NC0004944_Fact Sheet_20180705

Fact Sheet
NPDES Permit NC0004944
Permit Writer (email address): Sergei Chernikov, Ph.D. ([e-mail])
Date: June 11, 2018
Division/Branch: NC Division of Water Resources/NPDES Complex Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
0 Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
1. Basic Facility Information
Facility Information
Applicant/Facility
Salisbury Investments I, LLC / Edge Water Treating, LLC
Name:
(formerly DuraFiber Technologies, Inc.; Performance Fibers
Operations, Inc.; INVISTA, S.a.r.l; KOSA; and Hoechst
Celanese)
Applicant Address:
5320 Old Pineville Rd., Charlotte, NC 28217
Facility Address:
7401 Statesville Blvd., Salisbury, NC 28147
Permitted Flow:
2.305 MGD
Facility Type/Waste:
MAJOR Industrial; 10% domestic, 90% industrial
Facility Class:
Class WW -4
Treatment Units:
• Bar screen and grit removal;
• Chlorine contact (sanitary wastes)
• Two covered equalization tanks;
• Three aeration basins (one out -of —service);
• Anaerobic groundwater treatment unit (out -of -service);
• Three secondary clarifiers (one out -of -service);
• Three aerated polishing ponds;
• Chemical additional facilities;
• Aerobic digestion;
• Sludge dewatering; and
• Instrumented flow measurement.
Pretreatment Program?
N/A
County:
Rowan
Region
Mooresville
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Fact Sheet
NPDES Permit NC0004944
Edge Water Treating, LLC manufactures polyester resin and polyester fiber. As such, 40
CFR 414.31 and 414.41 (OCPSF Federal guidelines) are applicable. Primary raw
materials include terephthalic acid, ethylene glycol, and fiber finish oils. The product from
the facility is used to reinforce rubber goods such as automotive tires, v -belts, seat belts,
etc.
The facility was originally permitted in 1980 at a flow of 1.2 MGD. In 1992 a flow
modification request accompanied the permit renewal application. At that time, Hoechst
Celanese requested an increase in total flow from 1.2 MGD to 2.305 MGD to accommodate
the discharge of remediated groundwater associated with a RCRA site stabilization plan.
During the same period, USGS was requested to evaluate critical low flows and the
average flow of the receiving stream. The flows provided by USGS were half what they
had been when the permit was developed at 1.2 MGD. DWQ modeled the wastewaters in
1993 and established water quality based limits for BOD and ammonia nitrogen.
The most recent renewal application did not request any modification to the NPDES
permit. However, an ownership change was requested by the new owners (Salisbury
Investments, I, LLC) on June 1, 2018. They also requested that the facility name be
changed to Edge Water Treating, LLC.
2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
001 / North Second Creek
Stream Segment:
12-108-21
Stream Classification:
C
Drainage Area (mi2):
116
Summer 7Q10 (cfs)
6.9
Winter 7Q10 (cfs):
23
30Q2 (cfs):
Average Flow (cfs):
116
IWC (% effluent):
34
303(d) listed? / parameter:
No
Subject to TMDL? / parameter:
No
Subbasin/HUC:
Yadkin -Pee Dee 03-07-06; 03040102
USGS Topo Quad:
Salisbury, N.C.
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Fact Sheet
NPDES Permit NC0004944
3. Effluent Data Summary
Effluent data is summarized below 2011-2016.
Table. Effluent Data Summary
Parameter
Units
Average
Max
Min
Permit
Limit
Flow
MGD
1.189
2.188
2.305
BOD
pounds/day
9.9
73.0
60.0/149.0
NH3N
pounds/day
1.8
77.0
23.0/46.0
TSS
pounds/day
31.0
246.0
96.0/294.0
pH
SU
8.8
6.4
6.0-9.0
Temperature
°C
25.0
7.0
DO
mg/1
14.4
5.9
>5.0
TN
pounds/day
1.5
2.3
TP
pounds/day
0.5
0.9
Fecal Coliform
#/100 ml
14.4
240
MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum
4. Instream Data Summary
The facility discharges to North Second Creek in the Yadkin -Pee Dee River Basin. It is not listed
on the 303(d) list of impaired waters. As a member of the Yadkin Pee Dee River Basin Association
(YPDRBA), Edge Water Treating collects instream data at two stations. The upstream station,
Q4030000, is located on Second Creek at Highway 81 and Sherrills Ford Road upstream of both
Edge Water Treating and the Second Creek WWTP. The downstream station, Q4165000, is located
on Second Creek at US 61 near Salisbury and is downstream of both facilities.
