protection, Wastewater Compliance Evaluation Section, MS 3551, 2600 Blair Stone Road, Tallahassee, FL 32399-2400
PERMITTEE NAME:
MAILING ADDRESS:
FACILITY:
LOCATION:
COUNTY:
OFFICE:
Packaging Corporation of America
Post Office Box 1048
Valdosta, Georgia 31603-1048
Packaging Corporation of America - Valdosta Operations
5495 Clyattville-Lake Park Road
Valdosta, Georgia 31601
Hamilton
Northeast District
PERMIT NUMBER:
LIMIT:
CLASS SIZE:
MONITORING GROUP NUMBER:
MONITORING GROUP DESCRIPTION:
RE -SUBMITTED DMR: ❑
NO DISCHARGE FROM SITE: ❑
MONITORING PERIOD:
FL0000281
Final
MA
D-001
Discharge to Withlacoochee River
From:
To:
REPORT FREQUENCY: Monthly
PROGRAM: Industrial
Parameter
Quantity or Loading
Units
Quality or Concentration
Units
No.
Ex.
Frequency of
Analysis
Sample Type
Flow (Effluent)
PARM Code 50050 1
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
Report
(Monthly Avg.)
Report
(Day.Max.)
MGD
Continuous
Flow Totalizer
Flow (Upstream River)
PARM Code 50050 Q
Mon. Site No. CAL-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
CFS
Daily; 24 hours
Calculated
Flow (Downstream River)
PARM Code 50050 R
Mon. Site No. CAL-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
CFS
Daily; 24 hours
Calculated
Discharge Flow as percent of stream
flow
PARM Code 01352 P
Mon. Site No. CAL-1
Sample
Measurement
Permit
Requirement
20 %
(Day.Max.)
percent
Daily; 24 hours
Calculated
pH
PARM Code 00400 1
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
6.0
(Day.Min.)
9.0
(Day.Max.)
s.u.
Daily; 24 hours
In -situ
Oxygen, Dissolved (DO)
PARM Code 00300 1
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
1.5
(Day.Min.)
mg/L
Daily; 24 hours
In -situ
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge
and belief', true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.
NAME/TITLE OF PRINCIPAL EXECUTIVE OFFICER OR AUTHORIZED AGENT
SIGNATURE OF PRINCIPAL EXECUTIVE OFFICER OR AUTHORIZED AGENT
TELEPHONE
DATE
COMMENTS --- or EXPLANATION OF ANY VIOLATIONS (Reference all attachments here):
Version: April 27, 2018 — Effective: May 2018
Page 1 of 10 DEP Form 62-620.910(10), Effective Nov. 29, 1994

FACILITY:
DISCHARGE MONITORING REPORT - PART A (Continued)
Packaging Corporation of America - Valdosta Operations MONITORING GROUP NUMBER: D-001
MONITORING PERIOD From:
To:
PERMIT NUMBER: FL0000281
Parameter
Quantity or Loading
Units
Quality or Concentration
Units
No.
Ex.
Frequency of
Analysis
Sample Type
Biochemical Oxygen Demand-5
PARM Code 00310 Y
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
5550
(An.Avg.)
lb/day
Daily; 24 hours
24-hr TPC
Biochemical Oxygen Demand-5
PARM Code 00310 1
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
7792
(Mo.Avg.)
15585
(Day.Max.)
lb/day
Daily; 24 hours
24-hr TPC
Solids, Total Suspended
PARM Code 00530 1
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
10760
(Mo.Avg.)
16140
(Day.Max.)
lb/day
Weekly
24-hr TPC
True Color
PARM Code 00080 1
Mon. Site No. CAL-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
PCU
Daily; 24 hours
Calculated
Turbidity
PARM Code 00070 1
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
103
(Day.Max.)
NTU
Weekly
Grab
Specific Conductance
PARM Code 00095 1
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
3900
(Day.Max.)
umhos/cm
Weekly
Grab
Temperature (°C), Water
PARM Code 00010 1
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
Deg °C
Weekly
In -situ
Nitrogen, Ammonia, Total (as N)
PARM Code 00610 1
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
1.40
(Day.Max.)
mg/L
Monthly
Grab
Oxygen, Dissolved (DO)
PARM Code 00300 Q
Mon. Site No. SWU-1
Sample
Measurement
Permit
Requirement
Report
(Day.Min.)
Report
(Mon. Avg)
Report
(Day. Max)
mg/L
Daily; 24 hours
In -situ
pH
PARM Code 00400 Q
Mon. Site No. SWU-1
Sample
Measurement
Permit
Requirement
Report
(Day.Min.)
Report
(Day.Max.)
s u.
Weekly
In -situ
Temperature (°C), Water
PARM Code 00010 Q
Mon. Site No. SWU-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
Dcg °C
Weekly
In -situ
Version: April 27, 2018 — Effective: May 2018 Page 2 of 10
DEP Form 62-620.910(10), Effective Nov. 29, 1994

FACILITY:
DISCHARGE MONITORING REPORT - PART A (Continued)
Packaging Corporation of America - Valdosta Operations MONITORING GROUP NUMBER: D-001
MONITORING PERIOD From:
To:
PERMIT NUMBER: FL0000281
Parameter
Quantity or Loading
Units
Quality or Concentration
Units
No.
Ex.
Frequency of
Analysis
Sample Type
Specific Conductance
PARM Code 00095 Q
Mon. Site No. SWU-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
umhos/cm
Weekly
Grab
True Color
PARM Code 00080 Q
Mon. Site No. SWU-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
PCU
Daily; 24 hours
Grab
Turbidity
PARM Code 00070 Q
Mon. Site No. SWU-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
NTU
Weekly
Grab
Oxygen, Dissolved (DO)
PARM Code 00300 R
Mon. Site No. SWD-1
Sample
Measurement
Permit
Requirement
Report
(Day.Min.)
Report
(Mon. Avg)
Report
(Day.Max.)
mg/L
Daily; 24 hours
In -situ
pH
PARM Code 00400 R
Mon. Site No. SWD-1
Sample
Measurement
Permit
Requirement
Report
(Day.Min.)
Report
(Day.Max.)
s.u.
Weekly
In -situ
Temperature (°C), Water
PARM Code 00010 R
Mon. Site No. SWD-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
Deg °C
Weekly
In -situ
Specific Conductance
PARM Code 00095 R
Mon. Site No. SWD-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
umhos/cm
Weekly
Grab
True Color
PARM Code 00080 R
Mon. Site No. SWD-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
PCU
Weekly
Grab
Turbidity
PARM Code 00070 R
Mon. Site No. SWD-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
NTU
Weekly
Grab
Version: April 27, 2018 — Effective: May 2018
Page 3 of 10 DEP Form 62-620.910(10), Effective Nov. 29, 1994

DEPARTMENT OF ENVIRONMENTAL PROTECTION DISCHARGE MONITORING REPORT - PART A
When Completed mail this report to: Department of Environmental Protection, Wastewater Compliance Evaluation Section, MS 3551, 2600 Blair Stone Road, Tallahassee, FL 32399-2400
PERMITTEE NAME: Packaging Corporation of America
MAILING ADDRESS: Post Office Box 1048
Valdosta, Georgia 31603-1048
FACILITY:
LOCATION:
COUNTY:
OFFICE:
Packaging Corporation of America - Valdosta Operations
5495 Clyattville-Lake Park Road
Valdosta, Georgia 31601
Hamilton
Northeast District
PERMIT NUMBER:
LIMIT:
CLASS SIZE:
MONITORING GROUP NUMBER:
MONITORING GROUP DESCRIPTION:
RE -SUBMITTED DMR: ❑
NO DISCHARGE FROM SITE: ❑
MONITORING PERIOD:
FL0000281
Final
MA
D-001
Discharge to Withlacoochee River
From:
To:
REPORT FREQUENCY: Quarterly
PROGRAM: Industrial
Parameter
Quantity or Loading
Units
Quality or Concentration
Units
No.
Ex.
Frequency of
Analysis
Sample Type
Nitrogen, Total
PARM Code 00600 1
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
mg/L
Quarterly
Grab
Nitrogen, Total
PARM Code 00600 Q
Mon. Site No. CAL-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
lb/day
Quarterly
Calculated
Nitrogen, Kjeldahl, Total
(as N)
PARM Code 00625 1
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
mg/L
Quarterly
Grab
Phosphorus, Total (as P)
PARM Code 00665 1
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
mg/L
Quarterly
Grab
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge
and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.
NAME/TITLE OF PRINCIPAL EXECUTIVE OFFICER OR AUTHORIZED AGENT
SIGNATURE OF PRINCIPAL EXECUTIVE OFFICER OR AUTHORIZED AGENT
TELEPHONE
DATE
COMMENTS --- or EXPLANATION OF ANY VIOLATIONS (Reference all attachments here):
Version: April 27, 2018 — Effective: May 2018
Page 4 of 10 DEP Form 62-620.910(10), Effective Nov. 29, 1994

FACILITY:
DISCHARGE MONITORING REPORT - PART A (Continued)
Packaging Corporation of America - Valdosta Operations MONITORING GROUP NUMBER: D-001
MONITORING PERIOD From:
To:
PERMIT NUMBER: FL0000281
Parameter
Quantity or Loading
Units
Quality or Concentration
Units
No.
Ex.
Frequency of
Analysis
Sample Type
Phosphorus, Total (as P)
PARM Code 00665 Q
Mon. Site No. CAL-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
lb/day
Quarterly
Calculated
Oil and Grease
PARM Code 00556 1
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
5.9
(Day.Max.)
mg/L
Quarterly
Grab
Lead, Total Recoverable
PARM Code 01114 1
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
9.6
(Day.Max.)
ug/L
Quarterly
Grab
Hardness, Total (as CaCO3)
PARM Code 00900 1
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
mg/L
Quarterly
Grab
Nitrogen, Total
PARM Code 00600 R
Mon. Site No. SWU-1
Sample
Measurement
Permit
Requirement
Report
(Annual Geometric
Mean)
Report
(Day.Max.)
mg/L
Quarterly
Grab
Nitrogen, Ammonia, Total (as N)
PARM Code 00610 Q
Mon. Site No. SWU-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
mg/L
Quarterly
Grab
Phosphorus, Total (as P)
PARM Code 00665 R
Mon. Site No. SWU-1
Sample
Measurement
Permit
Requirement
Report
(Annual Geometric
Mean)
Report
(Day.Max.)
mg/L
Quarterly
Grab
Oil and Grease
PARM Code 00556 Q
Mon. Site No. SWU-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
mg/L
Quarterly
Grab
Lead, Total Recoverable
PARM Code 01114 Q
Mon. Site No. SWU-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
ug/L
Quarterly
Grab
Version: April 27, 2018 — Effective: May 2018
Page 5 of 10 DEP Form 62-620.910(10), Effective Nov. 29, 1994

FACILITY:
DISCHARGE MONITORING REPORT - PART A (Continued)
Packaging Corporation of America - Valdosta Operations MONITORING GROUP NUMBER: D-001
MONITORING PERIOD From:
To:
PERMIT NUMBER: FL0000281
Parameter
Quantity or Loading
Units
Quality or Concentration
Units
No.
Ex.
Frequency of
Analysis
Sample Type
Hardness, Total (as CaCO3)
PARM Code 00900 Q
Mon. Site No. SWU-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
mg/L
Quarterly
Grab
Nitrogen, Total
PARM Code 00600 S
Mon. Site No. SWD-1
Sample
Measurement
Permit
Requirement
Report
(Annual Geometric
Mean)
Report
(Day.Max.)
mg/L
Quarterly
Grab
Nitrogen, Ammonia, Total (as N)
PARM Code 00610 R
Mon. Site No. SWD-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
mg/L
Quarterly
Grab
Phosphorus, Total (as P)
PARM Code 00665 S
Mon. Site No. SWD-1
Sample
Measurement
Permit
Requirement
Report
(Annual Geometric
Mean)
Report
(Day.Max.)
mg/L
Quarterly
Grab
Oil and Grease
PARM Code 00556 R
Mon. Site No. SWD-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
mg/L
Quarterly
Grab
Lead, Total Recoverable
PARM Code 01114 R
Mon. Site No. SWD-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
mg/L
Quarterly
Grab
Hardness, Total (as CaCO3)
PARM Code 00900 R
Mon. Site No. SWD-1
Sample
Measurement
Permit
Requirement
Report
(Day.Max.)
mg/L
Quarterly
Grab
Version: April 27, 2018 — Effective: May 2018
Page 6 of 10 DEP Form 62-620.910(10), Effective Nov. 29, 1994

DEPARTMENT OF ENVIRONMENTAL PROTECTION DISCHARGE MONITORING REPORT - PART A
When Completed mail this report to: Department of Environmental Protection, Wastewater Compliance Evaluation Section, MS 3551, 2600 Blair Stone Road, Tallahassee, FL 32399-2400
PERMITTEE NAME:
MAILING ADDRESS:
FACILITY:
LOCATION:
COUNTY:
OFFICE:
Packaging Corporation of America
Post Office Box 1048
Valdosta, Georgia 31603-1048
Packaging Corporation of America - Valdosta Operations
5495 Clyattville-Lake Park Road
Valdosta, Georgia 31601
Hamilton
Northeast District
PERMIT NUMBER:
LIMIT:
CLASS SIZE:
MONITORING GROUP NUMBER:
MONITORING GROUP DESCRIPTION:
RE -SUBMITTED DMR: ❑
NO DISCHARGE FROM SITE: ❑
MONITORING PERIOD:
From:
FL0000281
Final
MA
D-001
Discharge to Withlacoochee River
REPORT FREQUENCY: Send Toxicity Monthly
PROGRAM: Industrial
To:
Parameter
Quantity or Loading
Units
Quality or Concentration
Results *
Units
No.
Ex.
Frequency of
Analysis
Sample Type
7-DAY CHRONIC STATRE
Ceriodaphnia dubia (Routine)
PARM Code TRP3B P
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
35
(Min.)
percent
Annually
Grab
7-DAY CHRONIC STATRE
Ceriodaphnia dubia (Additional)
PARM Code TRP3B Q
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
35
(Min.)
percent
As needed
Grab
7-DAY CHRONIC STATRE
Ceriodaphnia dubia (Additional)
PARM Code TRP3B R
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
35
(Min.)
percent
As needed
Grab
7-DAY CHRONIC STATRE
Pimephales promelas (Routine)
PARM Code TRP6C P
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
35
(Min.)
percent
Annually
Grab
7-DAY CHRONIC STATRE
Pimephales promelas (Additional)
PARM Code TRP6C Q
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
35
(Min.)
percent
As needed
Grab
7-DAY CHRONIC STATRE
Pimephales promelas (Additional)
PARM Code TRP6C R 1
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
35
(Min.)
percent
As needed
Grab
*ENTER "MNR" IN THE RESULTS COLUMN FOR EACH TEST THAT WAS NOT DONE THIS MONTH.
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted. Based on my inquiry of the person or persons who manage he system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge
and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.
NAME/TITLE OF PRINCIPAL EXECUTIVE OFFICER OR AUTHORIZED AGENT
SIGNATURE OF PRINCIPAL EXECUTIVE OFFICER OR AUTHORIZED AGENT
TELEPHONE
DATE
COMMENTS --- or EXPLANATION OF ANY VIOLATIONS (Reference all attachments here):
Version: April 27, 2018 — Effective: May 2018 Page 7 of 10
DEP Form 62-620.910(10), Effective Nov. 29, 1994

DEPARTMENT OF ENVIRONMENTAL PROTECTION DISCHARGE MONITORING REPORT - PART A
When Completed mail this report to: Department of Environmental Protection, Wastewater Compliance Evaluation Section, MS 3551, 2600 Blair Stone Road, Tallahassee, FL 32399-2400
PERMITTEE NAME:
MAILING ADDRESS:
FACILITY:
LOCATION:
COUNTY:
OFFICE:
Packaging Corporation of America
Post Office Box 1048
Valdosta, Georgia 31603-1048
Packaging Corporation of America - Valdosta Operations
5495 Clyattville-Lake Park Road
Valdosta, Georgia 31601
Hamilton
Northeast District
PERMIT NUMBER: FL0000281
LIMIT:
CLASS SIZE:
MONITORING GROUP NUMBER:
MONITORING GROUP DESCRIPTION:
RE -SUBMITTED DMR: ❑
NO DISCHARGE FROM SITE: ❑
MONITORING PERIOD:
From:
Final REPORT FREQUENCY: Annual
MA PROGRAM: Industrial
D-001
Discharge to Withlacoochee River
To:
Parameter
Quantity or Loading
Units
Quality or Concentration
Units
No.
Ex.
Frequency of
Analysis
Sample Type
Mercury, Total Recoverable
PARM Code 71901 1
Mon. Site No. EFF-1
Sample
Measurement
Permit
Requirement
Report
(Max.)
ug/L
Annually
Grab
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge
and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.
PRINT NAME & TITLE OF PRINCIPAL EXECUTIVE OFFICER OR AUTHORIZED AGENT
SIGNATURE OF PRINCIPAL OFFICER OR AUTHORIZED AGENT
TELEPHONE
DATE
COMMENTS -- or EXPLANATION OF ANY VIOLATIONS (Reference all attachments here):
Version: April 27, 2018 — Effective: May 2018
Page 8 of 10 DEP Form 62-620.910(10), Effective Nov. 29, 1994

INSTRUCTIONS FOR COMPLETING THE WASTEWATER DISCHARGE MONITORING REPORT
Read these instructions before completing the DMR. Hard copies and/or electronic copies of the required parts of the DMR were provided with the permit. All required information shall be completed in full and typed or printed
in ink. A signed, original DMR shall be mailed to the address printed on the DMR by the 28th of the month following the monitoring period. The DMR shall not be submitted before the end of the monitoring period.
The DMR consists of three parts --A, B, and D--all of which may or may not be applicable to every facility. Facilities may have one or more Part Ns for reporting effluent or reclaimed water data. All domestic wastewater facilities
will have a Part B for reporting daily sample results. Part D is used for reporting ground water monitoring well data.
When results are not available, the following codes should be used on parts A and D of the DMR and an explanation provided where appropriate. Note: Codes used on Part B for raw data are different.
CODE
DESCRIPTION/INSTRUCTIONS
ANC
DRY
FLD
IFS
LS
MNR
Analysis not conducted.
Dry Well
Flood disaster.
Insufficient flow for sampling.
Lost sample.
Monitoring not required this period.
CODE
DESCRIPTION/INSTRUCTIONS
NOD
OPS
OTH
SEF
No discharge from/to site.
Operations were shutdown so no sample could be taken.
Other. Please enter an explanation of why monitoring data were not available.
Sampling equipment failure.
When reporting analytical results that fall below a laboratory's reported method detection limits or practical quantification limits, the following instructions should be used:
1. Results greater than or equal to the PQL shall be reported as the measured quantity.
2. Results less than the PQL and greater than or equal to the MDL shall be reported as the laboratory's MDL value. These values shall be deemed equal to the MDL when necessary to calculate an average for that parameter and
when determining compliance with permit limits.
3. Results less than the MDL shall be reported by entering a less than sign ("<") followed by the laboratory's MDL value, e.g. < 0.001. A value of one-half the MDL or one-half the effluent limit, whichever is lower, shall be
used for that sample when necessary to calculate an average for that parameter. Values less than the MDL are considered to demonstrate compliance with an effluent limitation.
PART A -DISCHARGE MONITORING REPORT (DMR)
Part A of the DMR is comprised of one or more sections, each having its own header information. Facility information is preprinted in the header as well as the monitoring group number, whether the limits and monitoring
requirements are interim or final, and the required submittal frequency (e.g. monthly, annually, quarterly, etc.). Submit Part A based on the required reporting frequency in the header and the instructions shown in the permit. The
following should be completed by the permittee or authorized representative:
Resubmitted DMR: Check this box if this DMR is being re -submitted because there was information missing from or information that needed correction on a previously submitted DMR. The information that is being revised
should be clearly noted on the re -submitted DMR (e.g. highlight, circle, etc.)
No Discharge From Site: Check this box if no discharge occurs and, as a result, there are no data or codes to be entered for all of the parameters on the DMR for the entire monitoring group number; however, if the monitoring
group includes other monitoring locations (e.g., influent sampling), the "NOD" code should be used to individually denote those parameters for which there was no discharge.
Monitoring Period: Enter the month, day, and year for the first and last day of the monitoring period (i.e. the month, the quarter, the year, etc.) during which the data on this report were collected and analyzed.
Sample Measurement: Before filling in sample measurements in the table, check to see that the data collected correspond to the limit indicated on the DMR (i.e. interim or fmal) and that the data correspond to the monitoring
group number in the header. Enter the data or calculated results for each parameter on this row in the non -shaded area above the limit. Be sure the result being entered corresponds to the appropriate statistical base code (e.g.
annual average, monthly average, single sample maximum, etc.) and units.
No. Ex.: Enter the number of sample measurements during the monitoring period that exceeded the permit limit for each parameter in the non -shaded area. If none, enter zero.
Frequency of Analysis: The shaded areas in this column contain the minimum number of times the measurement is required to be made according to the permit. Enter the actual number of times the measurement was made in the
space above the shaded area.
Sample Type: The shaded areas in this column contain the type of sample (e.g. grab, composite, continuous) required by the permit. Enter the actual sample type that was taken in the space above the shaded area.
Signature: This report must be signed in accordance with Rule 62-620.305, F.A.C. Type or print the name and title of the signing official. Include the telephone number where the official may be reached in the event there are
questions concerning this report. Enter the date when the report is signed.
Comment and Explanation of Any Violations: Use this area to explain any exceedances, any upset or by-pass events, or other items which require explanation. If more space is needed, reference all attachments in this area.
Version: April 27, 2018 — Effective: May 2018
Page 9 of 10 DEP Form 62-620.910(10), Effective Nov. 29, 1994

PART B - DAILY SAMPLE RESULTS
Monitoring Period: Enter the month, day, and year for the first and last day of the monitoring period (i.e. the month, the quarter, the year, etc.) during which the data on this report were collected and analyzed.
Daily Monitoring Results: Transfer all analytical data from your facility's laboratory or a contract laboratory's data sheets for all day(s) that samples were collected. Record the data in the units indicated. Table 1 in Chapter 62-
160, F.A.C., contains a complete list of all the data qualifier codes that your laboratory may use when reporting analytical results. However, when transferring numerical results onto Part B of the DMR, only the following data
qualifier codes should be used and an explanation provided where appropriate.
CODE
DESCRIPTION/INSTRUCTIONS
<
The compound was analyzed for but not detected.
A
Value reported is the mean (average) of two or more determinations.
J
Estimated value, value not accurate.
Q
Sample held beyond the actual holding time.
Y
Laboratory analysis was from an unpreserved or improperly preserved sample.
To calculate the monthly average, add each reported value to get a total. For flow, divide this total by the number of days in the month. For all other parameters, divide the total by the number of observations.
Plant Staffing: List the name, certificate number, and class of all state certified operators operating the facility during the monitoring period. Use additional sheets as necessary.
PART D - GROUND WATER MONITORING REPORT
Monitoring Period: Enter the month, day, and year for the first and last day of the monitoring period (i.e. the month, the quarter, the year, etc.) during which the data on this report were collected and analyzed.
Date Sample Obtained: Enter the date the sample was taken. Also, check whether or not the well was purged before sampling.
Time Sample Obtained: Enter the time the sample was taken.
Sample Measurement: Record the results of the analysis. If the result was below the minimum detection limit, indicate that.
Detection Limits: Record the detection limits of the analytical methods used.
Analysis Method: Indicate the analytical method used. Record the method number from Chapter 62-160 or Chapter 62-601, F.A.C., or from other sources.
Sampling Equipment Used: Indicate the procedure used to collect the sample (e.g. airlift, bucket/bailer, centrifugal pump, etc.)
Samples Filtered: Indicate whether the sample obtained was filtered by laboratory (L), filtered in field (F), or unfiltered (N).
Signature: This report must be signed in accordance with Rule 62-620.305, F.A.C. Type or print the name and title of the signing official. Include the telephone number where the official may be reached in the event there are
questions concerning this report. Enter the date when the report is signed.
Comments and Explanation: Use this space to make any comments on or explanations of results that are unexpected. If more space is needed, reference all attachments in this area.
SPECIAL INSTRUCTIONS FOR LIMITED WET WEATHER DISCHARGES
Flow (Limited Wet Weather Discharge): Enter the measured average flow rate during the period of discharge or divide gallons discharged by duration of discharge (converted into days). Record in million gallons per day
(MGD).
Flow (Upstream): Enter the average flow rate in the receiving stream upstream from the point of discharge for the period of discharge. The average flow rate can be calculated based on two measurements; one made at the start
and one made at the end of the discharge period. Measurements are to be made at the upstream gauging station described in the permit.
Actual Stream Dilution Ratio: To calculate the Actual Stream Dilution Ratio, divide the average upstream flow rate by the average discharge flow rate. Enter the Actual Stream Dilution Ratio accurate to the nearest 0.1.
No. of Days the SDF > Stream Dilution Ratio: For each day of discharge, compare the minimum Stream Dilution Factor (SDF) from the permit to the calculated Stream Dilution Ratio. On Part B of the DMR, enter an asterisk
(*) if the SDF is greater than the Stream Dilution Ratio on any day of discharge. On Part A of the DMR, add up the days with an "*" and record the total number of days the Stream Dilution Factor was greater than the Stream
Dilution Ratio.
CBOD5: Enter the average CBOD5 of the reclaimed water discharged during the period shown in duration of discharge.
TKN: Enter the average TKN of the reclaimed water discharged during the period shown in duration of discharge.
Actual Rainfall: Enter the actual rainfall for each day on Part B. Enter the actual cumulative rainfall to date for this calendar year and the actual total monthly rainfall on Part A. The cumulative rainfall to date for this calendar
year is the total amount of rain, in inches, that has been recorded since January 1 of the current year through the month for which this DMR contains data.
Rainfall During Average Rainfall Year: On Part A, enter the total monthly rainfall during the average rainfall year and the cumulative rainfall for the average rainfall year. The cumulative rainfall for the average rainfall year is
the amount of rain, in inches, which fell during the average rainfall year from January through the month for which this DMR contains data.
No. of Days LWWD Activated During Calendar Year: Enter the cumulative number of days that the limited wet weather discharge was activated since January 1 of the current year.
Reason for Discharge: Attach to the DMR a brief explanation of the factors contributing to the need to activate the limited wet weather discharge.
Version: April 27, 2018 — Effective: May 2018
Page 10 of 10 DEP Form 62-620.910(10), Effective Nov. 29, 1994

GEORGL&
wir DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Summary Page
Name of Facility King America Finishing, Inc.
NPDES Permit No. GA0003280
This permit is a reissuance of an extended NPDES permit for King America Finishing, Inc. The facility
is a textile mill that performs preparation (includes scouring, de -sizing, bleaching, mercerization, etc.),
dyeing, finishing, and flame-retardant treatment of woven cotton and synthetic/cotton blended fabrics.
A maximum of 2.770 MGD of process water, cooling water, and stormwater is discharged to the
Ogeechee River in the Ogeechee River Basin. The permit expired on November 30, 2018 and became
administratively extended.
The permit was placed on public notice from September 30, 2020 to November 20, 2020.
Please Note The Following Changes to the Proposed NPDES Permit From The Existing Permit
Parts I.A.1, I.A.2, and I.A.3 — Effluent Limitations and Monitoring Requirements
• Added three tiers of effluent limitations to ensure that the technology based effluent limits
accurately reflect production levels without restricting facility operations.
• Modified the production -based effluent limitations for BOD5, sulfide, total phenols, and total
chromium based on updated production information.
• Modified the COD effluent limitations (Tier 1) from 5,500 lbs/day daily average and 11,000
lbs/day daily maximum to 5,328 lbs/day daily average and 10,656 lbs/day daily maximum based
on the production -based effluent limitation guidelines.
• Reduced the monitoring frequency for TSS from 5/week to 1/week based on performance.
• Reduced the monitoring frequency for sulfide from 7/week to 3/week based on performance.
• Replaced the previously misapplied concentration -based effluent limits of 30 mg/L daily average
and 45 mg/L daily maximum for TSS with report only requirements.
• Reduced the monitoring frequency for total phenols from 1/week to once every two months based
on performance.
• Reduced the monitoring frequency for total chromium from 1/week to once every two months
based on performance.
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 1

GEORGL&
wir DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Summary Page
• Replaced the concentration -based effluent limits of 1.2 mg/L daily average and 2.0 mg/L daily
maximum for total chromium with report only requirements due to the lack of any reasonable
potential for the discharge to cause or contribute to a violation of Georgia's Water Quality
Standards for chromium.
• Removed instream monitoring for total hardness as sufficient data was collected to characterize
the receiving stream so that site -specific data may be used when conducting a reasonable
potential analysis for hardness -dependent metals.
• Modified the ammonia mass -based effluent limits from 260 lbs/day daily average and 520 lbs/day
daily maximum to 181 lbs/day daily average and 336 lbs/day based on the facility's permitted
daily average flow and the concentration -based effluent limitations noted in the wasteload
allocation.
• Added monthly monitoring for organic nitrogen and nitrate/nitrite per Georgia's Plan for the
Adoption of Water Quality Standards for Nutrients (2013).
• Reduced the monitoring frequency for total Kjeldahl nitrogen, total nitrogen, and orthophosphate
from 1/week to 1/month based on best professional judgement.
• Removed monitoring requirements and effluent limit of 1.6 mg/L daily maximum for
formaldehyde due to concerns over the accuracy of available analytical methods due to matrix
interference. Any potential toxic effects of formaldehyde will be captured through the whole
effluent toxicity testing required in the permit.
• Removed the instream limits for color of A80 ADMI based on information provided from a color
study and permit sampling which indicated no reasonable potential for the effluent to cause or
contribute to a violation of Georgia's narrative Water Quality Standard for color.
• Removed sodium monitoring based on best professional judgement as there is no numeric water
quality standard for sodium to compare against. Any potential toxic effects of sodium will be
captured through the whole effluent toxicity testing required in the permit.
• Removed peroxide monitoring based on best professional judgement as there is no numeric water
quality standard for peroxide to compare against. Any potential toxic effects of peroxide will be
captured through the whole effluent toxicity testing required in the permit.
• Removed THPC monitoring based on best professional judgement as there is no numeric water
quality standard for THPC to compare against. Any potential toxic effects of THPC will be
captured through the whole effluent toxicity testing required in the permit.
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 2

GEORGL&
wir DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Summary Page
• Added escherichia coli effluent limitations of 126 #/100mL daily average and 410 #/100 mL
which will replace the fecal coliform effluent limitations subject to EPA approval of the proposed
changes to the GA. Comp. R. & Regs. which adopt e. coli and enterococci as pathogen indicators
for waters designated as fishing, coastal fishing, and drinking water. EPD will provide written
authorization for the change.
Part I.A.4 — Surface Water Monitoring Requirements
• Removed instream formaldehyde monitoring based on best professional judgement as there is no
numeric water quality standard for formaldehyde to compare against. Any potential toxic effects
of formaldehyde will be captured through the instream whole effluent toxicity testing required in
the permit.
• Removed instream sodium monitoring based on best professional judgement as there is no
numeric water quality standard for sodium to compare against. Any potential toxic effects of
sodium will be captured through the instream whole effluent toxicity testing required in the
permit.
• Removed instream sulfide monitoring based on best professional judgement as there is no
numeric water quality standard for sulfide to compare against. Any potential toxic effects of
sulfide will be captured through the instream whole effluent toxicity testing required in the
permit.
• Removed instream peroxide monitoring based on best professional judgement as there is no
numeric water quality standard for peroxide to compare against. Any potential toxic effects of
peroxide will be captured through the instream whole effluent toxicity testing required in the
permit.
• Added a requirement that downstream specific conductance and whole effluent toxicity testing
be conducted concurrently to verify that the downstream sampling location is representative of
the effluent plume within the Ogeechee River.
Part lII.0 — Special Conditions
• Paragraphs 2 and 3 from the previous permit have been removed as they have been consolidated
and expressed in Part I.A.4. Paragraphs 2 and 3 previously outlined the instream sampling
requirements for the facility.
• Paragraphs 4-7 from the previous permit have been consolidated and included as paragraph 3 in
this permit. Paragraphs 4-7 previously outlined effluent and instream whole effluent toxicity
testing requirements.
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 3

GEORGL&
wir DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Summary Page
• Paragraph 8-10 and 12 from the previous permit are one-time requirements that have been
completed and have been removed from this permit. Paragraphs 8 and 9 previously outlined a
mercury characterization study and a potential mercury minimization plan. Paragraph 10
previously included requirements for a color study. Paragraph 12 previously required
Perfluorooctane sulfonate (PFOS) sampling.
• Paragraph 11 from the previous permit has been removed as the contents of the language are
included in the permit's boilerplate language. Paragraph 11 previously required an annual
certification outlining any change in processes or wastewater characteristics.
• Added Paragraph 2 requiring characterization a Per- and Polyfluoroalkyl Substances (PFAS)
Characterization Study.
• Added language to Paragraph 3 requiring the permittee to prepare a Toxicity Identification
Evaluation work plan and conduct a Toxicity Identification Evaluation (TIE) and Toxicity
Reduction Evaluation (TRE) in the event that two WET tests are failed.
• Added language to Paragraph 3 requiring a modified dilution series and additional IC25 reporting
for chronic WET tests.
• Added Paragraph 4 addressing the facility's Sludge Management Plan approved August 31,
2020.
• Added Paragraph 5 requiring a written notification of increased production prior to granting
coverage under the Tier 2 or Tier 3 effluent limitations for higher levels of production.
Standard Conditions & Boilerplate Modifications
The permit boilerplate includes modified language or added language consistent with other NPDES
permits.
Final Permit Determinations and Public Comments
❑ Final issued permit did not change from the draft permit placed on public notice.
• Public comments were received during public notice period.
• Public hearing was held on November 17, 2020.
• Final permit includes changes from the draft permit placed on public notice. See attached permit
revisions and/or permit fact sheet revisions document(s)
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 4

GEORGIA
wir DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Revisions to Draft Permit
Name of Facility King America Finishing, Inc.
NPDES Permit No. GA0003280
Were there any revisions between the draft proposed NPDES permit placed on public notice and
the final proposed NPDES permit? If yes, specify: ® Yes ❑ No
Part I.A.1 — Effluent Limitations and Monitoring Requirements
• Revised the monitoring frequency for COD from 3/Week to 5/Week.
• Revised the fecal coliform effluent limitations from seasonal limitations of 500 #/100mL
daily average and 500 #/100mL daily maximum (May -Oct) and 1,000 #/100mL daily
average and 4,000 #/100mL daily maximum (Nov -Apr) to year-round effluent limitations
of 200 #/100mL daily average and 400 #/100mL daily maximum.
• Added escherichia coli effluent limitations of 126 #/100mL daily average and 410
#/100mL daily maximum which will replace the fecal coliform effluent limitations upon
EPA approval of the proposed changes to the Georgia Rules for Water Quality Control,
Chapter 391-3-6.03 (Water Use Classifications and Water Quality Standards) for bacterial
indicators. EPD will provide written authorization for the change.
Part I.A.2 — Effluent Limitations and Monitoring Requirements
• Revised the monitoring frequency for COD from 3/Week to 5/Week.
• Revised the fecal coliform effluent limitations from seasonal limitations of 500 #/100mL
daily average and 500 #/100mL daily maximum (May -Oct) and 1,000 #/100mL daily
average and 4,000 #/100mL daily maximum (Nov -Apr) to year-round effluent limitations
of 200 #/100mL daily average and 400 #/100mL daily maximum.
• Added escherichia coli effluent limitations of 126 #/100mL daily average and 410
#/100mL daily maximum which will replace the fecal coliform effluent limitations upon
EPA approval of the proposed changes to the Georgia Rules for Water Quality Control,
Chapter 391-3-6.03 (Water Use Classifications and Water Quality Standards) for bacterial
indicators. EPD will provide written authorization for the change.
Page 1 of 3

GEORGIA
wir DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Revisions to Draft Permit
• Added a requirement that the permittee submit a written notification of increased
production to obtain coverage under the "Tier 2" effluent limitations.
Part I.A.3 — Effluent Limitations and Monitoring Requirements
• Revised the monitoring frequency for COD from 3/Week to 5/Week.
• Revised the fecal coliform effluent limitations from seasonal limitations of 500 #/100mL
daily average and 500 #/100mL daily maximum (May -Oct) and 1,000 #/100mL daily
average and 4,000 #/100mL daily maximum (Nov -Apr) to year-round effluent limitations
of 200 #/100mL daily average and 400 #/100mL daily maximum.
• Added escherichia coli effluent limitations of 126 #/100mL daily average and 410
#/100mL daily maximum which will replace the fecal coliform effluent limitations upon
EPA approval of the proposed changes to the Georgia Rules for Water Quality Control,
Chapter 391-3-6.03 (Water Use Classifications and Water Quality Standards) for bacterial
indicators. EPD will provide written authorization for the change.
• Added a requirement that the permittee submit a written notification of increased
production to obtain coverage under the "Tier 3" effluent limitations.
Part I.A.4 — Surface Water Monitoring Requirements
• Revised the monitoring frequency for instream acute WET tests using Ceriodaphnia dubia
from 1/Quarter to 1/Month.
Part I.D — Reporting Requirements
• Updated to the new e-Reporting Phase II compliance date of December 21, 2025, per 40
CFR 127.16. The revision to the rule became effective January 4, 2021.
Part III.0 — Special Conditions
• Modified the PFAS characterization study language to clarify what per- and
polyfluoroalkyl substances must be characterized. The revised language requires that the
permittee characterize all PFAS used in processing or manufacturing at the facility or
believed present in the process wastewater or sludge due to contact with any raw materials,
intermediate products, finished products, byproducts, or waste products.
Page 2 of 3

GEORGIA
wir DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Revisions to Draft Permit
• Modified the PFAS characterization study to indicate that, where applicable, draft
analytical method 1633 should be used to analyze the PFAS compounds.
• Revised the WET testing requirements to require the reporting of the 25% inhibition
concentration (IC25) when conducting chronic WET tests.
• Modified the chronic WET test dilution series to 0%, 2%, 4%, 8%, 16%, 32%, 64%, 100%.
• Added detailed requirements and interim milestones for the completion of a Toxicity
Identification Evaluation (TIE) work plan, TIE/TRE, and additional data gathering
activities.
• Added a special condition for the permittee to submit a written notification of increased
production to obtain coverage under the "Tier 2" or "Tier 3" effluent limitations.
The permittee has been made aware of these changes
Page 3 of 3

GEORGIA
immmr DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Revisions to Draft Fact Sheet
Name of Facility King America Finishing, Inc.
NPDES Permit No. GA0003280
Were there any revisions between the draft proposed NPDES permit fact sheet placed on public
notice and the final proposed NPDES permit fact sheet? If yes, specify:
® Yes ❑ No
Section 1.8 — Description of the Wastewater Treatment Facility
• Updated the wastewater treatment facility description to reference dredging that occurred
in Fall 2021.
Section 3.3 — Georgia 305(b)/303(d) List Documents
• The receiving waterbody stream segment has been reclassified as the Ogeechee River from
Nevill's Creek to Hwy 301 based on the approved 2020 Integrated 305(b)/303(d) Report.
Section 4.1— Water Quality Based Effluent Limitations (WQBELs) & Technology Based Effluent
Limitations (TBELs)
• The boilerplate language for water quality based effluent limitations and technology based
effluent limitations has been updated.
Section 4.2 — Reasonable Potential Analysis
• The boilerplate language for reasonable potential analysis has been updated.
Section 4.3 — Whole Effluent Toxicity
• The narrative surrounding WET testing has been moved to Section 4.3.
• The WET testing narrative has been revised as the monitoring frequency for instream acute
WET tests using Ceriodaphnia dubia has been returned to 1/Month as was included in the
previous permit.
1 of 3

GEORGIA
immmr DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Revisions to Draft Fact Sheet
Section 4.4 — Conventional Pollutants: Outfall 001 & Instream Discussions
• Revised the fecal coliform narrative to reflect the change from seasonal effluent limitations
to year-round effluent limitations of 200 #/100mL daily average and 400 #/100mL daily
maximum.
• Added escherichia coli to replace the fecal coliform effluent limitations subject to EPA
approval of the proposed changes to the Georgia Rules for Water Quality Control, Chapter
391-3-6.03 (Water Use Classifications and Water Quality Standards) for bacterial
indicators. EPD will provide written authorization for the change.
Section 4.9 — Comparison & Summary of Water Quality vs. Technology Based Effluent Limits
• Updated the effluent limitation comparison table to reflect the change from seasonal
effluent limitations to year-round effluent limitations of 200 #/100mL daily average and
400 #/100mL daily maximum.
• Updated the effluent limitation comparison table to include e. coli effluent limitations of
126 #/100mL daily average and 410 #/100mL daily maximum.
Section 5.1 — Special Conditions
• Modified the narrative to discuss the addition of IC25 reporting and a modified dilution
series for chronic WET tests.
• Added narrative regarding the requirements and interim milestones for the completion of
a Toxicity Identification Evaluation (TIE) work plan, TIE/TRE, and additional data
gathering activities
• Modified the fact sheet to reflect the revised sludge management plan approved on October
7, 2021, which adds additional sludge disposal locations.
• Added narrative requiring a written notification of increased production to obtain coverage
under the "Tier 2" or "Tier 3" effluent limitations.
2 of 3

GEORGIA
immmr DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Revisions to Draft Fact Sheet
Section 5.3 — Anti -Backsliding
• Removed the anti -backsliding narrative for fecal coliform whose effluent limitations have
been returned to 200 #/100mL daily average and 400 #/100mL daily maximum.
Appendix C
• Updated the reasonable potential analysis to include the revised water quality standards for
cadmium.
The permittee has been made aware of these changes.
3 of 3

