NC0002305_Fact Sheet Final 2018_20180816

Fact Sheet
NPDES Permit No. NCOOO23O5
Permit Writer/Email Contact: Ron Berry, [e-mail]
Date: January 5, 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 Information
Facility Information
Applicant/Facility Name:
Lear Corporation (formerly Guilford Mills, Inc.)
Applicant Address:
1754 NC Hwy 903; Kenansville, NC 28349
Facility Address:
1754 NC Hwy 903; Kenansville, NC 28349
Permitted Flow:
1.5 MGD
Facility Type/Waste:
Industrial Treatment for combined 94% Industrial/6% WTP and
Domestic wastewater
Facility Class:
Class III
Treatment Units:
EQ basin, aeration basin, secondary clarification, flocculation, tertiary
clarification, chlorination, de -chlorination
Pretreatment Program (Y/N)
NA
County:
Duplin
Region
Wilmington
Briefly describe the proposed permitting action and facility background: Lear Corporation (formerly
Guilford Mills, LLC) submitted a renewal application August 3, 2016 for its Kenansville plant NPDES
Page 1 of 16

permit. The Kenansville plant conducts operations for knitting, weaving, dying, fire retardant lamination,
and other finishing process of synthetic fibers. All the generated wastewater from water softeners,
sanitary, and industrial sources are collected in an EQ basin and treated in the facility's wastewater
treatment system and then discharged to Outfall 001.
Currently this facility is classified under SIC codes 2258 and 2262 and is subject to 40 CFR 410 Textile
Mills Subpart E Knit Fabric Finishing which applies production based limits. A model of this segment of
the Cape Fear River Basin was completed in 1977 and assigned BOD, TSS, and DO minimum water
quality based criteria to this discharge. A 2007 STREAM model study was completed for this facility
discharge to better define BOD loading criteria to sustain instream WQBEL DO. MBAS monitoring was
added to the permit renewal in 2003 because of concerns about surfactants. There is no water quality
standard for MBAS in C class waters. Ammonia is added as part of their wastewater treatment process.
At the request of the US EPA, the Division asked the Permittee to provide additional information in
regard to the fire -retardant chemicals used in their textile manufacturing process. MSDS sheets were
provided and attached to the renewal application.
After further review of the production status and its impact to the draft permit TBEL by the Permittee, a
request was made to include in this permit renewal a second limitation page to allow for an anticipated
future production increase of 62,100 lb/day which was in line with historical production levels.
2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Outfall 001 — NE Cape Fear River
Stream Segment:
18-74-(1)
Stream Classification:
C, SW
Drainage Area (mi2):
326
Summer 7Q10 (cfs)
6.5
Winter 7Q 10 (cfs):
18
30Q2 (cfs):
-
Average Flow (cfs):
398
IWC (% effluent):
26.4
303(d) listed/parameter:
No
Subject to TMDL/parameter:
Yes- State wide mercury TMDL, requires submittal of one
mercury measurement at low detection level (1631E)
Subbasin/HUC:
03-06-22/02030007
USGS Topo Quad:
G27SE
Page 2 of 16

3. Effluent Data Summary
Effluent data is summarized below for the period January 2014 through April 2017.
Table. Effluent Data Summary
MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA -Daily Average
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/l 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
Page 3 of 16
Permit
Parameter
Units
Average
Max
Min
Limit
Flow
MGD
0.602
1.11
0.10
MA 1.5
BOD
lbs/day
31.3
105
5
DM 333.5
MA 166.8
COD
lbs/day
539.2
4,313
60
DM 5,336
MA 2,668
TSS
lbs/day
124.4
759
15
DM 1,454.1
MA 727.1
Not < 6.0
pH
Su
7.05
8.5
6.2
nor > 9.0
Fecal Coliform
#/100 ml
5.7
73
1
DM 400
MA 200
TRC
µg/I
20.7
22
17
DM 28
Sulfide
lbs/day
0.206
7.00
0.02
DM 13.3
MA 6.7
Total Phenols
lbs/day
0.073
0.44
0.01
DM 6.7
MA 3.3
Total Chromium
lbs/day
0.067
0.74
0.02
DM 6.7
MA 3.3
Oil and Grease
mg/I
5.39
34.0
5.0
DM 45.0MA
30.0
Total Cyanide
µg/I
8.8
30
5
DM 73
MA 19
DO
mg/I
6.85
8.5
6.0
DA not < 6
NH3-N
mg/I
1.33
21.8
< 0.2
Temperature
°C
20.7
30
11
Conductivity
umhos/cm
460.6
722
309
TN
mg/I
5.209
27.50
0.22
TP
mg/I
3.178
12.90
0.76
Total Copper
m/I
13.4
109
10
Total Zinc
m/I
29.1
92
10
MBAS
mg/I
0.106
0.42
0.04
MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA -Daily Average
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/l 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
Page 3 of 16

