NC0005177_Fact Sheet_20180706

Fact Sheet
NPDES Permit No. NC0005177
Permit Writer/Email Contact Bing Bai, [e-mail]:
Date: July 6, 2018
Division/Branch: NC Division of Water Resources/NPDES Complex Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
® 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 and Receiving Waterbody Information
Page 1 of 11
Facility Information
Applicant/Facility Name:
FMC Lithium USA Corporation / FMC Lithium Division
Applicant Address:
P. O. Box 795; Bessemer City, NC 28016
Facility Address:
1115 Bessemer City -King Mountain Highway: Bessemer City, NC 28016
Facility/Permit Status:
Class 2/Active; Renewal
County:
Gaston
Receiving Stream:
Unnamed tributary
to First Creek
Index No.
11-135-4-1
Stream Classification:
C
303(d) Listed?
No
Subbasin:
Catawba River
Basin/03-08-37
Subject to
TMDL/parameter:
Statewide Mercury
TMDL
HUC:
03050103
Regional Office:
Mooresville
Drainage Area (mi2):
1.4
State Grid / USGS Quad:
F 13 SE
Summer 7Q10 (cfs)
0.27
30Q2 (cfs)
0.58
Page 1 of 11

Winter 7Q10 (cfs):
0.43
Average Flow (cfs):
1.7
Outfall 001 (main plant)
Permitted Flow:
0.615 MGD
Cooling tower blowdown, boiler blowdown, low volume industrial
Type of Waste:
wastewater, condensation, once -through cooling water, scrubber
wastewater, filtrate (clean water) from RO units, with trace amounts
stormwater
Treatment Units:
Reverse Osmosis Filtration, Hydrogen Peroxide Addition, pH
Adjustment, R&D Pond, Retention Pond, Effluent Flow Weir.
IWC (%):
78%
Outfall 004 (organic unit sources)
Permitted Flow:
(no permitted flow)
Type of Waste:
Stormwater with trace amounts of condensation, boiler blowdown, once -
through cooing water, and cooling tower blowdown
IWC (%):
N/A
Briefly describe the proposed permitting action and facility background: FMC Lithium USA
Corporation owns and operates a manufacturing facility west of Bessemer City, NC that produces lithium
compounds, organic and inorganic. Lithium is currently received as lithium carbonate and converted to
various commodities. Because of the safety issues involved with lithium compound manufacturing the
plant is divided and isolated into two separate operations, organic production and inorganic production.
The domestic waste from this facility is collected and sent to the local POTW in Bessemer City.
This permit contains conditions and requirements for industrial -based wastewater and stormwater.
Because of the various wastewater characteristics, plant operations, and sources, Outfall 001 is designated
as the primary industrial wastewater discharge and has a permitted flow. Outfall 004 is primarily a
stormwater discharge with traces of intermittent industrial sources.
During the routine compliance inspection on March 24, 2015, an outfall originating from the Effluent
Treatment Pond dam was identified. FMC was requested to monitor the subject outfall and report results
on DMR form (identified as Outfall 002) through July 2015 including monitor twice per month on flow,
BOD, TSS, Total Chloride, Total Nitrogen, Total Phosphorus, pH, DO and Conductivity. Monitoring was
discontinued in August 2015 due to the expiration of permit. In this permit renewal, Outfall 002 will be
added with quarterly monitoring for above parameters.
COLLECTION AND OPERATION
The condensate, boiler blowdown, and stormwater produced by the organic operation is sent to the
Research & Development (R&D) pond. The R&D pond also collects stormwater from the surrounding
area of the labs, roof drains, and other inorganic process areas, and is normally transferred into the plant
process wastewater collection system. If required, the R&D pond can be transferred either to the local
POTW or diverted into the stormwater conveyance channel.
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The plant process wastewater system collects wastewater from the R&D pond, lithium hypochlorite
scrubber, two reverse osmosis filtration systems, cooling tower blowdown, boiler blowdown, condensate,
once -through cooling water, drains, process wastewater, and stormwater. After the majority of wastewater
sources are collected, the pH is measured and sulfuric acid is added as needed. Additional miscellaneous
small volumes of condensate and boiler blowdown combined after the pH adjustment. The wastewater
continues through an open channel to the lower 24 acre retention pond. As needed the retention pond is
set up to siphon wastewater via a manually adjusted flow to a flow weir box that discharges to Outfall
001.
The scrubber wastewater stream is treated with hydrogen peroxide to convert the hypochlorite to chloride.
The two reverse osmosis units provide filtration to remove metals by recycling the high total dissolved
solids waste stream and discharging the relatively clean water as wastewater.
The stormwater/wastewater that enters the stormwater conveyance channel enters a sedimentation pond,
continues to another polishing pond, and is then discharged from Outfall 004. A calibrated weir is
available to monitor Outfall 004 flow. If needed the sedimentation pond flow can be diverted to the lower
24 -acre retention pond.
The discharge from Outfall 004 continues down a concrete channel, mixes with Outfall 001, and
discharges into an unnamed tributary to First Creek.
2. Effluent Data Summary
Table 2. Effluent Data Summary — Outfall 001 (January 2013 through December 2017)
Parameter
Units
Average
Max
Min
Permit
Limit
Flow
MGD
0.43
0.582
0.081
0.615
BODS
mg/1
2.3
11.2
< 2
MA 30
DM 45
TSS
mg/1
4.04
< 12.5
< 2.5
MA 30
DM 45
DO
mg/1
9.87
15.3
6.4
DA > 5.0
pH
SU
7.9
8.6
6.9
6-9 SU
Conductivity
gmohs/cm
1246
1476
1023
—
Total Chloride
mg/1
131.9
198
< 0.05
—
Total Nitrogen
mg/1
0.4
0.9
0.024
—
Total Phosphorus
mg/1
< 0.05
< 0.05
< 0.05
—
MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA -Daily Average
Page 3 of 11