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
Table of Contents
Acronyms 2
General 3
Monitoring Frequency of Constituents 4
Per- and Polyfluoroalkyl Substances (PFAS) 5
Technology -Based Effluent Limitations 16
Water Quality -Based Effluent Limitations 19
Anti -Backsliding Regulations / Removal of Monitoring Requirements 28
Whole Effluent Toxicity 30
Instream Monitoring 36
Due to the volume of comments received and the number of topics covered in a comment, EPD has summarized and grouped
comments together based on the topic.
Page 1 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
Acronyms
CFR — Code of Federal Regulations
COD — Chemical Oxygen Demand
CWA — Clean Water Act
EAD — Environmental Administrative Decisions
EPA — Environmental Protection Agency
EPD — Environmental Protection Division
GA. Comp. R. & Regs. — Georgia Rules and Regulations for the Water Quality Control Act
IC25 — Inhibition Concentration 25%
IWC — Instream Waste Concentration
KAF — King America Finishing, Inc.
LOEC — Lowest Observed Effect Concentration
NOEC — No Observed Effect Concentration
NPDES — National Pollutant Discharge Elimination System
ORK — Ogeechee Riverkeeper
PFAS — Per- and Polyfluoroalkyl Substances
PFOA — Perfluorooctanoic Acid
PFOS — Perfluorooctane Sulfonate
POTW — Publicly Owned Treatment Works
qPCR - Quantitative Polymerase Chain Reaction
TBEL — Technology Based Effluent Limitation
TDS — Total Dissolved Solids
THPC — Tetrakis (hydroxymethyl) Phosphonium Chloride
TIE — Toxicity Identification Evaluation
TMDL — Total Maximum Daily Load
THE — Toxicity Reduction Evaluation
TRI — Toxics Release Inventory
TSCA — Toxic Substances Control Act
TSS — Total Suspended Solids
USC — United States Code
WET — Whole Effluent Toxicity
WQBEL — Water Quality Based Effluent Limitation
Page 2 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
General
1. The fish kill caused by King America has ruined our once thriving
business. We have seen first-hand how this amazing resource has been
affected. The visual changes in the color of our river and our
sandbars. Milliken now operates much like King America by over
exceeding their limits and paying fines. In no way should their permits
be altered to allow more leniency.
2. The Ogeechee River remains vulnerable to the stressors that
contributed to the largest fish -kill in Georgia's history, and global
warming will only serve to exacerbate the ongoing water quality
issues that contributed to this disaster by increasing the severity of
droughts and the frequency of destructively high-water temperatures.
This leads us to the dire conclusion that any changes to any of the 57
NPDES permits affecting this water basin will likely require more
stringent requirements rather than more lenient ones.
3. The public needs to be confident that there is rigorous attention to
pollutants emitted by the Milliken Plant. Casual discussions with
stakeholder groups using the river, in my opinion, reveals a reduction
in confidence that issues related to the Milliken Plant have been
effectively addressed. Although these are often relayed in the form of
anecdotes, weakening testing requirements and failure to include
PFAS will not help with this erosion of confidence.
4. My Labrador Retriever, who swam in the river daily, died of squamous
cell carcinoma of the mouth shortly after the pollution, and that
disease is rare but can be caused, in particular, by exposure to
EPD has evaluated the submitted permit application and supporting
documentation and proposed a NPDES permit in accordance with
applicable Federal and State regulations ensuring the permit is legal,
enforceable, and protective of water quality standards, human health,
and the environment.
Where less stringent effluent limitations have been applied, the rationale
has been based on the allowable exceptions defined in Section 402(o)(2)
of the CWA (33 U.S.C. § 1342(o)(2)). The implementation of such
revised limitations will not result in a violation of a water quality
standard under Section 303 of the CWA (33 U.S.C. § 1313) applicable
to such waters.
Page 3 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
formaldehyde, which, guess what, was one of the pollutants identified
in the King Finishing case.
I refuse to lose another beloved friend and therefore support the
strictest possible measures to keep the Ogeechee River clean and safe.
5. The permit should be protective of human health and the environment.
This includes recreational activities such as fishing and kayaking, and
the protection of our drinking water resources.
Monitoring Frequency of Constituents
1. There should be more frequent testing of constituents, not less as you
propose.
Milliken has repeatedly failed to operate this plant in compliance with
the current permit and should not be allowed to reduce any
environmental requirements related to operations or testing.
The draft permit improperly allows for a reduction in testing
frequency.
The Milliken has not been able to consistently meet EPA water quality
standards as evidenced by the record of violations. These violations
do not support less frequent testing and reducing parameters tested,
changes that are indicated in a side -by -side comparison of the current
and NPDES proposed permit. Reductions in frequency of testing
EPA's NPDES Permit Writers' Manual, EPA-833-K-10-001 (Sept.
2010) at Section 8.1.3, p. 8-5, directs that "the permit writer should
establish monitoring frequencies sufficient to characterize the effluent
quality and to detect events of noncompliance, considering the need for
data and, as appropriate, the potential cost to the permittee." EPD
evaluated the available data and determined for several parameters a
reduction of monitoring frequencies could be granted without increasing
the risk for undetected events of noncompliance, refer to Appendix D of
the Fact Sheet for additional information.
Effluent monitoring frequency reductions were proposed in the draft
permit for TSS, COD, sulfide, total phenols, and total chromium. Based
on public comments received, EPD has returned the monitoring
frequency for COD to 5/Week. The facility has not displayed non-
compliance with the TBELs for COD, but COD is a useful indicator of
Page 4 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
could lead to a less rapid response to discharge -related increases of
the chemicals listed in the permit.
EPD RESPONSE
wastewater treatment efficiency and process controls, as evidenced by
prior corrective action plans for the KAF facility.
Additionally, the draft permit reduced the instream monitoring
frequency of acute WET testing for ceriodaphnia dubia. Based on EPD's
review of WET testing, instream acute toxicity has not been detected for
ceriodaphnia dubia as part of the historical WET testing. However, in
consideration of the commentors concerns and the periodic toxicity
exhibited in the effluent, EPD has returned the monitoring frequency for
acute ceriodaphnia dubia WET testing to once per month.
EPD additionally reduced the monitoring frequencies for total Kjeldahl
nitrogen, total nitrogen, and orthophosphate in the draft permit. These
constituents did not have effluent limitations and monitoring was
included to aide in the future development of numeric nutrient criteria.
Monthly monitoring data is sufficient to collect the data needed to
develop and calibrate EPD water quality models. The proposed, reduced
monitoring frequency remains unchanged in the final permit for these
constituents.
Per- and Polyfluoroalkyl Substances (PFAS)
The discharge of a specific pollutant (or group of pollutants) cannot be
permitted if it is not disclosed in a NPDES permit application. The Clean
Water Act generally prohibits pollutant discharges to streams and rivers.
The NPDES permitting program is a limited exception to that prohibition,
and discharges under the program cannot be approved unless they are
adequately disclosed. The Environmental Protection Agency has stressed
the need for disclosure of pollutants during the permitting process:
The EPA Environmental Appeals Board's decision in re: Ketchikan Pulp
Company, 7 E.A.D. 605 (EPA) (1998) and the decision in Piney Run
Pres. Ass 'n v. Cty. Comm 'rs of Carroll Cty., Maryland, 268 F.3d 255
(4th Cir. 2001) contemplates when a "permit shield" is granted for
pollutants not addressed in the NPDES permit. The comment as it
pertains to Clean Water Act compliance under the current permit is
inapplicable to the permit reissuance process under consideration now
Page 5 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
[D]ischargers have a duty to be aware of any significant pollutant
levels in their discharge. [...] Most important, [the disclosure
requirements] provide the information which the permit writers need
to determine what pollutants are likely to be discharged in significant
amounts and to set appropriate permit limits. [...] [P]ermit writers
need to know what pollutants are present in an effluent to determine
approval permit limits in the absence of applicable effluent guidelines.
The EPA Environmental Appeals Board's decision in re: Ketchikan Pulp
Company further emphasized the importance of disclosure. In Piney Run
Pres. Ass'n v. Cty. Comm'rs of Carroll Cty., Maryland, the court
followed Ketchikan and stated:
The Ketchikan decision therefore made clear that a permit holder is in
compliance with the [Clean Water Act] even if it discharges pollutants
that are not listed in its permit, as long as it only discharges pollutants
that have been adequately disclosed to the permitting authority. [...]
To the extent that a permitholder discharges a pollutant that it did not
disclose, it violates the NPDES permit and the [Clean Water Act].
Milliken failed to disclose PFAS in its permit application, in violation of
the Clean Water Act. Sampling discussed below establishes that the
facility is discharging PFAS. The failure to disclose the presence of PFAS
should result in EPD remanding the permit to Milliken to disclose fully
such PFAS discharges.
EPD RESPONSE
and should be raised separately. Regarding the aspects of the comment
which apply to the permit reissuance, while important for developing our
regulatory framework, the cases are largely inapplicable to this draft
permit which explicitly considers per- and polyfluoroalkyl substances
(PFAS) through a special condition requiring a PFAS Characterization
Study.
PFAS are emerging pollutants of concern and significant resources are
currently being employed at the national and state levels to develop
multi -media and multi -program research and risk communication plans
to address PFAS. As this response to comments is being drafted, US
EPA has yet to promulgate instream water quality criteria and has not
yet developed any 40 C.F.R. § 136 approved wastewater analytical test
methods for this category of pollutants. EPA has however published
draft analytical method 1633 for 40 PFAS compounds since the draft
permit was placed on public notice. While not nationally required for
compliance monitoring, the draft method is recommended for use in
individual permits. Where applicable, draft method 1633 will be used for
the PFAS Characterization Study required in Part III.C.2 of the permit.
EPD continues to stay engaged and is following US EPA's progress as
it evaluates PFAS as it relates to discharges from point sources to surface
waters.
The proposed permit expands upon the PFAS Characterization Study
required in the previous permit and will serve to assist in the
identification of potential sources of PFAS from the facility. EPD may
reevaluate the permit based on the results of the PFAS Characterization
Study and, if necessary, modify the permit in accordance with 40 C.F.R.
§ 122.62(a)(2).
Page 6 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
For all pollutants, the Clean Water Act requires permitting agencies to
impose technology -based effluent limitations. If these limits are not
enough to ensure compliance with water quality standards, then water
quality -based effluent limits must be included. EPD has apparently not
evaluated any limits on PFAS, which is understandable since the
permittee did not disclose them. But EPD should insist on such disclosure
and develop permit terms accordingly.
Technology -based effluent limits are "the minimum level of control that
must be imposed in a permit." These limits "are developed independently
of the potential impact of a discharge on the receiving water, which is
addressed through water quality standards and water quality -based
effluent limitations." As EPA has recognized, "technology -based limits
aim to prevent pollution by requiring polluters to install and implement
various forms of technology designed to reduce the pollution discharged
into the nation's waters." When EPA has not issued a national effluent
limitation guideline for a particular industry, permitting agencies must
implement technology -based effluent limits on a case -by -case basis using
their "best professional judgment."
There are available technologies used to reduce the discharge of PFOAs
from industrial wastewater. Although it is beyond the expertise of the
Riverkeeper to design wastewater treatment systems, it has been widely
reported that effective technologies include activated carbon treatment,
ion exchange resins, and high-pressure membranes, like nanofiltration or
reverse osmosis.
40 C.F.R. § 125.3(c) allows for technology -based treatment
requirements to be imposed on a case -by -case basis under Section
402(a)(1) of the CWA, to the extent that EPA -promulgated effluent
limitations are inapplicable. EPA has already promulgated applicable
effluent limitation guidelines at 40 C.F.R. 410 — Subpart D for woven
fabric fmishing and commission finishing which apply to the facility's
operations.
US EPA recently issued its Effluent Guidelines Program Plan 14, EPA-
821-R-21-001 (Jan. 2021) fulfilling its requirements at Section 304(m)
of the CWA (33 U.S.C. § 1314(m)) to biennially publish a plan for new
and revised effluent limitations guidelines. As part of this plan, US EPA
has indicated its intent to conduct a Multi -industry Detailed Study of
industrial PFAS use, treatment, and discharges to surface water and
POTWs focusing on five -point source categories: PFAS manufacturers,
pulp and paper manufacturers, textile and carpet manufacturers, airports,
and metal finishers. US EPA has indicated that further study is required
of textile manufacturers, prior to initiating any revised rulemaking. US
EPA has since issued its Preliminary Effluent Guidelines Program Plan
15, EPA-821-R-21-003 (Sep. 2021) and Multi -Industry Per- and
Polyfluoroalkyl Substances (PFAS) Study — 2021 Preliminary Report,
EPA-821-R-21-004 (Sep. 2021) which reaffirms EPA's intent to
conduct a separate detailed study to collect and review information and
data on the use, treatment, and discharge of PFAS from textiles and
carpet manufacturers.
Per- and polyfluoroalkyl substances (PFAS) are an extensive group of
man-made chemicals which are emerging pollutants of concern.
Significant resources are currently being employed at the national and
state levels to develop multi -media and multi -program research and risk
Page 7 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
communication plans to address PFAS. As this response to comments is
being drafted, US EPA has yet to promulgate instream water quality
criteria and has developed only a limited number of draft wastewater
analytical test methods. EPD continues to stay engaged and is following
US EPA's progress as it evaluates PFAS as it relates to discharges from
point sources to surface waters. Hence, Part III.C.2 of the permit requires
a PFAS Characterization Study while the CWA framework for
potentially regulating PFAS discharges pursuant to the NPDES program
is under development. EPD may reevaluate the permit based on the
results of the PFAS Characterization Study and, if necessary, modify the
permit in accordance with 40 C.F.R. § 122.62(a)(2).
EPD must ensure that Georgia water quality standards will not
be violated by the discharge. If there is a "reasonable potential" that water
quality standards will be exceeded, EPD must include water quality -
based effluent limits in the permit as well. Georgia water quality
standards provide: "All waters shall be free from toxic, corrosive, acidic
and caustic substances discharged from municipalities, industries or other
sources, such as nonpoint sources, in amounts, concentrations or
combinations which are harmful to humans, animals or aquatic life." Ga.
Comp. R. & Regs. 391-3-6-.03(5)(e).
PFAS are known to harm human health, and they certainly qualify as
toxic substances under state law. Two of the most commonly studied
PFAS, perfluorooctanoic acid ("PFOA") and perfluorooctane sulfonate
("PFOS"), have been found to cause developmental effects to fetuses and
infants, kidney and testicular cancer, liver malfunction, hypothyroidism,
high cholesterol, ulcerative colitis, lower birth weight and size, obesity,
decreased immune response to vaccines, reduced hormone levels and
delayed puberty.
Where numeric criteria have not been established whole effluent
biomonitoring may be used to develop a whole effluent toxicity (WET)
limit. The proposed permit contains whole effluent toxicity limits,
consistent with EPD's NPDES Reasonable Potential Procedures (2003).
This approach is necessary and appropriate for the protection of Georgia
water quality criteria in accordance with GA. Comp. R. & Regs. 391-3-
6-.03(5)(e).
During the development of the draft permit, EPD determined King
America Finishing does not discharge to a reach of the Ogeechee River
that has a designated use for drinking water and there are no surface
water drinking water intakes in the downstream vicinity of the discharge.
The referenced US EPA drinking water advisories/standards only
address exposure through drinking water ingestion (not exposure via
consumption of food sources or skin contact) and are not directly
applicable to instream water quality standards for point source
discharges to surface waters. (Clarification about the Appropriate
Page 8 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED ill
EPA established a lifetime health advisory of 70 ppt for the combined
concentrations of PFOA and PFOS in drinking water. Since then, in June
2018, the Agency for Toxic Substances and Disease Registry released an
updated Draft Toxicological Profile for PFOA, PFOS, and other PFAS.
The report suggested that many of the chemicals are much more harmful
than previously thought. For instance, the minimum risk levels, or the
amount of a chemical a person can eat, drink, or breathe each day without
a detectable risk to health, was determined to be only 11 ppt for PFOA,
and 7 ppt for PFOS. Epidemiological studies show that many of these
same health outcomes result from exposure to other PFAS. Given these
harms, states like Michigan, New York, New Hampshire, New Jersey,
and Vermont have acknowledged the dangers of these compounds and
have either proposed or finalized drinking water standards for various
PFAS at 20 ppt and lower.
1. PFAS are also harmful to the environment. They have been shown to
cause harmful effects in fish, amphibians, mollusks, and other aquatic
invertebrates — resulting in developmental and reproductive impacts,
behavioral changes, adverse effects to livers, disruption to endocrine
EPD RESPONSE
Application of the PFOA and PFOS Drinking Water Health Advisories,
(Nov. 2016))
EPD does however acknowledge the emerging concerns regarding PFAS
and the efforts to develop on a national level a comprehensive PFAS
Action Plan. US EPA's action plan is a multi -media, multi -program,
national research, management, and risk communication plan to address
PFAS in drinking water, identify and clean up PFAS contamination,
expand monitoring of PFAS in manufacturing, increase PFAS scientific
research, and exercise effective enforcement tools. Of specific interest
during the permitting process are US EPA's efforts to develop water
quality criteria for PFAS, identify industrial sources that may warrant
further study and regulations, and continued efforts to develop analytical
methods.
In conjunction with the national response for PFAS, EPD is working on
furthering the objectives of the action plan on a state level. Part III.C.2
of the permit requires a PFAS Characterization Study to determine and
quantify the potential the facility has to discharge PFAS into the
environment through the discharge of treated wastewater effluent or
through industrial sludge disposal.
To learn more about this class of chemicals and EPD's investigation and
response to them, please visit our webpage at:
https://epd.georgia.gov/pfoa-and-pfos-information.
Fish consumption advisories are risk -based recommendations on the
amount of fish from a specific waterbody that is safe to consume (e.g.,
servings per day, week, month, or year). The recommendation is
informed by the measured concentration of contaminants in a sample of
Page 9 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
systems, and weakened immune systems. Moreover, they are
extremely resistant to breaking down in the environment, can travel
long distances, and bio-accumulate in organisms.
EPD must ensure that residents who fish, boat, and swim downstream
of the discharge are protected. Many people fish for sustenance and
recreate downstream of Milliken's discharge location. Emerging
research is showing that PFAS—even at low levels —are harmful. In
addition, one of the key characteristics of the class is that they bio-
accumulate in many fish species. We have evidence, discussed
below, that downstream fish are being contaminated with PFAS from
the facility and thus are being caught and eaten by Georgia citizens.
As part of the ORK and Milliken sampling event in December 2018,
two separate effluent samples were analyzed by 2 independent
laboratories for 21 perfluoroalkyl substances (PFAS) including PFOS
and PFOA using EPA Method 537 (Modified). This sampling
indicated that 11 of 23 PFAS analytes were present at concentrations
above the reporting limit. Further, these data indicated that the sum
of PFOS and PFOA concentrations were between 203 and 227
ng/L(ppt). Although the effluent and the Ogeechee River are not
drinking water sources, these concentrations greatly exceed EPA's
established human health advisory level of 70 parts per trillion (ppt)
for PFOS and PFOA combined in drinking water and indicate a
continuous source of PFASs to the Ogeechee River which is utilized
by residents for fish consumption. No plausible source of these
pollutants other than this textile mill exists. The documented presence
of these pollutants requires that EPD remand the permit to the
permittee for full disclosure of its discharge of these chemicals.
EPD RESPONSE
fish that are representative of a specific waterbody. The underlying basis
for the recommendation is an established toxicity criterion, which
represents a level of contaminant that an individual can be exposed to
every day without experiencing adverse health effects. Instream water
quality criteria do not inform or help develop fish tissue advisories.
At this time, neither GA EPD nor US EPA has developed instream water
quality standards or fish consumption guidelines for PFAS. EPD
acknowledges the emerging concerns regarding PFAS and is working on
furthering the objectives of US EPA's PFAS Action Plan on a state level.
Specifically, for the KAF facility, a PFAS Characterization Study has
been included at Part III.C.2 of the permit to determine and quantify the
potential the facility has to discharge PFAS into the environment through
the discharge of treated wastewater effluent or through industrial sludge
disposal. EPD may consider more targeted actions, such as fish tissue
studies, as more information becomes available.
Page 10 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
In addition to effluent sampling, ORK has conducted, and is in the
process of collecting, fish tissues representative of the type and size
of fish typically consumed from the Ogeechee River and analyzing
these representative fish species for PFOA and PFOS.
Fish were collected from the Ogeechee River between the Interstate
16 and Highway 80 bridges. This is approximately 38 miles
downstream of the Milliken discharge. A total of 7 fish were collected
and PFOS was detected in all 7 fish. The fish were filleted and
submitted to an analytical laboratory for analysis for PFOS and
PFOA.
Five of the 7 fish contained PFOS at concentrations in excess of
10 µg/kg. Based on the Consortium Best Practices guidelines, PFOS
tissue concentrations in a majority of the samples would result in a
fish consumption advisory for this section of the Ogeechee River of 2
meals per week to be protective of human health.
Using EPA's 2016 Drinking Water Health Advisory reference dose
(RfD) of 2x10-5 milligrams per kilogram per day, a fish consumption
limit can be developed. Specifically, the Great Lakes Consortium for
Fish Consumption Advisories developed the Best Practice
for Perfluorooctane Sulfonate (PFOS) Guidelines which contains
recommendations for consumption of fish containing PFOS based on
EPA's RfD. The guidelines assessed a meal size of 227 grams (1/2
pound) of raw fish per meal for a 70 kg adult.
This data calls for further action. Admittedly, this data is limited and
more information is needed. It should not be the Riverkeeper's job to
collect this data. Rather, the State should require the company to
collect this data and submit it to EPD as part of a proper disclosure of
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Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
2.
its PFAS-related discharges. Thus, the permit should be withdrawn
and the company should be required to make a proper disclosure of
its PFAS-related discharges and the results of a properly designed fish
tissue sampling protocol at which point, if appropriate, TBELs,
WQBELs, and appropriate monitoring conditions should be imposed.
A fish tissue study is long overdue and should be completed before
the permit is granted.
The presence of per- and polyfluoroalkyl substances (PFAS) in fish
tissue downstream of this plant raises serious concerns for those of us
that consume fish and shellfish taken from waters around our homes.
A permit should not be issued without a fish tissue study, which
should have already been completed under the terms of the previous
permit.
We would like to express our alarm regarding news that the
Riverkeeper has taken samples indicating that Milliken has been
discharging a harmful class of long-lasting chemicals known as
PFAS, despite submitting reports to the contrary to EPD. The
Riverkeeper reports that these carcinogens appear to be accumulating
in fish. EPD can begin to address this disturbing development by
conducting the comprehensive fish tissue study that was part of the
fish kill litigation settlement but canceled due to Milliken' erroneous
reporting.
ORK has discovered that Milliken has been discharging a harmful
class of chemicals known as PFAs, despite submitting reports to GA
EPD suggesting otherwise. ORK has also discovered that these
carcinogens are appearing in the fish people consume. A permit
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Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
should include standards and guidelines for PFAs and fish
consumption. It is essential that people know what they are eating and
are not exposed to harmful chemicals. A comprehensive fish tissue
study should be done before any new permit is issued.
A threat has been identified by the Ogeechee Riverkeeper of PFA
bioconcentration in fish tissues. PFAs are an acknowledged emerging
threat to water quality and human health. The permit should be
amended to address this new threat. People have the right to know
what contaminants are in the fishes they are consuming and to have
the EPD work towards setting recommendations in the form of
consumption advisories for those contaminants. Included in this effort
should be the reduction of PFAs to the river basin. Other states have
consumption advisories for PFOs/PFAs (Michigan is an example).
PFAS can accumulate and stay in the human body for long periods of
time. There is evidence that exposure to PFAS can lead to adverse
health outcomes in humans The most -studied PFAS chemicals are
PFOA and PFOS. Studies indicate that PFOA and PFOS can cause
reproductive and developmental, liver and kidney, and
immunological effects in laboratory animals. Both chemicals have
caused tumors in animals. The most consistent findings are increased
cholesterol levels among exposed populations, with more limited
findings related to low infant birth weights, effects on the immune
system, cancer (for PFOA), and thyroid hormone disruption (for
PFOS). Why would you allow these possibilities?
ORK's discovery of PFAS/PFOS in Ogeechee River fish
demonstrates Milliken/King America's lack of transparency
regarding their past/current production line. That the fish tissue study
called for under the 2013 permit has not been completed is reason
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Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
enough to delay EPD issuing the permit as it now stands. It took ORK
spending its own time and money collecting samples and submitting
them to an independent laboratory to again prove that these
compounds are present in the facility's effluent.
Recognizing that subsistence fishing is still practiced on the Ogeechee
for several populations, Milliken must be required to complete a fish
tissue survey focused on emerging contaminants that are found in the
company's discharge.
Part III.C.2 of the draft permit contains requirements for a Per -and
Polyfluoroalkyl Substances (PFAS) Characterization Study. KAF asserts
that the legal, analytical, and scientific framework regarding PFAS, when
considered as a broad chemical group rather than specific non -polymeric
or polymeric compounds, is too uncertain at this time to allow for clear
implementation of a broad characterization requirement like the one
proposed in the draft permit. KAF requests that the PFAS
characterization requirement be removed from the draft permit.
In accordance with 40 C.F.R. § 122.21(g)(13), "applicants shall provide
to the Director, at his or her request, such other information as the
Director may reasonably require to assess the discharges of the facility
and to determine whether to issue an NPDES permit." Additionally,
consistent with US EPA's NPDES Permit Writers' Manual, EPA-833-
K-10-001 (Sept. 2010) at Section 6.2.1.5, p. 6-15, the permit writer may
require monitoring for pollutants which are expected present in the
discharge based on the raw materials stored or used, products or by-
products of the facility operation, or available data and information on
similar facilities. Hence, EPD is requiring KAF to characterize the
discharge of pollutants.
US EPA has identified textile mills as potential contributors of PFAS as
part of their manufacturing process (Effluent Guidelines Program Plan
14, EPA-821-R-21-001 (Jan. 2021)). In conjunction with the national
response for PFAS, EPD is working on furthering the objectives US
EPA's PFAS Action Plan on a state level. The PFAS Characterization
Study required in the permit will serve to assist in the identification of
potential sources of PFAS from the facility. This permit condition is
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Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
necessary and appropriate for the protection of Georgia water quality
criteria in accordance with GA. Comp. R. & Regs. 391-3-6-.03(5)(e).
KAF objects to the specific language of Part III.C.2.a, which requires that
the permittee characterize, within one (1) month, all per -and
polyfluoroalkyl substances (PFAS) employed by the facility. PFAS is a
broad class of chemicals that includes thousands of non -polymeric and
polymeric compounds, the vast majority of which are not currently
regulated under environmental or worker protection laws. Because of
this, and because PFAS are commonly provided to manufacturers in
proprietary formulations, the specific chemical identity of PFAS
compounds is not required to be disclosed by the manufacturer and is
often not readily available to the permittee. Most notably, PFAS
compounds are not typically identified (and are not required to be
identified) as hazardous components on Safety Data Sheets. Any
characterization effort by the permittee will depend on the willingness
and capability of suppliers to provide accurate information to the
permittee, and any characterization requirement imposed by the Georgia
EPD should consider and allow for this constraint. Specifically, any
permittee — including KAF — would need more than one month just to
work with suppliers in an effort to obtain this information, and the permit
language should clearly acknowledge that the characterization is limited
to the information provided by the suppliers. The permit language should
also recognize the possibility that this information will be considered
proprietary and may not be provided by suppliers voluntarily.
Part III.C.2 of the proposed permit requires that the permittee
characterize and report all per- and polyfluoroalkyl substances (PFAS)
used in processing or manufacturing facility at the facility or believed
present in the facility's wastewater or sludge and submit a report to EPD.
In addition, the report should identify any PFAS known or believed to
be present in the facility's wastewater or sludge, including any PFAS
compounds found in raw materials, residual PFAS compounds from
previous activities, and breakdown products. Where such
characterizations are reliant on third -party manufacturer's data, the
characterization should at a minimum include any PFAS which is
required to be identified as part of the Toxic Substances Control Act
(TSCA) and Toxic Release Inventory (TRI) reporting requirements. The
permittee shall identify where such third -party information is identified
as confidential business information so that EPD may obtain the
information independently, as necessary.
For PFAS data obtained by the permittee which is identified as
confidential under the Georgia Open Records Act, O.C.G.A § 50-18-70,
et seq., the permittee shall submit to EPD a "protected" and "redacted"
version of the information accompanied by an affidavit supporting the
permittee's confidentiality claims in accordance with EPD procedures.
The permittee has been given ample notice regarding the PFAS
Characterization Study and the requirement to characterize all PFAS
used in processing or manufacturing at the facility or believed present in
the facility's wastewater or sludge within one month of the effective date
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Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
of the permit. The proposed permit condition remains unchanged from
the draft permit.
Technolozy-Based Effluent Limitations
The permit establishes three tiers of TBEL mass -based limits which are
related to production. However, it is unclear how those limitations are to
be applied. This will result in confusion regarding the status of
compliance at the facility. The permit requires that the average daily
production (in terms of pounds of product/day) be reported each month
and could result in the limits changing on a monthly basis as production
changes. For daily average discharge limitations, this approach is
straightforward. Once the average daily production is known for the
month, the average discharge load is calculated and compared to the daily
average limitation for the appropriate tier. However, this approach is
problematic for the daily maximum limitation. Since production may
change from day to day, compliance with the daily maximum limitation
should be based on the limitation established for the tier based on
production for that day, not the tier based on the average daily production
value which may allow a higher discharge load. This will make it
challenging to determine if the facility is in or out of compliance. The
permit should be modified to define how the limit changes and provide a
justification for using average daily production values to establish daily
maximum limitations.
The daily average and daily maximum effluent limitations established in
the permit are based on a reasonable measure of the facility's actual
production rate consistent with US EPA's NPDES Permit Writers'
Manual, EPA-833-K-10-001 (Sept. 2010) at Sections 5.2.2.5 and
5.2.2.7. This level of production represents a long-term average
production rate that is expected to exist during the permit term and is
subsequently used to calculate both the daily average and daily
maximum effluent limitations. The use of daily production values to
establish dynamic daily maximum effluent limits, as the commentor has
suggested, are contrary to the long-standing US EPA guidance for
establishing production -based effluent limitations.
As part of the permit application process, the permittee requested
consideration that the production levels return to the historical levels
achieved in 2011. To accurately reflect production levels without
restricting facility operations, EPD has established 3 tiers of effluent
limitations. The permittee will be required to comply with the tiered
permit limitations based on the monthly average production levels
(lbs/day).
EPD appreciates the commentor's concerns regarding the status of
compliance with a tier -based approach to effluent limitations. To provide
further transparency, EPD has adopted certain elements of the
production -based limitations for the automotive manufacturing industry
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Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
established at 40 C.F.R. § 122.45(b)(2)(ii)(A)(2). The revised permit
includes a requirement that the permittee notify EPD in writing at least
two business days prior to the month they expect to be operating at a
higher level of production (higher than Tier 1). The notice shall specify
the anticipated level and the period during which the permittee expects
to operate at the alternate level. New notice is required to cover a period
or production level not covered by prior notice or, if during two
consecutive months otherwise covered by a notice, the production level
at the permitted facility does not in fact meet the higher level designated
in the notice.
It defies reason that limits be based on the facility's production levels.
The health of the Ogeechee River itself must be the sole determiner of
the limits and restricts you set.
The draft permit improperly bases limits on the facility's production
levels, not the health of the river.
We agree with the Riverkeeper's objection to tiered limitations based on
the facility's self -reported production levels rather than setting thresholds
that best protect the river. This is another example of prioritizing the
permittee's interest in controlling costs over the public interest in a safe,
clean, and diverse environment. Presumably, higher production levels
would be accompanied by higher revenues that could cover the costs of
keeping pollutant discharges low enough to be protective. The facility's
production levels have no bearing on the river's resiliency and should not
be used as an excuse to allow increased pollution levels.
Restrictions on discharge levels should be based on models of river health
and current available science, not on facility production goals.
When drafting a National Pollutant Discharge Elimination System
(NPDES) permit, a permit writer must consider the impact of the
proposed pollutants in a discharge on the quality of the receiving water.
Water quality goals for a waterbody are defined by state water quality
criteria or standards. By analyzing the effect of a pollutant in the
discharge on the receiving water, a permit writer could find that
technology -based effluent limitations (TBELs) alone will not achieve
the applicable water quality standards or protect downstream users. In
such cases, the Clean Water Act (CWA) and its implementing
regulations require development of water quality -based effluent
limitations (WQBELs). WQBELs help meet the CWA objective of
restoring and maintaining the chemical, physical, and biological
integrity of the nation's waters and the goal of water quality that provides
for the protection and propagation of fish, shellfish, and wildlife and
recreation in and on the water (fishable/swimmable).
WQBELs are designed to protect water quality by ensuring water quality
standards are met in the receiving water and the designated use and
downstream uses are protected. On the basis of the requirements of 40
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Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
C.F.R §125.3(a), additional or more stringent effluent limitations and
conditions, such as WQBELs, are imposed when TBELs are not
sufficient to protect water quality. (US EPA's NPDES Permit Writers'
Manual, EPA-833-K-10-001 (Sept. 2010) at Ch. 6, p. 6-1)
TBELs aim to prevent pollution by requiring a minimum level of effluent
quality that is attainable using demonstrated technologies for reducing
discharges of pollutants or pollution into the waters of the State. TBELs
are developed independently of the potential impact of a discharge on
the receiving water, which is addressed through water quality standards
and WQBELs. The NPDES regulations at 40 C.F.R. § 125.3(a) require
NPDES permit writers to develop technology -based treatment
requirements, consistent with CWA section 301(b), that represent the
minimum level of control that must be imposed in a permit. The
regulation also requires permit writers to include in permits additional or
more stringent effluent limitations and conditions, including those
necessary to protect water quality. (US EPA's NPDES Permit Writers'
Manual, EPA-833-K-10-001 (Sept. 2010) at Ch. 5, p. 5-1)
The draft permit placed on public notice evaluates the need for both
TBELs and WQBELs for pollutants of concern (see Fact Sheet). Where
more stringent WQBELs are required, they have been included in the
permit.
WQBELs are developed to protect designated uses and water quality
criteria and can originate from modeling (WLAs), TMDLs, and other
EPD policies (e.g., reasonable potential analysis). WQBELs are not
always more stringent than TBELs, in which case the more stringent
TBELs are included in the NPDES permit. An example of such a
situation in this permit is BOD5 for which the calculated production -
based TBELs were more stringent than the corresponding WQBELs. At
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Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
the highest tier of production, TBELs of 423 lbs/day daily average and
846 lbs/day daily maximum are required. Conversely, the applicable
WQBELs based on water quality modeling (WLA) for BOD5 would be
776 lbs/day daily average and 1,551 lbs/daily maximum. As such,
production -based TBELs were included in the permit as they are more
stringent than the modeled WQBELs for BOD5.
Water Quality -Based Effluent Limitations
The Draft permit does not include limitations for cyanide and uses the
highest reported cyanide concentration (18 µg/L) as a basis for a
reasonable potential analysis. However, during a joint sampling event
between ORK and Milliken, cyanide was detected at 120 µg/L. Using the
reasonable potential approach detailed in Ga. Comp. R. & Regs. 391-3-
6.-06(4)(d)5(ii), the permittee is required to monitor for cyanide for a
period of 10 months. Specifically, there are less than 10 data points (only
1 result of 18 µg/L for cyanide was reported in the permit application).
The resulting instream concentration of 5.83 µg/L (based on the 120 µg/L
result) is greater than half of the chronic cyanide criterion of 5.2 µg/L.
Thus, additional monitoring is required. If additional data has been
generated, the data should be made public and the Fact Sheet for the
permit should be updated describing the results of a reasonable potential
analysis for cyanide in the discharge.
The extent of the December 2018 joint sampling event between ORK
and the permittee was limited to parameters specifically included in the
2013 NPDES permit. Split sampling was thus not conducted for cyanide
nor is the permittee required to submit third -party data as part of the
NPDES permit application.
In addition to the cyanide sampling conducted in preparation for the
NPDES application, the permittee submitted additional results of a split
sampling analysis conducted in June 2019; whereas the sample results
were 22 µg/L and 26 µg/L with an average of the split sample results as
24 µg/L. Based on EPDs review and analysis, there is no reasonable
potential for the cyanide to cause or contribute to an instream violation
of Georgia Water Quality Standards, thus effluent limits have not been
included in the permit.
KAF notes that Georgia EPD has chosen to retain several water -quality
based effluent limitations that were proposed for Georgia EPD to
consider in Consent Decree 6:12-CV-00058 (the "Consent Decree")
settling litigation between KAF and the Ogeechee Riverkeeper (the
EPD has retained several water -quality based effluent limitations
originally proposed for consideration in Consent Decree 6:12-CV-
00058. Where such water -quality based effluent limitations were
included and retained, the limitations were considered to be an
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Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
"Riverkeeper") in 2013. Those limits include sulfide, TDS, and
ammonia at Tier 1 production levels and COD, sulfide, TDS, and
ammonia at Tier 2 and Tier 3 production levels. While KAF does not
object to Georgia EPD's selection of those specific permit limitations, the
company does not believe it is appropriate to use the Consent Decree as
the basis for those limits in this reissuance of the permit as is currently
stated. Specifically, KAF directs Georgia EPD's attention to footnote 2
on pages 30 and 31 of the permit rationale. The purpose of the Consent
Decree was to settle Clean Water Act violations that allegedly occurred
in 2011 and 2012. It was not to establish water -quality based effluent
limitations. Georgia EPD should reconsider the stated basis for those
current limits and rely on a basis that is legally supportable.
EPD RESPONSE
appropriate numeric translation to attain and maintain Georgia's
narrative water quality criteria and will fully protect the receiving
water's designated use. The proposed permit and basis for effluent limits
remains unchanged.
1. With specific regard to fecal coliform, as noted above, the draft permit
weakens the protections from the prior permit. The 2013 Milliken
permit included a concentration -based discharge limitation for fecal
coliform, which allowed a daily maximum discharge of 200 colonies
per 100 millimeters (200 cfu/100mL) and a 400 cfu/100mL daily
maximum. EPD's new proposed permit allows an increase of this
discharge, permitting for the months of May through October a daily
average of 500 cfu/100mL and a daily maximum of 500 cfu/100mL.
During the months between November and April, the permit allows
a daily average of 1,000 cfu/100mL and a daily maximum of 4,000
#/100mL. We object to this change in permit terms based upon the
anti -backsliding law.
Additionally, for water bodies where contact recreation activities are
anticipated to occur, the Georgia water quality standard provides that
fecal coliform are not to exceed a geometric mean of 200 cfu/100mL.
If it can be demonstrated that fecal coliform levels from non -human
The designated use for the Ogeechee River at the discharge location is
fishing/secondary contact recreation. Fecal coliform is the currently
approved bacterial indicator for the protection of secondary contact
recreation in and on the water. (GA R. & Regs. 391-3-6-.03(6)(c))
On September 25, 2015, the facility began operation of a septic tank
system under general permit GAG278093. All sanitary wastewater from
the facility was re -directed to the septic system, thereby eliminating
sanitary wastewater from the direct discharge to the Ogeechee River. On
October 9, 2015, a series of dye tests were performed confirming that
the sanitary wastewater was isolated from the discharge covered under
this permit. Furthermore, in July of 2017, Milliken conducted a
Quantitative Polymerase Chain Reaction (qPCR) DNA test which
indicated no human -based fecal coliform was detected while
simultaneously indicating that fecal coliform from non -human sources
exceeded 200 cfu/100mL.
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Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
sources exceed 200cfu/100mL occasionally (emphasis added), then
the allowable geometric mean for fecal coliform shall not exceed 500
cfu/100mL in free -flowing streams during the summer recreational
months (May to October). In July of 2017, Milliken conducted a
Quantitative Polymerase Chain Reaction (qPCR) DNA test to
determine the amount of human -based fecal coliform present in the
sample. The result of this single test was that no human -based fecal
coliform was detected. The amount of human -derived fecal coliform
in all other samples is unknown. One test should not be the basis for
this weakening of the permit. To demonstrate compliance with this
regulation, the permit should be modified to include additional qPCR
testing a minimum of monthly to demonstrate that the discharge
continues to contain no human -based fecal coliform counts.
Based on the permit application data, it further appears that the
summer standard of 500 cfu/100mL will also be consistently (not
occasionally) exceeded. Thus, EPD should establish a compliance
schedule requiring Milliken to identify and implement alternatives to
achieve the Georgia water quality standard of 500 cfu/100 mL as
daily maximum and daily average limitations. Without a compliance
schedule, the discharge is likely to continue to exceed the established
permit limitation without any clear date when the facility will be
compliant with the permit.
2. Fecal coliform is another issue. The plant has demonstrated its
inability to answer the question of why they violate this parameter so
frequently. It is past time to bring this facility into compliance on
fecal coliform. Reducing requirements on this parameter is
laughable, and yet Milliken/King America's request that EPD lower
effluent limitations is borne out in the draft permit put out for public
comment by the EPD.
EPD RESPONSE
The removal of sanitary wastewater has not eliminated fecal coliform
exceedances and there is a reasonable potential for the discharge to cause
or contribute to an instream violation of Georgia's Water Quality
Standards for fecal coliform. Historical data indicates that the levels of
fecal coliform in the discharge exceed not only the current effluent
limitations of 200 #/100mL daily average and 400 #/100mL daily
maximum, but also the seasonal effluent limitations included in the
proposed draft permit based on the contributions of non -human sources.
In response to exceedances of the effluent limitations in the current
permit, the permittee is required as part of Consent Order EPD-WP-
9076, issued May 05, 2021, to conduct an alternatives analysis regarding
treatment technology that will evaluate alternatives to allow the facility
to consistently meet fecal coliform effluent limitations while
simultaneously consistently meeting the effluent limitations for other
parameters in the NPDES Permit. Implementation of this condition
requires the permittee to meet the current fecal coliform effluent
limitations of 200 #/100mL daily average and 400#/100mL daily
maximum. Considering that the consent order requires the evaluation
and selection of treatment technologies to meet the 200 #/100mL daily
average and 400 #/100mL fecal coliform effluent limitations, it is no
longer justified to backslide through the inclusion of less stringent
effluent limitations. The proposed permit has been revised retaining the
current effluent limits of 200 #/100mL daily average and 400 #/100mL
daily maximum.
The permittee is expected to be in compliance with the effluent
limitations for fecal coliform upon the effective date of the permit.
Exceedances of the fecal coliform effluent limitations will be handled by
EPD's compliance office.
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Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
Additionally, as part of the 2019 Triennial Review process, EPD is
finalizing recommendations to replace fecal coliform and adopt
Escherichia coli (e. coli) and enterococci as pathogen indicators for
waters designated as fishing, coastal fishing, and drinking water. The
proposed criteria must be approved by the DNR Board and the US EPA
before they can take effect and be used in NPDES permits. In
anticipation of approval during the upcoming permit term, the permit
includes language which allows for the transition from fecal coliform
effluent limitations discussed above to year-round e. coli effluent
limitations of 126 #/100mL daily average (expressed as a geometric
mean) and 410 #/100mL daily maximum. The e. coli limitations were
calculated to yield the same gastrointestinal illness rate as the fecal
coliform limitations and therefore are equivalently protective of human
health and do not constitute backsliding.
KAF requests that the fecal coliform limitations be excluded from the
renewed permit, on the following basis:
Since sanitary sewage is no longer discharged to the wastewater treatment
plant to be treated, KAF no longer has any human or industrially -related
source of pathogens directed to the permitted outfall. This has been
confirmed through dye tests and analysis of the effluent for human gene
biomarkers.
Fecal coliform is the currently approved bacterial indicator for waters
designated as fishing and for the protection of secondary contact
recreation in and on the water. (GA R. & Regs. 391-3-6-.03(6)(c)) The
current Georgia water quality criteria for fecal coliform does not apply
specifically to human sources and the proposed criteria does not
distinguish between human and non -human sources at all, hence the
exclusion of sanitary wastewater is not a justifiable basis for the removal
of fecal coliform effluent limitations nor a guarantee that pathogens are
absent from the facility's discharge that may cause harm to humans
recreating in and on the water.
Review of the renewal application and all data submitted by the
permittee during the last permit term indicates a persistent and highly
variable presence of fecal coliform in the discharge which frequently
exceeds Georgia's instream water quality standards and current permit
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Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
limits. Fecal coliform bacterium are highly variable in the receiving
stream after treatment and dilution is not considered in EPD's reasonable
potential analysis as bacteria have the inherent ability to reproduce in the
receiving stream. WQBELs have been applied for fecal coliform based
on the facility's reasonable potential to cause or contribute to a violation
of Georgia's water quality criteria for fecal coliform.
EPD has also included provisions to replace the fecal coliform effluent
limitations with e. coli effluent limitations during the permit term subject
to EPA approval of the proposed changes to the Georgia Rules for Water
Quality Control, Chapter 391-3-6.03 (Water Use Classifications and
Water Quality Standards) for bacterial indicators. The transition to e. coli
is discussed in more detail in the above EPD Responses and in Sections
4.4 and 5.2 of the Fact Sheet.
KAF requests that the fecal coliform limitations be excluded from the
renewed permit, on the following basis:
The fecal coliform limitations in the current permit were originally added
based on a condition in the Consent Decree between KAF and the
Ogeechee Riverkeeper. The Consent Decree specifically states that its
conditions are not contingent upon the EPD's adoption any limitations,
and the Consent Decree in no way prohibits or discourages the Georgia
EPD from making modifications to any limits in future permits based on
new information.
Based on a review of the permitting files, EPD agrees that Consent
Decree 6:12-CV-00058 was the original basis for the fecal coliform
effluent limit. However, EPD is required to review the renewal
application and all data submitted by the permittee during the last permit
term. The data received indicates a persistent and highly variable
presence of fecal coliform in the discharge which frequently exceeds
Georgia's instream water quality standards. Fecal coliform bacterium are
highly variable in the receiving stream after treatment and dilution is not
considered in EPD's reasonable potential analysis as bacteria have the
inherent ability to reproduce in the receiving stream. WQBELs have
been applied for fecal coliform based on the facility's reasonable
potential to cause or contribute to a violation of Georgia's water quality
criteria for fecal coliform.
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Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
These effluent limitations are independent of the conditions established
in the consent decree (Civil Action No. 6:12-CV-00058) between King
America Finishing, Inc. and the Ogeechee-Canoochee Riverkeeper
signed on January 15, 2014.
EPD has also included provisions to replace the fecal coliform effluent
limitations with e. coli effluent limitations during the permit term subject
to EPA approval of the proposed changes to the Georgia Rules for Water
Quality Control, Chapter 391-3-6.03 (Water Use Classifications and
Water Quality Standards) for bacterial indicators. The transition to e. coli
is discussed in more detail in the above EPD Responses and in Sections
4.4 and 5.2 of the Fact Sheet.
KAF requests that the fecal coliform limitations be excluded from the
renewed permit, on the following basis:
Fecal coliform is common in water and soil due to wildlife. The KAF
wastewater facility, like all rural outdoor environments, is exposed to
wildlife, with alligators and waterfowl attracted to the ponds and other
treatment units. This wildlife is likely to contaminate the ponds and other
treatment units with fecal coliform, and these sources are outside of the
reasonable control of KAF.
Fecal coliform is the currently approved bacterial indicator for waters
designated as fishing and for the protection of secondary contact
recreation in and on the water. (GA R. & Regs. 391-3-6-.03(6)(c)) The
current Georgia water quality criteria for fecal coliform does not apply
specifically to human sources and the proposed criteria does not
distinguish between human and non -human sources at all, hence the
exclusion of sanitary wastewater is not a justifiable basis for the removal
of fecal coliform effluent limitations nor a guarantee that pathogens are
absent from the facility's discharge that may cause harm to humans
recreating in and on the water.
Furthermore, the permittee is required as part of Consent Order EPD-
WP-9076, issued May 05, 2021, to conduct an alternatives analysis
regarding treatment technology that will evaluate alternatives to allow
the facility to consistently meet fecal coliform effluent limitations while
simultaneously consistently meeting the effluent limitations for other
parameters in the NPDES Permit.
Page 24 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
EPD has also included provisions to replace the fecal coliform effluent
limitations with e. coli effluent limitations during the permit term subject
to EPA approval of the proposed changes to the Georgia Rules for Water
Quality Control, Chapter 391-3-6.03 (Water Use Classifications and
Water Quality Standards) for bacterial indicators. The transition to e. coli
is discussed in more detail in the above EPD Responses and in Sections
4.4 and 5.2 of the Fact Sheet.
KAF requests that the fecal coliform limitations be excluded from the
renewed permit, on the following basis:
The EPD has demonstrated that it has the freedom to use professional
judgement to exclude bacterial indicator limitations from NPDES
permits. In the 2016 Ogeechee River TMDL document (and other
TMDLs), the EPD states the following:
Municipal and industrial wastewater treatment facilities with the
potential for fecal coliform in their discharge are given end -of -pipe limits
to meet the applicable water quality standard. An exception is
constructed wetland systems, which have a natural level of fecal coliform
input from animals attracted to the artificial wetlands.
The Richmond Hill — Elbow Swamp Constructed Wetlands Facility is
specifically mentioned in this TMDL as a facility that qualifies for this
exclusion from bacterial indicator limitations, even though the Georgia
EPD is aware that Richmond Hill's effluent contains fecal coliform. KAF
requests that the same professional judgement be applied to the renewed
KAF permit.
The Total Maximum Daily Load Evaluation for Eight Stream Segments
in the Ogeechee River Basin for Fecal Coliform (2016) established
allowable pollutant loadings and other quantifiable parameters to return
the identified stream segments to supporting their designated use.
TMDLs are site -specific evaluations which consider wasteload
allocations (point sources) and load allocations (non -point sources)
within a watershed in order to determine a pollution reduction target.
This specific TMDL determined that point source discharges were not
the primary source of fecal coliform and that bacterial contributions from
the constructed wetland system did not require a wasteload allocation.
The lack of a wasteload allocation in a TMDL does not preclude the
inclusion of effluent limitations within an NPDES permit, nor do the
circumstances at the King America Finishing facility mirror that of the
example provided by the commenter.
Nonetheless, based on EPD's best professional judgement and
reasonable potential analysis, fecal coliform limitations have since been
applied at the final effluent following an upgrade of the Richmond Hill
— Elbow Swamp Constructed Wetlands Facility
Page 25 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
KAF requests that the fecal coliform limitations be excluded from the
Georgia EPD is not knowledgeable on how the state of South Carolina
renewed permit, on the following basis:
analyzes reasonable potential for bacteria and EPD does not determine
our RPA nor establish effluent limitations based on other state's
Other states have demonstrated flexibility with this issue Milliken has
determinations.
facilities in the State of South Carolina that have manufacturing processes
and wastewater treatment facilities like those at the KAF facility. When
the potential for effluent bacterial indicator limitations was considered,
the State of South Carolina allowed for two common-sense approaches at
these Milliken facilities:
i. At two facilities, sanitary sewage going to the wastewater treatment
plant was pre -disinfected and South Carolina required indicator
bacteria to be sampled at an internal outfall after the treatment.
Effluent sampling and limitations were not required.
ii. At one facility, sanitary sewage was segregated and pumped to a
POTW. The facility was considered to have no reasonable
potential going forward. Effluent sampling and limitations were
not required. KAF believes that the Georgia EPD has the same
flexibility regarding effluent bacterial indicator limitations.
KAF requests that the fecal coliform limitations be excluded from the
Effluent disinfection is an extremely common form of wastewater
renewed permit, on the following basis:
treatment with several demonstrated treatment technologies (e.g.,
chlorination, ozonation, ultraviolet radiation, microfiltration). The
No additional measures, outside of continuous effluent disinfection, can
permittee's concerns that the use of chemical disinfection could impact
be reasonably expected to prevent intermittent exceedances of the fecal
compliance with other permit terms and limitations and spills may result
coliform indicator bacteria. Effluent disinfection may require storage of
from the storage of hazardous chemicals have no legal basis for the
large quantities of hazardous materials, such as gaseous chlorine or
elimination of fecal coliform effluent limitations. Furthermore, the
bleach, only a few yards from a natural wetland and less than half a mile
permittee is required as part of Consent Order EPD-WP-9076, issued
Page 26 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
from the Ogeechee River. Chemical disinfection of the effluent would
also likely result in the discharge of additional salts, disinfection
byproducts, and toxicants. Such chemical disinfection of the discharge
could impact KAF's compliance with other permit terms and limitations.
Given the low risk associated with the natural sources of this bacteria, the
much higher risk from the storage and discharge of hazardous chemicals
is unwarranted.
EPD RESPONSE
May 05, 2021, to conduct an alternatives analysis regarding treatment
technology that will evaluate alternatives to allow the facility to
consistently meet fecal coliform effluent limitations while
simultaneously consistently meeting the effluent limitations for other
parameters in the NPDES Permit.
KAF requests that the fecal coliform limitations be excluded from the
renewed permit, on the following basis:
KAF expects that most other industrial wastewater treatment plants in the
State of Georgia are exposed to wildlife and have the same potential for
natural sources of fecal contamination. If the Georgia EPD establishes a
general policy that NPDES permits for these discharges must have
bacterial indicator monitoring and limitations, regardless of whether the
site has human or industrially -related sources of pathogens, this would
undoubtedly result in significant cost and an unnecessary burden for
industry in the State of Georgia, without providing a significant benefit
to the environment. KAF encourages the application of common-sense
approaches to this potential issue statewide, such as the sanitary sewage
segregation implemented at our facility.
EPD evaluates permits on a case -by -case basis and considers
information provided within the specific permit application and permit
compliance history. Fecal coliform is the currently approved bacterial
indicator for waters designated as fishing and for the protection of
secondary contact recreation in and on the water. (GA R. & Regs. 391-
3-6-.03(6)(c)) The facility's discharge has demonstrated the reasonable
potential cause or contribute to a violation of Georgia's water quality
criteria for fecal coliform thus effluent limitations are required.
Page 27 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
Anti -Backsliding Regulations / Removal of Monitoring Requirements
1. Section 402(o) of the CWA prohibits backsliding, or the reissuance of
a permit with "effluent limitations which are less stringent than the
comparable effluent limitations in the previous permit." 33 U.S.C. §
1342(o)(1). The draft permit reduces and/or eliminates certain permit
limits and also reduces and/or eliminates monitoring frequency for a
number of parameters of concern. We oppose any such backsliding in
the permit.
In 2013, EPD issued the current permit which set out certain limits
and conditions. These permit conditions were imposed to ensure that
the facility met the CWA and did not violate any applicable state
water quality laws. Presumably, EPD believed these permit terms and
conditions were necessary and appropriate to protect water quality in
the Ogeechee River. The draft permit, however, contains lower
effluent limitations for a number of parameters of concern including
fecal coliform, formaldehyde, total suspended solids (TSS), color,
total phenols, and total chromium. It also weakens monitoring
requirements for chemical oxygen demand (COD), TSS, total
phenols, total chromium, total Kjeldahl Nitrogen, total Nitrogen,
color, sodium, peroxide, total mercury, and sulfide.
Riverkeeper opposes all such instances of backsliding and requests
that EPD maintain or strengthen the permit terms and conditions as
they existed in the previous permit. We particularly believe that the
permit should not be weakened given that the permittee has failed to
meet the terms of the current permit as evidenced by the numerous
permit exceedances it has reported.
Reductions in monitoring frequency do not constitute backsliding as
defined in Section 402(o) of the CWA (33 U.S.C. § 1342(o)) and 40
C.F.R. § 122.44(1). Comments relating to the reduction of monitoring
frequencies have been addressed separately in this response to comments
document.
In general, the term "anti -backsliding" refers to the statutory and
regulatory provisions established at 33 U.S.C. § 1342(o) that prohibit
renewal, reissuance, or modification of an existing NPDES permit that
contains effluent limitations less stringent than those established in the
previous permit. There are, however; exceptions to this prohibition
established at 33 U.S.C. § 1342(o)(2) and at 33 U.S.C. § 1313(d)(4)
which allow for less stringent effluent limitations to be applied, provided
they comply with the "safety -clause" established at 33 U.S.C. §
1342(o)(3).
Less stringent effluent limitations have been applied for TSS, total
phenols, and chromium, total, and effluent limitations have been
removed for formaldehyde and color based on the allowable backsliding
exceptions. Section 5.3 of the fact sheet identifies the applicable
exception for each instance where less stringent effluent limitations or
monitoring have been applied. The implementation of such revised
limitations will not result in a violation of a water quality standard under
Section 303 of the CWA (33 U.S.C. § 1313) applicable to such waters.
The legal rationale for allowing instances of backsliding is already
addressed at length in the draft permit's fact sheet, but EPD has provided
Page 28 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
2. Less than a decade ago the facility was responsible for a massive fish
kill which decimated wildlife in the Ogeechee River and endangered
the public health of nearby communities and homes. Now you want
to loosen regulations when due to the facility's history of negligence
regulations should be stricter.
Testing and discharge mitigation efforts should be strengthened and
enforced for all hazardous chemicals in use at the King America
Finishing Plant.
3. Despite the fact that the present owner of the facility, Milliken &
Company, has repeatedly violated the existing permit, this draft
permit proposes eliminating the testing of serious parameters and
constituents, including formaldehyde and the flame retardant THPC.
EPD RESPONSE
additional narrative regarding formaldehyde in this response to
comments as it was specifically identified by several commenters.
Georgia does not have an instream numeric water quality criterion for
formaldehyde nor does US EPA have a national recommended water
quality criterion. Consistent with EPD's NPDES Reasonable Potential
Procedures (2003), where numeric criteria have not been established
whole effluent biomonitoring may be used to develop a whole effluent
toxicity (WET) limit. This approach is necessary and appropriate for the
protection of Georgia water quality criteria in accordance with GA.
Comp. R. & Regs. 391-3-6-.03(5)(e). Whole effluent toxicity testing is
thus more suitable to identify any toxicity exhibited by formaldehyde in
the effluent and provides the added benefit of identifying any potential
additive and synergistic effects on the effluent as a whole. Additionally,
historical formaldehyde analytical results have shown considerable
issues with quality control and quality assurance as well as matrix
interference due to the co -extraction of other matrix contaminants. Such
issues can cause false positive results, overreporting of formaldehyde
concentrations, and overall analysis accuracy issues which limit the
suitability of formaldehyde sampling for the determination of aquatic
toxicity.
Commenters have additionally expressed concerns related to the
removal of monitoring requirements for THPC, sodium, and peroxide in
the effluent. THPC, sodium, and peroxide do not have numeric water
quality criteria with which to conduct a reasonable potential analysis
against, and as previously discussed above, effluent WET testing is the
appropriate compliance standard to ensure the protection of Georgia
water quality criteria.
Page 29 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
Similarly, the instream monitoring requirements for formaldehyde,
sodium, peroxide, and sulfide were removed as there are no numeric
water quality criteria with which to compare the instream data against to
determine whether the receiving waterbody is supporting its designated
use.
Whole Effluent Toxicity
1. Due to the past fish kill and continued permit violations, any new
permit should be more strict on toxicity.
Milliken has continually failed to meet EPA standards, with 12
violations in the last 12 quarters. Failure to meet standards is not an
argument for lowering those standards. Any new permit should be
stricter on toxicity limits.
In May of 2011, the Ogeechee River experienced one of the largest
fish kills in our state's history. 38,00+/- fish were killed along with
alligators, turtles, and birds over a 77-mile stretch of the river. This
trail of devastation began in Screven County, just downstream of the
discharge pipe of a textile treatment facility — King America Finishing
(KAF), Inc., now Milliken. Ogeechee Riverkeeper (ORK) sued KAF
in 2012 for violations of the Clean Water Act. The settlement
agreement put in place comprehensive and stringent environmental
protections.
2. Considering the plant's recent track record on ongoing toxicity issues
and continued multiple permit violations, as well as the plant's history
The current permit requires WET testing at the frequencies listed below.
Based on the submitted WET testing results from December 2013 — May
2021, the number of tests and percentage of violations have been
summarized below.
Effluent Data
Instream Data
Acute WET
Chronic WET
Acute WET
Chronic WET
C. dubia
2/Week
# of Tests 912
# of Viol. 15
Viol. 1.64
P. Promelas
1/Year
11
1
9.09
C. dubia
1/Month
124
4
3.23
P. Promelas
1/Year
11
0
0
C. dubia
1/Month
131
0
0
P. Promelas
1/Year
8
0
0
C. dubia
1/Month
119
4
3.36
Instream acute toxicity has not been detected for ceriodaphnia dubia as
part of the historical WET testing. However, in consideration of the
commentors concerns and the periodic toxicity exhibited in the effluent,
EPD has returned the monitoring frequency for acute ceriodaphnia
dubia WET testing to once per month.
Page 30 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
of the disastrous fish kill in 2011, any new permit should be more
strict on toxicity.
The company should be made to upgrade its wastewater treatment
operation further until it can consistently pass its WET testing.
As you know, the toxicity of the effluent has been the Riverkeeper's
primary concern since the fish kill, which was itself the result of a toxic
discharge event. Since the last permit iteration, both the company and
Riverkeeper have conducted toxicity sampling and both the company's
and the Riverkeeper's sampling results have identified toxicity as an
ongoing concern. Although a significant number of chronic toxicity tests
have been either at the permit limit or have violated the limit, the draft
permit has maintained the monitoring frequency for whole effluent
testing established in the prior permit. Further, many of the testing
frequency reductions have been justified because of ongoing aquatic
toxicity testing; however, the permit does not increase this toxicity testing
to ensure compliance. We believe that the frequency of the toxicity
sampling must be increased as further explained below.
Given the high variability exhibited in the chronic tests and the number
of periodic violations, we believe chronic toxicity testing must occur
weekly. We agree and support the change to the permit that requires that
if two test results violate the limit of > 8% effluent or are acutely toxic
(LC50<100%), a toxicity identification and reduction evaluation (TI/RE)
be implemented in accordance with federal Environmental Protection
Agency ("EPA") guidance. The initiation of a TI/RE should require the
development of a compliance schedule. This schedule should establish
milestones to identify the toxicants, develop and identify alternatives to
Historical WET testing does not demonstrate a distinguishable trend of
the effluent becoming more toxic overtime nor are there indicators that
toxicity has been experienced instream which has not been identified
through effluent WET testing. Hence, the proposed monitoring
frequency of monthly for chronic toxicity testing for the water flea is
sufficient to identify toxicity in the effluent. Additionally, due to the fact
that the NOEC is limited to the concentrations tested, the coefficient of
variation is limited by the selected dilution series and is subject to
uncertainty.
The commentor has also raised concerns over the selection of the
dilution series for the chronic WET testing as well as the lack of IC25
reporting. As is noted by the commentor, the NOEC is the state of
Georgia's metric for determining compliance with WET requirements,
not the IC25. To provide additional transparency regarding WET testing
results, EPD has required the IC25 to be reported to supplement the
NOEC. EPD has additionally evaluated the selected dilution series for
the chronic WET testing and has established in the permit a defined
dilution series of Control, 2%, 4%, 8%, 16%, 32%, 64%, 100%. The
revised dilution series includes two additional test concentrations to
provide a more precise concentration -response relationship near the
IWC using a modified 0.5 dilution factor in order to increase the
precision of effect concentrations estimated from those relationships.
Page 31 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
remove the toxicants, and bring the facility back into compliance with the
permit limit.
This request to increase chronic toxicity testing for the water flea,
Ceriodaphnia dubia, to weekly is based on the following:
• The effluent has been observed to be chronically toxic and has
become more toxic over time;
• The effluent exhibits substantial variability (coefficient of
variation of 60%);
• The discharge has experienced long periods of time where the
discharge NOEC (No Observed Effect Concentration) was at the
limit of 8% effluent, and
• For tests in which inhibition concentration (IC25) data are
available, the tests predict effects on reproduction at or near the
instream waste concentrations
The facility has been required to analyze for chronic toxicity at a
frequency of monthly since 2013 using Ceriodaphnia dubia. The
limitation for chronic toxicity is established as a NOEC of >8%. This is
approximately the instream waste concentration under fully mixed 7Q10
flow conditions. As a result, nearly the entire river flow is allocated to
the facility for dilution prior to determining compliance.
The 25% inhibition concentration (IC25) should be used as the point
estimate for chronic toxicity; however, this value was not available in the
Pre -Draft permit document. Because the NOEC is a function of the
dilution series used, the results do not reflect the true variability of the
effluent. Additionally, the NOEC determination is influenced by the
variability of the testing, which can mask both toxic and non -toxic
samples. The IC25 is independent of test sensitivity and is therefore a
EPD RESPONSE
The modified dilution series has been included to increase confidence in
results near the IWC at the expense of losing precision when the NOEC
lies within the 32% - 100% range. The modified dilution series will also
negatively impact the ability to accurately compare historical WET
results with those obtained moving forward.
The draft permit placed on public notice also included stricter toxicity
requirements by including a special condition, at Part III.C.3.e for the
permittee to perform a TIE/TRE in the event that two WET tests are
failed. The proposed permit goes further and includes revisions to the
TIE/TRE special conditions requiring more explicit obligations within
the TIE/TRE process and where applicable; establishes a schedule for
the completion of such obligations
Page 32 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
better indication of actual sample toxicity. However, the test reports
identified above were reviewed to determine the dilution series utilized.
From this review, the dilution series for chronic aquatic toxicity testing
is 100%, 80%, 65%, 50%, 25%, 8% and 6.25%. Although the
compliance limit of 8% is bracketed, typically the critical concentration
(>8% effluent) is bracketed by 2 concentrations both above and below
8%. This was not the case for the tests reviewed as most tests only had
one exposure concentration less than 8% effluent.
Assuming a similar dilution series was used for all of the tests, the data
indicate that the effluent is highly variable with NOEC values ranging
from a low of 5% effluent to a high of 84% effluent. For the most toxic
test result collected in December 2018 (NOEC = 5% effluent), ORK
collected and split a sample with Milliken. The ORK test indicated that
the lowest observable effect concentration was 10% effluent and the IC25
was 10.6% effluent. The test run by Milliken reported that the NOEC
was less than the lowest concentration tested (6.25% effluent).
In the review of the May 2018 test report, it was noted that reproduction
levels in both the 6.25% and 25% exposure concentrations were
significantly different than the control while the 8% concentration was
not significantly different. The report states that the NOEC is 8% for this
test period. This scenario would be classified as a non -significant effect
bracketed by significant effects (response 6 in the USEPA guidance
(2002)). As such, the test would be considered valid and the NOEC
should be reported as the concentration below the LOEC of 6.25%. Thus,
the NOEC should have been reported as <6.25% effluent, not 8% as
reported.
The available data illustrate the following:
Page 33 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
• Since 12/12/2013 (and including the May 2018 report), there have
been 4 permit limit violations of the chronic toxicity limitation (1
each in 2013 and 2014 and 2 in 2018)
• There is a high degree of variability in the data. Effluent NOEC
values range from a low of 5% effluent (collected in December
2018) to a high of 84%. The calculated average of the NOEC
values is 40% and the data exhibit a coefficient of variation of
60%.
• Between November 2017 and June 2018 (8 tests), the NOEC
value was reported as 8% effluent for 7 of the tests.
• For the available data (94 tests plus 1 duplicate), there were 20
tests with results reported as NOEC of 8% or less. Note, for the
duplicate test, that both tests indicated that the NOEC was below
8% effluent.
As noted above, there is extensive variability in the reported NOEC
values. To determine if there are any data trends, the quarterly average
NOEC value was calculated for the available dataset. Again, the lack of
an IC25 value limits data interpretation; however, assuming that the test
concentration series has not changed, the data indicate that the effluent
has become more toxic over time.
During the period from November 2017 to June 2018 in which the NOEC
was consistently reported at 8% (with the exception of January 2018),
variability equivalent to that observed for the period of record would be
expected; thus, it is likely that actual toxicity varied around 8% effluent
—both above and below. This variability was not captured by the monthly
data. Thus, we believe that chronic aquatic toxicity testing should be
increased to weekly to understand the impact of the discharge on the
Ogeechee River. Further, the fact that the endangered native Robust
Redhorse fish has failed to establish a population downstream of the
Page 34 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
facilities effluent after restocking indicates that conditions are not ideal.
Finally, in addition to reporting the NOEC, the permittee should also be
required to report the chronic IC25 so that a better understanding of the
effluent variability can be obtained and the potential for instream impact
can be assessed. In summary, therefore, we support: weekly testing to
ensure compliance given reduced chemical monitoring; NOEC reporting
(because this is the state standard); and IC25 reporting because this is a
superior metric.
We understand that the permittee will resist this increased testing and
argue that other facilities in the state are not subject to similar testing
requirements. But this facility is very different from other industrial
dischargers in the state. The historical data and the history of the largest
fish kill in the state justify whatever marginal additional cost this entails
because of the importance of this issue.
Part III.C.3.e of the draft permit, on page 28, contains a condition that
requires the facility to complete both a Toxicity Identification Evaluation
(TIE) and Toxicity Reduction Evaluation (TRE) after two WET test
failures. Although KAF acknowledges the usefulness of the TIE and TRE
protocols in some situations, we object to this requirement as it is written,
because it may require the permittee to take actions under certain
circumstances that are not possible or that serve no useful purpose. For
example, toxicity failures at KAF have been infrequent, and when they
have occurred, the elevated toxicity was not persistent over time. When
toxicity is not persistent, execution of a TIE is impractical, as it is
impossible to collect a representative sample on which to perform the
identification activities. As the permit condition is written, KAF would
be required to complete the TIE protocol regardless of the availability of
toxic effluent. A TIE performed under these circumstances would yield
The historical results of the facility's whole effluent toxicity testing have
shown intermittent toxicity issues which have yet to be successfully
eliminated. To address toxicity, a special condition has been included at
Part III.C.3.e for the permittee to perform a TIE/TRE in the event that
two WET tests are failed. EPD has revised the TIE/TRE special
condition to provide more explicit obligations within the TIE/TRE
process and where applicable; to establish a schedule for the completion
of such obligations.
Page 35 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
no useful information to the permittee or Georgia EPD. In addition, in
some cases, the cause of toxicity in the effluent can be quickly and readily
identified without the need for a TIE. Examples would include toxicity
that corresponds to a wastewater treatment facility upset or an inadvertent
chemical release to the wastewater treatment facility. Under these
circumstances, the Toxicity Reduction Evaluation (TRE) activities can be
initiated immediately with no need for a TIE. KAF suggests that this
condition be modified in the following ways to prevent conditions that
require actions that are not possible or that serve no useful purpose:
a. Require the TIE/TRE only under conditions that suggest persistent
toxicity, such as the failure of consecutive toxicity samples.
b. Add language that explicitly allows for the discretion of a Professional
Engineer and the Georgia EPD in determining whether TIE activities
are necessary. For example, the permit could require submittal to the
Georgia EPD of a Corrective Action Plan, prepared by a Professional
Engineer, that considers the usefulness and practicality of the TIE
methodology in addressing the causes of the persistent toxicity.
Instream Monitoring
ORK requests that downstream samples be collected in a manner that
ensures samples are collected within the discharge plume, are
representative of downstream conditions, and allow the calculation of
percent effluent in the sample. Currently, the draft permit requires only
measurement of conductivity and collection of a sample at any location
within 25 feet of the discharge pipe. The data will be utilized by EPD to
determine if the downstream sampling is representative of sampling
The permit at Part I.A.4 includes a downstream sampling point identified
as 25 feet downstream of the discharge and 38 feet from the left
riverbank. This location was identified through water quality modeling
as the assumed center of the effluent plume. Conductivity sampling was
also included to confirm that the downstream sampling location is
representative of the effluent plume within the Ogeechee River.
Page 36 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
within the effluent plume. While we agree with the objective of the
requirement, ORK believes that the requirement is too vague.
Specifically, the language only requires Milliken to monitor the
conductivity of the sample but does not require Milliken to locate the
effluent plume and then sample directly from the plume. Given that there
is over an order of magnitude difference in receiving water and Milliken
effluent conductivity, location and identification of the plume based on
conductivity alone is possible.
Part I A.4 of the permit requires the permittee to collect a sample 25 feet
downstream of the outfall pipe for aquatic toxicity testing. Depending on
stream flow conditions, this results in a highly variable sample. We
understand that this sampling location was selected to monitor actual
instream conditions associated with the effluent discharge. However,
based on a limited review of sampling data, the collection of a sample
which contains a representative concentration of the effluent is often a hit
or miss proposition. For example, the May 2018 receiving water toxicity
test was conducted with a downstream sample which contained
essentially no effluent. The Ogeechee River flow for this sample period
was less than the harmonic mean flow for which Milliken modeled
expected effluent concentrations downstream of the discharge.
This data indicates that none of the downstream samples contained
effluent from the Milliken discharge. Specifically, the samples collected
25 feet downstream of the outfall were more representative of upstream
conditions than downstream. Further, based on modeling conducted by
Milliken, samples collected within the discharge plume 25 feet
downstream of the discharge should have had conductivity of between
249 and 309 µmhos/cm under harmonic mean flow conditions. In
contrast, the downstream samples used for testing contained only one-
EPD RESPONSE
Outside of the scope of the permit issuance, the permittee has also been
required as part of Consent Order EPD-WP-9076, issued May 05, 2021,
to demonstrate that the downstream sampling location is within the
effluent plume under variable effluent and river flow conditions and if
necessary, recommend adjustments to the sampling methodology where
feasible. The demonstration will include, but not be limited to, a
modeling analysis that evaluates expected conductivity at the
downstream sampling location based on the historical effluent data and
stream flows compared to historical actual conductivity readings at the
downstream location.
Under Part I.A.4 of the permit, EPD may review and approve an alternate
downstream sampling location should data indicate that the current
location is not representative of the effluent plume within the Ogeechee
River.
Page 37 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
EPD RESPONSE
third of the conductivity and were representative of upstream conditions,
not downstream discharge conditions.
To remedy this situation, we recommend the following improvements in
sampling methodology:
• Prior to collecting the downstream sample, the sampler shall
conduct a conductivity survey of the cross-section of the receiving
stream at a point 25 feet downstream of the outfall. The objective
of the survey is to identify the location of the effluent plume. The
survey shall be conducted from top to bottom and from bank to
bank at representative intervals across the stream.
• Once the location of the plume has been identified, the sampler
shall collect a vertically proportional sample; specifically, the
sample shall be collected representative of the bottom third,
middle third and top third of the receiving stream within the
discharge plume.
• Based on upstream and effluent conductivity values, the percent
effluent in the sample shall be calculated.
The reasonable potential analysis for various parameters assumes rapid
and complete dilution with the entire river flow to determine instream
concentrations. This presumes a mixing zone of unspecified and
unlimited size, without designating or physically defining a mixing zone.
Clearly, based on the downstream monitoring that has been conducted,
the mixing is neither rapid nor complete. Had complete mixing been
rapidly achieved, conductivity measurements for the May 2018 sampling
GA R. & Regs. at 391-3-6-.03(10) state that the use of a reasonable and
limited mixing zone may be permitted on receipt of satisfactory evidence
that such a zone is necessary and that it will not create an objectionable
or damaging pollution condition. EPD may establish a mixing zone
where the use of the dilution factor equations defined at GA R. & Regs.
at 391-3-6-.06(2)(f) are inapplicable and it is deemed necessary to define
such a zone within which certain water quality criteria may be exceeded.
Page 38 of 39

Public Comments and EPD Responses on Draft NPDES Permit
King America Finishing, Inc. — Permit No. GA0003280
COMMENT RECEIVED
event discussed above would have ranged between 158 and 182
µmhos/cm not 99-109 as reported by Milliken Further, assuming
complete mixing and providing the entire river flow for dilution, when
this is not the case, allows for areas where water quality criteria are
exceeded. Without delineation of the size of the mixing zone, the impact
of the discharge on the receiving stream is unknown. Georgia regulations
allow for properly identified and circumscribed mixing zones, but only
with limitations and restrictions that have not been met or addressed.
EPD RESPONSE
EPD's dilution factor equations assume a relatively rapid and complex
mix. US EPA guidance generally describes rapid and complete mixing
as mixing which occurs when the lateral variation in the concentration
of a pollutant in the direct vicinity of the outfall is small (US EPA's
NPDES Permit Writers' Manual, EPA-833-K-10-001 (Sept. 2010) at
Sec. 6.2.5.1, p. 6-20) The facility's outfall is equipped with a diffuser
which facilitates mixing and minimizes lateral variation in the
concentration of a pollutant in the direct vicinity of the outfall. CORMIX
modeling provided with the permit application indicates that based on
available near -field mixing, it is unnecessary to define a mixing zone
within which certain water quality criteria would be exceeded.
Page 39 of 39

GEORGIA
myDEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Mr. Gary Newman, Plant Manager
King America Finishing, Inc.
1351 Scarboro Hwy
Sylvania, Georgia 30467
Dear Mr. Newman:
Richard E. Dunn, Director
EPD Director's Office
2 Martin Luther King, Jr. Drive
Suite 1456, East Tower
Atlanta, Georgia 30334
404-656-4713
02/25/2022
RE: Permit Issuance
King America Finishing, Inc.
NPDES Permit No. GA0003280
Screven County, Ogeechee River Basin
Pursuant to the Georgia Water Quality Control Act, as amended, the Federal Clean Water Act, as
amended, and the Rules and Regulations promulgated thereunder, we have issued the attached permit for
the above -referenced facility.
Your facility has been assigned to the following EPD office for reporting and compliance.
Signed copies of all required reports shall be submitted to the following address:
Environmental Protection Division
Coastal District Office
400 Commerce Center Drive
Brunswick, Georgia 31523-8251
Please be advised that on and after the effective date indicated in the permit, the permittee must
comply with all terms, conditions, and limitations of the permit. If you have questions concerning this
correspondence, please contact Ian McDowell at 470.604.9483 or [e-mail].
Sincerely,
Richard E. Dunn
Director
RED:im
Enclosure(s)
cc: EPD Coastal District (Brunswick) Compliance Office — Michelle Dennis (e-mail)
EPD Watershed Planning and Monitoring Program — Josh Welte (e-mail)
EPD Watershed Planning and Monitoring Program — Tyler Parsons (e-mail)
Milliken & Company, Corporate Env. Dept. — Lee Slusher ([e-mail])
E-mail to EPA Region 4 mailbox: [e-mail]

Permit No. GA0003280
Issuance Date: 02/25/2022
..� GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
National Pollutant Discharge Elimination System Permit
In accordance with the provisions of the Georgia Water Quality Control Act (Georgia Laws 1964,
p. 416, as amended), hereinafter called the State Act; the Federal Water Pollution Control Act, as
amended (33 U.S. C. 1251 et seq.), hereinafter called the Federal Act; and the Rules and
Regulations promulgated pursuant to each of these Acts,
King America Finishing, Inc.
1351 Scarboro Highway
Sylvania, Georgia 30467
is issued a permit to discharge from a facility located at
1351 Scarboro Highway
Sylvania, Georgia 30467
Screven County
to receiving waters
the Ogeechee River (Outfall 001) in the Ogeechee River Basin.
in accordance with effluent limitations, monitoring requirements and other conditions set forth in
the permit.
This permit is issued in reliance upon the permit application signed on April 18, 2018, any other
applications upon which this permit is based, supporting data entered therein or attached thereto,
and any subsequent submittal of supporting data.
This permit shall become effective on April 01, 2022.
This permit and the authorization to discharge shall expire at midnight March 31, 2027.
d,(
Richard E. Dunn, Director
Environmental Protection Division

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
PART I
A.1. Effluent Limitations and Monitoring Requirements
Tier 1 (Average Production of Plant 1 <_ 97,9391bs/day)(1)
Page 2 of 32
Permit No. GA0003280
During the period specified on the first page of this permit, the permittee is authorized to discharge
from outfall number 001(2) (32.594658, -81.747894) — Process Water, Cooling Water, and
Stormwater.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent
Characteristics
(Units)
Discharge
Limitations
Monitoring
Requirements(3)
Mass Based
(lbs/day)
Concentration
Based (mg/L)
Measurement
Frequency
Sample
Type
Sample
Location
Daily
Avg.
Daily
Max.
Daily
Avg.
Daily
Max.
Flow (MGD)(4)
3.1
Report
--
--
Daily
Continuous
Final
Effluent
Temperature (°F)
--
See
Note 6�
--
--
See Note(s)
See Note(s)
Final
Effluent
Dissolved Oxygen
--
--
--
See
Note(6)
See Note(6)
See Note(6)
Final
Effluent
BOD5
323
646
30
60
5/Week
Composite
Final
Effluent
COD
5,328
10,656
Report
Report
5/Week
Composite
Final
Effluent
TSS
650
1,160
Report
Report
1/Week
Composite
Final
Effluent
Sulfide
9.8
19.6
1.5
3.0
3/Week
Grab
Final
Effluent
TDS
--
--
2,500
3,800
5/Week
Composite
Final
Effluent
Total Phenols
4.9
9.8
Report
Report
Once Every
Two Months
Grab
Final
Effluent
Mercury, Total (ng/L)
--
--
See
Note(7)
See
Note(?)
2/Year
Grab
See
Note(7)
Chromium, Total
4.9
9.8
Report
Report
Once Every
Two Months
Composite
Final
Effluent
Ammonia, as N(8)
181
336
7
13
Daily
Composite
Final
Effluent
Total Kjeldahl
Nitrogen(8)
--
--
Report
Report
1/Month
Composite
Final
Effluent

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 3 of 32
Permit No. GA0003280
Effluent
Characteristics
(Units)
Discharge
Limitations
Monitoring
Requirements(3)
Mass Based
(lbs/day)
Concentration
Based (mg/L)
Measurement
Frequency
Sample
Type
Sample
Location
Daily
Avg.
Daily
Max.
Daily
Avg.
Daily
Max.
Organic Nitrogen(8)
--
--
Report
Report
1/Month
Composite
Final
Effluent
Nitrate/Nitrite)
--
--
Report
Report
1/Month
Composite
Final
Effluent
Total Nitrogen(8)
--
--
Report
Report
1/Month
Calculation
Final
Effluent
Total Phosphorus, as
p(9)
--
--
Report
Report
3/Week
Composite
Final
Effluent
Orthophosphate, as P(9)
--
--
Report
Report
1/Month
Composite
Final
Effluent
Specific Conductance
(µmhos/cm)
--
--
Report
Report
Daily
Continuous
Final
Effluent
Color
(ADMI color value)
--
--
Report
Report
1/Week
Grab
Final
Effluent
Fecal Coliform(1°)(11)
(#/100mL)
--
--
200
400
1/Week
Grab
Final
Effluent
Escherichia Coli(1°)(11)
(#/100mL)
--
--
126
410
1/Week
Grab
Final
Effluent
Acute Whole
Effluent Toxicity(12)
(Ceriodaphnia dubia)
LCso
>100%
Effluent
--
--
--
2/Week
Composite
Final
Effluent
Acute Whole
Effluent Toxicity(12)
(Pimephales promelas)
LCso >
100%
Effluent
--
--
--
1/Year
Composite
Final
Effluent
Chronic Whole
Effluent Toxicity(12)
(Ceriodaphnia dubia)
NOEC
> 8%
Effluent
--
--
--
1/Month
Composite
Final
Effluent
Chronic Whole
Effluent Toxicity(12)
(Pimephales promelas)
NOEC
> 8%
Effluent
--
--
--
1/Year
Composite
Final
Effluent
The pH of the final effluent shall be continuously monitored and recorded. The continuous monitoring
system shall have an alarm system that warns that the pH is approaching effluent limits. In addition to
continuous monitoring, the pH of the final effluent shall be monitored by analyzing grab samples once
per day, five days per week. The pH of the final effluent shall not be less than 6.0 standard units or
greater than 8.0 standard units. The monthly minimum and maximum pH from each method shall be
reported.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
Page 4 of 32
Permit No. GA0003280
The effluent limitations and monitoring requirements established in Part I.A.1 of this permit are
effective for Plant 1 monthly average production levels up to 97,939 lbs of product per day. The
average daily production (lbs of product/day) for the month shall be reported with the monthly
discharge monitoring report in accordance with the reporting requirements in Part 1.D of this permit.
There shall be no discharge of floating solids or visible foam other than trace amounts.
All the parameters must be monitored, at a minimum, at the measurement frequency stated above if
there is any discharge. If there is no discharge, state such in the discharge monitoring report in
accordance with the reporting requirements in Part 1.D of this permit.
See Special Conditions, Part III.C.1 of this permit.
The temperature of the final effluent shall be continuously monitored. In addition to continuous
monitoring, the temperature of the final effluent shall be separately monitored once per day by a grab
sample, five days per week. The monthly minimum and maximum temperature from each method
shall be reported.
The dissolved oxygen concentration in the final effluent shall be continuously monitored. In addition
to continuous monitoring, the dissolved oxygen concentration of the final effluent shall be separately
monitored once per day by a grab sample, five days per week. The dissolved oxygen concentration in
the final effluent shall be 5.0 mg/L or higher at all times. The monthly minimum dissolved oxygen
concentration from each method shall be reported.
The concentration of mercury in the final effluent shall not exceed 6.0 ng/L or a concentration equal
to the concentration of mercury in the source water; whichever is greater. The permittee shall
concurrently monitor the final effluent and source water using EPA Method 1631E to quantify the
amount of mercury present in each. The detection limit for this method shall be no higher than 0.5
ng/L.
Ammonia, as N; total Kjeldahl nitrogen; organic nitrogen; nitrate/nitrite; and total nitrogen shall be
analyzed or calculated from the same effluent sample on the same day.
(9) Total phosphorus and orthophosphate shall be analyzed from the same effluent sample on the same
day.
(10)
Fecal coliform and escherichia coli bacteria shall be reported as the geometric mean of the values for
samples collected during the month.
The permittee is subject to the effluent limitations and monitoring requirements for fecal coliform
from the effective date of the permit and continuing until EPD provides written authorization to the
permittee subjecting the permittee to the effluent limitations and monitoring requirements for
escherichia coli.
(12) See Special Conditions, Part III.C.3 of this permit.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
A.2. Effluent Limitations and Monitoring Requirements
Tier 2 (97,939 < Average Production of Plant 1 <_ 111,8491bs/day)(1)
Page 5 of 32
Permit No. GA0003280
During the period specified on the first page of this permit, the permittee is authorized to discharge
from outfall number 001(2) (32.594658, -81.747894) — Process Water, Cooling Water, and
Stormwater.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent
Characteristics
(Units)
Discharge
Limitations
Monitoring
Requirements(3)
Mass Based
(lbs/day)
Concentration
Based (mg/L)
Measurement
Frequency
Sample
Type
Sample
Location
Daily
Avg.
Daily
Max.
Daily
Avg.
Daily
Max.
Flow (MGD)(4)
3.1
Report
--
--
Daily
Continuous
Final
Effluent
Temperature (°F)
--
See
Note 6�
--
--
See Note(s)
See Note(s)
Final
Effluent
Dissolved Oxygen
--
--
--
See
Note(6)
See Note(6)
See Note(6)
Final
Effluent
BOD5
369
738
30
60
5/Week
Composite
Final
Effluent
COD
5,500
11,000
Report
Report
5/Week
Composite
Final
Effluent
TSS
650
1,160
Report
Report
1/Week
Composite
Final
Effluent
Sulfide
11.2
22.4
1.5
3.0
3/Week
Grab
Final
Effluent
TDS
--
--
2,500
3,800
5/Week
Composite
Final
Effluent
Total Phenols
5.6
11.2
Report
Report
Once Every
Two Months
Grab
Final
Effluent
Mercury, Total (ng/L)
--
--
See
Note(7)
See
Note(?)
2/Year
Grab
See
Note(7)
Chromium, Total
5.6
11.2
Report
Report
Once Every
Two Months
Composite
Final
Effluent
Ammonia, as N(8)
181
336
7
13
Daily
Composite
Final
Effluent
Total Kjeldahl
Nitrogen
--
--
Report
Report
1 /Month
Composite
Final
Effluent
Organic Nitrogen(8)
--
--
Report
Report
1/Month
Composite
Final
Effluent

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 6 of 32
Permit No. GA0003280
Effluent
Characteristics
(Units)
Discharge
Limitations
Monitoring
Requirements(3)
Mass Based
(lbs/day)
Concentration
Based (mg/L)
Measurement
Frequency
Sample
Type
Sample
Location
Daily
Avg.
Daily
Max.
Daily
Avg.
Daily
Max.
Nitrate/Nitrite)
--
--
Report
Report
1/Month
Composite
Final
Effluent
Total Nitrogen(8)
--
--
Report
Report
1/Month
Calculation
Final
Effluent
Total Phosphorus, as
p(9)
--
--
Report
Report
3/Week
Composite
Final
Effluent
Orthophosphate, as P(9)
--
--
Report
Report
1/Month
Composite
Final
Effluent
Specific Conductance
(pathos/cm)
--
--
Report
Report
Daily
Continuous
Final
Effluent
Color
(ADMI color value)
--
--
Report
Report
1/Week
Grab
Final
Effluent
Fecal Coliform(10)(11)
(#/100mL)
--
--
200
400
1/Week
Grab
Final
Effluent
Escherichia Coli(io)(")
(#/100mL)
--
--
126
410
1/Week
Grab
Final
Effluent
Acute Whole
Effluent Toxicity(2
(Ceriodaphnia dubia)
LCso
>100%
Effluent
--
--
--
2/Week
Composite
Final
Effluent
Acute Whole
Effluent Toxicity(12
(Pimephales promelas)
LCso >
100%
Effluent
--
--
--
1/Year
Composite
Final
Effluent
Chronic Whole
Effluent Toxicity(12)
(Ceriodaphnia dubia)
NOEC
> 8%
Effluent
--
--
--
1/Month
Composite
Final
Effluent
Chronic Whole
Effluent Toxicity(12)
(Pimephales promelas)
NOEC
> 8%
Effluent
--
--
--
1/Year
Composite
Final
Effluent
The pH of the final effluent shall be continuously monitored and recorded. The continuous monitoring
system shall have an alarm system that warns that the pH is approaching effluent limits. In addition to
continuous monitoring, the pH of the final effluent shall be monitored by analyzing grab samples once
per day, five days per week. The pH of the final effluent shall not be less than 6.0 standard units or
greater than 8.0 standard units. The monthly minimum and maximum pH from each method shall be
reported.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
Page 7 of 32
Permit No. GA0003280
The effluent limitations and monitoring requirements established in Part I.A.1 of this permit are
effective for Plant 1 monthly average production levels greater than 97,939 lbs of product per day but
less than 111,849 lbs of product per day, provided that the permittee has notified EPD of an increase
in production in accordance with Part III.C.5 of this permit. The average daily production (lbs of
product/day) for the month shall be reported with the monthly discharge monitoring report in
accordance with the reporting requirements in Part 1.D of this permit.
There shall be no discharge of floating solids or visible foam other than trace amounts.
All the parameters must be monitored, at a minimum, at the measurement frequency stated above if
there is any discharge. If there is no discharge, state such in the discharge monitoring report in
accordance with the reporting requirements in Part 1.D of this permit.
See Special Conditions, Part III.C.1 of this permit.
The temperature of the final effluent shall be continuously monitored. In addition to continuous
monitoring, the temperature of the fmal effluent shall be separately monitored once per day by a grab
sample, five days per week. The monthly minimum and maximum temperature from each method
shall be reported.
The dissolved oxygen concentration in the final effluent shall be continuously monitored. In addition
to continuous monitoring, the dissolved oxygen concentration of the final effluent shall be separately
monitored once per day by a grab sample, five days per week. The dissolved oxygen concentration in
the final effluent shall be 5.0 mg/L or higher at all times. The monthly minimum dissolved oxygen
concentration from each method shall be reported.
The concentration of mercury in the final effluent shall not exceed 6.0 ng/L or a concentration equal
to the concentration of mercury in the source water; whichever is greater. The permittee shall
concurrently monitor the final effluent and source water using EPA Method 1631E to quantify the
amount of mercury present in each. The detection limit for this method shall be no higher than 0.5
ng/L.
Ammonia, as N; total Kjeldahl nitrogen; organic nitrogen; nitrate/nitrite; and total nitrogen shall be
analyzed or calculated from the same effluent sample on the same day.
Total phosphorus and orthophosphate shall be analyzed from the same effluent sample on the same
day.
Fecal coliform and escherichia coli bacteria shall be reported as the geometric mean of the values for
samples collected during the month.
The permittee is subject to the effluent limitations and monitoring requirements for fecal coliform
from the effective date of the permit and continuing until EPD provides written authorization to the
permittee subjecting the permittee to the effluent limitations and monitoring requirements for
escherichia coli.
(12) See Special Conditions, Part III.C.3 of this permit.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
A.3. Effluent Limitations and Monitoring Requirements
Tier 3 (111,849 < Average Production of Plant 1 <_ 128,1161bs/day)(1)
Page 8 of 32
Permit No. GA0003280
During the period specified on the first page of this permit, the permittee is authorized to discharge
from outfall number 001(2) (32.594658, -81.747894) — Process Water, Cooling Water, and
Stormwater.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent
Characteristics
(Units)
Discharge
Limitations
Monitoring
Requirements(3)
Mass Based
(lbs/day)
Concentration
Based (mg/L)
Measurement
Frequency
Sample
Type
Sample
Location
Daily
Avg.
Daily
Max.
Daily
Avg.
Daily
Max.
Flow (MGD)(4)
3.1
Report
--
--
Daily
Continuous
Final
Effluent
Temperature (°F)
--
See
Note 6�
--
--
See Note(s)
See Note(s)
Final
Effluent
Dissolved Oxygen
--
--
--
See
Note(6)
See Note(6)
See Note(6)
Final
Effluent
BOD5
423
846
30
60
5/Week
Composite
Final
Effluent
COD
5,500
11,000
Report
Report
5/Week
Composite
Final
Effluent
TSS
650
1,160
Report
Report
1/Week
Composite
Final
Effluent
Sulfide
12.8
25.6
1.5
3.0
3/Week
Grab
Final
Effluent
TDS
--
--
2,500
3,800
5/Week
Composite
Final
Effluent
Total Phenols
6.4
12.8
Report
Report
Once Every
Two Months
Grab
Final
Effluent
Mercury, Total (ng/L)
--
See
Note(7)
See
Note(?)
2/Year
Grab
See
Note(7)
Chromium, Total
6.4
12.8
Report
Report
Once Every
Two Months
Composite
Final
Effluent
Ammonia, as N(8)
181
336
7
13
Daily
Composite
Final
Effluent
Total Kjeldahl
Nitrogen
--
--
Report
Report
1 /Month
Composite
Final
Effluent
Organic Nitrogen(8)
--
--
Report
Report
1/Month
Composite
Final
Effluent