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: The current permit requires instream monitoring for dissolved oxygen, temperature, and
conductivity. Reviewed instream data in comparison to effluent date for recent 12 month span. The
review showed there was a positive influence on the downstream DO level. But this segment of the NE
Cape Fear River is classified Sw and the background DO did indicate Sw conditions. There were no
apparent impacts showed or significant differences between upstream and downstream samples for
temperature and conductivity. It was shown that the effluent conductivity consistently averaged 5 times
higher than the instream measurements. This draft permit will maintain the same instream monitoring
requirements.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): N
Name of Monitoring Coalition: NA
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): Since the last permit renewal
effective date September 2012 the facility had no limit violations but did incur one monitoring frequency
violation. No fines were assessed.
Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The facility passed 18 out of its last 19 quarterly chronic toxicity tests using ceriodaphnia
dubia with ChV limit of 27%. The required follow up chronic toxicity test conducted after the failed test
was passed exceeding the ChV limit.
Summarize the results from the most recent compliance inspection: The last facility inspection conducted
in 2016 reported no issues and the facility was well maintained and operated.
6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 213.0206, the following stream flows are used for dilution considerations
for development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 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 15,4 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
Page 4 of 16

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: Weekly ammonia
as nitrogen monitoring will be added to this permit to collect data for evaluation at the new permit
renewal.
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/2 detection limit for "less than" values; and 4) stream flows 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 January 2014
and August 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:
• 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: Cyanide
• 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: Copper, Zinc
• Application Effluent Pollutant Scan Review: An effluent pollutant scan was evaluated for
additional pollutants of concern. No parameters of concern were noted.
o 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 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.
Page 5 of 16

Toxicitv 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 an Industrial discharge with complex wastewater. A
chronic WET limit at 27% effluent concentration will continue with quarterly monitoring.
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. Mercury Effluent Data Summary
2017
# of Samples 1
Mercury Conc. ng/L < 0.5
Describe proposed permit actions based on mercury evaluation: No further action required since the
facility is < 2 MGD, the reported quantifiable levels of mercury is > 1 ng/1, and mercury is not a pollutant
of concern.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation
within this permit: NA
Other WOBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: New Chromium VI and
Chromium III water quality standards /EPA criteria were approved April 6, 2016 replacing the previous
Total Chromium standards. At this time, only Chromium III is hardness dependent. The WQBEL for
Chromium VI is more stringent than the equivalent Total Chromium TBEL while the WQBEL for
Chromium III is less stringent than the equivalent Total Chromium TBEL. However, no Chromium VI
data has been required to date and the majority of Total Chromium samples were < 10 gg/L.
Page 6 of 16

Table: Comparison Chromium Parameters WQBEL to TBEL
Parameter 1
Daily Maximum
Limit
Monthly Average Highest reported
Limit concentration
Chromium III - WQBEL
6,191.4 gg/L
917.2 g /L -
Chromium VI - WQBEL
53.2 g /L
41.8 gg/L -
Total Chromium — TBEL (1.5 MGD)
414.1 gg/L
207.0 gg/L 10.3 gg/L
1. Chromium III = Total Chromium — Chromium VI
Will add conditional Chromium VI monitoring in conjunction with Total Chromium monitoring to collect
Chromium VI data if Total Chromium exceeds 41.8 gg/L.
There is an aesthetic water quality standard for Total Phenols for class C streams but taking in account the
applicable 30Q2 dilution impact the WQBEL equivalent mass -based limit was less stringent than the
ELG limits.
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 122.47, and EPA May 2007 Memo: NA
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
7. Technology -Based Effluent Limitations (TBELs)
Industrials (if not applicable, delete and skip to next Section)
Describe what this facility produces: finished synthetic textile products
List the federal effluent limitations guideline (ELG) for this facility: 40 CFR 410.50 Textile Mills Subpart
E Knit Fabric Finishing (BPT, BAT).
If the ELG is based on production or flow, document how the average production/flow value was
calculated: This ELG is based on production. The annual average production based on production days
(lb/day) for the past 3 years (July 2013 — June 2016) was reported as 51,774 lb/day.
For ELG limits, document the calculations used to develop TBEL limits: The limits in Table I below are
based on proposed current production of 51,774 lb/day, the limits in Table II are based on proposed
future production of 62, 1 00lb/day, and both Tables applying the effluent guidelines in 410.50 Knit Fabric
Finishing.
Page 7 of 16

