NCS000115_Staff Review_20071228

NCS000115
+OF W A I'F Michael F.Easley,Governor
'90 William G.Ross 3r.,Secretary
(� North Carolina Department of Environment and Natural Resources
Coleen H.Sullins Director
7 Division of Water Quality
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Facility Name: Novozymes
NPDES Permit Number: NCS000115
Facility Location: Franklinton,NC(Franklin County)
Type of Activity: Enzyme producer
Receiving Streams: See Figure 1
River Basin: Tar-Pamlico River Basin,Sub-basin 03-03-01
Stream Classification: C,NSW , Cn
Proposed Permit Requirements: See attached draft permit.
Monitoring Data: See Table 1
Facility Location: See Figure 1
Response Requested by(Date): December 31,2007
Central Office Staff Contact: Kelly Johnson and/or Jennifer Jones 919 733-5083 ext. 376/
Special Issues:
§F,yid'�x} e?,ai�'.m"S`�.�Yseue��?f�aa�-�''"�"'-Ratln i►SCa1C: )1 8a8 -tD;"1lQ aP[1 `
Compliance history 2
Benchmark exceedance 4
Location(TMDL,ME 1
species, etc
Other Challenges: 1
• NIA
DIM; I Rating: 8/40
Special Issues Explanation:
■ Compliance: The facility was compliant over the past permitting cycle.
■ Benchmarks: The facility exceeded BODS regularly at one outfall. COD data trends do not follow BODS
trends as expected. Suspect possible issues with hold times or other sampling issue. TSS was high once at
each location. Nitrogen and phosphorus data are consistently low.
■ Location: There is no TMDL or impairment. There are no T&E species present.
■ Other challenges: This is a fairly easy permit. Aisha Lau reports that they seemed to be diligent about their
stormwater practices during the site visit.
Page 1 of 8

NCS000115
Description of Onsite Activities:
Novozymes'biological solutions are used in the production of thousands of products that you use in your everyday
life-from the clothes you wear to the sweets that you eat. Naturally-occurring enzymes are the basis for all
+ Novozymes' products. Using the evolutionary process nature creates new organisms that are better suited for
survival under new conditions. If our scientists are unable to find an enzyme'to solve a specific problem in nature,
they are able to develop it by imitating evolution. Novozymes manufactures both liquid and solid products.
Li uid forms:
Typically an enzyme product contains 1-5%enzyme protein. The enzyme is dissolved in water and stabilizers such
as glycerol, salt and sugar. A more advanced form is the proprietary encapsulated enzyme product that Novozymes
has recently developed, which offers improved stability and a delayed-release feature.
Solid forms:
Solid enzyme products are typically free-flowing powders consisting of particles with a diameter between 0.1 and 1
mm and mith an enzyme content in the range of 1-5%enzyme protein. Novozymes produces several kinds of
granulated and immobilized products. The most important is the T-granulate,which is a low-dusting,reinforced core
particle coated with a waxy material. The T-granulate is predominantly used in powder detergents. Other types
include the BG-granulate, used in enzymes for baking,and the immobilized product Sweetzymer, used in the
conversion of glucose to fructose.
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• Stormwater Permit File
• Tar-Pamlico River Basinwide Plan
• Draft 2006 303(d)List
• EPA Sector-Specific Permit, 2006 draft
• Natural Heritage Program's Federal Threatened and Endangered Species Database
• 40 CFR Subchapter N, Stormwater Effluent Guidelines
History:
• 31 August 1994:'Permit first issued
• 01 October 1999: Permit re-issued
• 31 October 2000: Permit modified (new facility name)
• 3 March 2004: Permittec notified that the permit would expire on 30 September 2004.
• 01 April 2004: Permittee submitted renewal application.
• Undated Fax(approximately in this timeframe?): DWQ(Darren England)and the facility contact
exchanged an undated fax regarding outfall monitoring. DWQ pointed out a material storage area that may
or may not have been in a drainage area, and specified that the facility either begin monitoring at that outfall
or request representative outfall status for it. Darren England wrote a note on drawing number FAA30806
dated 8/I 1/95 that the area in question was diked and drained to the waste processing facility per his
discussion with the facility contact. This issue was addressed by installing appropriate piping, as was
discussed at the August 2006 site visit.
August 2006: Site visit(This site visit is referenced in the 3 May 2007 letter,though no site visit report is
on file, and no further information is available in BIMS).
• 3 May 2007: DWQ acknowledged receipt of the application.
• 27 November 2007: DWQ contacted the applicant via email (the previous phone number was incorrect) to
obtain additional information about the facility. See phone log. I
Page 2 of 8