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 9 of 32
Permit No. GA0003280
Effluent
Characteristics
(Units)
Discharge
Limitations
Monitoring
Requirements(3)
Mass Based
(lbs/day)
Concentration
Based (mg/L)
Measurement
Frequency
Sample
Type
Sample
Location
Daily
Avg.
Daily
Max.
Daily
Avg.
Daily
Max.
Nitrate/Nitrite)
--
--
Report
Report
1/Month
Composite
Final
Effluent
Total Nitrogen(8)
--
--
Report
Report
1/Month
Calculation
Final
Effluent
Total Phosphorus, as
p(9)
--
--
Report
Report
3/Week
Composite
Final
Effluent
Orthophosphate, as P(9)
--
--
Report
Report
1/Month
Composite
Final
Effluent
Specific Conductance
(µmhos/cm)
--
--
Report
Report
Daily
Continuous
Final
Effluent
Color
(ADMI color value)
--
--
Report
Report
1/Week
Grab
Final
Effluent
Fecal Coliform(10)(11)
(#/100mL)
--
--
200
400
1/Week
Grab
Final
Effluent
Escherichia Coli(10)(11)
(#/100mL)
--
--
126
410
1/Week
Grab
Final
Effluent
Acute Whole
Effluent Toxicity°12>
(Ceriodaphnia dubia)
LCso
>100%
Effluent
--
--
--
2/Week
Composite
Final
Effluent
Acute Whole
Effluent Toxicity(12)
(Pimephales promelas)
LCso >
100%
Effluent
--
--
--
1/Year
Composite
Final
Effluent
Chronic Whole
Effluent Toxicity(12)
(Ceriodaphnia dubia)
NOEC
> 8%
Effluent
--
--
--
1/Month
Composite
Final
Effluent
Chronic Whole
Effluent Toxicity(12)
(Pimephales promelas)
NOEC
> 8%
Effluent
--
--
--
1/Year
Composite
Final
Effluent
The pH of the final effluent shall be continuously monitored and recorded. The continuous monitoring
system shall have an alarm system that warns that the pH is approaching effluent limits. In addition to
continuous monitoring, the pH of the final effluent shall be monitored by analyzing grab samples once
per day, five days per week. The pH of the final effluent shall not be less than 6.0 standard units or
greater than 8.0 standard units. The monthly minimum and maximum pH from each method shall be
reported.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
Page 10 of 32
Permit No. GA0003280
The effluent limitations and monitoring requirements established in Part I.A.1 of this permit are
effective for Plant 1 monthly average production levels greater than 111,849 lbs of product per day
but less than 128,116 lbs of product per day, provided that the permittee has notified EPD of an
increase in production in accordance with Part III.C.5 of this permit. The average daily production
(lbs of product/day) for the month shall be reported with the monthly discharge monitoring report in
accordance with the reporting requirements in Part 1.D of this permit.
There shall be no discharge of floating solids or visible foam other than trace amounts.
All the parameters must be monitored, at a minimum, at the measurement frequency stated above if
there is any discharge. If there is no discharge, state such in the discharge monitoring report in
accordance with the reporting requirements in Part 1.D of this permit.
See Special Conditions, Part III.C.1 of this permit.
The temperature of the final effluent shall be continuously monitored. In addition to continuous
monitoring, the temperature of the final effluent shall be separately monitored once per day by a grab
sample, five days per week. The monthly minimum and maximum temperature from each method
shall be reported.
The dissolved oxygen concentration in the final effluent shall be continuously monitored. In addition
to continuous monitoring, the dissolved oxygen concentration of the final effluent shall be separately
monitored once per day by a grab sample, five days per week. The dissolved oxygen concentration in
the final effluent shall be 5.0 mg/L or higher at all times. The monthly minimum dissolved oxygen
concentration from each method shall be reported.
The concentration of mercury in the final effluent shall not exceed 6.0 ng/L or a concentration equal
to the concentration of mercury in the source water; whichever is greater. The permittee shall
concurrently monitor the final effluent and source water using EPA Method 1631E to quantify the
amount of mercury present in each. The detection limit for this method shall be no higher than 0.5
ng/L.
Ammonia, as N; total Kjeldahl nitrogen; organic nitrogen; nitrate/nitrite; and total nitrogen shall be
analyzed or calculated from the same effluent sample on the same day.
Total phosphorus and orthophosphate shall be analyzed from the same effluent sample on the same
day.
Fecal coliform and escherichia coli bacteria shall be reported as the geometric mean of the values for
samples collected during the month.
The permittee is subject to the effluent limitations and monitoring requirements for fecal coliform
from the effective date of the permit and continuing until EPD provides written authorization to the
permittee subjecting the permittee to the effluent limitations and monitoring requirements for
escherichia coli.
(12) See Special Conditions, Part III.C.3 of this permit.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
A.4. Surface Water Monitoring Requirements
Page 11 of 32
Permit No. GA0003280
Surface water(s) adjacent to the wastewater discharge shall be monitored. Unless otherwise stated
or approved by EPD, samples shall concurrently be collected 25 feet upstream of the permittee's
discharge pipe and 25 feet downstream of the permittee's discharge pipe, as marked by a post on
the river bank, and at a distance of 38 feet (+/- 3 feet) from the left riverbank.
Surface water monitoring shall be conducted by the permittee as specified below:
Parameter
(Units)
Measurement Frequency
Sample
Type
pH (standard units)
1/Month
Grab
Temperature ('F)
1/Month
Grab
Specific Conductance(1) (µmhos/cm)
1/Month
Grab
Ammonia, as N (mg/L)
1/Month
Grab
Dissolved Oxygen (mg/L)
1/Month
Grab
Acute Whole Effluent Toxicity(1)
(Ceriodaphnia dubia)
1/Month
Grab
Acute Whole Effluent Toxicity(1)(2)
(Pimephales promelas)
1/Year
Grab
Chronic Whole Effluent Toxicity(1)(2)
(Ceriodaphnia dubia)
1/Month
Grab
(1)
(2)
Downstream specific conductance sampling should be conducted concurrently with the whole
effluent toxicity testing and obtained from the same sample location, including depth in the water
column. EPD will evaluate the data to confirm that the downstream sampling location is
representative of the effluent plume within the Ogeechee River.
Instream whole effluent toxicity testing will be conducted downstream only. See Special Conditions,
Part III.C.3 of this permit.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
B. Monitoring
1. Representative Sampling
Page 12 of 32
Permit No. GA0003280
Samples and measurements taken as required herein shall be representative of the volume
and nature of the monitored discharge. The permittee shall maintain a written sampling
plan and schedule onsite.
2. Sampling Period
a. Unless otherwise specified in this permit, quarterly samples shall be taken during
the periods January -March, April -June, July -September, and October -December.
b. Unless otherwise specified in this permit, semiannual samples shall be taken during
the periods January -June and July -December.
c. Unless otherwise specified in this permit, annual samples shall be taken during the
period of January -December.
d. Unless otherwise specified in this permit, "once every two months" samples shall
be taken during the periods January -February, March -April, May -June, July -
August, September -October, and November -December.
3. Monitoring Procedures
Analytical methods, sample containers, sample preservation techniques, and sample
holding times must be consistent with the techniques and methods listed in 40 CFR Part
136. The analytical method used shall be sufficiently sensitive. EPA -approved methods
must be applicable to the concentration ranges of the NPDES permit samples.
4. Detection Limits
All parameters will be analyzed using the appropriate detection limits. If the results for a
given sample are such that a parameter is not detected at or above the specified detection
limit, a value of "NOT DETECTED" will be reported for that sample and the detection
limit will also be reported.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
5. Recording of Results
Page 13 of 32
Permit No. GA0003280
For each measurement or sample taken pursuant to the requirements of this permit, the
permittee shall record the following information:
a. The exact place, date, and time of sampling or measurements, and the person(s)
performing the sampling or the measurements;
b. The dates and times the analyses were performed, and the person(s) performing the
analyses;
c. The analytical techniques or methods used;
d. The results of all required analyses.
6. Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s) designated herein more frequently
than required by this permit, using approved analytical methods as specified above, the
results of such monitoring shall be included in the calculation and reporting of the values
required in the Discharge Monitoring Report. Such increased monitoring frequency shall
also be indicated. EPD may require, by written notification, more frequent monitoring or
the monitoring of other pollutants not required in this permit.
7. Records Retention
The permittee shall retain records of all monitoring information, including all records of
analyses performed, calibration and maintenance of instrumentation, copies of all reports
required by this permit, and records of all data used to complete the application for this
permit, for a minimum of three (3) years from the date of the sample, measurement, report
or application, or longer if requested by EPD.
8. Penalties
The Federal Clean Water Act and the Georgia Water Quality Control Act provide that any
person who falsifies, tampers with, or knowingly renders inaccurate any monitoring device
or method required to be maintained under this permit, makes any false statement,
representation, or certification in any record or other document submitted or required to be
maintained under this permit, including monitoring reports or reports of compliance or
noncompliance shall, upon conviction, be punished by a fine or by imprisonment, or by
both. The Federal Clean Water Act and the Georgia Water Quality Control Act also
provide procedures for imposing civil penalties which may be levied for violations of the
Act, any permit condition or limitation established pursuant to the Act, or negligently or
intentionally failing or refusing to comply with any final or emergency order of the
Director of EPD

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
C. Definitions
Page 14 of 32
Permit No. GA0003280
1. The "daily average" mass means the total discharge by mass during a calendar month
divided by the number of days in the month that the production or commercial facility was
discharging. Where less than daily sampling is required by this permit, the daily average
discharge shall be determined by the summation of all the measured daily discharges by
weight divided by the number of days sampled during the calendar month when the
measurements were made.
2. The "daily maximum" mass means the total discharge by mass during any calendar day.
3. The "daily average" concentration means the arithmetic average of all the daily
determinations of concentrations made during a calendar month. Daily determinations of
concentration made using a composite sample shall be the concentration of the composite
sample.
4. The "daily maximum" concentration means the daily determination of concentration for
any calendar day.
5. A "calendar day" is defined as any consecutive 24-hour period.
6. "Bypass" means the intentional diversion of waste streams from any portion of a treatment
facility.
7. "Severe property damage" means substantial physical damage to property, damage to
treatment facilities that causes them to become inoperable, or substantial and permanent
loss of natural resources that can reasonably be expected to occur in the absence of a
bypass. Severe property damage does not mean economic loss caused by delays in
production.
8. "EPD" as used herein means the Environmental Protection Division of the Department of
Natural Resources.
9. "State Act" as used herein means the Georgia Water Quality Control Act (Official Code of
Georgia Annotated; Title 12, Chapter 5, Article 2).
10. "Rules" as used herein means the Georgia Rules and Regulations for Water Quality
Control.
11. The "Plant 1 average production" means the average production (lbs of product per day) of
woven cotton and synthetic fibers through the processes of preparation, dyeing, and
finishing. Product receiving further conditioning through Plant 2 operations such as flame-
retardant treatment and bisulfite washing is not to be considered as additional production
for the purposes of this permit.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
D. Reporting Requirements
Page 15 of 32
Permit No. GA0003280
1. The permittee must electronically report the DMR, OMR and additional monitoring data
using the web based electronic NetDMR reporting system, unless a waiver is granted by
EPD.
a. The permittee must comply with the Federal National Pollutant Discharge
Elimination System Electronic Reporting regulations in 40 CFR § 127. The
permittee must electronically report the DMR, OMR, and additional
monitoring data using the web based electronic NetDMR reporting system online
at: https://netdmr.epa.gov/netdmr/public/home.htm
b. Monitoring results obtained during the calendar month shall be summarized for
each month and reported on the DMR. The results of each sampling event shall be
reported on the OMR and submitted as an attachment to the DMR.
c. The permittee shall submit the DMR, OMR and additional monitoring data no later
than 11:59 p.m. on the 15th day of the month following the sampling period.
d. All other reports required herein, unless otherwise stated, shall be submitted to the
EPD Office listed on the permit issuance letter signed by the Director of EPD.
2. No later than December 21, 2025, the permittee must electronically report the following
compliance monitoring data and reports using the online web based electronic system
approved by EPD, unless a waiver is granted by EPD:
a. Sewer Overflow/Bypass Event Reports;
b. Noncompliance Notification;
c. Other noncompliance; and
d. Bypass
3. Other Reports
All other reports required in this permit not listed above in Part I.D.2 or unless otherwise
stated, shall be submitted to the EPD Office listed on the permit issuance letter signed by
the Director of EPD.
4. Other Noncompliance
All instances of noncompliance not reported under Part I.D. and Part II.A. shall be reported
to EPD at the time the monitoring report is submitted.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
5. Signatory Requirements
Page 16 of 32
Permit No. GA0003280
All reports, certifications, data or information submitted in compliance with this permit or
requested by EPD must be signed and certified as follows:
a. Any State or NPDES Permit Application form submitted to the EPD shall be signed
as follows in accordance with the Federal Regulations, 40 C.F.R. 122.22:
1. For a corporation, by a responsible corporate officer. A responsible
corporate officer means:
i. a president, secretary, treasurer, or vice president of the corporation
in charge of a principal business function, or any other person who
performs similar policy- or decision -making functions for the
corporation, or
ii. the manager of one or more manufacturing, production, or operating
facilities employing more than 250 persons or having gross annual
sales or expenditures exceeding $25 million (in second-quarter 1980
dollars), if authority to sign documents has been assigned or
delegated to the manager in accordance with corporate procedures.
2. For a partnership or sole proprietorship, by a general partner or the
proprietor, respectively; or
3. For a municipality, State, Federal, or other public facility, by either a
principal executive officer or ranking elected official.
b. All other reports or requests for information required by the permit issuing
authority shall be signed by a person designated in (a) above or a duly authorized
representative of such person, if:
1. The representative so authorized is responsible for the overall operation of
the facility from which the discharge originates, e.g., a plant manager,
superintendent or person of equivalent responsibility;
2. The authorization is made in writing by the person designated under (a)
above; and
3. The written authorization is submitted to the Director.
c. Any changes in written authorization submitted to the permitting authority under
(b) above which occur after the issuance of a permit shall be reported to the
permitting authority by submitting a copy of a new written authorization which
meets the requirements of (b) and (b.1) and (b.2) above.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 17 of 32
Permit No. GA0003280
d. Any person signing any document under (a) or (b) above shall make the following
certification:
"I certify under penalty of law that this document and all attachments were
prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who manage the system,
or those persons directly responsible for gathering the information, the information
submitted is, to the best of my knowledge and belief, true, accurate, and complete. I
am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations."

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
PART II
A. Management Requirements
1. Notification of Changes
Page 18 of 32
Permit No. GA0003280
a. The permittee shall provide EPD at least 90 days advance notice of any planned
physical alterations or additions to the permitted facility that meet the following
criteria:
1. The alteration or addition to a permitted facility may meet one of the criteria
for determining whether a facility is a new source in 40 CFR 122.29(b);
2. The alteration or addition could significantly change the nature or increase
the quantity of pollutants discharged. This notification applies to pollutants
which are subject neither to effluent limitations in the permit, nor to
notification requirements under 40 CFR 122.42(a)(1); or
3. The alteration or addition results in a significant change in the permittee's
sludge use or disposal practices, and such alteration, addition, or change
may justify the application of permit conditions that are different from or
absent in the existing permit, including notification of additional use or
disposal sites not reported during the permit application process or not
reported pursuant to an approved land application plan.
b. The permittee shall give at least 90 days advance notice to EPD of any planned
changes to the permitted facility or activity which may result in noncompliance
with permit requirements.
c. Following the notice in paragraph a. or b. of this condition the permit may be
modified. The permittee shall not make any changes, or conduct any activities,
requiring notification in paragraph a. or b. of this condition without approval from
EPD.
d. The permittee shall provide at least 30 days advance notice to EPD of:
1. any planned expansion or increase in production capacity; or
2. any planned installation of new equipment or modification of existing
processes that could increase the quantity of pollutants discharged or result
in the discharge of pollutants that were not being discharged prior to the
planned change
if such change was not identified in the permit application(s) upon which this
permit is based and for which notice was not submitted under paragraphs a. or b. of
this condition.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 19 of 32
Permit No. GA0003280
e. All existing manufacturing, commercial, mining, and silvicultural dischargers shall
notify EPD as soon as it is known or there is reason to believe that any activity has
occurred or will occur which would result in the discharge, on a routine or frequent
basis, of any toxic pollutant not limited in the permit, if that discharge will exceed
(i) 100 µg/L, (ii) five times the maximum concentration reported for that pollutant
in the permit application, or (iii) 200 µg/L for acrolein and acrylonitrile, 500 µg/L
for 2,4 dinitrophenol and for 2-methyl-4-6-dinitrophenol, or 1 mg/L antimony.
f. All existing manufacturing, commercial, mining, and silvicultural dischargers shall
notify EPD as soon as it is known or there is reason to believe that any activity has
occurred or will occur which would result in any discharge on a nonroutine or
infrequent basis, of any toxic pollutant not limited in the permit, if that discharge
will exceed (i) 500 µg/L, (ii) ten times the maximum concentration reported for that
pollutant in the permit application, or (iii) 1 mg/L antimony.
g.
Upon the effective date of this permit, the permittee shall submit to EPD an annual
certification in June of each year certifying whether or not there has been any
change in processes or wastewater characteristics as described in the submitted
NPDES permit application that required notification in paragraph a., b., or d. of this
condition. The permittee shall also certify annually in June whether the facility has
received offsite wastes or wastewater and detail any such occurrences.
2. Noncompliance Notification
If, for any reason, the permittee does not comply with, or will be unable to comply with
any effluent limitation specified in this permit, the permittee shall provide EPD with an
oral report within 24 hours from the time the permittee becomes aware of the
circumstances followed by a written report within five (5) days of becoming aware of such
condition. The written submission shall contain the following information:
a. A description of the discharge and cause of noncompliance; and
b. The period of noncompliance, including exact dates and times; or, if not corrected,
the anticipated time the noncompliance is expected to continue, and steps being
taken to reduce, eliminate, and prevent recurrence of the noncomplying discharge.
3. Facility Operation
The permittee shall at all times maintain in good working order and operate as efficiently
as possible all treatment or control facilities or systems installed or used by the permittee to
achieve compliance with the terms and conditions of this permit. Proper operation and
maintenance includes effective performance, adequate funding, adequate operator staffing
and training, and adequate laboratory and process controls, including appropriate quality
assurance procedures. This provision requires the operation of back-up or auxiliary
facilities or similar systems only when necessary to achieve compliance with the
conditions of the permit.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
4. Adverse Impact
Page 20 of 32
Permit No. GA0003280
The permittee shall take all reasonable steps to minimize or prevent any discharge in
violation of this permit which has a reasonable likelihood of adversely affecting human
health or the environment, including such accelerated or additional monitoring as
necessary to determine the nature and impact of the noncomplying discharge.
5. Bypassing
a. If the permittee knows in advance of the need for a bypass, it shall submit prior
notice to EPD at least 10 days (if possible) before the date of the bypass. The
permittee shall submit notice of any unanticipated bypass with an oral report within
24 hours from the time the permittee becomes aware of the circumstances followed
by a written report within five (5) days of becoming aware of such condition. The
written submission shall contain the following information:
1. A description of the discharge and cause of noncompliance; and
2. The period of noncompliance, including exact dates and times; or, if not
corrected, the anticipated time the noncompliance is expected to continue,
and steps being taken to reduce, eliminate and prevent recurrence of the
noncomplying discharge.
b. Any diversion or bypass of facilities covered by this permit is prohibited, except (i)
where unavoidable to prevent loss of life, personal injury, or severe property
damage; (ii) there were no feasible alternatives to the bypass, such as the use of
auxiliary treatment facilities, retention of untreated wastes, or maintenance during
normal periods of equipment downtime (this condition is not satisfied if the
permittee could have installed adequate back-up equipment to prevent a bypass
which occurred during normal periods of equipment downtime or preventive
maintenance); and (iii) the permittee submitted a notice as required above. The
permittee shall operate the treatment works, including the treatment plant and total
sewer system, to minimize discharge of the pollutants listed in Part I of this permit
from combined sewer overflows or bypasses. Upon written notification by EPD,
the permittee may be required to submit a plan and schedule for reducing bypasses,
overflows, and infiltration in the system.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
6. Sludge Disposal Requirements
Page 21 of 32
Permit No. GA0003280
Sludge shall be disposed of in accordance with the regulations and guidelines established
by EPD, the Federal Clean Water Act, and the Resource Conservation and Recovery Act
(RCRA). Prior to disposal of sludge by any method other than co -disposal in an
appropriate and permitted landfill, the permittee shall submit a sludge management plan to
the Watershed Protection Branch of EPD for written approval. For land application of
nonhazardous sludge, the permittee shall comply with the applicable criteria outlined in the
most current version of EPD's "Guidelines for Land Application of Sewage Sludge
(Biosolids) at Agronomic Rates" and with the State Rules, Chapter 391-3-6-.17. EPD may
require more stringent control of this activity. Prior to land applying nonhazardous sludge,
the permittee shall submit a sludge management plan to EPD for review and approval.
Upon approval, the plan for land application will become a part of the NPDES permit upon
modification of the permit.
7. Sludge Monitoring Requirements
The permittee shall develop and implement procedures to ensure adequate year-round
sludge disposal. The permittee shall monitor the volume and concentration of solids
removed from the plant. Records shall be maintained which document the quantity of
solids removed from the plant. The ultimate disposal of solids shall be reported (in the unit
of lbs) as specified in Part I.D of this permit.
8. Power Failures
Upon the reduction, loss, or failure of the primary source of power to said water pollution
control facilities, the permittee shall use an alternative source of power if available to
reduce or otherwise control production and/or all discharges in order to maintain
compliance with the effluent limitations and prohibitions of this permit.
If such alternative power source is not in existence, and no date for its implementation
appears in Part I, the permittee shall halt, reduce or otherwise control production and/or all
discharges from wastewater control facilities upon the reduction, loss, or failure of the
primary source of power to said wastewater control facilities.
9. Operator Certification Requirements
The person responsible for the daily operation of the wastewater treatment facility shall be
a Class II biological wastewater treatment system operator, certified in accordance with the
Georgia State Board of Examiners for Certification of Water and Wastewater Plant
Operators and Laboratory Analysts Rule 43-51-6.(b).

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
10. Laboratory Analyst Certification Requirements
Page 22 of 32
Permit No. GA0003280
The permittee shall ensure that, when required, the person in responsible charge of the
laboratory performing the analyses for determining permit compliance is certified in
accordance with the Georgia Certification of Water and Wastewater Treatment Plant
operators and Laboratory Analysts Act, as amended, and the Rules promulgated
thereunder.
B. Responsibilities
1. Right of Entry
The permittee shall allow the Director of EPD, the Regional Administrator of EPA, and/or
their authorized representatives, agents, or employees, upon the presentation of credentials:
a. To enter upon the permittee's premises where a discharge source is located or in
which any records are required to be kept under the terms and conditions of this
permit; and
b. At reasonable times, to have access to and copy any records required to be kept
under the terms and conditions of this permit; to inspect any facilities, equipment
(including monitoring and control equipment), practices, or operations regulated or
required under this permit; and to sample any substance or parameters in any
location.
2. Transfer of Ownership or Control
A permit may be transferred to another person by a permittee if:
a. The permittee notifies the Director of EPD in writing of the proposed transfer at
least thirty (30) days in advance of the proposed transfer;
b. A written agreement containing a specific date for transfer of permit responsibility
and coverage between the current and new permittee (including acknowledgement
that the existing permittee is liable for violations up to that date, and that the new
permittee is liable for violations from that date on) is submitted to the Director at
least thirty (30) days in advance of the proposed transfer; and
c. The Director, within thirty (30) days, does not notify the current permittee and the
new permittee of EPD's intent to modify, revoke and reissue, or terminate the
permit and to require that a new application be filed rather than agreeing to the
transfer of the permit.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
3. Availability of Reports
Page 23 of 32
Permit No. GA0003280
Except for data deemed to be confidential under O.C.G.A. § 12-5-26 or by the Regional
Administrator of the EPA under the Code of Federal Regulations, Title 40, Part 2, all
reports prepared in accordance with the terms of this permit shall be available for public
inspection at an office of EPD. Effluent data, permit applications, permittee's names and
addresses, and permits shall not be considered confidential.
4. Permit Modification
This permit may be modified, suspended, revoked or reissued in whole or in part during its
term for cause including, but not limited to, the following:
a. Violation of any conditions of this permit;
b. Obtaining this permit by misrepresentation or failure to disclose fully all relevant
facts;
c. A change in any condition that requires either a temporary or permanent reduction
or elimination of the permitted discharge; or
d. To comply with any applicable effluent limitation issued pursuant to the order of
the United States District Court for the District of Columbia issued on June 8,
1976, in Natural Resources Defense Council, Inc. et.al. v. Russell E. Train, 8 ERC
2120(D.D.C. 1976), if the effluent limitation so issued:
1. is different in conditions or more stringent than any effluent limitation in
the permit; or
2. controls any pollutant not limited in the permit.
5. Toxic Pollutants
The permittee shall comply with effluent standards or prohibitions established pursuant to
Section 307(a) of the Federal Clean Water Act for toxic pollutants, which are present in the
discharge within the time provided in the regulations that establish these standards or
prohibitions, even if the permit has not yet been modified to incorporate the requirement.
6. Civil and Criminal Liability
Nothing in this permit shall be construed to relieve the permittee from civil or criminal
penalties for noncompliance.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
7. State Laws
Page 24 of 32
Permit No. GA0003280
Nothing in this permit shall be construed to preclude the institution of any legal action or
relieve the permittee from any responsibilities, liabilities, or penalties established pursuant
to any applicable State law or regulation under authority preserved by Section 510 of the
Federal Clean Water Act.
8. Water Quality Standards
Nothing in this permit shall be construed to preclude the modification of any condition of
this permit when it is determined that the effluent limitations specified herein fail to
achieve the applicable State water quality standards.
9. Property Rights
The issuance of this permit does not convey any property rights in either real or personal
property, or any exclusive privileges, nor does it authorize any injury to private property or
any invasion of personal rights, nor any infringement of Federal, State or local laws or
regulations.
10. Expiration of Permit
The permittee shall not discharge after the expiration date. In order to receive
authorization to discharge beyond the expiration date, the permittee shall submit such
information, forms, and fees as are required by EPD at least 180 days prior to the
expiration date.
11. Contested Hearings
Any person who is aggrieved or adversely affected by an action of the Director of EPD
shall petition the Director for a hearing within thirty (30) days of notice of such action.
12. Severability
The provisions of this permit are severable, and if any provision of this permit, or the
application of any provision of this permit to any circumstance, is held invalid, the
application of such provision to other circumstances, and the remainder of this permit,
shall not be affected thereby.
13. Best Management Practices
The permittee will implement best management practices to control the discharge of
hazardous and/or toxic materials from ancillary manufacturing activities. Such activities
include, but are not limited to, materials storage, in -plant transfer, process and material
handling, loading and unloading operations, plant site runoff, and sludge and waste
disposal.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
14. Need to Halt or Reduce Activity Not a Defense
Page 25 of 32
Permit No. GA0003280
It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit.
15. Duty to Provide Information
a. The permittee shall furnish to the EPD Director, within a reasonable time, any
information which the Director may request to determine whether cause exists for
modifying, revoking and reissuing, or terminating this permit or to determine
compliance with this permit. The permittee shall also furnish upon request copies
of records required to be kept by this permit.
b. When the permittee becomes aware that it failed to submit any relevant facts in a
permit application or submitted incorrect information in a permit application or any
report to the Director, it shall promptly submit such facts and information.
16. Duty to Comply
a. The permittee must comply with all conditions of this permit. Any permit
noncompliance constitutes a violation of the Georgia Water Quality Control Act
(O.C.G.A. § 12-5-20 et. seq.) and is grounds for enforcement action; for permit
termination; revocation and reissuance, or modification; or for denial of a permit
renewal application. Any instances of noncompliance must be reported to EPD as
specified in Part I. D and Part ILA. of this permit.
b. Penalties for violations of permit conditions. The Federal Clean Water Act and the
Georgia Water Quality Control Act (O.C.G.A. § 12-5-20 et. seq.) provide that any
person who falsifies, tampers with, or knowingly renders inaccurate any monitoring
device or method required under this permit, makes any false statement,
representation, or certification in any record or other document submitted or
required to be maintained under this permit, including monitoring reports or reports
of compliance or noncompliance shall, upon conviction be punished by a fine or by
imprisonment, or by both. The Georgia Water Quality Control Act (Act) also
provides procedures for imposing civil penalties which may be levied for violations
of the Act, any permit condition or limitation established pursuant to the Act, or
negligently or intentionally failing or refusing to comply with any final or
emergency order of the Director.
17. Upset Provisions
Provisions of 40 CFR 122.41(n)(1)-(4), regarding "Upset" shall be applicable to any civil,
criminal, or administrative proceeding brought to enforce this permit.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
PART III
A. Previous Permits
Page 26 of 32
Permit No. GA0003280
1. All previous State wastewater permits issued to this facility, whether for construction or
operation, are hereby revoked by the issuance of this permit. This action is taken to assure
compliance with the Georgia Water Quality Control Act, as amended, and the Federal
Clean Water Act, as amended. Receipt of the permit constitutes notice of such action. The
conditions, requirements, terms and provisions of this permit authorizing discharge under
the National Pollutant Discharge Elimination System govern discharges from this facility.
B. Schedule of Compliance
1. The permittee shall achieve compliance with the effluent limitations specified for
discharges in accordance with the following schedule: N/A
2. No later than 14 calendar days following a date identified in the above schedule of
compliance, the permittee shall submit either a report of progress or, in the case of specific
actions being required by identified dates, a written notice of compliance or
noncompliance, any remedial actions taken, and the probability of meeting the next
scheduled requirement.
C. Special Conditions
1. Instream Waste Concentration
The permittee shall record stream flows measured at the USGS Rocky Ford gage
(#02202040) at 8:00 a.m. daily. The total final effluent flow volume discharged for the
following 24-hour period shall neither exceed 8% of the actual stream flow as measured at
the Rocky Ford gage nor a daily average of 3.1 MGD. The stream flow recorded each day
and the total final effluent flow volume discharged shall be reported in accordance with
Part I.D of this permit.
2. Per- and Polyfluoroalkyl Substances (PFAS) Characterization Study
The purpose of the PFAS Characterization Study is to determine if the facility has the
potential to discharge PFAS into the environment through the discharge of treated
wastewater effluent or through industrial sludge disposal.
a. Within one (1) month of the effective date of the permit, the permittee shall submit
to EPD a written report characterizing all per- and polyfluoroalkyl substances
(PFAS) used in processing or manufacturing at the facility or believed present in
the process wastewater or sludge due to contact with any raw materials,
intermediate products, finished products, byproducts, or waste products.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 27 of 32
Permit No. GA0003280
b. If per- and polyfluoroalkyl substances (PFAS) are used in processing or
manufacturing at the facility or believed present in the facility's wastewater or
sludge, then within two (2) months of the effective date of the permit, the permittee
shall perform the following sampling for all PFAS compounds identified in the
written report, and for which a sufficiently sensitive method is available, and
submit the results of the sampling to EPD as prescribed below:
i. Complete two (2) representative sampling events of the influent to the
wastewater treatment plant and effluent from the wastewater treatment plant
prior to discharge from the permitted outfalls identified in this permit. The
sampling events shall be at least 48 hours apart and the influent and effluent
samples shall be taken on the same day.
ii. Complete two (2) representative industrial sludge sampling events. The
sludge samples shall be representative of the sludge leaving the facility.
In the absence of a 40 C.F.R. Part 136 approved sampling method for PFAS, where
applicable, the permittee shall conduct sampling using draft analytical method 1633. For
compounds not covered in draft analytical method 1633, the permittee shall conduct
sampling in accordance with procedures outlined by EPA Region 4's Laboratory Services
and Applied Science Division. The reference document for such procedures is the
"Determination of Per- and Polyfluoroalkyl Substances by Liquid Chromatography
Tandem Mass Spectrometry (2019) ID:LSBPROC-800-R1" or the most recently approved
operating procedures document. The permittee may utilize an alternate sampling
methodology, provided that the methodology is reviewed and approved by the Georgia
Environmental Protection Division. At the time this permit is issued analytical test Method
533 is approved for use.
c. Within three (3) months of the effective date of the permit, the permittee shall
submit the PFAS Characterization Study Report (Report) to EPD for review
summarizing the results of the samples. The Report shall include the certified
laboratory reports as an attachment including the certified laboratory analytical
results to EPD. The Report shall be submitted in hard copy and analytical data shall
be reported using Microsoft Excel workbooks and submitted in electronic format
on a universal serial bus (USB), to the address below:
Georgia Environmental Protection Division - Watershed Protection Branch
Watershed Compliance Program
Attn: Watershed Compliance Program Manager
2 Martin Luther King Jr. Drive
Suite 1152 East
Atlanta, Georgia 30334

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
3. Whole Effluent Toxicity (WET) Testing
Page 28 of 32
Permit No. GA0003280
a. Acute Whole Effluent Toxicity testing of the fmal effluent and the Ogeechee River
25 feet downstream from the outfall pipe shall be conducted concurrently using the
water flea (Ceriodaphnia dubia). In performing the testing, the most current U.S.
EPA acute aquatic testing manual shall be followed. The reference document for
this method is "Methods for Measuring the Acute Toxicity of Effluents and
Receiving Waters to Freshwater and Marine Organisms, 5th Edition, U.S. EPA.
821-R-02-012, October 2002" or the most recently approved edition. The LCso
shall not be less than 100% effluent for the final effluent testing. Beginning with
the effective date of this permit, testing shall be conducted on the final effluent with
a frequency of twice per week (2/week) and instream with a frequency of once per
month (1/month) and reported in accordance with Part I.D of this permit.
b. Acute Whole Effluent Toxicity testing of the final effluent and the Ogeechee River
25 feet downstream from the outfall pipe shall be conducted concurrently using the
fathead minnow (Pimephales promelas). In performing the testing, the most current
U.S. EPA acute aquatic testing manual shall be followed. The reference document
for this method is "Methods for Measuring the Acute Toxicity of Effluents and
Receiving Waters to Freshwater and Marine Organisms, 5th Edition, U.S. EPA 821-
R-02-012, October 2002" or the most recently approved edition. The LCso shall not
be less than 100% effluent for the final effluent testing. Beginning with the
effective date of the permit, testing shall be conducted on both the final effluent and
instream with a frequency of annually (1/year) and reported in accordance with Part
I.D of this permit.
c. Chronic Whole Effluent Toxicity testing of the final effluent and the Ogeechee
River 25 feet downstream from the outfall pipe shall be conducted concurrently
using the water flea (Ceriodaphnia dubia) using a dilution series of 0%, 2%, 4%,
8%, 16%, 32%, 64%, 100%. In performing the testing, the most current U.S. EPA
chronic aquatic testing manual shall be followed. The reference document for this
method is "Short -Term Methods of Estimating the Chronic Toxicity of Effluents
and Receiving Waters to Freshwater Organisms, 4th Edition, U.S. EPA 821-R-02-
013, October 2002" or the most recently approved edition. The No Observed Effect
Concentration (NOEC) of the effluent shall be not less than 8% effluent for the
final effluent testing. In, addition the permittee shall report the 25% inhibition
concentration (IC25) of both the final effluent and instream WET tests. Beginning
with the effective date of the permit, testing shall be conducted on both the final
effluent and instream with a frequency of monthly (1/month) and reported in
accordance with Part I.D of this permit.
d. Chronic Whole Effluent Toxicity testing of the final effluent shall be conducted
using the fathead minnow (Pimephales promelas) using a dilution series of 0%,
2%, 4%, 8%, 16%, 32%, 64%, 100%. In performing the testing, the most current
U.S. EPA chronic aquatic testing manual shall be followed. The reference
document for this method is "Short -Term Methods of Estimating the Chronic
Toxicity of Effluents and Receiving Waters to Freshwater Organisms, 4th Edition,
U.S. EPA 821-R-02-013, October 2002" or the most recently approved edition. The

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 29 of 32
Permit No. GA0003280
No Observed Effect Concentration (NOEC) of the effluent shall be not less than
8% effluent for the final effluent testing. In, addition the permittee shall report the
25% inhibition concentration (IC25) of the final effluent. Beginning with the
effective date of the permit, testing shall be conducted on the final effluent with a
frequency of annually (1/year) and reported in accordance with Part I.D of this
permit.
e. Within three (3) months of the effective date of the permit, the permittee shall
submit to EPD for review and approval proposed procedures for the completion of
a Toxicity Identification Evaluation (TIE) work plan. The TIE work plan proposal,
at a minimum, shall include the following elements:
i. Phase I — Toxicity Characterization
1. Establish a duration of four (4) months for Phase I — Toxicity
Characterization testing;
2. Establish twice per week acute WET testing and weekly chronic
WET testing of the fmal effluent for ceriodaphnia dubia and
pimephales promelas;
3. For acute WET tests which exhibit toxicity (i.e., LCso < 100%)
based on the baseline effluent toxicity test, and all chronic WET
tests, Phase 1 toxicity characterization testing is required. The TIE
work plan shall detail the characterization tests to be performed and
the required procedures for conducting each characterization test;
4. Identify WET testing procedures (e.g., sample type, test
concentrations, test media renewals, etc.);
5. Establish quality assurance (QA) and quality control (QC)
procedures for testing; and
6. Identify the contract laboratory and/or consultants responsible for
sample analysis.
ii. Phase II & Phase III — Toxicity Identification and Toxicity Confirmation
1. Establish a duration of two (2) months for Phase II & III — Toxicity
Identification and Toxicity Confirmation procedures beginning two
(2) months after the commencement of Phase I — Toxicity
Characterization testing;
2. Identify WET testing procedures (e.g., sample type, test
concentrations, test media renewals, etc.); and
3. Identify quality assurance (QA) and quality control (QC) procedures
for testing.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 30 of 32
Permit No. GA0003280
f. If two WET tests are failed during the permit term, the permittee will be required to
complete a Toxicity Identification Evaluation (TIE), Toxicity Reduction Evaluation
(TRE), and additional data gathering activities in accordance with the following
schedule:
i. Following the submission of a written noncompliance notification, in
accordance with Part II.A.2 of the permit, for a second WET test failure, the
permittee shall immediately commence the Toxicity Identification
Evaluation (TIE) approved by EPD.
ii. Within one (1) month following a written noncompliance notification of a
second WET test failure, the permittee shall prepare and submit to EPD a
report which provides an in-depth review of the facility operations;
including the products produced, chemicals used, facility engineering
design, and wastewater treatment operations.
iii. Two (2) months following the initiation of the TIE, the permittee shall
prepare and submit to EPD a report which identifies the Phase II & III —
Toxicity Identification and Toxicity Confirmation procedures which will be
enacted based on the results of the toxicity characterization tests.
iv. Within three (3) months following a written noncompliance notification of a
second WET test failure, the permittee shall prepare and submit to EPD a
report which provides an evaluation of housekeeping practices, treatment
plant operations, and opportunities for chemical optimization.
v. Within six (6) months following a written noncompliance notification of a
second WET test failure, the permittee shall submit to EPD a TRE report
based on the results of the TIE and other data collection activities. The
report, at a minimum, shall include the following elements:
1. Identification of the proposed method for toxicity reduction (i.e.,
toxicity treatability approach and/or causative agent approach);
2. If the causative agent approach was pursued, the TRE shall include a
copy of the source identification evaluation;
3. Evaluation and summation of reduction methodologies considered
for the TRE;
4. Selection of reduction methodology; and
5. Implementation schedule for the proposed solution.
vi. Upon receipt of a TRE report, EPD may modify the permit to incorporate
recommendations from the TRE and, if applicable; a compliance schedule.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
4. Approved Sludge Management Plan
Page 31 of 32
Permit No. GA0003280
a. The permittee's approved Sludge Management Plan allows for sludge generated at
the facility to be sent to a third party for further treatment and ultimate disposal.
b. The permittee will report on an annual basis the amount of sludge sent to the third -
party during the most recent calendar year. The annual report shall be submitted to
EPD no later than February 19 of the following year.
c. The permittee will maintain sludge handling records in accordance with Part I.B .7
of the Permit.
d. The permittee will notify EPD in writing of any planned changes to the permittee's
sludge use or disposal practices.
5. Notification of Increased Production
The permittee shall notify the EPD compliance office in writing at least two business days
prior to the month they expect to be operating at a higher level of production (higher than
Tier 1). The notice shall specify the anticipated level and the period during which the
permittee expects to operate at the increased level of production. New notice is required to
cover a period or production level not covered by prior notice or, if during two consecutive
months otherwise covered by a notice, the production level at the permitted facility does
not in fact meet the higher level designated in the notice.
D. Biomonitoring and Toxicity Reduction Requirements
1. The permittee shall comply with effluent standards or prohibitions established by section
307(a) of the Federal Act and with chapter 391-3-6-.03(5)(e) of the State Rules and may
not discharge toxic pollutants in concentrations or combinations that are harmful to
humans, animals, or aquatic life.
If toxicity is suspected in the effluent, EPD may require the permittee to perform any of the
following actions:
a. Acute biomonitoring tests;
b. Chronic biomonitoring tests;
c. Stream studies;
d. Priority pollutant analyses;
e. Toxicity reduction evaluations (TRE); or
f. Any other appropriate study.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 32 of 32
Permit No. GA0003280
2. EPD will specify the requirements and methodologies for performing any of these tests or
studies. Unless other concentrations are specified by EPD, the critical concentration used
to determine toxicity in biomonitoring tests will be the effluent instream wastewater
concentration (IWC) based on the representative plant flow of the facility and the critical
low flow of the receiving stream (7Q10). The endpoints that will be reported are the
effluent concentration that is lethal to 50% of the test organisms (LC50) if the test is for
acute toxicity, and the no observed effect concentration (NOEC) of effluent if the test is for
chronic toxicity.
The permittee must eliminate effluent toxicity and supply EPD with data and evidence to
confirm toxicity elimination.

GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
The Georgia Environmental Protection Division proposes to issue an NPDES permit to the applicant
identified below. The draft permit places conditions on the discharge of pollutants from the wastewater
treatment plant to waters of the State.
Technical Contact: Ian McDowell ([e-mail])
470-604-9483
Draft permit:
z
X
First issuance
Reissuance with no or minor modifications from previous permit
Reissuance with substantial modifications from previous permit
Modification of existing permit
Requires EPA review
Designated as a Major facility
1.0 FACILITY INFORMATION
1.1 NPDES Permit No.: GA0003280
1.2 Name and Address of Owner/Applicant
King America Finishing, Inc.
1351 Scarboro Highway
Sylvania, Georgia, 30467
1.3 Name and Address of Facility
King America Finishing, Inc.
1351 Scarboro Highway
Sylvania, Georgia, 30467
(Screven County)
1.4 Location and Description of the discharge (as reported by applicant)
Outfall ID
Latitude Longitude
Receiving
Waterbody
001 32° 35' 40.7688" N 81° 44' 52.4184" W Ogeechee River
(32.594658) (-81.747894)
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 1

1.5 Production Capacity
The facility has two manufacturing units, referred to as Plant 1 and Plant 2. Plant 1 is a
complex manufacturing operation, as defined in 40 CFR 410.41, which performs dyeing
and fmishing of woven cotton and synthetic fibers. The average daily production rate over
the previous permit term was 97,939 lbs/day with the highest annual average daily
production of 111,849 lbs/day occurring in 2015. Daily production rates were calculated
based on the number of production days, not calendar days. Approximately 28% of this
production employs a natural fiber and the remaining 72% employs a natural and synthetic
fiber blend. Plant 2 applies flame retardant treatment and performs other special
conditioning on a portion of the product produced from Plant 1. The daily average
production rate over the past five years from Plant 2 was 74,101 lbs/day.
The permittee has requested consideration of future production levels when calculating
production -based technology -based limits, in anticipation that production may increase to
the production rates experienced in 2011. This future production is equivalent to 128,116
lbs/day from Plant 1 and 88,162 lbs/day from Plant 2. EPD has included tiered permit limits
based on production levels to ensure that technology based effluent limits accurately reflect
production levels without restricting facility operations. Tiered limits have been based on
the permittee's average production rate over the previous five years (Tier 1), the highest
annual average production rate over the previous five years (Tier 2), and the predicted
return to the 2011 production rate (Tier 3). The pollutant loading for all production tiers is
within the scope of the loading previously considered and permitted and would not trigger
an anti -degradation analysis.
1.6 SIC Code & Description
2282 — Yarn Texturizing, Throwing, Twisting, and Winding Mills
2299 — Textile goods, Not Elsewhere Classified
1.7 Description of Industrial Processes
The facility includes two internal manufacturing units, referred to as Plant 1 and Plant 2.
Plant 1
Plant 1 is a complex manufacturing operation which performs dyeing and finishing of
woven cotton and synthetic fibers. The fibers first undergo preparation which includes
singeing, desizing, heat -setting, mercerizing, bleaching, and washing. The fibers then
undergo dyeing which includes dye application, dye fixation with chemicals or heat,
washing, and drying. Finally, fibers undergo finishing. Finishing includes passing fabric
through a finish pad, a pre -dryer and/or set of dry cans, and then a tenter house.
Plant 2
Plant 2 provides further finishing through flame retardant treatment of cotton and synthetic
fabrics and special conditioning of those products. Flame-retardant treatment impregnates
the fabric with a reactant chemistry and then exposes the fabric, in subsequent process
steps, to reactant gases and liquids to chemically form the flame-retardant component on
the fabric. After the reaction, the fabric contains unreacted chemicals and chemical
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 2

byproducts that must be removed through thorough rinsing. Fabric is then washed with
bisulfite to remove excess formaldehyde and undergoes fmal softening.
1.8 Description of the Wastewater Treatment Facility
Wastewater at the facility receives initial screening and neutralization via sulfuric acid
before entering a 4.5 million -gallon equalization basin. Wastewater is then pumped from
the equalization basin to an activated sludge aeration basin for secondary treatment. Further
secondary treatment is then provided via polymer addition and the use of clarifiers.
Clarifiers #2 & #3 operate in parallel as the facility's main clarifiers, whilst Clarifier #1 is
operated as a backup system. Wastewater from the clarifiers is subsequently passed through
cloth media filters. Finally, tertiary treatment is provided through a granulated activated
carbon filtration system with CO2 neutralization before discharge to the Ogeechee River via
an effluent diffuser.
Waste sludge, filter backwash, and emergency bypass are diverted to two sludge holding
ponds. The facility has an ability to pump pond supernatant back into the equalization basin
to prevent pond overflow in heavy rainfall events. Primary wasting operations occur at the
first sludge holding pond, then water overflows to the second pond. This first pond has been
dredged every year or two with the most recent dredging occurring in the Fall of 2021. The
second pond has not been dredged since Milliken's involvement with the site. The sludge
storage capacity of the smallest sludge pond is approximately 14 3 million pounds, which
provides approximately 14.2 years of storage at the average solids wasting rate of 2,754
pounds of TSS per day. Sludge should be disposed of in an appropriate and permitted
landfill, or in accordance with an EPD approved sludge management plan.
Outfall
Operation Description Treatment Description
Screening, Neutralization, Activated Sludge,
001 Process Water, Cooling Water, and Sedimentation, Sludge Lagoons, Cloth Media
Stormwater Filtration, Carbon Adsorption, Discharge to
Surface Water, and Landfill
1.9 Type of Wastewater Discharge
® process wastewater ® stormwater
❑ domestic wastewater Z combined
Z other (cooling water)
Process wastewater, cooling water, and stormwater combine before treatment at the
wastewater treatment plant.
Domestic wastewater was separated from the above wastestreams in 2015 and was diverted
to a septic tank system which is covered under general permit no. GAG278093.
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 3

1.10 Characterization of Effluent Discharge as Reported by Applicant
(Please refer to the application for additional analysis)
1.10.a Outfall No. 001 — Process Water, Cooling Water, and Stormwater
Effluent Characteristics
(as Reported by Applicant)
Maximum Average
Daily Value Daily Value
Flow (MGD) 2.770 1.580
Biochemical Oxygen Demand,5-day 34 7
(mg/L)
Total Suspended Solids (mg/L) 59 <71
Temperature, Winter (°F) 86.4 68.4
Temperature, Summer (°F) 94.5 79.5
Ammonia (mg/L) 11.8 <1.3(1)
Total Phosphorus (mg/L) 54.8 27.0
(1) Less than signs indicate that non -detectable samples were reported, and that the method
detection limit was assigned to these samples for the purposes of reporting long term averages.
2.0 APPLICABLE REGULATIONS
2.1 State Regulations
Chapter 391-3-6 of the Georgia Rules and Regulations for Water Quality Control
2.2 Federal Regulations
Source
Activity Applicable Regulation
Industrial (Non POTW)
Non -Process Water
Discharges
40 CFR 122
40 CFR 125
40 CFR 127
40 CFR 136
Process Water Discharges
40 CFR 122
40 CFR 125
40 CFR 127
40 CFR 136
40 CFR 410
2.3 Industrial Effluent Limit Guideline(s)
Code of Federal Regulations, 40 CFR Part 410 Subpart D (Textile Mills Point Source
Category: Woven Fabric Finishing Subcategory)
See Appendix A of the Fact Sheet for Applicable Federal Regulations
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 4

In 2006 King America Finishing installed two flame-retardant processing lines at the
facility which performed additional fabric finishing for the facility. For ease of discussion
and calculations the flame-retardant operations are considered to constitute "Plant 2";
whereas all other operations are considered to constitute "Plant 1". It is important to note
that despite the nomenclature used, the installation of the flame-retardant processing lines
occurred within the existing facility and did not create a new building, structure, or facility.
Additionally, the installation did not reflect a substantially independent process than the
complex manufacturing operations already performed at the facility. As such, the
additional processing lines do not trigger a new source determination, as outlined in 40
CFR § 122.29, and thus effluent limitations for existing sources, not new sources, are
applicable.
3.0 WATER QUALITY STANDARDS & RECEIVING WATERBODY INFORMATION
Section 301(b)(1)(C) of the Clean Water Act (CWA) requires the development of limitations in
permits necessary to meet water quality standards. Federal Regulations 40 CFR 122.4(d) require
that conditions in NPDES permits ensure compliance with the water quality standards which are
composed of use classifications, numeric and or narrative water quality criteria and an anti -
degradation policy. The use classification system designates the beneficial uses that each
waterbody is expected to achieve, such as drinking water, fishing, or recreation. The numeric and
narrative water quality criteria are deemed necessary to support the beneficial use classification
for each water body. The antidegradation policy represents an approach to maintain and to protect
various levels of water quality and uses.
3.1 Receiving Waterbody Classification and Information
Rules and Regulations of the State of Georgia 391-3-6-.03(6) — Fishing
Propagation of Fish, Shellfish, Game and Other Aquatic Life; secondary contact recreation
in and on the water; or any other use requiring water of a lower quality.
(i) Dissolved Oxygen: A daily average of 6.0 mg/L and no less than 5.0 mg/L at all
times for water designated as trout streams by the Wildlife Resources Division. A
daily average of 5.0 mg/L and no less than 4.0 mg/L at all times for waters
supporting warm water species of fish.
(ii) pH: Within the range of 6.0 - 8.5.
(iii) Bacteria:
1. For the months of May through October, when water contact recreation
activities are expected to occur, fecal coliform not to exceed a geometric
mean of 200 per 100 mL based on at least four samples collected from a
given sampling site over a 30-day period at intervals not less than 24 hours.
Should water quality and sanitary studies show fecal coliform levels from
non -human sources exceed 200/100 mL (geometric mean) occasionally,
then the allowable geometric mean fecal coliform shall not exceed 300 per
100 mL in lakes and reservoirs and 500 per 100 mL in free flowing
freshwater streams. For the months of November through April, fecal
coliform not to exceed a geometric mean of 1,000 per 100 mL based on at
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 5

least four samples collected from a given sampling site over a 30-day period
at intervals not less than 24 hours and not to exceed a maximum of 4,000
per 100 mL for any sample. The State does not encourage swimming in
these surface waters since a number of factors which are beyond the control
of any State regulatory agency contribute to elevated levels of bacteria.
2. For waters designated as shellfish growing areas by the Georgia DNR
Coastal Resources Division, the requirements will be consistent with those
established by the State and Federal agencies responsible for the National
Shellfish Sanitation Program. The requirements are found in National
Shellfish Sanitation Program Guide for the Control of Molluscan Shellfish,
2007 Revision (or most recent version), Interstate Shellfish Sanitation
Conference, U.S. Food and Drug Administration.
(iv) Temperature: Not to exceed 90°F. At no time is the temperature of the receiving
waters to be increased more than 5°F above intake temperature except that in
estuarine waters the increase will not be more than 1.5°F. In streams designated as
primary trout or smallmouth bass waters by the Wildlife Resources Division, there
shall be no elevation of natural stream temperatures. In streams designated as
secondary trout waters, there shall be no elevation exceeding 2°F natural stream
temperatures.
3.2 Ambient Information
Outfall ID
7Q10 1Q10
(cfs) (cfs)
Hardness Annual Upstream Total
(mg/L as Average Suspended Solids
CaCO3) Flow (cfs) (mg/L)
001 94 89 35 1767 Data unavailable)
(1) For the Reasonable Potential Analysis calculations, EPD used 10 mg/1 as a conservative value.
3.3 Georgia 305(b)/303(d) List Documents
The Ogeechee River (R030602020304) from Nevill's Creek to Hwy 301 is listed as not
supporting the designated use.
2020 Integrated 305{b)/303(d) List - Streams
Reach Name/ID Reach Location/County River Basin/ Assessment/ Cause/ Size/Unit Category/ Notes
Use
Data Provider Source
Priority
Ogeechee Rirer
GAR030602020306
Neville Creek to Hwy 301
Bulloch, Screren
Ogeechee
Fishing
Not Supporting
1,9,10
Fish Tissue
(Mercury)
NP
7
Miles
ITMDL completed Fish Tissue (Mercury) 2005.
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3.4 Total Maximum Daily Load (TMDL)
The Ogeechee River is not supporting its designated use due to the trophic-weighted
residue value of mercury in fish tissue. There was a TMDL developed for total mercury
fish tissue in 2005 which is applicable to this segment of the Ogeechee River. King
America Finishing is listed in this TMDL and was given a wasteload allocation of 6.0 ng/L
for Total Hg and 0.05 ng/L for McHg equivalent to their effluent discharge during TMDL
development. The facility was also subject to mercury characterization and/or
minimization conditions.
The previous permit included special conditions requiring a six month mercury
characterization study, with an additional requirement to develop a mercury minimization
plan if the characterization showed the average concentration of total mercury was greater
than 6.0 ng/L. Results of the mercury characterization study showed an average
concentration for total mercury of 0.73 ng/L; therefore, a minimization plan was not
required and mercury monitoring was reduced to twice per year for the remainder of the
permit term. To assure that average total mercury concentrations remain below the 6.0 ng/L
wasteload allocation or the concentration of mercury in the source water; whichever is
greater, twice per year effluent and source water monitoring has been established in this
permit.
3.5 Wasteload Allocation Date (07/10/2018)
See Appendix B of the Fact Sheet
4.0 PERMIT CONDITIONS AND EFFLUENT LIMITATIONS
4.1 Water Quality Based Effluent Limitations (WQBELs) & Technology Based Effluent
Limitations (TBELs)
When drafting a National Pollutant Discharge Elimination System (NPDES) permit, a
permit writer must consider the impact of the proposed pollutants in a discharge on the
quality of the receiving water. Water quality goals for a waterbody are defined by state
water quality criteria or standards. By analyzing the effect of a pollutant in the discharge
on the receiving water, a permit writer could find that technology -based effluent limitations
(TBELs) alone will not achieve the applicable water quality standards or protect
downstream users. In such cases, the Clean Water Act (CWA) and its implementing
regulations require development of water quality -based effluent limitations (WQBELs).
WQBELs help meet the CWA objective of restoring and maintaining the chemical,
physical, and biological integrity of the nation's waters and the goal of water quality that
provides for the protection and propagation of fish, shellfish, and wildlife and recreation in
and on the water (fishable/swimmable).
WQBELs are designed to protect water quality by ensuring water quality standards are met
in the receiving water and the designated use and downstream uses are protected. On the
basis of the requirements of 40 C.F.R §125.3(a), additional or more stringent effluent
limitations and conditions, such as WQBELs, are imposed when TBELs are not sufficient
to protect water quality.
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TBELs aim to prevent pollution by requiring a minimum level of effluent quality that is
attainable using demonstrated technologies for reducing discharges of pollutants or
pollution into the waters of the State. TBELs are developed independently of the potential
impact of a discharge on the receiving water, which is addressed through water quality
standards and WQBELs. The NPDES regulations at 40 C.F.R. §125.3(a) require NPDES
permit writers to develop technology -based treatment requirements, consistent with CWA
section 301(b), that represent the minimum level of control that must be imposed in a
permit. The regulation also requires permit writers to include in permits additional or more
stringent effluent limitations and conditions, including those necessary to protect water
quality.
For pollutants not specifically regulated by Federal Effluent Limit Guidelines (ELGS), the
permit writer must identify any needed TBELS and utilize best professional judgment to
establish TBELS or determine other appropriate means to control its discharge if there is a
reasonable potential to cause or contribute to a violation of the water quality standards.
4.2 Reasonable Potential Analysis (RPA)
EPA regulations at 40 C.F.R. §122.44(d)(1)(i) state, "Limitations must control all
pollutants or pollutant parameters (either conventional, nonconventional, or toxic
pollutants) which the Director determines are or may be discharged at a level that will
cause, have the reasonable potential to cause, or contribute to an excursion above any
[s]tate water quality standard, including [s]tate narrative criteria for water quality."
[emphasis added]
EPA regulations at 40 C.F.R. §122.44(d)(1)(ii) require States to develop procedures for
determining whether a discharge causes, has the reasonable potential to cause, or
contributes to an instream excursion above a narrative or numeric criterion within a state
water. If such reasonable potential is determined to exist, the NPDES permit must contain
pollutant effluent limits and/or effluent limits for whole effluent toxicity. Georgia has
reasonable potential procedures, based upon the specific category of pollutants and/or
specific pollutant of concern. Chemical specific and biomonitoring data and other pertinent
information in EPD's files will be considered in accordance with the review procedures
specified in the GA Rules and Regulations for Water Quality Control, Chapter 391-3-6 in
the evaluation of a permit application and in the evaluation of the reasonable potential for
a discharge to cause an exceedance in the numeric or narrative criteria.
The term "pollutant" is defined in CWA section 502(6) and 40 C.F.R. § 122.2. Pollutants
are grouped into three categories under the NPDES program: conventional, toxic, and
nonconventional. Conventional pollutants are those defined in CWA section 304(a)(4) and
40 C.F.R.§401.16 (five day -biochemical oxygen demand (BOD5), total suspended solids
(TSS), fecal coliform, pH, and oil and grease). Toxic (priority) pollutants are those defined
in CWA section 307(a)(1) and include 126 metals and manmade organic compounds.
Nonconventional pollutants are those that do not fall under either of the above categories
(conventional or toxic pollutants) and include parameters such as, but not limited to,
chlorine, ammonia, nitrogen, phosphorus, chemical oxygen demand (COD), and whole
effluent toxicity (WET).
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EPD evaluates the data provided in the application and supporting documents. If a
pollutant is listed in the following sections of this fact sheet below, the permit writer
determined the pollutant is a pollutant of concern and there may be a reasonable potential
to cause or contribute to an instream violation of the Georgia water quality standards. If a
pollutant is not listed below, EPD determined the pollutant is not a pollutant of concern or
has determined, based on the data provided in the application, there is no reasonable
potential to cause or contribute to an instream violation of the Georgia water quality
standards. An example may be if the applicant reported "not detect" or "below detection
limit"
Upon identification of a pollutant of concern by the permit writer, in accordance with 40
C.F.R. §122.44(d)(1)(ii), the permit writer must then perform a reasonable potential
analysis using a procedure which has accounted for any combination of the following
criteria: existing controls on point and nonpoint sources of pollution, the variability of the
pollutant or pollutant parameter in the effluent, the sensitivity of the species to toxicity
testing (when evaluating whole effluent toxicity), and where appropriate, the dilution of
the effluent in the receiving water to determine if the pollutant and its discharge has the
reasonable potential to cause, or contribute to an in -stream excursion above the allowable
ambient concentration of a state narrative or numeric criteria within the state's water
quality standard for an individual pollutant.
In accordance with 40 C.F.R. §122.44(d)(1)(iii), if the permit writer has determined, using
a reasonable potential procedure the pollutant of concern in the discharge causes, has the
reasonable potential to cause, or contributes to an in -stream excursion above the allowable
ambient concentration of a state numeric or narrative criteria within a state water quality
standard for an individual pollutant, the permit must contain effluent limits for that
pollutant. If the permit writer has determined there is insufficient data, the permit writer
might also consider monitoring requirements to collect the additional data related to the
presence or absence of a specific pollutant to provide information for further analyses for
the development of appropriate numeric or narrative standard .
The conventional, nonconventional, and toxic pollutants listed in the following sections
have been identified by the permit writer as pollutants of concern and the permit writer has
determined through current practices and procedures one of the following: no additional
monitoring or numeric and/or narrative effluent limits are needed; additional monitoring is
required; or numeric and/or narrative effluent limits are necessary to protect the receiving
water body and its downstream users and those limits have been included in the permit.
The monitoring and sampling locations are prescribed in the permit and determined by the
permit writer after considering, at a minimum, the following: type of discharge, specific
pollutant, discharge frequency, location of the discharge, receiving waterbody,
downstream users, etc.
The sample type, grab vs. composite, is prescribed in the permit and determined by the
permit writer after considering, at a minimum, the analytical method required in 40 C.F.R.
§ 136, the type of pollutant, retention time, etc. Grab samples are required for the analysis
of pH, temperature, cyanide, total phenols, residual chlorine, oil and grease, fecal coliform
(including E. coli), or volatile organics.
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4.3 Whole Effluent Toxicity
Chronic WET testing measures the effect of wastewater on indicator organisms' growth,
reproduction and survival. Effluent toxicity is predicted when the No Observable Effect
Concentrations (NOEC) for a test organism is less than the facility's Instream Wastewater
Concentration.
Chronic WET testing for Ceriodaphnia dubia was required in the previous permit for both
the fmal effluent and the Ogeechee River 25 feet downstream of the outfall, with a
monitoring frequency of once per month. Additionally, Chronic WET testing for
Pimephales promelas was required in the previous permit for the final effluent, with a
monitoring frequency of quarterly for the first year and annually thereafter. Effluent
toxicity was determined when the NOEC exceeded the facility's maximum allowable IWC
of 8%
Acute WET testing measures the effect of wastewater on indicator organisms' survival.
Effluent toxicity is predicted when the Lethal Concentration 50% (LC50) is greater than or
equal to 100% effluent.
Acute WET testing for Ceriodaphnia dubia was required in the previous permit for both
the fmal effluent and the Ogeechee River 25 feet downstream of the outfall, with
monitoring frequencies of twice per week and once per month; respectively. Additionally,
Acute WET testing for Pimephales promelas was required in the previous permit for both
the fmal effluent and the Ogeechee River 25 feet downstream of the outfall, with a
monitoring frequency of quarterly for the first year and annually thereafter.
The WET testing results over the previous permit term have been included in Appendix E
of this fact sheet. Results of the WET testing showed periodic toxicity for both the Acute
WET testing and Chronic WET testing.
4.4 Conventional Pollutants: Outfall 001 & Instream Discussions
Pollutants of Concern Basis
pH
WQBEL
The instream waste concentration is 4.86% based on the facility's
permitted flow. The permit further limits the IWC to no greater than
8%. When the instream waste concentration is below 50%, there is
no reasonable potential to cause or contribute to a violation of the
instream Georgia Water Quality Standard; therefore, a limit of 6.0
s.u. to 9.0 s.u. is required.
On July 17, 2011, King America Finishing submitted a technical
memorandum demonstrating operational changes and requesting
resumption of discharge. On July 19, 2011, EPD approved the
resumption of discharge contingent on compliance with several
stipulations. One such stipulation was that the pH of the discharge
shall not fall below 6.0 s.u. or rise above 8.0 s.u. By limiting the
upper pH, the stipulation limits the amount of un-ionized ammonia
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April, 2022
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present in the discharge. Un-ionized ammonia can be toxic to
aquatic organisms and ammonia was identified to be one of the
primary contributors to the toxicity of the discharge. These more
stringent effluent limitations have been included in the permit.
In addition, upstream and downstream pH monitoring has been
retained in the permit to monitor instream water quality within the
vicinity of the discharge.
TBEL
The pH shall remain within the range of 6.0 s.u. to 9.0 s.u. at all
times in accordance with 40 CFR 410.42(a) Best Practicable
Control Technology Currently Available (BPT).
5-Day Biochemical
Oxygen Demand
WQBEL
The wasteload allocation completed on July 20, 2018,
recommended mass -based effluent limitations of 776 lbs/day daily
average and 1,552 lbs/day daily maximum, as well as concentration -
based effluent limitations of 30 mg/L daily average and 60 mg/L
daily maximum based on dissolved oxygen sag (DOSAG)
modeling.
The concentration -based effluent limitations have been included in
the permit, while more stringent mass -based effluent limitations
have been applied based on the applicable TBELs.
TBEL
The facility is subject to production -based effluent limitations in
accordance with 40 CFR 410.42(a) Best Practicable Control
Technology Currently Available (BPT). The permittee has
requested consideration of future production levels when
calculating production based TBELs, in anticipation that production
may increase to long-term production rates experienced in 2011.
The following effluent limitations have been included in the permit
based on three tiers of production.
Tier 1 (Average Production of Plant 1 < 97,939 lbs/day)
Daily Average (lbs/day): 323
Daily Maximum (lbs/day): 646
Tier 2 (97,9391bs/day < Average Production of Plant 1 < 111,849
lbs/day)
Daily Average (lbs/day): 369
Daily Maximum (lbs/day): 738
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Tier 3 (111,849 lbs/day < Average Production of Plant 1 <
128,116 lbs/day)
Daily Average (lbs/day): 423
Daily Maximum (lbs/day): 846
WQBEL
Total Suspended GA has a narrative Water Quality Standard for total suspended
Solids solids. A narrative permit condition stating, "there shall be no
floating solids or visible foam other than in trace amounts" has been
added.
Additionally, the previous permit included mass -based effluent
limitations of 650 lbs/day daily average and 1,160 lbs/day daily
maximum. These limits were developed in consultation with the
Wildlife Resource Division and are protective of aquatic life cycles
(e.g., reproduction). TSS mass -based effluent limitations have been
retained from the previous permit.
TBEL
The facility is subject to production -based effluent limitations in
accordance with 40 CFR 410.42(a) Best Practicable Control
Technology Currently Available (BPT). The permittee has
requested consideration of future production levels when
calculating production based TBELs, in anticipation that production
may increase to long-term production rates experienced in 2011.
The following effluent limitations were calculated based on three
tiers of production. The more stringent WQBELs have been
included in the permit.
Tier 1 (Average Production of Plant 1 < 97,939 lbs/day)
Daily Average (lbs/day): 872
Daily Maximum (lbs/day): 1,743
Tier 2 (97,939 lbs/day < Average Production of Plant 1 < 111,849
lbs/day)
Daily Average (lbs/day): 995
Daily Maximum (lbs/day): 1,991
Tier 3 (111,849 lbs/day < Average Production of Plant 1
128,116 lbs/day)
Daily Average (lbs/day): 1,140
Daily Maximum (lbs/day): 2,280
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Additionally, the concentration -based effluent limitations of 30
mg/L daily average and 45 mg/L daily maximum included in the
previous permit have been removed and replaced with a monitoring
only requirement. See Section 5.3 for discussion regarding anti -
backsliding regulations.
Fecal Coliform
WQBEL
A consent decree (Civil Action No. 6:12-CV-00058) signed on
January 15, 2014, negotiated a settlement between King America
Finishing, Inc. and the Ogeechee-Canoochee Riverkeeper. The
consent decree included a condition limiting the effluent's fecal
coliform concentration to 200 #/100mL daily average and 400
#/100mL daily maximum. This condition was incorporated into the
facility's previous NPDES permit. The previous permit's fecal
coliform limits are equivalent to Georgia's instream water quality
standards for fecal coliform.
On September 25, 2015, the facility began the operation of a septic
tank system under general permit no. GAG278093. All sanitary
wastewater from the facility was re -directed to the septic system,
thereby eliminating sanitary wastewater from the direct discharge
to the Ogeechee River. On October 9, 2015, a series of dye tests
were performed confirming that the sanitary wastewater was
isolated from the discharge covered under this permit.
Following the removal of sanitary wastewater from the facility's
discharge, sampling of the effluent continued to indicate the
presence of fecal coliform suspected to have originated from non-
human sources. On July 18, 2017, the facility collected samples for
fecal coliform, e. coli, and a fecal -associated human gene biomarker
which was analyzed using real-time quantitative Polymerase Chain
Reaction (qPCR) DNA analytical technology. The results of the
sampling showed no trace of human fecal sources despite a fecal
coliform reading of 420 MPN/100mL.
The removal of sanitary wastewater has not eliminated fecal
coliform exceedances and there is a reasonable potential for the
discharge to cause or contribute to an instream violation of
Georgia's Water Quality Standards for fecal coliform. Review of
the renewal application and all data submitted by the permittee
during the last permit term indicates a persistent and highly variable
presence of fecal coliform in the discharge which frequently
exceeds Georgia's instream water quality standards. Dilution is not
considered in EPD's reasonable potential analysis as bacteria have
the inherent ability to reproduce in the receiving stream. Effluent
limitations of 200 #/100 mL daily average and 400 #/100 mL daily
maximum have been included in the permit.
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April, 2022
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TBEL
There is no applicable federal technology based effluent limit.
Escherichia coli
WQBEL
EPD is finalizing recommendations to replace fecal coliform and
adopt e. coli and enterococci as pathogen indicators for waters
designated as fishing, coastal fishing, and drinking water as part of
the 2019 Triennial Review process. The proposed criteria must be
approved by the DNR Board and the US EPA before they can take
effect.
Review of data submitted by the permittee indicates a persistent and
highly variable presence of e. coli in the discharge which
occasionally exceeds Georgia's proposed instream water quality
standards for e. coli. E. coli bacterium are highly variable in the
receiving stream after treatment and dilution is not considered in
EPD's reasonable potential analysis as bacteria have the inherent
ability to reproduce in the receiving stream. EPD has determined
that the discharge has a reasonable potential to cause or contribute
to a violation of Georgia's proposed water quality criteria for e. coli.
In anticipation of approval of the proposed criteria during the
upcoming permit term, the permit includes language which allows
for the transition from fecal coliform effluent limitations discussed
previously to year-round e. coli effluent limitations of 126 #/100mL
daily average (expressed as a geometric mean) and 410 #/100 mL
daily maximum. The e. coli limitations were calculated to yield the
same gastrointestinal illness rate as the fecal coliform limitations
and therefore are equivalently protective of human health and do
not constitute backsliding.
TBEL
There is no applicable federal technology based effluent limit.
Temperature
WQBEL
GA has a numeric Water Quality Standard of 90 °F for maximum
temperature and a +A5 °F temperature differential (391-3-6-
.03(6)(a)(v)). Continuous temperature monitoring along with
additional grab sampling was required in the previous permit.
Monitoring indicated that effluent temperature occasionally
exceeded 90°F, with the highest result over the permit term of 94.5
°F. Temperature measurements, however, are recorded immediately
after the wastewater treatment plant and do not account for the
approximately 3/aths of a mile that the effluent travels in
underground piping prior to discharge to the Ogeechee River.
Cooling of the effluent occurs due to the ambient ground
temperature prior to discharge. This is supported by the instream
temperature data that indicates a negligible increase in instream
temperature downstream of the discharge. The instream data
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April, 2022
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showed that on average the downstream temperature was 0.15 °F
warmer than the upstream temperature. Based on this information,
EPD has determined the discharge does not have the reasonable
potential to cause or contribute to instream water quality standards
for temperature.
Effluent and instream temperature monitoring has been retained
from the previous permit to ensure consistent operation and
treatment and to ensure water quality standards continue to be met.
TBEL
There is no applicable federal technology based effluent limit.
4.5 Nonconventional Pollutants: Outfall 001 & Instream Discussions
Pollutants of Concern Basis
WQBEL
Flow A consent decree (Civil Action No. 6:12-CV-00058) signed on
January 15, 2014, negotiated a settlement between King America
Finishing, Inc. and the Ogeechee-Canoochee Riverkeeper. The
consent decree included a condition limiting the instream waste
concentration to 8%. This condition was incorporated into the
facility's previous NPDES permit and has been retained in this
reissuance.
In addition, a 3.1 MGD daily average flow limit has been included
in the permit, to ensure that the facility's discharge volume remains
within the scope of what was considered in the permit development
process.
TBEL
There is no applicable federal technology based effluent limit.
Chemical Oxygen
Demand
WQBEL
A consent decree (Civil Action No. 6:12-CV-00058) signed on
January 15, 2014, negotiated a settlement between King America
Finishing, Inc. and the Ogeechee-Canoochee Riverkeeper. The
consent decree included a condition limiting the effluent's chemical
oxygen demand loading to 5,500 lbs/day daily average and 11,000
lbs/day daily maximum. This condition was incorporated into the
facility's previous NPDES permit and has been retained in this
reissuance for the Tier 2 and 3 effluent limitations. The more
stringent TBELs will be applied for the Tier 1 effluent limitations.
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April, 2022
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TBEL
The facility is subject to production -based effluent limitations in
accordance with 40 CFR 410.42(a) Best Practicable Control
Technology Currently Available (BPT). The permittee has
requested consideration of future production levels when
calculating production based TBELs, in anticipation that production
may increase to long-term production rates experienced in 2011.
The following effluent limitations have been calculated based on
three tiers of production. The TBELs will be included in the permit
for Tier 1, while the Tier 2 and 3 effluent limitations will include
the more stringent WQBELs.
Tier 1 (Average Production of Plant 1 < 97,939 lbs/day)
Daily Average (lbs/day): 5,328
Daily Maximum (lbs/day): 10,656
Tier 2 (97,939 lbs/day < Average Production of Plant 1 < 111,849
lbs/day)
Daily Average (lbs/day): 6,085
Daily Maximum (lbs/day): 12,169
Tier 3 (111,849 lbs/day < Average Production of Plant 1 <
128,116 lbs/day)
Daily Average (lbs/day): 6,970
Daily Maximum (lbs/day): 13,939
Dissolved Oxygen
WQBEL
A daily minimum dissolved oxygen limit of 5.0 mg/L has been
added to the permit in accordance with the wasteload allocation to
ensure that the water quality standards for dissolved oxygen are met.
TBEL
There is no applicable federal technology based effluent limit.
Total Dissolved Solids
(TDS)
WQBEL
A consent decree (Civil Action No. 6:12-CV-00058) signed on
January 15, 2014, negotiated a settlement between King America
Finishing, Inc. and the Ogeechee-Canoochee Riverkeeper. The
consent decree included a condition limiting the effluent's total
dissolved solids concentration to 2,500 mg/L daily average and
3,800 mg/L daily maximum. This condition was incorporated into
the facility's previous NPDES permit and has been retained in this
reissuance to ensure consistent operation and treatment.
TBEL
There is no applicable federal technology based effluent limit.
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Total Hardness
(as CaCO3)
WQBEL
The previous permit included downstream hardness monitoring in
order to characterize the receiving stream and in order to use site -
specific data when conducting a reasonable potential analysis for
hardness -dependent metals such as chromium, total. The hardness
data acquired from the previous permit term has sufficiently
characterized the receiving stream hardness, thus further hardness
sampling has not been required in the facility's NPDES permit.
TBEL
There is no applicable federal technology based effluent limit.
WQBEL
Specific Conductance GA does not have Water Quality Standards for specific
conductance. Conductivity is however a useful indicator of a
wastewater treatment system's performance as it indicates the
presence of inorganic dissolved solids such as nitrate, sulfate,
phosphate, sodium, magnesium, iron, aluminum, etc. which are
present in the discharge. Furthermore, conductivity is a useful
indicator of changes in a water system as streams tend to have a
relatively constant range of conductivity and significant changes of
conductivity may be indicative of a potential change in facility
operations or a change in the wastewater treatment system. Effluent
and instream monitoring have been retained from the previous
permit for continued characterization of the effluent and receiving
waters.
TBEL
There is no applicable federal technology based effluent limit.
Sodium
WQBEL
GA does not have Water Quality Standards for sodium. Effluent and
instream sampling were included in the previous permit as an
indicator of salinity and toxicity.
Salinity is the total concentration of all dissolved salts in the water
including, but not limited to dissolved sodium. As salinity is
dependent on the concentration of all dissolved salts, not just
sodium, the accuracy for predicting salinity based on sodium is low.
A more acceptable and widely used method for estimating salinity
is based on conductivity, as conductivity is indicative of a wider
range of inorganic dissolved solids. The use of conductivity for the
estimation of salinity in the effluent/receiving stream is
recommended.
In addition, because GA does not have numeric Water Quality
Standards specific to sodium nor has EPA specified a national
recommended aquatic life criterion for sodium; the usefulness of
sodium monitoring to predict toxicity is limited. As such, toxicity is
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better measured by the whole effluent toxicity testing required in
the permit. If toxicity is detected in the effluent, the permittee may
then be required to perform a toxicity identification and reduction
evaluation that may target specific constituents such as sodium.
For the reasons indicated above, EPD has removed both effluent and
instream monitoring for sodium.
TBEL
There is no applicable federal technology based effluent limit.
Peroxides
WQBEL
GA does not have Water Quality Standards for peroxides. Peroxides
are strong oxidizers and are often used as bleaching agents.
Peroxides have moderate toxicity but break down rapidly in water.
Effluent and instream monitoring of hydrogen peroxide was
included in the previous permit and hydrogen peroxide was
consistently non -detectable. Based on the results of the effluent and
instream analyses, monitoring has been removed from the permit.
TBEL
There is no applicable federal technology based effluent limit.
Sulfide
WQBEL
A consent decree (Civil Action No. 6:12-CV-00058) signed on
January 15, 2014, negotiated a settlement between King America
Finishing, Inc. and the Ogeechee-Canoochee Riverkeeper. The
consent decree included a condition limiting the effluent's sulfide
concentration to 1.5 mg/L daily average and 3.0 mg/L daily
maximum. This condition was incorporated into the facility's
previous NPDES permit and will be retained in this permit
reissuance.
GA does not have Water Quality Standards for sulfides. Sulfides are
constituents found in many types of industrial wastes. When soluble
sulfides are added to water, they react with hydrogen ions to form
HS or H2S, with H2S as the primary concern for toxicity. Instream
monitoring of sulfide was included in the previous permit and with
a result of non -detect for 48 of the 49 sampling events. Based on
these results, instream monitoring for sulfide has been removed
from the permit. Sulfides will continue to be controlled through
effluent limitations and WET testing.
TBEL
The facility is subject to production -based effluent limitations in
accordance with 40 CFR 410.42(a) Best Practicable Control
Technology Currently Available (BPT). The permittee has
requested consideration of future production levels when
calculating production based TBELs, in anticipation that production
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April, 2022
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may increase to long-term production rates experienced in 2011.
The following effluent limitations have been included in the permit
based on three tiers of production.
Tier 1 (Average Production of Plant 1 < 97,939 lbs/day)
Daily Average (lbs/day): 9.8
Daily Maximum (lbs/day): 19.6
Tier 2 (97,939 lbs/day < Average Production of Plant 1 < 111,849
lbs/day)
Daily Average (lbs/day): 11.2
Daily Maximum (lbs/day): 22.4
Tier 3 (111,849 lbs/day < Average Production of Plant 1
128,116 lbs/day)
Daily Average (lbs/day): 12.8
Daily Maximum (lbs/day): 25.6
<
WQBEL
Total Phenols There is no Georgia Water Quality Standard for total phenols.
TBEL
The facility is subject to production -based effluent limitations in
accordance with 40 CFR 410.42(a) Best Practicable Control
Technology Currently Available (BPT). The permittee has
requested consideration of future production levels when
calculating production based TBELs, in anticipation that production
may increase to long-term production rates experienced in 2011.
The following effluent limitations have been included in the permit
based on three tiers of production.
Tier 1 (Average Production of Plant 1 < 97,939 lbs/day)
Daily Average (lbs/day): 4.9
Daily Maximum (lbs/day): 9.8
Tier 2 (97,939 lbs/day < Average Production of Plant 1 < 111,849
lbs/day)
Daily Average (lbs/day): 5.6
Daily Maximum (lbs/day): 11.2
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 19

