Loading...
HomeMy WebLinkAboutNC0005258_Fact Sheet_20180201Fact Sheet NPDES Permit No. NCO005258 Permit Writer/Email Contact Ron Berry, ron.berry(a)ncdenr.gov Date: February 1, 2018 Division/Branch: NC Division of Water Resources/NPDES Complex Permitting Fact Sheet Template: Version 09Jan2017 Permitting Action: M Renewal ❑ Renewal with Expansion ❑ New Discharge ❑ Modification (Fact Sheet should be tailored to mod request) Note: A complete application should include the following: • For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee • For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2' species WET tests. • For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based on industry category. Complete applicable sections below. If not applicable, enter NA. 1. Basic Facility Information Facility Information Applicant/Facility Name: SGL Carbon, LLC/SGL Carbon, LLC Applicant Address: 307 Jamestown Road, Morganton, NC 28655 Facility Address: 307 Jamestown Road, Morganton, NC 28655 Permitted Flow: No limit, monitor only (estimate annual average 2.0 MGD last 4 yrs) Facility Type/Waste: Minor industrial/98% once through, non -contact cooling water Facility Class: No biological treatment, class I proposed Treatment Units: None (pending dechlorination system) Pretreatment Program (Y/N) No County: Burke Region Asheville Briefly describe the proposed permitting action and facility background: The SGL, Carbon, LLC facility has applied for a NPDES permit renewal, and submitted a renewal application May 16, 2014. This facility manufactures synthetic graphite products for various industries averaging production in 2011-2013 of an estimated 20 million pounds per year. There have been no significant changes to the processes which Page 1 of 13 include extrusion, baking, graphitization, and support services. Based on US EPA previous continuation SIC 3624 Carbon and Graphite Products sub -category was excluded from Electrical and Electronic Component category because "pollutants would be in trace amounts and in quantities too small to be effectively reduced by treatment". This facility's NPDES discharge is from the conibined flows of once through/ non -contact cooling water _R%4_2 rvqx�ceai emission. Because of the plant wastewater collection system configuration with storm water connection, stonn water is collected and discharged through the same NPDES outfall, and is also covered under its own pen -nit NCS000009. Potable water from the local utility is the source of all facility cooling water that is required. Other facility closed loop cooling systems have blowdowns going to the local WWTP via the facility's sanitary sewer. Currently there is no treatment associated with this discharge. The stormwater flow from production areas is suspected of contributing levels of TSS, Oil & Grease, and copper. The location of the plant immediately adjacent to the WTP has resulted in Total Residual Chlorine (TRC) levels in the incoming potable water between 1 .300 and 1,500 ltg/L Based on the • compliance plan from the Permittee and reviewed by the Division, a February 1, 2018 TRC compliance date will be included in this Permit. During a previous NPDES renewal, a request was approved by the Division to remove pH limits since the primary contributing sources is once through/non-contact cooling water supplied by the adjacent local utility water treatment plant which is not highly buffered and considered not an issue to instream pH. 2. Receiving Waterbody Information: Receiving Waterbody Information Outfalls/Receiving Stream(s): Outfall 001/ Silver Creek Stream Segment: 11-34-(6.5) Stream Classification: WS -IV Drainage Area (mi2): 49.9 Summer 7Q10 (cfs) 20.9 Winter 7Q10 (cfs): - 30Q2 (cfs): 34.2 Average Flow (cfs): 74.8 IWC (% effluent): 13% 303(d) listed/parameter: None Subject to TMDL/parameter: None Subbasin/H-LJC: 03-08-30/03050101 USGS Topo Quad: E13NW Morganton South, NC Page 2 of 13 3. Effluent Data Summary Effluent data is summarized below for the period July 2015 through August 2017. Table. Effluent Data Summary Parameter Units Average Max Min Permit Limit Flow MGD 1.45 52 0.4 None TSS mg/l 5.59 13.5 < 5 MA 30.0 DM 45.0 Oil and Grease mg/1 4.59 9.2 < I MA 10.0 DM 15.0 Temperature °C 19.11 30.6 7.5 AM 29.0 AMI2.8 Total Copper mg/1 3.3 22 < 1 Total Lead mg/1 < 10 (no detects) Total Selenium mg/I < 10 (no detects) Total Silver mg/1 < I (no detects) Total Zinc mg/1 90.5 97 84 pH S.U. 7.27 7.8 6.5 Chronic Toxicity P/F Passed 10 of 10 WET ChV = 13% MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, AM -Ambient Maxiinum, AMI - Ambient Maximum Increase 4. Instream Data Summary Instream monitoring may be required in certain situations, for example: 1) to verify model predictions when model results for instream DO are within 1 mg/1 of instream standard at full permitted flow; 2) to verify model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other instream concerns. Instream monitoring may be conducted by the Permittee, and there are also Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee (in which case instream monitoring is waived in the permit as long as coalition membership is maintained). If applicable, summarize any instream data and what instream monitoring will be proposed far this permit action: The permit requires instream monitoring for temperature and is used in order to confirm compliance with the narrative standard not to increase the ambient stream temperature more than 2.8 °C and in no case cause the ambient stream temperature to exceed 29 °C. Review of instream, data for the past two years indicates that the effluent temperature does impact the stream ambient temperature but did not cause the ambient stream temperature to exceed 29 °C. However, there were 4 occasions when the increase in ambient stream temperature did exceed 2.8 °C. There was some abnormality in the 2017 data. This draft permit maintains the same instream monitoring and narrative standard requirements. Page 3 of 13 Is this facility a member of Monitoring Coalition with waived instream monitoring (YIN).