Table I: TBEL Development per 40 CFR 410.52(a)(b)/BPT & 410.53(a)/BAT - 51,774 lb/day
Pollutant
Daily Maximum
BPT
lb/1000 lb
Daily Maximum
Limit
lb /d
Monthly Average
BPT
lb/1000 lb
Monthly Average
Limit
lb/d
BOD5
5.0
258.87
2.5
129.44
COD (a)
60.0
3,106.44
30.0
1,553.22
COD (b)
20.0
1,035.48
10.0
517.74
Total COD
-
4,141.92
-
2,070.96
TSS
21.8
1,128.67
10.9
564.34
Sulfide
0.20
10.35
0.10
5.18
Phenols
0.10
5.18
0.05
2.59
Total
Chromium
0.10
5.18
0.05
2.59
pH
Not less than 6.0 S.U. nor greater than 9.0 S.U.
Table II: TBEL Development per 40 CFR 410.52(a)(b)/BPT & 410.53(a)/BAT - 62,100 lb/day
Pollutant
Daily Maximum
BPT
(lb/1000 lb)
Daily Maximum
Limit
(lb /d)
Monthly Average
BPT
(lb/1000 lb)
Monthly Average
Limit
(lb/d)
BODS
5.0
310.50
2.5
155.25
COD (a)
60.0
3,726.0
30.0
1,863.0
COD (b)
20.0
1,242.0
10.0
621.0
Total COD
-
4,968.0
-
2,484.0
TSS
21.8
1,353.78
10.9
676.89
Sulfide
0.20
12.42
0.10
6.21
Phenols
0.10
6.21
0.05
3.11
Total
Chromium
0.10
6.21
0.05
3.11
pH
Not less than 6.0 S.U. nor greater than 9.0 S.U.
If any limits are based on best professional judgement (BPJ), describe development: NA
Document any TBELs that are more stringent than WQBELs: Based on a Division approved STREAM
model study submitted in June 2007 using the facility average flow of 1.5 MGD, and the CBOD and
NBOD loading, it was demonstrated that a monthly average BOD loading of 24 mg/L summer and 30
mg/L winter was protective of the instream DO WQBEL of 5.0 mg/L. The current and proposed increased
production limitation conditions TBEL equivalent monthly average limit concentration are 12.41 mg/L
and 10.35 mg/L, which are more stringent than the model demonstrated BOD protective levels. All the
proposed TBEL TSS limits are more stringent than the 1977 model allocation of 2,071 lb/day daily
maximum and 1,033 lb/day month average.
Document any TBELs that are less stringent than previous permit: NA
Page 8 of 16

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: NA
9. 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
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(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
submit additional NPDES reports electronically. This permit contains the requirements for electronic
reporting, consistent with Federal requirements.
Page 9 of 16