Tier 3 (111,849 lbs/day < Average Production of Plant 1 <
128,116 lbs/day)
Daily Average (lbs/day): 6.4
Daily Maximum (lbs/day): 12.8
Formaldehyde
WQBEL
A consent decree (Civil Action No. 6:12-CV-00058) signed on
January 15, 2014, negotiated a settlement between King America
Finishing, Inc. and the Ogeechee-Canoochee Riverkeeper. The
consent decree included a condition requiring the facility to report
the effluent's daily average and daily maximum concentration.
Although there is no numeric Georgia Water Quality Standard for
formaldehyde, EPD had additionally included a daily maximum
effluent limitation of 1.6 mg/L based on best professional
judgement. The daily maximum effluent limit was based on the
chronic aquatic life water quality criterion established in the
technical document Derivation of Ambient Water Quality Criteria
for Formaldehyde (2001) written by Hohreiter and Riggs. The
aquatic life criterion was developed in accordance with the US
EPA's Guidelines for Deriving Numerical National Water Quality
Criteria for the Protection of Aquatic Organisms and Their Uses
(1985).
This daily maximum effluent limitation of 1.6 mg/L and the
instream monitoring included in the previous permit have been
removed from this permit reissuance due to concerns of the validity
of effluent sample results due to matrix interference. Furthermore,
the maximum downstream concentration measured during the
previous term was 0.14 mg/L, indicating that the chronic aquatic
life water quality criterion is not being exceeded. Whole effluent
toxicity testing will serve to ensure that toxicity is not present in the
discharge. See Section 5.3 for discussion surrounding anti -
backsliding regulations.
TBEL
There is no applicable federal technology based effluent limit.
WQBEL
Tetrakis(hydroxylmethyl) A consent decree (Civil Action No. 6:12-CV-00058) signed on
phosphonium chloride January 15, 2014, negotiated a settlement between King America
(THPC) Finishing, Inc. and the Ogeechee-Canoochee Riverkeeper. The
consent decree included a condition requiring the facility to report
the effluent's THPC concentration twice monthly.
There is no Georgia Water Quality Standard for THPC; however,
Georgia elected to incorporate the conditions of the third -party
consent decree in the previous permit due to its use in the flame -
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
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retardant processing. The THPC concentration of the effluent has
not been tied to any toxicity concerns and the effluent monitoring
data cannot be compared against any water quality standard or
acute/chronic aquatic life criterion. EPD has therefore removed
THPC sampling from this permit reissuance. Whole effluent
toxicity testing will serve to ensure that toxicity is not present in the
discharge.
TBEL
There is no applicable federal technology based effluent limit.
WQBEL
Per- and Polyfluoroalkyl The previous permit included a special condition requiring the
Substances (PFAS) permittee to sample their effluent twice within 60 days of the
effective date of the permit for perfluorooctanesulfonic acid
(PFOS). In addition, if the sampling detected PFOS in the effluent,
a plan of study was required for annual fish testing. The results of
both sampling events for PFOS were non -detect and no fish tissue
testing was required.
The facility has phased out the use of C8 fluorochemistries related
to PFOS, replacing them with C6 fluorochemistries and thus PFOS
is not expected to be present in the effluent. While C8
fluorochemistries such as PFOS and perfluorooctanoic acid (PFOA)
are among the more notable per- and polyfluoroalkyl substances
(PFAS), they are only a subset of PFAS. PFAS also includes several
C6 fluorochemistries in addition to the C8 fluorochemistries noted
above.
On February 14, 2019, EPA announced a comprehensive PFAS
Action Plan to address PFAS contamination and protect the nation's
drinking water. There are no surface water drinking water intakes
in the downstream vicinity of King America Finishing, Inc.'s
discharge; however, in light of the ongoing research and concerns
surrounding PFAS, a special condition has been included in the
permit requiring a PFAS Characterization Study. The purpose of the
PFAS Characterization Study is to determine if the facility has the
potential to discharge PFAS into the environment through the
discharge of treated wastewater effluent or through industrial sludge
disposal. See Section 5.4 for further discussion.
TBEL
There is no applicable federal technology based effluent limit.
WQBEL
Color A consent decree (Civil Action No. 6:12-CV-00058) signed on
January 15, 2014, negotiated a settlement between King America
Finishing, Inc. and the Ogeechee-Canoochee Riverkeeper. The
consent decree included a condition limiting the maximum color
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
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difference between the Ogeechee River (upstream) and the effluent
to ADMI until EPD took action on the color study required in the
previous permit.
King America Finishing, Inc. submitted the results of their color
study in October of 2015. The results showed that the difference in
color between the Ogeechee River (upstream) and the final effluent
was -13 ADMI on average and a +36 ADMI maximum.
Additionally, the difference in color between the Ogeechee River
(upstream) and the Ogeechee River (downstream) was -1 ADMI on
average and a +6 ADMI maximum. This study complements the
instream sampling required in the previous permit which indicated
an average delta ADMI of 3.2 and a maximum delta ADMI of +15.
EPD has evaluated the results of the color study and has determined
there is no reasonable potential for the effluent to cause or
contribute to an in -stream violation of the GA narrative water
quality standard for color. As a result, the color limits included in
the previous permit have been removed. See Section 5.3 for
discussion surrounding anti -backsliding regulations.
The effluent color monitoring requirements have been retained to
ensure that the effluent characterization remains within the scope of
which was observed during the color study.
TBEL
There is no applicable federal technology based effluent limit.
Total Phosphorus
WQBEL
Per the Strategy for Addressing Phosphorus in NPDES Permitting
(2011) all routine permit reissuances must include phosphorus
monitoring.
TBEL
There is no applicable federal technology based effluent limit.
Orthophosphate, as P
WQBEL
Per the Strategy for Addressing Phosphorus in NPDES Permitting
(2011) and the corresponding Georgia's Plan for the Adoption of
Water Quality Standards for Nutrients (2013) as amended, all
routine permit reissuances that have discharges upstream from
reservoirs, lakes, impoundments, and/or estuaries must include
orthophosphate monitoring.
Effluent monitoring from 2013-2018 indicated that approximately
10% of the facility's total phosphorus loading is in the form of
orthophosphate. Orthophosphate monitoring will be retained in this
permit to ensure continued characterization of the discharge as the
State works to develop numeric nutrient criteria.
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 22

TBEL
There is no applicable federal technology based effluent limit.
Ammonia, as N
WQBEL
A consent decree (Civil Action No. 6:12-CV-00058) signed on
January 15, 2014, negotiated a settlement between King America
Finishing, Inc. and the Ogeechee-Canoochee Riverkeeper. The
consent decree included a condition limiting the effluent's total
ammonia concentration to 7 mg/L daily average and 13 mg/L daily
maximum. This condition was incorporated into the facility's
previous NPDES permit and has been retained in this permit to
prevent degradation of instream water quality.
In addition, mass -based effluent limitations of 181 lbs/day daily
average and 336 lbs/day daily maximum have been incorporated in
the permit based on the facility's permitted daily average flow and
the concentration -based effluent limitations noted above.
In addition, instream monitoring has been retained from the
previous permit to ensure instream ammonia concentrations do not
exceed the calculated chronic toxicity concentration of 1.08 mg/L
for Rainbow Mussels as a result of the discharge.
TBEL
There is no applicable federal technology based effluent limit.
WQBEL
Total Kjeldahl Nitrogen, Per "Georgia's Plan for the Adoption of Water Quality Standards
Organic Nitrogen, for Nutrients" (2013) as amended, EPD is working to develop water
Nitrate/Nitrite quality models throughout the State of Georgia. EPD is requiring all
point source discharges with the presence of ammonia to monitor
for total Kjeldahl nitrogen, organic nitrogen, and nitrate/nitrite and
to develop these models.
TBEL
There is no applicable federal technology based effluent limit.
Total Nitrogen
WQBEL
A consent decree (Civil Action No. 6:12-CV-00058) signed on
January 15, 2014, negotiated a settlement between King America
Finishing, Inc. and the Ogeechee-Canoochee Riverkeeper. The
consent decree included a condition requiring the facility to report
the effluent's total nitrogen concentration. This condition was
incorporated into the facility's previous NPDES permit and has
been retained in this permit to characterize nutrient loading.
TBEL
There is no applicable federal technology based effluent limit.
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 23

4.6 Toxics & Manmade Organic Compounds (126 priority pollutants and metals):
Outfall 001 and Instream Discussions
Pollutants of Concern Basis
Copper, Total
WQBEL
Based on the data submitted in the application, the reasonable
potential analysis showed there is no reasonable potential for the
discharge to cause or contribute to an instream violation of the
Georgia Water Quality Standard for copper.
TBEL
There is no applicable federal technology based effluent limit.
Zinc, Total
WQBEL
Based on the data submitted in the application, the reasonable
potential analysis showed there is no reasonable potential for the
discharge to cause or contribute to an instream violation of the
Georgia Water Quality Standard for zinc.
TBEL
There is no applicable federal technology based effluent limit.
Arsenic, Total
WQBEL
Based on the data submitted in the application, the reasonable
potential analysis showed there is no reasonable potential for the
discharge to cause or contribute to an instream violation of the
Georgia Water Quality Standard for arsenic.
TBEL
There is no applicable federal technology based effluent limit.
Mercury, Total
WOBEL
There was a TMDL developed for total mercury fish tissue in 2005
which is applicable to this segment of the Ogeechee River. King
America Finishing is listed in this TMDL and was given a wasteload
allocation of 6.0 ng/L for Total Hg and 0.05 ng/L for MeHg
equivalent to their effluent discharge during TMDL development.
The facility was also subject to mercury characterization and/or
minimization conditions.
The previous permit included special conditions requiring a six
month mercury characterization study, with an additional
requirement to develop a mercury minimization plan if the
characterization showed the average concentration of total mercury
was greater than 6.0 ng/L. Results of the mercury characterization
study showed an average concentration for total mercury of 0.73
ng/L; therefore, a minimization plan was not required and mercury
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 24

monitoring was reduced to twice per year for the remainder of the
permit term. In addition, the mercury sample submitted with the
application showed a concentration of 1.3 ng/L. To assure that
average total mercury concentrations remain below the 6.0 ng/L
wasteload allocation or the concentration of mercury in the source
water; whichever is greater, twice per year effluent and source water
monitoring has been established in this permit.
TBEL
There is no applicable federal technology based effluent limit.
Chromium, Total
WQBEL
Based on the data submitted in the application, the reasonable
potential analysis showed there is no reasonable potential for the
discharge to cause or contribute to an instream violation of the
Georgia Water Quality Standard for chromium. As a result, the
chromium concentration limits of 1.2 mg/L daily average and 2.0
mg/L daily maximum included in the previous permit have been
removed and replaced with monitoring. See Section 5.3 for
discussion surrounding anti -backsliding regulations.
TBEL
The facility is subject to production -based effluent limitations in
accordance with 40 CFR 410.42(a) Best Practicable Control
Technology Currently Available (BPT). The permittee has
requested consideration of future production levels when
calculating production based TBELs, in anticipation that production
may increase to long-term production rates experienced in 2011.
The following effluent limitations have been included in the permit
based on three tiers of production.
Tier 1 (Average Production of Plant 1 < 97,939 lbs/day)
Daily Average (lbs/day): 4.9
Daily Maximum (lbs/day): 9.8
Tier 2 (97,939 lbs/day < Average Production of Plant 1 < 111,849
lbs/day)
Daily Average (lbs/day): 5.6
Daily Maximum (lbs/day): 11.2
Tier 3 (111,849 lbs/day < Average Production of Plant 1 <
128,116 lbs/day)
Daily Average (lbs/day): 6.4
Daily Maximum (lbs/day): 12.8
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 25

4.7 Calculations for Water Quality Based Effluent Limits
4.7.a Instream Waste Concentration (IWC)(1)
IWC = Effluent Flow (gal/day)
Effluent Flow (gal/day) + 7Q10 (gal/day)
IWC = 3,100,000 (gal/day)
(3,100,000 (gal/day) +60,749,568 (gal/day))
IWC = 0.0486 or 4.86%
(1) The instream waste concentration (IWC) is calculated to be 4.86% based on the
permitted flow and anticipated 7Q10 flow values. During periods of river flow that
are below the 7Q10 value, the permit limits the IWC to no more than 8%.
4.7.b Biochemical Oxygen Demand (5-day)
The concentration -based effluent limits are based on the dissolved oxygen sag
(DOSAG) modeling results in the Wasteload Allocation dated July 20, 2018.
Daily Average = 30 mg/L
Daily Maximum = 2.0 x Daily Average (mg/L)(1)
Daily Maximum = 2.0 x 30 (mg/L)
Daily Maximum = 60 mg/L
(1) The daily maximum is determined by using a 2.0x multiplier on the daily average.
This multiplier is consistent with that used in 40 CFR 410 Subpart D Regulations
for BOD5.
4.8 Technology Based Effluent Limitation Calculations
There are several ways to calculate TBELs when developing case -by -case limitations.
EPD can use an approach consistent with the statistical approach EPA has used to develop
effluent guidelines or they can utilize several other mathematically and statistically
accepted approaches depending on characteristics of the data. In general, EPD utilizes
EPA's "NPDES Permit Writer Manual," September 2010, Section 5.2.3, "Case -by -Case
TBELs for Industrial Dischargers" and EPA's "Technical Support Document for Water
Quality Based Toxic Control," March 1991, Section 5.2, "Basis Principles of Effluent
Variability," as guidance to develop limits.
If applicable, when there is no federal technology based effluent limit EPD evaluates the
effluent data, operating records and discharge monitoring reports to calculate the long-term
average for the parameter. The long-term average is then used to derive the effluent limits.
EPD recognizes there are several ways to calculate technology -based limits and, when
applicable, may deviate from the general practice.
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 26

4.8.a Chemical Oxygen Demand (Production -Based Effluent Limitations)
Tier 1— Average Production of Plant 1 < 97,939 lbs/day
Daily Average
CODPIant 1= Average Production x Daily Average Production Factor
CODPiant i = 97,939 (lbs/day) x 0.030
CODPlant 1= 2,938.2 lbs/day
CODFinishing (Natural Fiber) = Average Production of Finished Natural Fiber x Daily
Average Production Factor
CODFinishing (Natural Fiber) = 27,423 (lbs/day) x 0.010
CODFinishing (Natural Fiber) = 274.2 (lbs/day)
CODFinishing (Complex Blend) = Average Production of Finished Complex Blend x Daily
Average Production Factor
CODFinishing (Complex Blend) = 70,516 (lbs/day) x 0.030
CODFinishing (Complex Blend) = 2,115.5 (lbs/day)
CODTota1= CODPlant 1 + CODFinishing (Natural Fiber) + CODFinishing (Complex Blend)
CODTota1 = 2,938.2 (lbs/day) + 274.2 (lbs/day) + 2,115.5 (lbs/day)
CODTota1= 5,327.9 (lbs/day)
Daily Maximum
CODPiant 1= Average Production x Daily Maximum Production Factor
CODPiant i = 97,939 (lbs/day) x 0.060
CODPlant 1= 5,876.3 lbs/day
CODFinishing (Natural Fiber) = Average Production of Finished Natural Fiber x Daily
Maximum Production Factor
CODFinishing (Natural Fiber) = 27,423 (lbs/day) x 0.020
CODFinishing (Natural Fiber) = 548.5 (lbs/day)
CODFinishing (Complex Blend) = Average Production of Finished Complex Blend x Daily
Maximum Production Factor
CODFinishing (Complex Blend) = 70,516 (lbs/day) x 0.060
CODFinishing (Complex Blend) = 4231.0 (lbs/day)
CODTota1 = CODPlant 1 + CODFinishing (Natural Fiber) + CODFinishing (Complex Blend)
CODTota1= 5,876.3 (lbs/day) + 548.5 (lbs/day) + 4231.0 (lbs/day)
CODTota1 = 10,655.8 (lbs/day)
See Appendix F for the complete set of calculations.
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 27

4.8.b Biochemical Oxygen Demands -day (Production -Based Effluent Limitations)
Tier 1— Average Production of Plant 1 < 97,939 lbs/day
Daily Average
BOD5 = Average Production x Daily Average Production Factor
BOD5 = 97,939 (lbs/day) x 0.0033
BOD5 = 323 (lbs/day)
Daily Maximum
BOD5 = Average Production x Daily Maximum Production Factor
BOD5 = 97,939 (lbs/day) x 0.0066
BOD5 = 646 (lbs/day)
See Appendix F for the complete set of calculations.
4.8.c Total Suspended Solids (Production -Based Effluent Limitations)
Tier 1— Average Production of Plant 1 < 97,939 lbs/day
Daily Average
TSS = Average Production x Daily Average Production Factor
TSS = 97,939 (lbs/day) x 0.0089
TSS = 872 (lbs/day)
Daily Maximum
TSS = Average Production x Daily Maximum Production Factor
TSS = 97,939 (lbs/day) x 0.0178
TSS = 1,743 (lbs/day)
See Appendix F for the complete set of calculations.
4.8.d Sulfide (Production -Based Effluent Limitations)
Tier 1 — Average Production of Plant 1 < 97,939 lbs/day
Daily Average
Sulfide = Average Production x Daily Average Production Factor
Sulfide = 97,939 (lbs/day) x 0.0001
Sulfide = 9.8 (lbs/day)
King America Finishing, Inc.
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April, 2022
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Daily Maximum
Sulfide = Average Production x Daily Maximum Production Factor
Sulfide = 97,939 (lbs/day) x 0.0002
Sulfide = 19.6 (lbs/day)
See Appendix F for the complete set of calculations.
4.8.e Total Phenols (Production -Based Effluent Limitations)
Tier 1— Average Production of Plant 1 < 97,939 lbs/day
Daily Average
Total Phenols = Average Production x Daily Average Production Factor
Total Phenols = 97,939 (lbs/day) x 0.00005
Total Phenols = 4.9 (lbs/day)
Daily Maximum
Total Phenols = Average Production x Daily Maximum Production Factor
Total Phenols = 97,939 (lbs/day) x 0.0001
Total Phenols = 9.8 (lbs/day)
See Appendix F for the complete set of calculations.
4.8.f Total Chromium (Production -Based Effluent Limitations)
Tier 1— Average Production of Plant 1 < 97,939 lbs/day
Daily Average
Total Chromium = Average Production x Daily Average Production Factor
Total Chromium = 97,939 (lbs/day) x 0.00005
Total Chromium = 4.9 (lbs/day)
Daily Maximum
Total Chromium = Average Production x Daily Maximum Production Factor
Total Chromium = 97,939 (lbs/day) x 0.0001
Total Chromium = 9.8 (lbs/day)
See Appendix F for the complete set of calculations.
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 29

4.9 Comparison & Summary of Water Quality vs. Technology Based Effluent Limits
After preparing and evaluating applicable technology -based effluent limitations and water
quality -based effluent limitations, the most stringent limits are applied in the permit.
Pollutants of concern with an effluent limit of monitor and report are not included in the
below table.
Outfall 001(1) — Process Water, Cooling Water, and Stormwater
Tier 1 — Average Production of Plant 1 < 97,939 lbs/day
Parameter WQBELs TBELs Explanation
Flow (MGD) 3.1 None WQBEL — WQS
IWC (%) 8 None WQBEL — WQS
5.0
Dissolved Oxygen (mg/L) (Daily Minimum) None WQBEL —WQS
BOD5 (lbs/day) N/A 323/646 TBEL — ELG
BOD5 (mg/L) 30/60 N/A WQBEL — WQS
COD (lbs/day) 5,500/11,000 5,328/10,656 TBEL — ELG
TSS (lbs/day) 650/1,160 872/1,743 WQBEL — WQS
Sulfide (lbs/day) None 9.8/19.6 TBEL — ELG
Sulfide (mg/L) 1.5/3.0 N/A WQBEL — Other(2)
TDS (mg/L) 2,500/3,800 None WQBEL — Other(2)
Total Phenols (lbs/day) None 4.9/9.8 TBEL — ELG
Mercury, Total (ng/L) 6.0/6.0(3) None WQBEL — TMDL
Chromium, Total (lbs/day) N/A 4.9/9.8 TBEL — ELG
Ammonia, as N (lbs/day) 181/336 None WQBEL — Other(2)
Ammonia, as N (mg/L) 7/13 None WQBEL — Other(2)
Fecal Coliform 200/400 None WQBEL — WQS
(#/100mL)
E. Coli (#/100mL)4 126/410 None WQBEL — WQS
pH (s.u.) 6.0 — 8.0 6.0 — 9.0 WQBEL — WQS
(1) Whole effluent toxicity limitations are outlined separately in the special conditions section.
(2) Effluent limitations based on a consent decree (Civil Action No. 6:12-CV-00058) signed on
January 15, 2014, which negotiated a settlement between King America Finishing, Inc. and the
Ogeechee-Canoochee Riverkeeper.
(3) The concentration of mercury in the effluent shall not exceed 6.0 ng/L or a concentration equal
to the concentration of mercury in the source water; whichever is greater.
(4) The e. coli effluent limitations are effective upon EPD's written authorization.
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 30

Tier 2 — 97,939 lbs/day < Average Production of Plant 1 < 111,849 lbs/day
Parameter
WQBELs
TBELs Explanation
Flow (MGD)
IWC (%)
Dissolved Oxygen (mg/L)
3.1
8
5.0
(Daily Minimum)
None
None
None
WQBEL — WQS
WQBEL — WQS
WQBEL —WQS
BOD5 (lbs/day)
BOD5 (mg/L)
COD (lbs/day)
TSS (lbs/day)
Sulfide (lbs/day)
Sulfide (mg/L)
TDS (mg/L)
Total Phenols (lbs/day)
Mercury, Total (ng/L)
Chromium, Total (lbs/day)
Ammonia, as N (lbs/day)
Ammonia, as N (mg/L)
Fecal Coliform
(#/100mL)
N/A
30/60
5,500/11,000
650/1,160
None
1.5/3.0
2,500/3,800
None
6.0/6.0(3)
N/A
181/336
7/13
369/738
N/A
6,085/12,169
995/1,991
11.2/22.4
N/A
None
5.6/11.2
None
5.6/11.2
None
None
200/400 None
TBEL —ELG
WQBEL — WQS
WQBEL — Other(2)
WQBEL — WQS
TBEL — ELG
WQBEL — Other(2)
WQBEL — Other(2)
TBEL — ELG
WQBEL — TMDL
TBEL — ELG
WQBEL — Other(2)
WQBEL — Other(2)
WQBEL — WQS
E. Coli (#/100mL)4 126/410
pH (s.u.) 6.0 — 8.0
None WQBEL — WQS
6.0 — 9.0 WQBEL — WQS
(1) Whole effluent toxicity limitations are outlined separately in the special conditions section.
(2) Effluent limitations based on a consent decree (Civil Action No. 6:12-CV-00058) signed on
January 15, 2014, which negotiated a settlement between King America Finishing, Inc. and the
Ogeechee-Canoochee Riverkeeper.
(3) The concentration of mercury in the effluent shall not exceed 6.0 ng/L or a concentration equal
to the concentration of mercury in the source water; whichever is greater.
(4) The e. coli effluent limitations are effective upon EPD's written authorization.
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 31

Tier 3 — 111,849 lbs/day < Average Production of Plant 1 < 128,116 lbs/day
Parameter WQBELs TBELs Explanation
Flow (MGD) 3.1 None WQBEL — WQS
IWC (%) 8 None WQBEL — WQS
5.0
Dissolved Oxygen (mg/L) (Daily Minimum) None WQBEL —WQS
BOD5 (lbs/day) N/A 423/846 TBEL — ELG
BOD5 (mg/L) 30/60 N/A WQBEL — WQS
COD (lbs/day) 5,500/11,000 6,970/13,939 WQBEL — Other(2)
TSS (lbs/day) 650/1,160 1,140/2,280 WQBEL — WQS
Sulfide (lbs/day) None 12.8/25.6 TBEL — ELG
Sulfide (mg/L) 1.5/3.0 N/A WQBEL — Other(2)
TDS (mg/L) 2,500/3,800 None WQBEL — Other(2)
Total Phenols (lbs/day) None 6.4/12.8 TBEL — ELG
Mercury, Total (ng/L) 6.0/6.0(3) None WQBEL — TMDL
Chromium, Total (lbs/day) N/A 6.4/12.8 TBEL — ELG
Ammonia, as N (lbs/day) 181/336 None WQBEL — Other(2)
Ammonia, as N (mg/L) 7/13 None WQBEL — Other(2)
Fecal Coliform 200/400 None WQBEL — WQS
(#/100mL)
E. Coli (#/100mL)4
pH (s.u.)
126/410 None WQBEL — WQS
6.0-8.0 6.0-9.0 WQBEL — WQS
(1) Whole effluent toxicity limitations are outlined separately in the special conditions section.
(2) Effluent limitations based on a consent decree (Civil Action No. 6:12-CV-00058) signed on
January 15, 2014, which negotiated a settlement between King America Finishing, Inc. and the
Ogeechee-Canoochee Riverkeeper.
(3) The concentration of mercury in the effluent shall not exceed 6.0 ng/L or a concentration equal
to the concentration of mercury in the source water; whichever is greater.
(4) The e. coli effluent limitations are effective upon EPD's written authorization.
5.0 OTHER PERMIT REQUIREMENTS AND CONSIDERATIONS
5.1 Special Conditions
a. Instream Waste Concentration
A consent decree (Civil Action No. 6:12-CV-00058) signed on January 15, 2014,
negotiated a settlement between King America Finishing, Inc. and the Ogeechee-
Canoochee Riverkeeper. The consent decree included a condition limiting the
instream waste concentration (IWC) to 8%. This condition was incorporated into
the facility's previous NPDES permit and has been retained in this reissuance as a
special condition. Monitoring at USGS Rocky Ford gage (#02202040) has been
included to ensure discharges do not exceed the IWC of 8%.
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b. Per- and Polyfluoroalkyl Substances (PFAS) Characterization Study
EPD has included a PFAS characterization study in the permit based on the industry
category of the facility. The purpose of the PFAS Characterization Study is to
determine if the facility has the potential to discharge PFAS into the environment
through the discharge of treated wastewater effluent or through industrial sludge
disposal.
c. Whole Effluent Toxicity (WET) Testing
Due to issues with historical toxicity from the discharge, acute and chronic whole
effluent toxicity (WET) testing and limitations have been required for both the
effluent and the receiving waterbody. Failure of two WET tests will trigger a
requirement to conduct a Toxicity Identification Evaluation (TIE) and Toxicity
Reduction Evaluation (TRE). The permit includes the minimum requirements for
conducting a TIE/TRE. Additionally, to ensure a TIE/TRE can be completed within
six months of a second WET test failure, the permit requires that the permittee
submit a TIE work plan proposal to EPD for review and approval within three
months of the effective date of the permit.
As part of the TIE work plan, the permittee is required to conduct four months of
phase I — toxicity characterization testing. The phase I testing will consist of
biweekly acute WET testing and weekly chronic testing of the fmal effluent for
ceriodaphnia dubia and pimephales promelas. For acute WET tests which exhibit
toxicity (i.e., LC50 < 100%) based on the initial baseline effluent toxicity test, and
for all chronic WET tests, toxicity characterization testing is required.
The following toxicity characterization tests are recommended by EPA for TIE's:
baseline effluent toxicity testing, EDTA chelation testing, sodium thiosulfate
addition testing, filtration testing, aeration testing, post Cis solid phase extraction
column testing, methanol eluate testing, and graduated pH testing. Additionally,
where toxicity information from the characterization tests is insufficient for
determining classes/groups of compounds contributing to effluent toxicity, a pH
adjustment test at 3 s.u. and 10 s.u. should be run independently and in concert with
the filtration, aeration, solid phase extraction, and methanol eluate tests. As part of
the TIE work plan approval, EPD will ensure that proposed plan includes the
procedures for conducting the recommended characterization tests discussed
above.
Additional elements of the TIE work plan should include identifying WET testing
procedures, establishing quality assurance (QA) and quality control (QC)
procedures for testing, and identifying the contract laboratory and/or consultants
responsible for sample analysis. Phase I testing often includes modified testing
procedures from the standard WET testing manuals. The TIE work plan will need
to identify the WET testing procedures and identify any proposed modifications to
test volumes, test durations, number of replicates, number of test concentrations,
reduced test solution renewals, etc.
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Phases II and III of a TIE include further toxicity identification and toxicity
confirmation procedures based on the results of the phase I testing. The permit
requires that phase II and phase III testing commence two months after the start of
phase I toxicity characterization testing and continue for two months coincident
with the second half of the phase I testing. The TIE work plan requires that the
permittee identify basic WET testing procedures and QA/QC procedures for phases
II and III. Ultimately, the full scope of the phase II and phase III testing will be
determined by the initial results of phase I testing and, outside of the initial work
plan, the permittee will be required to submit a report describing the procedures
which will be enacted for phase II and III testing based on the results of the first
two months of phase I testing.
In the event that a second WET test failure is experienced during the permit term,
the approved TIE work plan will be triggered, in addition to the TRE and additional
data gathering activities required to support the TIE/TRE.
The permit requires that the permittee submit a report which provides an in-depth
review of facility operations including the products produced, chemicals used,
facility engineering design, and wastewater treatment operations. Additionally, the
permittee is required to submit a report which provides an evaluation of
housekeeping practices, treatment plant operations, opportunities for chemical
optimization.
Following the completion of the TIE and additional data gathering activities, the
permittee is required to submit a TRE report. The report should identify the
proposed method for toxicity reduction, an evaluation and summation of reduction
methodologies considered, a selection of a reduction methodology, and an
implementation schedule for the proposed solution. Additionally, if the causative
agent approach was selected as the proposed method for toxicity reduction the
report should include a copy of the source identification evaluation.
The results of any TIE/TRE triggered by toxicity violations, as prescribed in Part
III.C.3 of the permit do not preclude compliance or enforcement action related to
toxicity violations of the permit. The minimum permit requirements and additional
guidance provided in the fact sheet regarding TIE/TREs and additional data
gathering activities are based on the following EPA guidance documents:
U.S. Environmental Protection Agency. 1989. Generalized Methodology for
Conducting Industrial Toxicity Reduction Evaluations (TREs). EPA/600/2-88/070.
U.S. Environmental Protection Agency, Chemicals and Chemical Product Branch
Risk Reduction Engineering Laboratory, Cincinnati, OH.
U.S. Environmental Protection Agency. 1991a. Methods for Aquatic Toxicity
Identification Evaluations: Phase I Toxicity Characterization Procedures, 2nd ed.,
EPA/600/6-91/003. U.S. Environmental Protection Agency, Office of Research and
Development, Environmental Research Laboratory, Duluth, MN.
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U.S. Environmental Protection Agency. 1992. Toxicity Identification Evaluation:
Characterization of Chronically Toxic Effluents, Phase I, EPA/600/6-91/005F.
U.S. Environmental Protection Agency, Office of Research and Development,
Environmental Research Laboratory, Duluth, MN.
U.S. Environmental Protection Agency. 1993a. Methods for Aquatic Toxicity
Identification Evaluation: Phase II Toxicity Identification Procedures for Acutely
and Chronically Toxic Samples. EPA/600/R-92/080. U.S. Environmental
Protection Agency, Office of Research and Development, Duluth, MN.
U.S. Environmental Protection Agency. 1993b. Methods for Aquatic Toxicity
Identification Evaluation: Phase III Toxicity Identification Procedures for Acutely
and Chronically Toxic Samples. EPA/600/R-92/081. U.S. Environmental
Protection Agency, Office of Research and Development, Duluth, MN.
The permit also includes a modified chronic WET test dilution series to increase
confidence in results near the IWC. The modified dilution series includes two
additional test concentrations to provide a more precise concentration -response
relationship near the IWC using a modified 0.5 dilution factor. The modified
dilution series is 0%, 2%, 4%, 8%, 16%, 32%, 64%, 100%.
Finally, the permit requires reporting of the IC25 for chronic WET tests. The IC25
will provide a point estimate as opposed to the hypothesis testing techniques used
for the determination of the NOEC. The NOEC will continue to be the statistical
endpoint utilized by Georgia EPD for the purposes of compliance, but the IC25 will
supplement the results of the WET testing.
d. Sludge Management Plan
On October 07, 2021, EPD approved a sludge management plan allowing for the
disposal of wastewater sludge by incineration or beneficial reuse as supplemental
kiln fuel. The sludge management plan has been incorporated into this permit
reissuance and approves disposal of wastewater sludge to the facilities listed below;
contingent upon their willingness and ability to accept the sludge in accordance
with their solid waste and hazardous waste permits.
Holcim (US) Inc.
200 Safety St., Hwy 453
Holy Hill, SC 29059
Hazardous Waste Permit No.: SCD 003 368 891
VLS Piedmont, LLC
305 South Main Street
Mauldin, SC 29662
Solid Waste Processing Permit No.: SCD 233730-2001
Covanta Environmental Solutions
3920 Goshen Industrial Blvd
Augusta, GA 30906
Solid Waste Handling Permit No.: 121-019P
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e. Notification of Increased Production
The permittee requested consideration of future production levels when calculating
production -based technology -based limits, in anticipation that production may
increase to the production rates experienced in 2011. EPD has included tiered
permit limits based on production levels to ensure that technology based effluent
limits accurately reflect production levels without restricting facility operations.
Tiered limits have been based on the permittee's average production rate over the
previous five years (Tier 1), the highest annual average production rate over the
previous five years (Tier 2), and the predicted return to the 2011 production rate
(Tier 3). The pollutant loading for all production tiers is within the scope of the
loading previously considered and permitted and would not trigger an anti -
degradation analysis.
The permit requires a notification of increased production when the permittee
expects to operate at higher level of production than Tier 1. The permittee is
required to notify the EPD compliance office in writing at least two business days
prior to the month they expect to operate at a higher level of production (higher
than Tier 1). The notice must specify the anticipated level and period during which
the permittee expects to operate at the increased level of production. Furthermore,
new notice is required to cover a period or production level not covered by prior
notice or, if during two consecutive months otherwise covered by a notice, the
production level at the permitted facility does not in fact meet the higher level of
production designated in the notice.
The notice of increased production has been required to provide clarity regarding
the status of compliance with the tier -based effluent limitations and is required for
coverage under Tiers 2 and 3. A notice of increased production does not alone grant
coverage for effluent limitations under a higher level of production (Tier 2 or Tier
3), but must be accompanied by reporting in the monthly discharge monitoring
report which indicates that the monthly average production levels qualify for
coverage based on the production levels established in Tiers 2 and 3.
5.2 Compliance Schedules
The permittee shall attain compliance with all limits, except e. coli, on the effective date of
the permit. The permit includes provisions to replace the fecal coliform effluent limitations
with e. coli effluent limitations during the permit term following EPA approval of the
proposed changes to the Georgia Rules for Water Quality Control, Chapter 391-3-6-.03
(Water Use Classifications and Water Quality Standards) for bacterial indicators. EPD will
provide written authorization to the permittee replacing the fecal coliform effluent
limitations with e. coli limitations once the proposed criteria have been approved.
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5.3 Anti -Backsliding
Total Suspended Solids
The limits in this permit are in compliance with 40 C.F.R. 122.44(1). 40 C.F.R.
122.44(1)(2)(i)(B)(2) states, permit limits may be less stringent if "The Administrator
determines that technical mistakes or mistaken interpretations of law were made in issuing
the permit under section 402(a)(1)(b)." King America Finishing, Inc. is subject to
production -based effluent limitations in accordance with 40 C.F.R. 410.42(a) which
establish mass -based effluent limitations for TSS. Additionally, King America Finishing,
Inc. is subject to Georgia's narrative Water Quality Standard for TSS. The 2013 permit
includes concentration based TSS effluent limitations using EPD's best professional
judgement (BPJ) based on limits applied to municipal wastewater treatment facilities
through 40 C.F.R. 133, Secondary Treatment Regulations. This approach is improper as it
effectively creates a technology -based effluent limit (TBEL) when a TBEL already exists
for the facility under 40 C.F.R. 410.42(a). Additionally, the concentration -based effluent
limitations do not qualify as water quality -based effluent limits (WQBELs), as they do not
represent a translation of Georgia's narrative Water Quality Standard for TSS but rather a
reasonable level of treatment expected from secondary treatment technology for POTWs.
Thus, the concentration -based effluent limitations for TSS have been removed from this
permit.
Formaldehyde
The limits in this permit are in compliance with 40 C.F.R. 122.44(1). 40 C.F.R.
122.44(1)(2)(i)(C) states, permit limits may be less stringent if "a less stringent effluent
limitation is necessary because of events over which the permittee has no control and for
which there is no reasonably available remedy." Additionally, 40 C.F.R.
122.44(1)(2)(i)(B)(1) states, permit limits may be less stringent if "Information is available
which was not available at the time of permit issuance (other than revised, regulations,
guidance, or test methods) and which would have justified the application of a less stringent
effluent limitation at the time of permit issuance. While Georgia does not have a numeric
water quality standard for formaldehyde, in the 2013 permit EPD derived aquatic life
criteria for formaldehyde in accordance with EPA's Guidelines for Deriving Numerical
National Water Quality Criteria for the Protection of Aquatic Organisms and Their Uses
and available data on aquatic toxicity. In accordance with the 2013 permit requirements,
King America Finishing, Inc. conducted daily formaldehyde sampling on the effluent using
EPA Method 8315A. EPA Method 8315A is a hazardous waste test method published by
the EPA in the SW-846 Compendium which was utilized by the facility to substitute EPA
40 C.F.R. 136 Method 1667A due to the limited commercial availability of Method 1667A
certified labs. Both methods analyze formaldehyde through the derivatization of aldehydes
using 2,4-dinitrophenylhydrazine (DNPH) in a sample buffered to a pH of 5. Following
derivatization, high performance liquid chromatography is performed to analyze the
formaldehyde concentration. Due to the similarity in both Methods and the lack of an
alternative analytical method, the ability to accurately determine formaldehyde
concentrations may be hindered by matrix interferences.
The analytical data for formaldehyde submitted by King America Finishing, Inc. has shown
considerable variability and has resulted in several exceedances resulting in a consent order
issued by EPD (EPD-WP-8321). As part of the consent order, King America, Inc.
King America Finishing, Inc.
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completed a Corrective Action Plan which included investigations of formaldehyde
exceedances. Investigations included an assessment of production operations that use
formaldehyde or formaldehyde -bearing compounds, an assessment of wastewater
treatment plant operations, an evaluation of formaldehyde analytical methods and
procedures, and consideration of alternative treatment technologies. The investigations
yielded minor operational changes but the presence of matrix interference due to co -
extraction of other matrix contaminants was identified as a significant concern. King
America Finishing, Inc. has since shortened the hold time of samples to reduce the
likelihood of interferences. The Method hold time allowed for 3 days between sampling
and preparation and an additional 3 days between preparation and analysis. This hold time
was shortened to allow for 2 days between sampling and preparation and no more than 1
day between preparation and analysis. Although this approach has served to reduce matrix
contamination, attempts to modify the Method to eliminate matrix contamination all
together have been unsuccessful in meeting the quality assurance and quality control
procedures outlined in the Method.
The permittee may continue to evaluate alternative methodologies as part of their
Corrective Action Plan (CAP); however, in light of the information presented above, there
may be no reasonably available remedy for correcting the matrix interference experienced
in the analytical sampling for formaldehyde. Furthermore, the presence of such matrix
interferences calls into question the suitability of formaldehyde sampling for the
determination of aquatic toxicity. Thus, EPD has removed the formaldehyde effluent
limitations. Any potential toxicity of the effluent will continue to be captured by the whole
effluent toxicity testing required in the permit which would capture any toxicity exhibited
by formaldehyde in the effluent as well as identify any potential additive and synergistic
effects of the effluent as a whole. This approach is consistent with Georgia EPD's NPDES
Reasonable Potential Procedures (2003) document which outlines procedures for
permitting chemical constituents for which numeric water quality criteria have not been
established.
Color
The limits in this permit are in compliance with 40 C.F.R. 122.44(1). 40 C.F.R.
122.44(1)(2)(i)(B)(1) states, permit limits may be less stringent if "Information is available
which was not available at the time of permit issuance (other than revised regulations,
guidance, or test methods) and which would have justified the application of a less stringent
effluent limitation at the time of permit issuance." In the 2013 permit reissuance, EPD
included color limitations from a third -party settlement (Civil Action No. 6:12-CV-00058)
as interim limitations until a color study was completed. A color study was completed by
King America Finishing, Inc. in October of 2015. The results showed that the difference in
color between the Ogeechee River (upstream) and the final effluent was -13 ADMI on
average and a +36 ADMI maximum. Additionally, the difference in color between the
Ogeechee River (upstream) and the Ogeechee River (downstream) was -1 ADMI on
average and a +6 ADMI maximum. This study complements the instream sampling
required in the previous permit which indicated an average delta ADMI of 3.2 and a
maximum delta ADMI of +15. The results of the color study indicate that there is no
reasonable potential for the effluent to cause or contribute to an in -stream violation of the
Georgia narrative water quality standard for color. Thus, EPD has removed the color
limitations in light of the additional information.
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Total Phenols
The limits in this permit are in compliance with 40 C.F.R. 122.44(1). 40 C.F.R.
122.44(1)(2)(i)(B)(2) states, permit limits may be less stringent if "The Administrator
determines that technical mistakes or mistaken interpretations of law were made in issuing
the permit under section 402(a)(1)(b)." King America Finishing, Inc. is subject to
production -based effluent limitations in accordance with 40 C.F.R. 410.42(a) which
establish mass -based effluent limitations for total phenols. The 2013 permit includes total
phenols effluent limitations using EPD's best professional judgement based on the
demonstrated performance of the facility. This approach is improper as it effectively
creates a technology -based effluent limit (TBEL) when a TBEL already exists for the
facility under 40 C.F.R. 410.42(a) which establishes a nationwide standard for
performance. The previous permit limitations have been replaced with the effluent
limitations established in 40 C.F.R. 410.42(a). The less stringent effluent limitations will
not result in a violation of a water quality standard based on the reasonable potential
analysis.
Chromium, Total
The limits in this permit are in compliance with 40 C.F.R. 122.44(1). 40 C.F.R.
122.44(1)(2)(i)(B)(1) states, permit limits may be less stringent if "Information is available
which was not available at the time of permit issuance (other than revised regulations,
guidance, or test methods) and which would have justified the application of a less stringent
effluent limitation at the time of permit issuance." In the 2013 permit reissuance, EPD
included water quality -based effluent limitations for chromium using the conservative
assumption that all chromium discharged was in the form of Chromium VI. The inclusion
of a water quality -based effluent limitation was not based on data that indicated a
reasonable potential for the facility to violate the Georgia Water Quality Standard for
chromium but was rather included in an abundance of caution due to the 2011 fish kill.
Sampling over the previous permit term and data provided in the permit application
provided 156 data points for Chromium to be used in EPD's reasonable potential analysis.
The results of the reasonable potential analysis indicate that there is no reasonable potential
for the discharge to cause or contribute to an instream violation of the Georgia Water
Quality Standard for chromium. Thus, in accordance with the reasonable potential analysis
procedures outlined in Ga. Comp. R. & Regs. 391-3-6-.06(4)(d)(5)(ii) the concentration -
based water quality -based effluent limitations have been removed from the permit.
5.4 Per- and Polyfluoroalkyl Substances (PFAS)
Per- and polyfluoroalkyl substances; hereafter named PFAS are a group of man-made
chemicals that have been identified by EPA as emerging chemicals of concern. These
synthetic chemicals are identified by their elemental bonds of fluorine and carbon. Such
elemental bonds are difficult to break and as a result PFAS has been identified to be very
persistent in the environment and bioaccumulate in living organisms. This is of concern,
as initial studies have indicated that exposure to such substances can lead to adverse health
effects in humans and animals such as: reproductive and developmental, liver and kidney,
and immunological effects in laboratory animals. In response to such concerns, on
February 14, 2019, EPA announced a comprehensive PFAS Action and published further
updates in February 2020. The action plan is a multi -media, multi -program, national
research, management, and risk communication plan to address PFAS in drinking water,
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identify and clean up PFAS contamination, expand monitoring of PFAS in manufacturing,
increase PFAS scientific research, and exercise effective enforcement tools. Of specific
interest during this permitting process are EPA's efforts to develop water quality criteria
for PFAS, identify industrial sources that may warrant further study and regulations, and
continued efforts to develop analytical methods.
Several industries, including textile mills, have been identified as potential contributors to
PFAS as part of their manufacturing process. In conjunction with the national response for
PFAS, EPD is working on furthering the objectives of the action plan on a state level. This
includes the development of a PFAS Characterization Study special condition to be
included in permits where discharges of PFAS are suspected. The purpose of the PFAS
Characterization Study is to determine if the facility has the potential to discharge PFAS
into the environment through the discharge of treated wastewater effluent or through
industrial sludge disposal. This special condition requires PFAS monitoring so that EPD
may ensure that state waters are free from toxic substances, in amounts, concentrations or
combinations which are harmful to humans, animals or aquatic life. This permit condition
is necessary and appropriate for the protection of Georgia water quality criteria in
accordance with GA. Comp. R. & Regs. 391-3-6-.03(5)(e).
6.0 REPORTING
The facility has been assigned to the following EPD office for reporting, compliance and
enforcement.
Georgia Environmental Protection Division
Coastal District Office
400 Commerce Center Drive
Brunswick, Georgia 31523-8251
6.1 E-Reporting
The permittee is required to electronically submit documents in accordance with 40 CFR
Part 127.
7.0 REQUESTED VARIANCES OR ALTERNATIVES TO REQUIRED STANDARDS
Not applicable
8.0 PERMIT EXPIRATION
The permit will expire five years from the effective date.
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9.0 PROCEDURES FOR THE FORMULATION OF FINAL DETERMINATIONS
9.1 Comment Period
The Georgia Environmental Protection Division (EPD) proposes to issue a permit to this
applicant subject to the effluent limitations and special conditions outlined above. These
determinations are tentative.
Georgia Environmental Protection Division
Wastewater Regulatory Program
2 Martin Luther King Jr. Drive
Suite 1152 East
Atlanta, Georgia 30334
The permit application, draft permit, and other information are available for review at 2
Martin Luther King Jr. Drive, Suite 1152 East, Atlanta, Georgia 30334, between the hours
of 8:00 a.m. and 4:30 p.m., Monday through Friday and on EPD's website accessible
through the publicly available Georgia EPD Online System (GEOS) at:
https : //geo s. epd. georgia. gov/GA/GEOS/Public/GovEnt/Shared/Pages/Main/Login. aspx.
For additional information, you can contact 404-463-1511.
9.2 Public Comments
Persons wishing to comment upon or object to the proposed determinations are invited to
submit same in writing to the EPD address above, or via e-mail at
[e-mail] within 30 days of the initiation of the public comment period.
All comments received prior to that date will be considered in the formulation of final
determinations regarding the application. The permit number should be placed on the top
of the first page of comments to ensure that your comments will be forwarded to the
appropriate staff.
9.3 Public Hearing
Any applicant, affected state or interstate agency, the Regional Administrator of the U.S.
Environmental Protection Agency (EPA) or any other interested agency, person or group
of persons may request a public hearing with respect to an NPDES permit application if
such request is filed within thirty (30) days following the date of the public notice for such
application. Such request must indicate the interest of the party filing the request, the
reasons why a hearing is requested, and those specific portions of the application or other
NPDES form or information to be considered at the public hearing.
The Director shall hold a hearing if he determines that there is sufficient public interest in
holding such a hearing. If a public hearing is held, notice of same shall be provided at least
thirty (30) days in advance of the hearing date.
In the event that a public hearing is held, both oral and written comments will be accepted;
however, for the accuracy of the record, written comments are encouraged. The Director
or a designee reserves the right to fix reasonable limits on the time allowed for oral
statements and such other procedural requirements, as deemed appropriate.
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Following a public hearing, the Director, unless it is decided to deny the permit, may make
such modifications in the terms and conditions of the proposed permit as may be
appropriate and shall issue the permit.
If no public hearing is held, and, after review of the written comments received, the
Director determines that a permit should be issued and that the determinations as set forth
in the proposed permit are substantially unchanged, the permit will be issued and will
become final in the absence of a request for a contested hearing. Notice of issuance or
denial will be made available to all interested persons and those persons that submitted
written comments to the Director on the proposed permit.
If no public hearing is held, but the Director determines, after a review of the written
comments received, that a permit should be issued but that substantial changes in the
proposed permit are warranted, public notice of the revised determinations will be given
and written comments accepted in the same manner as the initial notice of application was
given and written comments accepted pursuant to EPD Rules, Water Quality Control,
subparagraph 391-3-6-.06(7)(b). The Director shall provide an opportunity for public
hearing on the revised determinations. Such opportunity for public hearing and the
issuance or denial of a permit thereafter shall be in accordance with the procedures as are
set forth above.
9.4 Final Determination
At the time that any final permit decision is made, the Director shall issue a response to
comments. The issued permit and responses to comments can be found at the following
address:
http://epd.georgia. gov/watershed-protection-branch-permit-and-public-comments-
clearinghouse-0
9.5 Contested Hearings
Any person who is aggrieved or adversely affected by the issuance or denial of a permit by
the Director of EPD may petition the Director for a hearing if such petition is filed in the
office of the Director within thirty (30) days from the date of notice of such permit issuance
or denial. Such hearing shall be held in accordance with the EPD Rules, Water Quality
Control, subparagraph 391-3-6-.01.
Petitions for a contested hearing must include the following:
1. The name and address of the petitioner;
2. The grounds under which petitioner alleges to be aggrieved or adversely
affected by the issuance or denial of a permit;
3. The reason or reasons why petitioner takes issue with the action of the
Director;
4. All other matters asserted by petitioner which are relevant to the action in
question.
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Appendix A — Applicable Federal Regulations
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Displaying title 40, up to date as of 11/19/2021. Title 40 was last amended 11/19/2021.
ENHANCED CONTENT - TABLE OF CONTENTS
Part 410 Textile Mills Point Source Category
General Provisions
§ 410.00 Applicability.
§ 410.01 General definitions.
§ 410.02 Monitoring requirements. [Reserved]
Subpart A Wool Scouring Subcategory
§ 410.10 Applicability; description of the wool scouring subcategory.
§ 410.11 Specialized definitions.
§ 410.12 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
§ 410.13 Effluent limitations representing the degree of effluent reduction attainable by the application of the best available
technology economically achievable (BAT).
§ 410.14 Pretreatment standards for existing sources (PSES).
§ 410.15 New source performance standards (NSPS).
§ 410.16 Pretreatment standards for new sources (PSNS).
§ 410.17 Effluent limitations representing the degree of effluent reduction attainable by the application of the best conventional
pollutant control technology (BCT). [Reserved]
Subpart B Wool Finishing Subcategory 410.20 - 410.27
§ 410.20 Applicability; description of the wool finishing subcategory.
§ 410.21 Specialized definitions.
§ 410.22 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
§ 410.23 Effluent limitation representing the degree of effluent reduction attainable by the application of the best available
technology economically achievable (BAT).
§ 410.24 Pretreatment standards for existing sources (PSES).
§ 410.25 New source performance standards (NSPS).
§ 410.26 Pretreatment standards for new sources (PSNS).
§ 410.27 Effluent limitations representing the degree of effluent reduction attainable by the application of the best conventional
pollutant control technology (BCT). [Reserved]
Subpart C Low Water Use Processing Subcategory 410.30 - 410.37
§ 410.30 Applicability; description of the low water use processing subcategory.
§ 410.31 Specialized definitions.
§ 410.32 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
§ 410.33 Effluent limitations representing the degree of effluent reduction attainable by the application of the best available
technology economically achievable (BAT).
§ 410.34 Pretreatment standards for existing sources (PSES).
§ 410.35 New source performance standards (NSPS).
§ 410.36 Pretreatment standards for new sources (PSNS).
§ 410.37 Effluent limitations representing the degree of effluent reduction attainable by the application of the best conventional
pollutant control technology (BCT). [Reserved]
Subpart D Woven Fabric Finishing Subcategory 410.40 - 410.47
410.00 - 410.97
410.00 - 410.02
410.10 - 410.17

§ 410.40
§ 410.41
§ 410.42
§ 410.43
Applicability; description of the woven fabric finishing subcategory.
Specialized definitions.
Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
Effluent limitations representing the degree of effluent reduction attainable by the application of the best available
technology economically achievable (BAT).
§ 410.44 Pretreatment standards for existing sources (PSES).
§ 410.45 New source performance standards (NSPS).
§ 410.46 Pretreatment standards for new sources (PSNS).
§ 410.47 Effluent limitations representing the degree of effluent reduction attainable by the application of the best conventional
pollutant control technology (BCT). [Reserved]
Subpart E
§ 410.50
§ 410.51
§ 410.52
§ 410.53
§ 410.54
§ 410.55 New source performance standards (NSPS).
§ 410.56 Pretreatment standards for new sources (PSNS).
§ 410.57 Effluent limitations representing the degree of effluent reduction attainable by the application of the best conventional
pollutant control technology (BCT). [Reserved]
Subpart F Carpet Finishing Subcategory 410.60 - 410.67
§ 410.60 Applicability; description of the carpet finishing subcategory.
§ 410.61 Specialized definitions.
§ 410.62 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
Effluent limitations representing the degree of effluent reduction attainable by the application of the best available
technology economically achievable (BAT).
Pretreatment standards for existing sources (PSES).
New source performance standards (NSPS).
Pretreatment standards for new sources (PSNS).
410.50 - 410.57
§ 410.63
§ 410.64
§ 410.65
§ 410.66
Knit Fabric Finishing Subcategory
Applicability; description of the knit fabric finishing subcategory.
Specialized definitions.
Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
Effluent limitations representing the degree of effluent reduction attainable by the application of the best available
technology economically achievable (BAT).
Pretreatment standards for existing sources (PSES).
§ 410.67 Effluent limitations representing the degree of effluent reduction attainable by the application of the best conventional
pollutant control technology (BCT). [Reserved]
Subpart G Stock and Yarn Finishing Subcategory 410.70 - 410.77
§ 410.70 Applicability; description of the stock and yarn finishing subcategory.
§ 410.71 Specialized definitions. [Reserved]
§ 410.72 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
§ 410.73 Effluent limitations representing the degree of effluent reduction attainable by the application of the best available
technology economically achievable (BAT).
§ 410.74 Pretreatment standards for existing sources (PSES).
§ 410.75 New source performance standards (NSPS).
§ 410.76 Pretreatment standards for new sources (PSNS).
§ 410.77 Effluent limitations representing the degree of effluent reduction attainable by the application of the best conventional
pollutant control technology (BCT). [Reserved]
Subpart H Nonwoven Manufacturing Subcategory 410.80 - 410.87

§ 410.80 Applicability; description of the nonwoven manufacturing subcategory.
§ 410.81 Specialized definitions. [Reserved]
§ 410.82 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
§ 410.83 Effluent limitations representing the degree of effluent reduction attainable by the application of the best available
technology economically achievable (BAT).
§ 410.84 Pretreatment standards for existing sources (PSES).
§ 410.85 New source performance standards (NSPS).
§ 410.86 Pretreatment standards for new sources (PSNS).
§ 410.87 Effluent limitations representing the degree of effluent reduction attainable by the application of the best conventional
pollutant control technology (BCT). [Reserved]
Subpart I Felted Fabric Processing Subcategory 410.90 - 410.97
§ 410.90 Applicability; description of the felted fabric processing subcategory.
§ 410.91 Specialized definitions. [Reserved]
§ 410.92 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
§ 410.93 Effluent limitations representing the degree of effluent reduction attainable by the application of the best available
technology economically achievable (BAT).
§ 410.94 Pretreatment standards for existing sources (PSES).
§ 410.95 New source performance standards (NSPS).
§ 410.96 Pretreatment standards for new sources (PSNS).
§ 410.97 Effluent limitations representing the degree of effluent reduction attainable by the application of the best conventional
pollutant control technology (BCT). [Reserved]
Title 40
PART 410 - TEXTILE MILLS POINT SOURCE CATEGORY
Authority: Secs. 301, 304 (b), (c), (e), and (g), 306 (b) and (c), 307 (b) and (c), and 501 of the Clean Water Act (the Federal Water Pollution Control
Act Amendments of 1972, as amended by the Clean Water Act of 1977) (the "Act"); 33 U.S.C. 1311, 1314 (b), (c), (e), and (g), 1316 (b) and (c), 1317
(b) and (c), and 1361; 86 Stat. 186 et seq., Pub. L. 92-500; 91 Stat. 1567, Pub. L. 95-217.
Source: 47 FR 38819, Sept. 2, 1982, unless otherwise noted.
GENERAL PROVISIONS
§ 410.00 Applicability.
This part applies to any textile mill or textile processing facility which discharges or may discharge process wastewater pollutants to the waters of
the United States, or which introduces or may introduce process wastewater pollutants into a publicly owned treatment works.
§ 410.01 General definitions.
In addition to the definitions set forth in 40 CFR part 401, the following definitions apply to this part:
(a) Sulfide shall mean total sulfide (dissolved and acid soluble) as measured by the procedures listed in 40 CFR part 136.
(b) Phenols shall mean total phenols as measured by the procedure listed in 40 CFR part 136.
(c) Total Chromium shall mean hexavalent and trivalent chromium as measured by the procedures listed in 40 CFR part 136.
(d) The term commission finishing shall mean the finishing of textile materials, 50 percent or more of which are owned by others, in mills
that are 51 percent or more independent (i.e., only a minority ownership by company(ies) with greige or integrated operations); the mills
must process 20 percent or more of their commissioned production through batch, noncontinuous processing operations with 50
percent or more of their commissioned orders processed in 5000 yard or smaller lots.
(e) The term product, except where a specialized definition is included in the subpart, shall mean the final material produced or processed at
the mill.
§ 410.02 Monitoring requirements. [Reserved]

Subpart A - Wool Scouring Subcategory
§ 410.10 Applicability; description of the wool scouring subcategory.
The provisions of this subpart are applicable to process wastewater discharges resulting from the following types of textile mills: wool scouring,
topmaking, and general cleaning of raw wool.
§ 410.11 Specialized definitions.
In addition to the definitions set forth in 40 CFR part 401 and § 410.01 of this part, the following definitions apply to this subpart:
(a) The term wool shall mean the dry raw wool as it is received by the wool scouring mill.
(b) The term oil and grease shall mean total recoverable oil and grease as measured by the procedure listed in 40 CFR part 136.
(c) The term commission scouring shall mean the scouring of wool, 50 percent or more of which is owned by others, in mills that are 51
percent or more independent (i.e., only a minority ownership by company(ies) with greige or integrated operations); the mills must
process 20 percent or more of their commissioned production through batch, noncontinuous processing operations.
§ 410.12 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
(a) Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following
effluent limitations representing the degree of effluent reduction attainable by the application of the best practicable control technology
currently available (BPT):
Pollutant or pollutant
property
BPT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 lb) of wool
BOD5 10.6 5.3
COD 138.0 69.0
TSS 32.2 16.1
Oil and grease 7.2 3.6
Sulfide 0.20 0.10
Phenol 0.10 0.05
Total chromium 0.10 0.05
pH (1) (t)
1 Within the range 6.0 to 9.0 at all times.
(b) Additional allocations equal to the effluent limitations established in paragraph (a) of this section are allowed any existing point source
subject to such effluent limitations that scours wool through "commission scouring" as defined in § 410.11.
§ 410.13 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
available technology economically achievable (BAT).
(a) Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following
effluent limitations representing the degree of effluent reduction attainable by the application of the best available technology
economically achievable (BAT):
Pollutant or pollutant BAT limitations
property

Pollutant or pollutant
property
Maximum for any 1 Atkk3Jiamifaf5migwalues for 30 consecutive
day days
Maximum for any 1 Average of daily values for 30 consecutive
day days
Kg/kkg (or pounds per 1,000 Ib) of wool
COD 138.0 69.0
Sulfide 0.20 0.10
Phenols 0.10 0.05
Total chromium 0.10 0.05
(b) Additional allocations equal to the effluent limitations established in paragraph (a) of this section are allowed any existing point source
subject to such effluent limitations that scours wool through "commission scouring" as defined in § 410.11.
§ 410.14 Pretreatment standards for existing sources (PSES).
Any existing source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply
with 40 CFR part 403.
§ 410.15 New source performance standards (NSPS).
Any new source subject to this subpart must achieve the following new source performance standards (NSPS):
Pollutant or pollutant
property
Maximum for any 1
day
NSPS
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of wool
BOD5 3.6 1.9
COD 52.4 33.7
TSS 30.3 13.5
Sulfide 0.20 0.10
Phenols 0.10 0.05
Total chromium 0.10 0.05
pH (t) (t)
1 Within the range 6.0 to 9.0 at all times.
Note: Additional allocations for "commission scouring" are not available to new sources.
§ 410.16 Pretreatment standards for new sources (PSNS).
Any new source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply with 40
CFR part 403.
§ 410.17 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
conventional pollutant control technology (BCT). [Reserved]

Subpart B - Wool Finishing Subcategory
§ 410.20 Applicability; description of the wool finishing subcategory.
The provisions of this subpart are applicable to process wastewater discharges resulting from the following types of textile mills: wool finishers,
including carbonizing, fulling, dyeing, bleaching, rinsing, fireproofing, and other such similar processes.
§ 410.21 Specialized definitions.
In addition to the definitions set forth in 40 CFR part 401 and § 410.01 of this part, the following definition applies to this subpart:
(a) The term fiber shall mean the dry wool and other fibers as received at the wool finsihing mill for processing into wool and blended
products.
(b) [Reserved]
§ 410.22 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
(a) Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following
effluent limitations representing the degree of effluent reduction attainable by the application of the best practicable control technology
currently available (BPT):
Pollutant or pollutant
property
BOD5
COD
TSS
Sulfide
Phenol
Total chromium
BPT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pound per 1,000 Ib) of fiber
22.4
163.0
35.2
0.28
0.14
0.14
pH (1)
1 Within the range 6.0 to 9.0 at all times.
11.2
81.5
17.6
0.14
0.07
0.07
(1)
(b) Additional allocations equal to the effluent limitations established in paragraph (a) of this section are allowed any existing point source
subject to such effluent limitations that finishes wool or blended wool fabrics through "commission finishing" as defined in § 410.01.
§ 410.23 Effluent limitation representing the degree of effluent reduction attainable by the application of the best
available technology economically achievable (BAT).
(a) Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following
effluent limitations representing the degree of effluent reduction attainable by the application of the best available technology
economically achievable (BAT):
Pollutant or pollutant
property
BAT limitation
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of fiber

BAT limitation
Pollutant or pollutant
property
Maximum for any 1
day
Average of daily values for 30 consecutive
days
COD 163.0 81.5
Sulfide 0.28 0.14
Phenols 0.14 0.07
Total Chromium 0.14 0.07
(b) Additional allocations equal to the effluent limitations established in paragraph (a) of this section are allowed any existing point source
subject to such effluent limitations that finishes wool or blended wool fabrics through "commission finishing" as defined in § 410.01.
§ 410.24 Pretreatment standards for existing sources (PSES).
Any existing source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply
with 40 CFR part 403.
§ 410.25 New source performance standards (NSPS).
Any new source subject to this subpart must achieve the following new source performance standards (NSPS):
Pollutant or pollutant
property
BOD5
COD
TSS
Sulfide
Phenols
Total Chromium
pH
NSPS
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (pounds per 1,000 lb) of fiber
10.7
113.8
32.3
0.28
0.14
0.14
(1)
Note: Additional allocations for "commission finishers" are not available to new sources.
1 Within the range 6.0 to 9.0 at all times.
§ 410.26 Pretreatment standards for new sources (PSNS).
5.5
73.3
14.4
0.14
0.07
0.07
(1)
Any new source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply with 40
CFR part 403.
§ 410.27 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
conventional pollutant control technology (BCT). [Reserved]
Subpart C - Low Water Use Processing Subcategory
§ 410.30 Applicability; description of the low water use processing subcategory.