- NO Name of Monitoring Coalition: NA 5. Compliance Summary Summarize the compliance record with permit effluent limits (past 5 years): The facility reported 2 Oil and Grease limit violations in 2013. As result of the violations a fine of $1,387 was assessed by the Division and paid by the Permittee. Summarize the compliance record with aquatic toxicity test limits and any second species test results (past 5 years): The facility passed 17 of 18 quarterly chronic toxicity tests using ceriodaphnia dubia at 13% effluent concentration. The two followed up chromic tests conducted after the failed test indicated the ChV > 52%. Summarize the results from the most recent compliance inspection: The last facility inspection in March 2017 was conducted to sample the TRC concentration in the effluent and to determine its impact to Silver Creek (receiving stream). As anticipated the effluent TRC level was found to be extremely high, 1,180 Rg/L and the downstream TRC was 690 ug/L. The Permittee was advised to provide an action plan to the Division to remediate the effluent TRC concentration to meet WQBEL of 17 pg/L. The report was received and reviewed and included an estimated compliance date by February 2018. The Division has advised the Permittee a new TRC limit will be in this permit with an effective compliance date of February 1, 2018. 6. Water Quality -Based Effluent Limitations (WQBELs) Dilution and Mixing Zones In accordance with 15A NCAC 2B.0206, the following strearnflows are used for dilution considerations for development of WQBELs: I Q 10 streamflow (acute Aquatic Life); 7Q10 streamflow (chronic Aquatic Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH). If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA If applicable, describe any mixing zones established in accordance with 15A NCAC 2B. 0204(b): NA Oxygen -Consuming Waste Limitations Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits (e.g., BOD= 30 mg/l for Municipals) may be appropriate if deemed more stringent based on dilution and model results. If permit limits are more stringent than TBELs, describe how limits were developed: NA Ammonia and Total Residual Chlorine Limitations Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of 1.0 mg/l (summer) and 1.8 mg/l (winter). Acute ammonia limits are derived from chronic criteria, utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals. Page 4 of 13 Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection of aquatic life (17 ug/1) and capped at 28 ug/l (acute impacts). Due to analytical issues, all TRC values reported below 50 ug/l are considered compliant with their permit limit. Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: The TRC WQBEL limit of 28 Rg/L (any value reported as < 50 µg/l_ is considered in compliance) will bei posed in this permit with a TRC compliance effective date of February 1, 2018. Reasonable Potential Analysis (RPA) for Toxicants If applicable, conduct RPA analysis and complete information below. The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero background; 3) use of'h detection limit for "less than" values; and 4) streamflows used for dilution consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of Instream Dissolved Metals Standards, dated June 10, 2016. A reasonable potential analysis was conducted on effluent toxicant data collected between 2007 through 2017 for annually monitored metals and September 2015 through August 2017 for copper. Pollutants of concern included toxicants with positive detections and associated water quality standards/criteria. Based on this analysis, the following permitting actions are proposed for this permit: • Effluent Limit with Monitoring. The following parameters will receive a water quality -based effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable water quality standards/criteria: No action required. • Monitoring Only. The following parameters will receive a monitor -only requirement since they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but the maximum predicted concentration was >50% of the allowable concentration: Copper. Monitoring Only_ The following parameters will receive a monitor -only requirement as they continue to be pollutants of interest. Lead, Selenium • No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria and the maximum predicted concentration was <50% of the allowable concentration: Silver, Zinc. • POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for additional pollutants of concern. a The following parameter(s) will receive a water quality -based effluent limit (WQBEL) with monitoring, since as part of a limited data set, two samples exceeded the allowable discharge concentration: NA o The following parameter(s) will receive a monitor -only requirement, since as part of a limited data set, one sample exceeded the allowable discharge concentration: NA If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals Implementation Fact Sheet for freshwaterlsaltwater to this Fact Sheet. Include a printout of the RPA Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program. Page 5 of 13 Toxicity Testing Limitations Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than domestic waste) will contain appropriate WET limits and monitoring requirements, with several exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test failure. Describe proposed toxicity test requirement: This industrial effluent contains toxic components, a chronic WET limit at 13% effluent concentration will be maintained on a quarterly frequency. Mercury Statewide TMDL Evaluation There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply with EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and industrial facilities with known mercury discharges. Given the small contribution of mercury from point sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will receive an MMP requirement. Industrials are evaluated on a case-by-case basis, depending if mercury is a pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL value of 47 ng/l. Not a source for mercury Other TMDL/Nutrient Management Strategy Considerations If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation within this permit: NA Other WQBEL Considerations If applicable, describe any other parameters of concern evaluated for WQBELs: NA If applicable, describe any special actions (HQW or OR W) this receiving stream and classification shall comply with in order to protect the designated waterbody: NA If applicable, describe any compliance schedules proposed for this permit renewal in accordance with 15A NCAC 2H 0107(c)(2)(B), 40CFR 122.4 7, and EPA May 2007 Memo: An effective date of February 1, 2018 has been approved by the Division for meeting the new TIBC effluent limit. If applicable, describe any water quality standards variances proposed in accordance with NCGS 143- 215.3(e) and 15A NCAC 2B.0226for this permit renewal: NA 7. Technology -Based Effluent Limitations (TBELs) Based excluded from Electrical and Electronic Component category because "pollutants would be in trace amounts and in quantities too small to be effectively reduced by treatment". Page 6 of 13 If any limits are based on best professional judgement (BPJ), describe development: NA Document any TBELs that are more stringent than WQBELs: NA Document any TBELs that are less stringent than previous permit: NA 8. Antidegradation Review (New/Expanding Discharge): The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not degrade water quality. Permitting actions for new or expanding discharges require an antidegradation review in accordance with 15A NCAC 213.0201. Each applicant for a new/expanding NPDES permit must document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105( c)(2). In all cases, existing instream water uses and the level of water quality necessary to protect the existing use is maintained and protected. If applicable, describe the results of the antidegradation review, including the Engineering Alternatives Analysis (EAA) and any water quality modeling results: NA 9. Antibacksliding Review: Sections 402(0)(2) and 303(d)(4) of the CWA and federal regulations at 40 GFR 122.44(1) prohibit backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL limits, or WQBELs may be less stringent based on updated RPA or dilution). Are any effluent limitations less stringent than previous permit (YES/NO): NO If YES, confirm that antibacksliding provisions are not violated: NA 10. Monitoring Requirements Monitoring frequencies for NPDES permitting are established in accordance with the following regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 28.0500; 2) NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance, Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not considered effluent limitations under Section 402(0) of the Clean Water Act, and therefore anti - backsliding prohibitions would not be triggered by reductions in monitoring frequencies. For instream monitoring, refer to Section 4. 11. Electronic Reporting Requirements The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports (DMRs) electronically. Effective December 21, 2020, NPDES regulated facilities will be required to Page 7 of 13 submit additional NPDES reports electronically. This permit contains the requirements for electronic reporting, consistent with Federal requirements. 12.Summary of Proposed Permitting Actions: Table. Current Permit Conditions and Proposed Changes Parameter Current Permit Proposed Change Basis for Condition/Change Flow Monitor Only No change 15A NCAC 213 ,0505 TSS MA 30.0 mg/l No change TBEL.,, Secondary treatment DA 45.0 mg/l standards/40 CFR 133 / 15A NCAC 213 .0406 Temperature AM 29.0 °C ambient No change WQBEL, State WCC standard, 15A Ambient stream increase NCAC 2B.0211((3)0) not to exceed 2.8°C Oil and Grease MA 10.0 mg/l No change BPJ - Pollutant of concern, DM 15.0 mg/l comingled sw run off Total Residual DM 28 pg/L (< 50 pg/L) Add weekly WQBEL, State WCC standard, 15A Chlorine monitoring with NCAC 02B .0211(3)(1)(iv) effective compliance date of February 1, BPJ -compliance date, time to 2018 install treatment pH Monitor Only No change BPJ - Pollutant of interest Total Copper Monitor Only Reduce monitoring to Strategy for RPA - predicted value quarterly is > 50% of WQBEL Total hardness No requirement Add quarterly E ad U Required to calculate hardness monitoring dependent metal WQBEL Total Lead Monitor Annually No change BPJ - Pollutant of interest. Total Selenium Monitor Annually No change BPJ - Pollutant of interest. Total Silver Monitor Annually Remove Strategy for RPA -- predicted non - detect value is < 1 Vg/L (PQL) Total Zinc Monitor Annually Remove Strategy for RPA - predicted non - detect value is < 50% of WQBEL Toxicity Test Chronic limit, 13% No change WQBEL, No toxics in toxic effluent concentration amounts. 