Table 3. Effluent Data Summary - Outfall 002 (April 2015 through July 2015) Not in permit
Parameter
Units
Average
Max
Min
Permit
Limit
Flow
GPM
2.11
2.8
0.8
-
BODS
mg/1
2.13
3
< 2
-
TSS
mg/1
14.9
26
5.3
-
DO
mg/1
7.5
8.9
6.5
-
pH
SU
6.8
7.3
6.6
-
Conductivity
gmohs/cm
742.1
831
376
Total Chloride
mg/1
33.9
41.1
15.3
-
Total Nitrogen
mg/l
0.47
1.3
0.024
-
Total Phosphorus
mg/l
0.06
0.08
< 0.05
-
Table 4. Effluent Data Summary - Outfall 004 (Jan 2013 through December 2017
Parameter
Units
Average
Max
Min
Permit
Limit
Flow
MGD
0.48
2.11
0.004
-
TSS
mg/l
3.9
21
< 2.5
-
pH
SU
7.5
8
6.6
6-9 SU
Conductivity
gmohs/cm
815.7
1069
400
-
Total Chloride
mg/l
25.9
35.8
4.4
-
3. 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 for this
permit action: Current permit does not require instream monitoring.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (Y/7V): NO
Name of Monitoring Coalition: NA
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4. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): There is no reported limit
violations from the facility during the past 5 years.
Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The facility passed 17 of 17 quarterly chronic toxicity tests.
Summarize the results from the most recent compliance inspection: The last facility inspection conducted
on April 06, 2018 reported that the facility was well maintained and operated in compliance.
5. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixin Zones
ones
In accordance with 15A NCAC 2B.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): 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.
Ifpermit limits are more stringent than TBELs, describe how limits were developed: Current effluent
limitations for BODS and TSS are based on Secondary Treatment Standards.
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.
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: Current permit
does not require monitoring for ammonia and TRC. There are no proposed changes.
Reasonable Potential Analysis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
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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/z 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 October 2012
and April 2017. 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:
Outfall 001
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: NA
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: Chloride.
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: Arsenic, Beryllium, Cadmium, Chromium, Copper, Cyanide, Fluoride, Lead,
Molybdenum, Nickel, Selenium, Silver, Zinc.
Outfall 004
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: NA
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: NA
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: Arsenic, Beryllium, Cadmium, Chloride, Chromium, Copper, Cyanide, Fluoride,
Lead, Molybdenum, Nickel, Selenium, Silver, Zinc.
If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals
Implementation Fact Sheet for freshwater/saltwater 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.
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
Page 6 of 11

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: Chronic WET limit at 78% effluent will continue 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/1
Table 5. Mercury Effluent Data Summary
Year
2015
# of Samples
1
Annual Average Conc. n /L
0.75
Maximum Conc., ng/L
0.75
TBEL, ng/L
47
WQBEL, ng/L
15.4
Describe proposed permit actions based on mercury evaluation: Since no annual average mercury
concentration exceeded the WQBEL, and no individual mercury sample exceeded the TBEL, no mercury
limit is required. Since mercury is not a pollutant of concern in this facility, MMP is not required.
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: NA
Page 7 of 11

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: NA
6. Technology -Based Effluent Limitations (TBELs)
Industrials (if not applicable, delete and skip to next Section)
Describe what this facility produces: Lithium compounds.
List the federal effluent limitations guideline (ELG) for this facility: No ELG is applicable for this
facility, limitations are based on Secondary Treatment Standards.
If the ELG is based on production or flow, document how the average production/flow value was
calculated: NA
For ELG limits, document the calculations used to develop TBEL limits: NA
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
7. 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: NA
8. Antibacksliding Review
Sections 402(0)(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
Page 8 of 11