This permit requires instream monitoring for temperature, conductivity, and dissolved oxygen. The
monitoring is provisionally suspended due to the facility's membership in the YPDRBA.
Review of instream data for the period 1/2006 — 12/2010 indicates that the dissolved oxygen
standard of 5 mg/l and pH standard of 6.0 — 9.0 were maintained, and there were no apparent
differences between upstream and downstream stations.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): YES
Name of Monitoring Coalition: Yadkin Pee Dee River Basin Association
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Fact Sheet
NPDES Permit NC0004944
5. Compliance Summary
The facility reported 1 NH3-N limit violation in 2012.
The facility passed 20 of 20 quarterly chronic toxicity tests, as well as all 4 second species chronic
toxicity tests.
6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing' Zones
In accordance with 15A NCAC 213.0206, the following streamflows are used for dilution
considerations for development of WQBELs: 1Q10 streamflow (acute Aquatic Life); 7Q10
streamflow (chronic Aquatic Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual
average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results):
N/A
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B.0204(b):
N/A
Oxv-uen-ConsuminLy Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality
modeling to ensure protection of the instream dissolved oxygen (DO) water quality standard.
Secondary TBEL limits (e.g., BOD= 30 mg/1 for Municipals) may be appropriate if deemed more
stringent based on dilution and model results.
If permit limits are more stringent than TBELs, describe how limits were developed: water quality
based limits for BOD were determined for the 1993 permit application based on DWQ's draft
wasteload allocation dated May 24, 1993. DWQ's modeling analysis predicted a minimum DO of 5
mg/L based on a discharge of 1.574 MGD, 131 pounds/day BODS, and 17 pounds/day ammonia
nitrogen. The modeling used a typical CBOD decay rate and a CBOD/BOD ratio. These values
were adjusted using site specific information, and a minimum BOD limit of 150 pounds/day was
established for the summer months with ammonia nitrogen limits of 23 pounds/day monthly
average and 46 pounds/day daily maximum. BOD limitations determined using the technology
based effluent guidelines were used to set winter BOD limitations. However, given the current
level of production and the decreased process and sanitary flows BOD limitations for this permit
were limited by the technology based effluent guidelines.
Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic
criterion of 1.0 mg/1 (summer) and 1.8 mg/1 (winter). Acute ammonia limits are derived from
chronic criteria, utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5
for Non -Municipals.
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Fact Sheet
NPDES Permit NC0004944
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for
protection of aquatic life (17 gg/1) and capped at 28 gg/1 (acute impacts). Due to analytical issues,
all TRC values reported below 50 gg/l are considered compliant with their permit limit.
Limitations for ammonia were based on a model. The limits were not changed in this permit
renewal.
Reasonable Potential Analysis (RPA) for Toxicants
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 1/ 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 during the last 5
years. 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: Total Copper (the RPA is attached). The rest
of the parameters were below detection level.
In addition, the attached spreadsheet compared OCPSF limits with WQBELs and the
following limits in the permit are based on the WQBELs: Acrylonitrile, Anthracene,
Benzo(a)anthracene, 3,4-Benzofluoranthene, Benzo(k)fluoranthene, Benzo(a)pyrene,
Chrysene, 2,6-Dinitrotoluene, Fluoranthene, Hexachlorobenzene, Total Chromium
(monthly average only), Total Cyanide, Total Lead, and Total Nickel.
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 is a Major Industrial Facility and a chronic WET
limit at 34.0% effluent will continue on a quarterly frequency.