15A NCAC 213.0200 and 15A NCAC 213,0500 Electronic No requirement Add Electronic In accordance with EPA Electronic Reporting Reporting Special Reporting Rule 2015. Condition MGD - Million gallons per day, MA - Monthly Average, WA - Weekly Average, DM - Daily Max, AM -Ambient Maximum Page 8 of 13 13. Public Notice Schedule: Permit to Public Notice: 1111118 Per 15A NCAC 2H .0109 & .0 111, The Division will receive comments for a period of 30 days following the publication date of the public notice. Any request for a public hearing shall be submitted to the Director within the 30 days comment period indicating the interest of the party filing such request and the reasons why a hearing is warranted. 14. Fact Sheet Addendum (if applicable): Were there any changes made since the Draft Permit was public noticed (Yes/No): NO If Yes, list changes and their basis below: NA 15. Fact Sheet Attachments (if applicable): • RPA Spreadsheet Summary • Dissolved Metals Implementation/Freshwater or Saltwater • March 16, 2017 Asheville Regional Office inspection report, responses from Permittee to TRC issue Date: February 1, 2018 Name: Page 9 of 13 PDES_I_mplementation of Instream Dissolved Metals Standards - Freshwater Standards The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by the NC Environmental Management Commission (EMC) on November 13, 2014. The US EPA subsequently approved the WQS revisions on April 6, 2016, with some exceptions. Therefore, metal limits in draft permits out to public notice after April 6, 2016 must be calculated to protect the new standards - as approved. Table 1. NC Dissolved Metals Water Quality Standards/Aquatic Life Protection Parameter Acute FW, µg/I (Dissolved) Chronic 1~W, µg/1 (Dissolved) Acute SW, µg/1 ; (Dissolved) Chronic SW, µg/1 (Dissolved) Arsenic 340 150 69 36 Beryllium 65 6.5 --- --- Cadmium Calculation Calculation 40 8.8 Chromium III Calculation Calculation --- --- Chromium VI 16 11 1100 50 Copper Calculation Calculation 4.8 3.1 Lead Calculation Calculation 210 8.1 Nickel Calculation Calculation:'74 8.2 Silver Calculation 0.06 1.9 0.1 Zinc Calculation Calculation 90 81 Table 1 Notes: 1. FW= Freshwater, SW= Saltwater 2. Calculation = Hardness dependent standard 3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life standards for Mercury and selenium are still expressed as Total Recoverable Metals due to bioaccumulative concerns (as are all human health standards for all metals). It is still necessary to evaluate total recoverable aquatic life and human health standards listed in 15A NCAC 213.0200 (e.g., arsenic at 10 µg/l for human health protection; cyanide at 5 µg/L and fluoride at 1.8 mg/L for aquatic life protection). Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A NCAC 02B .0211 Subparagraph (11)(d) Metal NC Dissolved Standard, µg/1 Cadmium, Acute WER* { 1. 136672 -[In hardness](0.041838)} e^{0.9151 [In hardness] -3.1485} Cadmium, Acute Trout waters WER*{1.136672-[In hardness] (0.041838)} e^{0.9151[In hardness] -3.6236} Cadmium, Chronic WER*{1.101672-[In hardness] (0.041838)} e^{0.7998[ln hardness] -4.4451} Chromium III, Acute WER*0.316 e^{0.8190[ln hardness]+3.7256} Chromium III, Chronic WER*0.860 e^{0.8190[ln hardness]+0.6848} Copper, Acute WER*0.960 e^{0.9422[ln hardness] -1.700} Copper, Chronic WER*0.960 e^}0.8545[ln hardness] -1.702} Lead, Acute WER*{1.46203-[In hardness](0.145712)} • ell {1.273[ln hardness] -1.460} Lead, Chronic WER*{1.46203-[ln hardness](0.145712)} • ell {1.273[In hardness] -4.705} Nickel, Acute WER*0.998 • e^{0.8460[ln hardness]+2.255} Page 10 of 13 Silver, Acute WER*0.85'• e^{1.72[ln hardness] -6.59} Silver, Chronic Not applicable Zinc, Acute WER*0.978 - e^{0.8473[ln hardness]+0.884} Zinc, Chronic WER*0.986 • e^{0.8473[ln hardness]+0.884} General Information on the Reasonable Potential Analysis (RPA) The RPA process itself did not change as the result of the new metals standards. However, application of the dissolved and hardness -dependent standards requires additional consideration in order to establish the numeric standard for each metal of concern of each individual discharge. The hardness -based standards require some knowledge of the effluent and instream (upstream) hardness and so must be calculated case-by-case for each discharge. Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR 122.45(c). The discharge -specific standards must be converted to the equivalent total values for use in the RPA calculations. We will generally rely on default translator values developed for each metal (more on that below), but it is also possible to consider case -specific translators developed in accordance with established methodology. RPA Permitting Guidance/WQBELs for Hardness -Dependent Metals - Freshwater The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern, based on recent effluent data, and calculate the allowable effluent concentrations, based on applicable standards and the critical low -flow values for the receiving stream. If the maximum predicted value is greater than the maximum allowed value (chronic or acute), the discharge has reasonable potential to exceed the standard, which warrants a permit limit in most cases. If monitoring for a particular pollutant indicates that the pollutant is not present (i.e. consistently below detection level), then the Division may remove the monitoring requirement in the reissued permit. 