The provisions of this subpart are applicable to process wastewater discharges resulting from the following types of textile mills: yarn
manufacture, yarn texturizing, unfinished fabric manufacture, fabric coating, fabric laminating, tire cord and fabric dipping, and carpet tufting and
carpet backing. Rubberized or rubber coated fabrics regulated by 40 CFR part 428 are specifically excluded.
§ 410.31 Specialized definitions.
In addition to the definitions set forth in 40 CFR part 401 and § 410.01 of this part, the following definitions apply to this subpart:
(a) The term general processing shall mean the internal subdivision of the low water use processing subcategory for facilities described in §
410.30 that do not qualify under the water jet weaving subdivision.
(b) The term water jet weaving shall mean the internal subdivision of the low water use processing subcategory for facilities primarily
engaged in manufacturing woven greige goods through the water jet weaving process.
§ 410.32 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following effluent
limitations representing the degree of effluent reduction attainable by the application of the best available technology economically achievable
(BPT):
Pollutant or pollutant
property
BOD5
COD
TSS
ph
General Processing
BPT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (pounds per 1,000 lb) of product
1.4
2.8
1.4
1 Within the range 6.0 to 9.0 at all times.
Pollutant or pollutant
property
BOD5
COD
TSS
(1)
Water Jet Weaving
0.7
1.4
0.7
(1)
BPT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (pounds per 1,000 1Ib) of product
8.9
21.3
5.5
ph
1 Within the range 6.0 to 9.0 at all times.
§ 410.33 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
available technology economically achievable (BAT).
(1)
4.6
13.7
2.5
(1)

Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following effluent
limitations representing the degree of effluent reduction attainable by the application of the best available technology economically achievable
(BAT):
Pollutant or pollutant
property
COD
Pollutant or pollutant
property
COD
General Processing
BAT limitations
Maximum for any 1 Average of daily values for 30 consecutive
day days
Kg/kkg (pounds per 1,000 Ib) of product
2.8
Water Jet Weaving
BAT limitations
Maximum for any 1
day
1.4
Average of daily values for 30 consecutive
days
Kg/kkg (pounds per 1,000 Ib) of product
21.3 13.7
§ 410.34 Pretreatment standards for existing sources (PSES).
Any existing source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply
with 40 CFR part 403.
§ 410.35 New source performance standards (NSPS).
Any new source subject to this subpart must achieve the following new source performance standards (NSPS):
General Processing
Pollutant or pollutant
NSPS
property Maximum for any 1 Average of daily values for 30 consecutive
day days
Kg/kkg (pounds per 1,000 Ib) of product
BOD5 1.4 0.7
COD 2.8 1.4
TSS 1.4 0.7
pH
1 Within the range 6.0 to 9.0 at all times.
(1)
Water Jet Weaving
Pollutant or pollutant NSPS
property
(1)

Pollutant or pollutant
property
Maximum for any 1 AveralOBSdaily values for 30 consecutive
day days
Maximum for any 1 Average of daily values for 30 consecutive
day days
Kg/kkg (pounds per 1,000 Ib) of product
BOD5 8.9 4.6
COD 21.3 13.7
TSS 5.5 2.5
pH (1) (1)
1 Within the range 6.0 to 9.0 at all times.
§ 410.36 Pretreatment standards for new sources (PSNS).
Any new source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply with 40
CFR part 403.
§ 410.37 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
conventional pollutant control technology (BCT). [Reserved]
Subpart D - Woven Fabric Finishing Subcategory
§ 410.40 Applicability; description of the woven fabric finishing subcategory.
The provisions of this subpart are applicable to process wastewater discharges resulting from the following types of textile mills: woven fabric
finishers, which may include any or all of the following unit operations: Desizing, bleaching, mercerizing, dyeing, printing, resin treatment, water
proofing, flame proofing, soil repellency application and a special finish application.
§ 410.41 Specialized definitions.
In addition to the definitions set forth in 40 CFR part 401 and § 410.01 of this part the following definitions apply to this subpart:
(a) The term simple manufacturing operation shall mean all the following unit processes: Desizing, fiber preparation and dyeing.
(b) The term complex manufacturing operation shall mean "simple" unit processes (desizing, fiber preparation and dyeing) plus any
additional manufacturing operations such as printing, water proofing, or applying stain resistance or other functional fabric finishes.
(c) For NSPS (§ 410.45) the term desizing facilities shall mean those facilities that desize more than 50 percent of their total production.
These facilities may also perform other processing such as fiber preparation, scouring, mercerizing, functional finishing, bleaching,
dyeing and printing.
§ 410.42 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
(a) Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following
effluent limitations representing the degree of effluent reduction attainable by the application of the best practicable control technology
currently available (BPT):
Pollutant or pollutant
property
BPT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product

BPT limitations
Pollutant or pollutant
property
BOD5
COD
TSS
Sulfide
Phenol
Total Chromium
pH
Maximum for any 1
day
6.6
60.0
17.8
0.20
0.10
0.10
1 Within the range 6.0 to 9.0 at all times.
Average of daily values for 30 consecutive
days
3.3
30.0
8.9
0.10
0.05
0.05
(b) Except as provided in paragraph (e) of this section for commission finishing operations, the following limitations establish the quantity or
quality of pollutants or pollutant properties, controlled by this section and attributable to the finishing of woven fabrics through simple
manufacturing operations employing a synthetic fiber or through complex manufacturing operations employing a natural fiber, which
may be discharged by a point source subject to the provisions of this subpart, in addition to the discharge allowed by paragraph (a) of
this section.
Pollutant or pollutant
property
COD
BPT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
20.0 10.0
(c) Except as provided in paragraph (e) of this section for commission finishing operations, the following limitations establish the quantity or
quality of pollutants or pollutant properties, controlled by this section and attributable to the finishing of woven fabrics through simple
manufacturing operations employing a natural and synthetic fiber blend or through complex manufacturing operations employing a
synthetic fiber, which may be discharged by a point source subject to the provisions of this subpart, in addition to the discharge allowed
by paragraph (a) of this section.
Pollutant or pollutant
property
COD
BPT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
40.0 20.0
(d) Except as provided in paragraph (e) of this section for commission finishing operations, the following limitations establish the quantity or
quality of pollutants or pollutant properties, controlled by this section and attributable to the finishing of woven fabrics through complex
manufacturing operations employing a natural and synthetic fiber blend, which may be discharged by a point source subject to the
provisions of this subpart, in addition to the discharge allowed by paragraph (a) of this subpart.
Pollutant or pollutant
property
BPT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days

BPT limitations
Pollutant or pollutant
property
COD
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pound per 1,000 Ib) of product
60.0 30.0
(e) Additional allocations equal to the effluent limitations established in paragraphs (a), (b), (c), and (d) of this section are allowed any
existing point source subject to such effluent limitations that finishes woven fabrics through "commission finishing" as defined in §
410.01.
147 FR 38819, Sept. 2, 1982, as amended at 48 FR 39624, Sept. 1, 1983]
§ 410.43 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
available technology economically achievable (BAT).
(a) Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following
effluent limitations representing the degree of effluent reduction attainable by the application of the best available technology
economically achievable (BAT):
Pollutant or pollutant
property
BAT limitations
Maximum for any 1 Average of daily values for 30 consecutive
day days
Kg/kkg (or pound per 1,000 Ib) of product
COD 60.0 30.0
Sulfide 0.20 0.10
Phenols 0.10 0.05
Total Chromium 0.10 0.05
(b) Except as provided in paragraph (e) of this section for commission finishing operations, the following limitations establish the quantity or
quality of pollutants or pollutant properties, controlled by this section and attributable to the finishing of woven fabrics through simple
manufacturing operations employing a synthetic fiber or through complex manufacturing operations employing a natural fiber, which
may be discharged by a point source subject to the provisions of this subpart, in addition to the discharge allowed by paragraph (a) of
this section.
Pollutant or pollutant
property
COD
BAT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
20.0 10.0
(c) Except as provided in paragraph (e) of this section for commission finishing operations, the following limitations establish the quantity or
quality of pollutants or pollutant properties, controlled by this section and attributable to the finishing of woven fabrics through simple
manufacturing operations employing a natural and synthetic fiber blend or through complex manufacturing operations employing a
synthetic fiber, which may be discharged by a point source subject to the provisions of this subpart, in addition to the discharge allowed
by paragraph (a) of this section.
Pollutant or pollutant BAT limitations
property

Pollutant or pollutant
property
Maximum for any 1
day
Maximum for any 1
day
Atizadintitatirtiyaialues for 30 consecutive
days
Average of daily values for 30 consecutive
days
COD
Kg/kkg (or pounds per 1,000 Ib) of product
40.0 20.0
(d) Except as provided in paragraph (e) of this section for commission finishing operations, the following limitations establish the quantity or
quality of pollutants or pollutant properties, controlled by this section and attributable to the finishing of woven fabrics through complex
manufacturing operations employing a natural and synthetic fiber blend, which may be discharged by a point source subject to the
provisions of this subpart, in addition to the discharge allowed by paragraph (a) of this subpart.
Pollutant or pollutant
property
COD
BAT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
60.0 30.0
(e) Additional allocations equal to the effluent limitations established in paragraphs (a), (b), (c), and (d) of this section are allowed any
existing point source subject to such effluent limitations that finishes woven fabrics through "commission finishing" as defined in §
410.01.
[47 FR 38819, Sept. 2, 1982, as amended at 48 FR 39624, Sept. 1, 1983]
§ 410.44 Pretreatment standards for existing sources (PSES).
Any existing source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply
with 40 CFR part 403.
§ 410.45 New source performance standards (NSPS).
Any new source subject to this subpart must achieve the following new source performance standards (NSPS):
Pollutant or pollutant
property
BOD5
COD
TSS
Sulfide
Phenols
Total Chromium
Simple Manufacturing Operations
NSPS
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
3.3
41.7
8.8
0.20
0.10
0.10
1.7
26.9
3.9
0.10
0.05
0.05

NSPS
Pollutant or pollutant
property
Maximum for any 1
day
Average of daily values for 30 consecutive
days
pH1
1 Within the range 6.0 to 9.0 at all times.
Note: Additional allocations for "commission finishers" are not available to new sources.
Complex Manufacturing Operations
Pollutant or pollutant
property
BOD5
COD
TSS
Sulfide
Phenols
Total Chromium
pH1
NSPS
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
3.7
68.7
14.4
0.20
0.10
0.10
(1)
1 Within the range 6.0 to 9.0 at all times.
Note: Additional allocations for "commission finishers" are not available to new sources.
Desizing
Pollutant or pollutant
property
BOD5
COD
TSS
Sulfide
Phenols
Total Chromium
pH
1.9
44.2
6.4
0.10
0.05
0.05
(1)
NSPS
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
5.5
59.5
15.6
0.20
0.10
0.10
2.8
38.3
6.9
0.10
0.05
0.05
1 Within the range 6.0 to 9.0 at all times.

NOTE: Additional allocations for "commission finishers" are not available to new sources.
§ 410.46 Pretreatment standards for new sources (PSNS).
Any new source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply with 40
CFR part 403.
§ 410.47 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
conventional pollutant control technology (BCT). [Reserved]
Subpart E - Knit Fabric Finishing Subcategory
§ 410.50 Applicability; description of the knit fabric finishing subcategory.
The provisions of this subpart are applicable to process wastewater discharges resulting from the following types of textile mills: knit fabric
finishers, which may include any or all of the following unit operations: Bleaching, mercerizing, dyeing, printing, resin treatment, water proofing,
flame proofing, soil repellency application and a special finish application.
§ 410.51 Specialized definitions.
In addition to the definitions set forth in 40 CFR part 401 and § 410.01 of this part, the following definitions apply to this subpart:
(a) The term simple manufacturing operation shall mean all the following unit processes: desizing, fiber preparation and dyeing.
(b) The term complex manufacturing operation shall mean "simple" unit processes (desizing, fiber preparation and dyeing) plus any
additional manufacturing operations such as printing, water proofing, or applying stain resistance or other functional fabric finishes.
(c) For NSPS (§ 410.55) the term hosiery products shall mean the internal subdivision of the knit fabric finishing subcategory for facilities
that are engaged primarily in dyeing or finishing hosiery of any type.
§ 410.52 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
(a) Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following
effluent limitations representing the degree of effluent reduction attainable by the application of the best practicable control technology
currently available (BPT):
Pollutant or pollutant
property
BOD5
COD
TSS
Sulfide
Phenols
Total chromium
BPT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 lb) of product
5.0
60.0
21.8
0.20
0.10
0.10
pH (1)
1 Within the range 6.0 to 9.0 at all times.
2.5
30.0
10.9
0.10
0.05
0.05
c)
(b) Except as provided in paragraph (d) of this section for commission finishing operations, the following limitations establish the quantity
or quality of pollutants or pollutant properties, controlled by this section and attributable to the finishing of knit fabrics through simple
manufacturing operations employing a natural and synthetic fiber or through complex manufacturing operations employing a synthetic

fiber, which may be discharged by a point source subject to the provisions of this subpart, in addition to the discharge allowed by
paragraph (a) of this section.
Pollutant or pollutant
property
COD
BPT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
20.0 10.0
(c) Except as provided in paragraph (d) of this section for commission finishing operations, the following limitations establish the quantity
or quality of pollutants or pollutant properties, controlled by this section and attributable to the finishing of knit fabrics through complex
manufacturing operations employing a natural and synthetic fiber blend, which may be discharged by a point source subject to the
provisions of this subpart, in addition to the discharge allowed by paragraph (a) of this section.
Pollutant or pollutant
property
COD
BPT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
40.0 20.0
(d) Additional allocations equal to the effluent limitations established in paragraphs (a), (b), and (c) of this section are allowed any existing
point source subject to such effluent limitations that finishes knit fabrics through "commission finishing" as defined in § 410.01.
[47 FR 38819, Sept. 2, 1982, as amended at 48 FR 39624, Sept. 1, 1983]
§ 410.53 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
available technology economically achievable (BAT).
(a) Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following
effluent limitations representing the degree of effluent reduction attainable by the application of the best available technology
economically achievable (BAT):
Pollutant or pollutant
property
COD
Sulfide
Phenols
Total Chromium
BAT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
60.0
0.20
0.10
0.10
30.0
0.10
0.05
0.05
(b) Except as provided in paragraph (d) of this section for commission finishing operations, the following limitations establish the quantity
or quality of pollutants or pollutant properties, controlled by this section and attributable to the finishing of knit fabrics through simple
manufacturing operations employing a natural and synthetic fiber or through complex manufacturing operations employing a synthetic
fiber, which may be discharged by a point source subject to the provisions of this subpart, in addition to the discharge allowed by
paragraph (a) of this section.
Pollutant or pollutant
property
BAT limitations

Pollutant or pollutant
property
Maximum for any 1
day
Maximum for any 1
day
Atizadintitatirtiyaialues for 30 consecutive
days
Average of daily values for 30 consecutive
days
COD
Kg/kkg (or pounds per 1,000 Ib) of product
20.0 10.0
(c) Except as provided in paragraph (d) of this section for commission finishing operations, the following limitations establish the quantity
or quality of pollutants or pollutant properties, controlled by this section and attributable to the finishing of knit fabrics through complex
manufacturing operations employing a natural and synthetic fiber blend, which may be discharged by a point source subject to the
provisions of this subpart, in addition to the discharge allowed by paragraph (a) of this section.
Pollutant or pollutant
property
COD
BAT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
40.0 20.0
(d) Additional allocations equal to the effluent limitations established in paragraphs (a), (b), and (c) of this section are allowed any existing
point source subject to such effluent limitations that finishes knit fabrics through "commission finishing" as defined in § 410.01.
[47 FR 38819, Sept. 2, 1982, as amended at 48 FR 39624, Sept. 1, 1983]
§ 410.54 Pretreatment standards for existing sources (PSES).
Any existing source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply
with 40 CFR part 403.
§ 410.55 New source performance standards (NSPS).
Any new source subject to this subpart must achieve the following new source performance standards (NSPS):
Pollutant or pollutant
property
BOD5
COD
TSS
Sulfide
Phenols
Total chromium
Simple Manufacturing Operations
NSPS
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
3.6
48.1
13.2
0.20
0.10
0.10
1.9
31.0
5.9
0.10
0.05
0.05
pH (1) (1)

1 Within the range 6.0 to 9.0 at all times.
NOTE: Additional allocations for "commission finishers" are not available to new sources.
Complex Manufacturing Operations
Pollutant or pollutant
property
BOD5
COD
TSS
Sulfide
Phenols
Total Chromium
pH
NSPS
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
4.8
51.0
12.2
0.20
0.10
0.10
2.5
32.9
5.4
0.10
0.05
0.05
(1_)
1 Within the range 6.0 to 9.0 at all times.
NOTE: Additional allocations for "commission finishers" are not available to new sources.
Hosiery Products
Pollutant or pollutant
property
Maximum for any 1
day
NSPS
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
BOD5 2.3 1.2
COD 19.8
TSS 3.7
Sulfide 0.10
Phenols 0.05
Total Chromium 0.05
pH (1_) (1_)
1 Within the range 6.0 to 9.0 at all times.
NOTE: Additional allocations for "commission finishers" are not available to new sources.
§ 410.56 Pretreatment standards for new sources (PSNS).
Any new source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply with 40
CFR part 403.
30.7
8.4
0.20
0.10
0.10

§ 410.57 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
conventional pollutant control technology (BCT). [Reserved]
Subpart F - Carpet Finishing Subcategory
§ 410.60 Applicability; description of the carpet finishing subcategory.
The provisions of this subpart are applicable to process wastewater discharges resulting from the following types of textile mills: carpet mills,
which may include any or all of the following unit operations: Bleaching, scouring, carbonizing, fulling, dyeing, printing, resin treatment,
waterproofing, flameproofing, soil repellency, looping, and backing with foamed and unfoamed latex and jute. Carpet backing without other carpet
manufacturing operations is included in subpart C.
§ 410.61 Specialized definitions.
In addition to the definitions set forth in 40 CFR part 401 and § 410.01 of this part, the following definitions apply to this subpart:
(a) The term product shall mean the final carpet produced or processed including the primary backing but excluding the secondary backing.
(b) The term simple manufacturing operation shall mean the following unit processes: fiber preparation and dyeing with or without carpet
backing.
(c) The term complex manufacturing operation shall mean "simple" unit processes (fiber preparation, dyeing and carpet backing) plus any
additional manufacturing operations such as printing or dyeing and printing.
§ 410.62 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
(a) Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following
effluent limitations representing the degree of effluent reduction attainable by the application of the best practicable control technology
currently available (BPT):
Pollutant or pollutant
property
BPT limitations
Maximum for any 1 Average of daily values for 30 consecutive
day days
Kg/kkg (or pounds per 1,000 lb) of product
BOD5 7.8 3.9
COD 70.2 35.1
TSS 11.0 5.5
Sulfide 0.08 0.04
Phenol 0.04 0.02
Total Chromium 0.04 0.02
pH (1) (1)
1 Within the range 6.0 to 9.0 at all times.
(b) The following limitations establish the quantity or quality of pollutants or pollutant properties, controlled by this section and attributable
to the manufacture of carpets through complex manufacturing operations, which may be discharged by a point source subject to the
provisions of this subpart, in addition to the discharge allowed by paragraph (a) of this section.
Pollutant or pollutant
property
Maximum for any 1
day
BPT limitations
Average of daily values for 30 consecutive
days

BPT limitations
Pollutant or pollutant
property
COD
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
20.0 10.0
§ 410.63 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
available technology economically achievable (BAT).
(a) Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following
efflluent limitations representing the degree of effluent reduction attainable by the application of the best available technology
economically achievable (BAT):
Pollutant or pollutant
property
COD
Sulfide
Phenols
Total chromium
BAT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
70.2
0.08
0.04
0.04
35.1
0.04
0.02
0.02
(b) The following limitations establish the quantity or quality of pollutants or pollutant properties, controlled by this section and attributable
to the manufacture of carpets through complex manufacturing operations, which may be discharged by a point source subject to the
provisions of this subpart, in addition to the discharge allowed by paragraph (a) of this section.
Pollutant or pollutant
property
COD
BAT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
20.0 10.0
§ 410.64 Pretreatment standards for existing sources (PSES).
Any existing source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply
with 40 CFR part 403.
§ 410.65 New source performance standards (NSPS).
Any new source subject to this subject must achieve the following new source performance standards (NSPS):
Pollutant or pollutant
property
NSPS limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
kg/kkg (or pounds per 1,000 Ib) of product

NSPS limitations
Pollutant or pollutant
property
BOD5
COD
TSS
Sulfide
Phenols
Total chromium
pH
Maximum for any 1
day
4.6
26.6
8.6
0.08
0.04
0.04
1 Within the range 6.0 to 9.0 at all times.
Average of daily values for 30 consecutive
days
NOTE: Additional allocations for "commission finishers" are not available to new sources.
§ 410.66 Pretreatment standards for new sources (PSNS).
2.4
17.1
3.8
0.04
0.02
0.02
Any new source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply with 40
CFR part 403.
§ 410.67 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
conventional pollutant control technology (BCT). [Reserved]
Subpart G - Stock and Yarn Finishing Subcategory
§ 410.70 Applicability; description of the stock and yarn finishing subcategory.
The provisions of this subpart are applicable to process wastewater discharges resulting from the following types of textile mills: Stock or yarn
dyeing or finishing, which may include any or all of the following unit operations and processes: Cleaning, scouring, bleaching, mercerizing, dyeing
and special finishing.
§ 410.71 Specialized definitions. [Reserved]
§ 410.72 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
(a) Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following
effluent limitations representing the degree of effluent reduction attainable by the application of the best practicable control technology
currently available (BPT):
Pollutant or pollutant
property
BOD5
COD
TSS
BPT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 lb) of product
6.8
84.6
17.4
3.4
42.3
8.7

BPT limitations
Pollutant or pollutant
property
Sulfide
Phenol
Total chromium
pH
Maximum for any 1
day
0.24
0.12
0.12
1 Within the range 6.0 to 9.0 at all times.
(b) [Reserved]
Average of daily values for 30 consecutive
days
0.12
0.06
0.06
§ 410.73 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
available technology economically achievable (BAT).
Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following effluent
limitations representing the degree of effluent reduction attainable by the application of the best available technology economically achievable
(BAT):
Pollutant or pollutant
property
COD
Sulfide
Phenols
Total chromium
BAT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
84.6
0.24
0.12
0.12
§ 410.74 Pretreatment standards for existing sources (PSES).
42.3
0.12
0.06
0.06
Any existing source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply
with 40 CFR part 403.
§ 410.75 New source performance standards (NSPS).
Any new source subject to this subpart must achieve the following new source performance standards (NSPS):
Pollutant or pollutant
property
BOD5
COD
TSS
Sulfide
NSPS
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
3.6
33.9
9.8
0.24
1.9
21.9
4.4
0.12

NSPS
Pollutant or pollutant
property Maximum for any 1 Average of daily values for 30 consecutive
day days
Phenols 0.12 0.06
Total chromium 0.12 0.06
pH (1) (1)
1 Within the range 6.0 to 9.0 at all times.
NOTE: Additional allocations for "commission finishers" are not available to new sources.
§ 410.76 Pretreatment standards for new sources (PSNS).
Any new source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply with 40
CFR part 403.
§ 410.77 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
conventional pollutant control technology (BCT). [Reserved]
Subpart H - Nonwoven Manufacturing Subcategory
§ 410.80 Applicability; description of the nonwoven manufacturing subcategory.
The provisions of this subpart are applicable to process wastewater discharges resulting from facilities that primarily manufacture nonwoven
textile products of wool, cotton, or synthetics, singly or as blends, by mechanical, thermal, and/or adhesive bonding procedures. Nonwoven
products produced by fulling and felting processes are covered in subpart I - Felted Fabric Processing.
§ 410.81 Specialized definitions. [Reserved]
§ 410.82 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following effluent
limitations representing the degree of effluent reduction attainable by the application of the best practicable control technology currently available
(BPT):
BPT limitations
Pollutant or pollutant
property Maximum for any 1 Average of daily values for 30 consecutive
day days
Kg/kkg (or pounds per 1,000 lb) of product
BOD5 4.4 2.2
COD 40.0 20.0
TSS 6.2 3.1
Sulfide 0.046 0.023
Phenol 0.023 0.011
Total chromium 0.023 0.011
pH

1 Within the range 6.0 to 9.0 at all times.
§ 410.83 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
available technology economically achievable (BAT).
Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following effluent
limitations representing the degree of effluent reduction attainable by the application of the best available technology economically achievable
(BAT):
Pollutant or pollutant
property
COD
Sulfide
Phenols
Total chromium
BAT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
40.0
0.046
0.023
0.023
§ 410.84 Pretreatment standards for existing sources (PSES).
20.0
0.023
0.011
0.011
Any existing source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply
with 40 CFR part 403.
§ 410.85 New source performance standards (NSPS).
Any new source subject to this subpart must achieve the following new source performance standards (NSPS):
Pollutant or pollutant
property
BOD5
COD
TSS
Sulfide
Phenols
Total Chromium
pH
NSPS
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
2.6
15.2
4.9
0.046
0.023
0.023
1 Within the range 6.0 to 9.0 at all times.
NOTE: Additional allocations for "commission finishers" are not available to new sources.
§ 410.86 Pretreatment standards for new sources (PSNS).
1.4
9.8
2.2
0.023
0.011
0.011
Any new source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply with 40
CFR part 403.

§ 410.87 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
conventional pollutant control technology (BCT). [Reserved]
Subpart I - Felted Fabric Processing Subcategory
§ 410.90 Applicability; description of the felted fabric processing subcategory.
The provisions of this subpart are applicable to process wastewater discharges resulting from facilities that primarily manufacture nonwoven
products by employing fulling and felting operations as a means of achieving fiber bonding.
§ 410.91 Specialized definitions. [Reserved]
§ 410.92 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
practicable control technology currently available (BPT).
Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following effluent
limitations representing the degree of effluent reduction attainable by the application of the best practicable control technology currently available
(BPT):
Pollutant or pollutant
property
BOD5
COD
TSS
Sulfide
Phenol
Total chromium
pH
1 Within the range 6.0 to 9.0.
§ 410.93 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
available technology economically achievable (BAT).
BPT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
35.2
256.8
55.4
0.44
0.22
0.22
17.6
128.4
27.7
0.22
0.11
0.11
Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this subpart must achieve the following effluent
limitations representing the degree of effluent reduction attainable by the application of the best available technology economically achievable
(BAT):
Pollutant or pollutant
property
COD
Sulfide
Phenols
BAT limitations
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 Ib) of product
256.8
0.44
0.22
128.4
0.22
0.11

BAT limitations
Pollutant or pollutant
property
Total Chromium
Maximum for any 1
day
Average of daily values for 30 consecutive
days
0.22 0.11
§ 410.94 Pretreatment standards for existing sources (PSES).
Any existing source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply
with 40 CFR part 403.
§ 410.95 New source performance standards (NSPS).
Any new source subject to this subpart must achieve the following new source performance standards (NSPS):
Pollutant or pollutant
property
BOD5
COD
TSS
Sulfide
Phenols
Total Chromium
pH
NSPS
Maximum for any 1
day
Average of daily values for 30 consecutive
days
Kg/kkg (or pounds per 1,000 lb) of product
16.9
179.3
50.9
0.44
0.22
0.22
1 Within the range of 6.0 to 9.0 at all times.
(1)
Note: Additional allocations for "commission finishers" are not available to new sources.
§ 410.96 Pretreatment standards for new sources (PSNS).
8.7
115.5
22.7
0.22
0.11
0.11
(1)
Any new source subject to this subpart that introduces process wastewater pollutants into a publicly owned treatment works must comply with 40
CFR part 403.
§ 410.97 Effluent limitations representing the degree of effluent reduction attainable by the application of the best
conventional pollutant control technology (BCT). [Reserved]

Appendix B — Wasteload Allocation
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 44

National Pollutant Discharge Elimination System
Wasteload Allocation Form
Part I: Background Information _
WLA Request Type: Relasuance. ® Expansion 0
Facility Name: King America Finishing WPCP
NPDES Permit No.: GA0003280
Receiving Water. Ogeechee River
Relocation 0
County:
Expiration Date:
River Basin:
Modification 0
WQMU: 0291
Outfall Number 001
10-Digit HUC: 0308020203
Manual bar screening, neutralization, activated sludge, sedimentation, cloth media filter, granulated
Additional information: (history,- special conditions, other facilities): treatment plant to a newly Installed septic tank eyerem.
Requested by: Ian McDowell Title: EE Program: WRP
Telephone: [phone] Date: 5/2/2018
Part II: Receiving Water inforrnation
Receiving Water: Ogeechee River Designated Use Classification: Fishing
. Integrated 305(b)1303(d) List: Yes ® No ❑ Partial Support: 0 Not Support ® Criteria: TWR
Total Maximum Daily Load: Yee ® No 0 Parameter(s) Mercury (Hg) WLA Complies with TMDL Yee ® No 0
EPA 2005 TMDL for Total Mercury Fish Tissue In Ogesches River assigned a Tots' Hg concentration of 6.0 nglL to the facility. 2013 WLA I
• recommended the facility to conduct a mercury characterization or minimization study. King America performed a six month Influent
and affluent Hg monitoring and submitted a report In 2014. The data Indicated average Hg concentration was 0.73 nglL In source water
and a0.50 noiL In final effluent. Since these levels were well below the 8.0 threshold, no H minimbattion plan was ulred.
New Discharge 0
Screven
11/30/2018
Ogeechee River
Discharge s its.: Domestic ❑ Industrial ® Both 0 Proh elrtion (D:1): Flow(s) Requested (MGD): 3.1
Industrial Contributions rype;si: Preparation, dyeing, and finishing of woven cotton syntheticicotton blended fabrics
Treatment Process Description: activated carbon; sludge lagoons- landfill
In 2015, the facility redirected all sanitary sewage from the wastewater
•
Part III: Water Quality Model Review Information
Model Type: Uncalibrated 0 Calibrated IS Verified 0 Cannot be Modeled 0
Field Data: None ❑ Fair .? Good ❑ Excellent 0
Model and Field Data Description: Steady-state dlssohred oxygen Georgia DOSAG model
Critical Water Temperature:rC): 28 Drainage Area (mi'): 2129 Mean annual streamflow at discharge (cis): 1767
7Q10 Yield (dslmI : 0.044 Velocity (range fps): 0.5 — 0.6 30Q3 streamflow at discharge (da): 213
Effluent Flow Rats {oy): 4.8 NC (%): 4.9 7Q10 streamflow at discharge (cfs): 94
Slope (range - fpm): 0.3 — 2.4 K1: 0.02 K3: 0.06 K2 : 0.2 -1.0 1010 streamflow at discharge (ds): 89
I. SOD: 0.6 Ebr�p Coef. (ft''): 0.054 f-Ratio BOD1JBODa): 2 Li, :.. round Hardness i as CaCOa)(r-1.. ): 36
I[' The predicted minimum dissolved oxygen Is 5.5 mglL, occurring 5 to 7 miles downstrsem from the discharge location. The streamflow
. Information has been updated referencing USGS flow station 02202500 (1937-2018), Ogeechee River at U.S. Hwy 80 near Eden, approx.
58 miles downstream from the discharge cuffed. Hardness value Is calculated from the facll , 's Instream monitorin. data 2013-2018
Model Length (ml): 96
Part IV: Recomrn nded Permit Limitations and Conditions (ibelday as a daily average except as noted)
Rationale: Same as current 0 Revised r[5'� New 0
Location: Ogeechee River
Effluent '"Fecal
Flow Rate "BODe
!MGM
Monitor 778
Ammonia
(n L)
7.0
DO
(minimum)
ONO-)
5.0 6.0 — 9.0 200
Collform
. N0.MOpmi
pH
(etd. units)
Total
Phosphorus
r. ;.L
Monitor Monitor Monitor Monitor
Nitrite -
Nitrate
Organic
Nitrogen
I mg I. i
TiW
OW
Additional Comments:
• Priority pollutant permit limits, aquatic toxicity testing requirements, and other parameters required by categorical effluent guidelines
• or Identified during review of permit application are to be detemdned by WRP.
- *The BODs load of 776 Wahl equivalents to 30 mg/L.
• • **Fecal Collfonn limit Is recommended based on presence of fecal In the facility's DMR data.
. Current ammonia limit meets the U.S. EPA's Aquatic Life Ambient Water Quality Criteria for Ammonia -Freshwater 2013 under the 7Q10
stream flow condition.
. Effluent monitoring of TKN, nitrate -nitrite, and organic nitrogen Is recommended. Those nitrogen constituents should be analyzed
from the same effluent sample. Organic nitrogen should be calculated as TKN minus NHS,
• Effluent monitoring for Ortho-P has been removed after reviewing of effluent phosphorus data (2013. 2018). The results have shown an
approximately 10% of Total-P In the facility's effluent Is Ortho-P.
Prepared by: Lucy Sun Date: 6121/2018 Revleured Josh Waite Date:
imp... -
Part V:
i/
Program Manager Comments
Georgia Department a Nair Resources
Environmental Protection Division
Atlanta, Georgia

Appendix C — Reasonable Potential Analysis
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 45

Reasonable Potential Analysis for Freshwater
Stream Data:
Receiving stream Hardness:
Upstream TSS:
7Q10:
1410:
35
10
94
60,749,568
89
57,518,208
mg/L
mg/L
ft3/s
gal/day
ft3/s
gal/day
Permit Name: King America Finishing, Inc.
NPDES Permit No.: GA0003280
Effluent Data:
Flow
TSS
3,100,000
59
gal/day
mg/L
Instream TSS: 12.38 mg/L
Acute Dilution factor: 19.55
Chronic Dilution factor: 20.60
Water Quality Criteria:
Mean annual streamflow at discharge:
Dilution factor:
IWC
1,767
1,141,962,624
369.375
4.855162058
ft3/s
gal/day
Flow (gal/day)
IWC -
Flow (gal ,day, 7Q10(gal/day)
Acute Water Quality Criteria (WQCA,,,)
Metal
Ko °
a
f°
Maximum
effluent CT
(pg/L)
Instream Co
(pg/L)
WQC ncu,e
(pg/L)
Action needed?
Arsenic
4.80.E+05
-0.729
0.51
78
2.05
340.00
no
Cadmium
4.00.E+06
-1.131
0.000
0
0.00
0.67
no
Chromium III
3.36.E+06
-0.930
0.00
0
0.00
241.15
no
Chromium VI
3.36.E+06
-0.930
0.00
0
0.00
16.00
no
Copper
1.04.E+06
-0.744
0.34
10
0.17
5.00
no
Lead
2.80.E+06
-0.800
0.00
0
0.00
20.25
no
Mercury
NA
NA
NA
0.0013
0.0001
1.40
no
Nickel
4.90.E+05
-0.572
0.00
0
0.00
192.64
no
Zinc
1.25.E+06
-0.704
0.28
241
3.39
48.14
no
■
Pole Min = 1Q0 (%)+ Flay (%)(gVegY
Chronic Water Quality Criteria (WQCchron;,)
Metal
Kp°
a
f°
Average effluent
(pg/L)
Instream C°
(pg/L)
WQC Chronic
(Pg/L)
Action needed?
Arsenic
4.80.E+05
-0.729
0.51
78
1.94
150.00
no
Cadmium
4.00.E+06
-1.131
0.000
0
0.00
0.33
no
Chromium III
3.36.E+06
-0.930
0.00
0
0.00
31.37
no
Chromium VI
3.36.E+06
-0.930
0.00
0
0.00
11.00
no
Copper
1.04.E+06
-0.744
0.34
10
0.16
3.65
no
Lead
2.80.E+06
-0.800
0.00
0
0.00
0.79
no
Mercury
NA
NA
NA
0.0013
0.0001
0.012
no
Nickel
4.90.E+05
-0.572
0.00
0
0.00
21.40
no
Zinc
1.25.E+06
-0.704
0.28
241
3.22
48.54
no
Selenium
NA
NA
NA
0
0.00
5.00
no
fn -
1+Kpo x TSS,os,<,,,,(mg/L)('')x 10-6
1
Instream Co = Effluent Cr(mg/L)x fp mg/L
DF
Chronic Dilution Factor =
7Q10 \g/� /+Flow (gal/ /
Flow
/ d ,
Human Health Water Quality Criteria (WQCa°,,,a°aaam+)
Metal
Km
a
f °
Maximum effluent
C r
(pg/L)
Instream CoWQC
(µg/U
cn,en;<
(pg/L)
Action needed.
?
Arsenic
4.00.E+05
-0.729
0.51
78
0.11
50.00
no
Total Recoverable Effluent Limit
Metal
Cs
(pg/L)
Chronic CT
(µg/L)
30-Day Avg
Chronic CT
(Ibs/day)
30-Day Avg
Acute CT
(pg/L)
Daily Max
Acute CT
(Ibs/day)
Daily Max
Arsenic
0.0
N/A
N/A
N/A
N/A
Cadmium
0.0
N/A
N/A
N/A
N/A
Chromium III
0.0
N/A
N/A
N/A
N/A
Chromium VI
0.0
N/A
N/A
N/A
N/A
Copper
0.0
N/A
N/A
N/A
N/A
Lead
0.0
N/A
N/A
N/A
N/A
Mercury
0.0
N/A
N/A
N/A
N/A
Nickel
0.0
N/A
N/A
N/A
N/A
Zinc
0.0
N/A
N/A
N/A
N/A
Selenium
0.0
N/A
N/A
--
--
NOTES:
(1) Chronic and acute total recoverable metal effluent concentration (CT) from EPA 823-B-96-007, June 1996, page 33:
(2) Assuming background dissolved metal concentration (Cs) in the stream is 0 pg/L, equations above become:
NOTES:
*Water Quality Criteria (WQC) from State of Georgia Rules and Regulations 391-3-6-.03.
End of report
(1)
(2)
WQC"COax(QH+1Q10)-(1Q10xCs)
AcuteCT = fD
QE
WQC cmmx (Qe+ 7Q10)- (7Q1(1r Cs)
Chronic C., = fO
Qe
WQC x(Qe+1Q10)
Acute CT - fD
Q.
Chronic CT
WQC x (Qa+7Q 0)
fr,
Qe

Reasonable Potential Analysis for Freshwater
Stream Data:
Receiving stream Hardness:
Upstream T55:
7Q10:
1Q10
35
10
94
60,749,568
89
57,518,208
mg/L
mg/L
ft3/s
gal/day
ft3/s
gal/day
Permit Name: King America Finishing, Inc.
NPDES Permit No.: GA0003280
Effluent Data:
Flow
TSS
3,100,000
59
Water Quality Criteria:
gal/day Mean annual stream0ow at discharge:I 1,767 Ift3/s
mg/L 1,141,962,624 gal/day
Dilution factor: 369.375
Instream TSS: 12.38 mg/L
Acute Dilution factor: 19.55
Chronic Dilution factor: 20.60
Water Quality Criteria (WQC)
Nonmetal
Effluent
Concentration
(pg/L)
Instream
Concentration
(pg/L)
WQC
(pg/L)
WQC/2
(pg/L)
Actionneeded?
Cyanide(Chronic)
18.0
0.87
5
2.6
no
Phenols(Chronic)
46.00
2.23
300
150
no
Phenols( Human Health)
150.0
0.41
857000
428500
no
NOTES:
*Water Quality C iteria (WQC) from State of Georgia Rules and Regulations 391-3-6-.03.
End of report

Ammonia Reasonable Potential Analysis
General Information
Facility
Permit #
Staff
Date
King America Finishing, Inc.
GA0003280
McDowell
23.May.19
Upstream Conditions
Basis
Flow, Qs
Concentration, Cs
213.00 cfs
0.03 mg/L
Qstream (30Q3) as determined by WPMP
background concentration generally —0.13 mg/L or as specified by WPMP
MEINIETIREEZEIr
Flow, Qd
Flow, Qd
Concentration, Cd
IWC
2.770 MGD
4.29 cfs
7.00 mg/L
2.0 %
effluent flow rate
effluent flow rate
permitted daily average concentration
instream waste concentration
Predicted Downstream
Basis
Flow, Qr
Concentration, Cr
Applicable Criteria
Ratio
RP
Action
217.29 cfs
0.17 mg/L
1.08 mg/L
16 %
No
None
calculated combined flow
calculated instream concentration
instream toxicity criteria as determined by WPMP
predicted instream concentration as % of criteria
is there reasonable potential to exceed criteria?
what is appropriate permitting action?
Exhibit 6-14 Example of applying mass -balance equation to conduct reasonable potential
analysis for conservative pollutant under conditions of rapid and complete mixing
Upstream
(Qs, Cs)
06,
Discharge
(0d7 Cd)
ABC Inc.
uurroo
Downstream
(Qr, Cr)
Pristine Creek
Mass -Balance Equation: QsCs + QdCd = QrCr
Dividing both sides of the mass -balance equation by Qr gives the following:
C _ (Qd)(Cd)+(Qs)(Cs)
Qr

Appendix D — Performance -Based Reductions
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 46

Performance -Based Reductions of NPDES Permit Monitoring Frequencies
King America Finishing, Inc.
GA0003280
Permit Requirements
Monitoring Data
Compliance History
Performance History
Parameter
Baseline Monitoring
Monthly Average Limit'
(Ibs/day)
Monthly Average Limit'
(mg/L)
Time Period
Long Term Average
(Ibs/day)
Long Term Average
(mg/L)
# of SNCs in the Past 2 Years
# of Violations in the Past Year
Ratio (Mass)
Ratio (Conc.)
Most Stringent Ratio
Proposed Monitoring
BOD5
5/Week
323
30
4/1/2017 - 04/01/2019
93
6
0
0
29%
20%
29%
5/Week'
COD
5/Week
5,328
--
4/1/2017 - 04/01/2019
3410
--
0
0
64%
--
64%
5/Week3
TSS
5/Week
650
--
4/1/2017 - 04/01/2019
91
6
0
0
14%
--
14%
1/Week
Sulfide
7/Week
9.8
1.5
4/1/2017 - 04/01/2019
3.20
0.20
0
0
33%
14%
33%
3/Week
Total Ammonia
7/Week
181
7
4/1/2017 - 04/01/2019
23.91
1.55
0
5
13%
22%
22%
7/Week
Total Phenols
1/Week
4.9
--
4/1/2017 - 04/01/2019
0.3
--
0
0
5%
--
5%
1/2Mos
Total Chromium
1/Week
4.9
--
4/1/2017 - 04/01/2019
0.16
0.01
0
0
3%
--
3%
1/2Mos
' The monthly average limits are from the proposed draft permit
2 The monitoring frequency of BOD5 has not been reduced as historical data occassionally exceeded the proposed daily maximum effluent limitations
3 COD is a useful indicator of wastewater treatment efficiency and process controls, thus the COD monitoring frequency has not been reduced due to other effluent limitation exceedance experienced at the facility
https://www3.epa.gov/npdes/pubs/perf-red.pdf
Page 1 of 1

Appendix E — WET Testing Results
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 47

Historical Data (2015-2019)- WET Testing Results
King America Finishing, Inc.
GA0003280
Date
Effluent Data
In -Stream Data (25 feet downstream)
Acute Whole Effluent Toxicity
Chronic Whole Effluent Toxicity
Acute Whole Effluent Toxicity
Chronic Whole Effluent Toxicity
Cerlodaphnla dubla
Pimephales Promelas
Cerlodaphnla dubla
Pimephales Promelas
Cerlodaphnla dubla
Pimephales Promelas
Cerlodaphnla dubla
12/1/2013
100
—
—
—
—
12/3/2013
100
—
—
—
—
--
--
12/5/2013
100
--
—
—
100
—
—
12/10/2013
100
—
—
—
—
12/12/2013
100
100
6
—
—
100
--
12/13/2013
--
--
—
100
—
--
100
12/16/2013
100
—
--
—
—
—
—
12/18/2013
100
--
—
—
—
--
--
12/23/2013
100
—
—
—
—
—
—
12/27/2013
100
—
—
—
—
—
—
1/1/2014
100
—
—
—
—
—
—
1/3/2014
100
—
65
--
--
—
--
1/6/2014
100
—
—
—
100
—
—
1/8/2014
100
—
—
—
—
—
—
1/10/2014
—
—
25
—
—
—
100
1/13/2014
100
—
—
—
--
—
—
1/15/2014
100
—
—
—
—
—
—
1/20/2014
100
—
—
—
--
—
—
1/22/2014
100
—
—
—
—
—
—
1/27/2014
100
--
--
--
--
--
--
1/30/2014
100
—
—
--
—
—
2/3/2014
50
—
—
—
100
—
—
2/6/2014
100
--
—
—
—
—
—
2/10/2014
60
—
—
—
100
—
--
2/13/2014
100
--
--
—
—
—
—
2/17/2014
52
—
—
—
--
2/19/2014
40
--
--
—
—
—
—
2/21/2014
—
—
6
—
100
—
100
2/24/2014
100
--
--
—
100
—
—
2/25/2014
100
—
—
—
100
—
—
2/26/2014
100
—
--
—
100
—
—
2/27/2014
100
—
—
—
100
--
—
2/28/2014
100
—
50
--
100
—
--
3/1/2014
100
—
—
—
100
—
—
3/2/2014
100
—
—
—
100
—
—
3/3/2014
100
—
80
—
100
100
100
3/4/2014
100
—
—
—
100
—
—
3/5/2014
100
—
—
—
100
—
—
3/10/2014
100
100
—
50
—
—
—
3/13/2014
100
—
—
—
—
—
—
3/17/2014
100
—
—
—
—
—
—
3/19/2014
100
—
—
—
—
—
—
3/24/2014
100
—
—
—
—
—
—
3/26/2014
100
—
—
—
—
—
—
3/31/2014
100
—
—
--
--
—
4/1/2014
--
—
25
—
—
--
100
4/2/2014
100
—
—
—
100
--
—
4/7/2014
100
—
—
—
—
4/9/2014
100
—
—
—
—
--
--
4/14/2014
100
—
—
—
—
4/16/2014
100
—
--
—
—
--
--
4/21/2014
100
—
—
—
—
4/23/2014
100
—
—
—
—
—
--
4/28/2014
100
--
--
—
—
--
—
4/30/2014
100
—
—
—
--
—
--
5/5/2014
100
—
80
—
100
—
100
5/7/2014
100
—
—
—
—
—
—
5/12/2014
100
—
—
—
--
—
—
5/14/2014
100
—
—
—
—
—
—
5/19/2014
100
—
—
--
--
—
--
5/21/2014
100
—
—
—
—
—
—
5/27/2014
100
--
--
--
5/28/2014
100
—
—
—
—
—
—
6/2/2014
100
—
74
—
—
—
100
6/3/2014
100
—
—
—
—
—
—
6/4/2014
100
--
—
—
100
100
—
6/5/2014
100
—
—
—
—
—
—
6/6/2014
100
—
—
—
—
6/7/2014
100
—
—
—
—
--
--
6/8/2014
100
—
—
—
—
6/9/2014
_
100
—
84
100
—
--
100
6/10/2014
100
—
—
—
—
6/11/2014
100
—
—
—
100
—
--
6/12/2014
100
--
—
—
—
—
6/13/2014
100
—
—
—
—
—
--
6/14/2014
100
—
—
—
—
6/15/2014
100
—
--
—
—
--
--
6/16/2014
100
—
46
—
—
--
100
6/17/2014
100
—
--
—
—
—
—
6/18/2014
100
—
—
—
—
6/19/2014
100
—
—
—
—
--
--
6/20/2014
100
100
—
—
100
—
—
6/21/2014
100
—
—
—
—
—
—
6/22/2014
100
—
—
—
—
6/23/2014
100
—
52
—
—
--
100
6/24/2014
100
—
—
—
—
6/25/2014
100
—
--
—
100
--
--
6/26/2014
100
—
—
—
—
—
—
6/27/2014
100
—
--
—
—
—
—
6/28/2014
100
—
—
—
—
—
—
6/29/2014
100
—
—
—
—
—
—
6/30/2014
100
—
—
—
—
—
—
7/1/2014
100
—
—
—
—
—
—
7/2/2014
100
--
—
—
100
—
—
7/3/2014
100
—
—
—
—
—
—
7/4/2014
100
--
--
--
—
—
—
7/5/2014
100
—
—
—
—
—
—
7/6/2014
100
--
--
--
—
—
—
7/7/2014
51
—
6
—
—
—
100
7/8/2014
54
--
--
--
—
—
—
7/9/2014
100
—
65
—
100
—
—
7/10/2014
100
--
--
--
—
—
—
7/11/2014
100
—
—
—
—
—
—
7/12/2014
100
--
—
—
—
—
—
7/13/2014
100
—
—
—
—
—
—
7/14/2014
100
—
25
--
100
—
100
Page 1 of 8

Historical Data (2015-2019) - WET Testing Results
King America Finishing, Inc.
GA0003280
7/15/2014
100
—
—
—
—
—
—
7/16/2014
100
—
--
--
—
—
—
7/17/2014
100
—
—
—
—
—
—
7/18/2014
100
—
—
—
—
—
—
7/19/2014
100
—
—
—
—
—
—
7/20/2014
100
—
—
—
—
—
—
7/21/2014
100
—
50
—
100
—
100
7/22/2014
100
—
—
—
—
—
—
7/23/2014
100
—
—
—
100
—
—
7/24/2014
100
—
—
—
—
—
—
7/25/2014
100
—
—
—
—
—
—
7/26/2014
100
—
—
—
—
—
—
7/27/2014
85
—
—
—
—
—
—
7/28/2014
100
--
65
—
—
—
100
7/29/2014
100
—
—
—
—
—
—
7/30/2014
100
--
--
--
100
--
--
7/31/2014
100
—
—
—
100
—
—
8/1/2014
100
—
—
--
100
—
--
8/2/2014
100
—
—
—
—
—
—
8/3/2014
100
—
—
—
—
--
—
8/4/2014
100
—
50
—
—
—
100
8/5/2014
100
—
—
—
—
—
—
8/6/2014
100
—
—
—
100
--
-
8/7/2014
19
—
—
—
—
8/8/2014
100
—
—
—
—
--
--
8/9/2014
100
—
—
—
—
8/10/2014
100
—
—
—
—
—
—
8/11/2014
100
—
65
—
—
—
100
8/12/2014
100
—
—
—
—
—
—
8/13/2014
100
—
—
—
100
—
—
8/14/2014
100
—
—
—
—
—
—
8/15/2014
100
—
—
—
—
8/16/2014
100
—
--
—
—
--
--
8/17/2014
100
—
—
—
—
8/18/2014
100
—
65
—
—
--
100
8/19/2014
100
—
—
—
—
8/20/2014
100
—
--
—
100
—
--
8/21/2014
100
—
—
—
—
8/22/2014
100
—
--
—
—
--
--
8/23/2014
100
—
—
—
—
8/24/2014
100
—
--
—
—
--
--
8/25/2014
100
--
25
—
—
--
100
8/26/2014
100
—
—
—
—
—
—
8/27/2014
100
--
--
—
100
—
—
8/28/2014
100
—
—
—
—
—
—
8/29/2014
100
—
--
—
—
8/30/2014
100
—
—
—
—
—
--
8/31/2014
100
--
-
-
-
-
-
9/1/2014
100
—
65
—
—
—
100
9/2/2014
100
—
—
—
—
—
—
9/3/2014
100
—
—
—
100
100
—
9/4/2014
100
—
—
—
—
—
—
9/5/2014
100
—
—
—
—
—
—
9/6/2014
100
—
—
—
—
—
—
9/7/2014
100
—
—
—
—
—
—
9/8/2014
100
—
65
100
—
—
100
9/9/2014
100
—
—
—
—
—
—
9/10/2014
100
100
—
—
100
—
—
9/11/2014
100
—
—
—
—
—
—
9/12/2014
100
—
—
—
—
—
—
9/13/2014
100
—
—
—
—
—
—
9/14/2014
100
—
—
—
—
—
—
9/15/2014
100
—
50
—
—
—
100
9/16/2014
100
—
—
—
—
—
—
9/17/2014
100
—
—
—
100
—
—
9/18/2014
100
—
—
—
—
—
—
9/19/2014
100
—
—
—
—
—
—
9/20/2014
100
—
—
—
—
—
—
9/21/2014
100
—
—
—
—
—
—
9/22/2014
100
—
50
—
--
—
100
9/23/2014
100
—
—
—
—
—
—
9/24/2014
100
—
—
—
100
—
—
9/25/2014
100
—
—
—
—
—
—
9/26/2014
100
—
—
—
--
—
—
9/27/2014
100
—
—
—
—
—
—
9/28/2014
100
—
—
—
--
—
—
9/29/2014
100
—
65
—
--
—
100
9/30/2014
100
--
--
--
10/1/2014
100
—
—
—
100
—
--
10/2/2014
100
—
—
—
—
10/3/2014
100
—
—
—
—
—
--
10/4/2014
100
—
—
—
—
10/5/2014
100
—
--
—
—
--
--
10/6/2014
100
—
25
—
—
—
100
10/7/2014
100
—
—
—
—
—
—
10/8/2014
100
--
—
—
100
--
-
10/9/2014
100
—
—
—
—
--
—
10/10/2014
100
—
—
—
—
10/11/2014
100
—
—
—
—
--
--
10/12/2014
100
—
—
—
—
10/13/2014
100
—
65
—
—
—
100
10/14/2014
100
--
-
-
-
-
10/15/2014
100
—
—
—
100
—
--
10/16/2014
100
—
—
—
—
10/17/2014
100
—
--
—
—
--
--
10/18/2014
100
—
—
—
—
10/19/2014
100
—
--
—
—
--
--
10/20/2014
100
—
65
—
—
—
100
10/21/2014
100
—
—
—
—
—
—
10/22/2014
100
—
—
—
100
—
—
10/23/2014
100
—
—
—
—
—
—
10/24/2014
100
—
—
—
—
10/25/2014
100
—
—
—
—
--
--
10/26/2014
100
—
—
—
—
10/27/2014
100
—
—
—
—
--
100
10/28/2014
100
—
65
—
—
—
—
10/29/2014
100
—
—
—
100
—
—
10/30/2014
100
—
—
—
—
10/31/2014
100
—
—
—
—
--
--
Page 2 of 8

Historical Data (2015-2019) - WET Testing Results
King America Finishing, Inc.
GA0003280
11/1/2014
100
11/2/2014
100
—
—
—
—
—
—
11/3/2014
100
—
65
—
—
—
100
11/4/2014
100
—
—
—
—
—
—
11/5/2014
100
—
—
—
100
—
—
11/6/2014
100
—
—
—
—
—
—
11/7/2014
100
—
—
—
—
—
—
11/8/2014
100
—
—
—
—
—
—
11/9/2014
100
—
—
—
—
—
—
11/10/2014
100
—
65
—
—
—
100
11/11/2014
100
—
—
—
—
—
—
11/12/2014
100
—
—
—
100
—
—
11/13/2014
100
—
—
—
—
—
—
11/14/2014
100
—
—
—
—
—
—
11/15/2014
100
—
—
—
—
—
—
11/16/2014
100
—
—
—
—
—
—
11/17/2014
100
—
65
—
—
—
100
11/18/2014
100
—
—
—
—
—
—
11/19/2014
100
—
—
—
100
—
—
11/20/2014
100
—
—
—
—
—
—
11/21/2014
100
—
—
—
—
—
—
11/22/2014
100
—
—
—
—
—
—
11/23/2014
100
—
—
—
—
—
—
11/24/2014
100
—
50
—
—
—
100
11/25/2014
100
—
—
—
—
—
—
11/26/2014
100
—
—
—
100
—
—
11/27/2014
100
--
-
--
--
-
--
11/28/2014
100
—
—
—
—
—
—
11/29/2014
100
--
--
--
--
--
--
11/30/2014
90
—
—
—
—
—
—
12/1/2014
100
--
50
—
--
—
100
12/2/2014
100
—
--
—
—
—
—
12/3/2014
100
--
—
—
100
--
-
12/4/2014
100
—
—
—
100
—
—
12/5/2014
100
—
—
—
100
—
--
12/8/2014
100
—
8
50
—
—
100
12/9/2014
100
—
—
—
--
12/10/2014
100
100
—
—
100
--
--
12/11/2014
100
--
-
-
--
-
12/12/2014
100
—
—
—
—
—
--
12/13/2014
100
--
-
-
--
-
12/14/2014
100
—
—
—
—
—
--
12/15/2014
100
—
8
—
—
—
100
12/16/2014
100
—
—
—
—
—
—
12/17/2014
100
—
—
—
100
--
-
12/18/2014
100
—
—
—
—
—
—
12/19/2014
100
—
—
—
—
12/20/2014
100
—
—
—
—
--
--
12/21/2014
100
—
—
—
—
12/22/2014
100
—
65
—
—
--
100
12/24/2014
100
—
—
—
100
—
—
12/25/2014
100
—
--
—
—
—
—
12/26/2014
100
—
—
—
—
12/27/2014
100
—
—
—
—
—
--
12/28/2014
100
—
—
—
—
12/29/2014
100
—
25
—
—
—
100
12/30/2014
100
—
—
—
—
12/31/2014
100
—
—
--
100
—
—
1/1/2015
100
—
—
—
—
—
—
1/2/2015
100
—
—
—
—
—
—
1/3/2015
100
—
—
—
—
—
—
1/4/2015
100
—
—
—
—
—
—
1/5/2015
100
—
80
—
—
—
100
1/6/2015
100
—
—
—
—
—
—
1/7/2015
100
—
—
—
100
—
—
1/8/2015
100
—
—
—
—
—
—
1/9/2015
100
—
—
—
—
—
—
1/10/2015
100
—
—
—
—
—
—
1/11/2015
100
—
—
—
—
—
—
1/12/2015
100
—
50
—
—
—
100
1/13/2015
100
—
—
—
—
—
—
1/14/2015
100
—
—
—
100
—
—
1/15/2015
100
—
—
—
—
—
—
1/16/2015
100
—
—
—
—
—
—
1/17/2015
100
—
—
—
--
—
—
1/18/2015
100
—
—
—
—
—
—
1/19/2015
100
—
25
—
--
—
100
1/20/2015
100
—
—
—
—
—
—
1/21/2015
100
—
—
—
100
—
—
1/22/2015
100
—
—
—
—
—
—
1/23/2015
100
—
—
—
--
—
—
1/24/2015
100
—
—
—
—
—
—
1/25/2015
100
—
—
—
--
—
—
1/26/2015
100
—
50
—
—
—
100
1/27/2015
100
—
--
—
--
—
—
1/28/2015
100
—
—
—
100
—
—
1/29/2015
100
—
--
—
--
—
—
1/30/2015
100
—
—
—
—
—
—
1/31/2015
100
—
--
—
--
—
—
2/1/2015
100
—
—
—
—
—
—
2/2/2015
100
—
25
—
—
--
100
2/3/2015
100
—
—
—
—
--
—
2/4/2015
100
—
—
—
100
—
—
2/5/2015
100
—
—
—
—
—
—
2/6/2015
100
—
—
—
—
2/7/2015
100
—
—
—
—
—
--
2/8/2015
100
--
-
-
-
-
2/9/2015
100
—
—
—
—
—
--
2/10/2015
100
--
--
-
-
-
-
2/13/2015
100
—
—
—
—
—
—
2/16/2015
100
—
--
—
—
2/18/2015
100
—
—
—
—
—
--
2/23/2015
100
—
—
--
—
—
--
2/25/2015
100
—
—
—
—
—
—
3/4/2015
100
—
—
—
—
—
—
3/6/2015
100
—
—
—
—
—
—
3/9/2015
100
—
8
—
100
—
100
3/11/2015
100
—
—
—
—
—
—
3/16/2015
100
—
—
—
—
—
—
Page 3 of 8

Historical Data (2015-2019) - WET Testing Results
King America Finishing, Inc.
GA0003280
3/18/2015
100
—
—
—
—
—
—
3/25/2015
100
—
--
--
--
—
—
3/27/2015
100
—
—
—
—
—
—
3/30/2015
100
--
--
4/3/2015
100
—
—
—
--
—
--
4/8/2015
100
—
—
—
—
4/10/2015
100
—
--
—
—
--
--
4/13/2015
100
—
25
—
100
—
100
4/15/2015
100
—
—
—
—
—
—
4/20/2015
100
—
--
—
—
4/22/2015
100
—
—
—
—
--
--
4/27/2015
100
—
—
--
—
—
--
4/29/2015
100
—
—
—
—
—
—
5/4/2015
100
—
—
—
100
—
—
5/6/2015
100
—
—
—
—
—
—
5/11/2015
100
—
—
—
—
—
—
5/13/2015
100
—
—
—
—
—
—
5/18/2015
100
—
65
—
--
—
100
5/20/2015
100
—
—
—
—
—
—
5/29/2015
100
—
--
—
--
—
—
5/30/2015
100
—
—
--
--
--
--
6/1/2015
100
100
8
75
100
100
100
6/3/2015
100
—
—
—
—
—
—
6/8/2015
100
—
—
—
—
6/10/2015
100
—
—
—
—
—
--
6/16/2015
100
—
—
—
—
6/17/2015
100
—
—
—
—
--
--
6/22/2015
100
--
--
—
—
—
—
6/24/2015
100
—
—
—
—
—
—
7/10/2015
100
—
—
—
—
—
—
7/11/2015
100
—
—
—
—
—
—
7/13/2015
100
—
65
—
100
—
100
7/15/2015
100
—
—
—
—
—
—
7/20/2015
100
—
—
--
--
—
--
7/22/2015
100
—
—
—
—
—
—
7/30/2015
100
—
—
--
--
--
--
7/31/2015
100
—
—
—
—
—
—
8/3/2015
100
--
--
—
—
--
—
8/5/2013
100
—
—
—
—
—
—
8/10/2015
100
—
65
—
100
—
100
8/12/2015
100
—
—
—
—
—
—
8/17/2015
100
—
—
—
—
8/19/2015
100
—
—
—
—
—
--
8/24/2015
100
—
—
—
—
8/26/2015
100
—
—
—
—
—
--
9/1/2015
100
--
65
--
100
--
100
9/3/2015
100
—
—
—
—
—
—
9/7/2015
100
—
—
—
—
—
—
9/18/2015
100
—
—
—
—
—
—
9/19/2015
100
—
—
—
—
—
—
9/21/2015
100
—
—
—
—
—
—
9/23/2015
100
—
—
—
—
—
—
9/28/2015
100
—
—
—
—
—
—
9/30/2015
100
—
—
—
--
—
—
10/5/2015
100
—
50
--
100
—
100
10/7/2015
100
—
—
—
—
10/12/2015
100
—
—
—
—
—
--
10/14/2015
100
—
—
—
—
10/22/2015
100
—
—
—
—
—
—
10/23/2015
100
--
--
—
—
--
--
10/26/2015
100
—
—
—
—
—
—
10/28/2015
100
—
—
—
—
—
—
11/2/2015
100
—
65
—
100
—
100
11/4/2015
100
—
—
--
--
—
--
11/9/2015
100
—
—
—
—
—
—
11/11/2015
100
—
—
—
—
—
—
11/16/2015
100
—
—
—
—
—
—
11/18/2015
100
—
—
--
--
—
--
11/23/2015
100
—
—
—
—
—
—
11/24/2015
100
--
--
--
--
--
--
11/30/2015
100
—
—
—
—
—
—
12/5/2015
100
—
--
—
—
—
—
12/6/2015
100
—
—
—
—
—
—
12/7/2015
100
—
8
—
100
--
100
12/9/2015
100
—
—
—
—
—
—
12/11/2015
100
—
—
—
—
12/14/2015
100
—
—
—
—
--
--
12/16/2015
100
—
—
—
—
12/21/2015
100
—
—
—
—
--
--
12/22/2015
100
—
--
—
—
—
—
1/1/2016
100
—
—
—
—
—
—
1/7/2016
100
—
—
—
—
—
—
1/8/2016
100
—
—
—
—
—
—
1/11/2016
100
—
25
—
100
—
100
1/13/2016
100
—
—
—
—
—
—
1/19/2016
100
—
—
—
--
—
—
1/20/2016
100
—
—
—
—
—
—
1/25/2016
100
—
--
—
--
—
—
1/27/2016
100
—
—
--
—
—
—
2/1/2016
100
--
—
—
—
--
—
2/5/2016
100
—
—
—
—
—
—
2/8/2016
100
—
8
—
100
—
100
2/10/2016
100
—
—
—
—
—
—
2/15/2016
100
—
—
—
—
—
—
2/17/2016
100
—
—
—
—
--
—
2/22/2016
100
--
—
—
—
--
—
2/24/2016
100
—
—
—
—
—
—
2/29/2016
100
—
—
—
—
—
—
3/8/2016
100
—
—
—
—
—
—
3/9/2016
100
—
—
--
--
—
--
3/14/2016
100
—
65
—
100
—
100
3/16/2016
100
—
—
—
—
—
—
3/21/2016
100
—
—
—
—
—
—
3/23/2016
100
—
—
—
—
—
—
3/30/2016
100
—
—
—
—
—
—
3/31/2016
100
—
—
—
—
—
—
4/4/2016
100
—
25
—
100
—
100
4/6/2016
100
—
—
—
—
—
—
Page of

Historical Data (2015-2019) - WET Testing Results
King America Finishing, Inc.
GA0003280
4/11/2016
100
—
—
—
—
—
—
4/14/2016
100
—
--
--
--
—
—
4/18/2016
100
—
—
—
—
—
—
4/20/2016
100
—
—
—
--
—
—
4/25/2016
100
—
—
—
—
—
—
4/27/2016
100
--
--
--
5/2/2016
100
—
25
—
100
—
100
5/4/2016
100
—
—
—
—
5/11/2016
100
—
—
—
—
--
--
5/12/2016
100
—
—
—
—
5/19/2016
_
100
—
—
—
—
--
--
5/20/2016
100
—
--
—
—
5/23/2016
100
—
—
—
—
--
--
5/25/2016
100
—
—
—
—
—
—
6/3/2016
100
—
—
—
—
—
—
6/4/2016
100
—
—
—
—
—
—
6/9/2016
100
—
—
—
—
—
—
6/10/2016
100
100
25
75
100
100
100
6/13/2016
100
—
—
—
—
—
—
6/15/2016
100
—
—
—
—
—
—
6/20/2016
100
—
—
—
—
—
—
6/23/2016
100
—
--
—
--
—
—
6/27/2016
100
—
—
--
--
--
--
6/29/2016
100
--
--
--
7/4/2016
100
—
—
—
--
--
--
7/15/2016
100
—
—
—
—
7/16/2016
100
—
—
—
—
--
--
7/18/2016
100
—
8
—
100
—
100
7/20/2016
100
—
—
—
—
—
—
7/25/2016
100
--
--
—
—
—
—
7/27/2016
100
—
—
--
--
--
--
8/2/2016
—
—
50
—
—
—
100
8/5/2016
100
—
—
—
—
—
—
8/6/2016
100
—
—
—
100
—
—
8/12/2016
100
—
—
—
—
—
—
8/13/2016
100
—
—
—
--
—
—
8/15/2016
100
—
—
—
—
—
—
8/17/2016
100
—
--
—
--
—
—
8/22/2016
100
—
—
—
—
—
—
8/24/2016
100
--
--
--
9/2/2016
100
—
25
—
—
—
100
9/3/2016
100
—
—
—
--
9/5/2016
100
—
—
—
100
--
--
9/7/2016
100
—
—
—
--
9/12/2016
100
—
—
—
—
--
--
9/14/2016
100
--
—
—
—
—
—
9/19/2016
_
100
—
—
—
—
—
—
9/21/2016
100
—
—
—
—
—
—
9/29/2016
100
—
—
—
—
—
—
9/30/2016
100
--
--
—
—
--
—
10/4/2016
100
—
—
—
—
—
—
10/6/2016
100
—
—
—
—
—
—
10/10/2016
100
—
25
—
100
—
100
10/14/2016
100
—
—
—
—
—
—
10/17/2016
100
—
—
—
—
—
—
10/19/2016
100
—
—
--
—
—
—
10/24/2016
100
—
—
—
—
—
—
10/27/2016
100
—
—
--
—
--
--
10/31/2016
100
—
—
—
—
—
—
11/4/2016
100
--
--
—
—
--
—
11/7/2016
—
—
65
—
—
—
100
11/10/2016
100
—
—
—
—
11/11/2016
100
—
—
—
100
—
--
11/17/2016
100
—
—
—
—
—
—
11/18/2016
100
—
—
—
—
—
—
11/21/2016
100
—
—
—
—
--
—
11/23/2016
100
—
—
—
—
—
—
12/1/2016
100
--
--
--
—
--
12/2/2016
100
—
—
—
—
—
—
12/5/2016
100
—
8
—
100
—
100
12/7/2016
100
—
—
—
—
—
—
12/12/2016
100
—
—
—
—
—
—
12/14/2016
100
—
—
—
—
—
—
12/19/2016
100
—
—
—
—
—
—
12/21/2016
100
—
—
—
—
—
—
12/27/2016
100
—
--
—
--
—
—
12/28/2016
100
—
—
--
--
—
--
1/5/2017
100
—
—
—
—
1/6/2017
100
—
—
—
—
—
--
1/10/2017
100
—
—
—
—
1/11/2017
100
—
--
—
—
—
--
1/16/2017
87
—
25
—
100
—
100
1/18/2017
100
--
--
—
—
—
—
1/23/2017
100
—
—
—
—
1/25/2017
100
—
—
—
—
—
—
1/30/2017
100
—
—
—
—
—
—
2/1/2017
100
—
—
—
—
—
—
2/6/2017
100
—
25
--
100
--
100
2/8/2017
100
—
—
—
—
—
—
2/13/2017
100
—
--
--
--
--
--
2/15/2017
100
—
—
—
—
—
—
2/20/2017
100
--
--
--
--
--
--
2/22/2017
100
—
—
—
—
—
—
3/2/2017
100
—
--
—
—
—
—
3/3/2017
100
—
—
—
—
—
—
3/6/2017
100
--
25
—
100
--
100
3/8/2017
100
—
—
—
—
—
—
3/15/2017
100
—
—
—
—
3/16/2017
100
—
—
—
—
--
--
3/23/2017
100
—
—
—
—
3/24/2017
100
—
—
—
—
--
--
3/27/2017
100
—
--
—
—
—
—
3/28/2017
100
—
—
—
—
—
—
4/4/2017
100
—
—
—
—
—
—
4/8/2017
100
—
—
—
—
—
—
4/10/2017
100
—
—
—
100
—
—
4/13/2017
100
—
—
—
—
—
—
4/17/2017
100
—
—
—
—
—
—
Page 5 of 8