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Fact Sheet
NPDES Permit NC0004944
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 pounds/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
The mercury WQBEL for this facility is 35.2 ng/L, the mercury concentration reported on the
renewal application was <170.0 ng/L. Since this concentration does not exceed the WQBEL, no
mercury limit is required. However, since the facility is a Major Industrial facility, the Division
needs to collect additional mercury data and annual mercury monitoring will be added to the permit.
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: The vast majority of
the parameters reported on the renewal application were below detection level. The only exception
is copper.
If applicable, describe any special actions (HQW or ORW) this receiving stream and classification
shall comply with in order to protect the designated waterbody: N/A.
If applicable, describe any compliance schedules proposed for this permit renewal in accordance
with 15A NCAC 2H. 0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: N/A
If applicable, describe any water quality standards variances proposed in accordance with NCGS
143-215.3(e) and 15A NCAC 2B. 0226 for this permit renewal: N/A
7. Technology -Based Effluent Limitations (TBELs)
Industrials (if not applicable, delete and skip to next Section)
Describe what this facility produces: polyester resin and polyester fiber.
List the federal effluent limitations guideline (ELG) for this facility: 40 CFR 414.31 and 40 CFR
414.41.
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Fact Sheet
NPDES Permit NC0004944
If the ELG is based on production or flow, document how the average production/flow value was
calculated: This ELG is based on flow. The annual average flow for the past 5 years was reported
as 0.262 MGD.
For ELG limits, document the calculations used to develop TBEL limits: The limits in the attached
Table are based on flow of 0.047 MGD for subpart C and 0.215 MGD for subpart D.
If any limits are based on best professional judgement (BPJ), describe development: N/A
Document any TBELs that are more stringent than WQBELs: N/A
Document any TBELs that are less stringent than previous permit: N/A
8. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading
will not degrade water quality. Permitting actions for new or expanding discharges require an
antidegradation review in accordance with 15A NCAC 2B.0201. Each applicant for a
new/expanding NPDES permit must document an effort to consider non -discharge alternatives per
15A NCAC 2H.0105 (c) (2). In all cases, existing instream water uses and the level of water
quality necessary to protect the existing use is maintained and protected.
If applicable, describe the results of the antidegradation review, including the Engineering
Alternatives Analysis (EAA) and any water quality modeling results: N/A
9. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations
in a reissued permit to be as stringent as those in the previous permit, with some exceptions where
limitations may be relaxed (e.g., based on new information, increases in production may warrant
less stringent TBEL limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent 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 213.0500;
2) NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES
Guidance, Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012
Memo); 4) Best Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring
requirements are not considered effluent limitations under Section 402(o) of the Clean Water Act,
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Fact Sheet
NPDES Permit NC0004944
and therefore anti -backsliding prohibitions would not be triggered by reductions in monitoring
frequencies.
For instream monitoring, refer to Section A. (1).
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 submit additional NPDES reports electronically. This permit contains the
requirements for electronic reporting, consistent with Federal requirements.
12. Summary of Permitting Actions:
Current Permit Conditions and Changes from the previous permit
Parameter
Current Permit
Proposed Change
Basis for
Condition/Change
Flow
MA 2.305 MGD
No change
15A NCAC 2B.0505
BODS
MA 75.0 pounds/day
MA 60.0 pounds/day
TBEL. The production has
DM 187.0 pounds/day
DM 149.0 pounds/day
been reduced.
NH3-N
MA 23.0 pounds/day
No change
WQBEL. Based on protection
DM 46.0 pounds/day
of State WQ criteria. 15A
NCAC 2B.0200
TSS
MA 120.0 pounds/day
MA 96.0 pounds/day
TBEL. The production has
DM 369.0 pounds/day
DM 294.0 pounds/day
been reduced.
Fecal coliform
MA 200 /100ml
No change
WQBEL. State WQ standard,
DM 400 /100ml
15A NCAC 2B.0200
DO
> 5 mg/l
No change
WQBEL. State WQ standard,
15A NCAC 2B.0200
pH
6 — 9 SU
No change
WQBEL. State WQ standard,
15A NCAC 2B.0200
DO,
Instream monitoring
No change
15A NCAC 2B.0500
Conductivity,
Temperature
Total Copper
Monitor Only
Add limits
Limits are based on RPA.