1. To perform a RPA on the Freshwater hardness -dependent metals the Permit Writer compiles the following information: • Critical low flow of the receiving stream, 7Q 10 (the spreadsheet automatically calculates the 1 Q 10 using the formula 1 Q 10 = 0.843 (s7Q 10, cfs) 0.993 • Effluent hardness and upstream hardness, site-specific data is preferred • Permitted flow • Receiving stream classification 2. In order to establish the numeric standard for each hardness -dependent metal of concern and for each individual discharge, the Permit Writer must first determine what effluent and instream (upstream) hardness values to use in the equations. The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test results for any hardness data and contacts the Permittee to see if any additional data is available for instream hardness values, upstream of the discharge. If no hardness data is available, the permit writer may choose to do an initial evaluation using a default hardness of 25 mg/L (CaCO3 or (Ca + Mg)). Minimum and maximum limits on the hardness value used for water quality calculations are 25 mg/L and 400 mg/L, respectively. Page 11 of 13 If the use of a default hardness value results in a hardness -dependent metal showing reasonable potential, the permit writer contacts the Permittee and requests 5 site-specific effluent and upstream hardness samples over a period of one week. The RPA is rerun using the new data. The overall hardness value used in the water quality calculations is calculated as follows: Combined Hardness (chronic) _ (Permitted Flow, cfs *Avg. Effluent Hardness, mg/L) x (s7Q10, cfs *Avg. Upstream Hardness, mg/L) (Permitted Flow, cfs + s7Q10, cfs) The Combined Hardness for acute is the same but the calculation uses the 1Q10 flow. 3. The permit writer converts the numeric standard for each metal of concern to a total recoverable metal, using the EPA Default Partition Coefficients (DPCs) or site-specific translators, if any have been developed using federally approved methodology. found in The Metals Translator. Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA $23-B-96-007, June 1996) and the equation: Cdiss — 1 Ctotal 1 + f 1 [KP. ] [SS(I+a)] [10-6] 1 Where: ss = in -stream suspended solids concentration [mg/1], minimum of 10 mg/L used, and Kpo and a = constants that express the equilibrium relationship between dissolved and adsorbed forms of metals. A list of constants used for each hardness -dependent metal can also be found in the RPA program under a sheet labeled DPCs. 4. The numeric standard for each metal of concern is divided by the default partition coefficient (or site-specific translator) to obtain a Total Recoverable Metal at ambient conditions. In some cases, where an EPA default partition coefficient translator does not exist (ie. silver), the dissolved numeric standard for each metal of concern is divided by the EPA conversion factor to obtain a Total Recoverable Metal at ambient conditions. This method presumes that the metal is dissolved to the same extent as it was during EPA's criteria development for metals. For more information on conversion factors see the June, 1996 EPA Translator Guidance Document. 5. The RPA spreadsheet uses a mass balance equation to determine the total allowable concentration (permit limits) for each pollutant using the following equation: Ca = (s7Q10 + Ow) (Cwgs) — (s7O10)(Cb) QW Where: Ca = allowable effluent concentration (µg/L or mg/L) Cwgs = NC Water Quality Standard or federal criteria (µg/L or mg/L) Page 12 of 13 Cb = background concentration: assume zero for all toxicants except NH3* (gg/L or mg/L) Qw = permitted effluent flow (cfs, match s7Q10) s7Q 10 = summer low flow used to protect aquatic life from chronic toxicity and human health through the consumption of water, fish, and shellfish from noncarcinogens (cfs) * Discussions are on-going with EPA on how best to address background concentrations Flows other than s7Q10 may be incorporated as applicable: IQ 10 = used in the equation to protect aquatic life from acute toxicity QA = used in the equation to protect human health through the consumption of water, fish, and shellfish from carcinogens 30Q2 = used in the equation to protect aesthetic quality The permit writer enters the most recent 2-3 years of effluent data for each pollutant of concern. Data entered must have been taken within four and one-half years prior to the date of the permit application (40 CFR 122.21). The RPA spreadsheet estimates the 95th percentile upper concentration of each pollutant. The Predicted Max concentrations are compared to the Total allowable concentrations to determine if a permit limit is necessary. If the predicted max exceeds the acute or chronic Total allowable concentrations, the discharge is considered to show reasonable potential to violate the water quality standard, and a permit limit (Total allowable concentration) is included in the permit in accordance with the U.S. EPA Technical Support Document for Water Quality -Based Toxics Control published in 1991. 7. When appropriate, permit writers develop facility specific compliance schedules in accordance with the EPA Headquarters Memo dated May 10, 2007 from James Hanlon to Alexis Strauss on 40 CFR 122.47 Compliance Schedule Requirements. 8. The Total Chromium NC WQS was removed and replaced with trivalent chromium and hexavalent chromium Water Quality Standards. As a cost savings measure, total chromium data results may be used as a conservative surrogate in cases where there are no analytical results based on chromium III or VI. In these cases, the projected maximum concentration (95th %) for total chromium will be compared against water quality standards for chromium III and chromium VI. 9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge, are inserted into all permits with facilities monitoring for hardness -dependent metals to ensure the accuracy of the permit limits and to build a more robust hardness dataset. 