12. Summary of Proposed Permitting Actions:
Table I: Current Permit Conditions and Proposed Changes 51,774 lb/day
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
MA 1.5 MGD
No change
15A NCAC 213 .0505
MA 166.8 Ib/day
MA 129.4 Ib/day
TBEL - 40 CFR 410.52(a), lower
BODS
DM 333.5 Ib/day
DM 258.9 Ib/day
production
MA 2,668 Ib/day
MA 2.,071.0 Ib/day
TBEL - 40 CFR 410.52(b) & 210.53(a),
COD
DM 5,336 Ib/day
DM 4,142.0 Ib/day
lower production
MA 727.1 Ib/day
MA 564.3 Ib/day
TBEL - 40 CFR 410.52(a), lower
TSS
DM 1,454.1 Ib/day
DM 1,128.7 Ib/day
production
Sulfide
MA 6.7 Ib/day
MA 5.2 Ib/day
TBEL - 40 CFR 210.53(a), lower
DM 13.3 Ib/day
DM 10.4 Ib/day
production
Total Phenols
MA 3.3 Ib/day
MA 2.6 Ib/day
TBEL - 40 CFR 210.53(a), lower
DM 6.7 Ib/day
DM 5.2 Ib/day
production
Total Chromium
MA 3.3 Ib/day
MA 2.6 Ib/day
TBEL - 40 CFR 210.53(a), lower
DM 6.7 Ib/day
DM 5.2 Ib/day
production
Add conditional
BPJ - provide Chromium VI data if
Chromium VI
No requirement
detected > 41.8 µg/L as Total
monitoring
Chromium for next renewal
Fecal coliform
MA 200 /100ml
No change
WQBEL - State WQ standard, 15A
DM 400 /100ml
NCAC 2B.0211
TRC
DM 28 µg/l_
No Change
WQBEL - State WQ standard, 15A
NCAC 213.0211
MA 19.0 pg/I
MA 26.0 µg/I
(technical correction)
WQBEL -State WQ standard, 15A
Total Cyanide
DM 73.2 µg/I
Increase monitoring
NCAC 2B.0211 Pollutant
to weekly
of concern BPJ increase monitoring
DO
Daily Average > 6.0 mg/I
No change
WQBEL - State approved river
model
pH
6 .0 - 9.0 SU
No change
TBEL - 40 CFR 410.52(a)
Oil & Grease
MA 30.0 µg/I
No change
BPJ - concern over industrial
DM 45.0 µg/I
sources
NH3-N
No requirement
Add weekly
15A NCAC 02B.0400 et seq., 15A
monitoring
NCAC 02B 0.500 et seq.
Total Nitrogen
Monitor Monthly
No change
Discharge to Cape Fear River Basin -
15A NCAC 213.0500
Total Phosphorus
Monitor Monthly
No change
Discharge to Cape Fear River Basin
- 15A NCAC 2B.0500
Conductivity
Monitor 3/week
No change
15A NCAC 02B.0500
Temperature
Monitor 3/Week
No change
15A NCAC 02B.0500
MBAS
Monitor Quarterly
Remove
BPJ - No longer pollutant of interest
Total Copper
Monitor Quarterly
Remove
No RP to exceed WQBEL, predicted
level less than 50% of WQBEL
Total Zinc
Monitor Quarterly
Remove
No RP to exceed WQBEL, predicted
level less than 50/ of WQBEL
Page 10 of 16

MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
Table II: Proposed Changes for Increased Production — 62,100 lb/day'
Parameter
Chronic limit, 27%
62,100 lb/day
WQBEL -. No toxics in toxic
Toxicity Test
MA 129.4 Ib/day
No change
amounts. 15A NCAC 213.0200 and
BODS
effluent
DM 310.5 Ib/day
production
COD
MA 2,071.0 Ib/day
MA 2,484.0 Ib/day
15A NCAC 213.0500
Effluent Pollutant
DM 4,142.0 Ib/day
DM 4,968.0 Ib/day
increased production
TSS
Once every 5 years
No Change
40 CFR 122
Scan
DM 1,128.7 Ib/day
DM 1,353.8 Ib/day
production
Sulfide
MA 5.2 Ib/day
Add Electronic
TBEL - 40 CFR 210.53(a), increased
Electronic
DM 10.4 Ib/day
DM 12.4 Ib/day
In accordance with EPA Electronic
Total Phenols
No requirement
Reporting Special
TBEL - 40 CFR 210.53(a), increased
Reporting
DM 5.2 Ib/day
DM 6.2 Ib/day
Reporting Rule 2015.
Total Chromium
MA 2.6 Ib/day
Condition
TBEL - 40 CFR 210.53(a), increased
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
Table II: Proposed Changes for Increased Production — 62,100 lb/day'
Parameter
51,774 lb/day
62,100 lb/day
Basis for Condition/Change
MA 129.4 Ib/day
MA 155.3 Ib/day
TBEL - 40 CFR 410.52(a), increased
BODS
DM 258.9 Ib/day
DM 310.5 Ib/day
production
COD
MA 2,071.0 Ib/day
MA 2,484.0 Ib/day
TBEL - 40 CFR 410.52(b) & 210.53(a),
DM 4,142.0 Ib/day
DM 4,968.0 Ib/day
increased production
TSS
MA 564.3 Ib/day
MA 676.9 Ib/day
TBEL - 40 CFR 410.52(a), increased
DM 1,128.7 Ib/day
DM 1,353.8 Ib/day
production
Sulfide
MA 5.2 Ib/day
MA 6.2 Ib/day
TBEL - 40 CFR 210.53(a), increased
DM 10.4 Ib/day
DM 12.4 Ib/day
production
Total Phenols
MA 2.6 Ib/day
MA 3.1 Ib/day
TBEL - 40 CFR 210.53(a), increased
DM 5.2 Ib/day
DM 6.2 Ib/day
production
Total Chromium
MA 2.6 Ib/day
MA 3.1 Ib/day
TBEL - 40 CFR 210.53(a), increased
DM 5.2 Ib/day
DM 6.2 Ib/day
production
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
Note 1: A special condition will be added that allows activation of the higher 62,100 lb/day production limits
once the calendar year average production exceeds 62,100 lbs/day. All other monitoring requirements for
51,774 lb/day will continue unchanged for 62,1001b/day.
13. Public Notice Schedule:
Permit to Public Notice: 1/9/18
Per 15A NCAC 2H .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.
Tentative Issue Date for Final: 3/1/18
14. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): TBD
If Yes, list changes and their basis below: TBD
Page 11 of 16