Historical Data (2015-2019)- WET Testing Results
King America Finishing, Inc.
GA0003280
4/19/2017
100
—
—
—
—
—
—
4/24/2017
100
--
25
--
--
--
100
4/26/2017
100
—
—
—
—
—
—
5/1/2017
100
--
—
—
—
--
—
5/5/2017
100
—
—
—
—
—
—
5/8/2017
100
—
8
—
100
--
—
5/10/2017
100
—
—
—
—
—
100
5/12/2017
37
—
—
—
—
—
—
5/18/2017
100
—
—
—
—
—
—
5/19/2017
100
—
—
—
—
—
—
5/23/2017
100
—
—
—
—
—
—
5/24/2017
100
—
--
—
—
5/30/2017
100
—
—
—
—
--
--
5/31/2017
100
—
—
—
—
—
—
6/5/2017
100
100
80
100
100
100
100
6/7/2017
100
—
—
—
—
—
—
6/15/2017
100
—
—
—
—
—
—
6/16/2017
100
—
—
—
—
—
—
6/19/2017
100
—
—
—
—
—
—
6/21/2017
100
—
—
—
—
—
—
6/27/2017
100
—
—
—
—
—
—
6/28/2017
100
—
--
—
--
—
—
7/5/2017
100
—
—
—
--
—
—
7/6/2017
100
--
—
—
—
--
7/10/2017
100
—
65
—
—
—
100
7/14/2017
100
—
—
—
—
7/15/2017
100
—
—
—
100
--
--
7/21/2017
100
—
—
—
—
7/22/2017
100
—
—
—
—
--
--
7/26/2017
100
--
—
—
—
--
7/28/2017
100
—
—
—
--
—
--
7/31/2017
100
—
—
—
—
—
—
8/2/2017
100
—
—
—
—
—
—
8/4/2017
100
—
50
--
100
—
100
8/10/2017
100
—
—
—
—
—
—
8/11/2017
100
—
—
—
—
—
—
8/15/2017
100
—
—
—
—
—
—
8/16/2017
100
—
—
—
—
—
—
8/21/2017
100
—
—
—
—
—
—
8/23/2017
100
—
—
—
—
—
—
8/28/2017
100
—
—
—
—
—
—
8/30/2017
100
—
--
—
--
—
—
9/6/2017
100
—
—
--
--
—
--
9/7/2017
100
—
—
—
—
9/15/2017
100
—
—
—
—
--
--
9/16/2017
100
—
—
—
—
9/18/2017
100
—
50
—
100
--
100
9/20/2017
100
—
—
—
—
9/27/2017
100
—
—
—
—
—
--
9/28/2017
100
--
--
—
—
--
—
10/2/2017
100
—
25
—
100
—
100
10/6/2017
100
—
—
—
—
—
—
10/9/2017
100
—
—
—
—
—
—
10/12/2017
100
—
—
—
--
—
—
10/18/2017
100
—
—
—
—
—
—
10/19/2017
100
—
—
--
--
—
--
10/26/2017
100
—
—
—
—
—
—
10/27/2017
100
—
—
--
--
--
--
10/30/2017
100
—
—
—
—
—
—
11/1/2017
100
--
--
—
—
--
—
11/6/2017
—
—
8
—
—
—
100
11/7/2017
100
—
—
—
100
—
—
11/8/2017
100
—
—
—
—
—
—
11/17/2017
100
—
—
—
—
—
—
11/18/2017
100
—
—
—
—
—
—
11/20/2017
100
—
—
—
—
--
—
11/21/2017
100
—
—
—
—
—
—
12/2/2017
100
--
--
--
—
--
12/3/2017
100
—
—
—
—
—
—
12/4/2017
100
—
8
—
100
—
100
12/6/2017
100
—
—
—
—
—
—
12/16/2017
100
—
--
—
—
—
—
12/17/2017
100
—
—
—
—
—
—
12/20/2017
100
--
--
--
—
--
12/21/2017
100
—
—
--
—
—
1/19/2018
100
—
—
—
—
--
—
1/21/2018
100
—
—
—
—
—
—
1/22/2018
--
—
50
—
—
—
100
1/24/2018
100
—
—
—
—
—
—
1/26/2018
100
—
--
—
100
—
—
2/1/2018
100
—
—
—
—
—
—
2/2/2018
100
—
—
—
—
—
—
2/5/2018
100
—
8
—
100
—
100
2/7/2018
100
—
—
—
—
—
—
2/12/2018
100
—
—
—
—
—
—
2/13/2018
100
—
—
—
—
—
—
2/24/2018
100
—
—
—
—
—
—
2/25/2018
100
—
--
—
--
—
—
3/2/2018
100
—
—
—
—
—
—
3/3/2018
100
--
—
—
—
--
3/5/2018
100
—
8
—
100
—
100
3/7/2018
100
—
—
—
—
3/12/2018
100
—
—
—
—
--
--
3/14/2018
100
—
—
—
—
3/21/2018
100
—
—
—
—
--
--
3/23/2018
100
--
—
—
—
--
3/26/2018
100
—
—
—
--
—
--
3/28/2018
100
—
—
—
—
—
—
4/2/2018
100
—
8
—
100
—
100
4/4/2018
100
—
—
--
--
—
--
4/9/2018
100
—
—
—
—
—
—
4/11/2018
100
—
—
—
—
—
—
4/19/2018
100
—
—
—
—
—
—
4/20/2018
100
—
—
—
—
—
—
4/28/2018
100
—
—
—
—
—
—
4/29/2018
100
—
—
—
—
—
—
5/2/2018
100
—
—
—
—
—
—
5/7/2018
100
—
—
—
—
—
—
Page 6 of 8

Historical Data (2015-2019) - WET Testing Results
King America Finishing, Inc.
GA0003280
5/9/2018
100
—
—
—
—
—
—
5/14/2018
81
--
8
--
100
—
100
5/16/2018
100
—
—
—
—
—
—
5/24/2018
100
--
—
—
--
—
—
5/25/2018
100
—
—
—
—
—
—
5/31/2018
100
--
--
--
6/1/2018
100
—
—
—
--
—
--
6/4/2018
35
16
8
8
100
—
100
6/8/2018
100
—
—
—
—
—
—
6/14/2018
100
—
—
—
—
6/15/2018
100
—
—
—
—
--
--
6/22/2018
100
—
—
—
—
6/23/2018
100
—
—
—
—
—
--
6/26/2018
100
—
--
—
—
--
—
6/27/2018
100
—
—
—
—
—
—
7/11/2018
100
—
—
—
—
--
--
7/12/2018
100
—
—
—
—
—
—
7/16/2018
—
—
25
—
—
--
6
7/19/2018
100
—
—
—
—
—
—
7/20/2018
100
—
—
—
100
--
--
7/26/2018
100
—
—
—
—
—
—
7/27/2018
100
—
--
—
--
—
—
8/1/2018
100
—
—
—
--
—
—
8/2/2018
100
--
—
—
—
--
8/8/2018
100
—
—
—
—
—
--
8/9/2018
100
—
—
—
—
8/13/2018
—
—
25
—
—
--
100
8/16/2018
100
—
—
—
—
8/17/2018
100
—
—
—
100
--
--
8/24/2018
100
--
--
—
—
—
—
8/25/2018
100
—
—
--
--
--
--
9/1/2018
100
—
—
—
—
—
—
9/3/2018
100
—
—
—
—
—
—
9/4/2018
100
—
—
—
—
—
—
9/15/2018
100
—
—
—
—
—
—
9/16/2018
100
—
—
—
--
—
—
9/17/2018
—
—
65
—
—
—
100
9/19/2018
100
—
--
—
100
—
—
9/21/2018
100
—
—
—
—
—
—
9/26/2018
100
--
--
--
9/27/2018
100
—
--
--
—
—
10/1/2018
—
—
25
—
--
--
100
10/3/2018
100
—
—
—
100
—
—
10/5/2018
100
—
—
—
--
10/10/2018
100
—
—
—
—
--
--
10/13/2018
100
--
—
—
--
—
10/19/2018
100
—
—
—
—
—
--
10/20/2018
100
—
—
—
—
10/27/2018
100
—
—
—
—
—
--
10/28/2018
100
--
--
—
—
--
—
11/2/2018
100
—
—
—
—
—
—
11/3/2018
100
—
—
—
—
—
—
11/5/2018
—
—
8
—
—
—
100
11/8/2018
100
—
—
—
—
—
—
11/9/2018
100
—
—
—
100
—
—
11/27/2018
100
—
—
—
--
—
—
11/28/2018
100
—
—
—
--
—
—
12/7/2018
100
—
—
—
—
—
—
12/8/2018
100
—
—
—
—
—
—
12/10/2018
--
—
50
—
—
—
100
12/15/2018
100
--
—
—
—
—
12/16/2018
100
—
—
—
—
—
--
12/17/2018
100
--
6
—
100
--
50
12/19/2018
100
—
—
—
—
12/25/2018
100
—
--
—
—
—
--
12/26/2018
100
—
—
—
—
1/2/2019
100
—
--
--
--
—
1/3/2019
100
--
--
--
--
--
1/10/2019
100
—
—
—
—
—
—
1/11/2019
100
--
—
—
—
--
—
1/17/2019
100
—
—
—
—
—
—
1/18/2019
100
—
—
—
—
—
—
1/21/2019
—
—
65
—
—
—
100
1/24/2019
100
—
—
—
—
—
—
1/26/2019
100
—
—
—
100
—
—
1/31/2019
100
—
—
—
—
—
—
2/1/2019
100
—
—
--
—
—
--
2/4/2019
--
--
25
—
—
--
100
2/7/2019
100
—
--
—
—
—
—
2/8/2019
100
—
—
—
100
—
—
2/13/2019
100
—
—
—
—
—
—
2/14/2019
100
—
—
—
—
2/20/2019
100
—
—
—
—
--
--
2/21/2019
100
—
—
—
—
2/27/2019
100
—
—
—
—
--
--
2/28/2019
100
—
—
—
—
3/4/2019
100
—
8
--
100
—
100
3/6/2019
100
—
—
—
—
—
—
3/14/2019
100
—
—
—
—
—
—
3/15/2019
100
—
—
—
--
—
—
3/20/2019
100
—
—
—
—
—
—
3/21/2019
100
—
--
—
--
—
—
3/25/2019
100
—
—
—
—
—
—
3/27/2019
100
--
--
--
4/5/2019
100
—
—
—
—
—
—
4/6/2019
100
—
—
—
--
4/8/2019
100
—
65
—
100
--
100
4/10/2019
100
—
—
—
--
4/15/2019
100
—
—
—
—
--
—
4/17/2019
100
--
—
—
--
—
4/22/2019
100
—
—
—
—
—
--
4/24/2019
100
--
—
—
--
—
Results Analysis
NumberofTests
734
9
95
9
108
7
92
Numbero(Tests
205
2
26
2
25
1
26
(04/2017-04/2019)
Number of Violations'
13
1
4
0
0
0
2
Page 7 of 8

Historical Data (2015-2019)- WET Testing Results
King America Finishing, Inc.
GA0003280
Number of Violations'
(04/2017 - 04/2019)
3
1
1
0
0
0
2
Frequency of Violations
1.77%
11.11%
4.21%
0.00%
0.00%
0.00%
2.17%
Frequency of Violations
(04/2017 - 04/2019)
1.46%
50.00%
3.85%
0.00%
0.00%
0.00%
7.69%
' In -stream WET tests do not have limits; thus the data entered under the number of violations rows for in -stream data represents instances where some amount of toxicity was indicated in the receiving water, not permit violations.
rViolation
Page 8 of 8

Appendix F — Production -Based Effluent Limitations
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 48

Effluent Calculations from 40 CFR 410; Subpart D
King America Finishing, Inc.
GA0003280
Permit Limits = Average Production (Ibs/day) x Mass Factor (Ibs/1000 Ibs)
Tier 1- Average Production (Plant 1) <_ 97,939 Ibs/day
BPT Mass Factors (Ibs/ 1000 Ibs)
NPDES Permit Limits (Ibs/day)
Parameter
Source
Average Production (Ibs/day)
Daily Average
Daily Maximum
Daily Average
Daily Maximum
BOD5
Plant 1
97,939
3.3
6.6
323
646
COD
Plant 1- (a)1
97,939
30.0
60.0
2,938
5,876
Plant 1-(b)1-Natural Fiber
27,423
10.0
20.0
274
548
Plant 1- (d)1 - Complex Blend
70,516
30.0
60.0
2,115
4,231
Total
5,328
10,656
TSS
Plant 1
97,939
8.9
17.8
872
1,743
Sulfide
Plantl
97,939
0.10
0.20
9.8
19.6
Total Phenols
Plantl
97,939
0.05
0.10
4.9
9.8
Total Chromium
Plantl
97,939
0.05
0.10
4.9
9.8
Tier 2 - 97,939 Ibs/day < Average Production (Plant 1) <_ 111,849 Ibs/day
BPT Mass Factors (Ibs/ 1000 Ibs)
NPDES Permit Limits (Ibs/day)
Parameter
Source
Average Production (Ibs/day)
Daily Average
Daily Maximum
Daily Average
Daily Maximum
BOD5
Plantl
111,849
3.3
6.6
369
738
COD
Plant 1- (a)1
111,849
30.0
60.0
3,355
6,711
Plant l-(b)1- Natural Fiber
31,318
10.0
20.0
313
626
Plant 1 - (d)1 - Complex Blend
80,531
30.0
60.0
2,416
4,832
Total
6,085
12,169
TSS
Plant 1
111,849
8.9
17.8
995
1,991
Sulfide
Plant 1
_
111,849
0.10
0.20
11.2
22.4
Total Phenols
Plant 1
111,849
0.05
0.10
5.6
11.2
Total Chromium
Plant 1
-
111,849
0.05
0.10
5.6
11.2
Tier 3 - 111,849 Ibs/day < Average Production (Plant 1) <_ 128,116 Ibs/day
BPT Mass Factors (Ibs/ 1000 Ibs)
NPDES Permit Limits (Ibs/day)
Parameter
Source
Average Production (Ibs/day)
Daily Average
Daily Maximum
Daily Average
Daily Maximum
BOD5
Plant 1
128,116
3.3
6.6
423
846
COD
Plant 1- (a)1
128,116
30.0
60.0
3,843
7,687
Plant 1-(b)1-Natural Fiber
35,872
10.0
20.0
359
717
Plant 1- (d)1 - Complex Blend
92,244
30.0
60.0
2,767
5,535
Total
6,970
13,939
TSS
Plantl
128,116
8.9
17.8
1,140
2,280
Sulfide
Plantl
128,116
0.10
0.20
12.8
25.6
Total Phenols
Plant 1
-
128,116
0.05
0.10
6.4
12.8
Total Chromium
Plant 1
128,116
0.05
0.10
6.4
12.8
1 (a),(b),(c), & (d) refer to the BPT limitations established in the subsections of 40 CFR 410.42
Page 1 of 1

Appendix G — Historical DMR Data
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 49

Historical Data (2015-2019) - Daily Average DMR Values
King America Finishing, Inc.
GA0003280
Date
Parameters
BOD5 (Ibs/day) BOD5 (mg/L) COD (Ibs/day) TSS (Ibs/day) TSS (mg/L) Sulfide (Ibs/day) Sulfide (mg/L) Total Ammonia (Ibs/day) Total Ammonia (mg/L) Total Phenols (Ibs/day) Total Chromium (Ibs/day) Total Chromium (mg/L)
Monthly Average
1/1/2015
181
14
3052
162
12
13.43
1.00
23.41
1.76
0.6
0.12
0.01
2/1/2015
182
14
2893
208
15
12.81
1.00
33.08
2.39
0.9
0.15
0.01
3/1/2015
170
13
2502
203
16
14.20
1.18
26.00
1.98
0.6
0.11
0.01
4/1/2015
263
18
3551
329
22
14.29
1.13
17.73
1.17
0.7
0.15
0.01
5/1/2015
209
13
3414
213
13
19.55
1.43
20.59
1.30
0.8
0.15
0.01
6/1/2015
112
9
2623
121
9
2.39
0.20
15.91
1.26
0.6
0.12
0.01
7/1/2015
109
9
2530
80
7
2.06
0.20
7.70
0.66
0.6
0.14
0.01
8/1/2015
89
6
2679
74
5
2.89
0.20
11.86
0.82
0.6
0.13
0.01
9/1/2015
60
4
2468
46
3
2.80
0.20
10.39
0.75
0.8
0.16
0.01
10/1/2015
151
10
2860
230
16
2.81
0.20
11.53
0.82
0.7
0.15
0.01
11/1/2015
138
9
2399
68
5
2.77
0.20
16.36
1.19
1.0
0.15
0.01
12/1/2015
127
10
2564
76
6
2.64
0.20
15.00
1.14
0.7
0.12
0.01
1/1/2016
155
12
2398
142
11
2.56
0.20
17.07
1.29
0.6
0.12
0.01
2/1/2016
177
15
2415
193
16
2.44
0.20
12.81
1.05
0.6
0.11
0.01
3/1/2016
141
10
2401
137
9
2.77
0.20
16.99
1.23
1.1
0.15
0.01
4/1/2016
94
8
2143
64
6
2.31
0.20
11.31
1.02
0.9
0.11
0.01
5/1/2016
41
3
1832
31
3
2.41
0.20
8.15
0.66
0.8
0.13
0.01
6/1/2016
38
3
1663
40
3
2.64
0.20
8.89
0.69
0.7
0.13
0.01
7/1/2016
51
4
2060
59
4
2.50
0.20
10.58
0.82
0.7
0.13
0.01
8/1/2016
62
4
2354
73
5
2.83
0.20
15.16
1.08
0.8
0.16
0.01
9/1/2016
47
3
2764
49
4
2.69
0.20
13.45
0.99
0.6
0.13
0.01
10/1/2016
47
4
2474
40
3
2.55
0.20
16.33
1.27
0.6
0.13
0.01
11/1/2016
80
6
2760
94
7
2.42
0.20
21.95
1.79
0.6
0.13
0.01
12/1/2016
39
3
2649
36
3
2.55
0.20
18.04
1.33
0.8
0.12
0.01
1/1/2017
56
4
2071
46
4
2.44
0.20
13.61
1.11
0.7
0.13
0.01
2/1/2017
78
6
2271
38
3
2.60
0.20
13.38
1.05
0.7
0.14
0.01
3/1/2017
98
7
2969
59
4
2.88
0.20
14.91
1.03
0.5
0.14
0.01
4/1/2017
84
5
2941
65
4
3.13
0.20
17.66
1.12
0.8
0.16
0.01
5/1/2017
122
8
2813
83
5
3.10
0.20
12.15
0.79
0.9
0.17
0.01
6/1/2017
72
4
3054
62
4
3.50
0.20
12.09
0.69
0.9
0.18
0.01
7/1/2017
55
3
3192
53
3
3.10
0.20
15.33
1.04
0.1
0.15
0.01
8/1/2017
55
3
3629
57
3
3.42
0.20
17.32
1.02
0.2
0.19
0.01
9/1/2017
55
4
3447
42
3
2.66
0.20
27.60
2.06
0.2
0.13
0.01
10/1/2017
88
6
3535
105
7
2.84
0.20
43.61
3.05
0.1
0.15
0.01
11/1/2017
85
7
3398
55
5
2.57
0.20
29.76
2.16
0.1
0.12
0.01
12/1/2017
95
6
4405
97
6
3.03
0.20
23.56
1.54
0.2
0.17
0.01
1/1/2018
140
10
4094
140
10
4.10
0.28
45.96
3.38
0.1
0.12
0.01
2/1/2018
172
11
4171
196
12
3.25
0.20
10.94
0.67
0.3
0.17
0.01
3/1/2018
166
11
4220
152
10
2.98
0.20
11.64
0.81
0.1
0.15
0.01
4/1/2018
202
13
4062
135
9
3.18
0.20
23.73
1.41
0.2
0.16
0.01
5/1/2018
67
4
3529
96
6
3.04
0.20
93.40
5.73
0.2
0.16
0.01
6/1/2018
86
5
3976
140
8
3.21
0.20
13.99
0.90
0.3
0.16
0.01
7/1/2018
66
4
3384
66
4
3.56
0.20
24.08
1.44
0.4
0.18
0.01
8/1/2018
56
3
3456
82
5
3.59
0.20
13.41
0.72
0.2
0.18
0.01
9/1/2018
37
2
2795
47
3
3.06
0.20
14.77
0.97
0.1
0.14
0.01
10/1/2018
95
6
3261
113
7
3.31
0.20
10.84
0.67
0.2
0.15
0.01
11/1/2018
229
13
4839
201
12
3.21
0.20
64.06
3.77
0.2
0.17
0.01
12/1/2018
88
5
2639
92
5
3.93
0.24
17.70
1.25
0.2
0.166
0.01
1/1/2019
76
5
2408
77
5
2.99
0.20
21.59
1.45
0.1
0.138
0.01
2/1/2019
50
3
2968
42
3
3.26
0.20
9.85
0.64
0.2
0.161
0.01
3/1/2019
53
3
2749
43
3
3.15
0.20
11.92
0.75
0.2
0.154
0.01
4/1/2019
39
3
2297
35
3
2.80
0.20
10.69
0.76
0.2
0.146
0.01
Long Term Average
102
7
2962
100
7
4.06
0.29
19.61
1.35
0.5
0.14
0.01
8 of Violations (Current)
0
0
0
0
0
0
0
0
0
0
0
0
8 of Violations (Proposed)
0
0
0
0
--
5
0
0
0
0
0
--
Page 1 of 2

Historical Data (2015-2019) - Daily Maximum DMR Values
King America Finishing, Inc.
GA0003280
Date
Parameters
BOD5 (Ibs/day) BOD5 (mg/L) COD (Ibs/day) TSS (Ibs/day) TSS (mg/L) Sulfide (Ibs/day) Sulfide (mg/L) Total Ammonia (Ibs/day) Total Ammonia (mg/L) Total Phenols (Ibs/day) Total Chromium (Ibs/day) Total Chromium (mg/L) Temperature (°F)
Daily Maximum
1/1/2015
379
25
4611
292
20
21.93
1.00
66.41
4.74
0.7
0.14
0.01
69
2/1/2015
394
23
4830
468
32
17.85
1.00
93.99
6.83
1.4
0.18
0.01
72
3/1/2015
424
27
3689
422
31
36.23
2.40
91.54
7.73
0.6
0.12
0.01
78
4/1/2015
507
34
4498
891
59
24.29
2.00
43.90
2.83
0.9
0.17
0.01
81
5/1/2015
422
22
5755
665
35
74.86
4.80
31.69
1.66
0.9
0.17
0.01
87
6/1/2015
279
17
4184
296
19
3.42
0.20
82.24
6.05
0.7
0.14
0.01
90
7/1/2015
215
16
3377
199
15
3.17
0.20
15.24
1.07
0.8
0.16
0.01
90
8/1/2015
228
14
4091
266
16
3.60
0.20
27.48
1.69
0.7
0.14
0.01
90
9/1/2015
119
8
3448
100
7
3.39
0.20
26.38
1.71
0.8
0.17
0.01
90
10/1/2015
453
30
4029
684
45
3.70
0.20
19.61
1.51
0.9
0.17
0.01
84
11/1/2015
297
17
3101
147
11
3.77
0.20
34.41
2.18
1.1
0.17
0.01
84
12/1/2015
255
18
3541
185
14
3.19
0.20
23.67
1.65
0.7
0.14
0.01
81
1/1/2016
317
22
3441
352
11
3.55
0.20
39.33
2.37
0.7
0.14
0.01
78
2/1/2016
296
24
3485
390
16
3.50
0.20
29.35
2.41
0.7
0.12
0.01
75.74
3/1/2016
580
33
753
9
3.49
0.20
30.68
1.91
2.1
0.17
0.01
82.76
4/1/2016
250
22
3286
196
6
3.30
0.20
24.04
2.03
1.7
0.12
0.01
81
5/1/2016
78
6
2158
37
3
2.97
0.20
18.26
1.50
1.0
0.14
0.01
84
6/1/2016
73
5
2757
87
3
3.40
0.20
16.39
1.13
0.8
0.16
0.01
93
7/1/2016
128
10
2638
174
4
3.65
0.20
23.20
1.55
0.7
0.13
0.01
93
8/1/2016
258
22
3536
350
5
3.74
0.20
29.82
2.40
0.9
0.19
0.01
90
9/1/2016
108
8
4845
135
4
4.25
0.20
31.05
1.65
0.7
0.14
0.01
87.08
10/1/2016
91
7
3518
70
3
3.25
0.20
33.75
2.26
0.7
0.14
0.01
82.04
11/1/2016
225
15
3972
370
7
3.47
0.20
48.87
3.64
0.8
0.16
0.01
81
12/1/2016
78
5
4120
80
3
3.39
0.20
69.56
4.17
1.2
0.17
0.01
78
1/1/2017
143
10
2984
111
8
3.24
0.20
35.78
3.17
0.7
0.15
0.01
78
2/1/2017
165
11
2945
79
5
3.37
0.20
54.90
4.54
0.8
0.17
0.01
78
3/1/2017
224
14
4340
139
8
3.49
0.20
39.67
2.39
0.8
0.17
0.01
81
4/1/2017
202
12
4375
172
12
4.35
0.20
84.34
5.24
0.9
0.18
0.01
83.6
5/1/2017
439
23
5484
238
16
3.90
0.20
26.53
1.42
1.0
0.2
0.01
84.74
6/1/2017
186
11
4278
173
10
4.42
0.20
17.95
1.21
0.9
0.19
0.01
87.3
7/1/2017
191
11
4533
238
14
4.60
0.20
25.55
2.19
0.2
0.17
0.01
94.46
8/1/2017
86
5
6096
228
12
4.05
0.20
34.80
1.83
0.3
0.2
0.01
90.9
9/1/2017
155
10
4624
98
7
3.50
0.20
40.91
2.91
0.3
0.15
0.01
85.9
10/1/2017
321
21
5127
470
30
3.67
0.20
203.71
11.80
0.2
0.17
0.01
86.4
11/1/2017
194
13
4493
146
17
3.32
0.20
98.12
6.84
0.2
0.17
0.01
78.9
12/1/2017
220
14
5465
299
20
4.09
0.20
62.34
4.13
0.2
0.2
0.01
75.2
1/1/2018
223
14
5076
288
10
16.15
0.28
111.81
10.90
0.1
0.14
0.01
77.8
2/1/2018
405
27
5130
501
12
3.72
0.20
26.56
1.75
0.3
0.19
0.01
79.8
3/1/2018
269
16
5689
273
10
3.52
0.20
18.77
1.36
0.1
0.17
0.01
79.1
4/1/2018
352
21
5015
274
9
3.85
0.20
221.32
11.90
0.2
0.18
0.01
78.08
5/1/2018
141
8
5524
331
6
3.97
0.20
1312.05
76.00
0.2
0.19
0.01
85.6
6/1/2018
184
11
5474
430
8
3.85
0.20
25.14
1.91
0.3
0.19
0.01
88.60
7/1/2018
166
8
4415
152
4
4.44
0.20
98.91
5.93
0.4
0.19
0.01
89.90
8/1/2018
181
8
4475
238
5
4.64
0.20
38.26
1.65
0.2
0.20
0.01
88.60
9/1/2018
83
5
3833
163
3
3.84
0.20
73.85
4.71
0.1
0.17
0.01
88.10
10/1/2018
343
20
4307
366
7
3.97
0.20
25.92
1.85
0.2
0.18
0.01
88.6
11/1/2018
685
39
9626
539
31
3.79
0.20
301.91
18.10
0.2
0.173
0.01
79.9
12/1/2018
165
9
6446
345
18
13.50
0.71
171.30
15.80
0.2
0.19
0.01
76.8
1/1/2019
350
22
3452
205
13
4.21
0.26
222.25
14.10
0.2
0.162
0.01
72.9
2/1/2019
77
5
3582
65
4
3.94
0.20
53.21
4.17
0.2
0.176
0.01
78.6
3/1/2019
93
6
3336
67
5
3.75
0.20
33.26
2.11
0.3
0.175
0.01
77.1
4/1/2019
56
5
3146
50
3
3.32
0.20
28.31
2.07
0.3
0.156
0.01
82.1
0 of Violations (Current)
0 of Violations (Proposed)
0
0
1
1
1
4
0
0
0
0
4
1
4
0
0
Page 2 of 2

Appendix H — Historical Instream Data
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 50

Historical Data (2015-2019) - Instream Sampling Results
King America Finishing, Inc.
GA0003280
Date
Parameters
pH (s.u.) Min.
pH (s a.) Max.
Temperature (°F)
Conductivity (pmho/cm)
Total Ammonia (mg/L)
Formaldehyde (mg/L)
Sodium (mg/L)
Sulfide (mg/L)
Perox de (mg/L)
Dissolved Oxygen (mg/L)
Colo (ADMI)
Upstream
Downstream
Upstream
Downstream
Upstream
Downstream
Upstream
Downstream
Upstream
Downstream
Upstream
Downstream
Upstream
Downstream
Upstream
Downstream
Upstream
Downstream
Upstream
Downstream
Upstream
Downstream
1/1/2015
5.68
5.74
7.38
7.56
46.35
46.44
52
57
0.20
0.20
0.05
0.05
5
5
1
1
0.1
0.1
9.64
10.02
86
87
2/1/2015
6.4
6.38
7.03
7.16
46.12
46.14
54
60
0.20
0.20
0.05
0.05
5
5
1
1
--
--
9.44
10.03
65
68
3/1/2015
5.45
5.51
6.32
6.64
60.68
60.67
55
56
0.20
0.20
0.05
0.05
5
5
1
1
--
--
6.07
6.41
114
112
4/1/2015
5.48
5.53
6.76
6.69
66.96
66.97
68
70
0.20
0.20
0.05
0.05
5
5
1
1
--
--
6.03
6.23
152
150
5/1/2015
6.48
6.52
7.02
6.92
73.46
73.5
95
170
0.20
0.20
0.05
0.05
5
5
1
1
--
--
6.14
6.26
100
99
6/1/2015
6.78
6.95
7.07
7.14
80.31
80.29
117
200
0.20
0.20
0.05
0.05
3.37
29.3
0.2
0.2
--
--
6.65
6.69
66
70
7/1/2015
6.63
6.47
7.33
7.58
83.61
82.82
122
1078
0.20
0.20
0.05
0.05
5
5
0.2
0.2
--
--
6.01
6.16
58
55
8/1/2015
7.1
7.06
7.47
7.53
82.27
82.31
140
311
0.20
0.25
0.05
0.07
5
24.3
0.2
0.2
--
--
5.92
5.66
37
42
9/1/2015
5.7
5.96
7.29
7.48
75.11
75.11
96
185
0.20
0.20
0.05
0.08
5
29.3
0.2
0.2
--
--
5.45
5.62
65
69
10/1/2015
6.42
6.54
6.85
7.02
64.58
64.41
231
118
0.20
0.20
0.05
0.05
5
11
0.2
0.2
--
--
5.98
6.16
91
94
11/1/2015
5.96
6.37
7.85
7.67
60.06
60.01
72
66
0.20
0.20
0.05
0.05
5
6.17
0.2
0.2
--
--
4.96
4.99
138
153
12/1/2015
6.11
6.15
6.99
7.08
57.97
57.96
74
69
0.20
0.20
0.05
0.05
5
5
0.2
0.2
--
--
4.84
4.78
117
127
1/1/2016
6.3
6.33
7.88
7.89
46.17
46.22
136
47
0.20
0.20
0.05
0.05
90.6
5
0.2
0.2
--
--
8.09
7.98
145
143
2/1/2016
6.91
6.82
7.62
7.51
53.96
53.96
49
50
0.20
1.30
0.05
0.05
5
5
0.2
0.2
--
--
7.05
7.21
112
114
3/1/2016
6.12
6.14
8.5
6.59
63.3
63.33
70
77
0.20
0.20
0.05
0.05
5
5
0.2
0.2
--
--
6.14
6.15
125
120
4/1/2016
6
6.06
6.32
6.3
63.78
63.8
65
65
0.20
0.20
0.05
0.05
5
5
0.2
0.2
--
--
6.05
6.07
113
125
5/1/2016
6.66
6.667
7.03
6.99
69.73
69.74
97
103
0.20
0.20
0.05
0.05
5
5
0.2
0.2
--
--
6.33
6.3
72
73
6/1/2016
6.32
6.44
7.57
7.43
74.16
74.16
108
134
0.20
0.20
0.05
0.05
5
5
0.2
0.2
--
--
3.95
4.85
105
103
7/1/2016
6.1
5.98
7.51
7.49
79.43
79.45
125
209
0.20
0.20
0.05
0.05
5
37.2
0.2
0.2
--
--
4.74
5.19
59
60
8/1/2016
7.31
6.94
7.74
7.59
78.13
78.08
164
423
0.20
0.20
0.05
0.06
5
7.61
0.2
0.2
0
0
4.41
5.49
34
35
9/1/2016
6.96
7.29
7.29
7.35
74.37
74.46
118
331
0.23
0.20
0.05
0.05
5
9.28
0.2
0.2
0
0
5.96
5.85
78
80
10/1/2016
6.49
6.75
7.64
7.4
67.37
67.47
127
236
0.20
0.20
0.05
0.12
6.3
58.3
0.2
0.2
0
0
6.19
6.03
72
72
11/1/2016
7.51
7.42
7.91
7.87
61
61.04
113
156
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
2.83
3.06
40
44
12/1/2016
5.75
5.66
6.17
6.31
55.39
55.09
81
69
0.20
0.20
0.05
0.05
5
7.12
0.2
0.2
0
0
6.25
6.14
73
76
1/1/2017
5.1
5.23
6.12
6.11
55
54.64
69
73
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
6.13
6.45
108
104
2/1/2017
5.76
5.47
6.23
6.31
58.02
58.21
80
76
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
6.5
6.45
109
106
3/1/2017
5.15
5.76
6.25
6.2
60.76
60.44
86
96
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
6.73
6.78
117
115
4/1/2017
6.6
6.49
7.25
7.36
69.31
69.22
309
102
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
5.12
5.92
91
91
5/1/2017
6.75
6.25
7.11
7.01
74.84
74.95
221
268
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
5.11
6.01
68
75
6/1/2017
6.13
6.27
7.31
7.27
76.42
77.27
78
85
0.20
0.20
0.10
0.14
5
5
0.2
0.2
0
0
5.23
6.8
66
67
7/1/2017
5.95
6.79
7.12
7.71
79.66
79.79
88
110
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
5.75
5.64
57
60
8/1/2017
6.02
6.72
7.15
7.19
79.34
79.41
89
94
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
4.14
4.12
94
92
9/1/2017
6.45
6.56
7.25
7.29
76.15
76.06
101
105
0.20
0.20
0.05
0.05
5
11.3
0.2
0.2
0
0
4.67
4.43
85
79
10/1/2017
6.48
6.54
7.34
7.36
69.62
69.49
169
133
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
6
6.16
65
62
11/1/2017
7.04
6.79
7.23
7.28
57.88
66.16
68
66
0.20
0.20
0.05
0.05
5
10.1
0.2
0.2
0
0
7.43
7.23
54
57
12/1/2017
6.12
6.23
7.04
6.96
54.77
54.5
104
99
0.20
0.20
0.05
0.05
10.1
10.1
0.2
0.2
0
0
8.82
8.59
62
63
1/1/2018
6.65
6.78
6.78
6.98
48.84
48.73
92
81
0.20
0.63
0.05
0.05
5
5
0.2
0.9
0
0
7.08
7.39
60
60
2/1/2018
6.52
6.61
6.98
7.05
60.8
60.44
81
95
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
5.51
5.45
84
84
3/1/2018
6.93
6.57
7.13
7.06
59.09
59
102
96
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
5.88
5.99
85
85
4/1/2018
6.87
6.98
7.1
7.13
64.85
65.48
96
98
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
5.38
5.49
99
98
5/1/2018
6.81
6.77
7.23
7.12
71.67
71.24
108
109
2.00
0.32
0.08
0.06
5
5
0.2
0.2
0
0
4.25
4.38
101
103
6/1/2018
6.25
6.79
6.97
6.99
75.02
75.2
106
97
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
3.75
4.86
113
117
7/1/2018
6.63
6.79
6.95
7.05
78.74
79.04
102
106
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
5.21
5.16
80
81
8/1/2018
6.43
6.48
6.95
7.01
78.58
78.26
87
68
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
5.1
5.05
104
96
9/1/2018
7.02
7.01
7.68
7.49
80.11
79.84
99
66
0.20
0.20
0.05
0.09
3.87
34.8
0.2
0.2
0
0
5.14
5.36
34
33
10/1/2018
6.84
6.54
7.13
7.23
77.18
77.18
248
97
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
6.21
6.26
49
48
11/1/2018
6.12
6.32
6.55
6.35
71.69
72.23
70
135
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
5.16
5.88
84
84
12/1/2018
6.12
6.47
6.9
6.9
61.04
60.98
83
93
0.20
0.20
0.05
0.05
5
5.39
0.2
0.2
0
0
5.11
5.23
84
73
1/1/2019
6.12
6.65
6.74
6.91
60.01
60.19
77
65
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
7
7.1
90
87
2/1/2019
6.25
6.98
6.98
6.7
60.71
60.8
78
118
0.20
0.22
0.05
0.05
5
5.29
0.2
0.2
0
0
7.64
7.25
79
80
3/1/2019
6.39
6.27
6.53
6.84
59.63
59.5
84
104
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
6.96
6.84
84
81
4/1/2019
6.24
6.08
6.98
6.9
65.57
65.84
92
114
0.20
0.20
0.05
0.05
5
5
0.2
0.2
0
0
5.15
5.98
76
76
Page 1 of 11

Instream Water Quality Data (Minimum pH)
0
12/27/2014 4/6/2015 7/15/2015 10/23/2015 1/31/2016 5/10/2016 8/18/2016 11/26/2016 3/6/2'017 6/14/2017 9/22/2017 12/31/2017 4/10/2018 7/19/2018 10/27/2018 2/4/2019 5/15/2019
8/23/2019
Upstream pH (Min.)
Downstream pH (Min.)

Instream Water Quality Data (Maximum pH)
0
12/27/2014 4/6/2'015 7/15/2015 10/23/2015 1/31/2016 5/10/2016 8/18/2016 11/26/2016 3/6/2'017 6/14/2017 9/22/2017 12/31/2017 4/10/2018 7/19/2018 10/27/2018 2/4/2'019 5/15/2019
8/23/2019
Upstream pH )Max.)
Downstream pH (Max.)

50
E
r 40
Instream Water Quality Data (Temperature)
0
12/27/2014 4/6/2015 7/15/2015 10/23/2015 1/31/2016 5/10/2016 8/18/2016 11/26/2016 3/6/2'017 6/14/2017 9/22/2017 12/31/2017 4/10/2018 7/19/2018 10/27/2018 2/4/2019 5/15/2019 8/23/2019
.Upstream Temperature
Downstream Temperature

1200
1000
800
A 600
40
200
Instream Water Quality Data (Conductivity)
0
12/27/2014 4/6/2015 7/15/2015 10/23/2015 1/31/2016 5/10/2016 8/18/2016 11/26/2016 3/6/2017 6/14/2017 9/22/2017 12/31/2017 4/10/2018 7/19/2018 10/27/2018 2/4/2019 5/15/2019 8/23/2019
Upstream Conductivity
Downstream Conductivity

2.50
2.00
1.50
0.50
0.00
Instream Water Quality Data (Ammonia)
Upstream Ammonia
Downstream Ammonia
12/27/2014
4/6/2015 7/15/2015
■
111_i ■ ■ ■ ■-"et--
J\AL
•
10/23/2015 1/31/2016 5/10/2016 8/18/2016 11/26/2016 3/6/2017 6/14/2017 9/22/2017 12/31/2017 4/10/2018 7/19/2018 10/27/2018 2/4/2019 5/15/2019 8/23/2019

0.16
0.14
0.12
0.10
1 0.08
0.06
0.04
0.02
0.00
Instream Water Quality Data (Formaldehyde)
12/27/2014
4/6/2'015 7/15/2015 10/23/2015 1/31/2016 5/10/2016
8/18/2016 11/26/2016 3/6/2'017 6/14/2017 9/22/2017 12/31/2017 4/10/2018
7/19/2018 10/27/2018
2/4/2'019 5/15/2019
8/23/2019
Upstream Formaldehyde
Downstream Formaldehyde

100
60
50
3
0
12/27/2014 4/6/2'015 7/15/2015
Instream Water Quality Data (Sodium)
10/23/2015
1/31/2016 5/10/2016 8/18/2016 11/26/2016 3/6/2017 6/14/2017 9/22/2017 12/31/2017
4/10/2018
7/19/2018 10/27/2018 2/4/2'019 5/15/2019
8/23/2019
Upstream Sodium
Downstream Sodium

.2
1
0.8
106
0.4
0.2
0
12/27/2014
Instream Water Quality Data (Sulfide)
�Upstream Sulfide
Downstream Sulfide
■ ■
■
'
1
4/6/2015
7/15/2015
10/23/2015
1/31/2016
5/10/2016
8/18/2016
11/26/2016
3/6/2017
6/14/2017
9/22/2017
12/31/2017
4/10/2018
7/19/2018
10/27/2018
2/4/2019
5/15/2019
8/23/2019

12
to
.
6
O
I
0
12/27/2014
Instream Water Quality Data (Dissolved Oxygen)
Upstream D.O.
Downstream D.O.
4/6/2015
7/15/2015
10/23/2015
1/31/2016
5/10/2016
8/18/2016
11/26/2016 3/6/2017 6/14/2017 9/22/2017 12/31/2017
4/10/2018
7/19/2018
10/27/2018
2/4/2019
5/15/2019
8/23/2019

Instream Water Quality Data (Color)
180
160
140
120
1 PA
, A
_100
a
T.0 80
Color
, I'll \ �, „ —a —Downstream Color
\
l
V
20
12/27/2014 4/6/2'015 7/15/2015 10/23/2015 1/31/2016 5/10/2016 8/18/2016 11/26/2016 3/6/2'017 6/14/2017 9/22/2017 12/31/2017 4/10/2018 7/19/2018 10/27/2018 2/4/2'019 5/15/2019 8/23/2019

Appendix I — Color Study
King America Finishing, Inc.
NPDES Permit No. GA0003280
April, 2022
Page 51

CERTIFIED MAIL/ RETURN RECEIPT REQUESTED
October 23, 2015
Ms. Audra Dickson
Industrial Permitting Unit
Watershed Protection Branch
Georgia Environmental Protection Division
2 MLK, Jr. Dr. S.W., Suite 1152
Atlanta, GA 30334
RE: Color Study Results
King America Finishing, Inc.
NPDES Permit No. GA0003280
Screven County
Dear Ms. Dickson,
EPC1jpa/WRp
OCT 015
RECEIVED
This report is being submitted to the Environmental Protection Division ("Division") to communicate the
results of the color study required by Condition III.B.10 of the King America Finishing, Inc. ("King America")
NPDES permit that was issued and effective on December 1, 2013.
Per the color study plan, King America collected the following samples weekly beginning February 17,
2014 and ending August 15, 2014:
• Water collected upstream of the King America discharge,
• Water collected 25 feet downstream of the King America discharge,
• Wastewater treatment plant discharge prior to the addition of the polymer for color removal, and
• Final wastewater treatment effluent after polymer dosage.
In addition, the following mixtures were prepared to replicate low stream flow color impacts:
• 92% upstream river water + 8% effluent prior to polymer treatment,
• 92% upstream river water + 8% polymer treated effluent,
• 92% upstream river water + 8% deionized water,
• 92% upstream river water + 8% 500 ADMI color standard solution.

Each of the samples and mixtures described above were analyzed for ADMI color using Method 2120E of
the "Standard Methods for Examination of Water and Wastewater, 20th edition." Per the method, the
color value was recorded at the original pH and after the pH was adjusted to 7.6.
The results of the analyses are summarized in Table 1 of Appendix A.
For validation of the data, a theoretical ADMI value was calculated for each mixture, assuming a basic
mixing model. For example, for the mixture of 92% river water and 8% 500 ADMI color standard, the
theoretical ADMI value was calculated as follows:
[River/Standard Mixture Result] = (92% x [Upstream River Result]) + 8% x 500]
The theoretical ADMI color values for the mixtures are tabulated in Table 2 of Appendix A. The theoretical
color values were plotted against the actual color values to observe the degree of correlation. These plots
are shown in Figure 1 of Appendix B.
Please note that the ADMI Color method requires filtration of samples prior to color analysis, and at the
beginning of the study, all of the mixtures were prepared prior to filtration. However, after ten (10) weeks
of the study, it became apparent from the validation process described above that the 500 ADMI color
standard was being filtered out of the sample to a significant degree, resulting in ADMI color values well
below the expected values. This was not observed in other mixtures. To correct this, on April 23, the
facility begin filtering the river sample prior to mixing it with the ADMI color standard and analyzing for
color. The subsequent results for the color standard mixture were in line with theoretical values, so the
procedure was continued through the end of the study. For the purpose of the subsequent analysis of the
color standard mixture results, only the results from April 23 to the end of the study were considered.
The range of the coefficients of determination (IV) for the correlation plots is 0.92 to 0.98, indicating the
basic mixing model is capable of predicting the ADMI color values of mixtures to a high degree.
The color difference (result — upstream river result) was also calculated for each sample and mixture. The
color differences are summarized in Table 3 of the Appendix A. The current King America Permit includes
a limit of a difference of 80 ADMI color units. Graphs of the results compared to the 80 unit color
difference are in Figures 2 and 3 of Appendix B.
The average and maximum color difference are summarized in Table 4 of Appendix A. The following
observations can be made regarding the information in this table:
• The average color difference in all cases is below the generally accepted Method Detection Limit
(MDL) of this method of 25 ADMI Color Units. Therefore, the average color difference is within
the error of the ADMI method and can be considered negligible.
• The maximum color differences for all scenarios that replicate fully mixed conditions, with the
exception of the 500 ADMI standard, are also below the generally accepted MDL, and are
therefore within the error of the method. These increases can also be considered negligible. The

scenario that uses the 500 ADMI cannot be considered representative of the discharge since King
America's effluent color values have been consistently below 160 ADMI Color Units.
• The maximum color differences for all scenarios that do not replicate fully mixed conditions are
very low (less than two times the MDL). Since the King America discharge mixes rapidly in the
stream, these maximum color differences would not be observed in -stream. They are useful,
however, in demonstrating that even under worse case conditions, the color difference would be
insignificant.
Based on these observations, it is apparent that the King America discharge has a negligible impact on the
color of the receiving stream, even under low stream flow conditions. As a result, King America
respectfully requests that no color limitations, whether based on the effluent value or in -stream color
difference, be applied in the facility permit.
If you have any questions or need any additional information, please contact Lee Slusher of Milliken &
Company's Corporate Environmental Department for more information at [e-mail] or
[phone].
k you,
Robert La
Plant Manager
King America Finishing, Inc — Longleaf Plant
Cc: Mr. Bruce Foisy, EPD

Table 1- Analytical Results
r Mixture 4 (M4)
92% Upstream
8% 500 ADMI Std.
pH Adj. I
c6
LD
1 531
01
LO
ri
Ln
r
Ln
d•
LD
56
551
m
Lf1
O
LD
n
N
ri
N
M
-1
123
Ln
N
.-1
01
.-i
.-i
LD
0
.-i
O
ri
.-1
c
01
0
.--I
.--I
01
01
0
01
0
N
LD
LO
.--1
LO
N
01
ILL
LD
CO
0
r•
1
Ln
84.
0
N
m
.-i
Original
rl
1�
47
N
L.D
.--1
Ln
T�
Lf1
t�
LD
.-i
LD
60
65
68
LD
NMINNNO
ri
N
ci
0
rl
fn1
r1
.-1
r1
N
102
N
01
N
0
1\
(7)
01
00
ml
LD
Ln
LD
.-1
LD
LD
01
80
00
00
47.0
n
00
100.11Ojai- 132.0
Mixture 3 (M3)
92% Upstream
8% Deionized
pH Adj.
d'
Lf1
54
m
LD
01
Ln
Ln
LO
89
.--1
N
O
1\
LD
01
L11
01
N
0
ci
LI1
01
d'
01
95
0
0
ci
V
00
83
N
1�
74
01
LD
N
Lf1
L. 381
Ln
M
m
m
N
LD
01
d•
LD
Ln
0
•
m
01
O
Original
0
LO
51
0
LO
o
LO
N
LO
80
01
LD
00
LO
0)
01
n
01
o
0
m
01
.-i
01
fV
01
m
01
01
N
80
73
75
00
LO
0
Lf1
Ln
M
LD
M
271
LD
LO
000p
d'
LD
Lfl
27.0
N
LO
Mixture 2 (M2)
92% Upstream
8% Effluent
pH Adj.
00
LO
58
67
N
LO
CO
LO
0
0 1
74
1 731
Ill
01
98
1041
LO
0
r1
0
rti
0
103
81
86
0)
N
73
N
N.
CO
Ln
01
m
01
M
r1
m
N
NV)
M
N
LD
31.0,
LD
N
0
0
ri
Original
70
53
00
lD
63
00
LD
Ol
00
l0
1---
Ln
N
98
.--I
o
104
OV
r
100
102
LD
O1
N
00
84
77
dr
N
N
N
LD
Ln
01
m
00
m
321
54
N
LO
32.0
m
1-,
104.0.
Mixture 1(M1)
92% Upstream
8% Aeration Basin
'p
Q
x
Cl.
LMO
L�f1
O^
L(0
co
0011
00
Cr)N
001
Cr)^
cm-1
ri
00
ci
105
0
ci
104
CO00
1 83
Q^1
N
[IL
551
401
m
33_
O
0N.
�
O
m
O1
N.
O
CO .--1-1
r1
CTo
m
O
Cr)
LD
CO
Ln
N
LD
N
Ln
m
LD
06
N
1.
LD
N
102
m
o
r•-i
l0
O
CHr
105
r
LO
01
83
84
I�
N
0
N
72
Q1
Ln
01
CO
33
N
m
00
LD
01
V
Ol
LO
32.0
O1
0
o
ri
Sample 4 (S4)
Effluent, Prior to
Discharge
pH Adj.
58
631
51
n
d'
M
LD
0
LD
62
00
Ln
43
IN
Ln
Tr
Lfl
01
rNi
LD
N
77
00
LO
N
LD
LO
Ln
h
N
1�L
LO
Ln
LD
ci
LO
37
Ln
L)
O
Ln
01
d'
47
01
I�
O
m
O
LNO
O
N
ci
To
_
'El
O
50
M
LID
Cr)
d•
48
n
LO
0
LO
62
58
N
d'
49
57
LD
m
01
1--..N
i
75
m
64
56
Ill
N
LO
LD
Ln
LO
01
Ln
l0
M
LO
Ln
N
Ln
48
46
Ln
N
0
m
1-
LSO
0
m
r i
Sample 3 (S3)
Aeration Basin,
Prior to Polymer
Addition
pH Adj.
ri
LO
65
M
Ln
45
LO
1�
LO
LD
in
L.
m
LO
47
51
LD
LO
1 127
01
1�
77
Ln
n
67
01
Ln
77
67
67
(0 lO
r1
d'
00
Ln
48
01
d'
CO
N
N
1�
28.0
CO
rvl
LD
127.0
Original i
531
1-
L0
m
Ln
73
63
Ln
lD
o
LO
45
48
65
0
rm1
77
00
1-
01
1---
01
LDLO
56
76
01
01
1\
62
01
M
01
Ln
0
Ln
49
00
N
0
CO
0
N•
63.6
0
Om
.m-1
Sample 2 (52)
River, 25-ft
downstream of
discharge
_pH Adj.
m
Lfl
01
LO
00
LD
N
LD
L0
LD
01
CO00
00
0
00
108
01
01
LO
0
94
ri
0
00
01
n
0
Ln
00
84
78
to
00
c1
N.
47
0
to
M
ri
M
74
LD
Ln
m
lD
O
M
LnO
N
O
r-1
To
06
'i
O
60
56
67
d'
LD
00
LO
86
75
Lll
1---0
105
Ln
n
0
N
01
m
01
Ln
01
00
01
N
00
87
n
N
m
00
70
48
01
m
00
m
30
dr
1\
Ln'
Ln
O
LO
O
om
n
N
O
0
c1
r Sample 1(51)'
River,
Upstream of
Discharge
pH Adj.
67
58
01
LO
r1
LD
CO
LD
01
00
N
CO
85
1�
0
d'
0
0
1
c
102
n
01
01
01
N
N
4-1
87
83
75
06
IL
50
41
34
M
m
N
N
561
ri
LO
33.0
77.01
122.0
Original
N
LD
53
L--1
I�
V
Lot
LD
LO
06
76
1 73
105
ci
0
.--I
CO
0
.- I
0
0
.- 1
0
0
c I
L -1
0
ci
0l
01
m
CO
00
00
LD
N
0l
00
70
47
40
N
m
351
m
N
LO
Ln
0l
Ln
o
•
N
M
74.7
108.0
Sample Date
February 17, 2014
February 19, 2014
February 27, 2014
March 7, 2014
March 13, 2014
March 19, 2014
March 26, 2014
April 4, 2014
April 12, 2014
April 16, 2014
April 23, 20141
April 28, 2014
4--1E
O
N
2
May 14, 2014
May 21, 2014
May 29, 2014
June 4, 2014
June 11, 2014,
June 21, 2014
June 25, 2014
July 2, 2014
July 9, 20141
July 16, 2014
July 21, 20141
July 30, 20141
August 6, 20141
August 15, 2014
7
E
C
Average
E
7
E
X

Table 2: Mixtures —Analytical Results and Theoretical Calculations
Theoretical 4 (T4)
92% Upstream
8% 500 ADMI Std.
pH Adj.
N
LID
581
01
VD
r1
LO
0o
tD
al
00
e-1
00
Q
00
1061
V'
0
0
N
0
N.
a1
01
01
0
N
N.
00
83
ul
N.
01
co
tL
.--i
lr1
a-1
.7ul
341
33
77
tD
ri
LO
M
m
N
n
1201
f0
c
.ta
'L
O
63
53
tL
LD
lD
LD
0
01
LID,-1
N
73
1 104
0
ri
108
100
0
0
-1
L-1
0
ri
a1
01
83
00
CO
76
0o
CO
70
0p0p
V
40
32
u1
M
M
No
56
59
32
751
o0
ri
Theoretical 3 (T3)
92% Upstream
8% Deionized
pH Adj.
N
lD
00
lr1
al
LD
r-1
LD
01
LD
0
01
N
00
111
00
LO
00
IEOZ
0
r`�i
m
0
r-irNi
00
01
01
01
r-1
N
00
83
75
01
00
-1
N
05
-1
.7
V
m
1 33
LO
N.
LID
Li)
-1
l0
33
77
ri
N
Original
N
LO
53
70
M
LO
LC)
LO
0
01
tD
N
m
N
ul
0
ILOT
00
0
0
0
0
o
r-1
O
01
01
83
00
00
LD
N
N.
00
70
48
40
N
m
35
73
55
0
LD
Ni
m
75
00
0
Theoretical 2 (T2)
92% Upstream
8% Effluent
'
Q
2
a
l0
l0
CO
u1
CO
LO
0
lD
68
87
80
83
102
0
O
ri
106
104
ul
01
N
01
00
ri
ri
85
.-1
00
75
88
r1
N.
r-1
V1
N
.7
36
34
75
55
N
LO
V
m
LC)
N
00
c-I
ri
jp
.,a
'L
0
LL0
{
u`1
lmO
LID
LOO
0000
75
N
0
001
0
0
0001
011
0011
81
0000
l^D
87
70
op
V
40
34
36
N
55
LO
34
74
0
Theoretical 1(T1)
92% Upstream
8% Aeration Basin
a
2
a
n
lO
01
u1
00
Lip
O
l0
01
LD
N
00
r-1
00
M
00
N
0
r1
0
0
ri
l0
0
ri
0
ri
LD
01
N
01
00
.-1
ci
Lfl
00
.-I
00
75
CO
CO
tL
r-1
u1
ri
.7
36
34
75
-- - 54
N
l0
34
76
00
r-1
ci
Original
ri
LD
54
70
N
LD
N
LO
00
00
ul
N
N
N.
O
0
r-1
N.
01
V1
0
r 1
N
0
r-1
00
01
al
O1
N
al
N
00
85
LC)
n
N
00
r1
n
CO
V
J
40
34
LO
M
ri
N
54
ri
LO
.7
M
74
ul
0
r-1
Mixture 4 (M4)
92% Upstream
8% 500 ADMI Std.
pH Adj.
00
l0
53
al
LO
51
57
64
ID
ul
55
01T
Li"
O
l0
it
'-
N
rm-I
M
-1-I
ul
cN-I
01
r�-I
lD
0 vi
O
r�-I
01
01
O
c�-I
01
01
O
01
O
N
lD
LO
.-i
LO
01 01
77
LO
W
r-1
u
CO1 00
N
rm-I
Original
ri
N
N.
N
LO
ri
111
57
67
ri
LD
0
LD
651
681
126j
132
120
N
N
r-1
r1
N
ri
N
0
r-1
1021
N
01
N
0
r-1
N
01
01
00
a1
l0
651
r-1
LO
CD
01
0
00
88
47
85
N
M
ri
CM
C
M
2
a=+
X
92% Upstream
8% Deionized
. •
2
a
c
u1
541
M
l0
al
u1
65
Op
CO,
-I
n
OL
LO
Ol
ul
dl
0
ul
01
01
01
ul
01
o
0
00
83
^
74
38
M
(mY)
67
49
1111
33
O
Original
0
LO
e-1
u1
60
0
LD
N
lD
0
00
al
LO
00
LO
al
al
N
01
100
m
01
ri
01
N
01
M
01
al
N
80
73
75
00
LO
50
L(1
m
36
1�
N
LD
t0
00
V
LO
ul
27
01
l0
100
Mixture 2 (M2)
92% Upstream
8% Effluent
pH Adj.
68
00
ul
I'-
l0
N
LO
00
LC)
0
O1
74
I 731
ul
O1
CO
01
.7
0
ri
lD
0
ri
-1
0
ri
-1
0
ri
m
0
ri
ri
00
lD
00
al
n
m
N
N
N
CO
u1
al
(Y1
al
m
31
N
n
m
In
N
lD
r-1
m
75
106
Original
OL
53
00
LO
63
681
01
0o
LD
N
75
00
a1
ri
0
104
104
0
0
N
o
LO
al
N
00
V
0o
N.
N
74
N
N
LO
In
Cr)
m
CO
M
N
m
0
n
V
u1
N
LID
N
M
.7.7
n
o
1 Mixture 1(M1)
92% Upstream
8% Aeration Basin
pH Adj.
63
00
u1
70
64
781
N
01
78
al
N
981
N
01
m
e�-i
al
0
105
m
0
1041
C1
0o
831
01
N
Ni
N
ri
n
55
o
V
zt
mm
331
701
501
62
m
lD
N
m
r�i
1 Original
(1')
LD
53
N
LO
57
63
90
77
ID
N
f 102
M
0
LD
0
104
105
104
l0
01
83
77
70
72
01
u1
01
M
1 33
N
M
00
00
49
01
l0
Ni
M
74
LD
0
Sample Date
February 17, 2014
February 19, 2014
February 27, 2014
March 7, 2014
I March 13, 2014
I March 19, 2014
March 26, 2014
April 4, 2014
Y�-1
0
N
csi
Q
a
.17
,-
0
N
l�D
Q
a
�-1
r
0
N
N
Q
a
April 28, 2014
,I
0
N
N
T
C
May 14, 2014
May 21, 2014
May 29, 20141
June 4, 2014
June 11, 2014,
June21,2014
June 25,20141
r�i
0
N
N
T
r�-1
0
N
01
Trn
July 16, 2014
C-I
0
N
N
-,
r�i
0
NJ
O
,
August 6, 20141
August 15, 2014
Minimum
Averag]
7
E
N

Table 3: Color Differences (Result -Upstream)
rl
N
C6)
G
92% Upstream
8% 500 ADMI Std.
pH Adj. !
ri
Lf)
0
=10!
,-1
,-INNM
I
L.n
.D
0
-481
V
I.�
O
N
D
M
Ql
27
Ql
.--I
0
N
281
40!
Ql
N
N
M
28!
joz
.-I
N
If)
N
0
OD
^
0
d
Original
lD
V
M
.--I
Ol
M
N
V)
c-I
M
a --I
-40
-33
00
r-I
N
M
20
L--I
N
N
N
24
r-I
r-I
N
M
r-I
N
N
42
(7)
N
m
M
lD
N
M
N
24
Q)
N
O
O
dr
0
O
,-I
42.0
I -I
VIa
M
92% Upstream
8% Deionized
•a
=
m,i
dr
.D
N
M
0
-1
U)x-I
a 1
CT)
00
N�
m
dr
N
M
0
M
co -I
N
N
M
.--I
0
0
1-
LI)
0
N
,--I
I
2.0
Original
N
N
chi
H
dr
R
O
N
Ln
lD
V
CO
N.
01
Cr)
lD
dr
00
m
dr
N
M
Lf1
Cr
00
N
CO
M
0
Cr
VI
Lf)
4.0
,-1
to
ly
2
92% Upstream
8% Effluent
pH Adj.
r1
0
N
1--I
0
,--I
00
N
N
c-I
.D
LID
V
V
N
(S
, -I
.D
M
dr
N
r1
c-I
CO
N
I
LIl
N
Lf)
M
,--I
0
Q)
rI
N
I
0
00
Original
00
0
m
rI
N
71
0
N
N-
O
Q
V
0
rI
M
71
V
L-1
Lfl
r
1
N
O)
r1
�
M
M
NM
0
Lf)
r1
-0.4
0
Ql
N
VI
rl
92% Upstream
8% Aeration Basin
pH Adj.
c
O
-i
m
0
r1
00
I
.D
I
CT
,
r
,
m
IN
CO
dr
CO
r1
m
I
O
V
CO
ci
0
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.-1
1
CD
N�
I
lD
I
r1
O
00
1
r 1
,-i
I
0
O
, -1
Original
,-1
0
Q1
I
N
I
M
I
0
,--I
M
M
I
N
N
I
In
M
c'M
I
o
Q
I
c-I
Ql
N
(V
Cal
71
I
,--I
m
I
Lf)
I
n
10
0
Ol
rI
CO
O
,
0
N
r1
,-N
H!
V
V)
Effluent, Prior to
Discharge
pH Adj.
Q)
Lf)
00
r I
v-
,--1
I
,-1
Q)
N
0
N
),
N
dr
.D
-52
m
L11
N
NJ
c1
N
I
N
N
V
Lf)
,
Lf)
N
I.
N
N
M
NJ
lD
I
,-I
,-i
dr
I
,--1
N
N
rI
CO
N
01
I
CO
rI
0
lwD
al
dr
L-I
27.0
Original
NJ
r1
10�
NI
N
.D
r1
r1
0
m'-'
V'
Lf1
e--1
M
.D
N
1-9
rI
'-`2m
.D
r1
N
.D
N
.D
N
Q)
71
N
M
,--I
I
M
N
Ill
NI
,--1r1
24
INLf1
N
0
,--I
.D
,--1
0
.MD
0
,M-I
0
M
N
H
141
H
Aeration Basin,
Prior to Polymer
Addition
pH Adj.
.D
N
.D
1
.D
,-1
CO
M
N
N�
rl.D
N
NI
0
m
L-)
dr
Lf)
N
00
rl
N
N
1 -47I
0
N
-24
N
m
N
dr
I
rI
r1
CDL/)
24
ri
00
NI
00
N
,--I
e-1
0
lOD
0r
cM-I
25.0
Original
01
1
V
rl
CO
rl
0
NJ
N.
n
N
r1
rl
m
rl
0
.D
-53
m
'7
30
m
N
m
NJ
0
N
.--I
NI
M
0
0
NJ
Ql
Li-)
,--I
rI
I
N
N
LI)
,--I
dr
N
CO
N
r1
N
0
LD
,--I
,L-I-I
30.0
N
N
River, 25-ft
downstream of
discharge
"O
Q
2
a
c 1
Tv
r1
N
O
V
If
L -1
Lf11
V
CO
V
L -1
-15
N
,--1
m
V
0
M
r1
N
N
M
O
N
0
LA
,--1r1
.1-0
ri
ri
Original
N
I
M
dr
I
0
N
I
rl
I
N
0
cr
,--i
I
00
I
N
I
lD
I
,--I
e
,--I
I
,-I
I
rl
d
I
b
rl
rl
I
.D
L11
I
rl
r1
,
,--I
0
00
0
71
0
LD
Sample Date
February 17, 2014
February 19, 2014!
February 27, 2014
March 7, 2014
March 13, 2014
March 19, 2014
March 26, 20141
April 4, 2014
•-1
O
N
N
,--1
Q
Q
,�-I
O
N
.O
O_
Q
April 23, 2014
1 April 28, 2014
May 7, 20141
May 14, 2014
May 21, 20141
May 29, 20141
June 4, 2014
June 11, 2014
June 21, 2014
June 25, 2014
,--1
0
N
fV
Y
-,
July 9, 2014
July 16, 2014
,�-1
0
N
rl
rq
=
July 30,20141
August 6, 2014
August 15, 2014
Minimum
Average
Maximum

Table 4: Summary of Average and Maximum Color Differences
Y
7 C
U. a✓
V1
(U 4-
u Li
a X
Yes
0
z
0
z
H
}
'^
y
''
y
'^
}
3
o
E v p
X Eng
m a,
c
v
>..>
a,
No
No
0
zz
0
Yes
Yes
Yes
a,
>
Yes
Yes
0
zz
0
L
E C
i O
E a) N
X h
ro T al
2 v
V D.
C n
e-
i
m
N
:M
N
,-ii
O
al
00
V
N
•
0
d0 m J 1A
a 2
u
Yes
Yes
Yes
N
QJ
_ Yes
Yes
V1
QJ
01
el
Yes
V1
01
Yes
01
cu
Yes
vi
o
i2 o
m 0> Uro CC
al usfC0 c-I
> CO 2Q d ,
U G
C D
a --I
e�-I
i�-I
im-I
ci
ei
p
N
lD
LIDO
(0
= C
. OD
O
Adjusted
(0
C
OD
0
Adjusted
Original
Adjusted
(0
C
OfY
0
Adjusted
(0
C
G0
0
Adjusted
(0
C
CO
0
Adjusted
(0
C
Ea
L
0
Adjusted
Sample Results
River, 25-ft downstream of discharge
Aeration Basin, Prior to Polymer Addition
Effluent, Prior to Discharge
92% Upstream+8% Aeration Basin
92% Upstream+8% Effluent
92% Upstream+8% Deionized Water
92% Upstream+8% 500ADMI Std.
0
C YX
a)
u
H
N
m
d-
L(1
l0
N

Appendix B

Figure 1: Mixture Results versus Calculated Theoretical Values
120
100
80
60
40
20
Actual vs. Theoretical
92% Upstream + 8% Aeration Basin
(Original pH)
y=1.0339x - 2.3864
R' = 0.9403
ri
00
eh'
•
• •
•
Actual vs. Theoretical
92% Upstream + 8% Aeration Basin
(pH Adjusted)
120
100 y=0.9814x+14268 ,
R2 = 0.9247 • ; 0
804,i
•0.ir
Pi" •
60
40
44
20
O it
O 20 40 60 80 100 120 0 20 40 60 80 100 120
120
100
80
60
40
20
Actual vs. Theoretical
92% Upstream + 8% Effluent
(Original pH)
•
y = 0.9742x +2.5717
R'=0.9641
• Or •
.10
6.4
•
Actual vs. Theoretical
92% Upstream + 8% Effluent
(pH Adjusted)
120
100 y=0.9194x+4 8908 •
R2 = 0.9356 �.
80 • :.!
sic •••
f•
60 • . r
40 •�
•
20
O 0
O 20 40 60 80 100 120 0 20 40 60 80 100 120
120
100
80
60
40
20
Actual vs. Theoretical
92% Upstream + 8% Deionized
(Original pH)
y = 0.9102x+ 1.2502
R'=09773
•: i
•
••: •
ge
0
0 20 40 60 80 100 120
120
100
80
60
40
20
0
Actual vs. Theoretical
92% Upstream + 8% Deionized
(pH Adjusted)
y = 0.8678x+4 1782
R' = 0.9543 �•�j
••
0 20 40 60 80 100 120
RFP.F4 1Gn