10. Hardness and flow values used in the Reasonable Potential Analysis for this permit included: Parameter Value Comments Data Source) Average Effluent Hardness (mg/L) [Total as, CaCO3 or (Ca+Mg)] 45.6 Average of 7 Samples from WET tests Average Upstream Hardness (mg/L) [Total as, CaCO3 or (Ca+Mg)] 25 Default value 7Q10 summer (cfs) 20.9 USGS data 1 Q 10 (cfs) 17.25 Calculated by RPA spreadsheet Assigned Flow (MGD) 2.0 BPJ — flow history Page 13 of 13 T— p O C!) a � CD d z z N > SLa00o0= H O N W O N 00 0 0 eTaa0 V LLI LL II II II II II II �i 0 M 6 Is E V) V1 N Q bD O O d 'WI a= A a F u10 q 0: Q E Z W A M � o ®¢ N :ul ` a Z N m cc S W a lu p = W N w it U¢U -W eu Lu b+ ill w a 0) W r W — �- O t0 — 01 CO C M M O 0 N 0> r 1� F 1n N r M 01 N M M s 0- a W a � m d z z to SLa00o0= H O N W O N 00 0 0 eTaa0 V N r N N cM I.- Z LL II II II II II II �i 0 V) V1 N Q bD O O d •� 3 /Oy /O�� V V In •y Ln LnE s 0- a REASONABLE POTENTIAL ANALYSIS Pal 23 7/11/2017 2 2 24 8/3/2017 2 2 25 2.9792 1.5678 24 1.66 22.00 ug/L 36.52 ug/L Date 1 2 2 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Lead Copper Date Data BDL=1/2DL Results 1 9710/2015 '22 22 Std Dev. 2 10/812015 5 5 Mean 3 11/5/2015 1 0.5 C.V. 4 12/8/2015 ; < 1' 0.5 n 5 1/7/2010 8 8 6 215/2016 3 3 Mult Factor = 7 3/3/201£ ` < 1' 0.5 Max. Value 8 4/612016 ,; 7i 7 Max. Pred Cw 9 5/5/2010 t 1 0.5 10 817/3016 `< 1J 0.5 11 .717/2016 3. 3 12 8/412016 ' < 1' 0.5 13 9/15/2016 1 1 14 10/19/2016 < 1' 0.5 15 1174/2016 1 1 16 12/8/2016 ' < 1' 0.5 17 1/5/2017 6' 6 18 2/272017 < 1' 0.5 19 3(7/2017' < 1 0.5 20 4/872017 5' 5 21 5/4/2017 < 1 0.5 22 618/201:7 1 1 23 7/11/2017 2 2 24 8/3/2017 2 2 25 2.9792 1.5678 24 1.66 22.00 ug/L 36.52 ug/L Date 1 2 2 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Lead BDL=1/2DL Results = 5 Std Dev. 1.5021 5 Mean 4.5250 5 C.V. 0.3320 5 n 10 0.25 5 Mult Factor = 1.38 5 Max. Value 5.000 ug/L 5 Max. Pred Cw 0 DETECTS ug/L 5 5 9595 Final FW RPA w_upstream avg data column_diss to totalmetals_nodetects_defaults 2016_4291.xism, data 2- 10/10/2017 REASONABLE POTENTIAL ANALYSIS H1 H2 Effluent Hardness Upstream Hardness Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results 1 311/2015 44 44 Std Dev. 2.8200 1 25 25 Std Dev. N/A 2 6/1/2015 47; 47 Mean 45.5714 2 Mean 25.0000 3 911/2015 42 42 C.V. (default) 0.6000 3 I C.V. 0.0000 4 12/112015 42 42 n 7 4 n 1 5 3/1/2016 48 48 10th Per value 42.00 mg/L 5 10th Per value 25.00 mg/L 6 9/112016 48 48 Average Value 45.57 mg/L 6 Average Value 25.00 mg/L 7 12!1/2016 48r 48 Max. Value 48.00 mg/L 7 Max. Value 25.00 mg/L 8 8 i 9 9 10 10 ' t 11 11 12 12 13 13 14 . 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 '< 9595 Final FW RPA w_upstream avg data column_diss to totalmetals_nodetects_defaults 2016_4291.xism, data - 1 - 10/10/2017 REASONABLE POTENTIAL ANALYSIS Parl9 Selenium W Silver Date Data BDL=1/2DL Results Date Data BDL=1/2DL Result11.6750 1 12/4/2007 '< 10 5 Std Dev. 1.2649 1 :1214/2007 < 5 2.5 Std De.0675 2 12/9/2008 '< 10 5 Mean 4.6000 2 '1219/200$ < 5 2.5 Mean 3 1214/2009 < 10 5 C.V. 0.2750 3 12/4/2009 < 5 2.5 C.V. 0.6373 4 11/3/2010 '< 10 5 n 10 4 :111312610 < 5 2.5 n 10 5 1212/2011 < 2 1 5 '12/2/2011 < 0.5 0.25 6 11/7/2012 , '< 10 5 Mult Factor = 1.31 6 11/7/2012 < 5 2.5 Mult Factor = 1.79 7 12/3/2013 < 10 5 Max. Value 5.0 ug/L 7 '12/3/2013 < 5 2.5 Max. Value 2.500 ug/L 8 11(4/2014 < 10 5 Max. Pred Cw O DETECTS ug/L 8 . 71114/2014 < . 1 0.5 Max. Pred Cw O DETECTS ug/L 9 9/10/201$ ,< 10 5 9 '9/10/2015 < 1' 0.5 10 10/19/2016 < 10 5 10 10/19/2016 < 1 0.5 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 9595 Final FW RPA w_upstream avg data column_diss to totaimetals_nodetects_defaults 2016_4291.xism, data - 3 - 10/10/2017 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 REASONABLE POTENTIAL ANALYSIS BDL=1/2DL Results Emmommom 63 Std Dev. 32.6260 11 Mean 55.6364 71 C.V. 0.5864 22 n 11 22 48 Mult Factor = 1.66 101 Max. Value 101.0 ug/L 72 Max. Pred Cw 167.7 ug/L 21 97 84 9595 Final FW RPA w_upstream avg data column_diss to totaimetals_nodetects_defaults 2016_4291.xlsm, data - 4 - 10/10/2017 m Cc (D! C9 qZ LQ C!, Un q 6 6il,— C,4 CO cl) 0 0 OD C', � CR � i '� � 17 1 'T 1 CR I Cq 6 -1 10 0:01 - o mw��M -6 ET B is m EE Berry, Ron From: Berry, Ron Sent: Tuesday, January 16, 2018 3:37 PM To: 'Thompson, Billy' Cc: Wiggs, Linda; Heim, Tim Subject: RE: [External] SGL Carbon - Morganton NCO005258 Mr. Thompson, Your final NPDES permit is still under review and at best will be issued next week with an effective date of March 1, 2018. It sounds like this will fit within your time table as far as having treatment equipment in place and operational to meet your new residual chlorine limit. Do you agree? I would recommend not waiting until March 1, 2018 to begin treatment but instead begin treatment and monitoring as soon as the equipment is in place to give you time to make adjustments. Ron Berry Engineer Division of Water Resources/Complex Permitting North Carolina Department of Environmental Quality 919 807 6396 office ron.berry@ncdenr.gov 512 N. Salisbury Street 1617 Mail Service Center Raleigh, NC 27699-1617 Email correspondence to and from this address is subject to the From: Thompson, Billy[mailto:Billy.Thompson@sglgroup.com] Sent: Tuesday, January 16, 2018 10:00 AM To: Berry, Ron <ron.berry@ncdenr.gov> Subject: [External] SGL Carbon - Morganton NC0005258 Ron My plant engineerjust informed me that the pump for our chlorine removal system will not be here by February 1. The draft permit states that we begin monitoring for residual chlorine beginning in February. Is there a way to request a delay of the start date until later in the month? Also, I have not seen the final permit. Has it been mailed yet? 1 Billy Thompson Environmental Manager Phone +1(O28)432 -S773 Fax +1(828)4325885 SGL CARBON