9. 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, and therefore anti -
backsliding prohibitions would not be triggered by reductions in monitoring frequencies.
For instream monitoring, refer to Section 4
10. 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.
I LSummary of Proposed Permitting Actions:
Table 6. Current Permit Conditions and Proposed Changes (Outfall 001)
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
MA 0.615 MGD
No change
15A NCAC 2B .0505
BODS
MA 30 mg/l
No change
TBEL. Secondary treatment
DM 45 mg/l
standard.
TSS
MA 30 mg/l
No change
TBEL. Secondary treatment
DM 45 mg/l
standard.
DO
Not less than 5
No change
WQBEL. State WQ standard,
mg/1
15A NCAC 2B .0200
pH
6-9 SU
No change
WQBEL. State WQ standard,
15A NCAC 2B .0200
Conductivity
Monitor Monthly
No change
WQBEL. State WQ standard,
15A NCAC 2B .0200
Total Chloride
Monitor Quarterly
No change
Reasonable Potential Analysis
Total Nitrogen
Monitor Quarterly
No change
WQBEL. State WQ standard,
15A NCAC 2B .0200
Total Phosphorus
Monitor Quarterly
No change
WQBEL. State WQ standard,
15A NCAC 2B .0200
Toxicity Test
Chronic limit, 78%
No change
WQBEL. No toxics in toxic
effluent
amounts. 15A NCAC 2B.0200
and 15A NCAC 2B.0500
Electronic
No requirement
Add Electronic Reporting
In accordance with EPA
Reporting
Special Condition
Electronic Reporting Rule
2015.
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
Page 9 of 11

Table 7. Current Permit Conditions and Proposed Changes (Outfall 002 — New Outfall)
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
No requirement
Add Quarterly monitoring
15A NCAC 2B.0505
BODS
No requirement
Add Quarterly monitoring
15A NCAC 2B.0400
TSS
No requirement
Add Quarterly monitoring
15A NCAC 2B.0400
DO
No requirement
Not less than 5 mg/l
WQBEL. State WQ standard,
15A NCAC 2B.0200
Conductivity
Monitor monthly
15A NCAC 2B.0200
pH
No requirement
6 — 9 SU
WQBEL. State WQ standard,
15A NCAC 2B.0200
Total Chloride
Monitor quarterly
15A NCAC 2B.0200
Conductivity
No requirement
Add Quarterly monitoring
WQBEL. State WQ standard,
Potential Analysis
Oil and Grease
No requirement
15A NCAC 2B.0200
Total Chloride
No requirement
Add Quarterly monitoring
Reasonable Potential
discharge of boiler blowdown.
Analysis, pollutant of concern
Total Nitrogen
No requirement
Add Quarterly monitoring
WQBEL. State WQ standard,
NCAC 2B.0200
Electronic
No requirement
15A NCAC 213.0200
Total Phosphorus
No requirement
Add Quarterly monitoring
WQBEL. State WQ standard,
Electronic Reporting Rule
15A NCAC 2B.0200
Electronic
No requirement
Add Electronic Reporting
In accordance with EPA
Reporting
Special Condition
Electronic Reporting Rule
2015.
Table 8. Current Permit Conditions and Proposed Changes (Outfall 004)
Parameter
Current Permit
Proposed Change
ro
Basis for Condition/Change
Flow
Monitor monthly
No change
15A NCAC 2B.0505
TSS
Monitor monthly
No change
15A NCAC 2B.0400
pH
6 — 9 SU
No change
WQBEL. State WQ standard,
15A NCAC 2B.0200
Conductivity
Monitor monthly
No change
WQBEL. State WQ standard,
15A NCAC 2B.0200
Total Chloride
Monitor quarterly
Remove from permit
No RP in Reasonable
Potential Analysis
Oil and Grease
No requirement
Add quarterly monitoring
Pollutant of concern for
discharge of boiler blowdown.
State WQ standard, 15A
NCAC 2B.0200
Electronic
No requirement
Add Electronic Reporting
In accordance with EPA
Reporting
Special Condition
Electronic Reporting Rule
2015.
Stormwater section (Section B) in current permit is removed since wastewater discharged through Outfall
004 consists of stormwater, boiler blowdown, steam condensate and non -contact cooling water.
12. Public Notice Schedule:
Permit to Public Notice: 05/18/2018
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Per 15A NCAC 21-1.0109 &.0111, 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.
13. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): Yes
If Yes, list changes and their basis below:
• Permit expiration data has been extended to August 31, 2023 for a 5 -year permit cycle. A shorter
permit cycle may be issued during next permit renewal to match Division's Catawba River Basin
permitting schedule.
• Ownership of this facility has been changed from FMC Corporation to FMC Lithium USA
Corporation per the Permittee's request.
14. Fact Sheet Attachments (if applicable):
• RPA Spreadsheet Summary
• Dissolved Metals Implementation/Freshwater or Saltwater
• Mercury TMDL Evaluation
• Monitoring Report Violations
Page 11 of 11