Figure 2: Color Differences (Samples — Upstream)
100
80
60
40
20
Color Increase: [River, 25-ft downstream of discharge] -[Upstream]
Original
0
-20
pH Adj.
-40 Current Standard
-60
-80
-100
100
80
60
40
20
0
-20
-40
-60
-80
-100
100
80
40
20
0
-20
40
-60
-80
• 100
N a m o r- a N a e1 CO n N m O N m D M o N a 1 co a
• .1 N M \ .1 N N \ .-i .1 N \ \ e-1 N m \ e-i N
co
N N m M M M M Tr Tr ▪ Tr LAV\'1 V\1 eD ▪ ^ r N. • N. 00
Color Increase: [Aeration Basin, Prior to Polymer Addition] -[Upstream]
•
N a rn o N a e1 N a e1 CO en N CC) D N m D m 0 N a .1 CO a .-i
e- I N \ -4 .1 N rn \ .1 N N \ .-1 e-1 N \ \ eti N m \ ti N N \ e1
N N m M m m M ▪ v a V\1 M M M e\D M N N N nco
00
Color Increase: [Effluent, Prior to Discharge] -[Upstream]
N a m 0 N a e1 N a .-1 CO LA N C eD N 01 ID m 0 N a .1 0o a e1
e-1 N \ .1 .1 N m \ c-I N N \ e•-I c-I N \ \ .-1 N m \ e-I N N \ \
\ \ M \ \ \ \ a \ - \ vi \ \ \ 0 \ \ 00
N N m m Al m a `Cr a en en en UD 1D eD N N N co
- Original
- pHAdj.
Current Standard
- Original
- pHAdj.
Current Standard

Figure 3: Color Differences (Mixtures — Upstream)
100
80
60
40
20
Color Increase: [92% Upstream+8% Effluent] -[Upstream]
- Original
0
-20 - pH Adj.
-40 Current Standard
-60
-80
-100
100
80
60
40
20
0
-20
N a m o N ct rl N O ei CO ul N T ID N Ol 10 m 0 N a eti CO a a-1
✓ 1 N \ e l ei N M \ a-1 N N \ e-1 a-1 N \ \ e-1 N m \ ei N N \ r1
co
N N m m rn rn m • c a a 1\f1 Ln u\1 VD VD • VDki)n N N N- 0000
Color Increase: [92% Upstream+8% Effluent] -[Upstream]
- Original
pHAdj.
-40 Current Standard
-60
_80
100
100
80
60
40
20
N d M o N a e-I N • ei O Ln N 01 t0 N 01 10 m o N a eti CO d e-1
ei e-I N M \ e-I N N \ e-1 ei N \ - e-1 N CO \ ei N N \ ai
N N M m CO m CO ▪ a d a a 11 U 1 1! CO 1 N. n n N oo
Color Increase: [92% Upstream+8% Deionized Water] -[Upstream]
- Original
20 !tera.
t�i ---pHAdj-
-40 Current Standard
-60
-80
100
N a m o h a e-1 N • ei CO In N O, ID N O1 10 m o N a eti 03 a a-1
ei N \ e-1 e-1 N m \ - e-I N N \ a-1 1-1 N \ \ e•1 N m \ a-1 N N e-1
\ \ M \ \ \ \ \ \ \ U1 \ \ \ 10 10 \ \ \ N- \ \ \ 00 ----
N CO M M M a Tt 7 V1 ul n a0 aD 0 h n N CO
100
80
40
20
0
-20
-40
-60
-80
100
2/17 2/24 3/3 3/10 3/17 3/24 3/31 4/7 4/14 4/21 4/28 5/5 5/12 5/19 5/26 6/2
Color Increase: [92% Upstream+8% 500 ADMI Std.-[Upstream]
— Original
— — — pH Adj.
Current Standard

RGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PRD IONDMSION
SUMMARY PAGE
Name of Facilir.: City of Adel - Adel WPCP
NPDES Permit No.: GA0024911
This is a reissuance of the NPDES permit for the Adel WPCP. Up to 4.3 MGD (daily maximum) of
treated domestic wastewater is discharged to Bear Creek in the Suwannee River Basin or up to 2.5
MGD is land applied onto a dedicated site in Cook County.
The permit expired on May 31, 2018 and became administratively extended.
The permit was placed on public notice from December 19, 2019 to March 16, 2020. No public
comments were received.
Phase Note The Following Ch:iIIgot to the Proposed NPDES Permit From The Existin+Permit:
Part I.B.1. — Effluent Limitations and Monitoring Requirements:
• Removed monthly and weekly average flow limitations, since the facility is equipped with an
HCR controller and is limited based on an effluent to stream flow ratio
• Added a daily maximum effluent flow of 4.3 MGD based on facility design
• Clarified the instream wastewater concentration limitations based on the effluent to stream flow
ratio and included a calculation as reference for reporting purposes
• Removed effluent loading limitations for biochemical oxygen demand, total suspended solids,
and ammonia, since the facility discharges a variable flow based on stream conditions and a
calculated loading is not representative
• Decreased monthly average ammonia limit from 16.8 to 10.0 mg/L in accordance with EPD's
NPDES Permitting Strategy for Addressing Ammonia Toxicity, 2017.
• Revised five-day biochemical oxygen demand removal requirements from 85% to 65% in
accordance with requirements for equivalent to secondary treatment standards for pond systems
• Decreased monitoring frequency for total phosphorus and nitrate -nitrate from 1 day/week to 1
day/month
• Added orthophosphate, organic nitrogen, and total Kjeldahl nitrogen monitoring requirements
to determine nutrient speciation and to quantify nutrient loadings in the Suwannee River Basin.
• Removed total recoverable mercury monitoring, since analysis indicated that the pollutant is
not present at levels of concern
• Removed long term biochemical oxygen demand testing requirements since they have been
completed
• Revised chronic whole effluent toxicity testing requirements to require one test for two
consecutive quarters following permit issuance and annually thereafter to verify testing results
Adel WPCP
NPDES Permit No. GA0024911
March 2020
Page 1 of 2

Part I.B.2. — Land Treatment System:
• Clarified that the flow limitation of 2.5 MGD is a weekly average limit, in accordance with
sprayfield capacity, rather than average monthly and/or average daily
• Clarified that samples collected under B.1. for influent biochemical oxygen demand and total
suspended solids monitoring may be used to satisfy the requirements under B.2, for days when
both discharge locations are utilized
• Added monitoring requirements for total Kjeldahl nitrogen from the stabilization pond to the
sprayfield
• Replaced fecal coliform monitoring in groundwater wells with monitoring for Escherichia Cali
and clarified that downgradient wells are required to meet the maximum contaminant level in
accordance with the Safe Drinking Water Rules and Regulations
Standard Conditions and Boileril late Modifications!
The permit boilerplate includes modified language or added language consistent with current NPDES
permits.
Final Permit Determin;lions and Public Comments.
® Final issued permit did not change from the draft permit placed on public notice.
❑ Public comments were received during public notice period.
❑ Public hearing was held on
❑ Final permit includes changes from the draft permit placed on public notice. See attached
permit revisions and/or permit fact sheet revisions.
Adel WPCP
NPDES Permit No. GA0024911
March 2020
Page 2 of 2

E;ti*
r
1
DEPARTMENT OF NATURAL RESOURCES
F.NVIIZONMEt4T,ALPROTECTION DIVISION
Honorable Luther Duke, Mayor
City of Adel
Post Office Box 1530
Adel, Georgia 31620
Dear Mayor Duke:
Richard E. Dunn, Director
EPD Director's Office
2 Martin Luther King, Jr. Drive
Suite 1456, East Tower
Atlanta, Georgia 30334
404-656-4713
MAR 1 9 2020
RE: Permit Issuance
Adel Water Pollution Control Plant
NPDES Permit No. GA0024911
Cook County, Suwannee River Basin
Pursuant to the Georgia Water Quality Control Act, as amended; the Federal Water Pollution
Control Act, as amended; and the Rules and Regulations promulgated thereunder, we have today issued
the attached National Pollutant Discharge Elimination System (NPDES) permit for the referenced
wastewater treatment facility.
Your facility has been assigned to the following EPD office for reporting and compliance:
Georgia Environmental Protection Division
Watershed Compliance Program
2 Martin Luther King Jr. Drive
Suite 1152 East
Atlanta, GA 30334
Please be advised that on and after the effective date indicated in the attached NPDES permit, the
permittee must comply with all the terms, conditions and limitations of this permit.
If you have any questions, please contact Kelli-Ann Sottile at 404-463-4945 or via email at
[e-mail].
Sincerely,
� 4
Richard E. Dunn
Director
RED1kas
Attachment: NPDES Permit No. GA0024911, Fact Sheet
cc: Tommy Rice, City of Adel (:.: • . • ; ...... . )
Marzieh Shahbazaz, EPD Watershed Compliance Program (MarAehshahbazaz(c dnr.aa.aov)

Permit No. GA0024911
Issuance Date:
G_1� RGIA. MAR 19 2020
DEPARTMENT OF NATURAL RESOURCES
ENV[RONMENTI'AL PROTECTION DIVISION
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM PERMIT
In accordance with the provisions of the Georgia Water Quality Control Act (Georgia Laws
1964, p. 416, as amended), hereinafter called the State Act; the Federal Water Pollution
Control Act, as amended (33 U.S. C. 1251 et seq.), hereinafter called the Federal Act; and the
Rules and Regulations promulgated pursuant to each of these Acts,
City of Adel
P.O. Box 1530
Adel, Georgia 31620
is authorized to discharge from a facility located at
to receiving waters
Adel Water Pollution Control Plant (WPCP)
1325 Honeymoon Lane
Adel, Georgia 31620
(Cook County)
Bear Creek
(Suwannee River Basin)
in accordance with effluent limitations, monitoring requirements and other conditions set forth
in the permit.
This permit is issued in reliance upon the permit application signed on January 17, 2018, any
other applications upon which this permit is based, supporting data entered therein or
attached thereto, and any subsequent submittal• of supporting data.
This permit shall become effective on April 1, 2020.
This permit and the authorization to discharge shall expire at midnight, March 31, 2025.
Director,
Environmental Protection Division

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 2 of 28
Permit No. GA0024911
PART I
EPD is the Environmental Protection Division of the Department of Natural Resources.
The Federal Act referred to is The Clean Water Act.
The State Act referred to is The Water Quality Control Act (Act No. 870).
The State Rules referred to are The Rules and Regulations for Water Quality Control (Chapter 391-3-6).
A. SPECIAL CONDITIONS
1. MONITORING
a. The monthly average, other than for fecal coliform bacteria and Escherichia Coli, is the
arithmetic mean of values obtained for samples collected during a calendar month.
b. The weekly average, other than for fecal coliform bacteria and Escherichia Coli, is the
arithmetic mean of values obtained for samples collected during a 7-day period. The
week begins 12:00 midnight Saturday and ends at 12:00 midnight the following Saturday.
To define a different starting time for the sampling period, the permittee must notify the
EPD in writing. For reporting required by Part I.D.1. of this permit, a week that starts in
one month and ends in another month shall be considered part of the second month. The
permittee may calculate and report the weekly average as a 7-day moving average.
c. Fecal coliform bacteria and Escherichia Coli will be reported as the geometric mean of
the values for the samples collected during the time periods in I.A 1.a. and I,A.1.b.
d. Untreated wastewater influent samples required by I.B. shall be collected before any
return or recycle flows. These flows include returned activated sludge, supernatants,
centrates, filtrates, and backwash.
e. Effluent samples required by I.B. of this permit shall be collected after the final treatment
process and before discharge to receiving waters. Composite samples may be collected
before disinfection with written EPD approval.
f. A composite sample shall consist of a minimum of 5 subsamples collected at least once
every 2 hours for at least 8 hours and shall be composited proportionately to flow.
8.
Flow measurements shall be conducted using the flow measuring device(s) in accordance
with the approved design of the facility. If instantaneous measurements are required,
then the permittee shall have a primary flow measuring device that is correctly installed
and maintained. If continuous recording measurements are required, then flow
measurements must be made using continuous recording equipment. Calibration shall be
maintained of the continuous recording instrumentation to ± 10% of the actual flow.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 3 of 28
Permit No. GA0024911
Flow shall be measured manually to check the flow meter calibration at a frequency of
once a month. If secondary flow instruments are in use and malfunction or fail to
maintain calibration as required, the flow shall be computed from manual measurements
or by other method(s) approved by EPD until such time as the secondary flow instrument
is repaired. For facilities which utilize alternate technologies for measuring flow, the
flow measurement device must be calibrated semi-annually by qualified personnel.
Records of the calibration checks shall be maintained.
h. If secondary flow instruments malfunction or fail to maintain calibration as required in
I.A.1.g., the flow shall be computed from manual measurements taken at the times
specified for the collection of composite samples.
i. Some parameters will be reported as "not detected" when they are below the detection
limit and will then be considered in compliance with the effluent limit. The detection
limit will also be reported.
2. SLUDGE DISPOSAL REQUIREMENTS
Sludge shall be disposed of according to the regulations and guidelines established by the EPD
and the Federal Act section 405(d) and (e), and the Resource Conservation and Recovery Act
(RCRA). In land applying nonhazardous municipal sewage sludge, the permittee shall comply
with the general criteria outlined in the most current version of the EPD "Guidelines for Land
Application of Sewage Sludge (Biosolids) at Agronomic Rates" and with the State Rules,
Chapter 391-3-6-.17. Before disposing of municipal sewage sludge by land application or any
method other than co -disposal in a permitted sanitary landfill, the permittee shall submit a sludge
management plan to EPD for written approval. This plan will become a part of the NPDES
Permit after approval and modification of the permit. The permittee shall notify the EPD of any
changes planned in an approved sludge management plan.
If an applicable management practice or numerical limitation for pollutants in sewage sludge is
promulgated under Section 405(d) of the Federal Act after approval of the plan, then the plan
shall be modified to conform with the new regulations.
3. SLUDGE MONITORING REQUIREMENTS
The permittee shall develop and implement procedures to ensure adequate year-round sludge
disposal. The permittee shall monitor and maintain records documenting the quantity of sludge
removed from the facility. Records shall be maintained documenting that the quantity of solids
removed from the facility equals the solids generated on an average day. The total quantity of
sludge removed from the facility during the reporting period shall be reported each month with
the Discharge Monitoring Reports as required under Part I.D.1. of this permit. The quantity shall
be reported on a dry weight basis (dry tons).

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 4 of 28
Permit No. GA0024911
4. INTRODUCTION OF POLLUTANTS INTO THE PUBLICLY OWNED TREATMENT
WORKS (POTW)
The permittee must notify EPD of:
a. Any new introduction of pollutants into the POTW from an indirect discharger that
would be subject to Sections 301 or 306 of the Federal Act if the pollutants were directly
discharged to a receiving stream; and
b. Any substantial change in the volume or character of pollutants from a source that existed
when the permit was issued.
This notice shall include information on the quality and quantity of the indirect discharge
introduced and any anticipated impact on the quantity or quality of effluent to be discharged
from the POTW.
5. EFFLUENT TOXICITY AND BIOMONITORING REQUIREMENTS
The permittee shall comply with effluent standards or prohibitions established by section 307(a)
of the Federal Act and with Chapter 391-3-6-.03(5)(e) of the State Rules and may not discharge
toxic pollutants in concentrations or combinations that are harmful to humans, animals, or
aquatic life.
If toxicity is suspected in the effluent, the EPD may require the permittee to perform any of the
following actions:
a. Acute biomonitoring tests;
b. Chronic biomonitoring tests;
c. Stream studies;
d. Priority pollutant analyses;
e. Toxicity reduction evaluations (TRE); or
f. Any other appropriate study.
The EPD will specify the requirements and methodologies for performing any of these tests or
studies. Unless other concentrations are specified by the EPD, the critical concentration used to
determine toxicity in biomonitoring tests will be the effluent instream wastewater concentration
(IWC) based on the permitted monthly average flow of the facility and the critical low flow of
the receiving stream (7Q10). The endpoints that will be reported are the effluent concentration
that is lethal to 50% of the test organisms (LC50) if the test is for acute toxicity and the no
observed effect concentration (NOEC) of effluent if the test is for chronic toxicity.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 5 of 28
Permit No. GA0024911
The permittee must eliminate effluent toxicity and supply the EPD with data and evidence to
confirm toxicity elimination.
6. LAND APPLICATION SYSTEM
a. Definitions
i. "Hydraulic Loading Rate" means the rate at which wastes or wastewaters are
discharged to a land disposal or land treatment system, expressed in volume per
unit area per unit time or depth of water per unit of time.
ii. "Land Disposal System" means any method of disposing of pollutants in which
the pollutants are applied to the surface or beneath the surface of a parcel of land
and which results in the pollutants percolating, infiltrating, or being absorbed into
the soil and then into the waters of the State. Land disposal systems exclude
landfills and sanitary landfills but include ponds, basins, or lagoons used for
disposal of wastes or wastewaters, where evaporation and/or percolation of the
wastes or wastewaters are used or intended to be used to prevent point discharge
of pollutants into waters of the State. Septic tanks or sewage treatment systems, as
defined in Chapter 511-3-1-.02 (formally in Chapter 270-5-25-.01) and as
approved by appropriate County Boards of Public Health, are not considered land
disposal systems for purposes of Chapter 391-3-6-.11.
iii. "Land Treatment System" means any land disposal system in which vegetation on
the site is used for additional treatment of wastewater to remove some of the
pollutants applied.
iv. "Point Source" means any discernible, confined, or discrete conveyance,
including, but not limited to, any pipe, ditch, channel, tunnel, conduit, well,
discrete fissure, container, rolling stock, concentrated animal feeding operation, or
vessel or other floating craft, from which pollutants are or may be discharged.
This term does not include return flows from irrigated agriculture or agricultural
storm water runoff.
v. "Spray Field" means the wetted area of the land treatment system or land disposal
system where treated wastes, treated effluent from industrial processes,
agricultural or domestic wastewater, domestic sewage sludge, industrial sludge or
other sources is applied to the land via spray, excluding the buffer zone.
vi. "Treatment System" means the wastewater treatment facility which reduces high
strength organic waste to low levels prior to the application to the spray field.
vii. "Water" or "Waters of the State" means any and all rivers, streams, creeks,
branches, Iakes, reservoirs, ponds, drainage systems, springs, wells, and all other
bodies of surface or subsurface water, natural or artificial, lying within or forming
a part of the boundaries of the State which are not entirely confined and retained
completely upon the property of a single individual, partnership, or corporation.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
b. Monitoring Well Requirements
Page 6 of 28
Permit No. GA0024911
The permittee, upon written notification by the EPD, may be required to install
groundwater monitoring wells at the existing land treatment system. This requirement
may apply if monitoring wells were not included in the original design of the facility and
also, if the EPD determines the existing groundwater monitoring wells are not adequate.
c. Groundwater Requirements
If any groundwater samples taken from the groundwater monitoring wells at the
land treatment system are above the primary maximum contaminant levels for
drinking water, the permittee shall immediately develop a plan which will ensure
that the primary maximum contaminant levels for drinking water are not
exceeded.
ii. If any pollutants which are being discharged to the land treatment system are
detected in the groundwater samples taken from the compliance monitoring wells
at the land treatment system in amounts or concentrations which could be toxic or
otherwise harmful to humans or biota if those pollutants mingle with waters of the
State, then the permittee shall immediately develop a plan which will reduce the
amounts or concentrations of the pollutants to ensure they are not toxic or
otherwise harmful to humans or biota if those pollutants mingle with waters of the
State.
d. No Point Source Discharge(s) of a Pollutant to Surface Waters of the State
The land treatment system must be operated and maintained to ensure there is no point
source discharge(s) of pollutants to surface waters of the State.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 7 of 28
Permit No. GA002491 1
B.1. STREAM DISCHARGE: EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Discharge to Bear Crek - Outran #001 (31.119397°,-83.387618°)
The discharge from the water pollution control plant shall be limited and monitored by the permittee as
specified below:
Parameters
•
Discharge
limitations
Monitoring Requirements
Measurement
Frequency
Sample
Type
Sample
Location
Stream Flow (MGD)
Flow, Daily Maximum (MGD)
Discharge Flow as Percent of Stream Flow,
Daily Maximum (%) (1)
January to May
June to November
December
Report
4.3
25
14
25
Seven Days/Week
Seven Days/Week
Seven Days/Week
Continuous
Recording
Continuous
Recording
Continuous
Recording
Upstream
Effluent
Effluent
(1)
The daily maximum discharge flows as a percent of the stream flow, 14% and 25%, are equivalent to a discharge
ratio of 6:1 and 3:1, respectively. The following calculation should be used for reporting purposes:
FEOWD1scharge
% of Stream Flow —
Flow +Flow
Dtscharg stream
x 100%
Parameters
Discharge limitations in
mg/L
unless otherwise spucified
Monthly Weekly
Average Average
Monitoring Requirements
Measurement
Frequency
Sample Sample
Type Location
Five -Day Biochemical Oxygen Demand (1)
Total Suspended Solids (1)
30.0
90
45.0
120
Three Days/Week
Three Days/Week
Composite
Composite
i p°
Influent &
Effluent
Influent &
Effluent
Ammonia, as N (2)
10.0
15.0
Three Days/Week
Composite
Effluent
Fecal Colifonn Bacteria (#/100 mL)
200
400
Two Days/Week
Grab
Effluent
(1)
(2)
Numeric limits only apply to the effluent.
Ammonia, organic nitrogen, nitrate nitrite, and total Kjeldahl nitrogen (TKN) must be analyzed or calculated
from the same sample. Organic nitrogen, as N = TKN — ammonia, as N.
(Effluent limitations continued on the next page)

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 8 of 28
Permit No. GA0024911
B.1. STREAM DISCHARGE: EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
(CONTINUED)
Di char a to Bear Creek - Outran #001 i 31.119397°_ -83.387618°
Parameters
Five -Day Biochemical Oxygen Demand Removal,
Minimum (%) °)
pH, Daily Minimum — Daily Maximum (S.U.)
Total Residual Chlorine, Daily Maximum
Dissolved Oxygen, Daily Minimum
Total Phosphorus, as P (2)
Orthophosphate, as P (2)
Organic Nitrogen, as N (3)
Nitrate Nitrite, as N (3)
Total Kjeldahl Nitrogen, as N (3)
Chronic Whole Effluent Toxicity (%) (4)
Discharge
limitations in
mg/L unless
otherwise
s ' ecified
65
6.0 — 9.0
0.04
2.0
Report
Report
Report
Report
Report
Monitoring Requirements
Measurement
Frequency
See Below
Seven Days/Week
Seven Days/Week
Seven Days/Week
One Day/Month
One Day/Month
One Day/Month
One Day/Month
One Day/Month
Report NOEC 1 See Below
Sample
Type
See Below
Grab
Grab
Grab
Composite
Composite
Composite
Composite
Composite
Composite
Sample
Location
See Below
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Percent removal shall be calculated from monthly average influent and effluent concentrations. Influent and
effluent samples shall be collected at approximately the same time.
Total phosphorus and orthophosphate must be analyzed from the same sample.
Ammonia, organic nitrogen, nitrate -nitrite, and total Kjeldahl nitrogen (TKN) must be analyzed or calculated
from the same sample. Organic nitrogen, as N = TKN — ammonia, as N
Refer to Part I.C.9. CHRONIC WHOLE EFFLUENT TOXICITY.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
B.2. LAND TREATMENT SYSTEM
1.
Page 9 of 28
Permit No. GA0024911
TREATMENT REQUIREMENTS, LIMITATIONS AND MONITORING
Discharge from treatment pond to spray fields:
a.
Influent shall refer to the influent to the treatment facility and effluent shall refer to the
discharge from the stabilization pond to the spray fields. The discharge shall be limited
and monitored as follows:
Parameter (units)
Discharge
Limitations
Monthly average,
unless otherwise
stated
Flow, Weekly Average (MGD)
Five -Day Biochemical Oxygen Demand
(mg/L) (1)
Total Suspended Solids (mg/L) (1)
Nitrate -Nitrogen, as N
Total Kjeldahl Nitrogen, as N
pH (standard units), Daily Minimum &
Daily Maximum
2.5
50
90
Report
Report
6.0 —10.0
Monitoring Requirements
Measurement
Frequency
Sample
Type
Sample
Location
Seven Days/Week
One Day/Week
One Day/Week
One Day/Month
One Day/Month
One Day/Week
Continuous
Grab
Grab
Grab
Grab
Grab
Effluent
Influent &
Effluent (2)
Influent &
Effluent (2)
Effluent
Effluent
Effluent
Numeric limits only apply to the effluent.
For influent monitoring, the results of samples collected under B.1. may be used to satisfy the
requirements under this part for weeks when both the discharge to the stream and the land
treatment system are utilized.
b. The spray field of the land treatment system shall consist of 280 acres. The hydraulic
wastewater loading to the spray field must not exceed 2.3 in/week. The instantaneous
application rate for the site is 0.25 inches/hour. The hydraulic loading rates for each
spray field shall be monitored daily and submitted to EPD in accordance with Part I.A.3
of this permit,
c. A daily log will be kept by the land treatment system operator of the volume (gal) of
wastewater sprayed on each spray field for each day and shall be submitted to EPD in
accordance with Part I.A.3 of this permit.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 10 of 28
Permit No. GA0024911
d. A daily log will be kept by the land treatment system operator of the amount of rainfall
received each day within 0.5 miles of the permitted land treatment system and shall be
submitted to EPD in accordance with Part I.A.3 of this permit.
e. A written summary of pertinent maintenance for the land treatment system such as
planting, cutting vegetation, harvesting, resurfacing areas, etc. shall also be included in
the report and submitted in accordance with Part I.A.3 of this permit.
2. SYSTEM OPERATIONS
The land treatment system will be operated and maintained in accordance with the design criteria
as presented in the approved engineering reports, operation and maintenance manuals, the permit
application and/or other written agreements between EPD and the permittee. This includes, but
is not limited to, the following:
a. A vegetative cover must be maintained at all times on the land treatment site and must be
managed according to design criteria;
b. All treatment units are to be maintained and operated for maximum efficiency;
c. Hydraulic and nitrogen loading is to be maintained within design criteria;
d. Unless otherwise approved, no wastewater shall be applied via spray or aboveground drip
irrigation during rain or when the conditions are such that applied wastewater will not be
absorbed into the soil; and
e. If the hydraulic application rate(s) cannot satisfactorily be handled by the approved land
treatment system, corrective actions shall immediately be taken by the permittee.
f. The land treatment system may not result in a point source discharge to surface waters, as
mandated in the Rules.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
3. GROUNDWATER MONITORING REQUIREMENTS
Page 11 of 28
Permit No. GA0024911
a. Groundwater leaving the land treatment system boundaries (as defined in this permit as
the spray field) must not exceed the primary maximum contaminant Levels for drinking
water. Samples of the groundwater shall be monitored from each groundwater
monitoring well(s) by the permittee for the parameters and at the frequency listed below:
Parameter (units)
Measurement
Frequency
Depth to Groundwater (feet)
Nitrate, as N (mglL) <1)
pH (standard unit)
Specific Conductivity (µmho/cm)
Escherichia Coll (CFU/100mL) (2)
(1)
(2)
One Day/Month
One Day/Month
One Day/Month
One Day/Month
One Day/Quarter
Sample Type
Grab
Grab
Grab
Grab
Grab J�
The maximum contaminant level for nitrate nitrogen is 10.0 mg/L, as amended in the Safe
Drinldng Water Rules and Regulations.
The maximum contaminant level for E. coli is zero positive samples, as amended in the Safe
Drinldng Water Rules and Regulations.
b. Monitoring wells shall be identified in all reports submitted to EPD as up -gradient,
midfield, and down -gradient, as referenced below. The down -gradient groundwater
monitoring wells shall be considered the compliance wells. The monitoring wells are
identified as follows:
Well Location Weli Location
U-7 Up -gradient D-10 Down -gradient
U-8 Up -gradient D-13 Down -gradient
M-11 Midfield D-19 Down -gradient
D-20 Down -gradient
c. As per Part I.B.2 and Part II.A.9-10 of this permit, upon written notification to EPD,
additional up -gradient, mid -field and down gradient monitoring wells may be added in
accordance with EPD's Manual for Groundwater Monitoring, September 1991, as
amended, the Environmental Protection Agency Guidance Design and Installation of
Monitoring Wells, or other approved guidance without EPD approval and without

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 12 of 28
Permit No. GA0024911
modification to this permit. The additional wells are subject to the sampling parameters
and sampling frequency(s) in Part I.B.3 of this permit, Groundwater Monitoring
Requirements. The sampling analysis of additional wells shall be reported in accordance
with Part I.A.3 of this permit.
4. SOIL MONITORING REQUlREMENTS
a. A Soil Fertility Test(s) shall be performed annually in the fourth (4th) calendar quarter in
accordance with the latest edition of Methods of Soil Analysis (published by the
American Society of Agronomy, Madison, Wisconsin) or other methods approved by
EPD. Representative soil samples shall be collected from the land treatment system
using the Mehlich-1 extraction procedure. Results of the Soil Fertility Test(s) shall be
utilized by the permittee in the continuing operation and maintenance of the land
treatment system. The sampling analysis shall be reported in accordance with Part I.A.3
of this permit.
b. If the Soil Fertility Test(s) indicates a change in the pH value of one standard unit from
the previous year's pH value, the permittee shall immediately perform a Cation Exchange
Capacity and Percent Base Saturation analysis for the land treatment system. The
monitoring results of the Cation Exchange Capacity and Percent Base Saturation analysis
shall be submitted to EPD in accordance with Part I.A.3 of this permit
c. Where there are categorical and/or significant industrial discharges to the sewer system,
the permittee may be required, upon written notification by the Division, to sample for
additional parameters. These parameters may include heavy metals and organic
compounds.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
5. SURFACE WATER MONITORING
Page 13 of 28
Permit No. GA0024911
Surface water(s)1 adjacent to or traversing the land treatment system shall be monitored. Unless
otherwise stated and or approved by EPD, surface water samples will be collected at a maximum
of 100 feet upstream and a maximum 100 feet downstream of the land treatment system. The
surface water shall be monitored for the parameters and at the frequency listed below:
Parameter (units)
Measurement
Frequency
Nitrate, as N (mg/L)
Five -Day Biochemical Oxygen Demand
(mg/L)
Specific Conductivity (µmho/cm)
pH (standard units)
Total Kjeldahl Nitrogen (mg/L)
Temperature (°C)
Dissolved Oxygen (mg/L)
(1)
One Day/Quarter
One Day/Quarter
One Day/Quarter
One Day/Quarter
One Day/Quarter
One Day/Quarter
One Day/Quarter
Sample Type
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Surface waters as identified in the Design Development Report and permit application are: Not
Applicable

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
C. MONITORING AND REPORTING
1. REPRESENTATIVE SAMPLING
Page 14 of 28
Permit No. GA0024911
Samples and measurements of the monitored waste shall represent the volume and nature of the
waste stream. The permittee shall maintain a written sampling and monitoring schedule.
2. SAMPLING PERIOD
a. Unless otherwise specified in this permit, quarterly samples shall be taken during the
periods January -March, April -June, July -September, and October -December.
b. Unless otherwise specified in this permit, semiannual samples shall be taken during the
periods January -June and July December.
c. Unless otherwise specified in this permit, annual samples shall be taken during the period
of JanuaryDecember.
3. MONITORING PROCEDURES
All analytical methods, sample containers, sample preservation techniques, and sample holding
times must be consistent with the techniques and methods Listed in 40 CFR Part 136. The
analytical method used shall be sufficiently sensitive. EPA -approved methods must be
applicable to the concentration ranges of the NPDES permit samples.
4. RECORDING OF RESULTS
For each required parameter analyzed, the permittee shall record:
a. The exact place, date, and time of sampling, and the person(s) collecting the sample. For
flow proportioned composite samples, this shall include the instantaneous flow and the
corresponding volume of each sample aliquot, and other information relevant to
document flow proportioning of composite samples;
b. The dates and times the analyses were performed;
c. The person(s) who performed the analyses;
d. The analytical procedures or methods used; and
e. The results of all required analyses.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
5. ADDITIONAL MONITORING BY PERMITTEE
Page 15 of 28
Permit No. GA0024911
If the permittee monitors required parameters at the locations designated in I.B. more frequently
than required, the permittee shall analyze all samples using approved analytical methods
specified in I.C,3. The results of this additional monitoring shall be included in calculating. and
reporting the values on the Discharge Monitoring Report forms. The permittee shall indicate the
monitoring frequency on the report. The EPD may require in writing more frequent monitoring,
or monitoring of other pollutants not specified in this permit.
6. RECORDS RETENTION
The permittee shall retain records of:
a. All laboratory analyses performed including sample data, quality control data, and
standard curves;
b. Calibration and maintenance records of laboratory instruments;
c. Calibration and maintenance records and recordings from continuous recording
instruments;
d. Process control monitoring records;
e. Facility operation and maintenance records;
f. Copies of all reports required by this permit;
g. All data and information used to complete the permit application; and
h. All monitoring data related to sludge use and disposal..
These records shall be kept for at least three years. Sludge handling records must be kept for at
least five years. Either period may be extended by EPD written notification.
7. PENALTIES
Both the Federal and State Acts provide that any person who falsifies or tampers with any
monitoring device or method required under this permit, or who makes any false statement,
representation, or certification in any record submitted or required by this permit shall, if
convicted, be punished by a fine or by imprisonment or by both. The Acts include procedures
for imposing civil penalties for violations or for negligent or intentional failure or refusal to
comply with any final or emergency order of the Director of the EPD.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
8. WATERSHED PROTECTION PLAN
Page 16 of 28
Permit No. GA0024911
The permittee has a Watershed Protection Plan that has been approved by EPD. The pennittee's
approved Watershed Protection Plan shall be enforceable through this permit.
Each June 30th the permittee is to submit the following to EPD:
a. An annual certification statement documenting that the plan is being implemented as
approved. The certification statement shall read as follows: "I certify, under penalty of
law, that the Watershed Protection Plan is being implemented. I am aware that there are
significant penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations."
b. All Watershed Plan data collected during the previous year in an electronic format This
data shall be archived using a digital format such as a spreadsheet developed in
coordination with EPD. All archived records, data, and information pertaining to the
Watershed Protection PIan shall be maintained permanently.
c. A progress report that provides a summary of the BMPs that have been implemented and
documented water quality improvements. The progress report shall also include any
necessary changes to the Watershed Protection Plan.
The report and other information shall be submitted to EPD at the address below:
Environmental Protection Division
Watershed Planning and Monitoring Program
2 Martin Luther King Jr. Drive SE
Suite 1152 East
Atlanta, Georgia 30334
9. CHRONIC WHOLE EFFLUENT TOXICITY (WET)
The permittee shall conduct one chronic whole effluent toxicity (WET) test for two consecutive
quarters upon the effective date of the permit. The testing must be conducted in accordance with
the most current U.S. Environmental Protection Agency (EPA) chronic aquatic toxicity testing
manuals. The referenced document is entitled Short -Term Methods for Estimating the Chronic
Toxicity of Effluents and Receiving Waters to Freshwater Organisms, 4th Edition, U.S. EPA,
821-R-02-013, October 2002. Definitive tests must be run on the same samples concurrently
using both an invertebrate species (i.e., Ceriodaphnia dubia) and a vertebrate species (i.e.,
Pimephales promelas).. The testing must include a dilution equal to the facility's instream
wastewater concentrations (IWCs) of 14% and 25%.
EPD will evaluate the WET tests submitted to determine whether toxicity has been
demonstrated. An effluent discharge will not be considered toxic if the No Observed Effect
Concentration (NOEC) is greater than or equal to the Instream Wastewater Concentrations
(IWCs) of 14% and 25%. The results of the tests shall be submitted to EPD with the pennittee's
monthly Discharge Monitoring Reports.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 17 of 28
Permit No. GA0024911
Within ten months of the effective date of the permit, the permittee shall submit a report to EPD
that includes a summary, of the effluent data collected as well as copies of all the analytical
laboratory reports. The report shall be submitted to EPD at the address below:
Environmental Protection Division
Wastewater Regulatory Program
2 Martin Luther King Jr. Drive SE
Suite 1152 East
Atlanta, Georgia 30334
Upon receipt of the report, EPD will evaluate the results. If the test results indicate effluent
toxicity, the permittee may be required to perform additional tests or studies in accordance with
Part I.C.5 of the permit and/or the permit may be modified to include a chronic WET limit.
If the results of the quarterly tests do not indicate toxicity, then the permittee will only be
required to conduct annual chronic Whole Effluent Toxicity (WET) tests as specified above for
the remainder of the permit term. EPD will continue to evaluate the annual WET tests submitted
to determine whether toxicity has been demonstrated. If the test results indicate effluent toxicity,
the permittee may be required to perform additional tests or studies in accordance with Part I.C.5
of the permit and/or the permit may be modified to include a chronic WET limit.
D. REPORTING REQUIREMENTS
1. The permittee must electronically report the DMR, OMR and additional monitoring data using
the web based electronic NetDMR reporting system, unless a waiver is granted by EPD.
a. The permittee must comply with the Federal National Pollutant Discharge Elimination
System Electronic Reporting regulations in 40 CFR §127. The permittee must
electronically report the DMR, OMR, and additional monitoring data using the web
based electronic NetDMR reporting system online at:
https://netdmr. epa.gov/netdmr/public/home.htm
b. Monitoring results obtained during the calendar month shall be summarized for each
month and reported on the DMR. The results of each sampling event shall be reported on
the OMR and submitted as an attachment to the DMR.
c. The permittee shall submit the DMR, OMR and additional monitoring data no later than
11:59 p.m. on the 15th day of the month following the sampling period.
d. All other reports required herein, unless otherwise stated, shall be submitted to the EPD
Office listed on the permit issuance letter signed by the Director of EPD.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 18 of 28
Permit No. GA0024911
2. No later than December 21. 2020, the permittee must electronically report the following
compliance monitoring data and reports using the online web based electronic system approved
by EPD, unless a waiver is granted by EPD:
a. Sewage Sludge/Biosolids Annual Program Reports provided that the permittee has
an approved Sewage Sludge (Biosolids) Plan;
b. Pretreatment Program Reports provided that the permittee has an approved
Industrial Pretreatment Program in this permit;
c. Sewer Overflow/Bypass Event Reports;
d. Noncompliance Notification;
e. Other noncompliance; and
f. Bypass
3. OTHER REPORTS
All other reports required in this permit not listed above in Part I.D.2 or unless otherwise stated,
shall be submitted to the EPD Office listed on the permit issuance letter signed by the Director of
EPD.
4. OTHER NONCOMPLIANCE
All instances of noncompliance not reported under Part I.B. and Part II. A. shall be reported to
EPD at the time the monitoring report is submitted.
5. SIGNATORY REQUIREMENTS
All reports, certifications, data or information submitted in compliance with this permit or
requested by EPD must be signed and certified as follows:
a. Any State or NPDES Permit Application form submitted to the EPD shall be signed as
follows in accordance with the Federal Regulations, 40 C.F.R. 122.22:
1. For a corporation, by a responsible corporate officer. A responsible corporate
officer means:
i. a president, secretary, treasurer, or vice president of the corporation in
charge of a principal business function, or any other person who performs
similar policy- or decision making functions for the corporation, or

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 19 of 28
Permit No. GA0024911
the manager of one or more manufacturing, production, or operating
facilities employing more than 250 persons or having gross annual sales or
expenditures exceeding $25 million (in second-quarter 1980 dollars), if
authority to sign documents has been assigned or delegated to the manager
in accordance with corporate procedures.
2. For a partnership or sole proprietorship, by a general partner or the proprietor,
respectively; or
3. For a municipality, State, Federal, or other public facility, by either a principal
executive officer or ranking elected official.
b. All other reports or requests for information required by the permit issuing authority shall
be signed by a person designated in (a) above or a duly authorized representative of such
person, if:
1. The representative so authorized is responsible for the overall operation of the
facility from which the discharge originates, e.g., a plant manager, superintendent
or person of equivalent responsibility;
2. The authorization is made in writing by the person designated under (a) above;
and
3. The written authorization is submitted to the Director.
c. Any changes in written authorization submitted to the permitting authority under (b)
above which occur after the issuance of a permit shall be reported to the permitting
authority by submitting a copy of a new written authorization which meets the
requirements of (b) and (b.1) and (b.2) above.
d. Any person signing any document under (a) or (b) above shall make the following
certification:
"I certify under penalty of law that this document and all attachments were prepared
under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations."

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
PART II
A. MANAGEMENT REQUIREMENTS
1. PROPER OPERATION AND MAINTENANCE
Page 20 of 28
Permit No. GA0024911
The permittee shall properly maintain and operate efficiently all treatment or control facilities
and related equipment installed or used by the permittee to achieve compliance with this permit.
Efficient operation and maintenance include effective performance, adequate funding, adequate
operator staffing and training, and adequate laboratory and process controls, including
appropriate quality assurance procedures. Back-up or auxiliary facilities or similar systems shall
be operated only when necessary to achieve permit compliance.
2. PLANNED CHANGE
Any anticipated facility expansions, or process modifications which will result in new, different,
or increased discharges of pollutants requires the submission of a new NPDES permit
application. If the changes will not violate the permit effluent limitations, the permittee may
notify EPD without submitting an application. The permit may then be modified to specify and
limit any pollutants not previously Limited.
3. TWENTY-FOUR HOUR REPORTING
If, for any reason the permittee does not comply with, or will be unable to comply with any
effluent limitations specified in the permittee's NPDES permit, the permittee shall provide EPD
with an oral report within 24 hours from the time the permittee becomes aware of the
circumstances followed by a written report within five (5) days of becoming aware of such
condition. The written submission shall contain the following information:
a. A description of the noncompliance and its cause; and
b. The period of noncompliance, including the exact date and times; or, if not corrected, the
anticipated timethe noncompliance is expected to continue; and
c. The steps taken to reduce, eliminate, and prevent recurrence of the noncomplying
discharge.
4. ANTICIPATED NONCOMPLIANCE NOTIFICATION
The permittee shall give written notice to the EPD at least 10 days before:
a. Any planned changes in the permitted facility; or
b. Any activity which may result in noncompliance with the permit.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
5. OTHER NONCOMPLIANCE
Page 21 of 28
Permit No. GA0024911
The permittee must report all instances of noncompliance not reported under other specific
reporting requirements, at the time monitoring reports are submitted. The reports shall contain
the information required under conditions of twenty-four hour reporting.
6. OPERATOR CERTIFICATION REQUIREMENTS
The person responsible for the daily operation of the facility must be a Class II Certified
Operator in compliance with the Georgia State Board of Examiners for Certification of Water
and Wastewater Plant Operators and Laboratory Analysts Act, as amended, and as specified by
Subparagraph 391-3-6-.12 of the Rules and Regulations for Water Quality Control. All other
operators must have the minimum certification required by this Act.
7. LABORATORY ANALYST CERTIFICATION REQUIREMENTS
Laboratory Analysts must be certified in compliance with the Georgia State Board of Examiners
for Certification of Water and Wastewater Treatment Plant Operators and Laboratory Analysts
Act, as amended.
8. BYPASSING
Any diversion of wastewater from or bypassing of wastewater around the permitted treatment
works is prohibited, except if:
a. Bypassing is unavoidable to prevent loss of life, personal injury, or severe property
damage;
b. There are no feasible alternatives to bypassing; and
c. The permittee notifies the EPD at least 10 days before the date of the bypass.
Feasible alternatives to bypassing include use of auxiliary treatment facilities and retention of
untreated waste. The permittee must take all possible measures to prevent bypassing during
routine preventative maintenance by installing adequate back-up equipment.
The permittee shall operate the facility and the sewer system to minimize discharge of pollutants
from combined sewer overflows or bypasses and may be required by the EPD to submit a plan
and schedule to reduce bypasses, overflows, and infiltration.
Any unplanned bypass must be reported following the requirements for noncompliance
notification specified in II.A.3. The permittee may be liable for any water quality violations that
occur as a result of bypassing the facility.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
9. POWER FAILURES
Page 22 of 28
Permit No. GA0024911
If the primary source of power to this water pollution control facility is reduced or lost, the
permittee shall use an alternative source of power to reduce or control all discharges to maintain
permit compliance.
10. DUTY TO MITIGATE
The permittee shall take all reasonable steps to minimize or prevent any discharge or sludge
disposal which might adversely affect human health or the environment.
11. NOTICE CONCERNING ENDANGERING WATERS OF THE STATE
Whenever, because of an accident or otherwise, any toxic or taste and color producing substance,
or any other substance which would endanger downstream users of the waters of the State or
would damage property, is discharged into such waters, or is so placed that it might flow, be
washed, or fall into them, it shall be the duty of the person in charge of such substances at the
time to forthwith notify EPD in person or by telephone of the location and nature of the danger,
and it shall be such person's further duty to immediately take all reasonable and necessary steps
to prevent injury to property and downstream users of said water.
Spills and Major Spills:
A "spill" is any discharge of raw sewage by a Publicly Owned Treatment Works (POTW) to the
waters of the State.
A "major spill" means:
1. The discharge of pollutants into waters of the State by a POTW that exceeds the weekly
average permitted effluent limit for biochemical oxygen demand (5-day) or total
suspended solids by 50 percent or greater in one day, provided that the effluent discharge
concentration is equal to or greater than 25 mg/L for biochemical oxygen demand or total
suspended solids.
2. Any discharge of raw sewage that 1) exceeds 10,000 gallons or 2) results in water quality
violations in the waters of the State.
"Consistently exceeding effluent limitation" means a POTW exceeding the 30 day average limit
for biochemical oxygen demand or total suspended solids for at least five days out of each seven
day period during a total period of 180 consecutive days.
The following specific requirements shall apply to POTW's. If a spill or major spill occurs, the
owner of a POTW shall immediately:
a. Notify EPD, in person or by telephone, when a spill or major spill occurs in the system.
b. Report the incident to the local health department(s) for the area affected by the incident.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
The report at a minimum shall include the following:
Page 23 of 28
Permit No. GA0024911
1. Date of the spill or major spill;
2. Location and cause of the spill or major spill;
3. Estimated volume discharged and name of receiving waters; and
4. Corrective action taken to mitigate or reduce the adverse effects of the spill or
major spill.
c. Post a notice as close as possible to where the spill or major spill occurred and where the
spill entered State waters and also post additional notices along portions of the waterway
affected by the incident (i.e. bridge crossings, boat ramps, recreational areas, and other
points of public access to the affected waterway). The notice at a minimum shall include
the same information required in 11(b)(1-4) above. These notices shall remain in place
for a minimum of seven days after the spill or major spill has ceased.
d. Within 24 hours of becoming aware of a spill or major spill, the owner of a POTW shall
report the incident to the local media (television, radio, and print media). The report shall
include the same information required in 11(b)(1-4) above.
e. Within 5 days (of the date of the spill or major spill), the owner of a POTW shall submit
to EPD a written report which includes the same information required in 11(b)(1-4)
above.
f. Within 7 days (after the date of a major spill), the owner of a POTW responsible for the
major spill, shall publish a notice in the largest legal organ of the County where the
incident occurred. The notice shall include the same information required in 11(b)(1-4)
above.
g.
The owner of a POTW shall immediately establish a monitoring program of the receiving
waters affected by a major spill or by consistently exceeding an effluent limit, with such
monitoring being at the expense of the POTW for at least one year. The monitoring
program shall include an upstream sampling point as well as sufficient downstream
locations to accurately characterize the impact of the major spill or the consistent
exceedence of effluent limitations described in the definition of " Consistently exceeding
effluent limitation" above. As a minimum, the following parameters shall be monitored in
the receiving stream:
1. Dissolved Oxygen;
2. Fecal Coliform Bacteria;
3. pH;
4. Temperature; and
5. Other parameters required by the EPD.
The monitoring and reporting frequency as well as the need to monitor additional
parameters, will be determined by EPD. The results of the monitoring will be provided
by the POTW owner to EPD and all downstream public agencies using the affected
waters as a source of a public water supply.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 24 of 28
Permit No. GA0024911
h. Within 24 hours of becoming aware of a major spill, the owner of a POTW shall provide
notice of a major spill to every county, municipality, or other public agency whose public
water supply is within a distance of 20 miles downstream and to any others which could
be potentially affected by the major spill.
12. UPSET PROVISION
Provision under 40 CFR 122.41(n)(1)-(4), regarding "Upset" shall be applicable to any civil,
criminal, or administrative proceeding brought to enforce this permit.
B. RESPONSIBILITIES
1. DUTY TO COMPLY
The permittee must comply with all conditions of this permit. Any permit noncompliance is a
violation of the Federal Clean Water Act, State Act, and the State Rules, and is grounds for:
a. Enforcement action;
b. Permit termination, revocation and reissuance, or modification; or
c. Denial of a permit renewal application.
2. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE
It shall not be a defense of the permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity to maintain compliance with the conditions of
this permit.
3. INSPECTION AND ENTRY
The permittee shall allow the Director of the EPD, the Regional Administrator of EPA, and their
authorized representatives, agents, or employees after they present credentials to:
a. Enter the permittee's premises where a regulated activity or facility is located, or where
any records required by this permit are kept;
b. Review and copy any records required by this permit;
c. Inspect any facilities, equipment, practices, or operations regulated or required by this
permit; and
d. Sample any substance or parameter at any location.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
4. DUTY TO PROVIDE INFORMATION
Page 25 of 28
Permit No. GA0024911
The permittee shall furnish any information required by the EPD to determine whether cause
exists to modify, revoke and reissue, or terminate this permit or to determine compliance with
this permit. The permittee shall also furnish the EPD with requested copies of records required
by this permit.
5. TRANSFER OF OWNERSHIP
A permit may be transferred to another person by a permittee if:
a. The permittee notifies the Director in writing at least 30 days in advance of the proposed
transfer
b. An agreement is written containing a specific date for transfer of permit responsibility
including acknowledgment that the existing permittee is liable for violations up to that
date, and that the new permittee is liable for violations from that date on. This agreement
must be submitted to the Director at least 30 days in advance of the proposed transfer;
and
c. The Director does not notify the current permittee and the new permittee within 30 days
of EPD intent to modify, revoke and reissue, or terminate the permit. The Director may
require that a new application be filed instead of agreeing to the transfer of the permit.
6. AVAILABILITY OF REPORTS
Except for data determined to be confidential by the Director of EPD under O.C.G.A. 12-5-26 or
by the Regional Administrator of EPA under the Code of Federal Regulations, Title 40, Part 2,
all reports prepared to comply with this permit shall be available for public inspection at an EPD
office. Effluent data, permit applications, permittees' names and addresses, and permits shall not
be considered confidential.
7. PERMIT ACTIONS
This permit may be modified, terminated, or revoked and reissued in whole or in part during its
term for causes including, but not limited to:
a. Permit violations;
b. Obtaining this permit by misrepresentation or by failure to disclose all relevant facts;
c. Changing any condition that requires either a temporary or permanent reduction or
elimination of the permitted discharge;
d. Changes in effluent characteristics; and

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
Page 26 of 28
Permit No. GA0024911
e. Violations of water quality standards.
The filing of a request by the permittee for permit modification, termination, revocation and
reissuance, or notification of planned changes or anticipated noncompliance does not negate any
permit condition.
8. CIVIL AND CRIMINAL LIABILITY
Nothing in this permit shall be construed to relieve the permittee from civil or criminal
penalties for noncompliance.
9. PROPERTY RIGHTS
The issuance of this permit does not convey any property rights of either real or personal
property, or any exclusive privileges, nor does it authorize any injury to private property or any
invasion of personal rights, or any infringement of Federal, State or local laws or regulations.
10. DUTY TO REAPPLY
The permittee shall submit an application for permit reissuance at least 180 days before the
expiration date of this permit. The permittee shall not discharge after the permit expiration date.
To receive authorization to discharge beyond the expiration date, the permittee shall submit the
information, forms, and fees required by the EPD no later than 180 days before the expiration
date.
11. CONTESTED HEARINGS
Any person aggrieved or adversely affected by any action of the Director of the EPD shall
petition the Director for a hearing within 30 days of notice of the action.
12. SEVERABILITY
The provisions of this permit are severable. If any permit provision or the application of any
permit provision to any circumstance is held invalid, the provision does not affect other
circumstances or the remainder of this permit.
13. OTHER INFORMATION
Where the permittee becomes aware that it failed to submit any relevant facts in a permit
application, or submitted incorrect information in a permit application or in any report form to
the Director, it shall promptly submit such facts or information.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
14. PREVIOUS PERMITS
Page 27 of 28
Permit No. GA0024911
All previous State wastewater permits issued to this facility, whether for construction or
operation, are hereby revoked on the effective date of this permit. This action is taken to assure
compliance with the Georgia Water Quality Control Act as amended, and the Federal Clean
Water Act, as amended. Receipt of the permit constitutes notice of such action. The conditions,
requirements, terms and provisions of this permit authorizing discharge under the National
Pollutant Discharge Elimination System govern discharges from this facility.

STATE OF GEORGIA
DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
PART III
Page 28 of 28
Permit No. GA0024911
INDUSTRIAL PRETREATMENT PROGRAM FOR PUBLICLY OWNED TREATMENT WORKS (POTW)
1. The permittee may establish and operate an approved industrial pretreatment program.
2. If the EPD determines that the permittee is required to develop a local industrial pretreatment
program, the permittee will be notified in writing. The permittee shall immediately begin
development of an industrial pretreatment program and shall submit it to the EPD for approval
no later than one year after the notification.
3. During the interim period between determination that a program is needed and approval of the
program, all industrial pretreatment permits shall be issued by the EPD.
4. The permittee shall notify the EPD of all industrial users connected to the system or proposing to
connect to the system from the date of issuance of this permit.
5. Implementation of the Pretreatment Program developed by the State can be delegated to the
permittee following the fulfillment of requirements detailed in 391-3-6-.09 of the Rules and
Regulations for Water Quality Control.

FACT SHEET
swim.
GEIrRGIA
• DEPARTME►i. OE NATURAL RESOURCES
ENVIROONMF.NTALPROTECTION DIVISION
The Georgia Environmental Protection Division proposes to issue an NPDES permit to the
applicant identified below. The draft permit places conditions on the discharge of pollutants
from the wastewater treatment plant to waters of the State.
Technical Contact:
Kelli-Ann Sottile, Environmental Engineer
Kelly-arm.soitile .ga.gov
404-463-4945
Draft permit:
❑ First issuance
❑ Reissuance with no or minor modifications from previous permit
• Reissuance with substantial modifications from previous permit
❑ Modification of existing permit
® Requires EPA review
1. FACILITY INFORMATION
1.1 NPDES Permit No.: GA0024911
1.2 Name and Address of Owner/Applicant
City of Adel
Post Office Box 1530
Adel, Georgia 31620
1.3 Name and Address of Facility
Adel Water Pollution Control Plant
1325 Honeymoon Lane
Adel, Georgia 31620
1.4 Location and Description of the Discharge (as reported by applicant)
Outfall # Latitude (°) Longitude (°) Receiving Waterbody
001 31.119397 -83.387618 Bear Creek
Adel WPCP
NPDES Permit No. GA0024911
March 2020
Page 1 of 22

FACT SHEET
=Q-
1.5 Permitted Design Capacity
Discharge to Bear Creek:
The discharge to Bear Creek is limited by a stream to effluent flow ratio of 6:1 from June
through November and 3:1 from December through May. This is equivalent to an
instream wastewater concentration limitation of 14% and 25% respectively.
The permit also includes a daily maximum flow limitation of 4.3 MGD.
Land Application:
Since effluent can be stored or discharged, the allowable flow from the pretreatment
facility (aerated/polishing pond) to the land application site is governed by the capacity of
the sprayfields (2.5 MGD). Refer to section 5.2 for sprayfield calculations.
1.6 SIC Code and Description
SIC Code 4952 — Sewerage systems: Establishments primarily engaged in the collection
and disposal of wastes conducted through a sewer system, including such treatment
processes as may be provided.
1.7 Description of the Water Pollution Control Plant
Wastewater treatment:
The treatment process consists of coarse screening, an aerated lagoon, and
holding/stabilization pond. Treated effluent can be either discharged to Bear Creek
following chlorine disinfection or land applied onto a dedicated site.
Solids processing:
Solids settle and stabilize at the bottom of the ponds. Ponds are dredged and dewatered
sludge sent to a permitted landfill as needed.
1.8 Type of Wastewater Discharge
❑ Process wastewater
® Domestic wastewater
❑ Other (Describe)
0 Stormwater
❑ Combined (Describe)
Adel WPCP
NPDES Permit No. GA0024911
March 2020
Page 2 of 22

FACT SHEET
1.9 Characterization of Effluent Discharge (as reported by applicant) to Surface Water
Outfall No. 001:
Maximum Average
Effluent Characteristics Daily Daily
Value Value
Flow (MGD) 5.0 2.5
Five -Day Biochemical Oxygen Demand (mg/L) 55 29
Total Suspended Solids (mg/L) 110 42
Fecal Coliform Bacteria (#/100mL) 153 20
Ammonia, as N (mg/L) 6.1 2.2
Total Phosphorus, as P (mg/L) 1.3 0.6
(as Reported by Applicant)
2. APPLICABLE REGULATIONS
2.1 State Regulations
Chapter 391-3-6 of the Georgia Rules and Regulations for Water Quality Control
2.2 Federal Regulations
Source
Activity Applicable Regulation
Municipal
Municipal Effluent Discharge
Non -Process Water Discharges
Municipal Sludge Use and Disposal
40 CFR 122
40 CFR 125
40 CFR 133
40 CFR 122
40 CFR 125
40 CFR 122
40 CFR 257
40 CFR 501 & 503
3. WATER QUALITY STANDARDS & RECEIVING WATERBODY INFORMATION
Section 301(b)(1)(C) of the Clean Water Act (CWA) requires the development of
limitations in permits necessary to meet water quality standards. Federal Regulations 40
CFR 122.4(d) require that conditions in NPDES permits ensure compliance with the
water quality standards which are composed of use classifications, numeric and or
narrative water quality criteria and an anti -degradation policy. The use classification
system designates the beneficial uses that each waterbody is expected to achieve, such as
drinking water, fishing, or recreation. The numeric and narrative water quality criteria
are deemed necessary to support the beneficial use classification for each water body.
The antidegradation policy represents an approach to maintain and to protect various
levels of water quality and uses.
Adel WPCP
NPDES Permit No. GA0024911
March 2020
Page 3 of 22

MEM-
FACT SHEET
3.1 Receiving Waterbody Classification and Information — Bear Creek:
Specific Water Quality Criteria for Classified Water Usage 1391-3-6-.03(6)1:
Fishing: Propagation of Fish, Shellfish, Game and Other Aquatic Life; secondary contact
recreation in and on the water; or for any other use requiring water of a lower quality.
(i) Dissolved Oxygen: A daily average of 6.0 mg/L and no less than 5.0 mg/L at all times for
water designated as trout streams by the Wildlife Resources Division. A daily average of
5.0 mg/L and no less than 4.0 mg/L at all times for waters supporting warm water species
of fish.
(ii) pH: Within the range of 6.0 - 8.5.
(iii) Bacteria:
1. For the months of May through October, when water contact recreation activities are
expected to occur, fecal coliform not to exceed a geometric mean of 200 per 100 mL
based on at least four samples collected from a given sampling site over a 30-day period
at intervals not less than 24 hours. Should water quality and sanitary studies show fecal
coliform levels from non -human sources exceed 200/100 mL (geometric mean)
occasionally, then the allowable geometric mean fecal coliform shall not exceed 300 per
100 mL in lakes and reservoirs and 500 per 100 mL in free flowing freshwater streams.
For the months of November through April, fecal coliform not to exceed a geometric
mean of 1,000 per 100 mL based on at least four samples collected from a given
sampling site over a 30-day period at intervals not less than 24 hours and not to exceed a
maximum of 4,000 per 100 mL for any sample. The State does not encourage swimming
in these surface waters since a number of factors which are beyond the control of any
State regulatory agency contribute to elevated levels of bacteria.
2. For waters designated as shellfish growing areas by the Georgia DNR Coastal Resources
Division, the requirements will be consistent with those established by the State and
Federal agencies responsible for the National Shellfish Sanitation Program. The
requirements are found in National Shellfish Sanitation Program Guide for the Control of
Molluscan Shellfish, 2007 Revision (or most recent version), Interstate Shellfish
Sanitation Conference, U.S. Food and Drug Administration.
(iv) Temperature: Not to exceed 90°F. At no time is the temperature of the receiving waters to
be increased more than 5°F above intake temperature except that in estuarine waters the
increase will not be more than 1.5°F. In streams designated as primary trout or
smallmouth bass waters by the Wildlife Resources Division, there shall be no elevation of
natural stream temperatures. In streams designated as secondary trout waters, there shall
be no elevation exceeding 2°F natural stream temperatures.
Adel WPCP
NPDES Permit No. GA0024911
March 2020
Page 4 of 22

FACT SHEET
3.2 Ambient Information
Annual Hardness Upstream Total
7Outfall ID (fig) ins) Average (mg Suspended Solids
Flow (cfs) CaCO3/L) (mg/L)
001 0.15 0.13 18 25 (1) 10 (2)
(1) A conservative value of 25 mg/L will be used for the reasonable potential analysis
calculations.
(2) A conservative value of 10 mg/L will be used for the reasonable potential analysis
calculations.
3.3 Georgia 305(b)/303(d) List Documents
k.Lci14.arrr as
J.. Y. MAW LOOM to —1 Saxannet
Vy! `lemochee Rker
1 .554
'shoe
- ds mrapeEeo PC (2oo0 & aooal, DO mom).
Bear Creek is listed on the 2018 305(b)/303(d) list as not supporting its designated use
(fishing) but TMDLs have been completed for the impacted parameters (fecal coliform
bacteria and dissolved oxygen).
3.4 Total Maximum Daily Loads (TMDLs)
A TMDL evaluation for 15 stream segments in the Suwannee River Basin for fecal
coliform was completed in 2006. The TMDL recommended that all municipal treatment
facilities with the potential for the occurrence of fecal coliform in their discharge will be
given end of pipe limits equivalent to the water quality standard of 200 counts/100 ml or
less. The fecal coliform bacteria limits in the draft permit are in accordance with the
TMDL requirements.
A TMDL evaluation for the Suwannee River Basin for dissolved oxygen was completed
in 2001. The TMDL does not have a recommendation in load reductions for oxygen
demanding substances for point sources discharging to Bear Creek.
3.5 Wasteload Allocation (WLA)
WLAs for reissuance was issued on November 9, 2017. Refer to Appendix A of the Fact
Sheet for a copy of the WLAs.
4. LIMITATIONS AND PERMIT CONDITIONS FOR SURFACE WATER DISCHARGE
4.1 Reasonable Potential Analysis (RP)
Title 40 of the Federal Code of Regulations, 40 CFR 122.44(d) requires delegated States
to develop procedures for determining whether a discharge causes, has the reasonable
potential to cause, or contributes to an instream excursion above a narrative or numeric
criteria within a State water. If such reasonable potential is determined to exist, the
Adel WPCP
NPDES Permit No. GA0024911
March 2020
Page 5 of 22

• FACT SHEET
NPDES permit must contain pollutant effluent limits and/or effluent limits for whole
effluent toxicity. Georgia's Reasonable Potential Procedures are based on Georgia's
Rules and Regulations for Water Quality Control (Rules), Chapter 391-3-6-.06(4)(d)5.
The chemical specific and biomonitoring data and other pertinent information in EPD's
files will be considered in accordance with the review procedures specified in the Rules
in the evaluation of a permit application and in the evaluation of the reasonable potential
for an effluent to cause an exceedance in the numeric or narrative criteria.
Refer to Section 4.2 for reasonable potential analysis on effluent toxicity.
Refer to Section 4.6 for reasonable potential analysis on toxic and manmade pollutants.
4.2 Whole Effluent Toxicity (WET)
Chronic WET test measures the effect of wastewater on indicator organisms' growth,
reproduction and survival. Effluent toxicity is predicted when the No Observable Effect
Concentrations (NOEC) for a test organism is less than the facility's Instream
Wastewater Concentration (IWC). WET testing also requires a measure of test
sensitivity known as the Percent Minimum Significant Difference (PMSD). See Table
below from Section 10.2.8.3 (page 52) of EPA 821-R-02-013 Short-term Methods for
Estimating the Chronic Toxicity of Effluents and Receiving Waters to Freshwater
Organisms, 4th Edition, 2002 for PMSD variability criteria.
TABLE 6. VARIABILIIY CRITERIA (UPPER AND LOWER PMSD BOUNDS) FOR SUBLETHAL
HYPOTHESIS TESTING ENDPOINTS SUBMITTED ENDER NPDES PERMITS.'
Test Method
Endpoint Lower PMSD Bound Upper PMSD Bound
Method 1000.0, Fathead Minnow Larval
Survival and Growth Teat
Method 1002.0. Cerlodaphnia thrbia
Survival and Reproduction Teat
Method 1003.C. Seknachum
capricoraufwa Growth Test
growth 12 30
reproduction 13 47
growth 9_ 1 � +
1 Lower and upper PMSD bounds were deterraiued from ibe 101' and 901' percentile, respectively, of PMSD data
From EPA's WFT 1ffieriaboratmy Variability Study (USEPA, 2001 a: USEPA, 2001b).
PMSD must be calculated for each species tested as follows:
MSD
_ MinimumSignificart Data(MSD)
ControlMean
x 100
Adel WPCP
NPDES Pemut No. GA0024911
March 2020
Page 6 of 22

FACT SHEET
The effluent from the Adel WPCP will not be considered toxic if the No Observed Effect
Concentration (NOEC) is greater than or equal to the Instream Wastewater
Concentrations (1WCs) of 14% and 25%. If results of the WET tests predict toxicity or
are invalid, then the permittee may be required to perform additional WET tests or the
permit may be modified to include chronic WET effluent limitations.
The permittee submitted the results of 6 WET tests with the application. For 2014-2016
and 2018-2019 tests, the NOEC for Ceriodaphnia dubia survival and reproduction and
Pimephales promelas survival and growth was greater than the IWCs of 14% and 25%.
However, the 2017 test results indicate toxicity to the Pimephales promelas for growth.
Refer to WET Test results summary in the table below.
PMSD values were calculated for each set of results and compared to EPA's Variability
Criteria to ensure their validity. PMSD for Ceriodaphnia dubia reproduction and
Pimephales promelas survival from the five WET tests were lower or within EPA's
Variability Criteria; therefore, the tests are considered valid. Refer to Appendix C for
PSMD values.
Test
Sample
Date
No Observed Effect Concentration (NOEC)
Ceriodaphnia dubia Pimephales promelas
Survival (%) Reproduction (%) Survival (%) Growth (%)
1 2014 100 100 100 100
2 2015 100 25 100 100
3 2016 100 100 100 100
4 2017 100 100 100 <6.25
5 2018 100 100 100 100
6 2019(1) 50 50 50 50
(1) The high ,st instream wastewater concentration evaluated in this test was 50%.
Since effluent toxicity in the 2017 test results was only exhibited for growth in the
Pimephales promelas and not for survival of the species or in the results for
Ceriodaphnia dubia, evidence suggests that there may have been interference in the test,
which resulted in an unexpected reduction in growth. Additionally, the facility has passed
two subsequent WET tests (2018-2019) for both species. A WET limitation, therefore,
has not been included in the permit.
EPD is including requirements for two quarterly chronic WET tests to be conducted
following permit issuance to confirm a WET limit is not required. The permit also
requires annual chronic WET tests thereafter, if toxicity has not been demonstrated.
EPD will evaluate the WET tests submitted to determine whether toxicity has been
demonstrated. If the test results indicate effluent toxicity, the permittee may be required
to perform additional WET tests or studies in accordance with Part I.C.5 of the permit
and/or the permit may be modified to include a chronic WET limit.
Adel WPCP
NPDES Permit No. GA0024911
March 2020
Page 7 of 22