LLC 3O7Jamestown Road Morganton, North Carolina 28655 / United States SGLGroup-The Carbon Company Broad Base. Best Solutions. SGL CARBON SE, Soehnic-instrasse 8, 65201 Wiesbaden/Germany. Chair of theSupervisory Board: Susanne Klatten, Board of Management: Dr. Jurgen Kohler (CEO), Dr, Michael Majerus, Dr. Gerd VVin8efc|d.Registration court Wiesbaden, nRazos6o. This transmittal and/or attar hments ("Communication") is confidential to SG[ Group, including ills subsidiaries and affiliates, and may otherwise be privileged. If you are not the intended recipient, you are hereby notified that you have received this Communication inerror and any dissemination, distribution n,copying ofthis [ommun|catinnisstrictly prohibited. /fyou have received this Communication in error, please notify the sender under the address listed above and prorriptly delete this Communication. 01 - ^ ~ ��^ ��U:�p�ns���` �— Julie From: Thompson, Billy <Bi|ly.Thmpson@sglgmupmm> Sent: Tuesday, September l2,20I79:50AK4 To: Wiggs, Linda; Lundb|ad, K4ark;Gjet|ey, Lee Cc: Grzyb' Julie Ms. Wiggs Our current best approach is to treat any discharge to the receiving stream to remove any residual chlorine using a sulfite or thiusu|fate reagent. Treatment is fairly straight forward (chemical metering pumps and related system) and can be accomplished bvour current water treatment vendor. VVealso potentially may reroute some ufthe current discharge tothe local PUTVVfor treatment reducing the overall discharge iothe creek. Please let me know if you have further questions. Billy Thompson - From: Wiggs, Unda[moiko1inda»xiggs@ncdenr.gov] Sent: Thursday, August 31,2817lU:54AM To: Lundb|ad,Mark <Mark.Lundb|ad@sg|8roup.com>; Gjet|ey,Lee <Lee.Get|ey@sQ|eroup.corn>;Thompson, Billy <8i||y.Thonnpsnn@sg|Broup.00m> Cc: Grzyb,Julie ^ju|ie.Boyb@ncdenr.Qov> Subject: RE: SGL Carbon NCO0052SQ Hi Mark, Hope all is well. T am checking in for an Undate b O your decided BDDrOBCh to lower the residual chlorine. You had identified September 2017for the completion Ofyour evaluation BOM F8b[U8rV 2[)18for installation. Thanks, (�r- Environmental Senior Specialist —Asheville Regional Office Water Quality Regional Operations Section NCDEC)—DiviaionofVVaterResources 8282804500 office ' 8282907843 fax Email: linda.wiggs(o)-ncdenr.gov 20QOU.S.Hwy. 70 Swonnanoo.N.C.28778 <�Nothing Compares Email correspondence hoand from this address /ssubject b/the North Carolina Public Records Law and may bodisclosed h»third parties. 1 From: Wiggs, Linda Sent: Friday, April 21, 2017 3:52 PM To: Lundblad, Mark <Mark.Lundblad@sglgroup.com>; 'Gjetley, Lee' <Lee.Gietley@sglgroup.com>; 'billy.thompson@sglgroup.com' <biliy.thompson@sglgroup.com> Cc: Grzyb, Julie <ulie.grzyb@ncdenr.gov> Subject: SGL Carbon NC0005258 _ Mark, Your response was received on April 10, 2017 to the inspection letter dated March 16, 2017. Your response proposes an evaluation of treatment for lowering Total Residual Chlorine (TRC) to be completed by September 2017 with the purchase and installation of the equipment by February 2018. These proposed timelines appear to be acceptable. According to the NPDES Complex Permitting Supervisor Julie Grzyb, your permit renewal should occur by the end of 2017. A TRC effluent limitation of 28 pg/L will be placed in the permit, along with the standard footnote for TRC - The Division shall consider all effluent total residual chlorine values reported below 50 ug/l to be in compliance with the permit. However, the permittee shall continue to record and submit all values reported by a North Carolina certified laboratory (including field certified), even if these values fall below 50 ug/l. She also stated when your permit is assigned to one of the NPDES permit writers, that permit writer will contact SGL Carbon and confirm the proposed completion date so the permit effective date on the limitation or compliance schedule is accurate. Please contact me with any questions and updates as you progress towards these timelines. Thank you, Environmental Senior Specialist — Asheville Regional Office Water Quality Regional Operations Section NCDEQ — Division of Water Resources 828 296 4500 office 828 299 7043 fax Email: linda.wiggs(a�_ncdenr.gov 2090 U.S. Hwy. 70 Swannanoa, N.C. 28778 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Feya,,A<-,E- P-eqo"'5-�'t April 5, 2017 Linda Wiggs NC Department of Environmental Quality Division of Water Resources 2090 US Highway 70 Swannanoa, NC 28778 Response to Compliance Sampling Inspection Ms. Wiggs: SGL GROUP THE CARBON COMPANY BROAD BASE I BEST SOLUTIONS FDmsRECEIVED ion at water P&sourcw APR 10 2017 Wator Oualfty Reglond Operations Asheville Regional t'Jfflce We received a letter from you dated March 16, 2017 regarding a site inspection conducted February 28 and the associated findings. Your letter noted that during the inspection you tested our effluent at the outfall and found that we were discharging water with a total residual chlorine level of 1180 ug/l. You found the chlorine level to be 690 ug/1 as well. This violates the surface water standard level of 17 ug/1 for Silver Creek. The letter requires us to respond in writing . within 30 days of receipt of the letter and this will serve as our response. SGL participated in a conference call on March 30, 2017 to discuss the chlorine residual issue with you. In addition to you, Lee Gjetley our North American Environmental Manager, Billy Thompson our plant Environmental Manager and I were on the call. SGL does not add any chlorine to our water. The only source of chlorine is the residual chlorine in the water that we purchase from the local municipality. Due to our close proximity to the filtration