15. Fact Sheet Attachments (if applicable):
• RPA Spreadsheet Summary
• PPA Review Summary
• Dissolved Metals Implementation/Freshwater or Saltwater
Date: January 5, 2018
Permit Writer:
Page 12 of 16

NPDES Implementation 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 Q ality Standards/A uatic Life Protection
Parameter
Acute FW, gg/1
(Dissolved)
Chronic FW, gg/1
(Dissolved)
Acute SW, gg/1
(Dissolved)
Chronic SW, gg/l
(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/1 for human health protection; cyanide at 5 gg/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, gg/l
Cadmium, Acute
WER*{1.136672-[ln hardness] (0.04183 8)) • e^10.9151 [ln hardness] -3.1485}
Cadmium, Acute Trout waters
WER*{1.136672-[ln hardness] (0.04183 8)) • e^{0.9151[ln hardness] -3.6236}
Cadmium, Chronic
WER*{1.101672-[ln hardness] (0.04183 8)) • e^{0.7998[ln hardness] -4.4451}
Chromium II1, Acute
WER*0.316 e^{0.8190[ln hardness]+3.7256}
Chromium II1, 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-[1n hardness] (0. 145712)) • e^{1.273[ln hardness] -1.460}
Lead, Chronic
WER*{1.46203-[1n hardness] (0. 145712)) • e^{1.273[ln hardness] -4.705}
Nickel, Acute
WER*0.998 e^{0.8460[ln hardness]+2.255}
Nickel, Chronic
WER*0.997 e^{0.8460[ln hardness]+0.0584}
Page 13 of 16

Silver, Acute
WER*0.85 • e^ t 1.72[ln hardness] -6.59}
Silver, Chronic
Not applicable
Zinc, Acute
WER*0.978 eAt0.8473[ln hardness]+0.884}
Zinc, Chronic
WER*0.986 eAt0.8473[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.
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 14 of 16

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, mg2) 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.
EPA default partition coefficients or the "Fraction Dissolved" converts the value for
dissolved metal at laboratory conditions to total recoverable metal at in -stream
ambient conditions. This factor is calculated using the linear partition coefficients
found in The Metals Translator: Guidance for Calculating a Total Recoverable
Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996) and the
equation:
Cdiss = 1
Ctotal 1 + { [Kpo] [SS(1+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 = (s7Q 10 + Qw) (Cwgs) — (s7Q 10) (Cb)
Qw
Where: Ca = allowable effluent concentration (gg/L or mg/L)
Cwqs = NC Water Quality Standard or federal criteria (gg/L or mg/L)
Cb = background concentration: assume zero for all toxicants except NH3* (gg/L or mg/L)
Qw = permitted effluent flow (cfs, match s7Q 10)
Page 15 of 16

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:
1Q10 = 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
6. 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)]
62.5
Average of 5 Samples
Average Upstream Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
59.2
Average of 5 Samples
7Q10 summer (cfs)
6.5
USGS data
1Q10 (cfs)
5.41
Calculated by RPA spreadsheet
Permitted Flow (MGD)
1.5
Permit renewal application
Page 16 of 16