CSU00115
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Page 3 of 8

WCS000115
Central Office Review Summary:
1. Owner's Other Permits:
o NCG500115: Non-contact cooling water
o WQ0002806: Surface irrigation
o WQ0003487: Distribution of residual solids
2. General Observations:In general,this site does not raise any red flags. There are some questions about the outfalls
onsite,however. The material storage area issue that is discussed in the"History"section of this staff report appears
to have been addressed appropriately. The site visit report (a letter dated 8/11/06) says that the facility has kept
process water and stormwater conveyances separate and has marked the drainage with a color-coded system. (The
site map containing the stormwater drainage is FAA30806,'and the latest date on file is 8/11/95.
3. Im�nrment: Buffalo Creek(subbasin 03-03-01, index 28-78-1-10)is not listed on the 2006 303(d)list, and
therefore there is also no TMDL. The 2004 Basinwide Plan also does not address Buffalo Creek.
4. Threatened and Endangered: There are no T&E species present in the.receiving stream.
5. Location: Franklinton,NC is in subbasin 03-03-01. This facility is just off of Highway 56 east of Franklinton
and west of Louisburg. BIMS says that this facility is in subbasin 03-03-02, but it appears that it is actually in
subbasin 03-03-01. Note that the previous permits listed the receiving stream as"UT of Buffalo Creek, a c ass
WS-IV NSW stream". However, I believe that the facility was previously incorrectly located. S U�
6. Industrial Changes Since Previous Permit:
o Changes as of submittal: Conversion of several storm drains to process wastewater drains in raw
material unloading areas
o Changes since submittal: No
7. Analytical Monitoring rNot es: In general, Outfall 1 had fewer benchmark excursions than Outfall 2. Outfall 2
had consistently high BOD5 values, and unexpectedly, the COD values were not as high. Typically,COD values
are—4 times as high as BOD5. (Perhaps mention in the final permit cover letter that they should talk to their
analytical laboratory to ensure that they understand the hold times associated with these samples) .It is
unclear as to whether or not this is due to the process at the plant or if it is due to analytical error. The facility
did not collect all of the samples during the required timefi-ame. However, the facility corrected the mistake by
collecting samples at 2-month intervals after they realized the error. Three samples were collected between
March and August 2004. This is'not typically the way DWQ prefers to see the data. However,the two
parameters of concern(BOD5 and COD)would be expected to be higher during warmer months,and so this data
may provide a better perspective of the conditions onsite at the"worst case"scenario. The other parameters, ,
TSS,TKN,TP,and NO3-NO2 would only be marginally affected by temperature. Algae is more prolific during
warm months,which may have decreased the nutrient parameters to some degree,however,the data for these
parameters is sufficiently low such that I do not believe temperature was a significant variable in the data
collected.
8. Qualitative Monitoring Notes: In general, there are no significant issues of concern. There were occasional
floating solids, and there appears to be a housekeeping issue regarding plastic strapping at the facility.
Presumably, this strapping is the wrapping for a raw material that occasionally makes its way to the outfall. This
issue was not addressed in the inspection report from the August 2006 site visit. If there is a future site visit,it is
recommended that we ask about this issue.
9. EPA Sector-Specific Permit_&40 CFR Subchapter N: This facility does not fall easily into any of the EPA
Sectors or any of the categories in Subchapter N. The Sectors that are most closely related are Sector C
(Chemical and Allied Products Manufacturing)and Sector U(Food and Kindred Products). Neither sector
addresses enzymes, however. Therefore,I have reviewed the information for these Sectors, but have not found
any of the monitoring requirements to be applicable. Similarly, no parameters are addressed as a result of the
CFR.
Page 4 of 8