plant, this is the only reason that our chlorine level is high. We use municipal water to cool our various furnaces by using a single pass system. Additionally, as we informed you during your visit we were in the process of repairing our cooling towers. This is our only closed loop system and at this time we were discharging a much larger volume of single pass cooling water in our effluent. This situation likely increased the residual chlorine level in Silver Creek due to the over 3 million gallons per day increase in cooling water. We all agree that SGL has no past or current permitted total residual chlorine limit nor do we have any requirement to monitor for this material. We do recognize it is likely that we will receive a limit or a monitoring requirement when our permit is renewed. At this juncture we will evaluate the chlorine in our system and methods for removal prior to discharge. Based on your comments during our call, when we receive our new permit, it will have a residual chlorine limit of no less than 50 ug/1 at our outfall and that achieving this level will be compliant with any SGL Carbon, LLC 307 Jamestown Road Morganton, NC 28655 Sglcarbon.com Phone: (828) 437-3221 Fax: (828) 432-5885 requirements of our new permit. We are in the process of evaluating our discharges and determining the best course of action to comply with this limit. We propose the following timeline to address the issue: • Identify sources of municipal water entering the storm/cooling water drainage system by May 2017. • Evaluate treatment methodology, equipment and reagents to lower residual chlorine in effluent to acceptable levels and decide on best approach by September 2017. • Complete SGL Capital Expenditure approval process (budget must be allocated for FY 2018), purchase and install equipment by February of 2018. If you have any questions or concerns regarding this response please contact me at 828 432-, 5856. Sincerely, Mark Lundblad, Plant Manager SGL Carbon, LLC SGL Carbon, LLC 307 Jamestown Road Morganton, NC 28655 Sgicarbon.com Phone: (828) 437-3221 Fax: (828) 432-5885 ROY COOPER Director March 16, 2017 Mark Lundblad SGL Carbon RECEIVc 307 Jamestown Rd. Morganton, NC 28655 SUBJECT: Compliance Sampling Inspection SGL Carbon Corporation Permit No: NC0005258 Burke County Dear Mr. Lundblad: On February 28, 2017, the Division of Water Resources (Division) staff conducted a Compliance Sampling Inspection at the subject facility. Present during the inspection were Jeff Woodruff with SGL Carbon and Dan Boss with the Division. This inspection was conducted to determine the Total Residual Chlorine (TRC) levels in the SGL Carbon effluent and in Silver Creek downstream of the SGL Carbon discharge. TRC levels of an effluent are determined as compliant at a level of less than 50 ug/1. The Surface Water Standard for TRC pursuant to 15A NCAC 02B.0211(3) is 17 ug/l. The SGL Carbon effluent TRC was 1180 ug/1 and Silver Creek TRC, downstream of the SGL Carbon discharge, was 690 ug/l. Based on these results, SGL Carbon is exceeding the applicable North Carolina 15A NCAC 02B Surface Water Standard for Total Residual Chlorine. Please respond in writing within thirty (30) days of the date of this letter regarding SGL Carbon's remedial actions to remove TRC from their effluent discharge to a level that will not violate the Surface Water Standard of 17 ug/l. If you or your staff have any questions, please call me at 828-296-4500. Sincerely, Linda Wiggs Environmental Senior Specialist Asheville Regional Office Enc. Inspection Report cc: Billy Thompson, Jeff Woodruff SGL Carbon (e -copy) Asheville Files MSC 1617 -Central Files -Basement G:\WR\WQ\Burke\Wastewater\Industrial\SGL Carbon 05258\CSI. 2-28-20171tr.docx `Nothirt ompas State of North Carolina ( Environmental Quality I Water Resources 2090 U.S. Highway 70 Swannanoa, NC 28778 828 296 4500 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type Ir,, I 2 15 ( 3 I NCO005258 I11 12 17/02/2817 181, i 19 1 G 201 I 2111111=111111111111111111111111111111111IIII 166 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------Reserved---------- 671 70 ( 71 I—I 72 r, I_I I_I 73 �74 751 I I I I I I I8O Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES permit Number) 03:OOPM 17!02128 10/04/01 SGL Carbon Corporation 307 Jamestown Rd Exit Time/Date Permit Expiration Date Morganton NC 28655 04:OOPM 17/02/28 15/02/28 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Rick Ives, !/828-432-5811/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Self-Monitoring Program 0 Effluent/Receiving Waters Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Linda S Wiggst"!t�� ARO WQ//828-296-4500 Ext.4653/ Daniel J Boss j2, ARO WQ//828-296-4658/ Signature of Maflalent Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type 1 31 NC0005258 I11 12 17/02/28 1 101 17 18 t „ Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Present during the inspection were Jeff Woodruff with SGL and Dan Boss with DWR. This inspection was conducted to determine the Total Residual Chlorine (TRC) levels in the SGL effluent and in Silver Creek downstream of the SGL discharge. SGL effluent TRC —1180 ug/1 Silver Creek downstream of SGL discharge — 690 ug/l TRC levels of an effluent are judged as compliant at a level of less than 50 ug/I. The Surface Water Standard for TRC is 17 ug/I. Page# Permit: NC0005258 Inspection Date: 02/28/2017 Owner -Facility: SGL Carbon Corporation Inspection Type: Compliance Sampling Effluent Pipe Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? Comment: Upstream / Downstream Sampling Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? Comment: Yes No NA NE ❑ ❑ ❑ Page# 3