FACT SHEET
drzre
•
4.3 Applicable Water Quality Based Effluent Limitations (WQBELs)
When drafting a National Pollutant Discharge Elimination System (NPDES) permit, a
permit writer must consider the impact of the proposed discharge on the quality of the
receiving water. Water quality goals for a waterbody are defined by state water quality
standards. By analyzing the effect of a discharge on the receiving water, a permit writer
could find that technology -based effluent limitations (TBELs) alone will not achieve the
applicable water quality standards. In such cases, the Clean Water Act (CWA) and its
implementing regulations require development of water quality -based effluent limitations
(WQBELs). WQBELs help meet the CWA objective of restoring and maintaining the
chemical, physical, and biological integrity of the nation's waters and the goal of water
quality that provides for the protection and propagation of fish, shellfish, and wildlife and
recreation in and on the water (fishable/swimmable).
WQBELs are designed to protect water quality by ensuring that water quality standards
are met in the receiving water and downstream uses are protected. On the basis of the
requirements of Title 40 of the Code of Federal Regulations (CFR) 125.3(a), additional
or more stringent effluent limitations and conditions, such as WQBELs, are imposed
when TBELs are not sufficient to protect water quality.
The term pollutant is defined in CWA section 502(6) and § 122.2. Pollutants are grouped
into three categories under the NPDES program: conventional, toxic, and
nonconventional. Conventional pollutants are those defined in CWA section 304(aX4)
and § 401.16 (BOD5, TSS, fecal coliform, pH, and oil and grease). Toxic (priority)
pollutants are those defined in CWA section 307(a)(1) and include 126 metals and
manmade organic compounds. Nonconventional pollutants are those that do not fall
under either of the above categories (conventional or toxic pollutants) and include
parameters such as chlorine, ammonia, nitrogen, phosphorus, chemical oxygen demand
(COD), and whole effluent toxicity (WET).
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FACT SHEET
4.4 Conventional Pollutants
Pollutants of Concern Basis
pH
The instream wastewater concentration (IWC) is 14% from
June to November and 25% from December to May. When the
IWC is Iess than 50%, there is no reasonable potential to cause
or contribute to violation of the instream Georgia Water
Quality Standard; therefore, pH limits of 6.0-9.0 SU (daily
minimum -daily maximum) were included in the draft permit
Five -Day Biochemical Oxygen
Demand (BOD5)
According to the steady-state dissolved oxygen Georgia
DOSAG model, a monthly average BOD5 limit of 30 mg/L,
when combined with the ammonia limit (refer to Section 4.5
below), is protective of the instream Water Quality Standard
for dissolved oxygen described in Section 3.1 above. Refer to
the WLA in AppendixA for model inputs.
Since the facility discharges a variable flow based on a fixed
maximum ratio to the flow of the receiving stream, it is
infeasible to express a mass -based limitation that is
representative of the operation of the facility. Therefore, in
accordance with 40 CFR 122.45(f)(1)(iii), effluent loading
limitations for BOD5 have been removed from the permit
Refer to Section 6.8.
Total Suspended Solids (TSS)
The monthly average TSS limit of 90 mg/L is in accordance
with technology based effluent limitations for ponds (i.e.,
adjusted secondary standards).
Since the facility discharges a variable flow based on a fixed
maximum ratio to the flow of the receiving stream, it is
infeasible to express a mass -based limitation that is
representative of the operation of the facility. Therefore, in
accordance with 40 CFR 122.45(f)(lxiii), effluent loading
limitations for TSS have been removed from the permit. Refer
to Section 6.8.
The monthly average FCB limit of 200 #/100mL is in
Fecal Coliform Bacteria (FCB) accordance with the instream Water Quality Standards in
Section 3.1 above / TMDL requirements in Section 3.4 above.
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March 2020
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FACT SHEET
4.5 Nonconventional Pollutants
Pollutants of Concern
Basis
Chlorine is used for disinfection. A daily maximum TRC limit of
Total Residual Chlorine (TRC) 0.04 mg/L has been determined using the US EPA's chronic TRC
criterion of 11 µg/L in the receiving stream after dilution. Refer
to Section 4.7 below for calculations.
Dissolved Oxygen (DO)
According to the steady-state dissolved oxygen Georgia DOSAG
model, a minimum effluent DO of 2.0 mg/L is protective of the
instream Water Quality Standard for dissolved oxygen described
in Section 3.1 above.
Total Phosphorus (TP)
Total phosphorus monitoring has been included in the draft permit
in accordance with EPD's Strategy for Addressing Phosphorus in
NPDES Permitting, 2011.
Orthophosphate, Total
Kjeldahl Nitrogen (TKN),
Organic Nitrogen, Nitrate -
Nitrite
Ammonia (NH3)
Orthophosphate, TKN, organic nitrogen, and nitrate -nitrite
monitoring has been included in the draft permit. The data will be
used to determine nutrient speciation and to quantify nutrient
loadings in the Suwannee River Basin.
The monthly average ammonia limit was decreased from 16.8
mg/L to 10.0 mg/L in accordance with EPD's NPDES Permitting
Strategy for Addressing Ammonia Toxicity, 2017. A review of
Discharge Monitoring Report data indicates that the facility can
meet the proposed limit without process modification; therefore, a
compliance schedule was not included in the draft permit.
According to the steady-state dissolved oxygen Georgia DOSAG
model, the proposed monthly average ammonia limit of 10.0
mg/L, when combined with the BOD5 and dissolved oxygen limit
(Refer to Section 4.4 above), is also protective of the instream
Water Quality Standard for dissolved oxygen described in Section
3.1 above.
Since the facility discharges a variable flow based on a fixed
maximum ratio to the flow of the receiving stream, it is infeasible
to express a mass -based limitation that is representative of the
operation of the facility. Therefore, in accordance with 40 CFR
122.45(f)(lxiii), effluent loading limitations for ammonia have
been removed from the permit. Refer to Section 6.8.
Adel WPCP
NPDES Permit No. GA0024911
March 2020
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FACT SHEET
4.6 Toxics & Manmade Organic Compounds
The permittee submitted the results of three Priority Pollutant Scans (PPS) with the
permit application. The permittee also conducted three scans for total recoverable
mercury in accordance with the permit. All pollutants were "non -detect" except for the
following:
Pollutants of Concern Basis
Total Recoverable Copper This parameter was evaluated and its instream concentration was
found to be less than 50% of the acute and chronic instream water
quality standards. Refer to Appendix B of the Fact Sheet for
reasonable potential evaluations.
Total Recoverable
Mercury
In accordance with EPD reasonable potential procedures, copper is
not considered a pollutant of concern and additional monitoring is
not required.
This parameter was evaluated and its instream concentration was
found to be less than 50% of the acute and chronic instream water
quality standards. Refer to Appendix B of the Fact Sheet for
reasonable potential evaluations.
In accordance with EPD reasonable potential procedures, mercury is
not considered a pollutant of concern and effluent monitoring has
been removed from the draft permit.
Total Recoverable Nickel This parameter was evaluated and its instream concentration was
found to be less than 50% of the acute and chronic instream water
quality standards. Refer to Appendix B of the Fact Sheet for
reasonable potential evaluations.
Total Recoverable Zinc
In accordance with EPD reasonable potential procedures, nickel is
not considered a pollutant of concern and additional monitoring is
not required.
This parameter was evaluated and its instream concentration was
found to be less than 50% of the acute and chronic instream water
quality standards. Refer to Appendix B of the Fact Sheet for
reasonable potential evaluations.
In accordance with EPD reasonable potential procedures, zinc is not
considered a pollutant of concern and additional monitoring is not
required.
Adel WPCP
NPDES Permit No. GA0024911
March 2020
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FACT SHEET
4.7 Calculations for Effluent Limits
4.7.1 Instream Waste Concentration (IWC):
IWC — Q Rim(ft3/sec)
Q gin„ma (ft3lsec) + 7Q 10 (ft3/sec)
Q=Flow
C = Concentration
M = Mass
For June through November, the stream to effluent flow ratio is 6 to 1:
1
_ 1+6=14%
For December through May, the stream to effluent flow ratio is 3 to 1.
_ 1 _ 25 %
1+3—
4. Z3 Five -Day Biochemical Oxygen Demand:
• Weekly Average Concentration:
[C] Weekly = [C] Monthly (mg/L) x 1.5
=30x 1.5
= 45 mg/L
4.7.4 Total Suspended Solids:
• Weekly Average Concentration:
[C] weekly = [C] Monthly (mg/L) x 1.33
=90x 1.33
= 120 mg/L
4.7. S Fecal Colaform Bacteria:
• Weekly Average Concentration:
C weekly = C May (#1100 mL) x 2
= 200 x 2
=400#/100mL
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FACT SHEET
MI
4. 7.6 Total Residual Chlorine (TRC):
• Daily Maximum Concentration:
[TRC] Effluent =
Q n iu„nt (ft3/sec)
[Q Effluent (ft 3/sec) + 7Q10 (ft 3/sec)] x [TRC] st. (mg/L)
0.011
0.25
=0.04mg/L
4. Z 7 Ammonia:
• Toxicity Analysis:
The chronic criterion based on Villosa iris (rainbow mussel) is determined as follows:
0.0278 1.1994 o azs X �zo-adax�r,��
CCC=0.8876x(1+10''6u +1+10 -7'6Bg x2.126x 10 mg/L
Where: pH : pH of receiving stream and discharge
T : Temperature of receiving stream
CCC : Chronic Continuous Concentration
The ammonia effluent limit (monthly average) is then calculated as follows:
[NH3] Effluent =
(Q ffi„ent (ft3/sec) + 30Q3 (ft 3/sec)) x CCC (mg/L)-30Q3(ft3/sec)x[NH3]Stre.Bacic and (mg/L)
Q (ft3/sec)
Refer to Appendix C for detailed calculations.
• Weekly Average Concentration:
[C] Weekly = [C] monthly (mg/L) x 1.5
= 10.0x 1.5
= 15.0 mg/L
4.7.8 Metals
Not applicable.
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March 2020
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FACT SHEET
4.8 Applicable Technology Based Effluent Limits (TBELS)
Technology -based effluent limitations aim to prevent pollution by requiring a minimum
level of effluent quality that is attainable using demonstrated technologies for reducing
discharges of pollutants or pollution into the waters of the United States. TBELs are
developed independently of the potential impact of a discharge on the receiving water,
which is addressed through water quality standards and water quality based effluent
limitations. The NPDES regulations at Title 40 of the Code of Federal Regulations
125.3(a) require NPDES permit writers to develop technology -based treatment
requirements, consistent with CWA section 301(b), that represent the minimum level of
control that must be imposed in a permit. The regulation also indicates that permit writers
must include in permits additional or more stringent effluent limitations and conditions,
including those necessary to protect water quality.
For pollutants not specifically regulated by Federal Effluent Limit Guidelines, the permit
writer must identify any needed Technology based effluent limitations and utilizes best
professional judgment to establish technology based limits or determine other appropriate
means to control its discharge.
40 CFR Part §122.44(aX1) requires that NPDES permits include applicable technology -
based limitations and standards, while regulations at § 125.3(a)(1) state that TBELs for
publicly owned treatment works must be based on secondary treatment standards and the
"equivalent to secondary treatment standards" (40 CFR Part 133). The regulation applies
to all POTWs and identifies the technology -based performance standards achievable
based on secondary treatment for five-day biochemical oxygen demand (BOD5), total
suspended solids (TSS), and pH.
The table below shows the secondary treatment standards for ponds:
Parameter
Secondary Treatment Standards
BOD5
TSS CI)
BOD5 removal (concentration)
pH (Daily Minimum — Daily Maximum)
30-day Average 7-day Average
30 mg/L 45 mg/L
90 mg/L
>65%
6.0-9.0 S.U.
(1) Adjusted secondary standard for ponds in accordance
Volume 49, Number 184, page 37005, September 20, 1984
with Federal Register,
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March 2020
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FACT SHEET
4.9 Comparison & Summary of Water Quality vs. Technology Based Effluent Limits
After determining applicable technology -based effluent limitations and water quality -
based effluent limitations, the most stringent limits are applied in the permit:
Parameter
WQBELS (1) TBELS (1)
Monthly Average Monthly Average
Five -Day Biochemical Oxygen Demand (mg/L) 30.0 30.0
Total Suspended Solids (mg/L) None 90
Ammonia (mg/L) 10.0 None
Fecal Coliform Bacteria (#/100 mL) 200 None
Dissolved Oxygen (mg/L), Daily Minimum 2.0 None
Total Residual Chlorine (mg/L), Daily Maximum 0.04 None
pH (S.U.), Daily Minimum — Daily Maximum 6.0-9.0 6.0-9.0
Effluent limits in bold were included in the permit. Refer to Sections 4.5, 4.6, 4.7, and 4.8 above
for mom information.
5. LIMITATIONS AND PERMIT CONDITIONS FOR LAND TREATMENT SYSTEM
5.1 Pretreatment Limitations and Monitoring
5.1.1 BOD, TSS, and pHLimitations:
BOD: 50 mg/L; TSS: 90 mg/L; pH: 6.0 —10.0
The proposed BOD and TSS limits in the draft permit are in accordance with EPD
guidelines for land application of wastewater.
The proposed pH limits in the draft permit have been maintained from the current permit.
5.1.2 Nitrogen Loading:
Monthly monitoring for nitrate and total Kjeldahl nitrogen for the pond effluent has been
included in the draft permit to quantify nitrogen loading to the sprayfield and verify
design assumptions.
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FACT SHEET
KINIMMIZI..
5.2 Application Rate and Wetted Area
Treated effluent is disposed of via spray irrigation:
Wetted area: 280 acres
Application rate: 2.3 in/week
The wetted area and the application rate in the draft permit are in accordance with the
current permit
The maximum allowable flow to the spray field is as follows:
As;th (acres) x WLR (in/week) x 43, 560 ft2/acre x 7.48 gal/ft3
Site capacity — gallweek
12 in/ft
280X2.3X43,560X7.48
12
= 17,500,000 gal/week maximum or 2.5 MGD (7-day average)
5.3 Groundwater Monitoring Requirements
The intent of monitoring is to determine the influence of the land treatment system on the
quality of the groundwater. Groundwater leaving the spray field boundaries must meet
drinking water maximum contaminant levels (MCLs).
In accordance with EPD requirements for all municipal LAS facilities, groundwater will
be monitored for the following parameters:
Parameter (units)
Depth to Groundwater (feet)
Nitrate, as N (mg/L)
pH (standard units)
Specific Conductivity (µmhos/cm)
Fecal Coliform Bacteria (# coll100mL)
Based on the application submitted, it has been determined that monitoring for additional
parameters is not required at this time.
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FACT SHEET
5.4 Soil Monitoring Requirements
The intent of monitoring is to determine the influence of the treated wastewater on the
soil chemistry/composition. It will also aid the permittee with operation and maintenance
of the land treatment system.
In accordance with EPD requirements for all municipal LAS facilities, requirements to
conduct soil fertility tests, as well as Cation Exchange Capacity and Percent Base
Saturation analysis (depending on pH results), have been included in the draft permit.
Based on the application submitted, it has been determined that monitoring for additional
parameters is not required at this time.
5.5 Surface Water Monitoring Requirements
The intent of monitoring is to determine if the facility has an impact on perennial surface
water adjacent to or traversing the sprayfields by comparing results from upstream and
downstream samples.
Surface water, if present, will be monitored for the following parameters:
Parameter (units)
Nitrate, as N (mg/L)
Five -Day Biochemical Oxygen Demand (mg/L)
Specific Conductivity (µmho/cm)
pH (standard unit)
Total Kjeldahl Nitrogen (mg/L)
Temperature (°C)
Dissolved Oxygen (mg/L)
There are no surface waters within 300 feet of the sprayfield identified in the Design
Development Report and permit application.
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FACT SHEET
6. OTHER PERMIT REQUIREMENTS AND CONSIDERATIONS
6.1 Long -Term BOD (LTBOD) Test
For facilities with a capacity of 1.0 MGD or greater, EPD may include requirements for
LTBOD tests in permits for when data is needed for water quality modeling. The
permittee conducted a LTBOD test during the current permit cycle; therefore,
requirements for LTBOD testing have not been included in the draft permit.
6.2 Hydrograph Controlled Release (HCR) Discharges
The City of Adel is equipped with an HCR Controller, which allows the facility to
discharge a variable flow continuously proportional to the stream flow. Therefore, flow
limitations are based on a maximum effluent to stream ratio (or instream wastewater
concentration), in addition to a daily maximum limitation of 4.3 MGD based on the
design flow of the facility. All other limitations are expressed as monthly average and
weekly average in accordance with 40 CFR 122.45 requirements for POTWs.
40 CFR 122.45(f)(1)(iii) also states that facilities may be exempt from mass -based
limitations if the loading cannot be related to the measure of operation of the facility.
Since the facility discharges at variable flows based on daily stream condition
fluctuations, the calculation for mass -based loadings is not representative . of the
monthly/weekly loads to the stream. According to water quality modeling, the
concentration -based limits are protective of water quality standards provided the
maximum instream wastewater concentration is continuously maintained. Therefore,
mass -based limitations have not been included in the permit (refer to Section 6.8 below).
6.3 Industrial Pre-treatment Program (IPP)
The City does not have an approved IPP; therefore, language for establishing an IPP, if
necessary, has been included in the draft permit.
6.4 Sludge Management Plan (SMP)
Sludge is disposed of in a landfill; therefore, a SMP is not required.
6.5 Watershed Protection Plan (WPP)
The City has an approved Watershed Protection Plan; therefor, language reflecting the
approved plan has been included in the permit.
6.6 Service Delivery Strategy
The City of Adel is in compliance with the Department of Community Affairs
approved Service Delivery Strategy for Cook County.
6.7 Compliance Schedules
Effluent limitations are applicable immediately upon the effective date of the permit.
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FACT SHEET
6.8 Anti -Backsliding
In accordance with 40 CFR 122.44(1)(2Xi)(B)(2), a permit may be renewed, reissued, or
modified to contain a less stringent effluent limitation applicable to a pollutant if it is
determined that technical mistakes or mistaken interpretations were made and which
would have justified the application of a less stringent effluent limitation at the time of
permit issuance. If the permittee has installed treatment required to meet the effluent
limitations and has properly operated and maintained the facility, but is still unable to
meet the permit conditions, then the permit may also be issued with a less stringent limit
in accordance with 40 CFR 122.44(1)(2)(i)(E).
Design Flaw:
The current permit includes a monthly average flow limitation of 2.5 MGD, which was
not included in previous iterations of the permit. This value was inadvertently added to
the limitations on the discharge based on the capacity of the land treatment system. The
discharge flow, however, is limited based the following factors: Maintaining a maximum
instream wastewater concentration under variable instream flow conditions, which is
included in the current permit; and, the design capacity of the chlorination structure of 4.3
MGD. Therefore, the instream wastewater concentration limitations have been clarified
in the draft permit and the average monthly and weekly limitations have been replaced
with a daily maximum limitation of 4.3 MGD.
Since the monthly and weekly average flow was inadvertently included in the permit, the
removal of the limitations complies with the anti backsliding requirements of the Clean
Water Act.
Mass Based Limitations:
The current permit includes mass -based limits based on the inaccurate design flow of 2.5
MGD, which were also not included in previous iterations of the permit. The discharge
flow, rather, is controlled by an HCR (refer to Section 6.2) in order to maintain a
maximum instream wastewater concentration under variable flow conditions. Since the
discharge flows are based on fluctuating stream conditions, the calculation for loading
limitations is not representative of the weekly/monthly load to the stream.
40 CFR 122.45(f)(1)(iii) states that facilities may be exempt from mass -based limitations
if the loading cannot be related to the measure of operation of the facility. Furthermore,
water quality modeling indicates that the concentration -based limits are protective of
water quality standards provided the maximum instream wastewater concentration is
continuously maintained. Therefore, mass -based limitations are not required in the permit
and have been removed.
Since mass -based limitations were also inadvertently included in the permit based on an
inaccurate design flow, the removal of the limitations complies with the anti -backsliding
requirements of the Clean Water Act.
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March 2020
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FACT SHEET
Percent Removal:
The current permit includes a percent removal limitation of 85% for five-day biochemical
oxygen demand based on secondary treatment standards. The facility, however, is
equipped with a waste stabilization pond, thus qualifying for "equivalent to secondary
treatment standards" in accordance with 40 CFR 133.103, which requires a percent
removal for five-day biochemical oxygen demand of not less than 65%. Additionally, the
facility maintains their pond and is unable to consistently meet the limitation of 85%.
Since the facility is unable to meet the current limit with proper operation and this limit is
greater than that required by the equivalent standards, a limitation of 65% has been
included in the draft permit and the change is in compliance with the anti backsliding
requirements of the Clean Water Act.
7. REPORTING
7.1 Compliance office
The facility has been assigned to the following EPD office for reporting, compliance and
enforcement:
Georgia Environmental Protection Division
Watershed Compliance Program
2 Martin Luther King Jr. Drive
Suite 1152 East
Atlanta, Georgia 30334
7.2 E-Reporting
The permittee is required to electronically submit documents in accordance with 40 CFR
Part 127.
8. REQUESTED VARIANCES OR ALTERNATIVES TO REQUIRED STANDARDS
Not applicable.
9. PERMTT EXPIRATION
The permit will expire five years from the effective date.
10. PROCEDURES FOR THE FORMULATION OF FINAL DETERMENATIONS
10.1 Comment Period
The Georgia Environmental Protection Division (EPD) proposes to issue a permit to this
applicant subject to the effluent limitations and special conditions outlined above. These
determinations are tentative.
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March 2020
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FACT SHEET
NEB
The permit application, draft permit, and other information are available for review at 2
Martin Luther King Jr. Drive, Suite 1152 East, Atlanta, Georgia 30334, between the
hours of 8:00 a.m. and 4:30 p.m., Monday through Friday. For additional information,
you can contact 404-463-1511.
10.2 Public Comments
Persons wishing to comment upon or object to the proposed determinations are invited to
submit same in writing to the EPD address above, or via e-mail at
EPDcomments(dnr.ga.gov within 30 days of the initiation of the public comment
period. All comments received prior to that date will be considered in the formulation of
final determinations regarding the application. The permit number should be placed on
the top of the first page of comments to ensure that your comments will be forwarded to
the appropriate staff.
10.3 Public Hearing
Any applicant, affected state or interstate agency, the Regional Administrator of the U.S.
Environmental Protection Agency (EPA) or any other interested agency, person or group
of persons may request a public hearing with respect to an NPDES permit application if
such request is filed within thirty (30) days following the date of the public notice for
such application. Such request must indicate the interest of the party filing the request,
the reasons why a hearing is requested, and those specific portions of the application or
other NPDES form or information to be considered at the public hearing.
The Director shall hold a hearing if he determines that there is sufficient public interest in
holding such a hearing. If a public hearing is held, notice of same shall be provided at
least thirty (30) days in advance of the hearing date.
In the event that a public hearing is held, both oral and written comments will be
accepted; however, for the accuracy of the record, written comments are encouraged.
The Director or a designee reserves the right to fix reasonable limits on the time allowed
for oral statements and such other procedural requirements, as deemed appropriate.
Following a public hearing, the Director, unless it is decided to deny the permit, may
make such modifications in the terms and conditions of the proposed permit as may be
appropriate and shall issue the permit.
If no public hearing is held, and, after review of the written comments received, the
Director determines that a permit should be issued and that the determinations as set forth
in the proposed permit are substantially unchanged, the permit will be issued and will
become final in the absence of a request for a contested hearing. Notice of issuance or
denial will be made available to all interested persons and those persons that submitted
written comments to the Director on the proposed permit.
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FACT SHEET
-1.
If no public hearing is held, but the Director determines, after a review of the written
comments received, that a permit should be issued but that substantial changes in the
proposed permit are warranted, public notice of the revised determinations will be given
and written comments accepted in the same manner as the initial notice of application
was given and written comments accepted pursuant to EPD Rules, Water Quality
Control, subparagraph 391-3-6-.06(7)(b). The Director shall provide an opportunity for
public hearing on the revised determinations. Such opportunity for public hearing and the
issuance or denial of a permit thereafter shall be in accordance with the procedures as are
set forth above.
10.4 Final Determination
At the time that any final permit decision is made, the Director shall issue a response to
comments. The issued permit and responses to comments can be found at the following
address:
http://epdgeorgia.gov/watershed protection-branchpermit-arid public-comments-clearinghouse-0
10.5 Contested Hearings
Any person who is aggrieved or adversely affected by the issuance or denial of a permit
by the Director of EPD may petition the Director for a hearing if such petition is filed in
the office of the Director within thirty (30) days from the date of notice of such permit
issuance or denial. Such hearing shall be held in accordance with the EPD Rules, Water
Quality Control, subparagraph 391-3-6-.01.
Petitions for a contested hearing must include the following:
1. The name and address of the petitioner;
2. The grounds under which petitioner alleges to be aggrieved or adversely affected
by the issuance or denial of a permit;
3. The reason or reasons why petitioner takes issue with the action of the Director;
4. All other matters asserted by petitioner which are relevant to the action in
question.
Adel WPCP
NPDES Permit No. GA0024911
March 2020
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FACT SHEET
Appendix A
Adel Water Pollution Control Plant
NPDES Permit No. GA0024911
Waste Load Allocation (WLA)

National Pollutant Discharge Elimination System
Wasteioad Allocation Form
-- ' �..
• Part is Background it
_
WLA Request Type: Reissuance _l Expansion ■ Relocation • New Discharge ■
Facility Name: Adel WPCP County: Cook WQMU: 0905
NPDES Permit No.: GA0024911 Expiration Date: 5/31/2018 Outran Number. 001
Receiving Water: Bear Creek River Basin: Suwannee 10-Digit HUC: 0311020304
Discharge Type: Domestic ■ Industrial U Both Proportion (D:I): Flow(s) Requested (MGD): 2.5
Industrial Contributions Tyoe(s): Production plating does some pretreatment prior to discharging to sewer.
Coarse screening using manual bar screen, aerated lagoon, combined holding/stabilization pond, and
Treatment Process Description: chlorine disinfection. Sludge removed from aeration pond is spread onto on-slte sand fl& iki c 'cs)
Cook County landfill.
Dried slue Is dised at the --
Additional Information: {historyspecial conditions, other fadiitieC;H drograih control release discharge with a land application system
Requested by: Kim Hembree Title: ES Program: WRP NOV 13
Telephone: [phone] Date: b1112017
„ P rt ��- i of V I fi infant tiof.! . _ .. }sr . . limpteLisiimpn
r
Receiving Water Bear Creek to the Wlthlacoochee River Designated Use Classification: Fishing
Integrated 305(b)/303(d) List: Yes No • Support: ❑ Not Support: _! Criteria: Fecal Conform Becter's
Total Maximum Daily Load: Yes ® No • Parameter(s) FC, DO WLA Complies with TMDL Yes ® No ❑
TMDLs for fecal conform were completed In 2000 and 2008 In the Suwannee River Basin. A 26% Toad reduction of fecal colllonn In Beer
Creak was recommended. The fecal conform limit of 200 counts/100 mL meets the TMDL recommendation.
A dissolved oxygen TMDL was developed in 2001 in the Suwannee River Basin. There was no recommendation in load reductions for
biochemical • • en demand total n . • • en and total • hos • horus for • • int sources discha • In • to Bear Creek.
. -..! y4+.�r:,a,-.` .y.+n f...'v....'� •-..... '... ma's, •yr. ,�•7•-. r.- �.y-. - v_ y}.ram ._ '3 -. J 44. 'r+s: lam. "- •'!'o4A.ra -.. .f^' Yr �..TS.11o-..
- Part 111:. Water Wei Ity Model Review information
Model Type: Uncalibrated • Calibrated c 4 Verified a Cannot be Modeled ■ Model Length (mi): 9.3
Field Data: None • Fair ® Good • Excellent •
Model and Field Data Description: Steady-state dissolved oxygen Georgie DOSAG model.
Critical Water Temperature:(•C): 28 Drainage Area (min): 24.8 7Q10 streamflow at discharge (cis): 0.16
7010 Yield (cfslml): 0.006 Velocity (range fps): 0.15.0.19 1010 streamflow at discharge (ofs): 0.13
€flitira tfFf`ofiw'Ratb'(cfs) - - $:64 .-. 7010 IWC (%):" t4(6:t).128-(3:t)----•Meanaannual.streamflow atdlecharge.(cfs):....18 - -..._
f Slope (range - fpm): 5.0 - 8.0 K1: 0.1510.02 K3: 0.7 -1.2 Escape Coaf. (ff1): 0.11 K2 (range): 2.3.2.9 ;
SOD: 0.2 - 0.4 f-Ratlo (BODe1BOD5) 2 Background Hardness (mg/L as CaCO1): 62 '•'
The • r•sdlcted minimum dissolved o en concentration Is 5.7 m . , occurrin . a • • roximstel 1.2 miles downstream from the d a ,
,. ,.s ._.....-2..a.- _:.--.
Part IV: Recommended Penis Limitations and Conditions (rg1.i. as a monthly average except ae n d)
Rationale: Same as current • Revised . New In
Location: Bear Creek
i
Effluent Flow Rate BODe NH�-N DO ecal
TRC TSS CF Iforsn pH Total Nitrite - TKN Organic
(MGD) (minimum) (tellymeat.) (Nalifo ) feu' units) Phosphorus Nitrate Nitrogen ..
Monitor 30 10 2.0 0.04 90 200 6.0 - 9.0 Monitor Monitor Monitor Monitor
Additional Comments:
• Priority pollutants permit limits, aquatic toxicity tasting requirements, and other parameters required by categorical effluent guidelines ,
are to be determined by WRP. -
• Discharge to Bear Creek Is limited to periods when the stream flow to effluent ratio Is at least 6:1 (June through November) and et least .
3:1 (December through May). ,,r
• The revised ammonia limit meets the U.S. EPA's Aquatic Life Ambient Water Quality Criteria for Ammonia -Freshwater 2013.
• Effluent monitoring for total phosphorus, TKN, nitrate-nitrits, and organic nitrogen is recommended. TKN, nitrate -nitrite, ammonia, and ,,�
organic nitrogen should be analyzed from the same effluent sample. Nutrient monitoring data will be used to determine nutrient ,y,
spsclatlon and the nutrient loads being discharged Into waters entering Florida. it
• Monitoring data have shown an approximately 40% correlation of ortho-phosphorus to total phosphorus In the facility effluent.
• The Clty has obtained approval of its Watershed Assessment (WA). The Clty needs to complete Its Watershed Protection Plan and l}
submit It to the Georgia EPD for review and approval.
Prepared by: Lucy Sun - Elate 10,23f2017 I Reviewed cy: Josh Welts .. • Date: 10/25/2017
- r
Part•V: Program Manager Comment
Elizabeth Booth
Gsorple Deportment or Nature! Resources
Environmental Protection Division

FACT SHEET
Appendix B
Adel WPCP
NPDES Permit No. GA0024911
Stream Data u0stream of the dischar2e):
TSS:
7Q10:
1Q10:
Mean flow:
10
0.15
0.13
18
Flow Limitations :
mg/L
ft3/s
ft3/s
fl/s
Dilution factor (under all conditions):
Instream Wastewater Concentration:
3 to 1
25 %
Stream data downstream of the dischai•2e:
Hardness (at 7Q10):
TSS (at 7Q10):
Dilution factor (at average flow):
Dilution factor (at 7Q10):
Dilution factor (at 1Q10):
25.0 mg/L
41.29 mg/L
4.0
4.0
4.0
Effluent Data:
TSS:
Flow (Max):
Flow:
42.0
4,300,000
6.7
mg/L
gallday
ft3/s
Dilution Factor = s'"°°°' (ft3/sec) + Qa�9nent (ft3/sec)
QffIluent (ft3/sec)
Acute Water Quality Criteria (WQC, a) - Metals:
Metal
K0
a
fn
Maximum
effluent C7
(its)
Instream CD
(-)
WQC, o
(1)
Action
needed?
Arsenic
4.80.E+05
-0.729
0.00
0.0
0.0
340.00
no
Cadmium
4.00.E+06
-1.131
0.000
0.0
0.0
0.52
no
Chromium III
3.36.E+06
-0.930
0.00
0.0
0.0
183.07
no
Chromium VI
3.36.E+06
-0.930
0.00
0.0
0.0
16.00
no
Copper
1.04.E+06
-0.744
0.27
3.7 1
0.25
3.64
no
Lead
2.80.E+06
-0.800
0.00
0.0
0.0
13.88
no
Mercury
NA
NA
NA
0.0
0.0
1.40
no
Nickel
4.90.E+05
-0.572
0.29
10.0
0.7
144.92
no
Zinc
1.25.E+06
-0.704
0.21
11.0
0.58
36.20
no
1
fD _1 + Kpo x TSSin (mg/L) 114°x 10-6
Instream CD = Effluent CT (mg/L) x fD mg/L
DF
Page 1 10/31/2019

FACT SHEET
Appendix B
Adel WPCP
NPDES Permit No. GA0024911
Chronic Water Quality Criteria (WQCcii J - Metals:
Metal
Km
a
f°
Average
effluent CT
(N)
Instream CD
(lig/L.)
WQC per.
(lam)
Action
needed?
Arsenic
4.80.E-05
-0.729
0.00
0.0
0.0
150.00
no
Cadmium
4.00.E+06
.1.131
0.000
0.0
0.0
0.09
no
Chromium III
3.36.E+06
-0.930
0.00
0.0
0.0
23.81
no
Chromium VI
3.36.E+06
-0.930
0.00
0.0
0.0
11.00
no
Copper
1.04.E-606
-0.744
0.27
1.20
0.08
2.74
no
Lead
2.80.E-06
-0.800
0.00
0.0
0.0
0.54
no
Mercury
NA
NA
NA
0.0
0.0
0.012
no
Nickel
4.90.E--05
-0.572
0.29
5.7
0.4
16.10
no
Zinc
1.25.E+06
-0.704
0.21
8.0
0.42
36.50
no
1
f° =
1 + Kpp x T SSm, (mg/L) (1+°`)x 10-6
Instream CD = Effluent CT(mg/L) x f° mg/L
DF
Water Quality Criteria (WQC) - Non Metals:
Pollutant
Effluent CT
(1 )
Instream
Concentration
(1182)
WQC
(ufI/L)
WQC/2
(WA)
Action
needed?
NA
0.11
0.00
IF
0
no
NOTES:
- Water Quality Criteria (WQC) from State of Georgia Rules and Regulations 391-3-6-.03.
• If the calculated instream concentration is less than 50% of the instream water quality criteria, then the constinuent will be
considered not to be present at levels of concern.
- If the calculated instream concentration is greater than 50% of the instream water quality criteria, then additional monitoring
may be required or a permit limit for that constinuent may be included in the permit.
Page 2 10/31/2019

FACT SHEET
Appendix B
City of Adel WPCP
NPDES Permit No. GA0024911
Stream Data I upstream of the discharaet: Effluent Data:
TSS:
7Q10:
1Q10:
Mean flow:
10
0.15
0.13
18
Flow Limitations :
mg/L
ft /s
ft3/s
ft3/s
Dilution factor (under all conditions):
Instream Wastewater Concentration:
6 to 1
Stream data (downstream of the dischai
Hardness (at 7Q10):
TSS (at 7Q10):
Dilution factor (at average flow):
Dilution factor (at 7Q10):
Dilution factor (at 1Q10):
14 %
25.0 mg/L
41.29 mg/L
7
Acute Water Quality Criteria (WQCA ) - Metals:
TSS:
Flow (Max):
Flow:
42.10
mg/L
4,300,000 jgal/day
6.7 ft3/s
Dilution Factor = Qs (ft3/sec) + QFffiuent (ft3/sec)
Q Efeuent (ft3 /Sec)
Metal
KPo
a
fD
Maximum
effluent Cr
(118/I-)
Instream CD
(11g/L)
WQC Am,
(1t62)
Action
needed?
Arsenic
4.80.E+0S
-0.729
0.00
0.0
0.0
340.00
no
iCadmium
4.00.E+06
-1.131
0.000
0.0
0.0
0.52
no
Chromium III
3.36.E+06
-0.930
0.00
0.0
0.0
183.07
no
Chromium VI
3.36.E+06
-0.930
0.00
0.0
0.0
16.00
no
Copper
1.04.E+06
-0.744
0.27
3.7
0.14
3.64
no
Lead
2.80.E+06
-0.800
0.00
0.0
0.0
13.88
no
Mercury
NA
NA
NA
0.0
0.0
1.40
no
Nickel
4.90.E+05.
-0.572
0.29
10.0
0.4
144.92
no
Zinc
1.25.E+06
-0.704
0.21
11.0
0.33
36.20
no
1
fD = 1+KPoxTSS,.,,(mgL) «1' x10-6
Instream Co = Effluent CT (mg/L) x fD m�I
DF
Page 1 10/31/2019

FACT SHEET
Appendix B
City of Adel WPCP
NPDES Permit No. GA0024911
Chronic Water Quality Criteria (WQC) - Metals:
Metal
ICE
a
fD
Average
effluent Cr
(142)
Instream CD
01844
WQC moth.
(time)
Action
needed?
fusenic
4.80.E+05
i
0.0
0.0
150.00
no
Cadmiiun
4.00.E+0b
0.000
0.0
0.0
0.09
no
Chromium HI
3.36.E+06
-0.930
1
0.0
_ 0.0
23.81
no
Chromium VI
3.36.E+06
-0.930
0.00
0.0
0.0
11.00
no
Copper
1.04.E+06
-0.744
0.27
1.20
0.05
2.74
no
Lead
2.80.E+06
-0.800
0.00
0.0
0.0
0.54
no
Mercury
NA
NA
NA
0.0
0.0
0.012
no
Nickel
4.90.E+05
-0.572
0.29
5.7
0.2
16.10
no
Zinc
1.25.E+06
-0.704
0.21
8.0
0.24
36.50
no
1
f D = 1 + Kp0 x TSS1,. (mg/I.,) (''')x 10-6
Instream CD =Effluent Cr Ong)x fD
DF
Water Quality Criteria (WQC) - Non Metals:
Pollutant
Effluent Cr
(WA)
Ingram
Concentration
(1182)
WQC
(142)
WQC/2
(1182)
Action
needed?
NA
U,tt
0.00
'F
0
no
NOTES:
- Water Quality Criteria (WQC) from State of Georgia Rules and Regulations 391-3-6-.03.
- If the calculated instream concentration is less than 50% of the instream water quality criteria, then the constinuent will be
considered not to be present at levels of concern.
- If the calculated instream concentration is greater than 50% of the instream water quality criteria, then additional monitoring
may be required or a permit limit for that constinuent may be included in the permit.
Page 2 10/31/2019

FACT SHEET
Appendix C
Adel Water Pollution Control Plant
NPDES Permit No. GA0024911
WET Test PMSD Values:
PMSD = Minimum Significant Data (MSD) / Control Mean x 100 %
WET Test #1
2014
Species
PMSD Bounds
MSD
Control Mean
PMSD
Water Flea (C. dubia)
_
_ 13-47
--
--
24.80
Fathead Minnow t P. promelas)
12-30
--
--
13.80
WET Test #2
2015
1Water Flea (C. dubia)
Species
Fathead Minnow (P. promelas)
WET Test #3
PMSD Bounds
13-47
12-30
MSD ' Control Mean PMSD
23.4
2016
21.4
Species
PMSD Bounds
MSD Control Mean
PMSD
Water Flea (C. dubia w
13-47
-- --
14.9
Fathead Minnow { P. promelas
12-30
_
-- --
21.2
WET Test #4
2017
Species _
PMSD Bounds
MSD
Control Mean
PMSD
Water Flea (C. dubia)
13-47
--
--
13.1
Fathead Minnow iP. promelas;
12-30
--
--
16.5
WET Test #5
2018
Species
PMSD Bounds
MSD
Control Mean
PMSD
Water Flea t C. dubia
13-47
Fathead Minnow i f'. rn 'melas�
12-30
19.0
MMi
11.2
WET Test #6
2019
Species
PMSD Bounds
MSD
Control Mean
PMSD
Water Flea (C. dubia)
13-47
5.13
27.10
18.9
Fathead Minnow (P. prnmelas;
12-30
0.07
0.28
26.2
Within
Within
Within
Within
Within
Within
Within
Within
Within
Within
Within
Within
11/1/2019

FACT SHEET
Appendix D
Adel Water Pollution Control Plant
NPDES Permit No. GA0024911
Ammonia Toxicity Calculation

Ammonia Toxicity Analysis
for
Waste Load Allocation Development (Updated 2013)
Data: 10/19/2017
Facility: City of Adel
NPDES Permit Number. GA0024911
Receiving Stream: Bear Creek to Withlacoochee River
Engineer. !umy Sun
Comments: HCR + LAS Permit
Stream and Facility Data:
Background Stream pH (standard units): 8.8 WQ Data
Effluent pH (standard units): 9.0
Final Stream pH (standard units): 8.87
Stream Temperature (Celsius): 24.0 Not Critical Condkion
7010 Streamfiow (cfs): 0.15 June -Nov
Stream background concentration (Total NH3-N, mg/L): 0.07 WQ Da
Facility Discharge (MGD/cfs): 0.016 0.025 1/8 Stream Flow
Total Combined Flow (cfs): 0.17
Effluent oorrcentra ton (Total NH3-N, mg/L) - 10.34
If 1Q34 Is greater than 17.4 mg/L, use 17.4 mg/L in WLA modeling.
Chronic Critallon based on Village Inc (Rainbow mussel):
Instream CCC - criterion continuous concentration (chronic criterion):
CCC = 0.8876 x (0.02781(1 + 10R'°8°' P}4) + 1.19941(1 + 1004"7!lOa)) x (2.128 x 100 °*0" (2Pil1lY%CT ))
Allowable instream concentration CCC (Total NH3-N, moll) • 1.53
Acute Criterion when Oncorhynchus sairnonid spades ere present:
Instream Criterion Maximum Concentration (CMC) = same as acute criterion:
Instream CMC • Min((0.2751(1 + 10r7 )) + (39.0 / (1 + low "7m'4)),0.7249 x (0.0114/(1 + 100' 'P/4) + 1,61811(1 + 100"-7 1)) x
(23.12 x 10j0`01°"c2'"))))
Allowable Instream concentration CMC, (Total NH3-N mg/1) • 13.38
Acute Criterion when Oncorhynchus salmonld species are absent:
instrsam CMC • 0.7249 x (0.01141(1 + 101 aK - I") + 1.81811(1 + 100"' 7 ))) x MIN(51.93, 23.12 x 1010'0381`Pl)
Allowable Instream concentration CMC, (Total NH3-N mg/I) = 13.38
Based an National Criterion For Ammonia In Fresh Water As Revised In Year 2013
Source: Aquatic Life Ambient Water Quality Criteria for Ammonia - Freshwater 2013, U.S. Environmental Protection Agency, Office of Water,
Office of Science and Technology, EPA-822-R-13-001. April 2013. Washington. D.C.
Georgia Department of Natural Resources, Environmental Protection Division, Atlanta, Georgia

Ammonia Toxicity Analysis
for
Waste Load Allocation Development (Updated 2013)
Date: 10/1912017
Facility: City of Adel
NPDES Permit Number. GA0024911
Receiving Stream: Bear Creek to Wlthla000chee River
Engineer: Lucy Sun
Comments: HCR + LAS Permit
Stream and Facility Data:
Background Stream pH (standard units): 6,8
Effluent pH (standard units): 9.0
Final Stream pH (standard units): 6.92
Stream Temperature (Celsius): 16.0
7010 Streernflow (ds): 0.15
Stream background concentration (Total NH3-N, mg/L): 0.07
Facility Discharge (MGDIcfs): 0.032 0.050
Tote! Combined Flow (cis): 0.20
Effluent concentration (Total NH3-N. mg/L) = 9.90
WO Data
Dec -May
WQ Data
1/3 Strum Flow
If 9.90 la greater than 17.4 mg/L, use 17.4 mg/L In WLA modeling.
Chronic Criterion based on Vllloaa iris (Rainbow mussel):
Instream CCC - criterion continuous concentration (chronic criterion):
CCC = 0.8876 x (0.0278 / (1 + 10r''°e0"PM) + 1.1994 ! (1 + 10e"' "1")) x (2.126 x 10"a1" ")
Allowable instream concentration CCC (Total NH3-N, mgll) • 2.51
Acute Criterion when Oncorhynchus salmonid species are present
instream Criterion Maximum Concentration (CMC) ■ same as acute criterion:
Inetream CMC = Min((0.276 / (1 + 106 "ore)) + (39.0 ! (1 + 10e"' 7'")),0.7249 x (0.01141(1 + 1092m -P"r) + 1.6181 ! (1 + 100"2")) x
(23.12 x 10r0' 62"11))
Allowable instream concentration CMC, (Total NH3-N mgri) ■ 24.89
Acute Criterion when Oncorhynchua selmonld species ere absent:
Instream CMC = 0.7249 x (0.0114/(1 + 10r'x6'"P") + 1.6181 l (1 + 10iP"-"ND x MIN(61.93, 23.12 x 101002°"cm:'1)
Allowable Instream concentration CMC, (Total NH3-N mg/I) ■ 24.89
Based on National Criterion For Ammonia In Fresh Water As Revised In Year 2013
Source: Aquatic Life Ambient Water Quality Criteria for Ammonia - Freshwater 2013, U.S. Environmental Protection Agency, Office of Water,
Office of Silence and Technology, EPA-822-R-13-001, April 2013. Washington, D.C.
Georgia Department of Natural Resources, Environmental Protection Division, Atlanta, Georgia

Attachment 2
A
Alcoa
MEMORANDUM
Alcoa Corporation
201 Isabella Street
Suite 500
Pittsburgh, PA 15212-5858 USA
Tel: [phone]
To: Piper Peterson, USEPA Region 10, SuperfundProject Manager
From: Ghosh, Rajat, PH.D., PE, Alcoa Corp
Re: Fluoride Removal from Industrial Wastewaters — A Technology Review
Date: April 7, 2020
Introduction
Fluorides are found in wastewater discharges from a number of industries: glass manufacturers,
electroplating operations, steel and aluminum, pesticides and fertilizer, groundwater and the
semiconductor industry. Fluoride effluent concentrations can vary over a wide range, and
restrictions on final effluent level depend on place of discharge. For aluminum smelting, fluoride
is present in a variety of wastes generated during the electrolytic process:
Potliner
- Pot bath material
Used anode (bath often stuck to anode)
- Dusts in the potrooms (rafters, floor, underpot, etc.).
Wastes from air emission control, including wet scrubbing sludge, bag house dusts, etc.
The majority of the fluoride present in these materials is in the form of sodium fluoride, which is
a very soluble fluoride species. As such, whenever these wastes get wet or materials contaminated
with these wastes get wet, fluoride impacted waters result. Such waters may also contain elevated
concentrations of sodium, carbonate/bi-carbonate alkalinity, sulfate, ammonia, cyanide, TOC, and
exhibit low ORP. More dilute fluoride wastewaters occur when leachate impacts stormwater runoff
or groundwater.
Alcoa has conducted various fluoride waste water treatment studies, including treatment with lime
(Dzombak et al., 1996), various adsorbents including activated alumina (Alcoa Mt. Holly
operations; Alcoa Portovesme operations ATC Rpt RDE 09-109, Alcoa Technical Center Rpt.
RDE 06-005) as well as electro-coagulation (Mead Custodial Trust Report, 2017), all with mixed
success. This white paper summarizes the results from these various treatment studies and
highlights the inherent challenges associated with sustainable treatment of fluoride in waste waters
to low ppm levels on a continuous or interim basis.

Page 2
Technology Background
Treatment of wastewaters for fluoride removal has been actively studied over the past several
decades as wastewater discharge limits have become increasingly more stringent. Cost effective
treatment options vary with the concentration of fluoride, its speciation and the characteristics of
the wastewater. The most common treatment methods fall into the following categories:
• Electrodialysis (and reverse electrodialysis);
• Reverse osmosis;
• Absorption;
• Adsorption;
• Calcium -based precipitation;
• Combined sequestration and separation/precipitation;
• Evaporation/crystallization; and
• Electro-coagulation
Of these treatment technologies, only four types of technologies are practical for treating dilute
industrial wastewaters with fluoride levels less than 50 mg/1 from physical footprint as well as cost
effectiveness standpoint. These technologies are:
• Calcium based precipitation (lime or calcium chloride with pH adjustments)
• Adsorption (primarily activated alumina as the adsorbent)
• Electro-coagulation
• Reverse osmosis
The other technologies, like evaporation/crystallization as well as electrodialysis are suitable for
low flow (volume) highly concentrated wastes such as, scrubber blowdown where fluoride levels
are expected to be greater than 100-150 mg/l.
The rest of the white paper focusses on discussing the relative advantages and disadvantages as
well as overall technical practicability of the four technologies highlighted above for treating
fluoride in industrial discharges with concentrations between 5-50 mg/1 and flow rates in the 10-
200 gpm range, that are typically seen at non -operating leachate impacted groundwater as well as
surface water sites.
Chemical Precipitation Technology
Calcium -based precipitation approaches have been studied extensively by many including Alcoa
in laboratory, pilot and full scale (Dzombak et al. (1996)). These programs have primarily
involved addition of calcium chloride or calcium hydroxide. The general chemistry associated
with calcium -based precipitation is pretty straight forward, where an abundant source of calcium,
either in the form of calcium chloride or in the form of slaked lime reacts with dissolved fluoride

Page 3
ions to promote chemical precipitation of calcium fluoride which is stable in the neutral to high
pH range according to the following reactions:
CaC12 + 2F- = CaF2 + 2C1-
Ca(OH)2 + 2F- + = CaF2 +H2O +0.502
(1)
(2)
Although both sources of calcium can be used, lime is most easily handled as an emulsified slurry.
Most typically lime is supplied as a dry and somewhat corrosive powder that is difficult to handle.
Figure 1 shows the results of pilot -scale chemical precipitation of fluoride containing stormwater
from one of Alcoa's operations in Massena, NY. The treatment system was implemented to treat
variable stormwater flows impacted with dissolved fluoride in the 20 — 100 mg/1 range at one of
the facility's outfalls. Given the use of calcium chloride, a pH stabilizer (an alkali) was used to
stabilize the calcium fluoride precipitate. Even with significant excess stoichiometric addition of
calcium, lowest treated effluent fluoride concentration was limited to 5 mg/1 at a high pH between
9.5 and 10.
m
75
70
55
80
5$
50
45
5
0.0 5.5
Calcium Chloride Precipitation of Dissohed Fluoride
Mas-E CB49 Stamm Water. Dissolved F = -60 mg0_, by SE; Initial 50, -60 mp5
Ca:(2F) ratio = 3, with varying pH & SO, concentraion s
Dissolved F concenraiion of Crr99
wlhout pH adjustment -5 rrg:
70
75
5.0
pH, Dnils
8.5
5..0
9.6
10.0
HOre:
mndul pn= 0.2
Vpdaled: 1572555
Figure 1. Massena East CB-49 Stormwater Fluoride Precipitation using Calcium Chloride and
Caustic.
Another wet precipitation approach that Alcoa's Brazilian operations (Modified Pocos process)
have implemented in full scale is fluoride removal via calcium fluorapatite formation, which
exhibits lower solubility than calcium fluoride. The chemical reaction entailed in here is as follows:

Page 4
15Ca(OH)2+ 10H3PO4+ 3F- = 3Cas(PO4)3F(s) + 27H2O + P01- + 3H+ + 30H-
(3)
Figure 2 presents the result of the modified POCOS process as applied to a fluoride containing
stormwater from a former smelting operations. Different stoichiometric amounts of lime were
added to optimize treatment effectiveness (Tests A, B and C). Test C with the highest
stoichiometric dose of lime was able to bring the final treated fluoride concentrations to below 6
ppm. However, test C also generated the highest sludge concentration at 1635 mg/1 TSS compared
to the other tests.
Similar to the POCOS process, the Brazilian operations have also looked at straight treatment of
fluoride using lime (Equation 2) with aluminum sulfate as the coagulant to help the reaction to
enhance the sludge formation. Figure 3 shows the results of full-scale treatment using the lime -
aluminum sulfate combination which was able to treat influent fluoride levels from —45 mg/1 to <
10 mg/1 legal limit However, the lime efficiency in treating the fluoride was only 6% from
stoichiometric standpoint resulting in addition of excess lime and hence significant sludge
production. Figure 3 also shows the aerial view of the treatment ponds indicating the sludge
production.
Implementation of Chemical Precipitation: Alcoa's experience with chemical precipitation of
fluoride is mixed. Problems have ranged from precipitation of large quantities of gypsum where
sulfate is present; to unacceptably high levels of fluoride in the treated wastewater; and, frequently,
concomitant scaling of the equipment with solids, such as calcium carbonates.
Fluoride as a function of regenerant dose
30
25
t test A
—0— test B
t test C
20
E 15
10
5
—
0
0 0.5
1
hours
1.5 2 25
Figure 2. Fluoride treatment data using Modified Pocos Process.

Page 5
—F Conc Inlet —Legal Linut +F Conc Outlet
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Figure 3. Full scale Fluoride treatment smelter stormwater fluoride at Alcoa's Brazilian operation.
Typically, pH adjustment with acids and/or caustic is needed on inflow and effluent. The hydroxide
demand of the fluoride reduction system is met long before the calcium demand is met which
means the pH ends up much higher than allowed for discharge and post pH adjustment is required
when lime is used as the primary source of calcium for precipitation. Such is not the case for
calcium chloride as the calcium source, which is purchased as a liquid and is far easier to handle and
deliver. However sometime, additional alkali is added to optimize fluoride removal.
The treatment plant requires chemical storage, chemical mixing and reaction tanks, large settling
pond, press for the settled solids, and means to dispose of the filter cake. The process is energy
and thus carbon intensive in that large amounts of chemicals are used and large amounts of sludge
must be managed. Treatment plants typically require daily, if not fulltime attendance.
Adsorption Technology
The four most common adsorbents for dissolved fluoride for influent levels < 50 ppm are activated
alumina, bonechar, hydroxyapatite and tricalcium phosphate, respectively, in the order from most
efficient to less efficient.
Open source literature is flooded with studies involving treatment of fluoride from wastewater and
drinking water using some form of activated alumina sorbent (Ghorai and Pant (2004, 2005); Ku
and Chiou (2002); Tang et al., (2009)). In majority of these studies, sorption data have been
correlated with Langmuir and Freundlich isotherms and pH has been shown as a critical master
variable on fluoride removal. Alcoa has performed a series of studies to further optimize
commercially available activated alumina to meet low effluent fluoride levels from its smelter
stormwater streams. Pre -conditioning of activated alumina was performed by acid treating the
media with a combination of caustic, DI water and sulfuric acid to create more positively charged
sites to improve the sorption capacity. Figure 4 presents the results of the long-term pilot tests
performed at a smelter location (Ghosh et al., (2009)). Figure 5 shows the cumulative adsorption

Page 6
loading capacity over the course of these tests. During the course of this pilot operation, the media
was recycled 3 times with no significant loss in the capacity.
35 00
ESCT= 30 m in; Hydraulic Loadig = 1.5 gpmff-P; Media Installed: 13.36 kg of Activate d Alumina CAN 2848
krFuene Flucride rmiLj —# EFRurnt Fluoride (rogLj — Fluoride Compliarxr Linit (pprtQ
—.1-4d9uentpll(S1U1 EHluentpHj5U}
0 1000 2000 3000 4000 5000 6000
Liters
7-aa
SAC
MOO
t 25.00
E
•
z
c 20r00 te
Y 15.00
e
� 10.00
590
0.00
d4D2.E:
L AA media
Z I ntluentstomnwater
3- AAcnlu
4. AU d issoked
-
5..6u
4A0
3A0
Fluoride Compliance kink = 6 raga
\jl
300, 6.46
321,735
2AR
L00
DM
0 50 160 150 200
Bed Volumes (EBY= 03d056 L]
regenerate dforfrststepof 60 rninuteswith1j6 Naoki
250
306
350
adjusted to target pH of" 5-0 using sulfuric arid
ran pilot flow rate 1.13 L./min
Fluoride measured by ISE Clan specific Electrcde I
Figure 4. Results of modified activated alumina adsorption for treatment of smelter stormwater
containing dissolved fluoride in the 15-30 mg/l.
As shown in Figure 4, even with modified activated alumina surface, treated effluent levels below
2 ppm cannot be achieved. Also, as shown in Figure 5, to achieve concentrations below 2 ppm, the
loading on the activated alumina media will be in the 1 mg/gm which is impractical from the
physical footprint and media change out frequency perspective. Even to achieve 6 mg/1 treated
effluent, the loading on the activated alumina was only 6 mg/gm or 0.6%; which outlines the need
to frequently change the media for disposal following few cycles of regeneration.
Alcoa also performed bench scale studies to evaluate the feasibility of treating smelter
stormwater and landfill leachates containing dissolved fluoride using various other adsorbents,
namely, hydroxyapatite, tri-calcium phosphate and bone -char, respectively (Ghosh et al.,
(2006)). Of all mineral phases, fluorapatite is the most stable form of fluoridic mineral under the
environmental conditions found in shallow surface aquifers (Ksp = lx 1060) (Rao, 2003).
Equation 4 shows the reaction between the fluoride ion and hydroxyapatite:
Ca5(PO4)3OH (s) + F = Ca5(PO4)3F (s) + OH
(4)

Page 7
■F
q8
•
Ian
ELD
6i8
an
on
•Cyde1 m6 F/6A
■Cyde2m6Ff.A4 ACyde3m5FLOA
•
322, 7.73
■
i ■ 321, 697i ♦
•+
•
7aq,9JEi
7
, 6.14.
■
•
♦
i III
••
■
a
i■
*
.
•
0
100 7n0 3E0 000
6edYdunes pEEIY =13.0581
Figure 5. Fluoride adsorption capacity onto modified activated alumina over three cycles of
regeneration.
Fluorapatite is stable over a wide pH range (2.5<pH<13) and is widely used for the production of
phosphorus fertilizers. Hydroxyapatite has been used heavily for in situ as well as surface
treatment of heavy metals, like, Pb, U at many DOD sites (Ma et al., 1993, 1994), and is a
common constituent in animal and fish bones.
One way of introducing calcium phosphates in the treatment mix was to use a combination of
calcium chloride and phosphoric acid, while another option was to use crystals of hydroxyapatite
(calcined fish bone powder) or simply rock phosphate mixed with some form of calcium salt.
The final objective of either treatment mix is to form a stable fluoride precipitant with low
enough dissolved fluoride concentration (< 4 ppm) in the aqueous phase, theoretical minimal
sludge generation and benign by-products (e.g. sulfates, chlorides, minimal phosphates).
Figures 6, 7 and 8 presents the results of the bench scale treatability study with hydroxyapatite
(HAP), tri-calcium phosphate (TCP) and bone char, respectively. All of these media were in the
form of powder and were tested in bench scale jars where different amounts of sorbent were
used for a fixed volume of fluoride containing groundwater. As shown in Figure 6, significantly
high dose of HAP is required to lower the fluoride levels in the contaminated groundwater to
below the MCL of 4 ppm. In fact, to achieve a consistent fluoride concentration of less than 4
ppm, a HAP loading of 122 g per liter of solution and a contact period of 24 hours are required,
which translates to a fluoride loading of only 0.5 mg/g HAP. Given this performance, HAP as a
sorbent is not recommended as a solution for F treatment of leachate impacted groundwater.

Page 8
F 'inr1111! C nnrrri1 rinp, l
r4
60
54
.10
30
20
10
a
+ 116.P Loading = 16 01<
-0 HAP I oaging = 1,3 g11.
H kP Loa:Lng = 100 gfL
-��
—
s
-- —_.
MCI - 4 ppm
._.
. , . ,
4 i 8 10 12 14
pine, 6ociis
Figure 6. Fluoride removal from leachate impacted smelter groundwater with different amount of
hydroxyapatite (HAP) (Influent F concentration = 61 mg/1)
74
18
Ix
As shown in Figure 7, significantly high dose of TCP is also required to lower the fluoride levels
in the leachate impacted smelter groundwater to below the MCL of 4 ppm. In fact, to achieve a
consistent fluoride concentration of less than 4 ppm, a TCP loading of 140 g per liter of solution
and a contact period of 24 hours are required, which translates to a fluoride loading of only 0.4
mg/g HAP. Given this performance, TCP as a sorbent is not recommended as a solution for F
treatment of groundwater.
BrimacTM bone -char (20x 60 mesh) was used to remove fluoride from leachate impacted smelter
groundwater at different loading. As shown in Figure 8, bone -char performed better than the HAP
and TCP as far fluoride removal is concerned. To achieve a consistent fluoride concentration of
less than 4 ppm, a bone -char loading of 74 g per liter of solution and a contact period of 24 hours
are required, which translates to a fluoride loading of only 0.8 mg/g bone -char. Still, this is
considered a low enough loading rate as far as an adsorbent capacity is concerned when compared
to activated alumina and is not deemed as a suitable sorbent for removing fluoride.

Page 9
70
60
J SO
E
i 40
Lt 30
0= • 20
10
0
- o- TCP Lowing - 1.63 gfL
- TCP Loading - 16.3 gTL
TCP Loading - 163 g/L
2 4 6 6 10 12 14
ume, hours
16
18
20
27
21
Figure 7. Fluoride removal from leachate impacted smelter groundwater with different amount of
tri-calcium phosphate (TCP) (Influent F concentration = 61 mg/1)
n-
u 30
O
� 20
10
—Banechar Loading = 191.
6 nechar Loading = 10 g4
Banechar Loading = 100 g!L
0 2 1 6 8 10 12 14 16 1B 20 22 24
inr4 haws
Figure 8. Fluoride removal from leachate impacted smelter groundwater with different amount of
bonechar (Influent F concentration = 61 mg/1)
Implementation of Chemical Adsorption: Due to the poor adsorption efficiencies (mass fluoride
adsorbed per mass of sorbent); adsorption is not a cost-effective option for moderate to large mass
loading of fluoride. It is best applicable for low flows at low concentrations (i.e., concentrations
< 10 mg/1). This is in contrast with adsorbent technologies for other contaminants, such as PAHs
and organics, where activated carbon as the sorbent media can function with high loading
capacities at low empty bed contact time of —20 minutes, resulting in longer operating times and
smaller physical footprint. Moreover, such carbon media can be regenerable over multiple cycles

Page 10
thereby increasing the operating times of these sorption columns. In contrast, for fluoride
adsorption, media like activated alumina has lower adsorption rates and loses its efficiency rapidly
over few cycles of regeneration resulting in the need for frequent media replacements. As such the
process is energy and thus carbon intensive in that large amount of chemical media (activated
alumina) are used and large amounts of used media must be managed via landfilling. On the other
hand, adsorption involves simple treatment train and requires infrequent attendance as compared
with chemical precipitation.
Electro-Coagulation Technology
In the electro-coagulation (EC) process, electric current is passed through a set of electrodes
immersed in a fixed volume of electrolyte solution, CaC12, where pH adjusted fluoride containing
water is introduced. Calcium ions produced as a result of electrolysis at one of the electrodes reacts
in a stoichiometric manner with dissolved fluoride to form flocs of calcium fluoride precipitate. A
polymer solution is added to improve the floc formation and settling process. Figure 9 shows the
schematic of an electro-coagulation reactor including an influent pre-treatment chamber for pH
adjustment of the influent and post treatment chamber for improved flocculation and settling using
a polymer. This figure and associated data presented below are from a technical report prepared by
Arconic Technology (Arconic, 2017).
Table 1 shows the performance of the EC process during pilot testing of smelter groundwater
impacted with fluoride at a former smelting site in the State of Washington. As shown in Table
1, the EC removal efficiency ranges from 51% to 92% for the well water with fluoride levels
between 5 and 45 ppm. The practical treatment limit of the technology is about 2 ppm. Sludge
generated during EC treatment at the rate of 3.152 lbs. (91.4% moisture) per 40 gallons of
wastewater, or 0.0788 lbs/gal, which is —25-30% lower than traditional chemical precipitation
process using CaC12.
Table 1. EC Performance of Smelter groundwater Treatment
Test ID
Influent F,
ppm
Effluent F,
ppm
Removal
%
Well TW-1B
5.1
2.5
50.98%
Well KMCP-
4B
12.7
3.2
74.80%
Well KM-5
38
2.9
92.37%
Implementation of electro-coagulation: One inherent advantage of this technology over
traditional chemical precipitation process is lower sludge production. On the other hand, it's an
energy intensive process and there is still a significant volume of sludge to press and dispose of.

Page 11
Figure 9. Schematic of the Electro-Coagulation Reactor
Reverse Osmosis (RO) Technology
Both low and high pressure RO membranes are available to remove influent fluoride levels in the
10-20 mg/1 range to close to 0.2 mg/1 in the treated effluent. However, the throughput at flows over
25 gpm requires large membrane footprint and becomes cost prohibitive. Also, RO membranes are
not suitable for treating higher concentrations of fluoride in the 50 mg/1 and higher range as the
rejection efficiency decreases resulting in generation of higher amounts of concentrated reject that
needs treatment. Also, in almost all the cases, the treated stream becomes acidic and needs pH
adjustment prior to discharge. Overall, although RO system is suitable for treating low
concentration of fluoride for drinking water supply, however, it becomes technologically
inefficient and cost prohibitive for sustaining treatment of industrial discharges containing fluoride
in excess of 30-40 mg/1 range and flows above 10-20 gpm. (Shen and Schafer (2015)).
Implementation of RO: While RO can treat moderate flows at low concentrations (typically, less
than 30 ppm), the concentrated reject has to be dealt with. Without an affordable means to dispose
of the reject (for example, discharge to POTW), it serves no purpose other than a concentration
step for a second phase of treatment to actually remove the fluoride from the liquid phase in the
first place.
Summary of Technology Performance
Table 2 shows the performance of the various relevant technologies for removal of fluoride from
stormwaters, surface water as well as groundwater impacted by current and former smelting
operations. As shown in Table 2, every technology listed can work in removing fluoride to low -
medium effluent levels, but has its own inherent limitations in terms of costs for labor,
maintenance, energy intensity, and disposal of unwanted. In other words, there is no optimum
technology available for removal of fluoride from large and dilute flows to low levels of 1-2 ppm,
a situation typically encountered at many active and former aluminum production sites.

Page 12
Table 2. Technology Screening Matrix for Treatment of Smelter Fluoride Wastewater and
Groundwater
Technology Class
Technology Type
Ideal Influent F
conc. range, mg/I
Treated F conc.
Range, mg/I
Comments
Chemical Precipitation
Calcium Chloride
10-100
>4
Moderate Sludge Generation,
Additional alkali added to optimize F
removal
Lime
10-100
>3
Significant Sludge Generation,
Equipment scaling, pH adjustment prior
to final discharge
Calcium Phosphate
10-50
>5
High sludge generation
Chemical Adsorption
Activated Alumina
5-50
2-6
pre -conditioning of AA is needed;
limited sorption capacity (-1 mg/g at 2
ppm, 6 mg/g at 6 ppm); frequent change
out of media
Bane Char
5-60
4-20
Limited adosption capacity (<1 mg/g);
not feasible for sustaining full-scale
treatment
Hydroxy-apatite
5-60
4-20
Low adsorption capacity (-0.4 mg/g);
not feasible for sustaining full-scale
treatment
Tri-calcium Phosphate
5-60
4-20
Low adsorption capacity ("0.5 mg/g);
not feasible for sustaining full-scale
treatment
Electro-coagulation
Calcium Chloride
5-50
—2.5
Lowest sludge generation; not efficient
for F levels less than 15-20 ppm
Reverse Osmosis
Membrane Filtration
5-20
<1
Expensive; need to manage
concentrated reject; not sustainable for
managing industrial flows > 20gpm and
concentrations> 30 mg/I
While chemical precipitation technologies are more robust to treat large flows at 10-100 ppm
range, there is a significant energy and secondary waste footprint in addition to the labor-intensive
operation. Sorption technologies on the other hand can generate lesser residuals but they work for
low to medium flow rates and moderate fluoride levels (5-50 ppm) with low loading capacities.
This means that the media might require frequent replacements. Electro-coagulation generates
lower sludge compared to chemical precipitation, but it does involve a high energy penalty, hence
increased carbon footprint for the same amount of treatment and is only effective over a narrow
influent concentration range (namely, 20-50 ppm). Finally, the reverse osmosis or nanofiltration
processes, although very effective in treating effluents to less than 1 ppm, works only for drinking
water and other dilute concentration with flows in the 1-20 gpm range. Concentrations in excess
of 20 ppm will increase the amount of reject to maintain the same treatment efficiency in these
membranes thereby requiring a secondary treatment process for the reject or disposal of highly
concentrated brine either via incineration or landfilling.

Page 13
References
Arconic Technology (2017) Final Report for Ex -Situ Treatability Study 2016 Activities for
Kaiser Mead NPL Site, Prepared for Mead Custodial Trust, Olympia, WA.
Dzombak, D.A., Dobbs, C.L., Culleiton, C.J., Smith, J.R. and Krause, D. (1996), "Removal of
Cyanide from Spent Potlining Leachate by Iron Cyanide Precipitation." Proceedings of
WEFTEC96, Vol. 3, Part I. Remediation of Soil and Groundwater, Water Environment
Federation, Alexandria, VA, 107-116.
Ghorai, S and Pant, K. (2004) Investigations on the column performance of fluoride adsorption
by activated alumina in a fixed -bed, Chemical Engineering Journal, 98, pp. 165-173.
Ghorai, S and Pant, K. (2005) Equilibrium, kinetics and breakthrough studies for adsorption of
fluoride on activated alumina, Separation and Purification Technology, 42 (3), pp. 265-271.
Ghosh, R. et al. (2006) Final Report for Bench Testing Evaluation of Various Treatment
Mechanisms for Fluoride Removal from Wastewater, Alcoa Internal Report RDE 06-005
cs0036P.
Ghosh, R. et al. (2009) Portovesme Defluoridation Pilot Project Report, Alcoa Internal Report
RDE 09-109 cs1829P.
Ku, Y and Chiou, H. (2002) The Adsorption of Fluoride Ion from Aqueous Solution by Activated
Alumina,
Ma, Q.Y., Traina, S.J., Logan, T.J., and Ryan, J.A. (1993) "In Situ Lead Immobilization by
Apatite." Environ. Sci. Technol., 27:9, 1803-1810.
Ma, Q.Y., Traina, S.J., Logan, T.J., and Ryan, J.A. (1994) "Effects of Aqueous Al, Cd, Cu,
Fe(II), Ni, and Zn on Pb Immobilization by Apatite." Environ. Sci. Technol., 28:7, 1219-1228.
Rao, N.S. and Devadas, D. (2003) Fluoride incidence in groundwater in an area of Peninsular
India
Shen, J. and Schafer, A. (2015) Factors affecting fluoride and natural organic matter (NOM)
removal from natural waters in Tanzania by nanofiltration/reverse osmosis, Science of the
Total Environment, 527-528, pp. 520-529.
Tang, Y., Guan, X., Su, T., Gao, N and Wang, J. (2009) Fluoride adsorption onto activated
alumina: Modeling the effects of pH and some competing ions, Colloids and Surfaces A:
Physicochemical and Engineering Aspects, 337, pp. 33-38.