NCS000115
Table 1: Analytical Monitoring* _ `\
Required Sample Total Precipitation Duration BOD COD TKN NO -NO TP TSS
Sampling Date Flow (in) (hours) Benchmark: Benchmark: Benchmark: Benchmark: Benchmark: Benchmark
Range (MGD) 30 mg/L 120 mg/L 20 mg/L 10 mglL 2 mglL
100 m IL
Outfall 1
1011102-
12/31/02
1I1103- "
3131103
411103-
6130/03
7/1/03- 9/4/2003 0.0296 1 2.00 22.0 75.0 0.95 0.80 0.40 11.30
9/30103
N/A 4/12/20 .0222 .75 3.25 6.1 65.0 1.21 0.82 0.50 25.00
N/A 614/20 .0592 2 3.00 9.3 51.1 2.63 1.56 0.50
NIA 8/12/2004.0444 1.5 1.00 16.7 1 57.3 0.90 0.42 0.30 55.70
Outfall 2
10/1/02-
12/31/02
1/1103-
3/31/03
4/1/03-
6/30103
711/03- 914/200 .2873 1 2.00 48.0 1.34 1.33 0.40 24.00
9/30103
NIA 4112120 .2155 .75 3.25 19.0 1.40 1.13 0.37 11.00
NIA 6/4/200 .5746 2 3.00 5.4 25.8 0.97 0.53 0.05 18.60 _
NIA 8/12120 .4309 1.51 1.00 7.23 1.38 1.09
"NmOver Current Benchmark
Data Not Collected
'Note in file that the lack of sampling during the required timef-ame was an oversight,and that they conducted testing at 2-month intervals after they realized the error.
Page 5 of 8

• ' gp00115
for a No Exposure Exclusion from NPDES stormwater discharge permit requirements. Additional information
' is provided in Part I Section A.
V
Discussions with permittee: Randy Green,919.494.3001, 27 November 2007
1. Owner/facility data are still correct? Contact people still correct? (Jack Blackmer and Randy Green were the
contacts during the 8/06 inspection. Steve Stadelman signed the application in 3104 and was also the person to
whom the 5107 application receipt letter was directed.)
a. Owner and facility names are correct. Randy Green is the new contact person.
2. Have there been any facility or process changes in the past few years?
H
a. No
3. Where are the two outfalls? There is a ditch that runs along one side of the property(no directional arrows on the
map,but it is on the side of the facility where the lagoons are,and at the"top"of the map). Are both of the outfalls
on this ditch? Where, specifically?
a. Area#3 drains to the second outfall. The outfall is at the bottom right corner of area#3 at the culvert. The
outfall flow goes along a street side ditch from"F"block to"M"block then under the road to an unnamed
tributary of Buffalo Creek.
Page 7 of 8

NCS000115
Recommendations: Based on the documents reviewed,the application information submitted one sufficient to
issue an Individual Stormwater Permit.
Prepared by(Signature) Date a
Stormwater Permitting Unit Supervisor
Concurrence by Regional Office o Date
r G
Water Quality Supervisor Date
Regional Office Staff Comments
(/ Y[/
/-
CV La.
,
� 5 S
f.
Page 8 of 8

E
February 1, 2008
Notes on Novozymes, Inc. Staff Report (NCS000115):
Stream ID and Class was investigated, and BIMS did not find the Correct section of Buffalo
Creek initially because it was listed as Buffalo Creek (South Side Tar River).
Correct information is:
Stream Class: WS-IV,NSW
Stream ID: 28-22
Stream Name: Buffalo Creek (South Side Tar River).
Sub-Basin: 03-03-01 (Tar-Pamlico River Basin)
Jennifer M.Jones