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Fact Sheet
NPDES Permit NC0004944
Toxicity Test
Chronic limit, 34.0%
No change
WQBEL. No toxics in toxic
effluent
amounts. 15A NCAC 2B.0200
and 15A NCAC 213.0500
OCPSF
Annual
Monitoring frequency
40 CFR 414.31 and 414.41
parameters
is maintained and
limits have been
The production has been
reduced.
reduced.
Electronic
No requirement
Added Electronic
In accordance with EPA
Reporting
Reporting Special
Electronic Reporting Rule
Condition
2015.
The Nutrient
No requirement
Added permit
Need to address the nutrient
Reopener for
reopener at Part I A.
issues in High Rock Lake
High Rock Lake
(5).
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
13. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): Yes — the facility
ownership and facility name was changed.
14. Fact Sheet Attachments (if applicable):
• RPA Spreadsheet Summary
• OCPSF spreadsheet calculation
• BOD and TSS spreadsheet calculation
• DMR violations
• WET test summary
• Ambient monitoring station results summary
15. Permitting Strategy for Stormwater
The facility discharges stormwater associated with industrial activity through five outfalls, A, B,
C, D, and 5 to Second Creek (North Second Creek, index no. 12-108-21). This waterbody was no
longer listed as impaired in biological integrity in NC's 2014 Integrated Report, and so language in
Part I., Section B, 1. B) (7) was revised accordingly.
The company included a discussion of some stormwater data results with the NPDES permit
renewal application but did not submit any stormwater monitoring data. Stormwater data
monitoring reports (DMRs) that were required to be submitted each year by March 1 to both the
Central and Regional Offices during the previous permit term could not be located in DWR's
Central Files during a review of years 2011-2016 and presumably were not submitted. Repeated
attempts to reach the contact noted in the application cover letter for these data were not
successful (e-mails not returned; phone number voice mail is for a different person).
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Fact Sheet
NPDES Permit NC0004944
The company stated that annual total toxic organics (TTO) testing for stormwater discharges and
resulted in one hit of methylene chloride (3.6 µg/1) from outfall 5 in 2010. TTO was not required by
the permit, and the company asserted there was no reason to suspect this substance was present
at this outfall. Methylene chloride is a common lab contaminant. The renewal permit does not
propose TTO monitoring for stormwater discharges.
The company's renewal application also indicated a 2009 sample from outfall C was above the 100
mg/1 benchmark (presumably for total suspended solids (TSS), but the application did not say). No
potential source was identified. TSS monitoring remains in the proposed permit because it is a
potential contaminant from industrial sites. Total phosphorus (TP) levels at all outfalls exceeded
the 2.0 mg/1 benchmark at least once during 2012-13. All TP exceedance values noted were below
3.0 mg/l, and no potential sources were identified. Three samples from outfall C were out of the
pH benchmark range (did not indicate whether higher or lower) also during 2012-13. Again, no
reasons were identified. The facility implemented Tier II response (monthly monitoring) because
of benchmark exceedances at outfalls A (for TP), C (for pH), and D (for TP) until achieving three
consecutive samples below benchmarks (apparently attained).
The renewal permit maintains total phosphorus (TP), total nitrogen (TN), total suspended
solids (TSS), biological oxygen demand (BOD), and non -polar Oil and Grease by EPA
Method 1664 (SGT -HEM) monitoring. The last parameter is the same as the "Total Petroleum
Hydrocarbons" parameter measured by this same EPA method during the previous permit cycle,
but it has been renamed to reduce confusion among permittees and labs over other methods
typically used to measure TPH. Proposed benchmarks for these parameters have not changed
since the last permit cycle. TN monitoring may no longer be necessary; however, DEQ does not
have any data on which to justify that change.
16. Changes in the Final Permit
➢ The owner name and facility name have been changed.
➢ The submission stormwater monitoring schedule has been updated [see Part I B. (4) (a), Table
2].
➢ The due date for your firm to apply for a separate stormwater permit has been provided [see
Part I B. (1) c)].
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